IR 05000255/1991013
| ML18057B017 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/27/1991 |
| From: | Caniano R, Foster J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18057B015 | List: |
| References | |
| 50-255-91-13, NUDOCS 9107110094 | |
| Download: ML18057B017 (26) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION II I Report No. 50-255/91013(DRSS)
Docket No. 50-255 License No. DPR-20 Licensee:
Consumers Power Company 1945 West Parnall Road Jackson, Michigan Facility Name:
Palisades Nuclear Plant Inspection At:
Palisades site, Covert, Michigan Inspection Conduct~d: June 17-20, 1991 7~
Inspectors:
J. Heller Accompanying Personnel: J. Stephan J. Wil 1 S. Orth
,yj. (Z.~;~
Radiological Controls and Emergency Preparedness Section Inspection Summary
- ~
Inspection on June 17-20, 1991 (R~port No. 50-255/91013(DRSS))
Areas Inspected:
Routine, announced inspection of the Palisades Nuclear Plant annual emergency preparedness exercise, involving review of the exe*rcise scenario (IP 82302), observations by five NRC representatives of key functions and locations during the exercise (IP 82301), and follow-up on licensee actions on previously identified items (IP 92701).
- Results:
No violations, deficiencies or deviations were identified. The licensee demonstrated a good response to a very challenging hypothetical scenario involving multiple instrument and equipment failures and a minor radiological releas Use of real meteorological data aided the realism of the scenari Emergency Operations Facility performance was considerably improved over the 1990 annual exercis One Open Item was identified relative to the organization and function of the Operations Support Center/Maintenance Support Center (OSC/MSC).
9107110094 910627 PDR ADOCK 05000255 G
DETAILS NRC Observers and Areas Observed J. Foster, Control Room, Technical Support Center (TSC), Operations Support/Maintenance Support Center (OSC/MSC), Emergency Operations Fa c il i ty ( EO F )
S. Orth, Control Room, TSC, OSC/MSC, EOF J. Stephan, EOF J. Will, Control Room, TSC J. Heller, OSE/MSC, in-plant teams Persons Contacted Consumers Power Company
- N. Brott, Emergency Preparedness Coordinator
- P. Donnely, PS&L Director
- K. Hass, RSD Manager
- R. Rice, Operations Manager
- C. Ready, Senior HP Technician
- C. Grady, Plant Mechanical Supervisor
- A. Katarsky, Emergency Planning Administrator
- J. Burnet, PS&L
- D. Vanderwalke, Engineering Programs
- A. Clark, General Health Physicist
- M. Mitchell, Emergency Planning
- M. Savage, Public Affairs Director
- *P. Loomis, Performance Specialist
- M. Dawson, Nuclear Instructor II
- K. Penrod, Emergency Planner
- T. Popp, Health Physics Technician
- C. Hillman, Plant Licensing
- R. Vincent, Plant Safety Engineering
- J. Hanson, Operat~ons Superintendent
- J. Werner, Quality Assurance
- D. Hoffman, Vice President, Nuclear
- R. Orosz, Operations Nuclear Engineering.& Construction Manager
- G. Van Hoot, Director, NPAD
- J. \\<larner, Property Protection M. Hobe, Emergency Preparedness, BRP M. Moore, Quality Assurance B. Jahn, Senior Technical Instructor K. Schneider, Nuclear Operations Analyst
- Denotes those attending the NRC exit interview held on June 20, 199 The inspectors also contacted other licerisee personnel during the tourse of the inspectio * *
Licensee Action on Previously Identified Items (IP 92701) (Open) Open Item No. 50-255/90011~01: During the 1990 annual exercise, the licensee failed to coordinate Operations Support Center/Maintenance Support Center (DSC/MSC) activities at a supervisor or director level. Also, the licensee had nci m~thod to uniquely identify and track inplant response teams. A new status board to track inplant teams was develope During the 1991 annual exercise, OSC/MSC performance was significantly improved, and the new status boards functioned well. However, concerns were identified as to overall OSC/MSC organization. This item will remain open pending_resolution of overall OSC/MSC concern (Closed) Open Item No. 50-255/90011-02: During the 1990 annual exercise~ the licensee failed to activate the EDF in a timely manne The EOF had been set up in advance to accommodate the setup-of computer equipment brought from the corporate office, resulting in the licensee's failure to demonstrate the ability to activate the facility under normal conditions. The licensee has purchased new computer hardware for use in the EDF, and it was decided that this equipment will be maintained in the EO EDF activation during the 1991 annual exercise was excellent, and the facility functioned well, as described in this report. This item is close (Closed) Open Item No. 50-255/90034-01:
The licensee had no programmatic method in place to insure that uncontrolled copies of procedural forms maintained in emergency response facilities are kept current. A procedural change addresses modification of forms and inventory requirements to assure that forms are maintained current. This item is close (Closed) Noncompliance 50-255/90034-02:
During the last routine inspection, numerous deficiencies were found in the emergency preparedness training program, including lack of adequate personnel identified to staff positions, lack of qualified personnel, and personnel having exceeded the three month 11 grace period" for emergency response training requalification. Discussion with licensee personnel and a review of records indicated that these
- problems had been adequately corrected. This item is close (Closed) Noncompliance 50-255/90034-03:
During the last routine inspection, it was identified that the individual assigned the position of Health Physics Support Group Leader had not had emergency response training, but was placed on the emergency response augmentation list from February to November 199 Discussion with licensee personnel and a review of training records indicated that this problem had been corrected; This item is close (Closed) Open Item 50-255/90034-04: During the last routine inspection, it was identified that Emergency Preparedness training lesson plans need to be reviewed and updated in a more timely manne Discussion with licensee personnel indicated that a
- procedure is now in place to route changes to procedures to the training department for review so that training plans can be revised as needed to reflect revised procedures. This item is close Genera An announced, daytime exercise of the Palisades Nuclear Plant Emergency Plan was conducted at the Palisades Nuclear Plant site on June 18, 199 The exercise tested the licensee's organizational capabilities to respond to a simulated accident scenario resulting in a minor release of radioactive effluent. This was a utility-only exercise. State and local counties participated to a very limited extent (State of Michigan representatives were present in the EOF).
