IR 05000255/1986019

Insp Rept 50-255/86-19 on 860818-20.No Violations or Deviations Noted.Major Areas Inspected:Emergency Preparedness Exercise Involving Observations of Key Functions & Locations

ML20209A698
Person / Time
Site:	Palisades
Issue date:	08/28/1986
From:	Foster J, Patterson J, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20209A653	List: IR 05000255/1986019 ML20209A647
References
50-255-86-19, NUDOCS 8609080084
Download: ML20209A698 (14)

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U. S. NUCLEAR REGULATORY COP #ilSSION

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REGION III

Report No. 50-255/86019(DRSS)

Docket No. 50-255 License No. DRP-20 Licensee: Consumers Power Company 212 West Michigan Avenue

Jackson, MI 49201

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Facility Name: Palisades Nuclear Plant Inspection At: Palisades Site, Covert, Michigan Inspection Condu ted: August 18-20, 1986

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Inspectors: . Patterson, NA d1[//ff[

Team Leader Dam / s't eviW24 Date Approved By:

N W. Snel , lef 3/zs/a Emergency Preparedness Section Date'

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Inspection Summary Inspection on August 18-20, 1986 (Report No. 50-255/86019(DRSS))

Areas Inspected: Routine, announced inspection of the Palisades Nuclear Plant Emergency Preparedness Exercise involving observations by five NRC representatives of key functions and locations during the exercis The inspection was conducted by three NRC inspectors and two consultant Results: No violations or deviations were identified as a result of the inspectio e60829 PDR ADOCK 05000255 1 G PD ,_, _ . _ . . .-_ . _ . _ _ _ . _ . . . - . _ _ . _ . . - _ _ _ _ . . _ , . --

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j Persons Contacted-NRC Observers and Areas Observed-J. Patterson, Control Room and Operational Support Center (OSC)

JJ Foster, Control Room and Technical. Support Center (TSC)

'F. Victor, TSC

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M. - Solberg, Emergency Operations Facility (EOF)

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G. Martin, TSC and EOF Consumers Power Company Personnei

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J. Firlit, General Manager, Palisades Plant T. Edward, Executive Director, Energy Supply Services, Corporate

! P.'Loomis, Emergency Planning Administrator, Corporate K. Farr, Public Affairs, Corporate J.' Storey, Public Affairs Director, Palisades K. Berry, Director, Nuclear Licensing, Corporate

.M. Mcbe, Instructor, Nuclear Training Department, Midland J. Lewis, Technical Director L. Kenaga, Staff Health Physicist J. Brunet, Emergency Planning Coordinator R. Rice, Operations Manager W. Beckman, Radiation Services Manager A. Katarsky, Emergency Planner, Corporate C. Axtell, Health Physics Superintendent ~

M. Mennucci, Radiation Safety Supervisor D. Joos, Plant Planning Director S. Cote, Palisades Property Protection ,

S. Kiss, Palisades Property Protection R. Orosz, Engineering and Maintenance Manager H.~ Esch, Administrations Manager E. Dziedzic, Materials and Facility Services Superintendent R. Fenech, Operations Superintendent P. Bruce, Electrical Superintendent K. Haas, Reactor Engineering' Superintendent E. Bogue, Radiation Safety Supervisor M. Dawson, Emergency Planning Technician *

R. Frigo, Operations Supervisor R. Christie, General Engineer J. Hager, Chemistry Lab Supervisor All names listed above attended the exercise exit meeting on August 20, 198 .

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. Licensee Actions on Previously Identified Items (Closed) Open Item No. 255/84-18-01: This item relates to an earlier request by NRC for additional training for the Post Accident Sample Monitoring (PASM) teams. Performance in the 1985 exercise, though improved, still could have been better. The licensee has condpcted additional drills in all phases of PASM during the last yea The performar;ce of the PASM team in this 1986 exercise was very good as observed oy the NRC inspector. This item is closed. This also completes Issue No. 5 of the licensee's corrective actions taken an a result of the 1985 exercis . (Closed) Open Item No. 255/85016-01: During the 1985 exercise, the Control Room participants were not given time to evaluate the emergency conditions and make an. emergency clascification due to a Controller's intercession in declaring the Alert conditio No similar actions were observed in this exercise. Both participants and Controllers in the Control Room performed their functions as they were trained to do. This item is closed and also completes Issue No. 1 of the licensee's corrective actions taken as a result of the 1985 exercis (Closed) Open Item No. 255/85016-02: In the 1985 exercise, the TSC personnel did not demonstrate a coordinated effort within the TSC nor with their counterparts in the Control Room resulting in '

