IR 05000220/1993012
| ML20057E844 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 10/06/1993 |
| From: | Craig Gordon, Mccabe E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20057E842 | List: |
| References | |
| 50-220-93-12, 50-410-93-12, NUDOCS 9310130229 | |
| Download: ML20057E844 (20) | |
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION I
Docket / Report Nos. 50-220/93-12: 50-410/93-12 License Nos: DPR-53: DPR-69 Licensee:
Niagara Mohawk Power Corooration P.O. Box 63. Lycoming. New York 13093 Facility:
Nine Mile Point Power Station. Scriba. New York Inspection Dates:
lune 15-18 and July 12-14. 1993
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Inspectors:
dir Craig (.pordon, Senior Emergency.
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Preparedness Specialist, DRSS
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David J. Chawaga, ERC, Region I
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Richard A. Plasse, Resident Inspector, NMP Neil S. Perry, Senior Resident, Limerick l
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John Will, Sonalysts, Inc. (NRC consultant)
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Approved By:
O2e d. k k )v
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l Ebe C. McCabe, Chief, Emergency date
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Preparedness Section, FRSSB, DRSS
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SCOPE
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Announced safety inspections of the emergency preparedness (EP) program (June 15-18) and of the annual, full-participation EP exercise (July 13). The inspection consisted of inspector observations, personnel interviews, and examination of selected procedures and records.
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Inspection areas included Site Emergency Plan (SEP) implementation, EP program changes; l
emergency facilities, equipment, instrumentation, and supplies; organization and management control; emergency response organization (ERO) training; and independent program audits.
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RESULTS The EP program overall was well implemented and administered. The SEP and Emergency Plan Implementing Procedures (EPIPs) were well maintained. Emergency response facilities and equipment were operationally ready. Management involvement in EP was evident.
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Some weaknesses were noted in the administration of the emergency response training
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program for other than shift operations personnel. Emergency Response Organization (ERO)
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positions and EP training were being revised to eliminate redundancies and emphasize performance-based training. Performance by shift operations crews during walk-through
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drills was very good. Independent audits were thorough. SEP implementation during the j
exercise was appropriate, but EPIP familiarity and NRC notification upon emergency
declaration was an exercise weakness. Several areas for potential improvement were noted.
No safety concerns or violations of regulatory requirements were identified.
9310130229 931006 gDR ADOCK 05000220
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TABLE OF CONTENTS
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1.0 Persons Contacted
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i 2.0 Operational Status of the Emergency Preparedness Program.............. 4 2.1 Changes to the Emergency Preparedness Program
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2.2 Emergency Facilities, Equipment, Instrumentation and Supplies.......
j 2.3 Organization and Management Control....................... 5
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2.4 Knowledge and Performance of Duties (Training)................
l 2.4.1_ EP Training Program
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2.4.2 Table-top walk-through exercises..................... 7
2.4.3 Summary of walk-through scenarios and observations.........
i 3.0 Independent and Internal Reviews and Audits......................
4.0 Licensee Action on Previous Inspection Findings
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5.0 Emergency Exercise.....................................
5.1 Scenario Planning..................................
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5.2 Exercise Scenario..................................
i 5.3 Activities Observed.................................
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5.4 Exercise Finding Classifications
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5.5 Exercise Observations
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5.5.1 Simulator Control Room (SCR).....................
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5.5.2 Technical Support Center (TSC).....................
l 5.5.3 Operational Support Center (OSC)...................18 j
5.5.4 Emergency Operations Facility (EOF).................
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5.5.5 Licensee Critique..............................
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6.0 Exit Meeting.......................................... 2 0 l
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DETAIIE
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1.0 Persons Contacted The following individuals were contacted during the inspection:
R. Abbott, General Manager, Site Support
S. Austin, EP Training Instructor N. Avrakotos, Emergency Preparedness Coordinator, NYPA
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D. Barcomb, Radiation Protection Manager
J. Benson, Drill Coordinator
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J. Blasik, Chemistry Manager D. Bosnic, Operations Superintendent, Unit 2
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G. Gresock, Planning / Scheduling Coordinator K. Dahlberg, Plant Manager, Unit 1
P. Harnett, EP Program Director, Plans
J. Jones, EP Program Director, Radiological
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J. Josh, Supervisor
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E. Kaish, Manager, EP Communications
J. Kaminsky, Director, EP Drills and Exercises
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T. Kulczycky, Supervisor, Safety Analysis
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P. Mangano, Coordinator
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C. McClay, Maintenance Department M. McCormick, Plant Manager, Unit 2
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P. McSparran, Operations Training Instructor
J. Mueller, Manager, Operations
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R. Pasternak, Manager, Technical Services J. Pavel, Site Licensing
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V. Perry, Nuclear Trainer R. Sanaker, General Supenisor, Operations Training, Unit 1
R. Slade, General Supervisor, Operations Training, Unit 2
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J. Spadafore, Safety Evaluation Group
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N. Spagnoletti, Executive Assistant
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P. Swafford, Radiation Protection Manager
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T. Verno, Supervisor, Security
C. Ware, Director, Emergency Preparedness
- Attended EP program review exit meeting on June 18,1993.