Attachment 1 describes the Scope and Objectives of the exercise and Attachment 2 describes the 1991 exercise scenari.
General Observations Procedures This exercise was conducted in accordance with 10 CFR Part 50, Appendix E requirements, using the Palisades Nuclear Plant Emergency Plan and Emergency Plan Implementing Procedure Coordination The licensee 1 s response was coordinated, orderly and timely. If the scenario events had been real, the actions taken by the licensee would have been sufficient to mitigate the accident and permit State and local authorities to take appropriate actions to protect the public 1 s health and safet Observers The licensee 1s controllers/observers monitored and critiqued this exercise along with five NRC observer Exercise Critique The licensee 1 s controllers/evaluators held critiques in each facility (with participants) immediately following the exercis Lead controllers also held a joint critique to discuss observed strengths and weaknesses for each facility and the overall exercis The NRC discussed observed strengths and weaknesses, developed independently by the NRC evaluation team, during the Exit Interview with the licensee which was held on June 20, 199.
Specific Obse~vations (IP 82301) Control Room (CR)
As in previous years exercises, the licensee utilized the Operation Superintendent 1 s*office as a simulated Control Roo Printouts of reactor parameters and messages were provided to exercise Control
Room personnel. A Control Room simulator is now onsite, and is in the process of debugging and software.upgrading. The licensee tentatively plans to utilize this simulator in subsequent years~
emergency exercises, and this should significantly increase the level of exercise realism for Control Room participant Use of data sheets and messages to simulate plant conditions and annunciator alarms makes realistic play for the Control Room personnel very difficult. The players could not readily find desired.information on the data forms; there was no effort to maintain a Control Room log; and where operators might check indicators (such as radiation monitors) as a matter of routine, they had to request the dat In spite of the limitations caused by the simulated Control Room, the operators did an excellent job of displaying their knowledge of the plant, proper use of procedures, and appropriate command and contro The exercise Shift Supervisor (SS) demonstrated commendable concern for personnel who might receive a high radiation dose as a result of sample valve operatio In setting u-p to take a primary coolant system sample, the SS was aware that the action would likely bring highly radioactive water outside of the**containment and into the sampling lines. The SS stated that he wanted the people at the valves in constant communication with the Control Room so he could personally control the evolutio He intended to throttle the sampling s,Ystem isolation valves*and shut them at the first indication of high radiation level * *
The SS also demonstrated appreciation of the potential for further core damage when he recommended not starting reactor coolant pumps as called for by the cooldown procedur Although plant cooldown procedures called for the operators to restart the Primary Coolant Pumps (PCPs), the SS recommended not doing s He based this on the fact that the plant was already being adequately cooled down due to coolant injection and natural circulation, and to start the pumps could aggravate any fuel damag Control Room and TSC personnel did a commendable job of keeping other plant personnel informed of plant conditions using the internal and external Public Address (PA) system Personnel around the plant were informed of plant conditions via the external PA syste Further, the Assistant Site Emergency Director kept Technical Support Center personnel informed of plant status and remedial actions via the internal PA syste Upon activation of the TSC and Operations Support Center/Maintenance Support Center (OSC/MSC), some confusion was caused by the presence of plant operators which had been sent into the plant by the Shift Supervisor (SS). Throughout the exercise, the SS continued to.