some areas of conflict. As observed by the NRC inspectors in this exercise, the TSC demonstrated a well coordinated effort and cooperative attitude within the support center and also related well with their counterparts in the Control Roo This item is close (Closed) Open Item No. 255/85016-03: In the 1985 exercise, the licensee failed to adegastely access and trend radiological field data including the magnitude, location and composition of the plume. This aspect was well demonstrated during this exercise from initial activities in the TSC to the final radiological assessments in the EO This item is close (Closed) Open Items No. 255/85016-04 and No. 255/85033-04: In the 1985 exercise, poor contamination control techniques were demonstrated in the OSC, including poor " frisking" techniques by those individuals who did observe the frisking rule Contamination control techniques including use of anti-contamination clothing, respirators, and use of friskers were very well demonstrated in this exercise as observed by the NRC inspector. This item is closed as well as Issue No. 4 of the licensee's corrective actions taken as a result of the 1985 exercis (Closed) Open Item No. 255/85016-06: In the 1985 exercise, the offsite monitoring team did not initiate steps to decontaminate their vehicle upon leaving the plume. This vehicle decontamination procedure was successfully demonstrated when the team left the plume during the 1986 exercise. This item is close . _

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l General An exercise of the Palisades Plant Site Emergency Plan and Emergency Implementing Procedures (EIPs) was conducted on August 19, 1986. The exercise tested the response of the licensee to a hypothetical accident scenario, resulting in a major release of radicactive material to the environment. An attachment to this report describes the exercise scope and objectives and gives a narrative summary of the exercise scenari This was a full-scale exercise for the State of Michigan and a partial participation for Allegan, Berrien and Van Buren Countie . General Observations Procedures This exercise was conducted in accordance with 10 CFR Part 50, Appendix E requirements using the Palisades Nuclear Generating Plant Emergency Plan and associated implementing procedure Coordination The licensee's response was generally coordinated, orderly and timel If these events had been real, the actions taken by the licensee would have been sufficient to permit State and local authorities to take appropriate actions to protect the public health and safet Observers Licensee observers monitored and critiqued this exercise along with five NRC observers and a number of Federal Emergency Management Agency (FEMA) observers. FEMA observations on the responses of State and local governmental organizations will be provided in a separate repor Critique The licensee held a critique at the Palisades Plant on August 20, 1986. The NRC critique followed immediately after the licensee's self critique. Personnel who atter.ded this joint meeting are listed in Section . Specific Observations Control Room The Control Room was simulated in a small room closely adjacent to

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the actual Control Room. This was used due to test procedures being conducted in the Control Room. Lack of space and instrumentation in this substitute room made Control Room simulation difficult at time The initial message at 0815 giving initial conditions did not include the announcement that the annual exercise was startin Control Room personnel responded appropriately to all simulated accident conditions. Decisions were well thought out and were

appropriate to the situatio Where necessary priorities were

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Proper classifications of the Notice of Unusual Event (NUE) and Alert were made, based on the appropriate Emergency Action Level (EAL) fcr each event. Notifications were accurate and timely, and the proper notification forms were utilized. Operators showed coordination, determination, and perseverance in their efforts to mitigate the effects of the simulated accide:: Innevative ways to correct plant problems were discussed and attempted. As an example, a valve lineup which would have restored the containment spray system function had to be stopped by the controller, as it would have defeated the developed scensri Operators appeared to be well trained, were knowledgeable of their procedures (Emergency Operating Procedures, Emergency Plan, Emergency Plan Implementing Procedures), used their procedures properly, and responded appropriately to operational and safety systems failure Operators quickly and efficiently reviewed their EALs, which minimized the'. time necessary to make classifications for the NUE and Aler A detailed log of activities was maintained, which would have allowed reconstruction of activities during the simulated acciden Habitability checks (radiological- surveys via portable meter and air monitor sampling) were performed on a periodic basis. The Shift Supervisor properly guided the Control Room team and kept them informed of plant and overall condition Communication with the Technical Support Center was by direct contact with Control Room personnel, and was generally adequate. However, Control Room personnel, were unaware that a General Emergency had been declared until approximately one hour after the declaration, and were never aware that a bomb had exploded in the parts warehous Both of these events were considered as critical information which should have been communicated to the Control Room. Problems in communication to the Control Room may have been partially due to the difficulty in hearing Public Address system announcements in the simulated Control Roo The transition of command and control from the initial Emergency Director in the Control Room to the Site Emergency Director (SED)

