ML20246N778
| ML20246N778 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/30/1989 |
| From: | Warnick R Office of Nuclear Reactor Regulation |
| To: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| Shared Package | |
| ML20246N784 | List: |
| References | |
| NUDOCS 8909080262 | |
| Download: ML20246N778 (7) | |
See also: IR 05000445/1989043
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AUG 351989
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In Reply Refer:To:
' Dockets: '50-445/89-43
50-446/09-43
,
TV Electric
- ATTN:
W. J. Cahill, Jr., Executive
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-Vice President
Skyway Tower
400 North Olive, L.B. 81
Dallas,-Texas 75201
~ Gentlemen:
SUBJECT: EMERGENCY-PREPAREDNESS APPRAISAL
During the period of June 5-9, 1989, NRC conducted an appraisal of the -
emergency preparedness program at the Comanche. Peak Steam Electric Station.
.The appraisal was performed by a team of inspectors and contractors with
Mr. Nemen M.' Tere as Team Leader. The objective of the appraisal was to
evaluate the' overall" adequacy and effectiveness of the licensee's onsite
emergency.. preparedness program and to identify areas of weakness that need to
be strengthened. Areas examined in this appraisal are described in the
. enclosed report. .Within these areas, the appraisal. team reviewed selected
procedures and representative records, inspected emergency facilities and
equipment, and interviewed personnel.
The findings of this emergency preparedness appraisal indicate that certain
corrective actions are required in your emergency preparedness program. These
are discussed in Appendix A, "Significant Appraisal Findings." Appendix B,
" Emergency Preparedness Improvement Items," contains'other findings which are
of lesser significance then those of Appendfx A, but which may require
corrective measures.
Appendices A and B of this letter contain an inclusive listing of all
. outstanding onsite emergency preparedness items at your facility at the time of
the appraisal. The findings of the prior emergency preparedness appraisal,
conducted during the period September 26 through October 7, 1983, are
considered closed since the present appraisal replaced those findings.
We recognize that in addition to applicable regulatory requirements, other
criteria were used to make a determination of adequacy, such as nuclear
industry standards and professional judgement, for which no explicit regulatory
requirement may currently exist. Notwithstanding this, you are requested to
submit a written statement within 30 days af ter receipt of this letter,
describing your planned actions for correcting each of the items contained in
-Appendix A and the results of your consideration of each of the items in
EIV SEPS
C:SEPS
C:RPB
D:DRSS
NRR ppg
- NMTerc
- DAPowers
- BMurray
BBeacidj'
RWarh'ick
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/ /89
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- previously concurred.
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8909080262 890830
ADOCK 05000445
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Should you.have any questions concerning this' inspection, we will.be pleased to
discuss them with you.
Sincerely,
Orlglnal Signed By,
u
R. F. Warnick, _ Assistant Director
for Inspection Programs 1
Comanche Peak Project. Division-
Office of Nuclear Reactor Regulation
Enclosures:
.
.
1.
Appendix A - Significant
Appraisal Findings
2.
Appendix'B -1 Emergency
Preparedness ~ Improvement Items
3. ' Appendix C - NRC Inspection Report-
50-445/89-43
50-446/89-43'
cc w/ enclosures:
TV Electric
ATTN:
Roger D. Walker, Manager,
Nuclear Licensing
h
S kyway. Tower
1400 North Olive Street, L.B. 81
Dallas, TX 75201
Juanita Ellis
President - CASE
- 1426 South Polk Street
Dallas, TX~ 75224
GDS Associates, Inc.
Suite 720
.
-1850 Ptrkway Place
Marietta, GA 30067-8237
- Susan M. Theisen
Assistant Attorney General
,
Environmental Protection Division
.P.O. Box 12548, Capitol Station
Austin, TX 78711-1548
Fulbright & Jaworski
. ATTN: Joseph' F. Fulbright
1301 McKinney Street
Houston, TX 77010
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.TU Electric
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Senior Citizens Alliance of:Tarrant -
1'
. County,;Inc.
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ATTN: : George A. Parker, Chairman
!
Public Utility Committee.
6048 Wonder Drive
< Fort Worth, TX- 76133
-Heron, Burchette, Ruckert, & Rothwell
ATTN: William A. Burchette, Ern.
Counsel for Tex-La' Electric
.1025 Thomas' Jefferson St. , N.W.
Washington, DC 20007-
E; F. Ottney
'P.O. Bc,x 1777
Glen Rose, TX 76043
Newman & Holtzinger,-P.C.
ATTN: Jack R. Newman, Esq.
.1615 L.--' Street, N.W.
Washington, D.C.
20036
' Chief, Technological Hazards Branch
-
FEMA Region 6-
Federal Center
800; North Loop 288
'Denton, Texas' 76201-3698
bec dist, by-RIV:
CPPD:0SP Reading _(MS:
7-H-17)
- RIV Files.
.
Local PDR
ADSP Read'ng (MS: 7-D-24)
- Site Reading File
- MIS-System, RIV-
NRC-PDR --
'*RSTS Operator
_
- DRP
- L.,Shea, ARM /LFMB
J. Dyer, NRR
P. McKee,.OSP'
J. Lyons, OSP
J. Wilson, ADSP, NRR
M. Malloy, DSP
J._ Moore, OGC-WF_
J. Gilliland
- M. Fields, OSP
E. Jordan
.
. B.' Grimes, NRR-WF
B. Hayes
- R.. Martin
- RPB-DRSS
D. Crutchfield, OSP-
- R. Warnick, CP
'*J) Wiebe, CP
- H. Livermore, CP
CPPD-LA, OSP
C. Grimes, OSP
- w/766
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APPENDIX A
SIGNIFICANT APPRAISAL FINDINGS
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Improvements in the following areas are required to achieve an adequate-
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program:
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Review the description of your emergency organization and revise it as
necessary to provide a clear depiction of all emergency functions required
during initial, intermediate, and final phases of augmentation and
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recovery; update the Site and Corporate Emergency Plans to describe the
updated organization; revise and issue implementing' procedures which have
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been human engineered so that all emergency response tasks can be carried
out using the command and information pathways of the organization. The
. updated description of the emergency or3..:dva+1on should include a
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sufficient level of detail:
clearly specify the command hierarchy, its
structure, reporting chains and interrelationships at any phase of
augmentation, and include supervisory as well as non-supervisory elements.
(See Section 2.0 of the Appraisal Report.)
'
Remove dose assessment responsibilities from the shift technical
advisor (STA) in order to comply with the intent of NUREG-0737,
Appendix C.
(Section2.0)
Complete training for emergency response personnel including any training
associated with'the completion of. emergency systems and related
procedures.
(Section 3.0)
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Review and revise. training requirements to include pt ctical, hands-on
training, and drill participation.
(Section 3.0)
Develop specific qualification requirements for each position in the
emergency response organization.
(Section 3.0)
Complete the 'nsta11ation and testing of instrumentation, systems, and
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controls in t .e control room that are required to assess plant and
environmental conditions.
(Section 4.1.1.1)
Complete the installation of Technical Support Center (TSC) equipment.
(Section 4.1.1.2)
Complete the setup of the multichannel analyzer and NaI detector
for counting environmental samples.
(Section 4.1.1.5)
Assemble medical kits containing key medical supplies for emergency
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response personnel who would respond as part of the first-aid team.
(Section 4.1.2.2)
Provide decontamination supplies in decontamination facilities.
(Section 4.1.2.3)
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Revise Procedure EPP-207 to provide _ specific instructions as to the riews
media and offsite agencies to be contacted initially for the dissemination
.of information to the.public.
(Section4.1.4)
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Complete the news media seminar providing the news media with the utility
points of contact and locations where accident information can be
obtained. .'(Section 4.1.4)
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Complete the training of the CPSES staff on their duties in the. News
Center and dissemination of information to the.public.
(Section 4.1.4)
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Complete the installation, testing, and turnover of.the Digital Radiation
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-Monitoring System (ORMS), and cf.afirm that instrument maintenance and
calibration. checks are performed in accordance with applicable
. requirements. -(Section 4.2.1.2)
Complete the installation, testing, and turnover of non-radiation
monitoHng systems.
Initiate appropriate preventive maintenance checks on
- the systems and conduct appropriate training on operation, analysis, and
distribution of data obtained from the systems.
(Section 4.2.1.3)
Complete the construction and installation of +.he primary meteorological
tower and related equipment.
(Section 4.2.1.1)
Complete the review.and revision of the Emergency Action
Level (EAL)/ Emergency C1s sification procedure.
(Section 5.1)
Revise procedures to assign a staff member other than the STA to perform
dose assessment functions until the control room is relieved of the
function by the TSC. (Section 5.1):
Revise Procedure EPP.-304 to add guidance for daveloping offsite
-PARS based on operational assessment of plant conditions.
Incorporate, in Procedure EPP-304, a oecisionmaking aid such as the
" logic tree" shown in IE Information Notice 83-28, Figure 1, " Flow
Chart for General Emergency Offsite Protective Decisions." Delete,
from Procedure EPP-304, those considerations (such as weather,
special facilities, and population distributions) that are not
germane to effectively developing and recommending a protective
action. Revise Procedure EPP-304 to eliminate the need to discuss
PARS with the state or counties until after the PARS are made to
offsite agencies.
(Section 5.3)
Demonstrate that the evacuation of the owner-controlled area (OCA),
including all buildings, can be accomplished in c thorough and timely
manner. (Section 5.4.3.2)
Demonstrate the capability of performing personnel accountability of
all personnel within the protected area within 30 minutes.
(Section 5.4.3.3)
Modify training materials to incorporate PARS based on core and
containment conditions and retrain all personnel having responsibilities
.to formulate PARS.
(Section 7.1.5)
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APPENDIX B
IMPROVEMENT ITEMS
The following matters are considered improvement items:
Position the required, dedicated emergency equipment in the Operations
Support Center (OSC) or provide assurance that all required equipment will
be properly located in the event of an emergency.
(See Section 4.1.1.3 of
the Appraisal Report.)
Install an ingestion pathway map to assist in monitoring the efforts of
o r site authorities responsible for defining the extent of long term,
/ / site radiological conditions.
(Section 4.1.1.4)
Maintain first-aid supplies in an orderly fashion.
(Section 4.1.2.2)
Review and revise Section 10.2 of the Emergency Plan to reflect the
correct location of the onsite first-aid supplies and that Hood General
Hospital Ambulance Service is the primary ambulance service, and complete
the turnover of the ambulance service from the contractor.
(Section 4.1.2.2)
Review and revise Section 6.9 of the Emergency Plan to list the electrical
and control building as the location of the decontamination facility in
the plant rather than the turbine building.
(Section 4.1.2.3)
Include the correct storage locations of emergency kits in procedures.
(Section 4.2.1.1)
Mark spare batteries with shelf life expiratior, dates to permit persons
performing inventories to readily deterrine if supplies are adequate.
(Section 4.2.1.1)
Provide potassium iodine (KI) tolerance testing for emergency responders.
