ML20213G610

Insp Repts 50-498/87-12 & 50-499/87-12 on 870406-10.No Violations or Deviations Noted.Emergency Preparedness Program Deficiencies Noted.Major Areas Inspected:Licensee Emergency Response Capabilities During Emergency Exercise

ML20213G610
Person / Time
Site:	South Texas
Issue date:	05/05/1987
From:	Baird J, Yandell L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20213G551	List: ML20213G550 ML20213G610
References
50-498-87-12, 50-499-87-12, NUDOCS 8705180367
Download: ML20213G610 (8)

See also: IR 05000498/1987012

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APPENDIX

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-498/87-12 Licenses: CPPR-128

50-499/87-12 CPPR-129

Dockets: 50-498

50-499

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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: Bay City and STP, Matagorda County, Texas

Inspection Conducted: April 6-10, 1987

Inspect : m .f/f/f7

J. B. Baird, NRC Team Leader Date

Accompanied

By: C. Hackney, RIV, NRC

C. Wisner, RIV, NRC

R. Hogan, HQ, NRC

F. Carlson, Comex Corporation

G. Bryan, Comex Corporation-

J. MacLellan, PNL, Battelle

G. Wehmann, EG&G Services

Approv d: .5"If/P7

L. A. Yandel1, Chief, Emergency Preparedness Date

' and Safeguards Programs Section

Inspection Summary

Inspection Conducted April 6-10, 1987 (Report 50-498/87-12; 50-499/87-12)

Areas Inspected: Routine, announced inspection of the licensee's emergency

response capabilities during an exercise of the emergency plan and procedures.

Results: Within the areas inspected, no violations or deviations were identified.

Four deficiencies were identified by NRC inspectors (paragraphs 4-7). Eight

additional deficiencies were also identified by both the NRC and the licensee

(paragraph 8).

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DETAILS

1. Persons Contacted

Licensee

• J. Goldberg, Group Vice President, Nuclear

• R. Chewning, Special Assistant to Vice President Nuclear Operations

• R. Cook,' Senior Duality Assurance Specialist-

J. Bumgardner, On.ft Supervisor

• R. Frazar, Manager, Emergency Preparedness

M. Friedlander, Shift Technical Advisor

• S. Head, Lead Engineer, Licensing

• W. Kinsey, Plant Manager

R. Latsch, Nuclear Chemist

• M. McBurnett, Principal Engineer, Site Licensing

T. Morris, Maintenance Training Coordinator

G. Painter, Manager, Public Information

G. Parkey, Technical Support Manager

J. Sikes,: Unit Supervisor

• G. Vaughn,. Vice President, Nuclear Operations

R. Waldrop, Manager, Public Affairs

• C. Walker, Site Public Affairs Manager

• A. Woods, Outage & Modifications Support Supervisor

Others

• J. Brady, Acting Readiness Division Manager, Energy International

D. Carpenter,. Senior Resident Inspector, NRC

• M. Fertel, Consultant,. Emergency Preparedness, Delian Corporation

• D. Garrison, Resident Inspector, NRC

• C. Johnson, Senior Resident Inspector, NRC

C. Shoemake, Consultant, Energy: International

• E. Webster, Project Director, Impell Corporation

• Denotes attendance at exit interview.

The NRC inspectors also held discussions with other station and corporate

personnel in the areas'of health physics, operations, and emergency

response organization.

.2. Follow-up on Previous Inspection Findings

(Closed) Deficiency (498/8635-006; 499/8635-006): Identification and

control of emergency equipment, supplies, and decisionmaking aids. The

NRC inspector found that the STP Emergency Plan (the Plan) identified the

requirements for control room equipment and supplies, and that the control

room was included in procedure OEPP02-ZA-0002, " Emergency Equipment and

Supplies Inventory," listings. In addition, it was determined that the

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- required equipment; supplies, records, and decisionmaking aids were in

place in the control room.

(Closed) Deficiency -(498/8635-008; .499/8635-008): Technical Support

Center (TSC) not supplied with adequate range and depth of equipment and

supplies. The NRC inspector' reviewed the equipment and supplies available

during the exercise on April 8, 1987. Based on this review and the

satisfactory availability of necessary equipment and supplies during the .

exercise, this area was determined to be adequate. In addition, it was

noted that the inventory of equipment and supplies was specified in

procedure OEPP02-ZA-002.

(Closed) Deficiency (498/8635-009; 499/8635-009): Physical layout and

concept of operations for the Operations Support Center (OSC). The NRC

inspector determined through a review of procedure OEPP01-ZA-0016,

" Operations Support Center Activation, Operation, and Deactivation

Procedure," and observation of the exercise that the OSC layout and

concept of operations appeared to be adequate to meet the functions stated

in NUREG-0737.

(Closed) Deficiency (498/8635-024; 499/8635-024): Number of electrical

outlets in the Public Information Officer (PIO) support room. The NRC

inspector determined during the exercise that an adequate number of

electrical outlets to support planned activities were provided in the PIO

support room of the Media Information Center (MIC).