in the TSC was acccraplished efficiently and without undue delay, b. Technical Support Center (TSC)

The TSC was activated in 22 minutes with no evidence of-prestaging observed. Assembly and accountability were completed in 26 minutes after the Alert was declared. Evacuation of non-essential personnel was simulated by means of a PA announcement. Notifications to State

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and County government offices and the NRC were made within the

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Important plant parameters were displayed on trend charts and graphs and were effectively utilized. The Site Emergency Director (SED)

and his staff closely monitored the Emergency Action Levels (EALs)

and changing plant, conditions to ensure that existing classifications were correct. The SED's briefings were frequent and meaningful with the entire staff as well as with his key support teams. The SED held detailed discussions with his team leaders to ensure that corrective actions were being focused on the priority item A good discussion took place between the technical support groups ~

in deciding whether with some failed fuel, partial lots of reactor safeguards equipment, and leaking reactor coolant pump seal, a General Emergency was justified. Finally the operations group recomended an upgrade to the Site Area Emergency based on loss of two fission product barriers, with elevated containment radiation readings. Offsite notifications were made, documented, and completed within the required time frames. The bomb threat was announced at 1015 and the bomb explosion at 1038. The latter was not heard in the Control Room as previously reporte Except for the ' actual announcements, there was little intearation of the bomb incident and its potential with other aspects of the emergency event. No consideration appeared to be given in the TSC to the projected effect of the bomb explosion or possibility of other consequences if other bombs were placed in key operating or reactor safety systems. Also, no discussion was heard on what effect the bomb explosion had on spare parts which might be required for the emergency. A more coordinated effort between plant security and the Operation Support Group and SED in the TSC should have been put fort It is recomended that integration of security / safeguards with the Palisades emergency organization be stressed in procedures and future emergency planning training. This is Open Item No. 255/86019-0 The TSC internal announcing system should have been used more frequently as an effective means to comunicate key information to those TSC staff working in the office cubicles where comunications

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were difficult. As the exercise progressed it was about 45 minutes before the first PA announcement was made at the Alert leve Emergency Plan Implementing procedure EI-3 stated that all cmergency classifications, including Notice of Unusual Event (NUE), should be announced over the PA system with a short explanation of the emergenc Because numerous NUEs have occurred under actual operating conditions where they were terminated as soon as they started, plant operating personnel had decided not to announce any of them over the plant PA system. However, NUEs that do persist after being identified should be announced on the PA system and all NUEs should be announced during the annual exercis _ - , . _ - _- . __ ~ -- .

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The TSC originated two messages containing Protective Action Recommendations (PARS) and phoned them in to the State E0C after the E0F had assemed responsibility. However, this was done because the E0F did not have a good telephone connection with the State at that time. The SED announced an upgrade to a General Emergency a based on the loss of two fission barriers, no containment spray, and increasing stack nonitoring levels. An initial PAR of sheltering up to two miles in all directions and five miles downwind in sectors H, J, and K was sent to the State at 110 .

The Health Physics responsibil.ities including habitability, offsite

and onsite monitoring, dose assessment and protective action formation were efficiertly demonstrated in the TSC. The transfer of dose assessment and PtR responsibilities from the TSC to the EOF went smoothly in spite of the scenario related loss of power by the TSC at the same tim The TSC continued to make dose assessment calculations in parallel with the E0F after the EOF took the lead in this area. Radiological status boards in the TSC were well

, maintained throughout the exercis Operational Support Center (OSC)

