ML20211Q408
| ML20211Q408 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 02/11/1987 |
| From: | Baird J, Yandell L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20211Q386 | List: |
| References | |
| 50-498-86-35, 50-499-86-35, NUDOCS 8703030083 | |
| Download: ML20211Q408 (75) | |
See also: IR 05000498/1986035
Text
APPENDIX C-
U.S. NUCLEAR REGULATORY COMISSION
' REGION IV
NRC Inspection Reports:
50-498/86-35
Construction Permits:
CPPR-128
50-499/86-35
CPPR-129
Dockets:
50-498
50-499
Licensee:
Houston Lighting & Power Company (HL&P)
P. O. Box 1700
Houston, Texas
77001
Facility Name:
South Texas Project (STP), Units 1 and 2
Inspection At:
South Texas Project, Matagorda County, Texas
Inspection Conducted:
December 1-12, 1986
Inspector:
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J.VB. Baird, RIV NRC (Team Leader)
Date
Other Inspectors:
C. Hackney, RIV NRC
C. Wisner, RIV NRC
R. Hogan, OIE NRC
W. Harrington, PNL, Battelle
G. Wehmann, EG&G
G. Bryan, Comex Corporation
F. Carlson, Comex Corporation
ChA
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Approved:
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L. A. Yandell, Chief, Emergency Preparedness
Date
and Safeguards Programs Section
Inspection Summary
Inspection Conducted December 1-12, 1986 (Reports 50-498/86-35; 50-499/86-35)
Areas Inspected:
Special, announced emergency preparedness implementation
inspection.
This included assessment of the licensee's emergency preparedness
program in the areas of administration; emergency organization; training;
emergency facilities and equipment; procedures; coordination with offsite
groups; and drills, exercises, and walkthroughs.
0703030003 070226
ADOCK 05000499
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' Resul ts:
In the seven areas inspected, no violations or deviations were
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identified.
Seventy-five emergency preparedness deficiencies were identified.
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CONTENTS *
P_ag,!!
INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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SUMMARY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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1.0 ADMINISTRATION . . . . . . . . . . . . . . . . . . . . . . . . . . . .
11
1.1-1.4
Responsibility Assigned, Authority, Coordination,
Selection, and Qualification . . . . . . . . . . . . . . . .
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2.0 EMERGENCY ORGANIZATION. . . . . . . . . . . . . . . . . . . . . . . .
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2.1-2.2
Onsite Organization and Augmentation Organization . . . . .
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3.0 TRAINING. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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3.1 Program Establishment. . . . . . . . . . . . . . . . . . . . . .
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3.2 Program Implementation . . . . . . . . . . . . . . . . . . . . .
16
4.0 EMERGENCY FACILITIES AND EQUIPMENT. . . . . . . . . . . . . . . . . .
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4.1 Emergency Facilities . . . . . . . . . . . . . . . . . . . . . .
18
4.1.1 Assessment Facilities . . . . . . . . . . . . . . . . . .
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4.1.1.1
Control Room . . . . . . . . . . . . . . . . . .
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4.1.1.2
Technical Support Center . . . . . . . . . . . .
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4.1.1.3
Operations Support Center. . . . . . . . . . . .
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4.1.1.4
Emergency Operations Center. . . . . . . . . . .
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4.1.1. 5 Post-Accident Coolant Sampling and Analysis. . .
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4.1.1.6
Post-Accident Containment Air Sampling &
Analysis . . . . . . . . . . . . . . . . . . . .
27
4.1.1.7
Post-Accident Gas & Particulate Sampling &
Analysis . . . . . . . . . . . . . . . . . . . .
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4.1.1. 8 Post-Accident Liquid Effluent Sampling and
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Analysis . . . . . . . . . . . . . . . . . . . .
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I4.1.2 Protective Facilities . . . . . . . . . . . . . . . . . .
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4.>1.2.1' Assembly / Reassembly Areas. . . . . . . . . . . .
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4.1.h.2 _ Medical Treatment Facilities . . . . . . . . . .
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-4.1.2.3 ' Decontamination Facilities . . . . . . . . . . .
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4.1.3. Expanded; Support Facilities . . . . . . . . . . . . . . .
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4.1.4 ' News Center . . . . . . . . . . . . . . . . . . . . . . .
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4.2 Emergency Equipment. . . . . . . . . . . . . . . . . . . . . . .
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4.2.1 Assessment Equipment. . . . . . . . . . . . . . . . . . .
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4.2.1.3
Assessment Equipment . . . . . . . . . . . . . .
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4.2.2- Protective Equipment. . . . . . . . . . . . . . . . . . .
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4.2.2.1
Respiratory Protection . . . . . . . . . . . . .
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4.2.2.2
Protective Clothing. . . . . . . . . . . . . . .
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4.2.3 Communications. . . . . . . . . . . . . . . . . . . . . .
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4.2.4 Damage Control / Corrective Action and Maintenance
Equipment . . . . . . . . . . . . . . . . . . . . . . . .
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4.2.5 Reserve Emergency Supplies and Equipment. . . . . . . . . 40
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4.2.6 Transportation. . . . . . . . . . . . . . . . . . . . . .
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5.0 PROCEDURES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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5.1 General Content and Format . ..................41
5.2 Emergency, Alarm, and Abnormal Occurrence Procedures . . . . . .
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5.3 Implementing Instructions. . . . . . . . . . . . . . . . . . . .
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5.4 Implementing Procedures. . . . . . . . . . . . . . . . . . . . .
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5.4.1 Noti fications . . . . . . . . . . . . . . . . . . . . . .
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5.4.2 Assessment Actions. . . . . . . . . . . . . . . . . . . .
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5.4.2.1
Offsite Radiological Surveys . . . . . . . . . .
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5.4.2.2
Onsite (out-of plant) Radiological Surveys . . .
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5.4.3 Protecti ve Actions. . . . . . . . . . . . . . . . . . . .
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5.4.3.2
Evacuation of Owner-Controlled Areas . . . . . .
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5.4.3.3
Personnel Accountability . . . . . . . . . . . .
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5.4.3.4
Personnel Monitoring and Decontamination . . . .
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5.4.4 Security During Emergencies . . . . . . . . . . . . . . .
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5.4.5
Repair / Corrective Actions . . . . . . . . . . . . . . . .
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5.4.6 Recovery. . . . . . . . . . . . . . . . . . . . . . . . .
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5.4.7 Public Information. . . . . . . . . . . . . . . . . . . .
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5.5 Supplementary Procedures . . . . . . . . . . . . . . . . . . . .
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5.5.2 Drills and Exercises. . . . . . . . . . . . . . . . . . .
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5.5.3
Review, Revision, and Distribution of Emergency
' Plan and Procedures . . . . . . . . . . . . . . . . . . .
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5.5.4 Audits of Emergency Preparedness. . . . . . . . . . . . .
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6.0 COORDINATION WITH OFFSITE GROUPS. . . . . . . . . . . . . . . . . . .
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6.1 O f f site Agenci es . . . . . . . . . . . . . . . . . . . . . . . .
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6.1.1 Hospitals . . . . . . . . . . . . . . . . . . . . . . . .
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6.1.2 Fire Support. . .....................63
6.1.3 Matagorda County. . . . . . . . . . . . . . . . . . . . .
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6.2 Gene ral Publ i c . . . . . . . . . . . . . . . . . . . . . . . . .
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6.3 News. Media . . . . . . . . . . . . . . . . . . . . . . . . . . .
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7.0 DRILLS, EXERCISES, AND WALKTHROUGHS . . . . . . . . . . . . . . . . .
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~ 7.1 Program Implementation . . . . . . . . . . . . . . . . . . . . .
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7.2 Wal kthrough Observation. . . . . . . . . . . . . . . . . . . . .
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Emergency Detection, Classification, and
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Notification. . . . . . . . . . . . . . . . . . . .
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7.2.4-7.2.8
Dose Calculations and Emergency Sampling and
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Analysis. . . . . . . . . . . . . . . . . . . . . .
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8.0 EXIT INTERVIEW. . . . . . * *
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9.0 PERSONS CONTACTED .
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tted from the numerical sequence were not reviewed as part of the
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INTRODUCTION
The purpose of this special preoperational inspection was to perform a
comprehensive evaluation of the HL&P emergency preparedness program and
determine if there was reasonable assurance that the emergency plan could be
implemented in the event of an emergency.
This inspection also included an
evaluation of the adequacy and effectiveness of areas for which explicit
regulatory requirements may not currently exist.
The inspection effort was
directed towards evaluating HL&P capability and performance rather than the
identification of specific violations of NRC requirements.
The inspection scope and findings were summarized on December 12, 1986, with
those persons indicated in Section 9.0 of this report.
See Section 8.0 of this
report for details of the exit meeting.
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SUMMARY
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The NRC inspectors reviewed the HL&P emergency plan and emergency plan
implementing procedures, examined facilities and equipment, and conducted
' interviews with'STP Station and offsite personnel. The purpose of this
" preoperational inspection was to determine the adequacy of HL&P's emergency
response capabilities.
Seven areas were inspected:
administration; emergency
organization; training; emergency facilities and equipment; procedures;
coordination with offsite groups; and drills, exercises, and walkthroughs.
The
' status of each of these areas is summarized as follows .
1. 0 Administration
The Manager, Emergency Preparedness Department, a new position established
just prior to this inspection, was responsible for emergency preparedness
' for STP.
The Manager, Emergency Preparedness Department reported to the
Vice President, Nuclear Plant Operations, who reported to the Board of
Directors through the Group Vice President.
The Manager, Emergency
Preparedness Department was at the same organizational level as the Plant
Manager, and was responsible for all onsite and offsite emergency
preparedness.
The Emergency Preparedness Department consisted of a
Manager, Support Division; Manager, Readiness Division; and four emergency
preparedness staff.
No deficiencies were identified in this area.
2.0 Emergency Organization
The emergency organizations were defined for both the on-shift and
emergency response organizations.
The NRC inspectors determined that
provisions had been made for an emergency coordinator to be available at
all times, with authority and responsibility to initiate emergency actions
within the provisions of the emergency plan.
Deficiencies were identified
in the identification and assignment of the emergency organization staff
below the manager level, and in the demonstration of the timely
augmentation of the onshift organization.
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3.0 Training
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The STP emergency preparedness and general employee training programs were
established and ongoing.
Neither program had achieved full effectiveness,
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however, at the time of this inspection.
Continuing changes to the
emergency preparedness program were requiring constant retraining of the
emergency response personnel, some of whom had not completed the original
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phase of the emergency plan training. General employee training was
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incomplete for many persons who were to have access to the protected area
and some of the emergency response personnel.
Training for offsite
emergency response personnel had been commenced but was in need of
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upgrading to achieve a satisfactory program.
The NRC inspectors noted
that emergency plan training was not always conducted to the standards of
other STP training.
The failure to complete required training was
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identified as a deficiency.
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4.0 Emergency Facilities and Equipment
TThe'NRC inspectors noted that facilities and equipment dedicated to
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support of emergency-response activities were in various stages of
1completion. Although most of the necessary equipment had been identified,
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significant items'such as data acquisition and analysis equipment,
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non'-radiation' process monitors, heating and ventilation systems, power
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distribution, radiation monitoring, and communications equipment were
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incomplete. .The post-accident and effluent monitoring and analysis
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equipment was installed but not operational.
Emergency kits and lockers
were not fully equipped and necessary items such as respiratory protection
and protective clothing were not sufficiently deployed.
The smooth
operation of the operational support center was identified as a concern
and the control room requirements for emergency supplies had not been
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identified. Additionally, HL&P had not completed the prompt public
notification system.
Multiple deficiencies were identified in regard to
the above observations.
5.0 Procedures
The NRC inspectors determined that the emergency plan implementing
procedures were not always consistent with the plan which they were
implementing.
In many cases, normal STP station operating procedures used
to implement the emergency plan and support the emergency plan
implementing procedures failed to adequately address emergency conditions.
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A significant number of procedures were undergoing revision and could not
be reviewed by the NRC inspectors.
Many areas were identified in which
there were either no implementing procedures or the procedures were
inadequate. Multiple deficiencies were identified in regard to the status
of STP emergency plan implementing procedures.
6.0 Coordination With Offsite Groups
The NRC inspectors determined that training for all offsite groups had
been initiated but not completed in an adequate manner.
Coordination
meeting and training had been conducted for the medical facilities;
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however, some coordination remained to be accomplished.
Training for fire
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fighting support personnel had not been completed.
The NRC inspectors
noted that plans for a media information center were essentially
completed.
The public information brochure in the form of a calendar had
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been prepared but had not been distributed to residents in the plume
exposure emergency planning zone, and the transient public information had
not been disseminated.
Several deficiencies were identified in regard to
the above observations.
7.0 Orills, Exercises, and Walkthroughs
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The NRC inspectors noted that no formal program had been established to
control drills and exercises.
However, drills were being conducted in
preparation for the graded exercise scheduled to be conducted in
April 1987.
During the inspection two operations crews actions were
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observed in a walkthrough and an onsite drill. Weaknesses were observed
in classification, notification of state and local agencies, and emergency
responsibilities.
Insufficient training, equipment, and procedures
existed at the time of the inspection to perform walkthroughs on dose
assessment and field monitoring.
The NRC inspectors observed the staffing
and operation of the emergency response facilities during an onsite drill.
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Weaknesses were noted in communications, radiological protection,
information flow to the Media Information Center, command and control, and
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several other areas.
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Conclusion
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HL&P had generally addressed the major response elements of.the emergency
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preparedness program; however, often in an incomplete-and fragmented
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fashion.
Many facilities and equipment were found to be incomplete or
General employee and emergency response organization
personnel training had not been completed.
Insufficient and generally
inadequate procedures had been provided to implement the emergency plan.
Management attention to emergency preparedness had been increased
significantly by recent organizational changes but was not effective yet
in effecting program completion in a satisfactory manner.
Provisions for
providing emergency information to and warning the public had not been
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completed.
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Based on the above observations, the NRC inspectors concluded that the
status of the HL&P emergency preparedness cannot be determined to be
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adequate until these areas are satisfactorily addressed.
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DETAILS
1. 0 ADMINI TRATION
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1.4 Responsibility Assigned, Authority, Ooordination, Selection, and
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The administration of Houston Lighting and Power Company's (HL&P)
emergency preparedness 7 program was reviewed with respect to the
requirements of 10 CFR 50.47(b)(1) and (16); 10 CFR 50, Appendix E,
paragraph IV.A; and the criteria contained in NUREG-0654, Sections II.A
and P.
NUREG-0654 has been endorsed by Regulatory Guide 1.101,
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Revision 2.
7ne NRC inspector reviewed Revision 3 of the South fexas PFoject
Generating Station Emergency Plan (hereafter referred to as the Plan) and
discussed the administration of HL&P's ' emergency preparedness program with
the Manager, Emergency Preparedness Department (EPD).
The Manager, EPD
has the responsibility for emergency preparedntss for the South Texas
Project (STP).
The Manager, EPD reports to the Vice President, Nuclear
Plant Operations, who reports to the Board of Directors through the Group
Vice President, Nuclear.
The organization and chain of command indicated
that the Manager, EPD has sufficient authority and management support for
emergency preparedness activities.
At the time of this review, the Vice
President, Nuclear Plant Operations position was unfilled.
In the
interim, ths Manager, EPD reported directly to Group Vice President,
Nuclear..
TheEPD,whNhhadbeencreatedonlyrecently,consistedofaManager,
Support Division; Manager, Readiness Division; and for emergency
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preparedness staff personnel.
Detailed job descriptions had been
developed for the three key positions: however, the nuuber of emergency
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preparedness staff positionr, had not been determinsd yet.
All of the
emergency preparedness functions that are described in the Plan had been
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assigned to specific positions in the EPD.
The job description for the' Manager, EPD included the responsibility for
coordination with'other HL&P Departments and external organizations for
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development of the Plan and atpropriate procedures to govern emergency
re'sponse' acth i ties.
Coordination with training, public relations,
security, nuclear plant operations licensing, quality assurance and the
Plant Operations Review Committee (PORC) was ongoing on an "as needed"
basis.
The administrative mechanism for assuring the EPD interface,s with
other HL&P departments was under development by the Manager, EPD.
The
Plant Manag @ and POEC review and approve revisions to the Plan and
emergency plan implementing procedures.
In addition, administrative
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provisions were in place to distribute procedures to the cognizant HL&P
departments for comments prior to transmittal to PORC or the Plant
Manager.
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From discussions with HL&P representatives and a review of position
descriptions for the Managers of the EPD and two EPD divisions, the NRC
inspector verified that selection and qualification criteria had recently
been issued with the creation of the EPD.
The scope of duties and
responsibilities were appropriately limited to emergency preparedness and
the division of responsibilities was balanced to support the overall
department responsibilities.
The NRC inspector determined that the managers assigned to the positions
described above met the criteria established in the position descriptions.
The person assigned interim Manager, Readiness Division was a contractor
employee who had been involved in exercise scenario development at STP for
some time.
Although the new EPD appeared to be appropriately established,
trained, and staffed to fulfill programmatic needs, the NRC inspectors
were not able to fully assess the effectiveness of the staff and
organization due to the short time that the new EPD organizational
structure had been in place.
The following is an observation the NRC inspectors call to the licensee's
attention.
This. observation is neither a violation nor an unresolved
item.
This item is recommended for licensee consideration for
improvement, but has no specific regulatory requirement.
Provide an administrative mechanism for direct interface between the
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emergency preparedness staff and other HL&P departments or changes to
organization, personnel, procedures, and equipment.
Based on the above findings, no deficiencies were identified in this area.
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2.0 EMERGENCY ORGANIZATION
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2.2 Onsite and Augmentation Organization
The onshift and augmentation organizations were reviewed with respect to
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requirements of 10 CFR 50.47(b)(1) and 10 CFR 50, Appendix E,
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paragraph IV.A.; and the criteria in NUREG-0654, Sections II.A and B.
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The on-shift and Station emergency response organizations were described
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in the Plan, Section C.
The duties and responsibilities of key emergency
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organization team members were described in the Plan.
Neither the Plan
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nor the implementing procedures described duties and responsibilities for
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team members below the manager level.
HL&P representatives stated that
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the duties for all Station emergency response organization positions were
being developed and would be included in the Plan and implementing
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procedures in future revisions.
Job descriptions for all normal personnei
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positic9s were being changed to include emergency response organization
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assignments. HL&P' representatives stated that there was no administrative
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procedure developed.to notify personnel to their assignment to the
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emergency response organization nor to notify the Training Department of
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the names and assigned positions of the personnel.
It was stated that
personnel would not be listed on the call-out roster for emergencies until
they had received the required training; however, there was no procedure
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for assuring that assigned personnel had received all of the required
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training, and'could be listed on the call-out roster.
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It.was determined.that provisions had been made to ensure that an
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- emergency coordinator (Emergency Director) would be available onsite at
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all times' and would have the-responsibility and authority to initiate
emergency actions withia the provisions of the Plan, including the
exchange of information with authorities responsible for coordinating and
implementing offsite emergency measures.
A line of succession had been
established for the Emergency Director and other key members of the
emergency response organization.
The NRC inspectors determined that HL&P had adequately provided manager
assignments of personnel to all necessary emergency response functional
a reas.' Assignments of personnel to staff and support positions had not
been made since all of the necessary staff and support positions had not
been identified.