+ Attended EP exercise exit meeting on July 14, 1993.
- Attended June 18 and July 15,1993 exit meetings.
The inspector also contacted other licensee personnel.
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i 2.0 Operational Status of the Emergency Preparedness Program 2.1 Changes to the Emergency Preparedness Program Changes in EP since the last inspection were reviewed, and associated details were discusse<'
with the Director, EP and other licensee program staff.
The most significant changes came just prior to the inspection and involved EP program staff
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replacements. A new EP Director was appointed to manage and administer the program.
i Through interviews, the inspectors noted that this individual, who was reassigned from another site department, had management and brief experience in EP as a training instructor.
At the time of the inspection basic program knowledge was shown, and knowledge of many of the details of implementing an efficient EP program was being developed. That included interrelationships with on-site and off-site support groups, familiarity with scenario development, qualifications of ERO personnel, and oversight of EP staff performance. In addition, one full-time EP staff position was lost and at least one other position was scheduled to be eliminated in accordance with the company's staff reduction plan.
Since the last inspection only minor changes in EPIP content were noted; these were reviewed and discussed with the EP staff. Updates to the Site Emergency Plan (SEP) and EPIPs were issued through controlled distribution. Sampling checks of EPIPs in emergency response facilities showed that copies were up to date.
The EP staff also provided information about planned program changes in training and qualifications for ERO personnel, and plans for possible relocation of the Emergency Operations Facility (see Section 4.0 for additional details).
Based upon the above review, this area was appropriately implemented.
2.2 Emergency Facilities, Equipment, Instrumentation and Supplies Inspection of the Technical Support Center (TSC), Operations Support Center (OSC), and
Emergency Operations Facility (EOF) indicated that facilities were in a good state of operational readiness. A limited review of control room emergency notification and emergency response equipment was performed. The readiness of Emergency Response Facilities (ERFs) was observed to be in agreement with information specified in the Emergency Plan. The inspector examined selected communications equipment, computer terminnis, and downwind survey kits. All of the emergency response equipment inspected was found to be functional and calibrated as necessary. No procedure discrepancies were observed. Break-away locks were intact and supply inventories were maintained in accordance with program requirements. In addition, individual ERP capability was satisfactorily demonstrated during the exercise. Overall, inspection results indicated that emergency response facilities and equipment were well maintained.
Based upon the above review, this area was effectively implemented.
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2.3 Organization and Management Control i
The inspector reviewed the duties and qualifications of individuals assigned to the Emergency
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Response Organization (ERO) and held independent interviews with senior licensee
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management.
I Overall responsibility for maintenance of the EP program rested with the Director, EP.
Three full-time EP Program Directors assumed leadership roles to carry out most EP functions while the Director, EP completed the transition into the position. Primary areas of responsibility were upkeep of Emergency Plans and EPIPs, drill / exercise coordination, radiological evaivations, liaison with State and local officials, and ERF maintenance.
Additional EP and training staffs were assigned to implement administrative and technical functions. Collectively, personnel involved in EP provided good support to on-site and off-site EP functions.
At least four individuals were qualified in key ERO positions. Site and corporate managers maintained qualification in their assigned positions. However, from review of other ERO positions identified in the SEP, the inspectors found several redundancies in assigned functional areas and ERO responsibilities. As a result, a one-for-one comparison could not be made of ERO positions listed in the SEP with those identified in the NTP-TQS-202, Revision 1, EP Training Program Matrix or with the positions on the ERO qualification list.
Examples were the assignments of Control Room (CR) Site Emergency Plan Coordinator, CR Advisor for Chemistry (currently the CR Dose Assessment Advisor), Technical Support Center (TSC) Staff Coordinator, and TSC Emergency Notification System (ENS) Liaison.
Through interviews with the Unit 1 Plant Manager; Vice President, Nuclear Generation; and i
General Manager, Site Support; management involvement in the program and support for EP was clear: each individual provided good awareness of on-site and off-site EP program details.