The OSC activation went smoothly and efficiently and was completed in less than 30 minutes. However, there was no announcement by the OSC Director when the facility was fully operationa Accountability of OSC and Maintenance Support Center (MSC) personnel was completed in five minutes. Coinmunications equipment in the MSC included two sound powered telephones, one to reach the OSC and the other to contact the TSC. They were helpful particularly for the onsite repair teams and the onsite radiation monitoring team Briefings to all onsite teams by the Health Physics (HP) Supervisor were thorough and included radiation protection guidance. The HP Supervisor kept a leg of emergency-related activities and the location and times the teams were dispatched. There were sufficient numbers of Controllers for all the OSC team The NRC observers accompanied two separate maintenance teams and also observed part of the Post Accident Sample Monitoring (PASM)

team's function. Both maintenance teams were knowledgeable of their assignments and demonstrated good ALARA practices including one team which used respirators, Self Contained Breathing Apparatus (SCBA)

and full anti-contamination clothin Communications were made with the OSC and for one team, also with the TSC. The PASM team demonstrated good technique in the use of the PASM panel for obtaining a sample, transferring it into a vial inside a lead lined container, and delivering it the Chemistry Hot La The complete PASM operations, from the request to the obtained results, took approximately 1 3/4 hours. The team followed procedure EI-7.1 satisfactorily. A reactor coolant sample and containment atmospheres samples were take .

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Frisker. stations were set up at both entrances to the OSC and used throughout the exercise. The do:imetry clerk was diligent-and efficient in issuing dosimetry and recording the identities and information needed for the inplant team The OSC Director demonstrated good command and control; however, he should have more. frequent plant status briefings for his staf Logs were kept by the Chemistry Supervisor and the Health Physics Superviso The OSC Director had access to both of these logs plus a timely

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list of events on the status board behina his desk. These aids- '

plus other coiimunications kept him well informe There were a few instances of radiation data received'from the TSC which proved to be incorrect. The data was challenged by the OSC and resolutions were made within a short time to agree on the correct dat Overall, the OSC was well organized, efficient, cooperative in -

their functions, and adequately demonstrated their_ emergency esponsibilitie d. Emergency Operations Facility (E0F) '

At 1005, plant personnel were dispatched to the E0F to provide interim management until the -initial General Office Emergency Response Team (G0RT) arrived. The plant personnel arrived at the EOF at 1024 and assumed their functions under the guidance of the E0F Administrator. At 1039, the E0F Administrator briefed all his staff on plant status prior to the GORT arrival at 104 There was no radiation monitoring of plant personnel entering the-EOF after the release had started. Even though these personnel exited the plant through portal radiation monitors they could have' received some surface contamination enroute to the EO The transition from the initial activation stage at the EOF to a fully operational status was very well don Command and Control by the E0F Director was excellen The frequent briefings given to the support team leaders and the exchange of information between team leaders and the E0F Director were well organized and efficient. Announcemer.ts on general conditions and State activities were made frequently by'the EOF Director to the EOF staff. Emergency telephone numbers were not readily available for the EOF Administrator. Copies had to be made from an emergency '

plan in an adjacent room and brought to.his des Also, a copy of

! the Emergency Plan and the Implementing Procedures should be available

at the Emergency Director's desk. Status boards were well i maintained and updated in a timely manner except for the HP trend i graph Data for these graphs did not begin until 1140 and was

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back fitted to 1045. It was well maintained after that.

! Communication and coordination by the logistics group, public I affairs and the secretarial / clerical groups was excellent.

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The HP staff expeditiously contacted the National Weather Bureau '

when onsite met.eorological information was lost. The communicator for the offsite monitoring teams provided radiation protection precautior.s to the teams, directed them where ta go, and monitored radiation data raceived from them. Arrangement';-were made with a

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local fire department to decontaminate vehicles after the exercis A tank truck was available but its actual use was simulate No information was provided as to what would be done with the contaminated wate There appeared to be a good rapport between the E0F managers and the State of Michigan. Good discussions were held several times in conjunction with issuance of PARS. Dose assessment values were correctly obtained and used. There was good coordination and cooperation between tha support groups, as well as the Emergency Director and his staf Once the EOF assumed HP and dose assessment responsibilities, interaction continued between the TSC and the EOF resulting in the TSC performing dose assessment calculations as a check in parallel with the E0 This proved to be very effectiv The E0F staff made good use of offsite monitoring data to back calculate release rates for comparison with release rates determined from plant monitors to identify any unmonitored release pathway However, the HP group needs additional guidance on when the field monitoring results and the calculated ret.ults are significan A1,so the unmonitored release pathway was never identified by the E0 Overall the E0F functioned well and exhibited a great deal of