dispatch operators from the Control Roo Failure to carefully coordinate separate teams dispatched from different locations could result in personnel injury and/or equipment damag **
At 0900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> the SS dispatched an Auxiliary Operator to check on the Bus Y-20 Inverter Breaker panel. Somewhat later, the OSC/MSC sent out their own team to check the panel, and confusion resulted regarding who was to do what with wha The Shift Supervisor, ~hile concerned with sigriificant tin-going plant casualties, was distracted by having to fill out a shift
- rotation schedule form for the TS Administrative details such as this should not be imposed on the Control Room staff while high priority actions are in progres *
Priorities for investigative and remedial team actions could have been better coordinated between the TSC, Shift Supervisor and OS Further, the Emergency Director's status board in the TSC was changed by various persons and did not always accurately reflect the current status and prioritie At 1017 hours0.0118 days <br />0.283 hours <br />0.00168 weeks <br />3.869685e-4 months <br />, an electrician supervisor, apparently assigned to one of the OSC/MSC teams, called the SS to ask him what he wanted him to do first. Coordination.of priorities should be between the Site Emergency Director, TSC Repair Coordinator, Shift Supervisor and the OSC Manage After OSC activation, communications with inplant teams should be between the team and the OS Altho~gh messages from the TSC indicated that a very minor (slightly higher than normal containment leakage) release was in progress starting at 0928 hours0.0107 days <br />0.258 hours <br />0.00153 weeks <br />3.53104e-4 months <br />, Control Room personnel received limited data pertaining to this release. Hence, Control Room personnel could not caution their operators about potential radiological hazards nor were they active participants in the discussion regarding upgrading plant status to a General Emergenc No violations or deviations were identifie Technical Support Center (TSC)
The layout of the Technical Support Center (TSC) requires that individual groups wotk in their respective cubicle Pe~iodic meetings were held in the command are TSC staff did an excellent job of determining plant status and attempting to develop mitigating strategies for the accident conditions portrayed by the scenario. These efforts were made more difficult by the wide ~ange of instrumentation made inoperable by scenario events. Equipment out of service and in need of restoration was identified, selected reactor parameters were trended, and general priorities for repair efforts were determined~
Event reclassification was aggressively pursued throughout the exercise. Considerable discussion centered around the status of the
- fission product barriers and the extent of the challenge to the integrity of the containment building. Late in the exercise, significant efforts were made to determine if the criteria for a GenerC'.l Emergency declaration had _been satisfie **
Accountability was completed rapidly and effectively. Following completion of accountability, approximately 45 minutes were needed for site evacuatio Habitability checks of the TSC were frequently made and appropriately displaye Personnel with monitors frequently checked the TSC spaces and duly noted the fact on the status-board in the Health Physics are However, as noted in their own critique, they failed to check the radiological conditions in either the simulated or actual Control Room. * This may have been an "exercise artificiality", as the available space in the simulated Control Room effectively precludes such survey Periodic staff briefings kept TSC staff adequately informed as to changing plant status. Notifications were made to offsite authorities and the NRC, as required, and*within notification goal TSC status boards #2, #3 and #4, which display the contents of the latest notification message, were dutifully updated every fifteen minutes; however, for an hour and fifteen minutes after the emergency had been upgraded to a General Emergency, no one noticed the board still indicated a plant status of Site Area Emergenc There was no question that all personnel present were aware of the actual classificatio TSC personnel did not often refer to these status boards, which contained information that they could more
- easily read from the copies provided the During this exercise, real time meteorological information was utilized. There were several wind direction shifts, and at one time during the day, there was a real 180 degree wind shift. Perhaps aggravated by the frequently changing wind conditions, the plume direction data displayed on various TSC status boards by geographic angular measurement and/or affected sectors were sometimes in error with each other or with the latest information receive At the entrance to the TSC Health Physics area to the left, there is a plume map with a place to indicate sectors affecte In the Health Physics cubicle, there are two status boards, one with times and wind direction and the other showing plume and sectors. Behind the Site Emergency Directors (SED's) chair is also a plume ma There were times when the plume and the sectors did not coincide on the same board and ti~es when all boards displayed slightly different dat The TSC status board entitled "Vital Equipment Out of Service" indicated equipment and systems requiring remedial attention with priorities assigned for Instrumentation & Control (I&C), Electrical and Mechanical group Priorities were assigned by group, so that I&C and Electrical (for example) were assigned to the same job with different priorities for accomplishment. There was no indication of overall priority assignment from which HP and others could work.
An unlabeled status board (apparently for use by the Emergency Director) was used to indicate equipment/system problems, priority,
- and status. Various people made changes to this board and the.
information displayed on this board differed from that displayed on the equipment out of service boar The TSC lacks an inplant team tracking status board. It was not clear that any one individual in the TSC was fully cognizant of the number of inplant teams and the status of completion of their*
respective tasks. This is critical information which should be constantly ava1lable to the individual in charge of the TS The TSC also lacks a board which can portray actions needed to be accomplished and their priority (by task). While priorities were being developed and assigned, the priorities assigned were relative to each discipline rather than by tas It was noted that most of the announcements made during the exercise did not initiate with a request for personnel to listen to the following messag *
No violations or deviations were identifie Operational Support Center (OSC) and Maintenance Support Center (MSC)
The MSC and OSC are not in the same roo The OSC is in a lunch room which permits easy briefing of assigned personne The MSC is in a locker room adjacent to the lunch roo The locker room is divided into three sections delineated by the lockers. This layout required that the facility leader provide three briefings to assure that all personnel in attendance were knowledgeable of plant statu The. supplies in both areas were located in locked cabinets that had been inventoried on a preset frequenc The supplies were readily available and handed out as necessar The OSC and MSC were activated in a professional, timely and orderly manne In general, adequate staffing appeared available for assignment as necessary to support various activitie In both facilities, the facility leader presence was quickly established by discussing the rules of conduct and the mission of e*ach facilit In addition, personnel were informed of plant status during briefings conducted by the facility leader and the TSC via the plant paging syste The paging system was auditable to everyone in attendance at the OSC and MS In both areas status boards were easy to read and maintained with accurate up-to-date informatio The inspector observed that the team status boards in each area identified the teams dispatched from the area. The board contained the name of the team members, time departed, type of work and the time dispatche However the team number was not unique to an activit For example, team one from the MSC may not perform the same activity as team one from the OS The duplication of team numbers could lead to communication problem.