(Section 4.2.1.1)
Assure that proper physical units are available at local instrument
channel racks for emergency radiation monitors read-outs.
(Section 4.2.1.2)
[
Install protective dust caps / thread protectors on spare self contained
breathing apparatus (SCBA) bottles.
(Section 4.2.2.1)
Initiate periodic testing as appropriate for all emergency communication
systems; review and revise procedures to require periodic testing of all
emergency communication systems and increase the FM radio capability at
the TSC to permit monitoring of emergency channels. (Section 4.2.3)
Correct administrative errors and discrepancies ir, emergency procedures.
(Section 5.1)
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Review the alarm response procedures (ALPS) and include appropriate
references to Procedure EPP-201.
(Section 5.2)
Correct inconsistencies in referencing the EP in abnormal conditions
procedure. (Section 5.2)
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Enhance the emergency dose assessment program with a segmented plume
- atmospheric dispersion model that will take wind shifts into account.
(Section 5.4.2.1)
Complete the documentation of the Xu/Q values using the dose assessment model
and document these values into procedures'.
(Section 5.4.2.1)
Delete the reference to the calculation of total population dose from
Procedure EPP-206.
(Section 5.4.2.1)
Ensure that units on ihe DRMS monitors used for dose assessment
calculations are consistent with those in the RM-11 system, and the dose
assessment.model.
(Section 5.4.2.1)
Revise Section 7.3.2 of'the Emergency Plan to indicate the actual
communication link between emergency facilities and the offsite monitoring
. teams. (Sc: tion 5'.4.2.2)
Develop a procedure for the routine maintenance and operability check on
the NaI detector system, and develop a procedure to describe counting -
procedures for environmental samples and the activation of the counting
laboratory. (Section 5.4.2.2)
Provide icgible maps showing environmental thermoluminescent
dosimeter (TLD) locations in Procedure EPP-309, including specific
descriptions on how to reach these locations.
(Section 5.4.2.5)
Consider issuing dosimetry to personnel as they ed er the Emergency
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Operations Facility (EOF).
(Section 5.4.3.1)
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Review and revise Procedure EPP-313 to specify the use of emergency
medical technicians (EMTs) as first-aid team members.
(Section 5.4.3.5)
Update the Letters of Agreement with the offsite support agencies.
(Section 6.0)
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Prepare a matrix that would indicate what offsite agencies are to be
trained, the subject to be trained on, and the status of completion.
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(Section 6.0)
Review the materials for EAL training and revise, as necessary, to ensure
that control room decisionmaking personnel fully understand the
application of the " fire" EAL. (Section 7.1.2)
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Revise Procedure EPP-303 to include instructions for using a default
release rate based on the most likely containment failure mode.
(Section7.1.4)
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APPENDIX C
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Appraisal Report:
50-445/89-43
Construction Permits: CPPR-126
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50-446/89-43
CPPR-127
Dockets: 50-445
50-446
Applicant: .TU Electric
400 North Olive, L.B. 81
Dallas, Texas 75201
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Facility Name: Comanche Peak Steam Electric Station (CPSES)
Appraisal At: Comanche Peak Site, Glen Rose, Texas
Appraisal Conducted: June 5-9, 1989
Appraiser:
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Nemen M. Terc, NRC Team Leader
Date
Personnel:
R. 'J. Everett, Chief, Nuclear Materials
Licensing Staff, NRC, Region IV
R. T. Hogan, Emergency Preparedness Analyst,
NRC, NRR
A. B. Earnest, Security Specialist, SEPS
NRC, Region IV
D. H. Schultz, Engineer, Comex Corporation
G. A. Stoetzel, Senior Research Scientist
Pacific Northwest Laboratories
M. N. Stein, Engineer, Sonolex Corporation
Approved:
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Dr. D. A. Powers, Chief, Security and
Date
Emergency Preparedness Section
Ay raisal Conducted June 5-9, 1989 (Report 50-445/89-43; 50-446/89-43)
Areas-Appraised and Approval Summary
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Special, announced emergency preparedness program appraisal to determine the
adequacy of the applicant's program.
8909080265 890830
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The appraisal of the onsite emergency preparedness program at Texas Utilities
Electric Company's (TUCO) Comanche Peak Electrir Steam Station included seven
general areas:
administration of the emergency preparedness program, emergency
organization, emergency training, emergency facilities and equipment,
procedures which implement the Emergency Plan, coordination with offsite
agencies, and walk-throughs of emergency duties.
A review of the applicant's emergency organization showed that although the
applicant had identified several organizational response elements, improvements
were needed to further clarify duties and responsibilities, and to provide an
organizational structure consistent with each emergency response task.
A review of the emergency preparedness training program showed that the program
had been established, but qualification requirements for each task or position
were not clearly specified and practical training was not required. A large
portion of the training had been performed for the emergency responders, but
the status of completion of some systems will require further training for
personnel operating such systems.
In addition, some organizational elements
had not received training consistent with their duties during emergencies.
Those portions of emergency response facilities (ERFs) that had been completed
were basically satisfactory; however, some facilities were still in various
stages of completion, and equipment and supplies were not completely in place.
Personnel accountability and evacuation of the protected areas (pas) and the
owner-controlled areas (OCAs) have not been demonstrated. The applicant has a
unique situation in these areas due to the large number of workers in the pas
and OCAs.
Specific deficiencies were found in some procedures, mainly in the procedure
used for making protective action recommendations (PARS), including the absence
of operational assessment of plant conditions, and the inclusion of extraneous
considerations which may have an impact on the efficient release of PARS.
.The appraisal team concluded that the applicant has made a strong commitment to
the emergency preparedness program. However, the findings identified in
Appendix A to this report need to be corrected in order for the applicant to
have an adequate emergency preparedness program.
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CONTENTS
PAGE
1.0 ADMINISTRATION ................................................ 4
2.0 EMERGENCY ORGANIZATION ........................................ 4
3.0 T RA I N I N G . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
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4.0 EMERGENCY FACILITIES AND EQUIPMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
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4.1 Emergency Facilities ..................................... 7
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4.1.1 As s e s sme nt Fa ci l i ti e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
4.1.1.1
Control Room ............................. 7
4.1.1.2 Technical Support Center ................. 8
4.1.1.3
Operations Support Center ................ 8
4.1.1.4
Emergency Operations Facility ............ 9
4.1.1.5 Offsite Laboratories ..................... 9
1
4.1.2
Protecti ve Faci li ti e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
4.1.2.1
Assembly / Reassembly Areas ............... 10
4.1.2.2 . Medical Treatment Facilities ............ 10
4.1.2.3
Decontamination Facilities .............. 11
4.1.3 Expanded Support Facilities ...................... 12
4.1.4 News Center, Public Information, and News Media .. 12
4.2 Emergency Equipment ..................................... 13
4.2.1 Assessment Equipment ............................. 13
4.2.1.1
Emergency Kits and Emergency Survey
Instruments ............................
13
4.2.1.2
Emergency Monitoring Systems ............ 14
4.2.1.3
Nonradiation Process Monitors .,......... 15
4.2.1.4
Meteorological Instrumentation .......... 15
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'4.2.2
Protective Equipment ............................. 15'
4.2.2.1
Respiratory Protection .................. 15
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.4.2.2.2
Protective Clothing ..................... 16
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4.2.3 Communications .................................... 16
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4.2.4 Damage Control / Corrective Action ................. 17
4.2.5_ Reserve Emergency Supplies and Equipment ......... 18
4.2.6 Transportation .................................... 18
5.0 EMERGENCY ~ IMPLEMENTING PROCEDURES ............................ 18
'5.1
General Content and Format .............................. 18
5.2 . Emergency, . Alarm, and Abnormal Occurrence Procedures .. . . 20
5.3 Implementing Instructions ............................... 21
5.4 Implementing Procedures ................................. 22
5.4.1 Notifications .................................... 22
5.4.2 Assessment Actions ............................... 23
5.4.2.1
Dose Assessment ......................... 23
5.4.2.2
Offsite Radiological Surveys ............ 24
5.4.2.3
Onsite (Out-of-Plant) Radiological
Surveys .................................. 25
5.4.2.4
In-Plant Radiological Surveys ........... 25
5.4.2.5
Radiological.and Environmental Monitoring.
Program ................................. 26
5.4.3 Protective Actions ............................... 26
5.4.3.1
Radiation Protection During Emergencies . 26
5.4.3.2
Evacuation of Owner-Controlled Areas .... 27
5.4.3.3
Personnel Accountability ................ 27
5.4.3.4
Personnel Monitoring and Decontamination ~.28
5.4.3.5 Onsite Fi rst-Aid / Rescue . . . . . . . . . . . . . . . . . 28
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5.4.4 Security During Emergencies ....................... 29
5.4.5 Repair / Corrective Action ......................... 29
5.4.6 R e c o v e ry . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . 2 9
5.5 Suppl ementa ry Procedure s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
5.5.1
Inventory, Operational Check, and Calibration of
Eme rg e n cy Eq u i pme n t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
5.5.2 Drills and Exercises ............................. 30
5.5.3 Review, Revision, and Distribution ............... 30
5.5.4 Audits of Emergency Preparedness ................. 31
6.0 - COORDINATION WITH OFFSITE GROUPS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
7.0 DRILLS, EXERCISES, AND WALK-THROUGHS ......................... 32
7.1 Wa l k-Th ro u g h Ob s e rva t i o n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
7.1.1
Eme rg e n cy De tecti o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 3
7.1.2 Emergency Cl a ssi ficati on . . . . . . . . . . . . . . . . . . . . . . . . . 33
7.1.3 Notification ..................................... 33
7.1.4 Do se Cal cul ati on s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
7.1.5 Protective Action Decisionmaking ................. 34
7.1.6 Offsite, Onsite, and In-ilant Radiological
Monitoring ....................................... 35
8.0 EX I T M E ET I NG . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 5
9.0 PERSONS CONTACTED ............................................ 36
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DETAILS
1.0 ADMINISTRATION OF EMERGENCY PREPAREDNESS
The administration of the applicant's emergency preparedness program was
reviewed with respect to the requirements of 10 CFR 50, Appendix E,
paragraph IV.A; and the criteria contained in NUREG-0654, Sections II.A
and P.
The appraisal team reviewed responsibilities assigned for the
administration of emergency planning, including authorities given to the
emergency planning manager.(EPM); coordination with onsite and offsite
organizations, and members of the public.
In addition, the appraisal team
reviewed the selection and qualifications of the emergency planning staff;
held discussions with members of the staff; reviewed position descriptions
and individual qualifications; and reviewed in place training programs for
. ensuring that the' staff remains abreast of current developments in the
emergency preparedness area.
Based on the above findings, this portion of the applicant's program
appears to be adequate.
'2.0
EMERGENCY ORGANIZATION
.The appraisal team reviewed the applicant's emergency response
organization against the requirements of 10 CFR 50.47 and 10 CFR 50,
Appendix E, paragraph IV.A.