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(Closed) Deficiency (498/8635-035; 499/8635-035): No procedure had been

provided to govern the activation of the TSC and the Emergency Operations

Center (EOC). The NRC inspector determined that procedures OEPP01-ZA-0014

and OEPP01-ZA-0018 had been provided, respectively, for the activation,

operation, and deactivation of the TSC and EOC.

(Closed) Deficiency (498/8635-036; 499/8635-036): OSC activation

procedure lacked policy on eating, drinking, smoking, and chewing. The

NRC inspector determined by review of procedure OEPP01-ZA-0016 that

section 3.12 prohibits eating, drinking, smoking, and chewing in the OSC

until after.the habitability checks are completed and the prohibition

removed by the OSC coordinator. It was also noted that section J.5 of the

Plan prohibits food and drink in contaminated and potentially contaminated

areas. The limits for contamination are given in section J.4.

(Closed) Deficiency (498/8635-038; 499/8635-038): A specific procedure

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had not been provided to implement decontamination of vehicles. The NRC

inspector'noted that procedure OEPP01-ZA-0034, " Monitoring and

Decontamination of Vehicles," provided guidelines for monitoring and

decontamination of vehicles used offsite.

(Closed) Deficiency (498/8635-041; 499/8635-041): No procedure had been

provided to control the use of emergency vehicles. The NRC inspector

determined that procedure OEPP03-ZA-0071, " Control and Maintenance of

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Company Owned Vehicles," includes the control of emergency response

vehicles at STP.

(Closed) Deficiency (498/8635-049; 499/8635-049): No approved procedure

had been provided for performing back-up dose calculations. The NRC

inspector noted that procedure OEPP01-ZA-0008, "Offsite Dose Projections,"

had been revised to include instructions for use of the STAMPEDE computer

code (a site specific modification of the NRC IRDAM code) as a back-up

dose projection calculation method.

(Closed) Deficiency (498/8635-050; 499/8635-050): Procedures for

activation of the E0C were not consistent with the Plan. The NRC

inspector determined that Revision 0 of the Plan, dated March 6, 1987,

described activation of the EOC in a manner consistent with the

procedures.

(Closed) Deficiency.(498/8635-053; 499/8635-053): Procedures for onsite,

out-of plant radiological monitoring. The NRC inspector determined that

procedure OEPP01-ZA-0005, "Onsite Radiological Controls," had been

implemented. The procedure provides guidelines and policies for onsite

radiological controls during a declared emergency condition.

(Closed) Deficiency (498/8635-061; 499/8635-061): Provisions for and

implementing procedures for recovery and reentry. The NRC inspector

determined that procedure OEPP01-ZA-0011, " Recovery Operations," had been

issued to provide guidance for reentry and recovery operations related to

emergency conditions.

(Closed) Deficiency (498/8635-063; 499/8635-063): Method for coordinating

dissemination of news information. The NRC inspector noted that MIC

procedures had been revised to provide for clearly specified coordination

of internal dissemination of news information during an emergency.

(Closed) Deficiency (498/8635-066; 499/8635-066): Emergency equipment

inventory lists. The NRC inspector determined that

procedure OEPP02-ZA-0002 had been revised to include inventory lists for

onsite and offsite monitoring kits.

(Closed) Deficiency (498/8635-067; 499/8635-067): Procedures for Plan

change reviews and submittal to the NRC. The NRC inspector determined

that procedure OEPP02-ZA-0004, " Revision of STPEGS Emergency Plan

Emergency Communications," had been provided for Plan change review and

submittal to the NRC to meet the requirements of 10 CFR 50.54(q).

(Closed) Deficiency (498/8635-075; 499/8635-075): Onshift communicators.

The NRC inspector noted that Table C-3 of the Plan required 2 control room

communicators and that 2 control room communicators were listed in the

current emergency response organization assignment matrix. It was further

noted that at least 31 persons had received the training specified in

EPT-0011, " Emergency Communicator Training."

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3. Program Areas Inspected

The following program areas were inspected. The inspection included

interviews.with cognizant individuals, observations of activities, and

record reviews. The depth and scope of these activities were consistent

with the current status of the facility ~ .

Except as noted, the inspection revealed no violations, deviations,

deficiencies, unresolved items, or open items Notations after a specific

inspection item identify the following: I = item not inspected or only

partially inspected, V = violation, D = deviation, H = deficiency,

U = unresolved item, and 0 = open item.

Inspection Procedure Functional Area and Inspection Requirements

82301 Evaluation of Exercises for Power Reactors

(1) Control Room - H (see paragraph 8)

(2) Technical Support Center - H (see

paragraph 4)

(3) Emergency Operation Facility - H (see

paragraph 4)

(4) Operations Support Center - H (see

paragraph 5)

(5) Corporate Command Center - I

(6) Offsite Monitoring Team - H (see '

paragraph 6)

(7) Corrective Action / Rescue Team - H

(see paragraph 7)

(8) Security / Accountability Team - H

(see paragraph 8)

(9) Press Center

(10) Medical Team - H (see paragraph 8)

-(11) Post Accident Sampling

4. Emergency Operations Facility - 82301(3J

The NRC inspector noted that radiological assessment in the E0C was not

able to satisfactorily characterize the magnitude of offsite radiological

consequences during the period from about 10:30 a.m. to approximately

2 p.m. The initial dose projections were up to 1000 times higher than the

scenario values and only about 5 field monitoring team measurements were

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available during this period. The dose projection inaccuracy was

primarily due to an inability to determine the radioactivity release rate

until late in the exercise, and the lack of field measurement data

resulted from'the failure to direct and use the field teams effectively.