The Vice President, Nuclear Generation was recently qualified as a Corporate Emergency Director. Managers stated that they interface with the Director, EP to obtain updates on the status of EP program activities. From meeting minutes and attendance records, the inspectors determined that EP staff routinely met with State and county officials to promote and maintain a cooperative relationship. One concern was raised with regard to the annual emergency action level (EAL) review with State and local governmental authorities required by 10 CFR 50, Appendix E, IV, B. For 1992, licensee staffindicated that a meeting was
held with New York State and Oswego County officials, but could not provide specific
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details or documentation about the meeting. Following the inspection, a licensee memo to
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file which summarized a December 16,1992 EAL review session was prepared and provided to the inspectors. Pending further review by the inspector, including ongoing licensee action to assure compliance with this requirement, this matter is classified as unresolved. (UNR 50-220/93-12-01, 50-410/93-12-01).
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r Based upon the above review, licensee performance in organization and management control
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aspects of EP was assessed as good.
2.4 Knowledge and Performance of Duties (Training)
2.4.1 EP Training Program Training records for all emergency preparedness training were being maintained as specified by administrative procedures. The EP training database, the Training Records and Information Network (TRAIN), was validated by comparing drill participation with the data in TRAIN. All persons assigned to ERO positions for drills were properly qualified for those positions at the time of participation and all persons listed on the qualification list were qualified. However, as discussed below, the TRAIN database did not track the positions in which individuals participated and contained some erroneous data.
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The emergency response training program was well-established, but qualifications were not performance-oriented. Except for operations personnel, there was no requirement to
demonstrate knowledge of or to perform in a designated role before being assigned to the
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Emergency Response Organization. Of the persons listed as qualified for ERO positions, only a limited number had the training experience of actually performing in those positions.
When they did participate in an exercise, drill, table top, etc., the TRAIN database did not track the position in which they participated. In the major drills and exercises held over the last two years, examples of number of participants versus the number qualified were:
3 out of 10 OSC Coordinators 2 out of 12 TSC Maintenance Coordinators 4 out of 13 TSC Technical Data Coordinators Further, comparison of a list of participants provided by the licensee with the TRAIN print-
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out showed that the dates of drill participation in the TRAIN print-out did not match the dates of participation provided separately by the licensee.
The general (EP Essentials) and senior position initial lesson plans were reviewed for technical content. The lesson plans were considered adequate in technical detail. Each lesson plan had specific objectives, some of which were satisfied by table top discussions with subject matter experts. The lesson plans were developed to provide a competent level of instruction on the objectives. A test question bank supporting the objectives was developed for each lesson plan, which was to be reviewed and updated annually, However, some lesson plans and test answer keys contained out-of-date information which had to be corrected by the instructors on a case-by-case basis. These were discussed with the EP training instructor.
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The procedure for EP instructor certification and recertification was reviewed. This review showed that the licensee was properly documenting instructor evaluations by class and supervisors.
The licensee stated they have recently initiated a continuing type EP requalification program but, with the exception of the requirement for operations personnel, the described program was vague in content and requirements. Control Room operations personnel were receiving continuing practical EP training through their Licensed Operator Requalification Training Program as outlined in NTP-TQS-102. However, for other ERO personnel, Paragraph 5.3 of the Emergency Preparedness Training Program (NTP-TQS-202) stated that requirements for requalification or continuing qualification were to be issued on an annual basis. These requirements had not been issued to date.
Because of the large number of designated ERO positions for which practical EP training is appropriate, it was difficult to schedule meaningful training. For example, in order to hold a facility training session for the TSC, considering the current list of ERO positions, over 20 designated positions should be filled (not including assessment and sample team members).
The EP Training instructor indicated that arranging schedules to accommodate that number of people from different groups was very difficult.
There were a number of lesson plans and tests that contained out-of-date material. Although, the procedure for Training Plan Development, NTP-TQS-503 (Revision 2), Paragraph 3.5.1.g stated that lesson plans, tests, handouts, etc. should be reviewed annually, the lesson plans for Site Emergency Director Qualification and Site Emergency Plan and Procedures and the SED qualification test, which were written in 1991, contained out-of-date material.
2.4.2 Table-top walk-through exercises The inspector performed walk-through scenarios with four shift groups (two from each unit),
each consisting of the site shift supervisor (Emergency Director), assistant site shift supervisor, shift technical advisor, communications aide, and chemical technician (chem tech). Each crew demonstrated their ability to execute EP-type actions under rapidly deteriorating plant conditions. With one exception, each crew classified the condition correctly, made timely notifications, and, when appropriate, issued the proper protective action recommendations. The one exception was a crew that was slow to classify a particular event. In that another crew with the same postulated conditions classified the event expeditiously as anticipated, the observers concluded the problem was with the particular crew's internal communications and not with the EAL or training. The chem techs on all four crews demonstrated the ability to do dose assessment and make the proper PAR recommendations to the Emergency Directors. Licensee operations training instructors reviewed the NRC-prepared scenarios, observed conduct of walk-throughs, and participated in discussion of critique findings. This review of EP training showed all individuals qualified for their designated walk-through assignments.