The Plan contained a list, by emergency response
facility, of emergency response organization manager positions and
individuals assigned to these positions by normal position titles. The
Plan was being revised to include all of the necessary emergency response
organization staff and support position assignments.
The NRC inspectors determined that augmentation of the on-shift staff
would be accomplished by STP personnel living within the vicinity of the
Station, except for staffing of the Media Information Center (MIC) which
would be by personnel from the HL&P Houston office.
An augmentation
survey had been conducted to determine response times for some personnel.
The response times surveyed did not include all emergency response
personnel and only included door-to-door travel time.
Based on the above findings, the following deficiencies must be corrected
to achieve an acceptable progranj
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Staff and support positions in the emergency response organization
below the manager level had not been identified, and duties and
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responsibilities for these positions had not been developed.
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(498/8635-001; 499/8635-001)
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A method had not been developed to notify personnel of their
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assignment to an emergency response organization position, identify
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names to Training, and include the names of properly qualified
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individuals on the call-out roster.
(498/8635-002; 499/8635-002)
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An unannounced augmentation drill had not been conducted to provide
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reasonable assurance that augmentation times in Table C-2 of the Plan
can be met.
(498/8635-003; 499/8635-003)
3.0 TRAINING
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3.1 Program Establishment
The area of training was reviewed with respect to the requirements of
10 CFR 50.47(b)(15) and (16); 10 CFR 50, Appendix E, paragraph IV.F; and
the criteria in NUREG-0654, Sections II.G and II.0.
The emergency preparedness training program was described in the STP
Interdepartmental Procedure IP-8.21, Revision 1, dated July 1, 1986, and
the Plan, Revision 3, Section M.
Both were essentially the same, and
described training requirements for both onsite and offsite personnel.
The NRC inspector noted that two were revised or updated independently;
therefore, the established system required dual revisions for necessary
changes and an opportunity for inconsistencies.
Further, review of
training records revealed that another specialized course for status board
keepers (EPT012) had been introduced to the system but not documented in
either procedure.
The NRC inspector noted that personnel were appointed emergency response
responsibilities according to job assessment.
Responsibility for
providing training resided in the Training Department.
Emergency
preparedness training was augmented by the emergency preparedness staff.
Each division manager was responsible to assure each person assigned
emergency responsibilities attended required training.
A program for general employee training (GET) had been established.
Three
categories or levels of training were presentea as Category I, II, and
III.
Respiratory training for onsite personnel was also provided.
GET,
Category I, was utilized for emergency preparedness training where
specialized training was nct required for assignment to the emergency
response organization.
Specialist emergency plan training was provided in
three phases of training as follows:
Emergency plan familiarization module.
Emergency plan implementing procedure familiarization module.
Specialized training (assigned by responsibility matrix).
The Plan and procedures did not define use of training modules for two of
the three phases of the training program; namely, the modules for
emergency plan familiarization and the module for emergency plan
implementing procedure (EPIP) familiarization.
These were not included or
referenced in the matrices for training content.
The matrix for assigning specialized training referred to 8 modules of
emergency plan training which would be presented in detailed or
abbreviated form, depending on the group being addressed.
Groupings of
-
_
_
_
_
15
emergency response organization personnel were assigned varying
combinations of the modules from all modules abbreviated for
administrative services and media relations positions.
The NRC inspector noted that inconsistencies' existed between the
description of topics to be covered (M.5.1 through 8, pages 4 and 5) and
the lesson identifier of the training matrix (Table M-1, page 8, lessons 1
)
.through 8 .
For example, the NRC inspector noted that fire and personnel
emergencies were included in the matrix lessons but not in the topics to
be covered.
The NRC inspector noted that training modules did not discuss " hands-on"
and "walkthrough" training requirements.
The training for emergency
response facilities and equipment was apparently done in the classroom
without seeing the facilities and equipment.
Training for offsite emergency response personnel was established by the
EPD and documented in Plant Procedures Manual Department
Procedure OEPP02-ZA-0005, Revision 0, dated September 12, 1986.
This
procedure established requirements for each offsite participant's training
by a matrix or required courses by position.
A handout had been prepared
for the task entitled "Matagorda County Radiological Emergency Response
Training i.;ourse." This training was intended for all offsite participants
except that subcontracted to the Radiation Management Corporation (RMC),
which was training offsite medical staff, ambulance (emergency medical
specialists) in the handling and treatment of radioactivity contamination
and injured patients.
Although sessions had been conducted by RMC,
records had not been made available to the licensee and were not available
for review by the NRC inspector.
The lesson plan for offsite training was
" built-in" to the table of contents of the handout.
Although there was
some utility to this practice, it provided no date effective or other
authorizing information.
Also, that method provided no instruction
information or notes for course presentation.
The same basic offsite training was given all offsite emergency response
personnel, regardless of their speciality or involvement.
No procedure
was provided for interfacing offsite emergency personnel (ambulance and
- '
fire fighters) with the STP plant personnel.
This should include where to
go on arrival and provisions for security and escort to the scene of the
,
emergency.
,
Trainers for Plan training were provided from the EPD staff and the Staff
-Training Division'of the STP Nuclear Training Department.
Members of the
EPD had been trained and certified as provisional instructors by the
Nuclear Training Department.
'
Training procedures included provisions for both initial training and
retraining on an annual basis.
The NRC inspector noted that no provisions
!
-were made for changes to the emergency preparedness program which would
require retraining or refresher training between annual retraining
sessions. '
{
.
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3
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. , - - - -
16
The NRC inspector noted that personnel were assigned to the emergency
response organization as a function of their regular job title.
A
separate unofficial roster was developed by the EPD which listed the
primary, backup and alternate for each emergency response position by
name.
These were not consistent in every case.
The following are observations the NRC inspectors call to the licensee's
attention.
These observations are neither violations nor unresolved
items.
These items are recommended for licensee consideration for
improvement, but have no specific regulatory requirement.
-
A lesson plan for offsite training should be prepared and controlled
similar to the onsite training plans.
-
A formal record keeping system should be established for control of
offsite training and retraining.
Provisions should be made in procedures for special training to
-
accommodate significant changes in the emergency preparedness
program.
-
Emergency plan training modules should provide for hands-on and
walkthrough training utilizing emergency response facilities and
equipment.
3.2 Program Implementation
The area of program implementation was reviewed with respect to the
requirements of 10 CFR 50.47(b)(15) and (16); 10 CFR 50, Appendix E,
Paragraph IV.F; and the criteria in NUREG-0654, Sections II.G and II.0.
The NRC inspector noted that GET commenced March 3, 1986, for Category I,
October 8, 1986, for Category II, and March 24, 1986, for Category III, as
documented in individual training records.
Although sessions had been
provided weekly previous to this inspection, review of all reactor
operations department individual training records and 64 records for other
personnel assigned to the emergency response organization revealed that
many individuals (approximately 30 percent) had not completed GET.
The NRC inspector noted that emergency plan training commenced May 27,
1986.
In the review of individual training records it was determined that
21 persons out of 164 had not received the training.
The NRC inspector
noted that in a few cases the assignment to the emergency response
organization had recently been made, but such training should have been a
prerequisite to the assignment or at least prior to placing the person's
name on the emergency response organization list.
Prerequisites were apparently not checked before giving emergency plan
training in all cases.
A prerequisite for individual modules of the
,
17
emergency plan training was GET; however, a review of 164 individual
training records showed approximately 30 percent with emergency plan
training but no GET.
Because the first year of training had not been completed, the NRC
inspector was unable to assess the system for controlling retraining in
No formal records were available for the offsite
training and retraining.
The NRC inspector reviewed lesson plans, instructional aids, handouts and
examinations as applicable to GET and emergency plan onsite and offsite
training.
It was noted that lesson plans were available in some form for
all training provided.
The lesson plans contained clearly stated
objectives for the students.
Each class record included a list of
attendees and adequate information on the class title and instructor.
Some of the records were observed to be inconsistent in content with some
information missing.
The NRC inspector determined that no training was provided for offsite
-fire fighters to train them as radiation workers.
Also, arrangements for
use of _and familiarization with site equipment had apparently been
discussed but not completed.
Examples of this were in regard to SCBA and
respiratory protection requirements.
Also, familiarization tours of the
site had been discussed with offsite fire fighters but the tours and
familiarization had not been completed.
Instructors for emergency plan training were interviewed by the NRC
inspector.
Subject knowledge was judged to be good.
The NRC inspector
also attended portions of sessions in GET-Category I and emergency plan
training.
The sessions were generally found to be well conducted
according to prescribed training procedures and guidelines.
A list of current, approved lesson plans was maintained by the Training
Department library, and was available to the instructors on request to
confirm that the latest revision was in use.
However, the NRC inspector
noted there were errors in the library list in that the list showed
Revision 0 for emergency communication training but Revision 1 was in use.
Also, the list showed Revision 0 for radiological release assessment but
Revision 2 was in use.
Examination control was provided by a Nuclear Training Department
precedure.
The NRC inspector reviewed examination development and
control, and completed examinations.
It was noted that a separate review
of each examination prepared was required by the procedure but not always
conducted.
Discussions with selected licensee and non-licensee personnel assigned to
various functional areas of emergency activities supported the fact that
training, as recorded, actually took place.
18
'
.
- Base ~d on the above findings, the following deficiency must be corrected to
achieve an acceptable program:
s
,
- -
GET and: specific emergency response training had not been completed
,s
'
,,for,the operatjons staff and personnel assigned to the emergency
,c
%
,~
, response organization.
(498/8635-004; 499/8635-004)
_
,
,.
s
,
s o
,,
'
'
!The following are observations the NRC inspectors call to the licensee's
attention
These observations are neither violations nor unresolved
~ ~
items.. These items are recommended for licensee consideration for
improvement, but have no specific regulatory requirement.
s
Internal audits of the training records and record system should be
-
conducted periodically to assure consistency identify discrepancies.
-
Emergency plan trainers should be credited on their training records
for emergency plan training they teach.
-
Followup interviews with training participants should be conducted to
check training effectiveness in accordance with 10 CFR 50,
Appendix E, paragraph IV.
-
All working copies of emergency plans and implementing procedures
should be provided with tabs to make use faster and more effective.
4.0 EMERGENCY FACILITIES AND EQUIPMENT
4.1 Emergency Facilities
4.1.1 Assessment Facilities
4.1.1.1
Control Room
The control room was inspected with respect to the requirements of
10 CFR 50.47(b)(8); 10 CFR 50, Appendix E, paragraph IV.E; and those
criteria of NUREG-0654,Section II.H, which were not reviewed in other
.
portions of this inspection.
l
The NRC inspector toured the control room; reviewed applicable P&ID
'
drawings, EPIPs, and sections of the Emergency Plan, FSAR, and draft
Technical Specifications; and inspected the control room shield wall and
the HVAC system.
The NRC inspector noted that control room construction was incomplete.
For example, not all of the Regulatory Guide 1.97 instrumentation required
for accident analysis and mitigation was functional; several cable trays
were not closed out; the HVAC and large portions of the electrical switch
gear systems were still under startup control; and installation of
communications and visual display equipment was in progress.
.
.
.
.
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__
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_-
. - . _ - .
_
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' -
'
,
-
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,
,
<
,
,
^
JAlthough construc' tion was incomplete, the NRC inspector was able to
- J nspect_the control ' room as an ERF and found:
i
,
. ,
,
L&
>
.. _
'
- ta." .The emergency. preparedness critical' path appeared to be completion of
1
U
M the' HVAC,iRegulatory Guide 1.97 instrumentation, ERFDADs (emergency
'
,
- -
N
' % response facilityJdath acquisition and display system), and QDPS
,
- -
(qualified display. processing system) systems.
,
,
.
.
.
y
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2
tn
A copy of the Plan and the EPIPs was available in the control room.
. .
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.
_
y'
n
c.
' Definition of the' emergency preparedness records, equipments and
supplies required in the control room was inadequate; and outfitting
-
was incomplete.
Examples are as follows:
s Page G-1 of the Plan (revision 2) listed the control room as an
'-
ERF.
Page G-3 noted that "The records available for each ERF
are listed in table G-2."
The control room was not included in
table G-2.
-
An analogous problem existed in that Plan table G-1 omitted the
control room from the " typical" emergency equipment and supplies
listing.
4
--
Although Plan page G-1 noted that "A detailed list of control
'
room equipment and instrumentation is provided in Section 6.0 of
-
'
the FSAR," the FSAR listing was not detailed (nine lines) nor
was it correct (no storeroom exists in the control room) nor
were the items listed therein available in the control room
(portable radiation monitoring instruments, SCBAs, food and
1
medical supplies, etc.).
-
The control room was omitted from EPIP OEPP02-ZA-0002
(Revision 0), " Emergency Equipment."
Although first aid kits, one portable beta gamma meter, and one-
'
-
'
air sampler were presuit, additional radiation control, medical,
'
and respiratory equipmer;t supplies were missing (e.g. low and
high range pencil dosimeters, boundary tape, protective
clothing, SCBAs, and medical supplies in excess of a simple
first aid kit).
f
The Plant Curve Book required by procedure OPGP03-Z0-0011
-
(revision 0) and the Technical Specification Interpretation
j
Manual required by Procedure OPG 03-0018 (Revision 0) were not
present in the control room.
i
l
Based on the above findings, the following deficiencies must be corrected
to achieve an acceptable program:
I -
>
1
,, ,
, ~ . _ _ , . - _ . - . - , . , _
.
- - . - . . - ~ . _ , _ . _
. - - .
- - - - -
--
-.
- -
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.-
.-
.-
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20
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The HVAC, Regulatory Guide 1.97 instrumentation, ERFDADS, and QDPS
systems were not operational in the control room.~
(498/8635-005;
499/8635-005)
-
The identification and control of emergency equipment, supplies, and
decisionmaking aids was not adequate for the control room, and
outfitting was inadequate.
(498/8635-006; 499/8635-006)
4.1.1.2
The TSC was inspected with respect to the requirements of
10 CFR 50.47(b)(8); 10 CFR 50, Appendix E, paragraph IV.E; applicable
criteria of NUREG-0654,Section II.A; and the guidance of NUREG-0696.
.
The NRC inspector reviewed the Plan, the EPIP index, and the FSAR; toured
the TSC, the roof mounted HVAC equipment space, and the TSC switch gear
room; reviewed P&ID drawings of power supplies and HVAC distribution; and
interviewed cognizant engineers concerned with HVAC, power distribution,
and space allocation.
The NRC inspector noted there were two TSCs at the STP site.
Since
communications and computer system limitations prevent cross connecting
TSCs to their opposite units, each TSC was dedicated to a particular unit.
Although construction was still in progress, the inspector was able to
conduct an adequate inspection of the Unit 1 TSC.
The TSC was located on the top floor of the Mechanical Auxiliary
Building (MAB) at the 72 foot elevation.
Three flights of stairs connect
the control room access hallway with the TSC access door, adequately
fulfilling the guidance concerning proximity of the two ERFs.
Although
the TSC has a separate habitability envelope from that of the control
room, the facility was designed to the same shielding and habitability
criteria as the control room.
The TSC HVAC included emergency ventilation
pre, HEPA, and charcoal filters.
Although neither the Plan nor the EPIPs define the size of the minimum TSC
staff, by observing existing desk placement and unassigned space, the NRC
inspector estimated that the TSC could accommodate more than 30 persons on
y
a 75 square foot per person basis and then overflow to the adjacent
[
computer room if additional space were required.
The TSC included an NRC
conference space (with 2 phone lines) and additional space for up to 5 NRC
'
~
staff. . On that basis, the inspector concluded that the size of the TSC
-
appeared to be adequate.
,
-
Normal"TSC ' electrical power was provided from the 13.8 KV IJ bus via a
'
_ dedicated transformer to 480 VAC load center 1W and thence to the TSC
motor control" center 1G8.
In the event of loss of normal power, the load
-
center supply breaker should open on undervoltage and lockout and a
A ,
-
&
, dedicated 1200 KW 4160 VAC TSC emergency diesel generator should restore
,
-
. power to the load center via a separate transformer following an auto
,,
l
start / dead bus transfer sequence.
TSC load breakers either fail as is or
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,
f
.,
_,
.
_ _ - -
._ - _ - - - _ _
- - .
21
auto sequence to close following power restoration.
Since the ERFDADs'and
plant computers were powered from uninterruptible power supplies (UPS),
they should survive the dead bus transfer although local terminals and
micro units may require restart / boot.
The NRC inspector found that:
a.
TSC construction was incomplete (e.g. primary TSC access door sill
and gasketing missing; status boards hung from pipe runs and secured
only at the top of the boards; communications, ERFDADs, radiation
monitoring, HVAC, toxic gas and smoke detection systems, TSC diesel,
load center, and power panel incomplete /not turned over to plant.)
Since the radio systems were not installed, the NRC inspector was
unable to verify radio communications between the TSC and field
teams.
b.
With the exception of desks, chairs, desk supplies, and phones, the
TSC equipment and supply outfitting was sparse and often inadequate.
Some items were still in their packing crates (e.g. copier), others
were laid in place but not ready for service (e.g. typewriter with no
ribbon, not secured to the typing table).
No inventory was available
at the storage lockers; some of the lockers were unlocked and
unsealed inviting pilferage.
The microfiche system was in place but
no hard copy capability existed nor was one programmed.
Technical
Specifications, E0Ps, and the FSAR were present.
c.
In the normal configuration with one supply and one exhaust fan
running, the ambient noise level in the TSC was unacceptably high.
The primary cause was air flow noise and the absence of acoustic
ceiling and paneling.
Although the NRC inspector acknowledged the
potential for improvement following ventilation system balancing and
the placement of acoustic panels around the walls, it appeared that
ambient noise would remain high.
The NRC inspector was informed that
an acoustic dampening suspended ceiling was not programmed.
Placement of the fire sprinkler heads above the level at which a
false ceiling would be placed confirmed that this information was
correct.
d.
No ventilation system indication was provided within the TSC.
The
l
NRC inspector concluded that TSC indication would be required to
verify appropriate system lineup without unnecessary personnel
exposure to radiation, toxic gases, and smoke threats.
The TSC and control room shared a common air induction plenum which
contained redundant monitors for smoke, radiation, and toxic gas
(anhydrous ammonia, vinyl acetate, ammonium hydroxide, and
hydrazene).
From normal lineup, upon sensor activation, the TSC
lineup shifted modes automatically.
If the threat was radiation, the
system lined up for filtration with about 15 percent makeup air; in
the event of an external smoke or toxic threat, the system isolated
to full recirculation.
Given an internal TSC smoke sensor signal,
.
. ._
_ _ _ .
- _
.
.-
- . .
. . -
- _ . -
_
. . _. .
. - . .
, , - .,
.
N
e
22
4
the system may be shifted manually to the smoke purge mode, a once
through full flow mode to purge smoke from the TSC.
In the event of
simultaneous external toxic gas and radiation sensor trips, the rad
'
signal takes priority and the system shifts to about 85 percent
. recirculation through the filter beds,
.
t
e.
The TSC was observed-to have floor mounted raised 120 VAC and.
.
telephone receptacles which appeared to represent a safety hazard.
f.
-The NRC inspector was informed that liaison'with one of the two
nearby chemical plants to define the toxic gas threat from the plant
'
was ongoing but inconclusive to date. Thus, the toxic chemical
threat was only partially defined.