The NRC inspector noted that the failure to assess the radiological impact

postulated by the scenario resulted in the formulation of protective

action recommendations which were overly conservative and extended the

area of concern well beyond the 10-mile emergency planning zone.

This constitutes a deficiency (498/8712-01; 499/8712-01).

No violations or deviations were identified.

5. Operations Support Center - 82301 (4)

The NRC inspector determined that the concept of operation for use of

inplant teams resulted in excessive time being taken to constitute and

dispatch teams for repair or corrective actions. For example, the NRC

inspector noted that approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> elapsed from identification of

the need to shut the power operated relief valve until a team arrived at

the scene to operate the valve.

This constitutes a deficiency (498/8712-02; 499/8712-02).

No violations or deviations were identified.

6. Offsite Monitoring Team - 82301 (6)

The NRC inspector noted that the radiological controls for the field

monitoring teams did not include tracking of the team member's

self-reading dosimeters through the field team communicator; direction for

counting of lapel air samples and tabulation of results; and attention to

limiting stay times while in the radioactive plume.

This constitutes a deficiency (498/8712-03; 499/8712-03).

No violations or deviations were identified.

7. Corrective Action / Rescue Team - 82301 (7)

The NRC inspector noted during the exercise that there were no backup

teams fully dressed and equipped for entry for each team entering areas

where radiological conditions were either unknown or expected to be

extreme as required by procedure OEPP01-ZA-0005, "Onsite Radiological

Controls." In addition, the NRC inspector noted that a reactor operator

was dispatched from the control room to rendezvous with inplant team

members without participating in the team mission and radiological

briefing specified in procedure OEPP01-ZA-0005.

This constitutes a deficiency (498/8712-04; 499/8712-04).

No violations or deviations were identified.

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8. Exercise Critique

The NRC inspectors attended the post-exercise critiques by the STP staff

on April 8 and 9, 1987, to evaluate the licensee's identification of

deficiencies and weaknesses as required by 10 CFR 50.47(b)(14) and

Appendix E of Part 50, paragraph IV.F.5. It was noted that many of the

observations by the NRC inspectors during the exercise were also

independently made and reported by the STP staff. Both the NRC and STP

staff identified the deficiencies listed below. Corrective action for

these identified deficiencies and weaknesses will be examined during a

future NRC inspection.

The shift supervisor, acting as Emergency Director, failed to classify

accident conditions as requiring the declaration of an Alert in a timely

fashion, necessitating the issuance of a contingency message by the

control room exercise controller to force the declaration of Alert. The

scenario event involving a fire in the 13.8 kV switchgear room was

apparent about 8:03 a.m. and the controller prompted the shift supervisor

to declare the Alert at about 8:14 a.m. , after the shift supervisor had

classified the event as a Notice of Unusual Event at approximately

8:13 a.m. It was planned that the scenario eveat would lead to the prompt

declaration of Alert pursuant to procedure OEPP01-ZA-0001, which stated

that a fire ". . . potentially affecting safety systems . . ." is an

Alert.

Control room radiological habitability monitoring was dependent

exclusively on the area radiation monitors and there was no use of

radiological protection technician radiation and swipe surveys, personnel

dosimeters, and personnel contamination monitoring and control points.

The exercise objective for each manager to periodically brief personnel

within the emergency response facilities concerning the status of the

emergency was not demonstrated in the TSC, in that such periodic briefings

were not conducted in the TSC during the exercise.

The general plant announcing system was not used to keep the plant

personnel and the onsite emergency response organization staff aware of

plant and emergency status. For example, the declaration of General

Emergency was not announced onsite.

Security force personnel were not trained and qualified in the use of

respiratory protection, possibly precluding their use for inplant search

tasks and for providing access to locked security areas.

Contamination control measures were not taken by the team responding to

the simulated medical emergency and no attempts were made to define and

control the potentially contaminated areas resulting from the team's

activities in treatment and removal of the injured person.

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The primary contamination ' control, point-was. established outside of the

~_ : plant at the OSC. Thisicbuld _ result in the unnecessary spread of

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contamination outside 'of the : power ~ block.

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The HL&P supplemental' field' monitoring team'(EDC-team)_ dispatched from

Houston did not have a defined role and functional integration.into the-

emergency response organization described in the Plan and implementing- ~

-procedures.

No ' violations or ' deviations were' identified.

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9. Exit Interview-

'The NRC-inspector met with two NRC-senior resident inspectors and licensee

representatives denoted in paragraph 1 on April-10, 1987, and summarized

the scope and-findings of the inspection as presented in this report.

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