In addition, the appraisal team reviewed
CPSES Emergency Plan, Revision 10, dated July 27, 1988 (hereafter referred
to as the Emergency Plan or EP) and Emergency Plan Procedures (EPPs), and
held discussions with applicant personnel to evaluate the emergency
organization.
The EP considers three basic augmentation phases (i.e., staffing levels):
. initial, intermediate, and final augmentation. The initial phase consists
of the minimum staff operating the plant (i.e., in particular, during back
shifts). The intermediate phase comprises the fully staffed onsite
emergency organization, formed within about 60 minutes. The final
augmentation phase includes the first two staffing levels, plus additional
corporate staff and other support groups. A fourth recovery phase would
be entered after the reactor has stabilized and any significant releases
of radioactivity to the environment and any further potential for releases
has ceased. At that point, the applicant will implement an organization
designed to recover from the accident. The recovery phase will be further
discussed in Section 5.4.6.
The applicant's emergency organization is identified in Section 1 of the
EP. This included a description of the various phases of augmentation,
including organizational charts and lists of duties and respon'sibilities
for some of the organizational elements.
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The appraisal team noted the following:
"
The EP failed to describe the functional breakdown of the initial
phase of the emergency organization consisting of the minimal staff
operating the plant. Emergency titles and specific duties of the
various organizational elements, including non-supervisory positions,
were lacking.
The applicant's organizational description did not include a block
diagram showing the chain of command and information flow for the
initial emergency phase.
The assignment of dose assessment responsibilities to the shift
technical advisor (STA) does not agree with NUREG-0737, Appendix C.
The STA is a critical element of the operations staff responsible for
technical support to operations during emergency conditions.
Dose
assessment responsibilities could prevent the STA from performing
primary operations duties assigned to the STA.
Although the EP described the general duties of some supervisory
elements (i.e., emergency coordinators [ECs]), specific details on
the organizational structure of the intermediate augmentation phase,
including a detailed functional breakdown for supervisory and
non-supervisory elements, were not provided.
The EP did not clearly present, by a separate organizational chart,
the organizational structure of the intermediate phase; including
lines of command, information flow, and interrelationships among
organizational elements.
The emergency organization chart (Figure 1.4) in the EP represents
the final augmentation phase due to the inclusion of corporate
support and emergency operations facility (EOF) activation. Again,
the description of the organization was obscured by the attempt to
represent three distinct phases of augmentation occurring at
different times, by one block diagram.
Procedures requiring the formal transfer of EC responsibilities from
the control room (CR) to the technical support center (TSC) or to the
EOF failed to indicate as a necessary condition that the ERF needs to
be fully activated for the EC to be able to adequately perform
duties.
The numbar of persons reporting directly to the EC appears to be
excessive. A study of the information flow patterns from and to the
EC would be needed to ensure that an excessive number of simultaneous
information inputs would not saturate the EC and result in deficient
coordination and control.
,
Based on the above findings, the following items are identified as
significant appraisal findings-
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Review the description of your emergency organization and revise it
as necessary to provide a clear depiction of all emergency functions
required during initial, intermediate, and final phases of
augmentation and recovery; update the' site and corporate EPs to
describe the updated organization; and revise and issue implementing
procedures which have been human engineered so that all emergency
response tasks can be carried out using the command and information
pathways of the organization. The updated description of the
emergency organization should include a sufficient level of detail:
clearly specify the command hierarchy, its structure, and reporting
chains and interrelationships at any phase of augmentation, and
include supervisory as well as non-supervisory elements.
(445/8943-01; 446/8943-01)
o
Remove dose assessment responsibilities from the STA in order to
comply with NUREG-0737, Appendix C.
(445/8943-02; 446/8943-02)
3.0 TRAINING
The appraisal team reviewed the applicant's training program with respect
to the requirements of 10 CFR 50, Appendix E, paragraph IV.F and the
criteria contained in NUREG-0654, Planning Standard 0, and the training
and retraining requirements for individuals assigned emergency duties and-
responsibilities as outlined in Section 13 of the EP and described in
Procedure TRA-105, " Emergency Preparedness Training."
The appraisal team noted that the training program described the initial
training and annual retraining for specific categories of emergency
personnel, including personnel onsite and corporate support personnel, but
.
no qualification requirements were specified for each emergency position.
Personnel were assigned to the emergency organization based on their
supervisor's judgement and their regular duties.
The appraisal team noted that hands-on training or drills were.not used to
qualify emergency response personnel; however, instructors were aware of
the need to conduct practical hands-on training and drills, and as a
consequence, made attempts to perform this type of training immediately
after the classroom training for that module, even though the procedures
and lesson plans did not require it. The appraisal team found no written
requirement that an individual participate in a full-scale drill.
The appraisal team noted that the training program was being implemented
in accordance with the training manual; however, all training had not been
completed.
For example, 31 percent of the public information training,
and 58 percent of the cardiopulmonary resuscitation training were still
l
pending.
In addition, the appraisal team noted that completion of
emergency systems and related procedures will require additional training.
The appraisal team noted that the training records documented ~the status
of emergency personnel participation in hands-on training or drills
associated with specific classroom training modules.
Records of
participation in the full-scale drills were being added to the computer
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training record system so that personnel without full-scale drill
experience could be identified.
Based on the above findings, the following items are identified as
significant appraisal findings:
Complete. training for emergency response personnel including any
'
training associated with the completion of emergency systems and
related procedures.
(445/8943-03; 446/8943-03)
Review and revise training requirements to include practical,
hands-on training, and drill participation.
(445/8943-04;
446/8943-04)
'
Develop specific qualification requirements for each position in the
emergency response organization.
(445/8943-05; 446/8943-05)
4.0 EMERGENCY FACILITIES AND EQUIPMENT
4.1 Emergency Facilities
4.1.1
Assessment Facilities
4.1.1.1
Control Room
The appraisal team reviewed the CR pursuant to the requirements of
10 CFR 50.47(b)(8); 10 CFR 50, Appendix E, paragraph IV.E; and the
criteria of NUREG-0654, Secticn II.H.
The appraisal team toured the CR to determine if updated copies of
the EP and the EP implementing procedures were in place; that the
emergency equipment specified in the EP was available and operable;
'and if the general status of completion of the CR would support
emergency preparedness operations.
In addition, the appraisal team
reviewed Procedure EPP-112, Revision 6. " Duties of Control Room
Personnel During Emergencies."
The appraisal team noted that several systems that would be used in
emergency operations, such as the Digital Radiation Monitoring
System (DRMS) (RM-11) and support systems such as CR heating,
ventilation, and air conditioning system (HVAC), were in various
stages of completion. Specifically, 80 of 96 channels of
instrumentation in the RM-11 had been installed and tested, and were
being controlled under the preventive maintenance program.
(The
remaining 16 channels were expected to be completed in late
August 1989. Duct-work modifications and other work being performed
in the CR HVAC system were expected to be completed and turned over to
the applicant in September 1989.)
,
Based on the above findings, the following item is identified
as a significant appraisal finding:
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Complete the installation and testing of instrumentation,
systems, and controls in the CR that are required to assess
plant and environmental conditions. (445/8943-06; 446/8943-06)
4.1.1.2
Technical Support Center (TSC)
The appraisal team reviewed the TSC pursuant to the requirements of
10 CFR 50.47(b)(8); 10 CFR 50, Appendix E, paragraph (IV)(E); and the
. criteria of NUREG-0654,Section II.H. .The appraisal team also
reviewed the EP and Procedure EPP-204, Revision 7, " Activation and
Operation of the TSC;" and supporting procedures for activities and
responsibilities of the TSC staff.
The appraisal team noted that the incomplete csndition of the CR
ventilation system affected the TSC in that the TSC ventilation
system is a part of the CR system.
The level of ongoing construction effort in the CR and TSC made
,
matters of general. housekeeping a concern, particularly in the
L
corridor and adjacent areas.
Dust and construction debris were noted
on various terminals, ERF computer, printers, and on shelves and
technical. manuals' in the TSC library.
Based on the above findings, the following item is identified as
a significant appraisal finding:
1E
Complete the installation of TSC equipment.
(445/8943-07;
'446/8943-07)
.
4.1.1.3
Operations Support Center (OSC)
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The appraisal team reviewed the OSC and alternate OSC pursuant to the
l
requirements of 10 CFR 50.47(b)(8); 10 CFR 50, Appendix E,
l
paragraph IV.E; and the criteria in NUREG-0654,Section II.H.
The
appraisal' team also reviewed the EP and Procedure EPP-205,
" Activation and Operation of the Operations Support Center (OSC)."
The appraisal team noted that a telecopier was listed as required
equipment in the OSC to facilitate communications between ERFs.
However, the team learned that the machine was in routine use in the
maintenance building. The OSC emergency equipment list was not
annotated to reflect the actual location of the machine, and no
person was assigned the responsibility to transport the machine to
the OSC in the event of an accident.
Based on the above findings, the following matter is considered
an improvement item:
~
Position the required, dedicated emergency equipment in the OSC
or provide assurance that all required equipment will be
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properly located in the event of an emergency.
(445/8943-08;
446/8943-08)
4.1.1.4
The appraisal team reviewed the EOF 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 appraisal team reviewed
the EP and Procedure EPP-206, " Activation and Operation of the
Emergency Operations Facility (EOF)."
The appraisal team toured the EOF to assure that all equipment and
facilities specified by the EP were installed and operable. The
appraisal team noted that the facility was complete with all
communication systems installed and operable.
The EOF was found to be adequately equipped with supplies and
equipment to perform its intended function. The team did note,
however, that although an emergency planning zone map (10-mile EPZ)
was installed, a 50-mile ingestion pathway map was not available in
the EOF command center to assist in the assessment of offsite
radiological conditions.
Based on the abe n findings, the following item is identified
as a significant appraisal finding:
Install an ingestion pathway map to assist in monitoring the
'
efforts of offsite authorities responsible for defining the
extent of long term, offsite radiological conditions.
(445/8943-09; 446/8943-09)
4.1.1.5
Offsite Laboratory Facilities
The appraisal team reviewed offsite laboratories with respect to the
requirements in 10 CFR 50.47(b)(8); 10 CFR 50, Appendix E,
paragraph IV.E; and criteria in NUREG-0654, Sections II.H and I.
In
addition, the appraisal team reviewed Sections 6.7 and 6.8 of the EP;
toured the applicant's laboratory located in the nuclear operations
support facility (NOSF); and interviewed several staff chemists. The
appraisal team noted that the applicant had not completed the setup
of the multichannel analyzer and the sodium iodide (NaI) detector
that would be used for spectral analysis of environmental samples.
No considerations had been given to detector-source geometries when
counting soil, vegetation, and water samples.
Based on the above findings, the following matter is identified as a
significant appraisal finding:
Complete the setup of the multichannel analyzer and'NaI detector
for counting environmerital samples.