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2.4.3 Summary of walk-through scenarios and obsen'ations Scenario #1 (Unit 2 - Shift A)
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Initial Conditions:
100% power; end of cycle; elevated RCS activity; elevated off-gas; no equipment out of service; no surveillance in progress. Weather clear / partly cloudy, with reports of high winds expected to pass through the area within the next few hours.
Event 1:
Steam leak in steam tunnel High temperature alarm, temperature increasing MSIV closure Reactor scram All control rods in Event 2:
Steam leak inside drywell Increasing drywell pressure (alarm at 0.75 psig)
Reactor levels being maintained above top of active fuel at 1.68 psig Containment isolation
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Alert conditions Fuel damage Drywell continuous air monitor (CAM) alarm Elevated readings on drywell high range rad monitors Event 3:
Loss of off-site power, diesels start Unusual Event (UE) conditions Event 4:
Containment penetration leak; Containment penetration low pressure alarm Reactor Building 289' elevation area rad monitor alarm Standby Gas Treatment System decreasing drywell pressure Site Area Emergency (SAE) conditions Event 5:
Increasing stack monitor readings Dose assessment indicates General Emergency conditions Observations i
l Crew displayed excellent command and control with superior teamwork. They declared the
. Alert within 1 minute of getting the containment isolation alarm and had completed their initial notification to the State and county within 11 minutes, and to the NRC within 22 minutes. The SAE was declared within 4 minutes of getting indications of a breach in primary containment and notifications were completed within 10 minutes. A General Emergency (GE) was declared as soon as the dose projection indicated the necessity to do so, and PARS were provided within 5 minutes of the declaration.
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Areas for potential improvement were attention to the radiation hazard to personnel passing through the plume while reporting to the site. Although this crew made good use of procedures, some omissions in use of forms was noted. For example, the EPP-26, Figure 5, PAR Recommendation Form, was not signed by the SED, and the EPP-20, Figure 1, Communications Aide Checklist, was used incorrectly.
Scenario #2 (Unit 1 - Shift E)
Initial Conditions:
100% power, end of cycle Elevated RCS activity, elevated off-gas No equipment out of service, no surveillance in progress Weather clear / partly cloudy, with reports of high winds expected to pass through the area in next few hours i
Event 1:
Steam leak in steam tunnel; main steam break area high temperature MSIV closure Reactor scram, all rods go in Event 2:
Steam leak inside drywell Increasing drywell pressure (alarm at 2 psig)
Reactor levels being maintained above top of active fuel at 3.5 psig
Containment isolation Alert conditions i
Fuel damage Drywell continuous air monitor alarm Elevated readings on drywell high range rad monitors Event 3:
Loss of off-site power, diesels start Unusual Event conditions l
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Event 4:
Containment penetration leak; Containment penetration low pressure alarm
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Reactor Building 237' elevation area rad monitor alarm
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Reactor Building Emergency Vent System auto start Decreasing drywell pressure Site Area Emergency conditions Event 5:
Increasing stack monitor readings
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Dose assessment indicates General Emergency conditions Observations Crew performance was noteworthy in the area of communications. The communications aide was very precise in executing notifications and in coordination with the site shift supervisor (Emergency Director). An Alert was declared immediately on receipt of the high drywell
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pressure alarm. Notifications were made within the allotted 15 minutes. The Community Alert Network (CAN) had been initiated within 17 minutes of the declaration. The Site Area Emergency was declared immediately on receipt of indication of a loss of containment.
Notifications were made within 9 minutes and the NRC was informed within 15 minutes. A l
General Emergency was considered when the release increased considerably, but the crew waited until they got the dose projection exceeding the GE EAL to make the declaration.
The notification went out with the more conservative default PAR to shelter 5 miles downwind although the dose projection did not call for it.
Minor discrepancies were noted. The Emergency Director made poor use of the Shift Supervisor's checklist - EPP 18, Figure 1. No times were shown on the EPP-26 worksheets and the Figure 5 worksheet was not filled out.