, competence and team wor e. Exercise Scenario and Control The scenario had some difficult problems which presented more challenges to the controllers, particularly the numerous electrical bus cross-connecting and consequential loss of capabilities. This electrical bus problem resulted in three contingency messages being

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issued which came close to prompting the players. Other scenario conditions resulted in problems which were straight forward and had more than one unique solutio There was a sufficient number of controllers to observe activities in each of the Emergency Response Facilities. Several data inconsistencies in the scenario caused some confusion for the players. The scenario demonstrated flexibility in the selection of the EALs in that for each EAL there were options to justify using an upgraded classification. In addition, the offsite dose rates appeared unrealistically lo In conclusion, the scenario contained a relatively high degree of difficulty and was adequate as the means to help the licensee achieve all the exercise objective , . - - - - _ - - - ..

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. Exit Interview The inspection team held an exit interview the day after the exercise on August 20, 1986 with the licensee representatives denoted in Section The NRC team leader discussed the scope and findings of the inspectio The inspectors also discussed the content of the report to determine if

.the licensee considered that any of the information was proprietar The licensee responded that none of the information should be proprietar Attachment: Palisades Exercise Scope and Objectives and Narrative Summary

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. SCOPE AND OBJECTIVES SCOPE A simulated abnormal radiological incident at the Palisades Plant will escalate to a General Emergency and will involve planned response and recovery actions that include emergency classification, notification of offsite organizations and plant personnel, simulated actions to correct the emergeacy conditions and initiation of accident assessment and protective actions, as necessary, to cope with the accident. The energency will then de-escalate, the recovery phase will be initiated and this will terminate the exercise. The exercise will simulate an emergency that results in offsite radiological releases which require response by offsite emergency response organization .2 OBJEC11VES

The major objective of the exercise is to evaluate the integrated capa-bility and a major portion of the basic elemerts of the onaite and off-site eeergency plans and the emergency response organizations. Specific objectives of the exercise to be demonstrated in various phases are listed below. The " free play" aspect of the exercise will be emphasize where practical. The exercise will demonstrate: , Adequacy of the Site Emergency Plan and the Site Emergency Plan Implementing. Procedures to ensure compliance with 10 CFR 50.47 and NUREC-0654 Activation, staffing and operation of Emergency Response Facilities Ef fective interface between CP Co Emergency Eesponse Facilities in the aosessment and mitigation of an accident, both operationally and radiologically Effective transfer of responsibilities from the Control Room to the Technical Support Center to the Emergency Operations Facility Recognition, classification and trending of emergency conditions t Site assembly and accountability of personnel within about 30 minutes Notification of Federal, State, local, Corporate and plant person-nel within specified time constraints Coordination with State of Michigan and Nuclear Regulatory Commission em'ergency response organizations *

• Both the State and NRC will participate on a full-scale basis. The State will supply personnel in the EOF while the NRC will send players to all CPCo Emergency Hesponse Facilitie .

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9. Access control of Emergency Response Facilities and the plant under emergency conditions 10. Mobilization'aad capabilities of onsite and offsite radiological monitoring teams 1 Ability to monitor, assess and trend radiological field data.

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12. Ability to formulate timely and appropriata protective actions based on Protective Action Guides and postulated event conditions 1 Capability to collect and analyze a post-accident primary coolant sample i

14. Ability of CP Co controller organization to effectively control and evaluate exercise performanc ,

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g NARRATIVE The plant is at full power,_98-100%, at the middle of core life. Bus 13 and 14 are cross-tied in preparation for resetting the " taps" on station power transformer 13. Bus 77 and 78 are also cross-tied as the supply breaker to transformer 13 also feeds transformer 77. Boric Acid pump P-56A will not run due to solidified boric acid. Spray pump P-54A has been disassembled follow -

ing a seal failure. HPSI motor-operated valve M0-3007 is out of service and blocked open. Service water pump P-7A basket strainer is clogged with debris-and marine life causing intermittent Hi-DP alar It is partly cloudy and cool. Forecasts call for a clearing trend with a 40% '

chance of showers in the mornin At 0845, primary coolant pump P-50E shears, stopping the impeller. *In the subsequent reattor trip, Control Rod 34 fails to insert. It remains fully withdrawn and fuel damage occurs. The primary coolant pump failure was chosen to provide a single initiation which could fail two fission product barrier Following the turbine trip, both diesel generators start. One trips im=e-dietely on overcurren A loose section of Bus IC enclosure cabinet is jarred by cycling breakers during fast transfer and falls against the bus bars causing both phase-to-phase and phase-to-ground faults. The following equipment is lost