(445/8943-10; 446/8943-10)
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4.1.2 :
Protective Facilities
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4.1.2.1
Assembly / Reassembly Areas
The appraisaliteam reviewed assembly / reassembly areas with respect to
.the requirements of 10 CFR 50.47(b)(0), 10 CFR 50, Appendix E,-
paragraph IV.E; and the criteria in NUREG-0654,Section II.J.
In
addition, the appraisal team reviewed the applicant's EP,
Section.8.0, Implementing Procedure EPP-314, and held-discussicrs
with members of the applicant's security management staff.
Tne appraisal team noted that the applicant had identified adequate
assembly areas inside~and outside of the pas, and these areas were
clearly marked and boundaries delineated.
In addition, the appraisal
team noted that site personnel had received training on evacuation
routes.and assembly areas. Evacuation' routes were' clearly marked.
The appraisal team noted that designated assembly areas outside the
PA were large and appeared to have the capability to hold all
evacuated personnel.
Bashdontheabovefindings,thisportionoftheapplicant'sprogram
appears to be adequate.
4.1:.2.2
Medical Treatment Facilities
The appraisal teta reviewed medical treatment facilities with respect
to.the requirements of 10 CFR 50.47(b)(12); 10 CFR 50, Appendix E,
paragraph IV.E; and criteria in NUREG-0654,Section II.L.
In
addition, the appraisal team reviewed Sections 10.2 and 10.3 of.the
EP and Procedure EPP-313 entitled, " Medical Re:ponse." The appraisal
team toured the first-aid facilities and conducted interviews with
representatives of the applicant's radiation protection, fire and
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medical, and industrial safety staffs.
The appraisal team noted that medical kits were not fully assembled.
First-aid supplies were found in the Electrical and Control Building
instead of in the Turbine Building as described in the EP.
In
addition, the appraisal team noted that supplies were not stored in
an orderly fashion.
The appraisal team noted that Section 10.3 of the EP stated that an
ambulance was available ensite for transporting injured personnel to
the appropriate medical facility. However, this ambulance was found
to be under the control of the construction contractor who has plans
to turn over the ambulance to the applicant before plant licensed
'operatiens commence. The appraisal team noted that Hood General
Hospital Ambulance Services was the primary ambulance service until
the onsite ambulance is available.
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Based on the above findings, the following item is identified as
a significant appraisal finding:
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Assemble medical kits containing key medical supplies for
emergency response personnel who would respond as part of the
first-aid team.
(445/8943-11; 446/8943-11)
In addition to the above finding, the following matters are
considered improvement items:
Maintain first-aid supplies in an orderly fashion.
(445/8943-12; 446/8943-12)
f
Review and revise Section 10.2 of the EP to reflect the correct
location of the onsite first-aid supply area and that Hood
General Hospital Ambulance Service is the interim ambulance
service and complete the turnover of the ambulance service.
(445/8943-13; 446/8943-13)
4.1.2.3
Decontamination Facilities
The appraisal team reviewed decontamination facilities with respect
^
to the requirements of 10 CFR 50.47 (b)(8); 10 CFR 50, Appendix E,
paragraph IV.E; and criteria in NUREG-0654, Sections II.J and K.
In
addition, the appraisal team reviewed Sections 6.9 and 9.3 of the
applicant's EP and examined the decontamination facilities located in
the Electrical and Control Building and the NOSF, and held
discussions with radiation protection personnel cognizant of the
decontamination' facility.
The appraisal team noted that the decontamination facility was
located in the Electrical and Control Building and not in the Turbine
Building as stated in the EP.
In addition, the appraisal team found
that' decontamination supplies were not in place, and that the
applicant had no requirements for performing an inventory of
decontamination supplies.
Based on the above findings, the following item is identified as
a significant appraisal finding:
Provide decontamination supplies in decontamination facilities.
(445/8943-14; 446/8943-14)
In addition to the above findings, this portion of the applicant's
program appears to be adequate, but the following matter is
considered an improvement item:
Review and revise Sem: tion 6.9 of the EP to list the _ electrical
and control building as the location of the decontamination
facility in the plant rather than the turbine building.
(445/8943-15; 446/8943-15)
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4.1.3.
Expanded Support Facilities
The appraisal team reviewed expanded support facilities pursuant to
the requirements of 10 CFR 50.47(b)(8); 10 CFR 50, Appendix E,
paragraph IV.E; and criteria in NUREG-0654,Section II.H.
The appraisal team noted that the applicant's expanded support
facilities consisted of the NOSF and the logistical support center.
These facilities normally performed functions that would be
expected to be performed in the event of an emergency. Corporate,
,
contractor, and other personnel would be adequately supported with
communications and evaluation equipment, such as computers and
reference materials.
The NOSF housed a complete document library
just outside the EOF command center.
Based on the above findings, this portion of the applicant's program
appears to be adequate.
4.1.4.
News Center, Public Information, and News Media
The appraisal team reviewed the applicant's News Center and the
programs to disseminate information to the news media and to the
public against the requirements of 10 CFR 50.47(b)(7), Appendix E,
paragraph IV.E; and criteria in NUREG-0054,Section II.G.
The appraisal team reviewed Section 6.4 of the EP; reviewed
Procedures EPP-207, " Actuation of the News Center and Personal
Duties," and CEPP-108, " Release of Emergency Related Information;"
interviewed the information coordinator; and inspected the News
Center.
The appraisal team noted that Procedure EPP-207 did not establish the
principal points of contact for the local news media and the offsite
support agencies for the initial dissemination of information to the
public. The applicant stated that the procedure in question was to
be re-written, based on the recommendations of an INPO audit, and the
revised procedure would include specific instructions as to the
agencies and media groups to be contacted.
At the time of the appraisal, a news media seminar had not been
conducted.
The applicant stated that a seminar would be conducted on
July 13, 1989, with invitations extended to the local media and the
major news services. At this meeting, the applicant would establish
the utility points of contact and the physical location where the
media can obtain information during an emergency.
The appraisal team
also noted that media training for the CPSES staff was about
20 percent complete at the time of the appraisal.
~
Based on the above findings, the following items are identified as
significant appraisal findings:
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Revise Procedure EPP-207 to provide specific instructions as to
the news media and offsite agencies to be contacted initially
for the dissemination of information to the public.
(445/8943-16; 446/8943-16)
Complete the news media seminar providing the news media with
the utility points of contact and locations where accident
information can be obtained.
(445/8943-17; 446/8943-17)
Complete the training of the CPSES staff on their duties in the
News Center and dissemination of information to the public.
(445/8943-18; 446/8943-18)
4.2 Emergency Equipment
4.2.1
Assessment Eouipment
4.2.1.1
Emergency Kits and Emergency Survey Instruments
The appraisal team reviewed emergency survey kits pursuant to the
requirements of 10 CFR 50.47(b)(9); 10 CFR 50, Appendix E,
paragraph IV.C; and the criteria of NUREG-0654, Sections II.H and I.
The appraisal team examined equipment and supplies designated for use
during facility emergencies.
Emergency equipment was found stored in
labeled lockers, cabinets, or foot lockers located in or adjacent to
the associated ERF. The storage facilities were found as specified
in the EP except that Procedure EPP-901, " Maintenance and Inventory
of Emergency Equipment and Supplies," Attachment 1 (Mo.ithly Inventory
Summary), reflected locations of supplies that were no longer
applicable or correctly listed as to location.
Specifically,
Attachment 1 listed an OSC cabinet on the 825-foot 6-inch level which
was no longer used and the EOF kit was listed as a cabinet which has
been deleted.
EOF supplies were properly stored in the EOF emergency
storage room.
The appraisal team performed inventories of the emergency kits, and
noted that the CR kit lacked one flashlight.
Spare batteries in all
kits were not uniformly marked as to " shelf life," and others had no
marking. The battery powered, self-reading pocket dosimeter charger
located in the CR kit did not reflect a date for installation of the
battery.
The appraisal team noted that emergency kits contained ample supplies
of potassium iodide (KI) for emergency workers, and manufacturer's
instructions were available regarding cosage and cautions associated
with usage. The appraisal team determined by interviews with
emergency workers that no iodide tolerance testing had be.en performed
for site personnel.
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Based on the above findings, the following matters are considered
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improvement items:
Include the correct storage locations of emergency kits in
procedures.
(445/8943-19; 446/8943-19)
Mark spare batteries with shelf life expiration dates to permit
persons performing inventories to readily determine if supplies
are adequate. (445/8943-20; 446/8943-20)
Provide KI tolerance testing for emergency responders.
(445/8943-21; 446/8943-21)
4.2.1.2
Emergency Monitoring Systems
The appraisal team reviewed the emergency monitoring systems pursuant
to the requirements of 10 CFR 50.47(b)(9); 10 CFR 50, Appendir. E,
paragraph IV.E; and criteria in NUREG-0654,Section II.H.
The appraisal team noted that the DRMS was installed but undergoing
repair and testing. Specifically, 16 of 96 channels directly related
to emergency response were in various stages of completion. The
planned completion date for turnover of a fully tested, operational
system was August 1989. All preventive maintenance requirements have
been identified and procedures prepared. Not all calibrations had
been completed at the time of the appraisal.
The appraisal team confirmed that the displays for the DRMS panels
for the various instrument channels had physical units, but the local
panel instrument racks did not include physical units on the
instrument channels (e.g., panel CPX-ECPRCV-10. "N Vent Stack PIG").
In event of failure of the DRMS display, operators would have to
obtain local it;strument channel readings, therefore, physical units
should be readily apparent on the instrument display.
Based on the above findings, the following item is identified as
a significant appraisal finding:
Complete the installation, testing, and turnover of the DRMS
system, and confirm that instrument maintenance and calibration
checks are performed in accordance with applicable requirements.
(445/8943-22; 446/8943-22)
In addition to the above findings, the following matter is
considered an improvement item:
Assure that proper physical units are available at local
instrument channel racks for ARM and PRM read-outs.
~
(445/8943-23; 446/8943-23)
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'4.2.1.3
Non-Radiation' Monitors
=The apprairal team reviewed the non-radiation process monitors
intended to measure vital parameters of a non-radiological nature
'(e.g., plant pressures, temperatures, flows,. seismic events, etc.)
which would be relied upon for accident detection, classification,
assessment, and mitigation; pursuant 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 appraisal team noted that installation of all non-radiation
monitors was complete, but operational testing of the seismic
monitoring system had not been complete.
~ Based'on the above. findings, the following item is identified as
a significant appraisal finding:
- Complete the installation, testing, and turnover of
non-radiation process monitoring systems.
Initiate appropriate
preventive maintenance checks on the systems and conduct
appropriate training on operation, analysis, and distribution of
data obtained from the system.
(445/8943-24;~446/8943-24)
4.2.1.4
Meteorological Instrumentation.
The appraisal team reviewed meteorological instrumentation pursuant
to 10 CFR 50.47(b)(9);'10 CFR 50, Appendix E, paragraph IV.B;
Regulatory Guides 1.23, 1.97, and 1.101; and the criteria in
NUREG-0737. 'In addition, the appraisal team reviewed Section 6.13.5-
of the applicant's EP and Procedure STA-714, " Meteorological
Moritoring Program," and held discussions with the applicant's
representative responsible for the meteorological system.