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The inspector did observe that a frisking station was established at the OSC and MS However, no stations were established at any entrance to the control room or technical support center. Scenario data did not support establishing these frisking stations to control potential contamination spread. These stations would be precautionary in nature and could provide early warning of contamination problem The inspector observed the briefings of two teams dispatched from the MS For each, the briefings were adequate to perform the required activit Once briefed, the teams went to the OSC for radiation briefings, addition of a radiation technician to the team, and the issuance of self reading dosimeter One team went to the TSC, where an engineer and auxiliary operator were added to the tea An observation made during the previous exercise evaluation pertained to briefing of inplant team The observation implied that a communication problem could evolve because the team was not convened at a central location and then briefed by all parties on the applicable work activities. The inspector didn't observe any briefing problems during this drill; however, the previous drill observation remains valid and does identify a potential problem are The first team observed was dispatched to a failed 120 volt AC Bus (Y-20). The team entered the TSC to obtain an engineer and auxiliary operator assigned to the tea While at the job site, personnel completed their assigned task and made recommendations to the shift supervisor and MS *
The inspector observed communications in the MSC and noted a terminology confusion when the MSC implied that the shift supervisor wanted power established to selected equipmen At this time, the need to power selected equipment was at the direction of the TSC and not the shift superviso The second team observed was required to install a jumper in the Control Room to permit use of the primary coolant sampling system that had been isolated by the containment isolation signa As part of the Emergency Plan the procedure~and jumpers required to perform this activity were staged in the MS The \\'!Orkmen had no difficulty performing the activity and the Control Room operator appropriately reviewed the workmens' activities while the jumpers were i nsta 11 e While overall inplant teams functioned well, several problems relative to team dispatch and tracking were evident. This relates to the overall organization of the inplant team functio Observations regarding these problems impacted on the Control Room and Technical Support Center as well as the OSC/MSC~ and individual comments are found in those sections of this report. These problems are as follows:
(1)
The Shift Supervisor retains the authority to dispatch operators directly from the Control Room, without
consultation with the OSC/MS This leads to the possibility that a team for a particular task can be dispatched from the OSC/MSC and an.Operator can be dispatched from the Control Room for the same tas This occurred during this exercise when two groups arrived at breaker Y-2 Once the OSC/MSC is established, control of all personnel entering the plant should be transferred to the OSC/MSC, and those already dispatched into the plant should be tracked as OSC/MSC team (2)
Several individuals in the TSC and the OSC/MSC were cognizant of the status of individual inpJant teams and the status of their assigned tasks, but it was not evident that the information was available to any one individua (3) Priorities were not always clear, and priorities for individual groups have the potential for confusion as to overall priority assigned to a tas (4)
The extent of the immediatel available workforce was not evident in the OSC MS.
status oar w ic could be utilized for ~uch a depiction listed all personnel in the plant, not those immediately available. A manager should be able to immediately determine his available workforce and summon additional personnel were deficiencies are eviden (5)
The practice of multiple briefings at different locations was less efficient than a single overall briefing fo a tea Different briefings for individual team members has the potential for confusio Ideally, the TSC, in coordination with the Control Room, should establish task priorities for a single facility (OSC} where all functions pertaining to inplant teams are directed. A single individual should be in overall charge of the facility, directing supervisors for the various disciplines (electrical, maintenance, I&C, health physics, operations, etc.). Each inplant team should be uniquely identified, and their status (task completion) tracked. A display board should provide a listing of assigned priorities by task, and a display board should provide a listing.of the available workforce by disciplin Teams should be assembled and briefed/debriefed as a team, and communicate as a team with the OS Where individuals were already in the plant performing tasks at the direction of the Control Room, they should be designated as teams, and receive subsequent direction ar.d tracking from the OS *
The individual in charge of the TSC should be constantly aware of which teams are in the plant, and the status of completion of their assigned task The OSC/MSC organization and the methodology.of inplant team tracking in the TSC is an Open Item (No. 50-255/91013-01).
No violations or deviations were identifie Emergency Operations Facility (EDF)
A pre-exercise inspection of the Emergency Operations Facility (EOF)
- indicated that the facility and equipment had not been pre-stage Computers are now maintained in the facility on moveable workstations. Setup of EOF was prompt and well organize Organization of Communications, Plant Physics, Health Physics, Plant Support Engineering Support, Secretarial/Clerical, Public Rel~tions and Security teams was promp Teams appeared to be proactive and well coordinated throughout the duration of the exercis Management by the EOF Director appeared to be \\',1ell coordinated as demonstrated by: prompt announcements of plant status, communications to the State and the NRC, interaction with TSC and field teams, frequent consultations with team leaders, periodic solicitation of input from team leaders and the Emergency Director and EOF Administrato The EDF Director remained anchored at his station throughout the exercise, so personnel did not have to hunt for hi Problems were being solved as a management tea Accountability procedures were correctly conducted by security personnel. Security appeared to have a high degree of awareness of all personnel moving in and out of the EOF and processing and badging was accomplished with little, if any, dela Dissemination of messages coming into the EOF by the secretarial/clerical team to the various EDF stations was promp Status board recording and the graphical display of meteorological, plume extent and direction, sheltered and evacuated areas, and others \\'las profuse in the EO Status board recorders worked very hard at maintaining the information curren Overall, the participants in the emergency exercise (players and controllers) went about their duties in a very serious manner, and spent considerable time in problem solving exercises and related activitie Good exercise professionalism was eviden Monitoring for habitability was conducted with one air sampling device in the room adjacent to the EOF where the secretarial/