'
'
Based'on the above findings, the following deficiencies must be
corrected to achieve an acceptable program:
"
~
' Installation of the TSC access door, status boards,-
-
' .
l
' "
'
communications, ERFDADS, radiation monitoring, HVAC, toxic gas
and smoke detection systems, acoustic wall panels, and emergency
-
i power provisions were incomplete.
(498/8635-007; 499/8635-007)
,,
~ The'TSC was not supplied with an adequate range and depth of
4
-
>-
-
equipmentand supplies to support emergency operations.
,
f_ "
>(498/8635-008; 499/8635-008)
-
'
The followingjare observations the NRC inspectors call to the
licensee's' attention.
These observations are neither violations nor-
F
unresolved items.
These items are recommended for licensee
i
consideration for improvement,- but have no specific regulatory
j
requirement.
-
Measures should be taken to mitigate the potential safety hazard
represented by the floor mounted, raised 120 VAC and telephone
>
receptacles.
,
-
-
Remote indication of the HVAC system lineup should be made
. available in the TSC.
-
The external threat represented by the nearby chemical plants
should be more clearly defined.
- 4.1.1.3
Operations Support Center
.
The Operations Support Center was inspected with respect to the
requirements in 10 CFR 50.47(b)(c); 10 CFR 50, Appendix E,
paragraph IV.E; and the criteria in NUREG-0654,Section II.H.
.
.
The NRC inspector toured the Operations Support Center (OSC) and
i
reviewed the Emergency Plan and Procedure OEPP-ZA-0016, Revision 0,
'
" Operations Support Center Activation, Operation, and Deactivation."
._,
-. . , - . - , . . - - - - - - , . . - - . .
- . - . - . . - . - -
.
- - .
. . . . -
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23
.
The activation procedure designates responsible personnel for key OSC
positions, assigns duties, provides a checklist for activation, and
contains. pertinent forms and checklists.
The OSC is located.on the ground floor of the administration
building. The OSC coordinator and support function supervisors are
located in a large conference room in the front part of the building.
' Personnel performing the support functions are located in the
maintenance shop area at the back of the building, approximately
100 feet and two doors from the supervisors.
The inspector noted several potential problems with the operation of
the OSC.
The first concerns the separation of the support function
supervisors from the support personnel with no provisions for
communications.
It is doubtful that the supervisors can maintain
awareness of plant status and support the coordinator while
simultaneously managing their personnel in another part of the
building.
Another concern involves the use of the maintenance shop as both the
OSC and the plant assembly point.
It was unclear to the inspector
that the OSC could operate effectively with a large number of
extraneous personnel present.
In addition, it is unclear if proper
OSC accountability can be maintained with a large number of people
located in several separate areas with numerous access and egress
points.
The activation procedure designates the support function
supervisors as being responsible for maintaining accountability of
their personnel.
The licensee plans to monitor for OSC habitability by taking periodic
air samples.
The inspector determined that this was inadequate for
personnel protection because periodic air sanpling and analysis does
not ensure continuous habitability.
Section G-1.2 of the Plan states
that, in the event of OSC evacuation, the function and personnel will
be transferred to the E0C.
This was not described in any procedure.
The activation procedure lacks a policy statement
.1 eating,
drinking, smoking, and chewing.
Also, the activation procedure does
not assign responsibility for establishing and maintaining OSC
habitability to the radiation protection group.
An inspection of the OSC emergency equipment locker found that very
little of the required locker inventory (per OEPP02-ZA-0002-002) was
actually in its assigned location.
Based on the above findings, the following deficiencies must be
corrected to achieve an acceptable program:
The physical layout and concept of operations for the OSC was
-
inadequate to perform the functions stated in NUREG-0737.
(498/8635-009; 499/8635-009)
__.
__
._
_
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.
_1
24
.
Responsibility and equipment and procedures had not been
--
-provided-for determining continuous habitability of the OSC.
-
(498/8635-010; 499/8635-010)
4 -
^
.
,
The following are observations the NRC inspectors call to the
licensee's attention.
These observations are neither violations nor
unresolved items. -These items are recommended for licensee
conside' ation for improvement, but have no specific regulatory
r
'
requirement.
~
-
Provisions should be made and included in procedures for
relocation of OSC.
-
Responsibility for habitability monitoring should be assigned in
the OSC activation procedure.
4.1.1.4
Emergency Operations Center
The E0C was inspected with respect to the requirements of
10 CFR 50.47(b)(8); 10 CFR 50, Appendix E, paragraph IV.E; and the
,
criteria in NUREG-0654,Section II.H and NUREG-0737, Section 8.4.f.
The NRC inspectors toured the facility and reviewed Section 7 of the
FSAR Report, the Plan, Section G.4, and the following EPIP,
OEP01-ZA-0002, " Emergency Direction." The E0C was located adjacent
to the HL&P training center building on HL&P property, approximately
0.5 miles east from the power plant. .The backup EOC was located in
the Central Power and Light (CP&L) building located at
Highway 35 East, Bay City, Texas, approximately 15 miles NW of STP
and serves as the CP&L STP information center.
The primary E0C was
designed to meet NUREG-0737, Supplement 1, habitability requirements.
There are no unique habitability requirements imposed upon the backup
E0C.
In order to conserve inspector manhours, the NRC inspectors
chose not to inspect the backup E0C.
That decision was based on the
low probability that relocation would be required and the absence of
any unique habitability requirements for the backup facility.
The
primary E0C consisted of approximately 5700 net usable square feet of
area.
The licensee had approximately 10 percent of the E0C occupied
with emergency response staff and contractor personnel. The EOC was
adjacent to the training building in a special habitability envelope.
Application of the NUREG 0696 rule of 75 square feet per person led
to the conclusion that.the E0C would suffice for a staff of
76 persons, above minimum guidance and HL&P programmed use.
Should
the need arise, ample overflow space was available in the training
building.
The E0C was designed to the standard building code, and to
the 100 year flood, wind, and wind gust criteria.
Concrete walls
provide a shielding protection factor of 5 for a postulated source
from 0.7 MeV gamma in a semi-infinite cloud.
Ventilation control
consisted of a system capable of manual command shift to a full
recirculation mode with 100 percent air flow through a pre-filter,
HEPA, and charcoal filter bed.
---
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25
The communications installation consisted of at least a primary
system and dual backup capability.
It was a flexible system with
capability to route communications via radio, commercial leased
lines, company owned PBX systems including one serving the E0C, or an
extensive company owned microwave system.
Installation of all
communications equipment had not been completed for E0C.
In order to increase survivability, most of the vital equipments such
as the telephone ring power, PBX, hotline, modems, etc., were powered
from a DC system that remains on a constant charging system. The
system may be fed from emergency diesel generator located adjacent to
the EOC in the event of a loss of offsite power.
The emergency
diesel generator had been installed, tested, and put on a routine
maintenance performance test.
OPEP07-DZ-0001, "E0C Diesel Generator
Performance" test described the periodic test procedure for the E0C.
The procedure did not describe testing frequency or if the results
would be reported to the emergency preparedness manager, e.g.,
if the
diesel generator would be out-of-service.
Installation, testing, and turnover of the QDPS, Emergency Response
Facility Data Acquisition and Display System, (ERFDADS), and
Radiation Monitor System (RMS) was in progress, but incomplete.
Procedures and training on these systems was incomplete.
Following the initial staffing of the EOC, the main entry to the
training building may be closed and all access would be by the east
door.
The E0C served a dual purpose, it was both an E0C and an
offsite reassembly area for personnel evacuated frcm the TSC, OSC,
and a decontamination facility.
Provisions had not been made for a
step off pad and frisking station in the E0C access control
procedures.
Persons entering and exiting the E0C may leave via the
same hallway.
E0C contamination could result.
The decontamination
rooms were located in the men and women restrooms adjacent to the
main control control area for the E0C.
Contaminated personnel may be
decontaminated in a shower facility that had been installed and was
operational.
Shower water will drain to a sewage system constructed
for the E0C.
The sewage was treated within the owner controlled
property and would remain within the owner controlled property.
Procedu es had not been developed implementing the activation,
operation, evacuation of emergency personnel to the alternate E0C,
and deactivation of the EOC.
Further, a contingency plan had not
been developed and procedures written for the activation and
operation of the TSC, as a command and control emergency facility,
.until the EOC was fully activated.
Additionally, if the TSC and OSC
are evacuated to the EOC there were not any procedures addressing how
the TSC and OSC were to function in the E0C.
f
Emergency equipment listed in the Plan did not contain vital
equipment for personnel monitoring. Additionally, procedures had not
been developed for location, distribution, collection of data, and
maintaining emergency equipment.
26
Based on the above findings, the following deficiencies must be
corrected to achieve an acceptable program:
-
Installation, testing, turnover, and personnel training for the
QDPS, ERFDADS, and RMS for the EOC had not been completed.
(498/8635-012; 499/8635-012)
-
Filter leak testing and charcoal efficiency determinations had
not been conducted for the E0C, and the-filter system had not
been put on a defined testing frequency.
(498/8635-013;
499/8635-013)
-
No provisions for protective clothing, personnel dosimetry, or
respiratory protection had been made for the E0C.
(498/8635-014; 499/8635-014)
.
-
There was no contingency plan for performing E0C functions in
the TSC in the event that the E0C was not functional.
(498/8635-015; 499/8635-015)
The following are observations the NRC inspectors call to the
licensee's attention.
These observations are neither violations nor
unresolved items.
These items are recommended for licensee
consideration for improvement, but have no specific regulatory
requirement.
-
Procedure OEP07-DZ-0001 should define the emergency diesel
testing frequency and notification of the Manager, Support
Division if the diesel will be out of service.
-
Procedures should be developed for radiological control,
radiological monitoring of personnel, and radiological
monitoring equipment for survey of emergency response personnel
(
arriving at the E0C.
-
Procedures should be developed for manual activation of the E0C
HVAC emergency filter mode.
-
Damper positions should be labeled (normal / emergency operating
.
position) and controls and control panel identified in the E0C
_
!
HVAC room.
!
l
_
The Plan should be revised to describe the E0C filter system
-
actually installed.
'
4.1.1.5
Post-Accident Coolant Sampling and Analysis
The post-accident coolant sampling and analysis systems were inspected
with respect to the requirements of 10 CFR 50.47(6)(8); 10 CFR 50,
Appendix E, paragraph IV.E; and the criteria in NUREG-0654,Section II.I.
.
27
The NRC inspector toured the post-accident coolant sampling areas and
observed that sampling equipment was installed as described in
Section G.14.5 of the Emergency Plan.
The equipment had been turned over
to startup, but had not completed testing as of this inspection date.
Licensee personnel stated that testing of the system should occur during
hot functionals.
The NRC inspector also toured the analytical laboratory on the 41 foot
level.
The laboratory equipment was observed as described in Section 6.9
of the Emergency Plan.
However, none of the equipment was operational due
to a recent relocation.
The Plan also describes a backup laboratory in a
HL&P building in Houston.
The Plan states that the backup laboratory has
equivalent analytical capability.
The backup laboratory was not inspected.
The NRC inspector reviewed a time and dose projection study for sampling
and. analyzing a reactor coolant sample (STP FSAR, Appendix 7A,
Amendment 55).
The study projected a time of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 8 minutes for an
undiluted sample and a time of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 38 minutes for a diluted
' sample.
Due to the inoperability of the system at the time of the
inspectio'n, a walkthrough was not performed to establish actual sample and
analysis time.
Based on the above findings, the followup deficiency must be corrected to
achieve an acceptable program:
-
The post-accident coolant sampling and analysis system was not
completed and operable, and the capability to sample and analyze a
sample within the required 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> had not been demonstrated.
(498/8635-016; 499/8635-016)
4.1.1.6
Post-Accident Containment Air Sampling and Analysis
The post-accident containment air sampling and analysis systems were
inspected with respect to the requirements of 10 CFR 50.47(6)(8);
10 CFR 50, Appendix E, paragraph IV.E; and the criteria in NUREG-0654,
Section II.I.
The NRC inspector toured the post-accident containment air sampling areas
and observed that sampling equipment was installed as described in
Section G.14.5 of the Emergency Plan.
The equipment had been turned over
to startup, but had not completed testing as of this inspection date.
The NRC inspector also toured the analytical labc ntory on the 41 foot
level as discussed in Section 4.1.1.5 of this report.
The NRC inspector reviewed a time and dose projection study for sampling
and analyzing a containment air sample (STP FSAR, Appendix 7A,
Amendment 55).
The study projected a time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 57 minutes for an
undiluted sample and a time of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 2 minutes for a diluted sample.
.
__
.
-
. _ _ _ .
_ _ _
_
._,
_ --
_ _..
.
.
.
.
,
.
4
.
28
?
'
.
5
Due to the inoperability_of the system at the. time of.the inspection, a
walkthrough was not, performed to establish actual sample.and' analysis
,
-time.
'
-
-
!
';<
>
l
Based on the'abovesfindings, the following deficiency must be corrected to
,
r
~ achieve an~ acceptable program:
. ,
~
-
' The post-accident containment air ' sampling and analysis system was
~ not completed and operable, and the capability to sample and analyze
'a sample within the required 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> had not been demonstrated.
'
t(498/8635-017; 499/8635-017)
i
4.1.1.7
Post-Accident Gas and Particulate Sampling and Analysis
'The post-accident gas and particulate effluent sampling and analysis
systems were' inspected with respect to the requirements of
,
10 CFR 50.47(6)(8); 10 CFR 50, Appendix E, paragraph IV.E; and the
'
~
criteria in NUREG-0654,Section II.I.
l
The NRC inspector toured the post-accident gas and effluent sampling areas
and observed that sampling equipment was installed as described in-
Section G.14.5 of the Emergency Plan. The equipment had been_ turned over
to startup, but had not completed. testing as of this inspection date.
j
Licensee personnel stated that testing is scheduled for May 1987.
The NRC inspector also toured the analytical laboratory on the 41 foot
level as, discussed in Section 4.1.1.5 of this report.
t
i
Based on the above findings, the'following deficiency must be corrected to
achieve an acceptable program:
4
The post-accident gas and particulate sampling and analysis system
'
'
-
l-
was not completed and operable, and the capability to sample and
analyze a sample under accident conditions had not been demonstrated.
(498/8635-018; 499/8635-018)
4.1.1. 8 Post-Accident Liquid Effluent Sampling and Analysis
!
The post-accident liquid effluent sampling and analysis systems were
!
inspected with respect to the requirements of 10 CFR 50.47(6)(8);
10 CFR 50, Appendix E, paragraph IV.E; and the criteria in NUREG-0654,
,
Section II.I.
The NRC inspector toured the post-accident liquid effluent sampling areas
l-
and observed that sampling equipment was installed as described in
Section G.14.5 of the Emergency Plan.
The equipment had been turned over
i
to startup, but had not completed testing as of this inspection date.
l
Testing is scheduled for May 1987.
!
!
. . _ - _ _ - _ . . _ - , . _ . . , . _ _ -
-
.-
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~
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.
.
'
29
.
.
-
.,a
- .
,
~
"The'NRC . inspector noted that the s' ample supply lines behind the panel did
,not appear.to,be shielded.
This could present an exposure problem if the
,
-waste tanks being sampled contain a high level of activity.
The:NRC inspector'also toured the analytical laboratory on the 41 foot
,
level as. discussed in Section 4.1.1.5 of this report.
)
" Based on the above findings, the following deficiency must be corrected to
--
- achieve an acceptable' program:
,
l
-
The post-accident liquid effluent sampling and analysis system was
not completed and operable, and the capability to sample and analyze
a sample under accident conditions had not been demonstrated.
'
(498/8635-019; 499/8635-019)
,
In addition, the following is an observation the NRC inspectors call to-
the licensee's attention.
This observation is neither a violation nor
unresolved item. -This item is recommended for licensee consideration for
improvement, but has no specific regulatory requirement.
-
-
The need for shielding post-accident liquid effluent sampling lines
to the liquid effluent sample station should be evaluated.
4.1.2
Protective Facilities
4.1.2.1 Assembly / Reassembly Areas
The area of assembly / reassembly areas was reviewed with respect to the
requirements of 10 CFR 50.47(b); 10 CFR 50, Appendix E, paragraph IV.E;
and the criteria in NUREG-0654,Section II.J.
The NRC inspector reviewed the Emergency Plan, Revision 3, Section F,
" Emergency Actions and Measures," Section G, " Emergency Response
Facilities," and Section J, " Radiological Exposure Control";
Procedure OEPP01-ZA-0005, " Radiological Controls";
Procedure OEPP01-ZA-0007, Revision 1, " Accountability / Evacuations"; and
Procedure OPRP08-ZC-0003, " Tool and Equipment Decontamination."
l
Addendum 3 to Procedure OEPP01-ZA-0007 states, "Except for training
purposes, this procedure is not usable without the information in
Items 2.0 and 3.0."
Item 2.0 pertains to the specific identity of
Assembly Area Supervisors and Item 3.0 pertains to the identification of
an assembly area location.
The Plan, Section F-5, pages 15 and 23, states that personnel onsite, but
located outside the protected area, will assemble in the Nuclear Training
'
Facility.
Procedure OEPP01-ZA-0007, Addendum 1, " Assembly Groups / Areas,"
does not support the statement contained in the Plan.
The Plan,Section I.2.1, page 3 states that contractor and construction
personnel shall proceed to the East Gate House by the safest most direct
i
,
30
,
route.
Addendum 1 to Procedure OEPP01-ZA-0007 does not provide assembly
instructions for non emergency contractor and construction personnel.
Procedure OEPP01-ZA-0007 does not address the adequacy of assembly areas
with respect to capacity for accommodating the number of persons expected,
shielding, ventilation and inventory of supplies, including for example,
respiratory protection, protective clothing, portable lighting, and
communication equipment.
Section G of the Plan states that, if required,
the TSC and OSC staffs will relocate to the E0C.
No evidence that the E0C
can support this additional manpower is provided.
Sections F-4 and J-10 of the Plan specify that offsite assembly areas will
be designated by the Emergency Director.
Procedure OEPP01-ZA-0007 does
not identify offsite assembly areas available to the Emergency Director,
except to provide an example in Addendum 3
"the fairgrounds in
Bay City."
Section J.12.4 of the Plan states that vehicles leaving the site during an
emergency will be monitored and, if necessary, decontaminated.
Procedure OEPP01-ZA-0005, Section 4.12.2 states that contaminated vehicles
will not be released until they have been decontaminated in accordance
with OPRP08-ZC-0003, " Tool and Equipment Decontamination".
A review of
the latter procedure indicates it is totally inadequate to provide
procedures for decontamination of vehicles.
It does not indicate the
location where decontamination will take place, where decontaminations
supplies will be kept, and how contaminated waste water will be handled. -
Based on the above findings, the following deficiencies must be corrected
~
in order to achieve an acceptable program:
-
Specific provisions and arrangements had not been made for offsite
-assembly areas.
(498/8635-020; 499/8635-020)
The following is an observation the NRC inspectors call to the licensee's
attention.
This observation is neither a violation nor an unresolved
item.
This item is recommended for licensee consideration for
improvement ^, but has no specific regulatory requirement.
RAconcil'e'thedifferencesbetweenthePlanand
-
Procedure OEPP01-ZA-0007 relative to assembly areas, and provide the
_
data required in addendum 3 of this procedure.