The appraisal team noted that the primary meteorological tower was
destroyed in a recent storm and was scheduled to be operational in
late July 1989. The new tower is to be constructed in the same
location as the old tower.
Based on the above findings, the following item is identified as
a significant appraisal finding:
Complete the construction and installation of the primary
meteorological-tower and related equipment.
(445/8943-25;
446/8943-25)
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4.2.2
protective Equipment
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4.2.2.1
Respiratory Protection
,
The appraisal team reviewed respiratory protection equipment pursuant
to the requirements of 10 CFR 50.47(b)(11); 10 CFR 50, Appendix E,
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paragraph IV.E; and criteria in NUREG-0654,Section II.H.
The
appraisal team inspected the SCBAs available in the CR, TSC, and EOF
and noteo' that SCBAs were not available in the OSC, but were located
in the adjacent corridor leading to the radiologically controlled
areas.
Each facility was provided with a large number of full-face
respirators with particulate and iodine cartridges. The applicant
had a large number of spare SCBA bottles, and had multiple
capabilities for filling SCBA bottles. The appraisal team examined a
spare bottle at a storage location on the open turbine deck and noted
that no dust cap / thread protector devices were installed. Without
protection, the threads could be damaged, and residue could collect
in the air nozzles.
Based on the above findings, the following matter is considered
an improvement item:
Install protective dust caps / thread protectors on spare SCBA
bottles.
(445/8943-26; 446/8943-26)
4.2.2.2
Protective Clothing
The appraisal team reviewed protective clothing supplies pursuant to
the requirements of 10 CFR 50.47(b)(8); 10 CFR 50, Appendix E,
paragraph IV.E; and criteria in NUREG-0654,Section II.H and J.
The appraisal team observed the stores of protective clothing and
determined that the protective clothing would be accessible, under
,
emergency conditions, to persons assigned to the facilities, and that
'
protective clothing supplies were adequate and ready for use.
Based on the above findings, this portion of the applicant's program
appears to be adequate.
4.2.3
Communications
The 6ppraisal team reviewed the emergency communication systems
pursuant to the requirements of 10 CFR 50.47(b)(6); 10 CFR 50,
Appendix E, paragraph IV.E; and criteria given in NUREG-0654,
Section II.H and J.
The appraisal team reviewed the applicant's communication systems and
the instructions for use as. described in Procedure EPP-202,
" Emergency Communications." All communication systems were in place
and operable.
Monthly communication tests'specified by
Procedure EPP-901, " Maintenance and Inventory of Emergency Equipment
and Supplies," had not been initiated.
Paragraph 2.0 of the
procedure stated that the procedure would not be implemented until
1
90 days before receipt of an operating license.
The applicant
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completed a check during the period of the appraisal. No problems
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were identified.
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~The appraisal team noted that paragraph 4.3.5 of Procedure EPP-901,
"Special Telephone Circuits," did not include the Point-to-Point
telephones located. in .the CR, TSC, OSC, Alternate OSC, EOF, and OSC;
therefore, these. circuits would not be scheduled for testing. The
Point-to-Point telephones were listed as emergency telephones in
>
EPP-202, " Emergency Communications."
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The appraisal team noted that the applicant's Gaitronics system used
for plant announcing, paging, and alarms was installed and operable
-except for the Unit 2 Gaitronics. The appraisal team determined that
no periodic testing of the plant alarms was being conducted. The
applicant stated that preventive maintenance had been established for
the system, but testing had not been performed.
The appraisal team noted that the applicant had increased the number
of.available channels on FM portable radios to a number that
permitted.first-aid, operations, and offsite survey teams to operate
on independent channels. However, the addition of channele was
accompanied by the disadvantage that the TSC, responsible 'or dose
assessment until relieved by EOF, was unable to monitor the results
of field surveys by off-site monito:ing teams.
Results had to be
passed through the OSC 'since only the OSC and the EOF have the proper
frequency for' communicating with offsite teams.
Based on the above findings, the following matter is considered
an improvement item:
"-
Initiate periodic testirg as appropriate for all emergency
communication systems; review and revise procedures to rere se
periodic' testing of all emergency communication' systems; or.
increase the FM radio capability at the TSC to permit monitoring
of emergency channels.
(445/8943-27; 446/8943-27)'
4.2.4
Damage Control / Corrective Action
The~ appraisal team reviewed procedures, maintenance equipment, and
supplies pursuant to the requirements of 10 CFR 50.47(b)(8);
20 CFR 50, Appendix E, paragraph IV.E; and criteria in NUREG-0654,
Section II.H.
The appraisal team determined that Procedure EPP-116, " Emergency
Repair and Damage Control," was the governing procedure for
initiating and implementing emergency repair functions.
Issues such
as team composition, planning, equipping, routing, and authorization
,,
were adequately covered by the procedure.
Identification of special
equipment was addressed in the planning phase, with ready
availability of tools in the tool crib of the Maintenance Building.
Based on the above findings, this portion of the applican't's program
appears to be adequate.
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4.2.5
Reserve Emergency Supplies and Equipment
The appraisal team reviewed reserve emergency supplies and equipment
pursuant to the requirements of 10 CFR 50.47(b)(B); 10 CFR 50,
Appendix E, paragraph IV.E; and criteria in SUREG-0654,Section II.H.
~The appraisal team interviewed site personnel and determined that
adequate stocks and supplies of emergency equipment were maintained-
at the warehouse and in-plant locations to support a prolonged
emergency response.
Based on the above findings, this portion of the applicant's program
appears to be adequate.
4.2.6
Transportation
The appraisal team reviewed the transportation equipment available
for emergency response pursuant to the requirements of
10 CFR 50.47(b)(8); 10 CFR 50, Appendix E, paragraph IV.E; and
,
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criteria in NUREG-0654,Section II.H.
The appraisal team determined that Procedure EPP-10R, " Control of
Designated Emergency Use Vehicles used for Routine Operations," was
the controlling procedure for three designated emergency vehicles.
The. appraisal team exa.nined the .four wheel drive vehicles and their
emergency kits and equipment, including two-way transceivers, and
concluded that.the vehicles were readily available for their intended
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use and could readily accomplish their function.
Based on the L ve findings, this portion of the applicant's program
appears to be adequate.
5.0 EMERGENCY IMPLEMENTING PROCEDURES
5.1 General Content and Format
The appraisal team reviewed the general content and format of EPPs
pursuant to the requirements of 10 CFR 50.47(b)(5) and (6); 10 CFR 50,
Appendix E, paragraph IV.D; and criteria in NUREG-0654,Section II.E
F.
H, and J.
The appraisal team noted that all EPPs conformed to a standard format that
-specified purpose, applicability, definitions, references, procedural
steps, and attachments anci checklists.
The appraisal team identified the following discrepancies in the
procedures:
a.
Procedure EPP-112. " Duties of CR Personnel During Emergen'cies,"
paragraph 4.2.2, " Shift Technical Advisnr," assigned the STA
secondary duties of performing dose assessment calculations. This
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assignment of the'STA to dose calculations was not consistent with
the guidance of NUREG-0737, Appendix C.
An alternate staff member
should be trained to perform dose assessment' functions to permit the
STA uninterrupted ability to monitor plant critical safety functions,
evaluate and analyze plant transient response, and perform accident
mitigation and other matters related to operational safety.
(See
Section 2 of this report.)
b.
Procedure EPP-204, " Activation and Operation of the Technical Support
Center (TSC)," addressed the subject of core damage assessment with a
note that required laboratory analysis of plant vent iodine and
particulate samples to be reported to the CR within I hour of.
sampling, and post-accident sampling system (PASS) results to be
completed within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> of the time the decision was made to obtain
the sample. The appraisal team determined that it was appropriate to
establish goals for_ performing analysis. However, writing the
procedure in a fashion that requited an activity to be performed that
may be impossible to achieve was not deemed appropriate.
!
Procedure EPP-206, " Activation and Operation of the Emergency Operations
Facility (EOF)," contained the following discrepancies:
a.
Action statements for the emergency staff, related to relocating the
EOF, were either inaccurate or incomplete.
For example, Table 4.3.6
directed the offsite radiological assessment coordinator to repor
to
the TSC onsite radiological assessment coordinator (ONRAC) to assist
with dose assessment responsibilities. DJe to limited TSC physical
size and probable radiological conditions, it was noted as highly
unlikely that any additional persons could be transported to or
accommodated in the TSC under accident conditions that required
relocation of the EOF.
b.
The apprai. cal team noted that after the activation of EOF, the
radiological assessment manager (RAM) and the EOF manager (EOFM) will
perform dose assessment and decisionmaking pertaining to PARS
in accordance with the guidance of NUREG-0737, Supplement 1, Table 1.
However, in the event the EOF became uninhabitable, the EOFM would go
to tha alternate EOF and the RAM to the TSC. This is contrary to the
guidanceofNUREG-0737,jupplement1.
In addition, the applicant did not provide instructions for
performing the functions of the EOFM and the RAM while they are in
transit from the EOF to the alternate EOF and to the TSC.
c.
Some persons were not directed to report to any location upon
relocation of the EOF, e.g., the EOF communications coordinator
(Table 4.3.13).
Procedure EPP-901, " Maintenance and Inventory of Emergency Eqtiipment and
Supplies," included Attachment 2, " Verification of Operability of
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Designated Emergency Equipment." This attachment was intended as an
equipment guide list; however, the equipment was not specified.
Several informal. documents were used to implement required functions in
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the 'cC,.such as a communications workbook, operational instructions for
the "-
radio, and an engineering workbook contained appendices and tables
cont O 'ng capacities, curves, and other plant information. The color
coded EAL classification flow charts in the ERFs were not annotated as to
title, revision, or source, The above examples were uncontrolled
documents that could contain erroneous information. The appraisal team
determined;that' operational instructions should be included in_the
applicable procedures and that design information should be verified
correct and then controlled. Job aids, such as EAL classification
schemes, snould be marked with the latest revision /date and compared to
centro 11ed document inventory lists before use.
The plant specific emergency operating procedures (EOPs) were contained in
binders entitled " Emergency Response Guidelines," which were noted to be
the title of generic vendor guidelines from which the plant specific E0Ps
were. derived. The. binders should use correct titles to be readily
identifiable.
Based on the above findings, the following items are identified as
significant appraisal findings:
Complete the review and revision of the EAL/ Emergency Classification
procedure.
(445/8943-28; 446/8943-28)
Revise procedures to assign a staff member other than the STA to
perform dose assessment functions until the CR is relieved of the
function by the TSC. (445/8943-29; 446/8943-29) (See also
G5/8943-02; 446/8943-02.)
In addition to the above findings, the following matter is considered
an improvement item:
Review and revise emergency procedures to correct errors and
discrepancies. (445/8943-30; 446/8943-30)
.