clerical support team is located. Part of the reason for this samplers' location is the noise it creates during operatio Discussion with licensee personnel indicated that the sampler would be relocated to the EOF itself if plant releases appeared to threaten the EO Frisking required at the entrance of the EOF was performed by some arriving players incorrectly or carelessly. Some arriving General Office personnel picked up the instrument probe without first determining whether their hand was contaminated, some placed the probe face down on furniture, others waved it near their hands.and feet without observing the. required distance. Stationing of trained personnel at this location would help ensure that frisking is conducted correctl Announcements via the Public Address system cannot be heard in the anteroom area where Security Personnel were located. For example, the announcement of the General Emergency could not be heard in this*
location. Placement of a speaker in this area should be evaluate A graphics board showing the Emergency Planning Zone and a release plume was observed in the room where the Public Affairs team was locate The plume location was not consistent with exercise data, and it was determined that this board was not being use Non-functional status boards should be removed or turned around to preclude confusing response personne Personnel setting up the Critical Function Monitor struggled for about five minutes in an attempt to plug the systems' cables into a wall socket that had been obscured by earlier status board placemen Finally, the offending status board was relocated to expose the socket. Status board locations should be marked to ensure that they are hung in the proper locatio No violations or deviations were identifie Field Monitoring Teams Field monitoring teams were not directly observed during this exercis Ne. significant problems were identified by monitoring of radio transmissions and field team locations on map board Recovery/Reentry Following a scenario time jump, a limited Recovery/Reentry demonstration was h~ld. It was noted that the procedure does not address consideration of the needs of the NRC during this timefram At a minimum, the NRC would request that any failed equipment not required for safe plant shutdown not be repaired until the NRC personnel could observe the repair and participate in the ~ailur~
analysis; that no records or documents be destroyed; that 1nterv1ews be arranged with all involved key licensee personnel; and that space be provided for NRC need No violations or deviations were identifie.
Exercise Objectives and Scenario Review (IP 82302)
The licensee submitted the.exercise and scope and.objectives and a draft scenario package for reviev1 by the NRC within the established timeframe Scenario review did not indicate any significant problem The scenario package was adequate in scope and content to ensure ease of use and contained enough information so that licensee controllers could control the exercis The licensee 1 s scenario was very challenging for a* utility-only exercise, including: loss of a significant amount of vital instrumentation, real time meteorology, multiple equipment failures, and assembly/accountabilit The degree of challenge in an exercise scenario is considered when assessing observed exercise weaknesse No violations or deviations were identifie.
Exercise Control Overall, exercise control was considered adequat controllers to control the exercise, and they were regarding their task No instances of controller observe There were adequate knowledgeable prompting were The Control Room personnel did not receive the kind of data which they thought would corroborate a release even a gaseous release. With high activity in the containment and a later report of high radiation in the Auxiliary Building, they thought that they would have gotten various other indications of a leak such as high stack vent activity, friskers alarming from personnel tracking the material all over the pla~t, etc. Further, they were given no data regarding changing wind direction which might have triggered a concern for their operators well-bein The Control Room operators, without corroborative evidence of a serious leak, were not concerned about the necessity to proceed with a Genera 1 Emergency declaratio No violations or deviations were identifie.
Licensee Critiques The licensee held facility critiques, a Controller exercise critique, and a critique where the conclusions of the Controller/Evaluators were formally presented to management and key player NRC personnel attended these critiques, and determined that significant NRC identified exercise deficiencies had also been identified by licensee personne.
Open Items Open Ite~s ere matters which have been discussed with the licensee which will be reviewed further by the inspector and which involves some actions on the part of the NRC or licensee or bot An Open Item disclosed during this inspection is discussed in Paragraph 6.c of this repor.
Exit Interview The inspectors held an exit interview on June 20, 1991, with the representatives denoted in Section *
The NRC Team Leader discussed the scope and findings of the inspectio The 1 i censee demonstrated a good response to a very challenging hypothetical scenario involving multiple instrument and equipment failures, real time meteorology *and a minor radiological releas One Open Item was identifie~ relative to the organization and function of the Operations S~pport Center/Maintenance Support Center (OSC/MSC), and _the tracking of inplant teams in the TS The Team Leader dtscussed options for the organization of a single facility OS The licensee was also asked if any of the information discussed during the exit interview was proprietary. The licensee responded that none of the informat_ion was proprietar Attachments:
1~ Palisades Nuclear Plant 1991 *Exercise Scope and Objectives Palisades Nuclear Plant 1991 Exercise Scenario Outline
1.0 SCOPE AND OBJECTIVES 1.1 SCOPE PALEX 91 is designed to meet exercise requirements specified in 10 CFR 50, Appendix E, Section IV.F. The Joint Public Information Center will not be activated during the exercis PALEX 91 is a utility only exercise and will not include the participation of local
governments. State personnel will participate only to the extent of answering phones and supplying information on. simulated offsite action.2 OBJECTIVES The following objectives will be demonstrated as dictated by the exercise scenari. Assessment and Classification Assess conditions which warrant classification within fifteen minutes of being provided those conditions.* Classify posed conditions in accordance with Emergency Action Levels within fifteen minutes of determination that conditions warrant classificatio.