Scenario #3 (Unit 2 - Shift D)
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Initial Conditions:
100% power, end of cycle
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Elevated RCS activity; increasing off-gas No equipment out of service, but a new condensate demineralizer bed was placed in service Operator and Radiation Protection Technician were going to perform a mark-up in the clean-up area Weather reports indicate high winds are expected to pass through the area Event 1:
Reactor coolant contaminant results in fuel failure Off-gas activity high alarm - Unusual Event (UE)
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Event 2:
Loss of off-site power UE conditions Event 3:
Leak in reactor water clean-up system, failure to isolate Clean-up area high temperature alarm, clean-up area radiation monitor alarm Site Area Emergency conditions Event 4:
Injury to RP Tech, contamination detected Report confirms leak in clean-up area Event 5:
Off-gas activity high-high alarm Main steam radiation monitors cause MSIV closure General Emergency conditions
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11 Observations Performance by this crew resulted in a delay in declaring the Site Area Emergency.
Uncertainty was observed during crew evaluation of the time at which the Emergency Director (ED) recognized that he had an unisolable leak outside containment. In this scenario, the Assistant Shift Supervisor understood the problem, but this information was not communicated to the ED expeditiously. The inspectors discussed with operations training instructors crew interpretation of EALs and communication of SEP information among crew
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This crew dedared an Unusual Event within three minutes of receiving an off-gas high activity alarm. Notifications were made within ten minutes of the declaration. At Time 17 (minutes), the operators received a secondary containment control alarm with the indication that clean-up failed to isolate. At Time 21, an operator was told to get a Radiation protection (RP) Technician and to check the radiation levels in the clean-up area. At Time 24, the RP Tech reported 2 R/hr at the entrance to the clean-up area. Temperature and radiation levels in the area were known to be increasing. At Time 27, the ED discussed the need to evacuate the Reactor Building. Main steam radiatic monitor readings were increasing. At Time 29, operators manually tripped the ru.or. At Time 36, the operators closed the Main Steam Isolation valves (MSIVs) (premature for what was intended in the scenario) and declared an Alert as of Time 37 (notifications completed within 9 minutes). At
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Time 39, all Area Radiation Monitors in the clean-up area were in high alarm. At Time 45, the operators correctly declared a SAE based on an unisolable primary leak outside of containment (notification within ten minutes).
This scenario was to have provided the clues that the primary leakage through the clean-up system was greater than 50 GPM (i.e., a primary leak greater than the Alert level), which in combination with other conditions would have put them in a GE. These conditions were not immediately obvious to the crew. Scenario modification was made to allow an abnormally high release rate (provided to exercise the chemistry technician in dose projection) to drive
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the problem. Upon receiving the chemistry technician's dose projection and PARS, the ED declared the GE immediately and was transmitting the notifications within seven minutes.
The chemistry technician was the only one to fill out all worksheets properly.
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Initial Conditions:
100% power, end of cycle Elevated RCS activity New condensate demineralizer bed placed m service Operator and RP Tech are going to perform a mark-up in the clean-up area Weather reports indicate high winds are expected to pass through the area
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Event 1:
Reactor coolant contaminant results in fuel failure
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Off-gas activity high alarm - Unusual Event l
Event 2:
Loss of annunciators - Alert Event 3:
Leak in reactor water clean-up system l
Failure to isolate l
Clean-up area high temperature alarm, clean-up area radiation
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monitor alarm
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Event 4:
Injury to RP Tech, contamination detected l
Report confirms leak in clean-up area Event 5:
Off-gas activity high-high alarm l
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Main steam radiation monitors cause MSIV closure l
General Emergency conditions l
Observations The Unusual Event was declared immediately on receipt of the off-gas high radiation alarm.
Initial notifications were completed within 11 minutes and the NRC was notified within 15 l
minutes. On recognition of the loss of the annunciators, the operators immediately declared an Alert. The Shift Supervisor (Emergency Director) astutely recognized that, were they to I
scram the reactor at that point, besides that not being desirable, doing so would have put them in a SAE.
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At Time 26, the operators had indication of a !eak in the clean-up area and of the failure to isolate. The Assistant Site Shift Supervisor (ASSS) sent operators to manually isolate the
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declared a SAE.
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This crew also had not recognized that the leak was greater than 50 gpm. The licensee l
controller introduced a drywell leak which, when pressure reached the 3.5 psig alarm trip-point, became a General Emergency that was immediately recognized and declared.
i The Chem Tech was given a high release rate in order to observe his ability to do dose projection and make the appropriate PAR. Both of these were done accurately.
Protective actions developed and recommended to the State were proper and conservative in all scenarios.
Overall, EP training was assessed as very good.