5.2 Emergency, Alarm, and Abnormal Condition Procedures
The appraisal team reviewed the alarm response procedures (ALPS), the
abnormal condition procedures (ABNs), and the emergency response
guidelines pursuant to the requirements of 30 CFR 50.47(6) and (8);
10 CFR 50, Appendix E, paragraph IV.E; and the criteria in NUREG-0654,
.
_
LSection II.H.
The appraisal team noted that the ALPS did not refer to the EP,or EP
. procedures.
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Some of the ABNs that would be entered in response to conditions requiring
activation of the EP, had no specific reference to the EP or an EP
procedure. The ABNs reviewed were:
1.
ABN-103A, "High Reactor Coolant Activity"
2.
ABN-803A, " Response to a Fire in the Control Room or Cable Spreading
Room"
3.
ABN-804A, " Response to Fire in the Safeguards Building"
4.
ABN-805A, " Response to Fire in the Auxiliary Building or the Fuel
Building"
5.
ABN-806A, " Response to Fire in the Electrical and Control Building"
6.
ABN-807A, " Response to Fire in the Containment Building"
7.
ABN-808A, " Response to Fire in the Service Water Intake Structure"
8.
ABN-809A, " Response to Fire in the Turbine Building"
~ Based on the above findings, the following matters are considered
improvement items:
Review the ALPS and include appropriate references to
Procedure EPP-201.
(445/8943-31; 446/8943-31)
Correct inconsistencies in referencing the EP in abnormal condition
procedures.
(445/8943-32; 446/8943-32)
5.3 Implementing Instructions
The appraisal team reviewed implementing instructions pursuant to the
requirements of 10 CFR 50.47(b)(5) and (6); 10 CFR 50, Appendix E,
paragraph IV.D; and criteria in NUREG-0654, Sections II.E, F, H, and J.
The appraisal team reviewed implementing instructions to determine if they
adequately implemented the provisions of the EP; provided the EC with an
adequate scope of authority and non-delegable responsibilities; provided
EALs based on observable information with-required response actions; and
directed the implementation of specific procedures required for effective
overall emergency response.
The appraisal team reviewed the applicant's procedure for formulating and
providing PARS with respect to the guidance of IE Information Notice 83-28
and NUREG-0654.
Procedure EPP-304 was reviewed for content, format, and
the method for formulating and communicating PARS during sever.e accidents.
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The appraisai team noted that Procedure EPP-304 did not incorporate the
guidance provided in IE Information Notice 83-28 because the procedure
failed to provide adequate instructions for developing PARS based on
operational assessment of plant conditions, that is, PARS based on the
precursors of a release, such as reactor core and reactor building
containment conditions. All PARS which were developed using EPP-304,
except baseline PARS, were based primarily on dose assessments, either
,
actual or projected.
Further, Procedure EPP-304 did not include a
decisionmaking flow chart to facilitate decisionmaking similar to that
shown in IE Information Notice 83-28.
The appraisal team al:c noted that Procedure EPP-304 included unnecessary
considerations for developing and communicating PARS that could result in
unnecessary delays.
Information used by offsite agencies to implement
corrective actions such as weather conditions, population distributions,
special facilities like nursing homes, hospital, prison, and offsite
evacuation routes were included in the applicant's process for
recommending protective actions.
In addition, the appraisal team noted that Procedure EPP-304 required that
decisionmakers review PARS with the Texas Department of Health before
recommending PARS to local officials, which further compromises the
applicant's ability to recommend protective actions within 15 minutes.
Based on the above findings, the following item is identified as
a significant appraisal finding:
Revise Procedure EPP-304 to add guidance for developing offsite
PARS based on operational assessment of plant conditions.
Incorporate, in Procedure EPP-304, a decisionmaking aid such as the
" logic tree" shown in IE Information Notice 83-28, Figure 1, " Flow
Chart for General Emergency Offsite Protective Decisions." Delete,
from Procedure EPP-304, those considerations (such as weather,
special fac ties, and population distributions) that are not
germane to etrectively developing and recommending a protective
action.
Revise Procedure EPP-304 to eliminate the need to discuss
PARS with the state or counties until after the PARS are made to
offsite agencies.
(445/8943-33; 446/8943-33)
5.4 Implementing Precedures
5,4.1
Notifications
The appraisal team reviewed notification procedures with respect to
the requirements of 10 CFR 50.47(b)(5); 10 CFR 50, Appendix E,
paragraph IV.D; and NUREG-0654, Sections II.E and F.
The appraisal team reviewed Procedures EPP-202, " Emergency
Communications," and EPP-203, " Notifications," for adequate
implementation of EP requirements; correlation of notification
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requirements with EALs; adequacy of instructions regarding message
content and equipment use; for provisions for required phone numbers;
and reference to an authentication scheme for initial notifications
to offsite authorities.
Based on the above review, this portion of the applicant's program
appears to be adequate.
5.4.2
Assessment Actions
5.4.2.1
Dose Assessment
The appraisal team reviewed dose assessment procedures against the
requirements in 10 CFR 50.47(b)(9); 10 CFR 50, Appendix E,
paragraph IV.B; NUREG-0654,Section II.I; and Supplement I to
The appraisal team reviewed Section 7.0 of the applicant's EP;
Procedures EPP-206, " Activation and Operation of the EOF," EPP-300,
" Manual Calculation of Offsite Dose Rates," EPP-303, " Micro-Computer
Based Emergency Dose Assessment," and EPP-304, " Protective Action
Guides;" and the documentation of the applicant's dose assessment
system.
In addition, the appraisal team conducted interviews with
key personnel who would have dose assessment responsibility during an
emergency.
The appraisal team noted that the applicant's dose assessment model
used a straight-line Gaussian atmospheric dispersion model which will
not account for' wind shifts nor calculate cumulative doses at
downwind locations. Current state-of-the-art dose assessment models
in the nuclear industry have segmented plume atmospheric dispersion-
models which account for wind shifts and provide the basis for
calculating cumulative doses and doses resulting from ground
deposition.
The appraisal team noted that an audit performed by the applicant
'
revealed that the normalized dispersion parameters (Xu/Q) used in
EDAM were not documented.
The appraisal team noted that the vendor
provided revised Xu/Q to the applicant, but that these values still
need to be formally documented and included in dose assessment
Procedures EPP-300 and EPP-303.
The radiation protection coordinator and the offsite radiological
assessment coordinator have a responsibility to calculate population
dose as defiried in Procedure EPP-206.
Interviews with emergency
response personnel, who would fill these positions in an emergency,
showed that personnel were not cognizant of the methodology to
calculate population doses.
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The appraisal team noted that Procedure EPP-206 references
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Procedure RPI-304, "Populatien Dose Assessment," which is no longer
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an active procedure for calculating population dose. Since the
applicant no longer has the capability te calculate population dose
and there is no requirement for performing population dose early in
an accident, the applicant should consider deleting this function
from Procedure EPP-206.
The appreisal team compared the units on the DRMS with those that
would be inputted to the EDAM computer program, and noted that the
containment high range area monitor (CTE-116) read in counts per
minute on the RM-11 while EDAM required the input in mR/h. Moreover,
the containment high range area Monitor-Train B was listed as CTW-117
on the RM-11 and CTE-117 in Procedures EPP-300 and EPP-303.
Based on the above findings, the following matters are considered
improvement items:
Enhance the emergency dose assessment program with a segmented
plume atmospheric dispersion model that will take wind shifts
into account.
(445/8943-34; 446/8943-34)
Complete the documentation of the Xu/Q values using the dose
assessment model and document these values into procedures.
(445/8943-35; 446/8943-35)
Delete the reference to the calculation of total population dose
from Procedure EPP-206.
(445/8943-36; 446/8943-36)
Ensure that units on the DRMS monitors used for dose assessment
calculations are consistent with those in the RM-11 system, and
the dose assessment model.
(445/8943-37; 446/8943-37)
5.4.2.2
Offsite Radiological Surveys
The appraisal team reviewed offsite radiological survey procedures
pursuant to the requirements of 10 CFR 50.47(b)(8) and (9);
10 CFR 50, Appendix E, paragraphs IV.B and E; and criteria in
NUREG-0654, Sections II.H, I, and K.
In addition, the appraisal team
reviewed Sections 6.13.11, 7.3.2, and Appendix J and H of the EP and
EPP-309, "Offsite Radiological Monitoring." Discussions were also
held with applicant's emergency planning staff cognizant of offsite
radiological monitoring.
The appraisal team noted several areas where pian and procedural
improve.nents could be made. Section 7.3.2 of the EP incorrectly
states that the TSC is in communications with the offsite monitoring
teams. Procedure EPP-309, Section 4.4.7.1 states that samples
returned to the NOSF from the field shall be logged in by the offsite
monitoring personnel on Form EPP-109-1. A review of Form EPP-109-1
showed it to be an emergency organization activities log ' sheet which
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does not appear to be adequate for logging in ramples from the field.
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nducted a walk-through with an offsite monitoring
' team (see Section ..z.6) and noted that samples collected in.the
field would sometimes be transported back to the NOSF via a runner;
hwever, nowhere in Procedure EPP-309 was there any discussion of the
ese'of a runner.
The . laboratory in the NOSF has the capability of performing more
detailed' analyses of environmental samples brought back from the
field using.the Na1 detector counting system (see Section 4.1.1.5).
No procedures exist for routine maintenance and operability checks on.
this system.
In addition, there are no procedures for use of the
system during an emergency which would include information such as
handling, preparation, and counting of the samples, recording of
sample results, and disposition of samples when sampling is complete.
Based on the above findings, the following matters are considered
improvement items:
Rev'se Section 7.3.2 of the EP to indicate the actual
communication link between emergency facilities and the offsite
monitoring teams.
(445/8943-38; 446/8943-38)
Develop a procedure for the routine maintenance and operability
check on the NaI detector system, and describe counting
procedures for environmental samples and the activ * ton of the
countingLlaboratory. (445/8943-39: 446/8943-39)
o.4.2.3
Onsite Out-of-plant Radiological Surveys
The. appraisal team reviewed onsite (out-of-plant) survey procedures
pursuant to the requirements of 10 CFR 50.07(b)(8) and (11);
10 CFR 50, Appendix E, paragraph IV.E; and :riteria fr, NUREG-0654,
'Section II.K.
In addition, the appraisal team revi ved Sections 7.3,
7.3.1, and 8.3 of the EP; Procedure EPP-310, 'O.m te and In-Plant.
Radiological Surveys;" and Procedure EPP-316, " Emergency Repair and
Damage Control." Interviews were held with cognizant members of the
radiation protection staff.
Based on the above review, this portion of the applicant's program
appears to be adequate.
5.4.2.4
In-Plant Radiological Surveys
The appraisal team reviewed in plant survey procedures pursuant to
.the requirements of 10 CFR 50.47(b)(8) and (11); 10 CFR 50,
Appendix E, paragraph IV.E; and criteria in NUREG-0654,Section II.K.