Communications Upon making an emergency classification, complete initial notifications within fifteen minutes to the State and locals and within one hour to the NRC using the Notification For Complete subsequent notifications to the State, locals, and NRC on a routine fifteen minute basis or as mutually agree Contact other organizations such as contractors, utilities, fire or medical support within one hour of recognizing that conditions exist that warrant their assistanc Provide accurate press release information on plant conditions within one hour after occurrenc Provide updates between appropriate Emergency Response Facilities at least every 30 minute.
Radiological. Assessment and Control Collect, analyze, document and trend radiological survey dat b. Analyze plant radiological conditions and implement protective actions for site personnel in accordance with procedure **
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-- ---------- --- Prepare and brief personnel for activities required iri high radiation area Monitor, track and document radiation exposure to m~tenance, operations, an monitoring team personne Calculate dose projections based on sample results or monitor reading Identify appropriate protective action recommendation Perform core damage assessments in accordance with procedures. This objective*
will be conducted apart from the main exercise and will be scheduled to meet NRC need. Emergency Response Facilities Staff and activate onsite Emergency Response Facilities within approximately 30 minutes of an Alert classit1catio b. Staff and activate the Emergency Operations Facility within about an hour of the Site Area Emergency declaratio Update status boards at least every 30 minutes. Document field team activities in logs or on appropriate status boards. * Track and prioritize status of key in plant job. Direction and Control Command and control all Emergency Response Facilities in accordance with assigned function b. Coordinate maintenance activitie Take appropriate measures to secure emergency equipment, supplies, and suppor d. Dispatch field teams in accordance with procedure Direct and monitor field team action Transfer Command and control in accordance with the Site Emergency Pla Perform accountability within approximately 30 minutes of the Alert classificatio * Brief Emergency Response Facility staffs approximately every 30 minutes on changes in plant status, emergency classification, field team progress, and offsite actions as appropriat Effectively coordinate with state and local governments as appropriat Demonstrate reentry and recovery in accordance with procedures 6. Exercise Control Allow adequate free play for players to demonstrate their capabilitie Accurately assess performance of exercise players and controller '
NARRATIVE SUMMARY 0800 (-0030)
A. The plant is at full power at the end of core life (10.5 gwd/mtu). Bi-weekly c.ontrol rod exercising per D/W0-1 Attachment 4 is in progres Technical Specification Surveillance Procedure S0-6, "Fire Protection Sprinkler System Water Flow Switch Alarm Surveillance Test," is in progress in conjunction with Checklist 21.13, "Quarterly Wet Pipe Fire System Alarm/Flow Test Checklist." Equipment in a degraded mode:
1.. Auxiliary Feedwater Pump P-8A is tagged out of service for coupling inspection and excessive unadjustable packing leakage noted during an incomplete performance of Technical Specification Test M0-38. P-8A packing is removed and the coupling is disassembled; coupling fasteners are broken and surfaces are scoured, necessitating replacement of the coupling. The LCO of Technical Specification 3.5.2.a has been entered, with 65 hours7.523148e-4 days <br />0.0181 hours <br />1.074735e-4 weeks <br />2.47325e-5 months <br /> remaining until plant shutdown is require.
Reactor Vessel Water Level Channel LTRI-0101A is inoperable due to periodic sensor channel failure and is deenergize.d for troubleshooting. The action of Technical Specification Table 3.17.4 footnote "K" is applicabl.
Containment Radiation Monitor RIA-2321 is inoperable due to detector failure; a replacement is on order for installation during the next refueling outage. The action of Standing Order 54 Table 3.17.4 Footnote "N" is applicable. *
D. Existing Alarm Conditions:
Annunciator NC?. EK-02-25,_ "Cont Gamma RIA-2321 Fail" Exercise responders will u&e actual meteorological condition Primary and secondary chemistry 1. * Primary System Chemistry ph: Boron: 103 ppm
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--. --c. ----Dissol\\.*-oo C>xygen:* <-u.02-ppi:n - ---------- ---------------------------- * -------- Hydrogen: 25 cc/kg *
-* Total beta gamma activity: 1.45 microcuries/ml Iodine dose equivalent: 3.1 E-2 microcuries/ml Total PCS. gas activity: 4.5 microcllrieslml h;
PCS Xe-133 specific isotope activity: 410 microcuries/k.
Secondary System Chemistry Primary to secondary leak rate: 0.001 gpm Offgas Xe-133: 5.45 E-5 microcuries/ml Condenser air inleakage: 3 scfm A and B steam generator gross gamma activities: <5.6 E-6 microcuries/ml G. Primary Coolant System Leak Rate (most recent results) Identified: 0.07 gpm Unidentified: 0.034 gpm Total: 0.104 gpm H. Total Containment Leak Rate (Technical Data Book Figure 10.1): 35,942 cc/min 0830-0840 (0000-0010)
Simulator Key: IClO, IC15, or IC20 The exercise begins with control rod exercising in progress on Group 4. When the Control Operator finishes exercising Rod 39, its mechanical pressure housing begins to crack and leak (Simulator malfunction RC03). Pressurizer and VCT Level begin to decrease due to a LOCA of approximately 150 gp Expected Actions: Respond to alarms in accordance with alarm response procedure.