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3.0 Independent and Internal Reviews and Audits l
Quality assurance reviews of the entire EP program were conducted independently each year by the Quality Assurance Department. The 1992 audit was performed by a Lead Auditor and reviewed by the Manager, QA. The inspector reviewed the November 4,1992 audit of the EP Program (performed July 10-October 16,1992) and discussed audit conduct with
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audit team members.
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The inspector determined that the 1992 audit was sufficient to satisfy the requirements of 10 CFR 50.54(t), identified areas requiring corrective action, and covered a review of off-site interfaces with State and local authorities. For audit findings, a Deviation Event Report (DER) system was in place and was used to track items to completion. Review of the report indicated that activities of the EP program were conducted effectively since the previous
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audit, and no DERs were issued. Only minor recommendations for EP improvement were made. Audit reports provided good detail of EP program evaluations in training, facilities, equipment, coordination with off-site agencies and the SEP. The audit was supplemented by observation of fire and practice drills during the audit period. The EP staff was attentive to resolving items identified by the audit report. Audits and surveillance reports were appropriately distributed to plant and corporate management.
This program area was assessed as being well implemented.
4.0 Licensee Action on Previous Inspection Findings Based upon NRC observations, discussions with licensee representatives, and examination of procedures and records, the status of open items is as follows:
(Update) 50-220/88-25-08; 50-410/88-25-08: A protection factor of five was not attainable at the double exit doors to the EOF.
The inspector reviewed the licensee calculations and determined that this item could not be closed during this inspection period. Specifically, the inspector concluded that the licensee's analysis did not address the volume of air, within the training center and outside of the EOF, that could directly contribute to radiation levels within the dose assessment and decision making areas in the EOF. Licensee personnel later provided an analysis addressing the volume of air of concern. The results of the licensee's later calculation indicated that the protection factor of five was attainable. However, the calculation was not sufficiently detailed to allow the inspector to validate the licensee's calculation. The licensee has formalized plans to move the EOF in 1994. The Nine Mile Point EOF will be combined with the FitzPatrick EOF, which is located outside of the 10 mile EPZ. This item will remain open pending further review and discussions with licensee personnel and/or relocation of the EOF.
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(Closed) 50-220/91-19-02; 50-410/91-19-02: Oswego County " Green Cards" not carried by all members of the ERO while responding to the August 1991 Site Area Emergency.
During a review oflicensee audit findings, it was noted that Oswego County Emergency Access Control Cards, commonly known as " Green Cards," were not carried by all members of the licensee's Emergency Response Organization (ERO). These cards were issued as part
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of a program to control access to the Emergency Planning Zone (EPZ) surrounding the Nine Mile Point facility during a plant emergency. These cards were designed to allow ERO personnel expeditious passage through off-site roadblocks.
The inspectors reviewed a draft revision of Emergency Plan Implementing Procedure, EPIP-EPP-14, " Emergency Access Control," which was dated May 1993. This procedure revision allowed the Niagam Mohawk Identification (ID) Card to be used for access control purposes.
The inspector also reviewed recently issued Oswego County Sheriff's Department and New York State Police memoranda indicating that Niagara Mohawk Power Company ID will be acceptable for access through road blocks during exercises, drills, and real emergencies. In addition, Niagara Mohawk employees have been reminded of the importance of maintaining possession of " Green Cards" via training, management memos and posted signs. For example, employees were asked to present their " Green Card" prior to admission to the annual General Employee Training course.
The inspectors' findings and licensee audits indicated a positive trend in performance and lessened reliance on " Green Cards" since this issue was identified in the original licensee audit. Licensee personnel indicated that they would continue to monitor program performance related to emergency access control. This item is closed.
(Closed) 50-220/91-19-03; 50-410/91-19-03: Accountability of personnel within protected area not achieved within 30 minutes of the August 1991 Site Area Emergency.
Licensee performance and corrective action were observed during the July 13, 1993, emergency exercise. The licensee acceptably demonstrated initial and continuous accountability of personnel within the protected area. This item is closed.
(Closed) 50-220/92-27-01; 50-410/92-31-01: Protective Action Recommendations (PARS) to off-site authorities following the General Emergency were not timely.
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emergency exercise. After the General Emergency was declared, the licensee immediately issued correct PARS, based on an evaluation of plant conditions, and the release into the
turbine building and off-site dose projections. This item is close.
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5.0 Emergency Exercise A full-participation emergency exercise was conducted at the Nine Mile Point Nuclear Power Station on July 13,1993 from 700 to 1430.
i 5.1 Scenario Planning Exercise objectives were submitted to NRC Region I on March 18,1993. The scenario was submitted to the NRC on April 20,1993. Region I reviewers discussed scenario improvements with the licensee's EP staff on June 16,1993. The revised scenario adequately tested the major portions of the Site Emergency Plan and EPIPs, demonstrated
areas previously identified for further review, and also provided for demonstration of areas
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previously identified by the NRC as in need of corrective action.