,
_
4.1.g2,MedicalTreatmentFacilities
< [ >'
The: provisions for' communication services at the onsite first aid station
were inspected with' respect to the requirements of 10 CFR 50.47(b)(8);
10 CFR 50, Appendix E, paragraph IV.E and the criteria in NUREG-0654,
Section II.L.
'
The NRC inspector conducted a walkthrough inspection of the onsite first
aid station to determine its communication service.
It was observed that
.
.-
-.
. - .
-
31
,
the station was equipped with dedicated phones as well as licensee
operated radio equipment.
In addition, radios tuned to the two
frequencies used by the two offsite ambulances are maintained at the
onsite first aid station.
The licensee's KI program was reviewed with respect to the requirements of
10 CFR 50.47(b)(8); 10 CFR 50, Appendix E, paragraph IV.E; and the-
criteria in NUREG-0654,Section II.H.
The NRC inspector examined the licensee's plans for using KI for thyroid
blocking of radioactive iodines.
It was determined that the licensee had
no plans to distribute KI to its emergency response personnel and thus did
not maintain supplies of KI.
4
The State of Texas has recently requested the licensee to establish and
maintain stocks of KI for its emergency workers and for the public.
Distribution of this drug is to be under the control of the State.
At the
time of this inspection, the licensee had not developed a program with
procedures on maintaining the State's KI stockpile.
The following are observations the NRC inspectors call to the licca we's
attention.
These observations are neither violations nor unrecolved
items.
These items are recommended for licensee consideration fce-
improvement, but have no specific regulatory requirement.
-
Consideration should be given to administration of KI to station
emergency workers that request the thyroid blocking agent while
performing emergency duties.
STP procedures should be developed for maintaining the State of Texas
-
KI stock.
4.1.2.3
Decontamination Facilities
The area of decontamination facilities was reviewed with respect to the
requirements of 10 CFR 50.47(b)(8), (10), and (11); 10 CFR 50, Appendix E,
paragraph IV.E; and the criteria in NUREG-0654, Sections II.J and K.
The NRC inspector reviewed the Emergency Plan, Revision 3, Section F,
" Emergency Actions and Measures," Section G, " Emergency Response Facilities,"
and Section J, " Radiological Exposure Control"; Procedure OEPP01-ZA-0005,
" Radiological Controls," Procedure OEPP01-ZA-0007, Revision 1,
" Accountability / Evacuations." The NRC inspectors conducted a review of
decontaminated facilities dedicated for use in emergencies.
The NRC
inspectors did not evaluate the adequacy of decontamination facilities
developed for use during routine operations.
OEPP01-ZA-0007 has identified the Administrative Building Machine Shop as
one of the primary assembly areas within the protected area.
The licensee
reported that over 300 people could be expected to report to this assembly
- - . - .
~,
.
. - . .
.
,-
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-
-
-
-
.-.
32
area.
It appeared that this area did not contain adequate facilities to
provide for the decontamination of persons reporting to this assembly
area. The Plan,Section I.2.1 states that contractor and construction
personnel shall proceed to the East Gate House by the safest most direct
route. The East Gate House does not contain adequate decontamination
facilities.
It appears that persons found contaminated at this point
would have to return to the plant for decontamination.
Section I.2.1 of
the Plan states that personnel decontamination can be performed at the
EOC.
It appears that the E0C does not have approved decontamination
facilities.
Procedures 6.2.6.2 states that a radiation monitoring team
shall if necessary establish a decontamination area at a designated
offsite assembly area.
It appears that no procedure establishes the
requirements for an offsite decontamination facility.
Based on the above findings, the following deficiency must be corrected in
order to achieve an acceptable program:
-
No provisions had been made for decontamination of personnel at
assembly areas outside of the normal radiological controlled area.
(498/8635-021; 499/8635-021)
4.1.3
Expanded Support Facilities
.
The provisions for expanded support facilities were reviewed with. respect
to the requirements of 10 CFR 50.47(b)(13); 10 CFR 50, Appendix E,
paragraph IV.E; and the criteria in NUREG-0654,Section II.C.
The NRC inspector conducted a walkthrough inspection of the -licensee's
Unit 1 control room /TSC, OSC, and E0F.
The control room was designated
space and three phone lines, including the Emergency Notification
System (ENS) and Health Physics Network (HPN) for the NRC. The TSC
contains desks for seven titled NRC positions and provided 12 phone lines
(including the ENS & HDN) for the NRC.
Space in the EOC has been provided
for the NRC, State of Texas and Matagorda County.
Space for specific
persons by title has been appropriately identified.
Equipment dedicated
for use by these support agencies have been provided and appropriately
identified.
This includes telephones, radios, communication consoles,
desks, office equipment and status boards.
EOC communications dedicated
for the NRC include the ENS and HPN phones plus an additional seven
dedicated lines.
It appears that the space and equipment provided to the
'
NRC, State of Texas and Matagorda County will be adequate.
This will be
verified in a subsequent NRC inspection during an emergency exercise.
Utility services for mobile radiological and radiochemical laboratories
operated by the State of Texas and the NRC are being provided on the south
side of the Nuclear Training Facility adjacent to the E0C.
The licensee
reported that these services will include electrical, phone, computer
link, and radio.
>
Based on the above findings, no deficiencies were identified in this area.
l
-
.-.
.-.
- _ . . . - - .
. . . _ _
,_
.
_ _ ~ . -
_
_
.
.
-
5'--
r
s
,
-
4 -
33
-
'
,
4.1.4 News _ Center
~ The news center was reviewed with respect to the requirements of
+
+ -
10 CFR:50.47(b)(7); 10 CFR 50, Appendix E, paragraph IV.E; and the
'
criteria in NUREG-0654,Section II.G.
The N'C. inspector reviewed the contents of Sections C and K of the STP
R
'
Emergency Plan and toured the Media Information Center (MIC) located in
the Holiday Inn in Bay City, Texas, and the Emergency Operations
Center (E0C) located at the STP site.
The Principal Spokesman position was omitted from Section C, Figure C-3
and Table C-3.
Job descriptions were included in the EPIP for the
- principal; staff, but job descriptions for all positions in the emergency
information staffing were not included.
Ample space is available for a
limited number of news media representatives and includes appropriate
equipment, visual aids and a public address system.
The NRC inspector
noted that the MIC is sufficient to accommodate 300-500 news media
representatives (including work tables and news briefing areas).
There is
a work space designated for Federal, State, and local public information
personnel.
Adequate telephone service has been provided or is available
for public information and working press at both the E0C and MIC.
Additional electric outlets are needed in the PIO Support Room, Meeting
Room 7, in the Holiday Inn.
Copying equipment is available in the E0C
and MIC, and larger and faster equipment has been located and is available
.
locally on short notice. Audio visual equipment and visual aids are
available at the MIC. The visual aids are particularly well done.
Security at ooth the EOC and MIC are adequate.
Media badging and crowd
control have been considered and provided for.
'
Based on the above findings, the following deficiencies must be corrected
in order to achieve an acceptable program.
.
i
' -
The HL&P principal spokesman position was not included in the Pian,
Section C, Figure C-3, and Table C-3.
(498/8635-022; 499/8635-022)
Job descriptions for MIC positions below the principal staff were not
-
included in the implementing procedures.
(498/8635-023;
499/8635-023)
The number of electrical outlets in the PIO support room of the MIC
-
was not adequate to support planned activities.
(498/8635-024;
499/8635-024)
i
,
i
?
-
. , . . -
-
,
-
,,
---.,
-
r - - . . ,
--,v._
,-,-,m__--._,r-__v
-- ,
--
- , , - , . - , - - - , .
,
-_- -
-
_ _ _ _ _ _ _ _ .
.
., '
_,s,
'
5
'
'
34
- -
'
_ .'
'
,
.
14.2-EmergencyNauipment
4'
/"
_
. _
,
,
_
4.2.1^ Assessment; Equipment-
r
-
,
,'4.'2.1.3 ~Non-Radi tion Process konitors
,
s
>
,
~
-The non-radiation process monitors were reviewed with respect to the
requirements of'10 CFR 50.47(b)(9) 10 CFR 50, Appendix E, paragraph IV.E
and the' criteria-in NUREG-0654,Section II.H.
The NRC inspector toured the control room and reviewed Plan Section H,
paragraphs H 1.1.2 (seismic monitoring) and 1.1.3 (plant process monitors)
which defined the STP non-radiation process monitors.
Amplifying
information was available in the Technical Specifications and the FSAR.
The NRC inspector found that the Technical Specifications were still in
development and the non-radiation process monitoring equipment
installation, testing, and turnover was. incomplete.
Based on the above findings, the following deficiency must be corrected to
achieve an acceptable program:
Non-radiation process monitor systems installation, testing and
-
turnover were not complete.
(498/8635-025; 499/8635-025)
4.2.2
Protective Equipment
4.2.2.1
Respiratory Protection
Respiratory protection equipment was reviewed with respect to the
requirements of 10 CFR 50.47(b)(11); 10 CFR 50, Appendix E,
paragraph IV.E; and the criteria given in NUREG-0654,Section II.H;
ANSI Z88.2-1969; and Regulatory Guide 8.15.
The NRC inspe: tor reviewed the licensee's provisions for providing
respiratory protection to emergency workers outside of the pienned
radiological control area.
Section J of the Emergency Plan states that
4
" respiratory protection will be used whenever possible and appropriate."
Procedure OEPP02-ZA-0002, Revision 0, Emergency Equipment, lists the
specific number, type, and location of respiratory protection equipment
dedicated to emergency response.
The procedure calls for 2 SCBAs in the
EOC, 2 SCBAs and 8 full-face respirators in the OSC, 4 SCBAs in the
Radiation Protection Office, 5 SCBAs and 10 full-face respirators at the
Site Access Facility, and 2 SCBAs in the TSC.
The licensee does have the capability to refill SCBA units, but the
capability was not described in the Plan or procedures.
Current plans are
to place one compressor at the Site Access Facility and another on the
west side of Unit 2.
The large separation should assure that refill
capability would be maintained under most release scenarios.
Interviews
,
.
35
determined that one of the compressors is to be linked to a cascade
system, thus providing an extended refill capability in the event of a
power loss.
The NRC inspector noted several other potential problems with the
licensee's plans.
The first is a discrepancy between respiratory
protection provisions listed in the FSAR and those listed in the
implementing procedures.
The FSAR calls for 25 " portable air-breathing"
units in the TSC.
The FSAR also states that " respiratory protection is
readily available to all E0C personnel." This statement is not consistent
with the E0C inventory listing.
The Plan and procedures do not include
respiratory protection devices stored in the control room.
In addition,
the supply of SCBAs stored in the OSC appears to be 'nadequate for the
facility's mission of providing operational support to the response
effort.
Finally, the licensee had not supplied respiratory protection for
offsite monitoring teams that may be required to traverse, sample, and
otherwise define a radioactive plume.
Based en the above findings, the following deficiencies must be corrected
to achieve an acceptable program:
-
Provisions for respiratory protection at emergency response
facilities were incomplete and not adequate.
(498/8635-026;
499/8635-026)
-
The Plan and implementing procedures were not consistent with the
respiratory protection provisions listed in the FSAR.
(498/8635-027;
499/8635-027)
-
Provisions were not made for respiratory protection for control room
personnel and field monitoring teams, and supplies of respiratory
protection devices for OSC emergency workers were inadequate.
(498/8635-028; 499/8635-028)
The following are observations the NRC inspectors call to the licensee's
attention.
These observations are neither violations nor unresolved
items.
These items are recommended for licensee consideration for
improvement, but have no specific regulatory requirement.
-
-
SCBA bottle refill capability should be addressed in the Plan and
-
implementing procedures.
.
w^ f Respirator protection for control room staff in an emergency should
be addressed in the Plan and implementing procedures.
-
'
-
Provisions for respiratory protection for offsite radiological field
teams should be made.
.
_.
.
_
36
4.2.2.2
Protective Clothing
The area of protective clothing was reviewed with respect to the-
requirements of 10 CFR 50.47(b)(8); 10 CFR 50, Appendix E, paragraph IV.E;
and the criteria in NUREG-0654,Section II.H.
The NRC inspector reviewed the licensee's provisions for providing
,
protective clothing to emergency workers.
This subject is not
specifically covered in the Plan.
Procedure OEPP02-ZA-0002, Revision 0,
" Emergency Equipment," specifies 15 pairs of yellow coveralls and 150
pairs of paper coveralls for storage at the Site Access Facility.
No
other procedure specifies the number, type, and location of protective
clothing units.
The FSAR commits the licensee to 25 units in the TSC and
states that protective clothing is "readily available to all E0C
personnel."
The NRC inspector observed that the licensee does have some stores of
protective clothing in most of the ERFs, but these had not been included
on an inventory listing. Therefore, it was not possible for the NRC
inspector to determine if adequate stores of protective clothing existed
at each facility or kit.
Based on the above findings, the following deficiencies must be corrected
to achieve an acceptable program:
,
-
. Provisions for protective clothing at emergency response facilities
'were incomplete and not adequate.
(498/8635-029; 499/8635-029)
-
Tte licensee had not addressed protective clothing in the Plan, and
had not designated the type, number, and location of protective
clothing. units in. an inventory procedure for each facility and
.
emergency kit, including the control room.
(498/8635-030;
499/8635-030)
t
l
4.2.3 Commimications
'
,
,
5 The' area of emergency communications was evaluated against the
l
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j
" requirements of 10 CFR 50.47(b); 10 CFR 50, Appendix E, paragraph IV.E;
[
,
and the criteria in NUREG-0654,Section II.F.
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The NRC: inspector reviewed the Plan, Secti a E, " Notification Methods and
Procedures, Section G, " Emergency Response Facilities";
j
.
. Procedure 0EPP01-ZA-0003, " Emergency Offsite Notification"; and
s
OEPP01-ZA-0004, " Emergency Response Personnel Notification".
The
l
- inspectors reviewed the emergency communication system in the control
room,'TSC, E0F, OSC and the following offsite support agencies; county E0F
l
(and Sheriff's office), the two agreement hospitals and the two agreement
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fire departments.
The appraisal team conducted a walkthrough of the
'
communications equipment during an emergency drill conducted on
I
December 10, 1986.
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37
The emergency communications system consists of the following subsystems:
telephone system, public address paging / alarm system, maintenance intercom
system, two-way radio, radio paging system, and integrated command control
consoles.
The telephone system consists of two operational telephone
switching systems.
These switching systems are computerized and sized to
share equally all of the STP telephone switching functions.
Telephone
instruments are single line ROLM type.
In high ambient noise areas the
telephones will be equipped with noise cancelling transmitters and
receivers and/or will be placed in wrap around noise reducing telephone
booths.
The voice paging system and alarm system is provided to transmit emergency
signals - fire, containment evacuation alarm, and site evacuation.
The
paging system is capable of broadcasting high-level audio messages
throughout loudspeakers strategically located in the plant.
Power for the
public address system is from normal plant 120 VAC sources.
A generator
backup is available during failure of the 120 VAC source.
Fully redundant radio repeater base stations, with automatic rollover,
provide communication between control base stations, mobile units and
hand-held portable radios within the plant area. A VHF base station is
provided for emergency communication between the plant and the HL&P Energy
Control Center.
Repeaters and base stations are powered by normal 120 VAC
backed up by a diesel generator.
A space for radio set-up facilities for
outside agencies such as the NRC and the State of Texas is provided at the
E0C.
The integrated command control consoles provide plant operators with
access to onsite/offsite telephone systems, two-way radio channels, radio
paging systems, and the public address systems and allow activation of the
plant emergency and fire alarm signals.
Command control consoles are
. located in the following emergency response facilities:
control room (2),
TSC (2), E0C (5), CAS and SAS.
Facsimile machines are located in the
following facilities:
control room, TSC, E0C (2), State of Texas (3), and
Matagorda County.
All communications coming through the command control
consoles are recorded on dual recorders
one for playback and one for the
record.
The recording equipment is maintained in the Administration
Building.
Special telephone service circuits (ring down) allow immediate and direct
contact with the NRC (ENS & HPN), the Matagorda County Sheriff's office,
and the State of Texas.
The onsite and offsite ambulances have radio equipment which permits them
to communicate directly with the onsite first aid station and with the
emergency rooms at the two agreement hospitals.
Persons responsible for
communicator duties are provided 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of " informal" training.
The
licensee defined informal training as not using a lesson plan and not
requiring a test at the conclusion of the training program.
Training in
the use of the command control consoles had not been initiated at the time
of the appraisal since the consoles were not in service.
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38
i
The licensee intends to use 11 sirens and approximately 1200 tone alert
j
radios for its, prompt notification system.
The licensee reported that the
sirens had been installed and performance test completed, but were not
officially turned over to the STP.
The sirens had not been used during
-
any emergency drill. 'The sirens may be activated from the E0C or the
Matagorda County Sheriff's office. The sirens can be selectively turned
on or all_ activated simultaneously.
The 1200 tone alert radios have been
received but have not been distributed to the public.
The signal to the
' -
radios.is transmitted by an FM radio station in Bay City.
This station
currently operates'on a 24-hour, 7-day per week schedule but is not
required to do so.
The station manager reported that there is no
requirement to notify the STP should the station operating hours be
reduced or if the station is shutdown for maintenance / repairs.
The
station manager reported that the station has no source of backup power in
the event commercial power is lost.
The station operating manager
reported that no message form would be used.
He described the procedures
for receiving and transmitting emergency messages; i.e., the sheriff calls
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the station, the message is entered into the station log and then
broadcast.
The station had not received a copy of the Matagorda County
Emergency Plan which does contain a " canned" message for broadcast by the
FM station.
The station manager reported that the station has a Class A license with a
primary service area extending 14.4 miles radius from the transmitter
located 1 mile south of Bay City.
The southwest edge of the EPZ is
approximately 20 miles from the station transmitting tower.
The licensee
reported that it had not made any checks in the southwest quadrant of the
,
EPZ to determine if the tone alert will function properly at that
distance.
The licensee reported that transient population signs have not s
been posted within the 10 mile EPZ.
The licensee has placed facsimile machines in the following emergency
response facilities:
control rcom, TSC, EOF (2), OSC, State of Texas (3),
and Matagorda County.
The licensee does not have an approved procedure describing periodic
testing of the entire emergency communication system.
The procedures do
,
_;
!
not provide for the periodic updating of offsite emergency response
organization telephone numbers on a quarterly basis.
Based on the above findings, the following deficiencies must be corrected
I
in order to achieve an acceptable program:
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The backup communications system between STP and the County and State
j
E0Cs was incomplete.
(498/8635-031; 499/8635-031)
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The prompt public notification system was incomplete and not verified
to be operable.
(498/8635-032; 499/8635-032)
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, ',Theif ilo ing are observations the NRC inspectors called to.the licensee's
- attention.
These observations are neither violations nor unresolved
items.
These'. items.are recommended for licensee consideration for
'
~
improvement, but'have no specific regulatory requirement.
.
A communications specialist or technician should be included in the
-
STP emergency' response organization.
-
A procedure should,be provided to govern the re. quired testing of the
'
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emergency communications system.
,
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Aprocedureshouldfbeprovidedfortheperiodicupdatingofthe
offsite emergencyiresponse personnel telephone numbers.