In addition.-the appraisal team reviewed Sections 7.3, 7.3.1, and 8.3
of the EP; Procedures EPP-310, "Onsite and In-Plant Radiological
,
Surveys," and EPP-316, " Emergency Repair and Damage Control," and
.
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interviewed radiation protection technicians and radiation protection
supervisors having emergency response duties.
Based on the above review, this portion of the applicant's program
appears to be adequate.
5.4.2.5
Radiological and Environmental Monitorinq_ Program
The appraisal team reviewed the environmental monitoring program
pursuant to the requirements of 10 CFR 50.47(b)(8), (9), and (11);
10 CFR 50, Appendix E, paragraphs IV.B and E; and criteria in
NOREG-0654, Sections II.H, I, and K.
In addition, the appraisal team
reviewed Sections 6.13.11, 7.3.2, and Appendix J and H of the EP and
Procedure EPP-309, "Offsite Radiological Monitoring," and held
discussions with the emergency planning staff cognizant of off:.ite
radiological monitoring.
The appraisal team noted that the map in Attachment I to
Procedure EPP-309, showing the locations of environmental TLDs, was
.
not legible, and additional training of radiation protection
technicians may be necessary to assist them in finding TLD locations.
Based on the above findings, the following matter is considered
an improvement item:
Provide legible maps showing environmental TLD locations in
Procedure EPP-309 including specific descriptions on how to
reach these locations.
(445/8943-40; 446/8043-40)
5.4.3
Protective Actions
5.4.3.1
Radiation Protection During an Emergency
The appraisal team reviewed the radiation protection program for
emergencies pursuant to the requirements of 10 CFR 50.47(b)(11);
10 CFR 50, Appendix E, paragraph IV.A; and criteria in NUREG-0654,
Section II.K.
In addition, the appraisal team reviewed Sections 9.0,
9.1, 9.2, and 9.3 of the EP, Procedures EPP-305, " Emergency Exposure
Guidelines and Personnel Dosimetry," and EPP-306, "Use of Thyroid
Blocking Agents," and held interviews with radiation protection
personnel.
The appraisal team noted that Procedure EPP-305 instructed the staff
to issue TLDs in the EOF to document personnel exposure, and gave the
EOF radiation protection coordinator the responsibility to issue TLDs
under specific emergency conditions, rather than the routine issuance
of TLD upon the arrival of each person at the EOF.
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Based on the above findings, the following matter is considered an
improvement item:
Consider issuing dosimetry to personnel as they enter the EOF.
(445/8943-41; 446/8943-41)
5.4.3.2
Evacuation of the Owner-Controlled Area
The appraisal team reviewed the applicant's plans for personnel
evacuation of the OCA pursuant to the requirements of
10 CFR 50.47(b)(10) and criteria contained in NUREG-0654,
Section II.J.
In addition, the NRC team reviewed the EP,
Section 8.0, and Procedure EPP-314.
The appraisal team noted that the applicant had a method to promptly
initiate the evacuation of tne exclusion area upon initiation of an
evacuation order.
The method used staged evacuation in three phases:
building evacuatien within the PA, evacuation of non-essential
personnel to assembly areas located adjacent to the PA access control
points, and evacuation of all non-essential personnel from the OCA.
The applicant designates the OCA as the " exclusion area." The
appraisal team noted that the applicant had not tested its ability to
evacuate the OCA in a timely manner.
The appraisal team noted that Procedure EPP-314, " Evacuatien and
Accountability," provided for a " sweep" of the OCA within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
However, this procedure did not include the search of approximately
300 buildings in the OCA which are routinely occupied during working
. hours. The appraisal team noted that the method used by the
applicant to conduct the " sweep" of these buildings consisted of
security vehicles driving through the areas with a voice amplifier
announcing a warning to personnel to evacuate.
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The appraisal team noted that under certain accident scenarios and
due to the prevalent wind direction on the site, a large number of
buildings and personnel in the OCA could be exposed to the
radioactive plume.
Based on the above findings, the following item is idertified as
a significant appraisal finding:
Demonstrate that the evacuation of the OCA, including all
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buildings, can be accomplished in a thorough and timely manner.
(445/8943-42; 446/8943-42)
5.4.3.3
Personnel Accountability
The appraisal team reviewed personnel accountability capabilities
pursuant to the requirements of 10 CFR 50.47(b)(10) and the criteria
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in NUREG-DC54.Section II.J.
In addition, the appraisal team
reviewed Proceouca-EPP-314, inspected access control points,
equipment, and held discussions with security and emergency
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preparedness personnel.
The appraisal team noted that the applicant had not yet demonstrated
the capability to perform personnel accountability of all personnel
in the PA within 30 minutes.
Based on the above findings, the following 1 tem is identified as a
significant appraisal finding:
,
Demonstrate the capability of performing personnel
accountability of all personnel within the PA within 30 minutes.
(445/8943-43; 446/8943-43)
5.4.3.4
Personnel Monitoring and Decontamination
The appraisal team reviewed the personnel monitoring and
decontamination program pursuant to the requirements of
10 CFR 50.47(b)(11); 10 CFR 50, Appendix E, paragraph IV.A; and the
criteria in NUREG-0654, Sections II.J and K.
In addition, the
appraisal team reviewed Section 8.3 of the applicant's EP;
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Procedures EPP-313, " Medical Response," RPI-402, " Personnel
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Decontamination," EPP-307, " Radiological Monitoring of Site
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Evacuees," and RPI-108, " Skin Contamination Worksheet;" and conducted
interviews with the radiation protection staff responsible for this
program.
Based on the above review, this portion of the applicant's program
appears to be adequate.
5.4.3.5
Onsite First-Aid / Rescue
The appraisal team reviewed onsite the first-aid / rescue program with
respect to the requirements of 10 CFR 50.47(b)(12); 10 CFR 50,
Appendix E, paragraph IV.E; and the criteria in NUREG-0654,
Section II.L. The appraisal team reviewed Section 10.2 and 10.3 of
the EP and Procedures EPP-308, " Transporting Contaminated, Injured
Personnel;" EPP-205, " Activation and Operation of the Operations
Support Center;" and EPP-313, " Medical Response." In addition, the
appraisal team interviewed representatives of the applicant radiation
protection staff, fire and medical staff, and industrial safety
staff.
The appraisal team noted that the applicant was in the process of
replacing first-aid team members with emergency medical
technicians (EMTs). Discussion with applicant's. representatives
revealed that there would be a minimum of five EMTs avairable on any
shift. Procedure EPP-313 did not specify the use of EMTs as
first-aid team members.
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Based on the above findings, the following matter is considered
an improvement item:
Review and revise Procedure EPP-313 to specify the use of EMTs
j
as first-aid team members.
(445/8943-44; 446/8943-44)
5.4.4
Security During Emergencies
The appraisal team reviewed security during emergencies pursuant to
the requirements of 10 CFR 73, Appendix C.
In addition, the
a ,2raisal team reviewed the applicant's security contingency plan
rand procedures, inspected security facilities, and held interviews
with selected members of the security organization.
The appraisers confirmed that there were an adequate number nf
security officers to implement the security contingency plan and to
perform security tasks pertaining to emergency response.
The
appraisers also noted that the security officers were aware of their
responsibilities during emergencies.
Based on the above review, .his portion of the applicant's program
appears to be adequate.
5.4.5
Repair / Corrective Actions
The appraisal team reviewed the repair and corrective actions program
with respect to the requirements of 10 CFR 50.47(b)(13); 10 CFR 50,
Appendix E, paragraph IV.H; ant; the criteria in NUREG-0654,
Section II.K.
In addition, the appraisal team reviewed
Procedure EPP-116, " Emergency Repair and Damage Control," for the
logistics involved in repair operations, the identification of a team
leader, and the presence of instructions to assure adequate
radiological and technical briefings of emergency repair personnel.
Based on the above review, this portion of the applicant's program
appears to be adequate.
5.4.6
Recovery Phase
The appraisal team reviewed recovery phase planning 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.
In
addition, the appraisal team reviewed Procedure EPP-121, " Reentry,
Recovery and Closeout," for identification of key positions in the
recovery organization; the d?lineation of organizational authority
for entering the recovery phase; and provisions for evaluating plant
conditions as well as radiological conditions when deciding if the
recovery phase is appropriate.
,
Based on the above reviev, tH s portion of the applicant's program
appears to be adequate.
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5.5 Supplementary Procedures
5.5.1
inventory, Operational Checks, and Calib-ation of Emergency Equipment
)
The appraisal team reviewed inventory, operational checks, and
calibration procedures pursuant 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.
In addition, the appraisal
team reviewed inventory and maintenance procedures applicable to
emergency equipment.
The appraisal team noted that inventories, calibration, and
performance testing had been adequately performed on a timely basis;
test results had been properly documented; and clear lines of
responsibilities were in place.
Based on the above review, this portion of the applicant's program
appears to be adequate.
5.5.2
. Drills and Exercises
The appraisal tem, reviewed the applicant's drills and exercise
program with respect to the requirements of 10 CFR 50, Appendix E,
paragraph IV.F and the criteria contained in NUREG-0654, Planning
Standard N.
.The' appraisal. team reviewed selected drill and exercise files;
observer and participant comments; the management controls for
assigning responsibility for tracking and correcting findings
identified in the drills and exercises; and the provisions for
conducting communications, medical, radiological monitoring, and
health physics drills.
Based on the above review, this portion of the applicant's program
appears to be adequate.
5.5.3
Review, Revision, and Distribution
The appraisal team reviewed the applicant's methods for performing
~
.the review, revision, and distribution of the EP and EPPs pursuant 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
,
The appraisal team noted that the EPM was responsible for verifying
that all emergency response telephone numbers were correct on a
quarterly basis and revising the emergency response organization
roster as necessary. The team noted that the telephone directory had
the latest date of its review and revision on the cover. " The rate of
change of numbers showed that the document was undergoing revision
approximately monthly. Checks of several telephone numbers verified
that the sampled numbers were correct.
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In addition, the appraisal team noted that periodic revisions to the
emergency procedures were initiated based upon changes in the
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program; that program users could readily initiate recommendations
for changes; and controlled documents contained properly revised and
updated procedures.
Based on the above review, this portion of the applicant's program
appears to be adequate.
5.5.4
Audits of Emergency Preparedness
The appraisal team reviewed the applicant's audit program of
emergency preparedness against the requirements of 10 CFR SC.54(q)
and (t) and criteria in NUREG-0654,Section II.P.9.
In addition, the
appraisal team reviewed Revision 2 of Procedures NQA 3.07, " Quality
Assurance Audit Program," and CHP-2.03, " Emergency Preparedness
Program Review," and held discussions with audit program personnel.
The appraisal team nuted that the applicant had conducted two
independent audits of the emergency preparedness program prior to the
appraisal. One of the audits was performed by a contractor and the
other by their corporate quality assurance audit staff. The
appraisal team noted that both audits had been performed within the
last 12 months preceding the appraisal; the audits were
comprehensive; and identified a number- of significant areas that
needed improvement.