Conclude that PCS leakage is indicated and refer to ONP 23.1, "Primary Coolant Leak," and Emergency Plan Implementing Procedure EI- ;--- ---J. --bperafois wnrrea.n:re-thanheleak rate eiceedschai'gTug-pifmp capacity and prepare------**-
to trip the reacto *
0840-0845" (0010-0015) The mechanical pressure housing for Rod 39 fails, ejecting the Rod 39 blade assembly and drive shaft to the fully withdrawn position and increasing the size of the LOCA to 250 gpm (Simulator malfunction RC 04). The reactor trips on variable high power and the pressure spike accompanying the rod ejection increases the PCS leak rate to 350 gpm (Simulator malfunction RC 04). The core power excursion and redistribution of core radial power causes 10-15% total fuel failure due to departure from nucleate boilin D. An Auxiliary Operator who is on a stepladder outside the station battery room door directing water flow to a floor drain while testing Aow Switch WFS-2B per S0-6 and CL 21.13 via Inspector's Test Valve MV-FP 505 is startled by the commotion attending the reactor trip and loses his footing. Grasping the drain hose for support, he
~advertently pulls* it from the floor drain directing its discharge into Inverter No 2 and Preferred AC Bus Y-20 which is located directly beneath the inverter. Regaining his footing, he closes MV-FP 505 to stop the spillage and leaves the scene to report to the Control Roo Expected Actions: Perform EOP 1.0 standard post trip action.
EOP 4.0, "Loss of Coolant Accident Recovery," will be invoked and Safety Function Status Checks commence.
The Shift Supervisor assumes the Site Emergency Director (SED) position and: Classifies a "Site Are.a Emergency" based on "PCS leak rate greater than charging pump capacity." Directs a public address announcement on the situation and sounding of the emergency sire Delegates actions and notifications identified in EI-1 and marked on EI-Attachment 1, including emergency staff augmentation; personnel accountability; activation of the Operational Support Center (OSC) and Technical Support Center (TSC); dose assessment; and activation of the
. Emergency Response Data System (ERDS).
- cC-1Ji!ectS-compleiion of-the-emergency notificatforiTonns of EI-3-ana-NOD ________ _
Form 3160. Commences 15 minute notifications per EI-. I
0845-0847 (0015-0017)
A. EOP 4.0 Safety Function Status Checks continu Prior to reaching the CHP setpoint of 3. 7 psig or the S~S setpoint of 1605 psia, Preferred AC Bus Y-20 Inverter No 2 output breaker trips due to a fault on the bus (Simulator malfunction ED08). This results in the following malfunctions: Auxiliary Feed Pump P-8C trip.
Primary and secondary rod position is los.
No reactor vessel level monitoring system channels are availabl * Core exit thermocouples are los.
Right channel of SIAS is disable.
Both main steam line gamma monitors are los..
1 The only operable containment high range monitor, RIA-2322, is los LTOP channel "B" is disabled due to loss of temperature input.
Multiple Control Room safety-related instruments are los In addition to those caused by instrument failures, various CFMS inputs are lost due to CFMS Multiplexer deenergizatio Expected Actions: * Operators will elect to remain in EOP 4.0 recovery actions (invoking EOP 9.0,
- "Functional Recovery Procedure," is optional but is unnecessary) and continue Safety Function Status Check.
Utiliie steam driven auxiliary feedwater pump P-8B for immediate auxiliary feed water requirements. P-8B, however, will not suffice to reach cold shutdown by itsel (0017-0045)
A.. Left channel SIAS is received due to low pressurizer pressur *--*-----*- --------*- -
---*-*----~-----~---
- -----------~--- -*--* *----------.--------- ------. ----***---- All Primary Coolant Pumps are intentionally secured when PCS pressure lowers to 1300 psia following SIAS. This action places reliance on natural circulation for core heat removal; natural circulation will be difficult to verify due to absence of core exit
thermocouples from the PIP computer and RVLMS core exit thermocouple Containment isolation occurs due to containment high pressure (CHP).
D. As. the containment pressurizes, an unmonitored release commences from several of the various small penetration leak paths which *make up total containment leakag E. Expected Actions: Complete EOP 4.0 Safety Function Status Checks.
. Complete staffing of the OSC, MSC, and TSC and turnover responsibilit.
Manually operate right channel SIS equipment.(and P-54A spray pump when CHP is received) and stop condensate pump.
Verify containment isolation when received; however, this action will not terminate the unmonitored release. Additionally,this leaves the atmospheric steam dump valves and/or code safeties to remove PCS heat; these paths are potential (but not actual) release paths until alternate steam line monitoring is in plac.
Verify containment spray and iodine removal systems are initiated and ~tart hydrogen recombiner (0045-0100) Fission gases escape the containment at an increasing rate as the containment pressurize Expected Actions: Continue EOP 4.0 operator action.
Evacuate non-essential personnel.* Players will devise an alternate ("pre-planned" according to Standing Order 54)
method to perform off site dose estimates, i.e., either instru~ented or based on survey data (containment area monitors RIA-1805 through 1808 and RIA-2315 should be considered unavailable due to lack of EEQ qualification and degraded containment conditions).