4.2.4
Damage C6ntrol/ Corrective Action and Maintenance Equipment
The NRC, inspector reviewed the Plan, Section G, " Emergency Response
,
Facilitics," and Secti.on L, " Recovery and Reentry".
e
procedure spetifically addresses the needs for onsite damage control
' -
correc,tive action and/or maintenance; equipment that existed at the time of
the apqraisal.
The licensee reported to the'NRC inspector that it was not
-
planning to' rely upon equipment-and in6truments from other offsite
'-
sources. ?he licensee does have an agreement letter with the~ Electric
Power Research Institute, Institute of Nuclear Power Operation, and the :,'
-
Atosic Industrial Forum ~should it become necessary to secure offsite
i
assistance.
The licensee does not currently have mutual assistance
j
agreements with.other nuclear power utilities.
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The primary source of reserve emergency supplies will be onsite stores. ~
,
,
The stored stock will be in addition to what is available in emergency
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kits.
As of the time of the appraisal, the minimum levels of emergency
supplies had not been determined.
The following are observations the NRC inspector called to the licensee's
.
attention.
These observations are neither violations nor unresolved
items.
These items a e recommended for licensee consideration for
improvement, but have no specific regulatory requirement.
,
l
Implement mutual assistance plans with other nuclear power utilities
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1
with the goal of ensuring a supply of compatible equipment and
'
instrumentation.
Estaalish minimum levels of emergency eq'uipment and instruments to be
-
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maintained casite.
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4
4.2.5
Reserve Emergency Supplies and Equipment
4.2.5.d Offsite Sources
The area of reserve. emergency supplies and equipment from outside sources
was reviewed with respect to the requirements of 10 CFR 50.47(b)(8);
10 CFR, Appendix E, paragraph IV.E; and the criteria in NUREG-0654,
Section II.H.
The licensee reported to the NRC inspector that STP does not intend to
rely on equipment and instruments from other offsite sources during an
emergency.
Based on the above findings, no deficiencies were identified in this area.
4.2.6 Transportation
The area of transportation available for emergency response was reviewed
with respect to the requirements of 10 CFR 50.47(b); 10 CFR 50,
Appendix E, paragraph IV.E; and the criteria in NUREG-0654, Revision 1,
Section II.H.
The NRC inspector reviewed the Plan, Section B, " Assignment of
Responsibility," Section H, " Accident Assessment"; and
Procedure OEPP02-ZA-0002, " Emergency Equipment."
No procedure pertaining to vehicles set aside to support an emergency
response existed at the time of this appraisal.
The NRC inspector conducted a walkthrough inspection of the licensee's
vehicles set aside to support a response to an emergency.
These vehicles
include:
two licensee owned ambulances, one rescue truck, one van and one
4-wheel drive utility truck.
The van is being outfitted as a mobile
counting laboratory.
The utility truck will be used by one of the field
monitoring teams.
All of the above vehicles contained fixed-in place
radios.
In addition, one small pickup has been identified as being available for
.use of the second field monitoring team.
It is not equipped with 4-wheel
drive, does not contain a fixed-in place radio and does not have a cover
to~ enclose the bed.
The licensee reported that the STP has available for
use,nine passenger cars with fixed-in place radios that would be available
to support an emergency response.
A key box system has been developed (but not operational at the time of
.the walkthrough inspection) which should ensure that keys to the principal
emergency vehicles will be readily available.
The two onsite ambulances and rescue truck are stationed near the onsite
first aid station.
The Rad-van and the two primary vehicles to be used
for field monitoring are routinely located at the Site Access Facility.
=
41
The following are observations th'e NRC inspector called to the licensee's
attention.
These observations are neither violations nor unresolved
items.
These items are recommended for licensee consideration for
improvement, but have no specific regulatory requirement.
Emergency vehicles to be provided by offsite support agencies should
-
be defined.
k
i
The feasibility of using an open bed, non 4-wheel drive vehicle for
-
field monitoring teams should be reevaluated.
-
A survey should be conducted to determine if portable hand-held
radios are satisfactory for communications with and between field
monitoring teams.
5.0 PROCEDURES
This area was reviewed with respect to the requirements of
10 CFR 50.47(b)(5) and (6); 10 CFR 50 Appendix E, paragraph IV.D; and the
criteria in NUREG-0654, Sections II.E, F, H, and J.
5.1 General Content and Format
A series of emergency plan procedures had been developed and approved at
the time of the appraisal. The licensee identified at least 12 additional
emergency plan procedures that are in varying degrees of preparation.
In
addition to the emergency plan procedures, other station procedures would
be utilized and implemented during response to a declared emergency.
These procedures include:
station et:orgency operating procedures; station
chemistry and radiochemistry procedures; station radiation protection
procedures; and station security procedures.
While the use of station procedures to support emergency plan procedures
,
l
is an acceptable practice, the appraisal team noted a number of referenced
l
station procedures that were not applicable under emergency conditions.
~
For example, emergency plan procedure, OEPP01-ZA-0005, " Radiological
!
Controls," states that station procedure OPRP08-ZC-0003, " Tool and
'
Equipment Decontamination," is the procedure to be used in decontaminating
vehicles as they exit the project during an emergency.
A review of the
-
latter procedure indicates it is totally inadequate as a procedure for
i
decontamination of vehicles.
Generically, the licensee intends to use
station radiation protection procedures as the procedures applicable to
l
'onsite, out-of plant and offsite monitoring during an emergency.
It was
j
the professional judgement of appraisal team members that this is not an
acceptable practice.
Appraisal team members identified a number of areas that may require
specific emergency procedures.
These include, but are not limited to, the
following: ' activation / operation of the backup E0C; emergency
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communication operability test program; emergency response organization
f..
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42
telephone directory (and call verification program); prompt notification
system test program; offsite support and assistance, and emergency
training and drills.
Some discrepancies, errors, and omissions were noted which made'the
emergency plan procedures and the Plan inconsistent with each other.
It
was the professional judgement of the appraisal team that the format of
the emergency plan procedures made _them difficult to understand and
follow.
Assignn:ent of the individual or organizational element having the
authority or responsibility for a procedure was not always specific.
.
^
, Based on the-above findings, the following deficiencies must be corrected
in order to achieve an acceptable program:
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Emergency' plan implementing procedures were not always consistent
with the Plan which they were implementing.
(498/8635-033;
499/8635-033)
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The licensee's emergency plan implementing procedures were-
incomplete, and normal station operating procedures used to implement
the' emergency plan failed, in many cases, to adequately address
emergency. conditions.
(498/8635-034; 499/8635-034)
No procedure had been provided to govern the activation, operation
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and deactivation of the TSC and E0C.
(498/8635-035; 499/8635-035)
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The OSC activation procedure lacked a policy statement on eating,
drinking, smoking, and chewing.
(498/8635-036; 499/8635-036)
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Procedures for assembly areas were not consistent with the Plan and
were incomplete.
(498/8635-037; 499/8635-037)
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A specific procedure had not been provided to implement and control
the decontamination of vehicles used offsite during an emergency.
(498/8635-038; 499/8635-038)
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HL&P had not designated the type, number, and location of protective
clothing units in an inventory procedure for each facility and
emergency kit, including the control room.
(498/8635-039;
i
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499/8635-039)
No procedure had been provided to govern the required testing of the
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emergency communications system and provide for periodic updating of
the offsite emergency response organization telephone numbers.
(498/8635-040; 499/8635-040)
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No procedures had been provided to ccntrol the use of vehicles
designated for use during an emergency.
(498/8635-041; 499/8635-041)
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(The'following'are observations the NRC inspectors called to the licensee's
'
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. ' attention. 'These, observations are neither violations nor unresolved
'
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- i tems.' Theie items-'are recommended for licensee consideration for
jiinprovement,' b'ut have no specific regulatory requirement.
_
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l Provide and employ ~a standard format for emergency plan implementing
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procedures.
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Generate a matrix of all Plan elements which require implementation
and the procedures written to implement those elements to identify
areas which have not been addressed by implementing procedures.
~5.2
Em'ergency,' Alarm, and Abnormal Occurrence Procedures
The area of emergency, alarm, and abnormal occurrence procedures was
reviewed with respect to the guidance of NRC Regulatory Guide 1.33,
" Quality Assurance Program Requirements (Operation)" and the criteria in
NUREG-0654, Sections 0, H, and I.
The NRC inspector noted that STP procedures were controlled by procedures
for preparation and approval of Reactor Operations Procedures
OPOPl-ZA-0002, and separate writers guide procedures for emergency
(OPOP1-ZA-0006) and off-normal (OPOP1-ZA-0007) procedures.
Each of the safety-related alarms was associated with an appropriate alarm
procedure.
The operator using those procedures was referenced (branched)
into an abnormal or emergency operating procedure.
At an appropriate step
in one of the procedures, further branching was made to the emergency plan
implementing procedures via reference to the potential need for
classification under OEPP01-ZA-0001, the emergency classification EPIP.
Although the branching had not been included in all procedures at the time
of this inspection, a program had been established to identify and include
branching wherever applicable.
This program, which is part of the
pre-licensing review program, was committed to be completed by fuel load.
The NRC inspector noted that retraining on procedure changes was
accomplished by first the designation of a reading file of changes and
then formal sessions in the operator requalification training.
Based on the above findings, no deficiencies were identified in this area.
,
5.3 Implementing Instructions
Since the NRC headquarters staff was conducting an ongoing technical
review of the STP emergency action' levels (EALs), the NRC inspector did
not review EPIP OEPP01-ZA-0001, " Emergency Classification." The NRC
inspector did review appropriate sections of the Plan and the other
implementing instructions, Procedures OEPP01-ZA-0009 (Revision 0),
.
" Notification of Unusual Event Implementing Actions," and OEPP01-ZA-0010,
'
" Alert, Site Area Emergency, General Emergency Implementing
Actions (Revision 0)."
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44
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iThe instructions were written to guide the Emergency Director (ED); his
authority and responsibility were defined as were the nondelegable duties
-
of the'ED. .EALs were defined although still in an iterative development
.
.
process as noted above.
There was no standa'd. format applied to the STP EPIPs. Although generally
r
the first paragraph stated the purpose of the procedure, thereafter any
semblance of standardization disappeared.
The NRC inspector noted the last sentence of the initial paragraph of Plan
page.E-2 incorrectly stated "The NRC is notified as soon as possible after
notification of state and local agencies or within one hour . . . ." This
statement did not' agree with the requirement stated in 10 CFR 50.72.
Table E-1 page 1 was printed twice, once with figure E-1 on the reverse
and once with table E-1, page 2 on the back.
Paragraph 4.1 of EPIP OEPP01-ZA-0009 (Revision 0) omitted consideration of
dose projections in determination of emergency classification; only plant
conditions were cited.
The NRC inspector recommended the addition of a
new paragraph 4.3: "4.3 Notification to the NRC shall be made immediately
after state and local notification and within one hour." The NRC
inspector noted that in the event of a NOVE, the ED was to direct security
to accomplish emergency response personnel notifications using
Procedure OEPP01-ZA-0004.
Paragraph 4.1.1 of that procedure required that
personnel listed on the ". . . appropriate Emergency Response Roster" be
notified.
No Emergency Response Roster existed; one was being developed.
In addition, the NRC inspector noted that a single procedure was used to
cover accidents classified as Alert, Site Area Emergency and General
Emergency.
Based on the above findings, the following deficiencies must be corrected
to achieve an acceptable program:
-
The Emergency Response Roster required by paragraph 4.1.1 of EPIP
OEPP01-2A-0004 had not been issued.
(498/8635-042; 499/8635-042)
-
The instructions for notification of the NRC in an emergency were not
consistent with the requirements of 10 CFR 50.72 (a)(3).
(498/8635-043; 499/8635-043)
The following are observations the NRC inspectors called to the licensee's
attention.
These observations are neither violations nor unresolved
items.
These items are recommended for licensee consideration for
improvement, but have no specific regulatory requirement.
-
Paragraph 4.1 of EPIP OEPP01-ZA-0009 should include considerations of
dose projections in determination of emergency classification.
!
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1
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45
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A new paragraph should be added to EPIP OEPP01-2A-0009 which states,
in effect, that notification to the NRC shall be made immediately
after state and local notification and within one hour.
Separate EPIPs should be issued for each of the four emergency
-
classifications, Notice of Unusual Event through General Emergency.
-
The EPIP procedure format should be standardized.
5.4 Implementing Procedures
5.4.1 Notifications
The area of notifications was reviewed with the respect to the
requirements of 10 CFR 50.47(b)(2)(5)(6), 10 CFR Appendix E IV C, 0.3.,
10 CFR 100.3 and the criteria of NUREG-0654, Sections E, F, H, and J.
The NRC inspector reviewed the notification section of OEPP01-ZA-0003,
" Emergency Offsite Notification," 0EPP01-ZA-0004, " Emergency Response
Personnel Notification," and OEPP01-ZA-0010, " Alert, Site Area Emergency,
General Emergency Implementing Actions." Following the declaration of a
Notification of Unusual Event (N0VE) the Security Manager was directed to
notify personnel listed on the appropriate Emergency Response Personnel
Callout form. There were two callout forms listed.
Form-01 for a NOUE
and Form-02 for an Alert or higher emergency class.
There was a message
form for relating standard messages to the emergency response personnel.
There was a column for pager notification; however, the notification
procedure did not address a pager system.
Additionally, the procedure had
not addressed personnel that were to be contacted on the first call and
what the caller should do toward contacting an alternate response team
member.
The NRC inspector noted that there had not been an emergency
'
personnel directory developed for all emergency response augmentation
personnel.
Personnel within the owner controlled property were to be notified by the
plant area public address system or by security guards in security
vehicles.
Security was to be responsible for contacting personnel outside
.the protected area and on the owner controlled property.
It should be
noted that the plant cooling reservoir had approximately 15 miles of
perimeter-that was not fenced and may be accessed through surrounding
property.
Additionally, portions of the owner controlled area had been
r leased to farming and cattle raising.
The NRC inspector determined that
notification, protected area evacuation, and owner controlled area
, evacuation-had not been addressed.
The licensee had installed one siren
near the cooling reservoir, however, the siren and its use had not been
-
-
described.
The NRC inspector noted that the protected area and owner controlled area
-
'
public address system had not been completely installed in all areas;
e.g., the E0C, the protected area, and Unit 2.
The evacuation tone had
been assigned, but not described in a procedure and a procedure written
i
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46
for instructing station personnel how to use and respond to the alert
system.
It was noted that notification of the onsite, offsite, federal,
state, and county governments was to be initiated upon-the declaration of
any emergency class.
The prompt public notification system may be
activated for alerting the general public upon the discretion of the the
state and county authorities.
However, it was noted that implementing
procedure for the prompt public notification system were incomplete.
State, county, and NRC telephone numbers were provided on a list.
The NRC inspector reviewed OEPP01-ZA-0004 titled, " Emergency Response
Personnel Callout - Alert or Higher." The personnel list for the
telephone book was incomplete and it was determined by review that the
telephone book was not included in the procedure and was to be completed
later.
Further, it was determined by procedure review and discussions
with selected emergency preparedness staff members that there was an
authentication scheme for initial notifications to the state.
Based on the above findings, the following deficiencies must be corrected
in order to achieve an acceptable program.
-
The implementing procedures for the prompt public notification system
were incomplete.
(498/8635-044; 499/8635-044)
-
The pager system indicated in OEPP01-2A-0004 had not been completed,
including the duty roster and pager distribution.
(498/8635-045;
499/8635-045)
The installation and testing of the protected area personnel
-
notification system was incomplete, and training and verifying that
the notification systeu could be heard by all onsite personnel had
not been conducted.
(498/8635-046; 499/8635-046)
-
An emergency response personnel call-out system, including a call out
directory for all emergency response personnel down to the working
level, had not been developed.
(498/8635-047; 499/8635-047)
The following are observations the NRC inspectors called to the licensee's
attention. These observations are neither violations nor unresolved
,
i
items.
These items are recommended for licensee consideration for
improvement, but have no specific regulatory requirement.
'
Consideration should be given to limiting the NOUE call-out list to
-
the plant manager or duty plant manager.
Additional personnel may be
notified on an as needed basis.
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The siren located near the reservoir area should be included in the
,
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notification procedure.
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5.4.2 Assessment Actions
The area of assessment actions was reviewed with respect to the
requirements of 10 CFR 50.47(b); 10 CFR 50, Appendix E, paragraph IV.B and
E; and the criteria in NUREG-0654, Sections II.H, I, J, and K.
The NRC inspector reviewed Sections C, D, F, G, and H of the
Plan (Revision 3 unless otherwise stated), Chapter 15 of the FSAR, and the
following EPIPs:
OEPP01-ZA-0001 (Revision 1), " Classification"
OEPP01-ZA-0002 (Revision 1), " Emergency Direction"
OPGP03-ZF-0001 (Revision 0), " Fire Protection Program"
OPGP03-ZF-0011 (Revision 0), "STP Fire Brigade" OPGP03-ZO-0011
(Revision 0), " Radiation Protection Program"
Since NRC headquarters was conducting the acceptance review of the Plan
and an ongoing technical review of the STP Emergency Action Levels in
Section D of the Plan and EPIP OEPP01-ZA-0001, the NRC inspector chose to
restrict findings to non-technical matters and apparent problems with
implementation of the Plan and EPIPs.
The NRC inspector reviewed assessment related organization and staffing as
shown in the Plan and noted that the TSC managar never assumed the
responsibility and authority of the Emergency Director (ED); instead the
TSC functioned in an advisory and coordination role. An inconsistency
existed concerning assignment of the responsibility for station management
as shown oa pages F-7 and F-11 and figure F-1, pages 2 and 3 in that it
rested with the ED during a NOVE, SAE, or GE classification, but with the
TSC during the an alert prior to E0C activation, although the ED function
was assigned to the control room.
The NRC inspector noted that the normal organization shown in figure C-1
appeared to be outdated since it was inconsistent with the station
organization provided to the NRC appraisal team at the entrance meeting.
l
The emergency response organizations shown in figures B-2 and C-3
differed; the EOC communicator was omitted from the latter and the
l
reporting senior over the OSC coordinator varied between the two figures.
The control room was not included in ERF staffing table C-3, although it
was designated an ERF and inclusion would demonstrate assignments such as
l
shift supervisor /ED, lead HP technician / dose assessment, auxiliary
l
operator / communicator, etc.
Neither the plant manager nor the plant
!
superintendent were assigned a primary role in the emergency organization;
in the staffing diagram shown on table C-3, page 1, they were assigned
only as alternate E0C EDs.
.
It was not clear when the E0C was required to activate.
Figure C-3
l
indicated activation at alert as did paragraph C.S.1.e while
paragraph D.3.2 indicated that only the TSC and OSC activate at alert.
l
1
l
l
!
48
During the EPIP review, the NRC inspector noted that no single procedure
'
orchestrated the information gathering and decisionmaking process.
Instead, the individual assigned overall responsibility for directing the
assessment' program required movement among a number of procedures.
For
example, the Emergency Director classifies the accident using
Procedure OEPP01-ZA-0001, then exits to Procedure OEPP01-ZA-002,
" Emergency Direction," which serves as a master ED checklist at all
classifications and concurrently exits to a procedurr. unique to the
particular classification, either OEPP01-ZA-0009 or -0010.