On July 12,1993, NRC observers attended a licensee briefing on the revised scenario. The
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licensee stated that certain emergency response activities would be simulated and that controllers would intercede in exercise activities to prevent disrupting plant activities.
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5.2 Exercise Scenario The scenario included the following simulated events:
Initial conditions with Unit 2 at 100% power, Unit 1 in mid-cycle outage; Residual l
e Heat Removal (RHR) Pump in 72-hour limiting condition for operation (LCO);
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increasing trends in activity levels of Off-Gas and Reactor Coolant monitors.
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Presence of unknown individual (intruder) within protected area without proper I
e identification.
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e Control rod drive trip due to motor electrical fault.
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Intruder seen again in Reactor Building on Elevation 261'.
Mechanical trip of Reactor Core Isolation Cooling (RCIC) turbine.
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Explosion in "A" RHR Pump motor with small fire in electrical cables and motor insulation.
e Small leak in 7D Main Steam Isolation Valve (MSIV) with resultant high temperature in Main Steam Tunnel.
e MSIV closure and automatic reactor scram.
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i Hydraulic lock in Scram Discharge Volume, preventing scram rod motion.
e Standby Liquid Control pump failure to inject boron.
e Main steam line rupture, loss of primary containment, and failed fuel.
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Elevated radioactive release in Turbine Building.
Event termination followed by recovery discussion.
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5.3 Activities Observed
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The NRC inspection team observed the activation and augmentation of the Emergency Response Facilities and actions of ERO staff. The following activities were observed:
1.
Selection and use of control room procedures.
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Detection, classification, and assessment of events.
3.
~ Direction and coordination of emergency response.
4.
Notification of licensee personnel and off-site agencies.
5.
Communications /information flow, and record keeping.
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Assessment and projection of off-site radiological doses.
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Consideration of protective action recommendations (PARS).
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Provisions for in-plant radiation protection.
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Provisions for communicating information to the public.
10.
Accident analysis and mitigation.
11.
Personnel accountability.
12.
The licensee's post-exercise critique.
5.4 Exercise Fmding Classifications Inspection findings were classified, where appropriate, as follows:
Exercise Strength: a strong positive indicator of the licensee's ability to cope with abnormal plant conditions and implement the emergency plan.
Exercise Weakness: less than effective emergency plan implementation which did not, alone, constitute overall response inadequacy.
i Area for Potential Imorovement: an aspect which did not significantly detract from the licensee's response, but which merits licensee evaluation for corrective action.
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5.5 Exercise Observations Emergency Response Organization (ERO) and Emergency Response Facility (ERF) activation and use were generally consistent with the Emergency Plan and Emergency Plan Implementing Procedures (EPIPs). There was good teamwork in the recognition,
anticipation, and mitigation of adverse plant conditions in each ERF. Command and control displayed by all emergency facility managers were effective, particularly in the Technical Support Center. Good coordination was observed with the NRC's site incident response teams within ERFs for providing team members with status of plant conditions and updates of licensee response activities.
5.5.1 Simulator Control Room (SCR)
The Control Room Operations staff demonstrated thorough knowledge, anticipated problems, and promptly recommended solutions to degraded plant conditions. Initiating conditions relative to the security threat were used correctly in classification of the Unusual Event and Alert.
No exercise strengths were identified. The following exercise weakness was identified.
5.5.1.1 Timely Notification of the NRC (UNR 50-220/93-12-02,50-410/93-12-02)
After declaration of the Unusual Event, notifications to the NRC Headquarters e
Operations Officer (HOO) were not complete or timely. The event notification worksheet did not have the proper information needed by the HOO. Rad Waste Operators (designated communicators) were not familiar with when to make Emergency Notification System (ENS) calls or, once calls were made, what information to provide to the HOO. Shift supervisor review of the worksheet and required notifications of other off-site agencies were not observed by the NRC.
The following Areas for Potential Improvement were noted:
5.5.1.2 Update of Security Information (IFI 50-220/93-12-03,50-410/93-12-03)
The licensee used security classifications in their overall emergency action level e
(EAL) scheme. After the initial events were classified as Security Alert 1 (Unusual Event) and Security Event 2 (Alert), updated security information on the intruder and security threat were not provided to the Site Emergency Director (SED) for EAL evaluation.
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5.5.1.3 Incorrect Press Release (IFI 50-220/93-12-04,50-410/93-12-04)
In conjunction with the delayed NRC notification following declaration of the Unusual
Event, a press release stated all federal agencies had been notified. At the time, NRC notification had not been made.