In addition, the appraisal team determined that
the applicant had a system in place to follow up on corrective
actions related to each finding identified by the auditors.
Based on the above review, this portion of the applicant's program
appears to be adequate.
6.0 COORDINATION WITH OFFSITE GROUPS
The applicant's contacts and coordination with the offsite support
agencies were reviewed pursuant to the requirements of 10 CFR 50.47(b)(3)
and criteria in NUREG-0654, Sections II.A, B, E, and L.
The appraisal team reviewed Sections 5.0, 5.1, and 5.2 of the applicant's
EP and Procedure TRA-105, " Emergency Preparedness Training." In addition,
the team interviewed the applicant's Public Information Coordinator and
selected representatives of offsite agencies. These contacts verified
that the applicant had contacted the responsible offsite agencies for the
purpose of providing training and conducting drills.
Further, these
contacts indicated that they had copies of the applicant's EP and
procedures, and understood their responsibilities during a CPSES
emergency. The training records reviewed indicated that a significant
amount of training had been conducted in the past 6 months on topics
~
appropriate to the response of each agency. The applicant stated that
original records of training are forwarded to the state of Texas for
their review and determination of adequacy. The appraisal team was unable
to determine which offsite agencies needed to be trained, the subjects to
train on, and the status of completion.
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The appraisal team also reviewed Letters of Agreement with the offsite
support agencies. Although 17 letters were on file, some were not current
and needed to be updated.
The appraisal team noted that a current emergency information brochure had
~
been provided to persons within the 10-mile EPZ and posters to inform
transients were posted-at public and business locations.
Based on the above findings, the following matters are considered
improvement items:
Update the. Letters of Agreement with the offsite support agencies.
(445/6943-45; 446/8943-45)
Prepare a matrix that would indicate what offsite agencies are to be
trained, the subject to be trained on, and the status of completion.
(445/8943-46; 446/8943-46)
7.0 DRILLS, EXERCISES, AND WALK-THROUGHS
7.1 Walk-Throughs Observations
The appraisal team performed walk-throughs to evaluate the performance of
selected teams of the emergency response organization with respect to
recognizing EAL entry conditions (emergency detection), correlating entry
conditions with the appropriate action level (classification), notifying
offsite agencies and emergency responders (notification), and formulating
PARS for consideration by offsite agencies.
The appraisal team conducted walk-throughs based on prepared scenarios of
postulated events. Personnel evaluated were given information such as
plant alarms, reports of hypothetical events, and changes in key
parameters to simulate events. When decisions required information that
would normally be available, the information was provided by the appraisal
team.
The appraisal team designed scenarios for the operating teams in order to
test the ECs ability to respond to " fast breaking" severe accidents
conditions requiring initial classification, escalation, and
recommendation of protective actions. Additionally, scenarios provided
events requiring dose assessment and notification from the CR as well as
the use of E0Ps for event mitigation. Scenarios began with normal
conditions and degraded to accident conditions requiring emergency
classification. The walk-throughs were conducted in the CR and operating
teams were allowed access to procedures and equipaent.
The format used for the walk-throughs was that of a " table-top" discussion
except that procedures, checklists, and notification forms were actually
used.
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Emergency Detection
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The. appraisal team communicated degrading plant conditions to the'CR-
operating team by orally identifying alarms and changes in pertinent
parameters; the operators.were expected to then use appropriate
procedures and.to simulate performing required actions.
Based on the above review, this portion of the applicant's program
appears to be-adequate.
7.1. 2 ~
Emergency Classification
l
The appraisai team postulated a fire in the "A" train diesel
generator as the event' requiring shift supervisors (SSs) to activate
the EP. Three of four crews classified the emergency correctly as an
alert; one crew over-classified the event as a site area emergency.
Although all classifications.were made in a timely manner, some minor
problems were observed during use of the " fire" EAL. Uncertainty
existed regarding whether the' diesel fire must meet the notification
of. unusual event criterion by burning for more than 10 minutes before
it could be considered a fire potentially affecting safety systems.
Additionally, one SS failed to discriminate between a fire affecting
a safety system and a fire causing the loss of a safety function.
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The appraisal team noted that all escalations performed by the
CR crew, the TSC group, and the EOF group were correct in accordance
with Procedure EPP-201 and were issued within 15 minutes of receiving
the initiating conditions.
Based on the above findings, the following matter is considered
an improvement item:
. Review the materials for EAL training and revise, as necessary,
!-
to ensure that CR decisionmaking personnel fully understand the
application of the " fire" EAL.
(445/8943-47; 446/8943-47)
7.1. 3 -
Notification
The Lppraisal team expected the SS to assign communicators and
authorize notification messages. The communicators were instructed
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to simulate required notifications.
procedures, special considerations, and personnel assignments for
notifying offsite agencies were discussed, and the notification forms
were filled out.
.
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Bused on the above review, this portion of the applicant's program
appears to be adequate.
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7.1.4
Dose Calculations
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The appraisal team noted that the STA performed dose calculations
based on data provided by the appraisal. team-in accordance with
Procedure EPP-303, " Micro-Computer Based, Emergency Dose Assessment."
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The appraisal team noted that during scenarios that resulted in a
large source term in containment but no. release, the STAS used
containment design leak rate for. performing dose projections, even
through plant conditions implied an eventual containment failure due
to overpressure.
(See-Section 5.3 of this report, " Implementing
Instructions" and 7.2.11, " Protective Action Decisionmaking.")
The appraisal' team conducted walk-throughs with three computer
operators.(two in the EOF and one in the TSC) who were responsible
for performing the dose calculations during an emergency. Based on
the walk-throughs, the training received acpeared to be adequate in
this area, however, the procedure was found not to include default
release rates.
Based on the above findings, the following matter is considered
an improvement item:
Revise Procedure EPP-303 to include instructions for using a
default release rate based on the most likely containment
failure mode. .(445/8943-48; 446/8943-48)
7.1;5
Protective Action Decisionmaking
The appraisal team used two types of scenarios: one resulting in a
general emergency with core damage and a radiological release.
Another scenario resulted in a general emergency with buildup of.a
-large source term in containment, no release in progress, and
degrading plant conditions that were precursors to a probable
radiological release.
The appraisal team noted that the PARS developed, based on dose
projections associatod with a potential release, were correct and
baseline PARS were used appropriately for initial recommendations;
however, PARS based on core and containment conditions were not
incorporated in the decisionmaking process.
(See 5.3, " Implementing
Instructions.")
Based on the above findings, the following item is identified as
a significant appraisal finding:
Modify training materials to incorporate PARS based on core and
containment conditions and retrain all personnel having
responsibilities to formulate PARS.
(445/8943-49; (46/8943-49)
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Offsite, Onsite, and In-Plant Radiological Monitoring
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The ap'praisal.teatii performed a walk-through for one offsite
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. radiological monitoring team. -Activities observed during the
walk-through-included assembly of. the team, equipment and' supplies,
plume monitoring techniques, air sampling:and analysis methods,
environmental sampling procedures, and recordkeeping. Performance of
C
the. team was adequate.
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Based on the above' review, this portion of the applicant's program
appears-to be' adequate.
8.0 EXIT MEETING
.At the conclu'sion of the appraisal, the appraisers reviewed the
findings identified in this report and the applicant agreed to take
corrective actions.
The applicant did not identify as proprietary
any of'the materials provided to or reviewed by the appraisers during the
appraisal.
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PERSONS CONTACTED
L. Barnes, Operations Coordinator
D.-Basinger, Balance of Plant Operator
T. Beaudin, Shift Supervisor
R. Beleckis, Senior Emergency Planner
,
M..Blevins, TSC Manager
T. Carden, Staff Emergency Planner
W. Carden, Radiation _ Protection Technician
a
D. Carlson, Auxiliary Operator
B. Clark, Shift Technical Advisor
T. Clouser, Balance of Plant Operator
V. Cornell, Licensing Engineer
C. Cotton, Assistant Shift Supervisor
D.' Curry, Balance of Plant Operator
J. Curtis, Radiation Protection Supervisor
S. Cyphen, Auxiliary Operator
T. Daskam, Shift Supervisor
P. Daugherty, Auxiliary Operator
D. Davis, Engineering Team Coordinator
K. Davis, Assistant Shift Supervisor
N. Eggenmayer, Assistant Shift Supervisor
R. Fishencord, Radiation Protection Supervisor - Rad Waste
E. Floyd, Radiation Protection Technician
R. Garces, Health Physics Technician
D. Goodwin, Shift Technical Advisor
B. Grace, Radiation Protection Coordinator
N. Harris, Senior Quality Assurance Technician
S. Harvty, Shift Superviser
W. Hise, Industrial Safety Supervisor
T. Jenkins, Engineering Support Coordinator
S. Johnson, Results Systems Engineer
J. Kelly, TSC Manager
M. Kertz, Reactor Operator
W. Knowles, Radiation Protection Technician
J. Laughlin, Emergency Coordinator Advisor
M. Lucas, Electrical Engineering Supervisor
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J. Luna, Radiation Protection Technician
C. Mansfield, Staff Health Physicist
R. McCamey, Staff Chemist
J. McInvale, Shift Technical Advisor
J. McMahon, Communications Coordinator
.
L. Meller, Auxiliary Operator
W. Melton, Emergency Coordinator Advisor
M. Mitchum, I & C Supervisor
D. Moore, Operations Coordinator
R. Muncy, Auxiliary Operator
L. Nace, EOF Manager
M. Niemeyer, Communications Coordinator
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W. Nix, Senior Emergency Planner
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G.'Nuchow, Reactor _ Operator
P. Olson, Auxiliary Operator
L. Pope, TSC Advisor
A. Redlow,~ Radiation Protection Supervisor
A. Reiff, Radiation Protection Training Coordinator
C. Rickgauer, Engineering Team Coordinator
T. Robinson, Emergency Preparedness Specialist
D. Ross, Reactor Operator
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T. Rucker, Balance of Plant Operator
J.LSalsman, Site Emergency Planning Coordinator
B. Scanlon,.TSC Advisor
E. Schmidt, Radiation Protection' Manager
E. Sirois, Senior Engineer
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R. Smith, Shift Technical Advisor
M. Smith, Shift Supervisor
B. Smith, Assitant Shift Supervisor
T. Spalding, Staff Chemist
M. Stakes, Staff Engineer,. Technical Support
W. Stengar,' Staff Emergency Planner
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P. Stevens, Engineering Support Coordinator
T. Stewart, Auxiliary Operator
F. Sutherland, Reactor Operator.
J. Taylor, Master Pcrts List Supervisor
N..Terrell, Operations Engineering Supervisor
D. Walden, Site Coordinator, Fire and Medical
J. Warkentin, Principal Engineer, Nuclear Engineering
J. Wise, Auxiliary Operator
NRC also held discussions with other station and curporate personnel in
the areas' of security, health physics, operations, training, and emergency
i
response,
In addition, NRC contacted representatives of offsite agencies.
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