The NRC inspector noted that there was no TSC activation EPIP.
In
addition, conflict existed concerning composition of the fire brigade as
described in Procedure OPGP03-ZF-0001 (Revision 0), which indicated that
"the brigade is composed of 5 members of the Chemops department" and
procedure OPGP03-2F-0011 (Revision 0) which indicated that "the brigade
consists of the Chemops foreman and 4 others from Chemops or auxiliary
operators.
Paragraph 3.1.3 of OPGP03-ZR-0001 (Revision 0) was also
incomplete.
As noted in Section 4.1.1.1 of this report, the NRC inspector found the
QDPS and ERFDADS systems referred to in the EPIPs to be inoperative.
The
licensee's procedures for assessing offsite radiological doses were
reviewed.
The pertinent procedure was OEPP01-ZA-0008, Revision 0, " Dose
,
Calculations and Protective Action Recommendations." The inspector
determined that the licensee has procedures for two of the three
independent methods of dose calculation.
The primary method for offsite dose assessment is the RM-21A Dose
Assessment System.
This is a computerized system which automatically
gathers and uses real time plant parameter data in its dose calculation
program.
When fully installed, terminals will be located in the TSC and
in the E0C.
At the ti!ne of this inspection, the primary dose assessment
system was not operat.onal and this method of dose calculation was not
assessed.
The secondary method was a computer calculation on a personal
computer (PC) using the program IRDAM.
The licensee's IRDAM code was
modified slightly to include several site specific parameters.
Several
PCs capable of running the IRDAM program were observed in the E0C and at
several other locations in the plant.
The licensee had no approved
procedure to perform dose calculations with the IRDAM program at the time
of the inspection.
The final backup method was a manual calculation method included in
OEPP01-ZA-0008, Revision 0.
The procedure was observed to be adequate,
but needed to be edited and reviewed with respect to human engineering
factors.
Based on the above findings, the following deficiencies must be corrected
to achieve an acceptable program:
_
's
-
49
.
'Thh licensee's. primary method of performing offsite dose calculations
-
(RM-21A) was not operational, thus the assessment
^
Procedure OEPP01-ZA-0008, Revision 0, had not been tested.
(498/8635-048; 449/8635-048)
-
The licensee had no approved procedure for performing backup dose
calculations using the IRDAM code.
(498/8635-049; 499/8635-049)
-
Provisions for activation of the EOC were not consistent in
describing when the E0C was required to be activated.
(498/8635-050;
499/8635-050)
-
Inconsistencies were noted in the normal and emergency response
organization, and the assignment of station management
responsibilities, as described in various sections of the Plan.
(498/8635-051; 499/8635-051)
The following are observations the NRC inspectors called to the licensee's
attention.
These observations are neither violations nor unresolved
items.
These items are recommended for licensee consideration for
improvement, but have no specific regulatory requirement.
-
Reconcile inconsistencies in the normal and emergency organization,
and the assignment of station management responsibility described in
the Plan and implemented in the EPIPs.
Reconcile differences in describing STP plans for when E0C activation
-
is required in the Plan and EPIPs.
Consider assigning the plant manager or plant superintendent as TSC
-
director when they are not required to function as Emergency
Director.
Clarify the fire brigade composition inconsistency between
-
Procedures OPGP03-ZF-0001 and OPGP03-ZF-0011.
Complete
paragraph 3.1.3 of Procedure OPGP03-ZR-0001.
-
the manual dose calculation procedure, OEPP01-ZA-0008, Revision 0,
should be edited or upgraded to include human engineering factors.
l
l
5.4.2.1
Offsite Radiological Surveys
The offsite radiological survey procedures were reviewed with respect te
the requirements of 10 CFR 50.47(b)(8); 10 CFR 50, Appendix E,
paragraph IV.B and E; and the criteria in NUREG-0654, Sections II.H, I,
l
and K.
!
The NRC inspector reviewed the licensee's offsite radiological survey
procedures to be used during an emergency.
The two procedures designated
l
were 0FRP04-ZS-0002, Revision 1, " Radiation Survey Methods," and
[
OPRP04-ZS-0004, Revision 1, " Airborne Radioactive Material Survey
l
,
>
50
Methods." These two procedures were written for routine inplant
.
radiological surveys and were observed to be inadequate and inappropriate
for offsite surveys.
Specifically missing in the procedures are survey
data sheets, information on use of instruments in relatively high
radiation fields, instructions on instrument use in adverse weather
conditions, use of instruments in locating the plume centerline and an
overhead plume, and information on performing surveys consistently with
all offsite licensee monitoring teams that also allows for maximum use of
survey data.
In addition, an overall procedure governing offsite monitoring activities
did not exist.
Some example items that should be included in such a
procedure are specific locations of field monitoring kits, a requirement
to inventory kit supplies and source-check instruments prior to leaving
the site, instructions on how to secure the appropriate transportation,
instructions for personnel protection, and instructions on sample and data
sheet disposition.
Based on above findings, the following deficiency must be corrected to
achieve an acceptable program:
Procedures had not been provided to govern offsite radiological
-
monitoring activities, including personnel protection measures.
(498/8635-052; 499/8635-052)
5.4.2.2
Onsite (Out-of-Plant) Radiological Surveys
The onsite radiological survey procedures were reviewed with respect to
the requirements of 10 CFR 50.47(b)(8), (9), and (11); 10 CFR 50,
Appendix E, paragraphs IV.B and E; and the critaria in NUREG-0654,
Sections II.H, I, and K.
The NRC inspector reviewed the licensee's onsite radiological survey
procedures to be used during an emergency.
The two procedures designated
~
4
by radiation protection staff were OPRP04-ZS-0002, Revision 1, " Radiation
Survey Methods," and OPRP04-ZS-0004, Revision 1, " Airborne Radioactive
Material Survey Methods." Actually, the licensee had no procedure for
radiological sampling and monitoring in the owner-controlled area outside
of the facility.
The two procedures specified were written for routine inplant radiological
surveys and were observed to be inadequate and inappropriate for onsite
(out-of plant) surveys.
Specifically missing in the procedures were
survey data sheets, information on the use of instruments in relatively
high radiation fields, instructions on instrument use in adverse weather
conditions, use of instruments in locating an overhead plume, and
information on performing surveys consistently among all licensee onsite
monitoring teams that also allows for maximum use of survey data.
In addition, an overall procedure governing onsite monitoring activities
did not exist.
Some example items that should be included in such a
.- _
51
procedure are specific locations of monitoring kits, a requirement to
inventory kit supplies and source-check instruments prior to using kit
items, instructions on how to secure the appropriate transportation,
instructions for personnel protection, and instructions on sample and data
sheet disposition.
Based on the above findings, the following deficiency must be corrected to
achieve an acceptable program:
-
Procedures had not been provided to govern onsite, out-of plant
radiological monitoring activities.
(498/8635-053; 499/8635-053)
5.4.3
Protective Actions
5.4.3.2
Evacuation of Owner-Controlled Area
The area of evacuation of nonessential personnel areas was reviewed with
respect to the requirements of 10 CFR 50.47(b) and the criteria in
The NRC inspector reviewed the Plan, Section F, " Emergency Actions and
Measures and Procedure," and OEPP01-ZA-0007, " Accountability / Evacuation."
Evacuations were to be determined by the Emergency Director (ED).
If a
radiological release has not occurred the ED may elect to send site
personnel offsite before there is a danger of radiation exposure.
Personnel were to be dismissed in a preferred order.
The procedure did
not allow for isolated areas to be evacuated, identification of radiaticii
limits including direct radiation and airborne contamination limits,
evacuation without assembly, and required evacuation of all non-essential
personnel at a Site Area Emergency.
During protected area evacuations,
personnel were to be instructed to evacuate, via the public address
system, to a designated reassembly area.
The evacuation point and
assembly point will be chosen by the ED with consideration of the
potential hazard threat and the wind direction.
There were no markings of
the primary or secondary evacuation routes.
The procedure included a
reference to the accountability, and personnel monitoring and
decontamination procedures.
In addition, the procedures included a means
of verifying that all individuals in the protected area onsite had been
warned of the emergency conditions and had followed instructions regarding
their actions.
The ED woulu request security officers to tour the owner
'
controlled area, using vehicles, to warn anyone present in trailers and
buildings to evacuate immediately.
The NRC inspector noted that security
-
vehicles were not equipped with the capability to instruct persons via a
vehicle installed public address system.
Based on the above findings, the following deficiencies must be corrected
in order to achieve an acceptable program:
I
- _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ - __.
52
-
Procedures had not been developed to verify and maintain the facility
public address system such that all personnel within the owner
controlled area can be given warning and verbal instructions in an
emergency.
(498/8635-054; 499/8635-054)
Provisions had not been made for notification and evacuation of the
-
owner controlled area (including Unit 2 and the reservoir area).
(498/8635-055; 499/8635-055)
The following are observations the NRC inspectors call to the licensee's
attention.
These obcervations are neither violations nor unresolved
'
iitems. These items are recommended for licensee consideration for
improvement, but have'no specific regulatory requirement.
Markers for the primary and secondary evacuation routes should be
-
'provided.
~
'
.
i
.
- ,' Provisions for security officers to give verbal instructions from
their vehicles to personnel in trailers and buildings should be
^ developed.
5.4.3.3
Personnel Accountability
The area of personnel accountability was reviewed with respect to the
requirements of 10 CFR 50.47(b)(10) and the criteria in NUREG-0654,
Section J.5.
The NRC inspector reviewed the Plan,Section I, and OEPP01-ZA-0007,
" Evacuation / Accountability." The Plan and EPIP stated that personnel
accountability would provide a full accounting of all individuals or
identify missing individuals within 30 minutes from the time the
accountability process was initiated.
Missing persons would be determined
and accounted for within one hour.
Security would periodically update the
computer list for access and egress from the evacuated area, if it was
controlled by key card, and report any significant information to the
security personnel performing personnel accountability.
The NRC inspector
noted that OEPP01-ZA-0007 did not specifically direct that personnel
accountability be maintained throughout the duration of the emergency
condition in the protected area, to include personnel in the control room,
The accountability procedure also did not identify how
continuous accountability would be maintained in the control room, TSC,
OSC, and E0C.
OEPP01-ZA-0007 specified the positions in the emergency organization to
whom reports of personnel accountability were to be made.
The NRC
inspector noted that the ED, on determining the need for initiating the
accountability process, would notify the security manager who would direct
the security shift supervisor to perform an accountability of personnel
remaining in the protected area.
The security officer would initiate the
automatic computer card reader method; however, the card reader and
computer system was not completely installed and operable.
The
- _ _ _ _ - _ _ _
53
_
information was being gathered on computer and printed out to the security
shift supervisor.
Additionally, security guards would be dispatched to
,
search the administration building and trailer area for personnel.
OEPP01-ZA-0007, Section 4.13, stated that assembly and accountability per
this procedure shall be accomplished prior to any evacuation or dismissal.
In a situation of an immediate radiological or chemical release an
alternate plan for accountability should be developed.
The Plan or
procedure did not address evacuation and accountability for Unit 2
construction site STP and contractor personnel that will be located on
HL&P property, but outside the protected area.
OEPP01-ZA-0007 stated that
.Section 5.10 addressed an alternate method for accountability if the
- electronic security computer was out of service.
The NRC inspector
reviewed Section 5.10 of EPP01-ZA-0007 and noted that security personnel
are to gather the badges of employees and account for personnel by
determining from missing badges those persons that'are missing.
The
security officer was to report the accountability progress to the
emergency director.
Based on the above findings, the following deficiency must be corrected in
order to achieve an acceptable program:
The installation, testing, and implementation of the security access
-
and accountability system, which would be employed in an emergency,
had not been completed.
(498/8635-056; 499/8635-056)
The following are observations the NRC inspectors call to the licensee's
attention.
These observations are neither violations nor unresolved
items.
These items are recommended for licensee consideration for
improvement, but have no specific regulatory requirement.
The " Accountability / Evacuation" procedure should address how
-
accountability would be maintained through the duration of the
emergency in the control room, OSC, TSC, and Unit 2 construction
area.
-
A drill should be conducted verifying that personnel accountability,
which includes identification of all personnel in the protected area,
could be accomplished within 30 minutes and missing persons found
within one hour.
5.4.3.4
Personnel Monitoring and Decontamination
The area of personnel monitoring and decontamination was reviewed with
respect to the requirements of 10 CFR 50.47(b)(10); 10 CFR 50, Appendix E,
paragraph IV.B; and the criteria in NUREG-0654, Sections II.J, K, and L.
The NRC inspector reviewed the licensee's Plan and procedures pertaining
'
to monitoring and decontamination of personnel outside of the normal
control point.
Revision 3 of the Emergency Plan states that amergency
l
,
.,
~
9
'
s
,
-
54
,
.,
e
, un
deconktaminationwilloccurattheaccesscontrolfacilityand/oratthe
"
EOC. . Decontamination capabilities at other assembly / reassembly areas were
i
d
.not ment one .
s
s
"Prodedure OEPP01-ZA-0007, " Accountability / Evacuation," calls for evacuated
plant personnel to be monitored at the reassembly area prior to being
released from duty.
Radiation emergency teams are required to perform the
monitoring; however, the licensee had no plans for assuring that
appropriate equipment, supplies, decon water, and water collection will be
available at the reassembly area.
Procedure OPRP08-ZC-0002, Revision 2, " Personnel Decontamination," is the
procedure that governs decontamination efforts.
This procedure gives
basic instructions on decontaminating skin and provides forms for
documenting contamination levels, actions taken, results, and follc.iup
actions.
The procedure does not, however, provide skin contamination,
levels that must be decontaminated or a reference to normal plant
Procedure PRP2-ZB-04, Revision 0, " Radioactive Contamination and Airborne
Radioactivity Guides and Limits."
Based on the above findings, the following deficiencies must be corrected
to achieve an acceptable program:
Procedures for personnel monitoring and decontamination were not
-
adequate to address emergency needs outside of the normal
radiological controlled area.
(498/8635-057; 499/8635-057)
The licensee had no plans or dedicated equipment for personnel
-
monitoring at assembly / reassembly areas.
(498/8635-058;
499/8635-058)
In addition, the following is an observation the NRC inspectors called to
the licensee's attention.
This observation is neither a violation nor
unresolved item.
This item was recommended for licensee consideration for
improvement, but has no specific regulatory requirement.
-
Procedure OPRP08-ZC-0002, Revision 2, " Personnel Decontamination,"
should specify a level for personnel contamination and reference a
definition of personnel contamination.
5.4.4
Security During Emergencies
The area of security during emergencies was reviewed with respect to
10 CFR 73, Appendix C and 10 CFR 100.3(a).
The NRC inspector toured the security offices, the east gate access
portal (EGAP), the central alarm station (CAS), the secondary alarm
station (SAS) contained within the EGAP, reviewed the Plan, Section F, and
Procedure OEPP01-ZA-0007, " Accountability / Evacuation."
55
In addition, the NRC inspector discussed security during emergencies with
members of the HL&P security force.
Since there are other NRC inspection
programs which ctver the safeguards aspects of the security program, to
avoid the possibility of inadvertent inclusion of safeguards information
in this report, the inspectors chose not to review the HL&P security plan
and procedures.
The NRC inspector noted that no habitability requirements were imposed
upon the EGAP, CAS, or SAS, nor had any been designed into these
facilities.
The absence of any special habitability features means that
contingency provisions must be made for the continuation of the access or
egress process during a radiological or chemical accident.
Procedures had
not been developed to describe how the alarm station functions would be
assumed by the CAS or SAS, whichever survived, and how the personnel
access processing function would be shifted to an alternate location along
the protected area perimeter or CAS.
Neither the Plan, Section F, nor the
accountability / evacuation procedure described personnel access or exit
gates and plant evacuation routes for leaving the protected area during
plant evacuation.
The Plan contained an example of how personnel may be
instructed to evacuate, however, neither the Plan or procedures were
descriptive of primary and alternate evacuation routes.
The NRC inspector noted that off-hours access to the EOC did not appear to
be a problem if the present security access control to the E0C is
maintained as was demonstrated during this inspection.
Neither the card reader system nor protected area access control measures
were implemented at the time of the appraisal.
The badge racks which form
an integral part of the manual accountability system had not been
installed at the EGAP.
Although GET included tne security requirements
for access to the protected area, not all of the STP or construction
employees had received GET training in the use of the system.
The NRC inspector noted that all guards were from a contracted security
force.
The nuclear security force contract was administered by STP with
Wackenhut Corporation.
Security was managed by HL&P management employees.
8,ased on the,above findings, the following deficiency must be corrected to
achieve an acceptable program:
, , . -
Procedures had not been developed to support response to a
-
s
radiological emergency and govern radiological protection for the
security force in an emergency.
(498/8635-059; 499/8635-059)
5.4.5 Repair / Corrective Actions
The area of repair /cor.ective actions was reviewed with respect to the
requirements of 10 CFR 50.47(b)(3); 10 CFR, Appendix E, paragraph IV.H;
and the criteria in NUREG-0654,Section II.K.
56
The NRC inspector reviewed the Plan, Section C, " Organizational Control of
Emergencies," Section G, " Emergency Response Facilities," Section H,
" Accident Assessment," Section J, " Radiological Exposure Control,"
Section L, " Recovery and Reentry"; Procedures OEPP01-ZA-0005,
" Radiological Control," 0EPP01-ZA-0006, " Search and Rescue / Contaminated
Injuries," and OEPP021-ZA-0002, " Emergency Equipment."
Procedure OEPP01-ZA-0005, " Radiological Control," provides guidelines and
policies for the radiological program in effect during a declared
emergency condition.
Procedures do not appear to exist that describe the
concept of operations for damage control, repair or corrective action
activities.
The individual to whom the team will report and the steps to
assure that individuals are properly briefed as to radiological
conditions, stay times, plan of action, etc., prior to the conduct of the
operation are not presently included in the emergency procedures.
Based on the above findings, the following deficiency must be corrected in
order to achieve an acceptable program:
Procedures had not been provided that describe the concept of
-
operations for damage control / repair or corrective action activities.
(498/8635-060; 499/8635-060)
5.4.6
Recovery
This area was reviewed with respect to the requirements of
10 CFR 50.47(b)(13); 10 CFR 50, Appendix E, paragraph IV.H; and the
criteria in NUREG-0654,Section II.M.
The NRC inspector reviewed Section L of the Plan and EPIP OEPP01-ZA-0011
(Revision 0), " Recovery Operations," and found that the Plan failed to
define minimum prerequisites for entry into recovery mode and did not
require establishing a method for periodic estimates of total population
exposure.
The procedure was deficient in that listing of prerequisite
conditions for entry into recovery did not include a requirement for
stable plant conditions.
In addition, the procedure did not require
'
establishing a method for periodic estimates of total population exposure.
No requirement existed.for coordination with the NRC, state, and local
.
agencies prior to deescalation or initiation of recovery as was required
l
by paragraph 1.5 of the Plan.
The NRC inspector also noted that the EPIP did not implement completely
the stated purpose of the Plan.
One stated purpose of Section L of the
Plan was ". . .'to discuss the requirements . . . of reentry into
evacuated areas of the station . . . "; however, except for tasking
imposed upon the Radiological Director to search for 10 CFR 20 violations
and to " determine reentry criteria for onsite areas that have been
evacuated," the procedure neglected reentry into evacuated areas of the
station and recovery planning responsibilities.