0930-1030 (0100-0200)
x-. --EOP-~[ () operator actions coiillnue.---Pc:::s-rn:vent0ry-1osses-are*rec0vereo by--sarety- --------
injection flo B. _Containment pressure peaks at approximately 20 psi This period of time is deliberately intended to be somewhat static to permit the TSC and the Control Room time to interpret data: Possible recognition that General Emergency conditions exist due to loss of all fissiori product barrier The fact that fuel damage has occurred must be recogniz.ed to reach a decision to classify the General Emergency. The lack of qualified instrumentation to determine the extent of core damage makes it imperative to initiate post accident sampling as soon as possible. This in turn involves violating containment integrity by utilizing I&C personnel to jumper open PCS sample valves CV-1910 and CV-1911. It will take approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> for sample results to be determine _ b. - Offsite survey results will indicate only the minute presence of noble gasse Players will have difficulty determining that General Emergency conditions exist. Information will not be provided by controllers if results are not -
forthcoming. Players will be left to determine the General Emergency cfussification "ased on bits and pieces of informatio. * Loss of Preferred AC Bus Y-20 has detrimental effects on several safety functions (repair efforts will not result in clearing the fault for the duration of the exercise): Loss of both primary and secondary rod position, reactor vessel water level monitoring, radiation instruments, and core exit thermocouples make confirmation of acceptable Safety Function Status Checks (reactivity control, PCS inventory control, core heat removal, containment isolation) less than straightforward. Alternative indications do exist, but their identification should engender considerable discussion between the TSC and Control Room personnel and exercise both communication and decision makin Mitigation of the consequences of the accident depends to an extent on throttling safety injection flow as soon as possible and regaining forced cooling of the PCS, *the criteria for which are affected by instrumentation losses; this should also exercise the TSC/Control Room interfac In the absence of normal radiation instrumentation, a strategy to ensure that timely and conservatjve protective action recommendations can be made to State and local agencies will need to be develope.
Allocation of personnel resources should support subsequent cooldown and recovery
___ and attempt to compensate for instrumentation losses_where necessary. Potential
-- ----- __, __ ---- -----1temrinelude:-------------
a. _ Repair of AFW Pump P-8A (mechanical).
. _, Restoration of AFW Pump P-.8C by defeating the low suction pressure trip (electrical). Troubleshooting Preferred AC Bus Y-20 fault (electrical). Provide alternate power to PIP (electrical). Provide alternate power to right channel SIS Block Circuit (electrical). Jumper open PCS sample valves CV-1910 and CV-1911 (l&C). Manually read rod position and core exit thermocouple temperatures (I&C). Reenter PIP computer program when available (l&C). Provide alternate radiation monitoring, e.g., main steam lines (l&C and Health Physics)*
D. Expected Actions: The EOF will be declared operational and assume responsibility for protective action recommendation.
.. A General. Emergency will be declare.
Repair and compensatory measures will commenc.
Operators will make preparations for PCS cooldown with TSC guidance and will conclude that safety injection throttling criteria are met using alternate indication (0200-0215) Preparations for PCS cool~own continue. Safety Injection is throttled to stabiliz.e PCS pressure and pressurizer leve Containment high pressure alarm clears; the release from containment essentially cease C. Expected actions: Conclude with TSC concurrence that Iodine Removal System operation is no longer required; stop spray pumps, close spray valves, and close T-102 isolation valves and
.. -reset SIA *--
__ __ ___ ___________ ___
.
--- ---
~-
2; Restore PCP seal bleedoff and manually restore Component Cooling Water to and from containment per O:NP * Conclude with TSC concurrence that PCP restart criteria are met (as CEIs and LTOP 'B' are not available), and restart PCP's P-SOB and P-SO.
Revise protective actions as appropriat (0215-0300)
A. While making preparations for PCS cooldown, operators attempt to place LTOP Channel
"A" in. service by opening PORV Isolation Valve M0-1042A per SOP 1 Attachment 8~
PORV PRV-1042B opens and does not reseat (Simulator malfunction RC-19). Operators reclose M0-1042A to isolate the new PCS leakage path. Neither channel of L TOP is now availabl C. Expected Actions:
Players will conclude that deliberate PCS cooldown is not permitted without at least one channel of LTOP being in service and devise a scheme to repower LTOP Channel "B" temperature inputs from an alternate power supply. Players may also elect to proceed with cooldown with neither channel of LTOP available by invoking 10 CFR 50.54 (x)..
1130-1230 (0300-0400) LTOP Channel "B" has been retlimed to service, or no PCS cooldown begins at 75 degrees fahrenheit per hou C. Expected Actions: Continue to cooldown to meet shutdown cooling entry requirements; eliminate reactor head voiding if require.
Determine if PcS activity is acceptable for circulation outside of containment and implement appropriate radiological controls in anticipation of shutdown cooling operation.
Determine alternate appropriate PCS post-accident sample flowpaths, as a LPSI pump is unavailable after RAS procedurally until PCS is less than 70 psi (0400-00>0) Players are provided new plant conditions. Personnel not involved in rec;oyery. plan.Q.ing ____ _
teririiiiate*paitidpalion*an-aconaucTCntiques-:--- Approximately 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> have elapsed since event initiation. The fault on Y-20 has been cleared and Y-20 is reenergized; auxiliary feedwater pump P-8C is in servic *
Shutdown cooling is in service, and PCS cooldown is in progress at 60 degrees Fahrenheit per hou C. PCS leakage into containment continues at approximately 20 gpm, resulting in an
- attendant small fission product release which no longer escapes the containmen D. Recovery planning begin Expected actions: Appropriate operating instructions will be developed which will direct expeditious cooldown and depressuriz.ation while providing for continued PCS inventory losses, i.e., modifications to GOP 9 or development of a TSC/PRC approved procedur.
Containment entry, survey, and leak location and isolation plans will be developed which account for potentially high fission product exposure (1430)
Terminate exercis *-------*---------
*- *----------------------