5.5.2 Technical Support Center (TSC)
Overall accident assessment activities in the TSC were well performed. TSC personnel provided good technical support to the Emergency Operations Facility (EOF). A qualified
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Site Emergency Director (SED) was productive in assisting the primary SED to effectively implement his duties. Direction given to the Operations Support Center allowed prompt dispatch of damage control teams. The SED provided separate status briefings to keep the TSC, EOF, and NRC base team and executive team staffs informed.
The following exercise strength was identified.
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Use of an additional SED to assist the designated SED. This individual demonstrated
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thorough knowledge of the SED role and provided invaluable assistance to the SED.
No weaknesses were identified. The following areas for potential improvement were identified.
5.5.2.1 TF dng of Page Announcements (IFI 50-220/93-12-05,50-410/93-12-05)
e On several occasions TSC announcements were made simultaneously with plant page announcements.
5.5.2.2 Containination Control (IFI 50-220/93-12-06, 50-410/93-12-06)
e Step-off pads for contamination control were not established as prescribed by EPP-13.
5.5.3 Operational Support Center (OSC)
Performance by OSC personnel was generally very good. Command of in-plant repair teams was effective; communications with Emergency Response Facilities (ERFs) and other emergency responders was maintained throughout the exercise while teams performed repair actions. The OSC Coordinator demonstrated a proactive approach and was immediately aware of the status of in-plant teams and repair activities as indications changed. A cautious approach was noted in deployment of field teams due to the security threat.
No exercise strengths or weaknesses were identified. The following area for potential improvement was identifie.
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5.5.3.1 Search Team Safety Consideration (IFI 50-220/93-12-07,50-410/93-12-07)
e Good initiative was shown in consideration of calling to the scene an explosives expert to assist in the reactor building security search. During the search, however, two teams were assigned to enter the building together, leaving one team without the assistance of an explosives expert to aid in identifying an explosive device.
5.5.4 Emergency Operations Facility (EOF)
Command and control demonstrated by the Corporate Emergencf Director (CED) and other key EOF staff were good. That included overall management of engineering, dose assessment, and other staff resources. Direction and coordination of field teams, protective action decision-making, and coordination with the NRC response team were generally proficient.
No exercise strengths or weaknesses were identified. The following areas for potential
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improvement were identified:
5.5.4.1 Effective Information Flow to Staff and NRC (IFI 50-220/93-12-08,50-410/93-12-08)
e Effective information flow between the CED and EOF managers was not apparent.
Briefings were not held by the CED among EOF and NRC staff to communicate the most up-to-date information available.
5.5.4.2 Verification of Information (IFI 50-220/93-12-09,50-410/93-12-09)
e Documentation, logs, and forms were either incomp!ete or not carefully reviewed prior to submission to the CED. Examples included: RHR fire and RCIC pump trip information not immediately provided by EOF emergency staff. Also, the radioactive release pathway was not satisfactorily explained by technical support staff, including off-gas treatment system isolation, resulting in the CED providing inaccurate information about the release.
5.5.4.3 Verification of Notification Form Information (IFI 50-220/93-12-10,50-410/93-12-10)
e Each notification message sent out from the EOF needed et crection after CED review. Emergency responders and their titles, dates, times, and transmitter's name were missing from most forms. After declaration of the General Emergency, the reason for protective action recommendations was not entered. Because of
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uncertainty in characterizing the release pathway, one message indicated a release was in progress, while the follow-up message indicated no release. Both messages were issued without CED approval.
5.5.5 Licensee Critique On July 14,1993, the Director, Drills and Exercises and lead controllers summarized licensee observations. The critique was thorough in scope and identified areas in need of corrective action. No licensee critique inadequacies were identified by the NRC.
6.0 Exit Meeting The inspector met with the licensee personnel denoted in Section 1 at the conclusion of the program inspection on June 18,1993 to discuss the scope and findings as detailed in this I
report.
The licensee was informed that no violations were identified. Several areas for potential improvement were discussed. The licensee acknowledged these findings and agreed to evaluate them and institute corrective actions as appropriate.
Following the licensee's exercise critique on July 14,1993, the inspection team met with the personnel denoted in Section 1 of this report. Team observations were summarized. The licensee was informed of the following:
e The NRC team's conclusion that the licensee's exercise response was generally proficient.
e No violations were found.
e Previous concerns had been adequately addressed and were resolved.
e The strength, weakness, and areas for potential improvement identified during this exercise.
Licensee management acknowledged the findings and indicated that they would evaluate and take appropriate action on the identified items.