Issues not addressed
included damage assessment and control, limiting conditions for
operation (LCO) review, safeguards verification, followup reporting,
l
-
_
-.
,~
57
records collection, surveys and sampling, traffic routing, toxic / flammable
gas monitoring, RWP issue, posting, decontamination, equipment tagout,
special reentry procedure development, whole body counting, TLD reissue,
etc.
Based cn the above findings, the following deficiency must be corrected-to
achieve an acceptable program:
-
The provisions for and implementing procedures did not adequately
-
address recovery and reentry.
(498/8635-061; 499/8635-061)
5.4.7 Public Information
The area of public information procedures was reviewed with respect to the
requirements of 10 CFR 50.47(b)(7); 10 CFR 50, Appendix E, paragraph IV.D;
and the criteria in NUREG-0654.
The NRC inspector reviewed Section K of the Plan, and the EPIP.
The EPIP identified the organization responsible for news dissemination,
.
but not the individual news media organizations that accomplishes the
task.
The commercial news agency that distributes the news releases to a
predetermined news media list, not included in the EPIP, was identified
along with their telephone number.
No individual news media or news media
personnel were identified. The method for coordinating the internal
dissemination of information to the various locations and individuals has
not been clearly specified.
Interim provisions for initial dissemination
of information to the news media prior to establishment of the licensee's
news center has been clearly provided for in the EPIP. While the
licensee's principal spokesman has been identified an alternate spokesman
has not been selected.
Adequate provisions of coordinating information
among the various spokesmen of the various organizations and groups have
been made.
Provisions for rumor control appear to be adequate.
Base ( on the above findings, the following deficiencies must be corrected
in order to achieve an acceptable program.
Individual news media, including name and address, to be contacted by
-
the commercial news wire service selected to disseminate the news
releases, and the name of a principal contact were not provided.
(498/8635-062; 499/8635-062)
The method for coordinating internal dissemination of news
-
information had not been clearly specified.
(498/8635-063;
499/8635-063)
,
An alternate principal HL&P spokesperson had not been identified.
-
(498/8635-064; 499/8635-064)
I
I
58
5.5 Supplementary Procedures
The inventory, operational check, and calibration procedures were reviewed
with respect to the requirements of 10 CFR 50.47(b)(8); 10 CFR 50,
Appendix E, paragraph IV.E; and the criteria in NUREG 0654,Section II.H.
The NRC inspector reviewed Procedure OEPP02-ZA-0002, Revision 0,
" Emergency Equipment." The procedure calls for a quarterly inventory of
emergency equipment stored in emergency facilities.
In addition, a
monthly inspection of locker lock-seals and a 6-month battery replacement
is required.
The health and safety services manager and the emergency and
safety services supervisor have responsibility to schedule and perform the
periodic inventories.
The inspector noted several inadequacies in the procedure which could
render the procedure ineffective.
The procedure did not specify any
corrective actions to be taken when an instrument fails either an
operational check or a battery check.
A " battery check only" was required
for "radiac instruments," but no source response check was required.
Radiological instruments on the inventory list were designated by a
general term (e.g., Ion Chamber, Frisker, etc.) allowing for the
possibility of replacing instruments with those having lesser
capabilities. Offsite and onsite radiological monitoring kit inventories
were not included in the procedure.
Emergency supplies and equipment
stored in the control room and at Wagner General Hospital were also not
included in the procedure.
Finally, some of the inventory lists lacked
necessary equipment and supplies (e.g. , emergency dosimetry, batteries,
protective clothing, etc.).
Based on the above findings, the following deficiencies must be corrected
to achieve an acceptable program:
The procedure governing inventory, operational check, and calibration
-
of emergency equipment was not adequate to assure that emergency
instrumentation would be available and functional.
(498/8635-065;
499/8635-065)
The emergency equipment inventory lists did not include onsite and
-
offsite monitoring kits, and did not include necessary equipment and
supplies.
(498/8635-066; 499/8635-066)
The following are observations the NRC inspectors call to the licensee's
attention.
These observations are neither violations nor unresolved
items.
These items are recommended for licensee consideration for
improvement, but have no specific regulatory requirement.
-
In the emergency equipment procedure, corrective actions to be taken
when an instrument either fails an operational check or a battery
check should be specified.
m .. , ,
'
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'
,
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-
,
,
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-
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59
-
,
,
.
s
,
rri
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4
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+?*
4
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'
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(
,,i The emergency equipment procedure should require an instrument
L
,
response check in addition to a battery check.
,
, ,
Inventory lists in the emergency equipment procedure should be
-
. written to insure that replacement -instruments do not provide a
<
lesser detection,l measurement, or sampling capability.
-
Emergency equipment inventory lists should include both onsite and
offsite monitoring kits or emergency equipment stored in the control
~
. room and Wagner General Hospital.
-
Emergency' equipment lists should be reviewed and revised to include
all necessary equipment and supplies.
5.5.2 Drills and Exercises
The area of drills and exercises was reviewed with respect to the
requirements of 10 CFR 50, Appendix E, paragraph IV.D.3, E, F, and H; and
the~ criteria of NUREG-0654,Section II.N.
The NRC inspector noted that the licensee's drill and exercise program was
documented in the Plan, Section N, and in Procedure OEPP02-ZA-0003,
" Emergency Drills and Exercises." The procedure included drill
requirements for communications, health physics, radiological monitoring,
medical response, and the annual radiological emergency exercise.
Drills
and exercises were administered by the EPD.
Provisions were included for
classification of the drills, scheduling, scenario development,
';
notification where necessary, pre-drills briefings, post-drill critique,
and documentation.
Corrective actions for weaknesses identified were
considered and included.
,
The NRC inspector noted that the procedure did not include provisions for
,
fire drills, although they were included in the Plan, Section N, and the
FSAR, Section 9.5.1.6.
Provisions were included to invite offsite groups
and agencies to participate in appropriate drills and exercises.
Requirements for off-hours and unannounced drills were discussed in the
procedure.
I
The NRC inspector determined that news media coverage of the annual
exercise would be provided via the corporate public affairs department
located in Houston, and this was included in exercise checklists.
Based on the above findings, no deficiencies were identified in this area.
5.5.3
Review, Revision, and Distribution of Emergency Plan and Procedures
The areas of review, revision, and distribution of the Plan were reviewed
t
with respect to the requirements of 10 CFR 50.47(b)(16); 10 CFR 50.54(q)
and (t); 10 CFR 50, Appendix E, paragraph IV.G and V; and the criteria in
l
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60
The NRC inspector reviewed the Plan, Section 0, " Emergency Plan," and
OPGP03-ZA-0013, " Maintenance and Distribution of Controlled Documents,"
and other related documents.
The NRC inspector discussed the content of
the document control procedures with the supervisor, Operations. Document
Control Center (0DCC).
HL&P maintained two separate document control
distribution list for emergency preparedness procedures; level one and
level two.
The level one document control list indicated that documents
were to be placed in Unit 1 and Unit 2 Control Rooms, TSC records room and
E0C record room.
The level one documents were to be placed in the above
mentioned areas by ODCC personnel within one workday of the effective
date.
Level two documents were to be distributed to an approved list of
HL&P personnel within 3 workdays of the effective date.
Recipients of the
level two documents were to sign an acknowledgment receipt form stating
that the recipient had updated their document.
The signed acknowledgement
sheet was to be returned to document control within five days.
Persons
failing to return the acknowledgement sheet would be sent a series of two
reminders from ODCC.
if the reminders were not answered, the plant
manager may take remedial action as deemed necessary.. The Plan,
Section 0.2.9, stated that persons failing to sign and return receipts
would be requested to return the receipt or the document.
In either case
no time limit had been established for the process of notification,
renotification, the plant managers remedial action, or return of the
controlled document.
The NRC inspector reviewed random response sheet
samples of 34 persons listed on the level 2 document control list.
Response from one sampling had approximately 40 percent returned signed
receipts.
Another list of receipts indicated approximately 35 percent had
returned the signed receipts.
Document control did not have a controlled
distribution list for initial distribution of the Plan, procedures, and
changes to those documents for state, county, public document room, or the
NRC as required in 10 CFR 50, Appendix E, Section V.
Distribution of the
emergency procedures was accomplished in accordance with
Procedure OPGP03-ZA-001.
The Plan, Section 0. specified that the Plan and
EPIPs would l'e reviewed and updated annually and was the responsibility of
the Emergency and Safety Services Supervisor.
In addition, the state and
county would participate in the annual review.
Review of PORC minutes for meetings held during May and June of 1985, and
six meetings' held during 1986, revealed nothing indicating a
10 CFR 50.54(q) review-having been conducted for the Plan or that the
'
, proposed changes had been reviewed for decreasing the effectiveness of the
plans'by the person proposing the changes.
Further, letters sent to the
NRC project manager dated October 15, 1986, and November 20, 1986, did not
indicate that a review had been conducted'to determine that the changes
did not decrease the effectiveness of the plans and that the plans, as
changed, continued to meet the standards ~in paragraph 50.54(b) and
Appendix E of the regulations.
This indicated that the Plan change
control was not being implemented as would be required after an operating
licensee is issued.
The NRC inspector determined that the Quality Assurance Department would
conduct an independent review of the emergency preparedness program on an
-. . _ _ - - _ _ _ _ _ . _ _
_
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_ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ - _
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,
61
annual basis (the NRC inspector noted that 10 CFR 50.54(t) requires an
assessment every 12 months). The audit would take into account the
results of drills and exercises, changes in HL&P and State of Texas policy
and plans, and various agreements with offsite agencies. .An annual review
had not been conducted for either the Plan or EPIPs; however, specific.
'
sections of the Plan had been reviewed, revised, approved, and updated.
Based on the above findings,.the following deficiency must be corrected to
achieve an acceptable program:
Procedures had not been provided for Plan change review and submittal
-
to-the NRC to meet the requirements of 10 CFR 50.54(q).
(498/8635-067; 499/8635-067)
The following are observations the NRC inspectors call to the licensee's
attention. These observations are neither violations nor unresolved
items.
These items are recommended for licensee consideration for
improvement, but have no specific regulatory requirement.
-
The document control procedure should be revised to strengthen the
action taken in regard to delinquent responders to the document
control receipt, in agreement with the Plan.
A controlled document distribution list should be developed for
-
i
sending appropriate documents to agencies outside of HP&L.
t.
Letters transmitting Plan and procedures to the NRC should include a
-
statement documenting the 10 CFR 50.54(q) review conducted, and
.
status concerning the results of the review.
5.5.4 A'udits.of Emergency Preparedness
The. area o'f audits'was reviewed with respect to the requirements of
,10 CFR'50.54(q) and (t) and the criteria in NUREG-0654,Section II.P.9.
j
3
'
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)TheNRCrinspectors.revie$edthePlan,Section0,"EmergencyPreparedness,"
!
'and discussed the audit process with Quality Assurance (QA) and selected
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4
plant staff.
The Plan stated that STP would arrange for an annual review,
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7
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audit,!and updating of the Plan and procedures.
The review would consider
,
findings from the annual independent audit findings.
The review of the
-.
emergency prep'aredness program was to include the Plan, EPIPs, training,
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drills,'and exercises, equipment maintenance and interface with federal,
state.-and local governments.
The results of the audit findings would be
forwarded to the Emergency and Safety Services Supervisor for action.
The
,
recommended actions are to be forwarded to the plant manager for review
'
!
and forwarded to the Plant Operations Review Committee (PORC) for a
l
recommendation of approval.
Upon approval by the plant manager, the
i
recommendations were to be implemented. All documentation of
recommendations and reviews would be retained for a period of five years.
l
Additionally, the Plan was to be submitted to the state and county
i
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,
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- _ _ _ _ _ _ _ _ _ _
62
authorities on an annual basis for review.
Comments from this review were
to be discussed between various organizations and incorporated in the
Plan.
The NRC inspector noted that the Plan did identify the organization that
would conduct the independent audit as the Station Operations Quality
Assurance Department (S0QAD).
The 50QAD performed all internal audits for
STP.
Procedures did not exist for directing the SGQAD staff in any
emergency preparedness program or annual audit activities.
Procedures
also did not exist to direct the auditors to review, for instance, NRC
regulatory requirements (e.g., 10 CFR 50.54 (t)) and guidance criteria
(e.g., NUREG-0654), observe emergency drills and exercises, inspection of
equipment, conduct interviews with emergency response personnel, onsite
and offsite training, and coordination with offsite authorities.
The Plan
specified that an annual audit would be conducted, however,
10 CFR 50.54 (t) and NUREG-0654,Section II.P.9. stated that an
independent audit should be conducted at least every 12 months.
10 CFR 50.54 (t) states that the 12 month review of the emergency
k
preparedness program is to be conducted by persons who have no direct
responsibility for implementation of the emergency preparedness program;
however, the NRC inspector noted that voting members of the PORC, which
recommend approval for the Plan and EPIPs, included the manager of S0QAD.
Based on the above findings, the following deficiencies must be corrected
in order to achieve an acceptable program:
Procedures had not been provided to describe how the 12-month
-
independent review and audit of the emergency preparedness program
would be conducted.
(498/8635-068; 499/8635-068)
-
The Operations Quality Assurance Department was not independent of
implementation of the emergency preparedness program as the manager
was a member of PORC, which reviewed and recommended approval of the
Plan and procedures.
(498/8635-069; 499/8635-069)
The following are observations the NRC inspectors call to the licensee's
attention.
These observations are neither violations nor unresolved
items.
These items are recommended for licensee consideration for
improvement, but have no specific regulatory requirements.
The Vice President, Nuclear should be identified as a recipient of a
-
copy of the 12-month program review and the annual audit report.
Results of the 12-month review related to offsite agencies should be
-
sent to the agencies and corrective actions required identified.
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6.1' Offsite Agencies
[ ^ The arei of-offsite s'pport agencies was reviewed against the requirements
u
'
of 10'CFR 50.47(b)(3) and the criteria in'NUREG-0654, Sections A.3, B.9,
'
E.1, E.4.a n, L.1,- and L.4.
6.1.1 Hospitals
The NRC inspectors toured and interviewed personnel identified in the plan
from both' hospitals that had been selected by HL&P for medical support.
The primary hospital is located approximately 21 miles from the STP site
in Bay City while the backup hospital.is located approximately 16 miles
from the site in Palacios.
The NRC inspectors held discussions with
hospital staff personnel concerning communications, training, equipment,
.
procedures, and facilities.
Two training sessions have been conducted for
the emergency team staff.
The training included a drill in which
!
personnel from STP participated.
Annual retraining is planned and a
videotape has been provided to the hospitals by STP for the purpose of
training new personnel throughout the year.
Both hospitals indicated that
coordination meetings and training were satisfactory.
Drills are being
scheduled with STP including critiques and hospital emergency plan
revisions as needed.
Although the hospital personnel expressed an
accurate understanding of responsibilities expected of them during an
emergency, neither hospital knew which responsibilities were described in
the Plan.
The licensee did not have current copies of the hospital
In addition, the hospital emergency plans did nct
contain the correct STP telephone numbers for verification.
The following are observations the NRC inspectors call to the licensee's
attention.
These observations are neither violations nor unresolved
items.
These items are recommended for licensee consideration for
improvement, but have no specific regulatory requirement.
Include exchange of emergency plans in the coordination efforts
-
.
between STP and the offsite agencies that could be called on to
!
provide support during an emergency.
Review the emergency plans for offsite agencies to assurance that the
-
plans, including telephone numbers and verification methods, are
consistent with the STP Plan.
6.1. 2 Fire Support
,
The NRC inspectors interviewed personnel from the Bay City and Palacios
volunteer fire departments.
Personnel from both fire departments
understood the responsibilities expected of them during an emergency and
the arrangements for equipment that were in place.
The Bay City Fire
,
Department expressed dissatisfaction with the level of training that had
i
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64
been provided by STP.
The licensee has made arrangements to provide tours
and training specific ~to fire fighting for all fire departments that could
respond to STP.
No drills have been conducted yet.
Based on the above findings, the following deficiency must be corrected to
achieve an acceptable program.
Fire department personnel had not been provided sufficient
-
information and training to enable them to provide the emergency
support described in the Plan.
(498/8635-070; 499/8635-070)
6.1.3 Matagorda County
The area of offsite agencies was reviewed against the requirements of
10 CFR 50.47(b)(3) and the criteria in NUREG-0654 Sections A.3, B.9, E.1,
E.4.a-n, L.1, and L.4.
The NRC inspector reviewed Section B.3 of the Plan and interfaces with the
applicable portions of the Emergency Management Plan for Matagorda County,
Bay City and Palacios and the State of Texas Emergency Management Plan.
The NRC inspector visited the Matagorda County E0C and interviewed the
county sheriff, who is the emergency Management coordinator for Hatagorda
County and employees at KMKS FM Radio Station, the designated Emergency
Broadcast System (EBS) station.
Matagorda County has the overall authority for protective actions and
measures taken in the county for the protection of personnel and property.
The State of Texas Department of Health Bureau of Radiation Control
provides assessment of radiological impact and damage to the environment.
The NRC inspector determined by personnel interview that the county and
KMKS would support the STP emergency response effort according to the
State and county emergency plans.
Training had been provided to emergency response personnel; however, only
l
one drill had been conducted.
Several coordination meetings including
table top discussions had been held.
The meetings included participation
l
from other offsite agencies which would respond to an emergency at STP.
l
Through interviews the NRC inspector determined that response personnel
were aware of their responsibilities, but did not know how the State,
'
l
county, and STP emergency plans described those responsibilities nor the
l
procedures that should be followed.
The State and county plans and
procedures have not been distributed.
!
The NRC inspectors determined by interview that the emergency response
'
personnel were satisfied with notifications and general emergency planning
l
information.
There appeared to be agreement between Matagorda County and
i
STP on emergency actions and associated protective action recommendations.
Based on the above findings, the following deficiency must be corrected to
achieve an acceptable program.
!
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.
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65
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Training and drills for offsite response and support agencies
(excluding medical) and necessary equipment and supplies for offsite
agencies had not been completed.
(498/8635-071; 499/8635-071)
The following is an observation the NRC inspectors call to the licensee's
attention.
This observation is neither a violation nor an unresolved
item.
This item is recommended for licensee consideration for
improvement, but has no specific regulatory requirement.
The Matagorda County, Bay City, and Palacios Emergency Management
-
Plan and the STP Plan should be distributed to the appropriate
offsite response agencies.
Procedures for specific activities should
be distributed to those personnel who would provide support in a
particular functional area; i.e., county public notification
procedures to the EBS radio station that provides emergency
instructions to the public.
6.2 General Public
This area of the licensee's program was reviewed with respect to the
requirements of 10 CFR 50.47(b)(7) and the criteria in NUREG-0654,
Section II.G.
The NRC inspector reviewed Section K of the Plan and the EPIP and
discussed this area of the licensee's program with selected licensee
personnel.
HL&P has prepared a calendar / brochure containing information on emergency
planning for distribution to the general public that HL&P plans to update
and distribute annually within the 10-mile EPZ and some appropriate
surrounding areas adjacent to the 10-mile zone.
HL&P planned to
distribute the calendar / brochure by mid-December 1986.
The
calendar / brochure contains a telephone number for the public to call for
'
assistance, but does not yet have an assigned telephone number for rumor
control.