Auxiliery feed.ater pump P-8A, LPSI pump P-67B, Service k'ater Pump P-7B, HPSI pump

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P-66B, Containment Spray Pumps P-52A and C, Station Power Transformers 11, 13 (. .

and 19, and the Meteorological Towe The primary coolant pump failure was chosen to provide a single init iation which could fail two fission product barrier The failure of Bus 1C removes.any possibility of operating the train of Emergency Core Cooling Systems powered by that bus, irrespective of diescl generator operability or availability of offsite pever. Lost are the two additional spray pumps, the effective containment air cooler, and the operable boric acid pump. Thus, containment pressure will increase with even a moderate primary coolant system leak and no method of boration is available from the control room.

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The Site EmerEency Director (SED) may imaediately elect to declare an Unusual Event based on the existence of plant conditions which warrant increased awareness of plant staff or due to an abnormal tri At 0855, the failed fuel monitor responds to fuel damage. The SED may elect to classify the situation as an Alert based on " coolant pump seizure leading to fuel failure." He may elect to wait for confirmation via sample analysi ,

At 0915, the upper seal on P-50B fails, leaking 60 gpm to containment. The situati It is, however, possibl,one that warrants the SEDAlert may declaration according elect to escalate to Siteto procedu' Area Emergency based on loss of two fission product barrier The Alert (or higher) declaration brings personnel accountability and activa-tion of the Technical Support Center (TSC) and Operational Support Cente NARRATIVE l

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,- The Site Emergency Director may elect to activate the Emergency Operations Facility (EOF) at .the Alert Classificatio .

Following completion of accountability, the Lead Security Controller, in conjunction with the Lead Onsite Controller, will initiate a security plan activation sequence. A bomb threat is received with bomb location and detona-tion time provided. The bomb will explode and result in. damage to the ware-house. No personnel vill-be injured. The warehouse is outside the~ protected area. The bomb is not a threat to plant operation. No change in emergency classification is warranted by procedur At 1045, P-505 seal fails completely, resulting in a LOCA of 1000 gpm. If not already classified, a Site Area Emergency should be declared based on LOCA greater than charging pump capacity. As containment pressure increases rapidly, stack monitor readings climb accordingly. A release begins through faulty purge valves to the stack. Noting this, the SED may opt to declare a General Emergency. He may, however elect to wait for confirmation by monitoring teams prior to declaration of General Emergenc At 1050, Primary Coolant System pressure is dropping rapidly. The Safety Injection Syster actrates, resulting in E Bus opening and subsequent loss ~of Fire System Jockey pump and Fire Pump 9A Pressurizer Heater Transformer 15, the seteorological tower, half of the lights and all wall outlets in the TS The computer used for dose calculations in the TSC is rendered inoperabl Based on anticipated operator actions, full TSC power should be restored in about five rinute ( Palisades personnel reporting to the EOF will be allowed access upon arriva General Of fice Response Team (GORT) will be allcwed entry sixty minutes af ter the decision to activate the EOT. Remaining General Office person.nel vill be Eranted access thirty minutes af ter arrival of the GOR There are three foreseen methods of terminating the release: 1) repair of spray pump P-54A, 2) repair of Bus IC, 3) plugging of release path through i

purge line. In any case, the earliest permissible repair is at 140 Items -

(1) and (2) employ spray pumps to condense steam, reduce pressure, and thereby i halt the release. Item (3) requires physical plugging of the line. Reentry "

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and recovery will be demonstrated administrative 1y through development of a recovery pla The exercise, or portions thereof, vill be terminated by the Exercise Coordina-tor in conjunction with Lead Controllers and State and Federal official .

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