The information in the calendar / brochure appears to be complete
and accurate with the exception noted above.
The dissemination of emergency information to transients had not been
conducted.
A survey of transient public use areas had been conducted by
HL&P and the specific locations for placement of posters and signs had
been determined.
The, licensee was in the process of providing emergency
information in local telephone books and posting permanent, all-weather
emergency information notices in public places.
Based on the above findings, the following deficiencies must be corrected
in order to achieve an acceptable program:
The public information for transients had not been distributed within
-
the 10-mile EPZ.
(498/8635-072; 499/8635-072)
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66
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The following is an observation the NRC inspectors call to the licensee's
attention.
This observation is neither a violation nor an unresolved
item.
This item is recommended for licensee consideration for
improvement, but has no specific regulatory requirement.
-
Provide a rumor control number to be inserted in the
calendar-brochure.
6.3 News Media
The area of news media training was reviewed with respect to the
,
requirements of 10 CFR 50.47(b)(7), and the criteria in NUREG-0654,
.a
Section II.G.
The NRC inspector discussed with appropriate HL&P personnel their program
3
to familiarize the news media in accordance with the Plan and the EPIP.
HL&P plans in this area appeared to be complete and adequate.
The first
media seminar is scheduled to be held at the HL&P offices in Houston,
Texas, on January 13, 1987, and a second session to be held in Bay City,
Texas, on January 20, 1987.
HL&P expects the media seminar..to occur
~
annually.
.
Based on the above findings, no deficiencies were identified in this area.
7.0 Orills, Exercises, and Walkthroughs
.
7.1 Program Implementation
This area was reviewed with respect to the requirements of
10 CFR 50.47(b)(14); 10 CFR 50, Appendix E, paragraph IV.4; and the
criteria in NUREG-0654, Section N.
-
The NRC inspector noted that training drills were commenced in August of
1986, to develop skills necessary for the emergency response organization
function assigned.
These drills started with talk-thrcugh training and
were subsequently converted to walkthroughs and hands-on training as
.
knowledge progressed.
State and county response personnel participation
had been similarly developed.
The NRC inspector also noted that no formal
program had been established to control and direct the drill and exercise
l
program.
Only a schedule had been provided for drills leading to the
'
first graded exercise schedule in April 1986, which included participation
'
by state and county.
,
Based on the above findings, the following deficiency must be corrected to
,
achieve an acceptable program:
,
A formal system had not been developed to implement and control the
'
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drills and exercises program.
(498/8635-073; 499/8635-073)
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7.2.3
Emergency Detection, Classification, and Notification
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a.
Walkthrough;
-
The NRC inspector. planned to conduct walkthroughs with six STP
control room crews. ' However, 'in view of a revision to the ece{gency
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.
bJassification, procedure three inys before the walkthrough
'
a
1 revision which the 6ews had not been trained on, the inspe,ctokchose
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to walk' one crew through using'the syperseded classification l
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procedure, to eva.luate a second cros during a utility drill condscted
Decembe 19, 1986,g nd to evaluate the remaining four crews at a
later ddte.
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,The walkthrough was scheduled at the convenience of the utility on
.'
December 8, 1986.
In preparation, generic 4-loop Westinghouse PWR
scenarios were drafted. - After riddition of site specific data and
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'
terminology, the s'cet.arios were re~ viewed by licensee training
,
managgment for technical accuracys
~
,
Ashifttechnicaladvisor(STA),'theshiftsupervisor(SS),theu$l1L
supervisor (US), two reactor operators (R0s), and two. reactor plant
operators (RPGs/A0s) participated.
None of the individuals invoivdd
.
in the walkthr' ughs were licensed at STPi altM ugh the two senior men
o
'
had held licenses at other. power plants.
Mest participants were
'
'.
scheduled for first quarter 1987 NRC oral examinations.
c,
4
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The walkthrough was conducted in' the simulator. Operators were
allowed to use any of the equipment, instrumentation, and
,
documentation available at tne simulator.
Emphasis was placed on the
,
~
ex.etgency plan and its implementation l particularly classification,
notification, communications, and protective action decisionmaking
s
based upon plant conditions.
To a lesser degree, casualty mitigation
was reviewed.
Oose assessment was not covered, since this HP y
,
function at STP was being evaluated separately.
3s
'
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Success or failure was measured with respect to STP requirements, not
' '
l
with respect to NUREG documents guidance.
However, where station
'
documentation differed from4M NUREGs, exceptions were noted and
l
included in this report.
j
Control room emergency communicators are drawn from the shift RP0s.
Only eine of the three RPGs involved in the walkthrough had completed
/EPT 11 (emergency communicator) training and only one class had been
-
. held to date;with 21 students.
A seccad communicator would be
'
necessary if,Jhe NRC were to require continuous communications with
/
th'e site in accordance with 10 CFR 50.72.c.
If the communicators
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wer'e drawn' from the RP0 group, under the minimum manning conditions
'
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no RP0s would be available for plant operations.
The communicator
. pool should be expanded to include other shift personnel.
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,
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.
,
,The walkthrough communicator was not familiar with the notification
-procedure, forms, or equipment.
It appeared that procedures and
' training would not support the state and local agency 15 minute
notification requirement; simulated notification took in excess of
15 minutes when accomplished in a table top environment without the
realistic complication of manning the boards, evaluatin) plant
conditions, running E0Ps, etc.
The operators omitted the decision to notify when que,ried about which
duties of the ED could not be delegated.
Given a Technical Specification requirement to shutdown, the
operators failed to declare a NOUE because their training indicated
none was required if the plant was placed in hot standby within the
time allowed by the LC0 action statement.
This is contrary to
NUREG-0654 guidance.
Neither the Plan nor the procedure discussed
the Technical Specifications shutdown NOUE in sufficient detail to
clarify the point.
The problem has been rectified in the current
version of the classification procedure; when operator training to
the new classification procedure has been completed, this problem
will be resolved.
b.
Drill:
Control Room
The utility drii! aducted December 10, 1986, confirmed the need for
a second control room emergency communicator and expansion of the
communicator pool beyond the shift RP0s.
State and local
,
notification of NOUE and alert was never completed; notification of
SAE took 19 minutes.
The NRC was not notified of NOUE or alert; the
'
SAE notification took 54 minutes.
Part of the problem can be
attributed to exercise artificialities such as the lack of a ring
c
down , '.ane in the simulator.
However, although the communicator did
!
his job well, he was simply swamped.
During the drill, the SS failed to classify the alert until he was
l
given a controller prompt message directing the classification.
The
utility failed to declare a general emergency although the lead
controlier informed the NRC inspector that scenario data required
,
declaration of a general emergency.
1
i
When contacted for the alert notification, the Texas Department of
Public Safety was unable to locate the notification forms.
l
During the drill, the NRC inspector noted that the control room
issued an order to gag the leaking safety relief valve (SRV).
!
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dagging the valve would have stopped the release.
It took in excess
,
of.an. hour to mobilize a repair team to attempt the gagging
operation.
The NRC inspector noted that the TSC drill was not fully effective.
Th_is appeared to be primarily because of the lack of familiarity by
the emergency response personnel with the TSC equipment and features,
and operation as a team.
The noise level of the ventilation system
made it very difficult for person-to person communications.
The
communication console was properly used by the TSC communicator, but
poor use was made of the console by the communicator for radiological
controls, who was not able to operate the console correctly.
In
addition, the telephone at the status board was not operational.
The
NRC inspector noted that technical materials were available to
support the plant-systems problem analysis, except for vendor or
technical manuals which were kept in another building.
During the
drill, the NRC inspector noted that the TSC manager did not make it
clear when the TSC was activated or who was in charge, nor did he
give periodic briefings to the staff via the TSC announcing system.
Operations Support Center
The NRC inspector observed the damage control team assigned to gag a
It was noted that almost 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> elapsed
between the time of the request for this task and the time the team
was dispatched.
The radiation protection technician reviewed
radiation control requirements and specified that SCBA equipment was
required; however, both this technician and another member of the
'
team wore full beards and no action was taken in regard to this
problem.
Due to errors by controllers, the damage control team was
l
not able to demonstrate activities planned.
For example, the team
was unable to demonstrate donning protective clothes at the access
[
control because they were prematurely confronted with the injured
l
man.
At one point a controller, when asked for results of an air
sample, gave the results of the main streamline monitor in analytical
'
units instead of survey instrument units.
In addition, one
controller could not readily respond to the health physics
technician's request for radiation survey data outside Unit 1,
although it was available in the scenario.
The NRC inspector noted
that drill participant's " play" was minimal and nonexistent at times,
impairing the evaluation of their actions.
As a result of the above
,
l
observations, the NRC inspector concluded that very little training
l
was derived from this portion of the drill.
Emergency 9peration Center
The NRC inspector observed personnel staffing of the EOC following
the declaration of an alert emergency class in the control room.
The
plaat manager departed the plant site and arrived at the E0C in
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approximately 12 minutes following the declaration of an alert.
Personnel were to sign in on the status board beside a key emergency
response function that they had been previously assigned.
The status
board indicated that the plant manager was the emergency director
prior to ha.iing been briefed by the control room ED or the arrival of
any EOC support.
Additionally, the NRC inspector noted that the
plant manager directed the control room ED to declare a SAE (a SAE
had been declared while the plant manager was enroute to the E0C) and
to dispatch health physics personnel.
Further, the plant manager
signed a public information notice release as the ED.
The emergency
plan stated that only the ED can approve public information releases.
The NRC inspector observed a lack of radiation protection support in
the E0C.
It was observed that habitability for the EOC was not
determined prior to activation or during the drill.
The E0C was
declared activated with the E0C ED taking over command from the
control room, approximately 59 minutes following the declaration of
an alert.
The NRC inspector noted that personnel in the E0C did not
have procedures and check lists for performing individual tasks.
Additionally, it was noted that E0C personnel kept.the noise levels
at a minimum and were professional in performing assigned tasks.
During the drill, some problems were noted with the status boards
which indicated they should be reviewed for possible revision related
to personnel functions and plant status.
Offsite Monitoring
There was no procedure for and the NRC inspector was unable to
observe deployment of offsite monitoring teams including checkout and
testing of equipment and briefing teams on initial plant conditions,
meteorological data and monitoring instructions.
The offsite teams
were directed to take radiation readings at specific predetermined
sample points rather than continuously as the team traveled along a
road. As a result, the team failed to define the plume.
The teams
were underutilized in that no readings were requested at several
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distances from the site.
The teams were not briefed throughout the
exercise nor were they informed when team direction transferred from
the radiological manager to the radiological director.
Personnel radiation protection was not observed.
Protective clothing
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and respirators were not used, dosimeters were not read.
Although
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the. teams were directed to a position outside the plume, no mention
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of, personnel dose tracking or protective measures (no eating,
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smoking, drinking, chewing) was made by either team members or the
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communicator in the E0C.
The practice of verifying data after each reading is time consuming.
During the drill, the team took several readings as requested;
however, when transmitting those readings, the EOC verified half of
the readings one at a time and never responded to the team for the
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remaining readings.
Data should be verified after a set of readings,
such as a complete traversal of the plume, so that the E0C receives
all available data froin a team.
Upon return, the team did not monitor or decontaminate themselves,
their equipment or the vehicles. There were no procedures for these
activities and the EOC did not request them.
The teams showed initiative in temporarily solving communications
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difficulties and notifying the EOC by pay telephone. A permanent
correction should be found for the radio transmission problems.
Although the teams were familiar with the tasks they were expected to
perform, their performance could not be evaluated because sufficient'
offsite monitoring activities were not demonstrated.
Exercise guidelines for players should specify what may be simulated.
These guidelines should be followed so that exercise objectives can
be demonstrated.
Controllers and evaluators should be warned
regarding prompting.
The importance of self-identified deficiencies
should be emphasized.
Media Information Center
The NRC inspector noted that the MIC was promptly setup and activated
in a timely fashion following the declaration of alert.
After the
setup in the Holiday Inn, it was noted that the public information
staff did not perform equipment and telephone operability checks to
verify readiness for activation.
In addition, facility briefings and
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communications between the various functional parts of the MIC were
initially weak and not effective during-the remainder of the drill.
During the drill, the lack of technical support for the liaison
person at ,the E0C and at the MIC severely impacted the efforts to
prepare and. release information to the media which accurately
depicted events that had occurred or were in progress.
A potential
problem was noted by the NRC inspector in regard to the approval of
news releases by the site ED.
Initially, approval of news releases
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could not be obtained because the ED had not assumed authority from
the control room and, later, the ED in the E0C was approving
information transmitted to the MIC which was rewritten and
distributed without actual approval of the news release by the ED.
Finally, it was noted that the graphics aids available in the media
briefing room consisted primarily of major system depictions and were
not adequate to show onsite features or offsite elements needed to
support the transfer of information to the media representatives.
Based on the ab(,ve findings, the following deficiencies must be
corrected to achieve an acceptable program:
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The operations crew walkthrough and drill identified problems in
timely notification of offsite agencies, errors in emergency
classification, and unfamiliarity with nondelegable
responsibilities of the ED.
(498/8635-074; 499/8635-074)
The number of-onshift control room communicators appeared to be
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inadequate and training for the communicators was incomplete.
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(498/8635-075; 499/8635-075)
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7.2.4-
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7.2.8 Dose Calculations and Emergency Sampling and Analysis
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The NRC inspector performed walkthroughs with three trained licensee
personnel to as'sess their readiness to perform dose calculations for
radioactivity released during emergencies.
The backup method using the
code IRDAM was used because the primary method (RM-21A) was not
operational.
All_three calculated the same Chi /Q, dose, and dose rate
values at various distances from the release point.
The licensee's
results agreed within 25 percent of the calculations performed by the NRC
inspector using a similar version of IRDAM.
The NRC inspector concluded
that an adequate assessment had been performed by these personnel, despite
having no approved procedure for guidance.
The NRC inspector also employed walkthroughs on the second backup method,
which was a manual calculation method included in OEPP01-ZA-0008,
Revision 0.
The procedure was observed to be adequate, but needed to be
edited and reviewed with respect to human engineering factors.
Two
walkthroughs were performed with licensee personnel.
Both results agreed
within a factor of ten with the NRC inspector's calculations; however,
calculation time was rather lengthy (20 and 30 minutes, respectively).
The NRC inspector attempted to have licensee personnel perform onsite and
offsite radiological monitoring walkthroughs.
It was determined, however,
that there was no onsite monitoring procedure and the designated offsite
monitoring procedure was not applicable for emergencies.
It was also
determined that monitoring kits were incomplete at the time of this
inspection.
Therefore, the NRC inspector chose to conduct no walkthroughs
in this area.
The licensee's post-accident sampling and analysis equipment was
essentially installed at the time of this inspection, but had not been
tested and was not operational.
Therefore, the NRC inspector did not
conduct a walkthrough in this area.
8.0 Exit interview
On December 12, 1986, at the conclusion of the inspection, the NRC
inspection team met with the the HL&P staff denoted in Section 9.0 of this
report.
Mr. J. B. Baird, the NRC team leader, summarized the status of
the Appendix A and Appendix B inspection findings.
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9.0 ' Persons Contacted
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HL&P Employees
J. Ashcroft, Associate Radiation Protection Technician
L. Baca, Reactor Plant Operator
- R. Balcom, Mancger, Operations
M. Berrens, Reactor Operator
K. Birchfield, Associate Radiation Protection Technician
- W. Blair, Maintenance Support Supervisor
R. Brown, Unit Supervisor
R. Butler, Jr. , Radiation Protection Technician
G. Chitwood, Reactor Operator
K. Christian, Unit Supervisor
L. Clark, Operation Support Engineering
- D. Cody, Manager, Nuclear Training Department
J. Constantin, Supervisor, Simulator Training
R. Craft, Senior Health Physicist
J. Dierickx, Chemistry Support Supervisor
E. Dugger, Reactor Operator
K. Espinoza, Reactor Plant Operator
B. Franta, Manager, Staff Training Division
M. Friedlander, Shift Technical Advisor
- R. Frazar, Manager, Emergency Preparedness Department
R. Gangluff, Chemistry Analytical Supervisor
W. Garcia, Jr. , Radiation Protection Technician
- J. Geiger, Manager, Nuclear Assurance
- M. Gonzalez, Manager, Media Relations
- R. Goodwin, Manager, Support Division
- J. Green, Manager, Operations Quality Assurance
R. Hamilton, Shift Supervisor
- R. Hawkins, Manager, Facility Services
C. Herring, Reactor Operator
J. Hodges, Reactor Operator
D. Homer, Senior Radiation Protection Technician
W. Isereau, Operations Quality Assurance Supervisor
D. Jammer, System Specialist
- G. Jarvela, Manager, Health and Safety Services
R. Kerr, Emergency Preparedness Coordinator
- W. Kinsey, Plant Manager
D. Lamb, Senior Operations Security Coordinator
J. Lindsey, Senior Health Physicist
R. Lockwood, Senior Health Physicist
J. Loesch, Plant Superintendent
- L. Lowe, Public Information Specialist
- M.
Ludwig, Manager, Maintenance
- M. McBurnett, Principal Engineer
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J. Mertick, Technical Support
J. Moerbe, Reactor Plant Operator
M. Nelson, Manager, Business Support
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K; N'emec, HVAC,.Tec'hnical Support
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D. Nester',' Lead Electrical, Technical Support
- G. Painter, Manager, Public Information
B. Parish, Radiological Support Supervisor
- G. Parkey, Manager, Technical Support
S. Parthasarathy, Staff Engineer
Pa Pearson, Training Instructor
D. Perez,-Senior Radiation Protection Technician
G. Peters, Planning and Scheduling Supervisor
M. Rickaway, Reactor Plant Operator
- H. Russell, Lead Training Instructor
- L. Ryley, Manager, Physical Protection Services
J. Simms, Emergency Preparedness Coordinator-
- D. Smith, Manager, Management Services
K. Struble, Shift Supervisor
.D. Tomas, General Supervisor, Training Pgn./Adm. Supt.
T. Underwood, Manager, Chemical Operations and Analysis
- C. Walker, Information Specialist
^N. Walker, Communications Conseltant
P. Walker, Senior Engineer, Site Licensing
G. Williams, Staff Engineer (Corporate)
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A. Woods, Outage and Modifications Support Supervisor
C. Wren, Fire Protection Engineer
Other Organizations
L. Bailey, Maintenance, Matagorda General tiospital
- J. Brady, Acting Manager, Readiness Div., Energy Inc.
M. Dykes, Public Relations, Matagorda General Hospital
J. Elliot, Fire Marshall, Bay City Fire Department
- H. Fertel, Emergency Preparedness, Delian Corp.
V. Hahlick, Member, Palacios Volunteer Fire Department
S. Hurta, Matagorda County Sheriff
C. Hyett, Safety Director, Wagner Hospital
D. Hyett, Administrator, Wagner Hospital
M. Sandlin, Manager, KMKS FM Radio Station
C. Shoemake, Emergency Preparedness, Energy Incorporated
B. Watson, Safety Director, Matagorda General Hospital
- E. Webster, Emergency Preparedness, Impell Corp.
A. Wood, Operations Manager, KMKS FM Radio Station
NRC
D. Carpenter, Senior Resident Inspector
T. Reis, Resident Inspector
- Denotes those present at the exit meeting.
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