IR 05000277/1985036

Insp Repts 50-277/85-36 & 50-278/85-34 on 851016-18.No Violation or Deviation Noted.Major Areas Inspected:Emergency Preparedness & Observation of partial-scale Annual Emergency Exercise Conducted on 851017

ML20138D559
Person / Time
Site:	Peach Bottom
Issue date:	12/06/1985
From:	Harpster T, Hawxhurst J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20138D535	List: IR 05000277/1985036 ML20138D532
References
50-277-85-36, 50-278-85-34, NUDOCS 8512130252
Download: ML20138D559 (11)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /34 Docket N /278 License N DPR-44/56 Priority -

Category C Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Peach Bottom Atomic Power Station Inspection At: Delta, Pennsylvania Inspection Conducted: October 16-18, 1985 Inspector: We 41 % vt-J'/ J. HgVxhurst, EP Specialist 5!8I

/ dite Team Leader NRC Team Members: G. Arthur, Jr., PNL (Sonalysts)

R. A. Fox, PNL (Battelle)

J. Beall, Region I J. Grant, Region I C. Gordon, Region I J. Martin, PNL (Battelle)

T. L. Harpster, Region I T. Johnson, Senior Resident Inspector H. Williams, Resident Inspector J. Rogers, Region I M. Gaitanis, NRC/HQ

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Approved by: 47' /l is [')

T. L. fiarpster/) Chief jdfte Emergency Pred/ redness Section Inspection Summary:

Inspection on October 16-18, 1985 (Report Nos. 50-277/85-36 and 50-278/85-34)

Areas Inspected: Routine announced emergency preparedness inspection and observation of the partial-scale annual emergency exercise conducted on October 17, 1985. The inspection involved 315 inspector-hours by a team of twelve NRC Region I and NRC Contractor personne gj21 0252 851209 G DOCK 05000277 PDR

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Results: The licensee's emergency response actions for this exercise were adequate to provide protective measures for the health and safety of the public. However, several significant areas of concern were identified that may lead to a degraded response capability and caused confusion during the exercise. The areas related to training of emergency response personnel and classification of emergencies (Emergency Action Levels) are identified as unresolve .

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DETAILS 1.0 Persons Contacted The following licensee management representatives attended the exit meeting on October 18, 198 * B. Logue, Superintendent, Nuclear Services

• D. Smith, Superintendent, Operations

• T. Ullrich, Superintendent, Nuclear Generation

• A. Hilsmeir, Manager, Radiation Protection

• R. Kankus, Director, Emergency Planning

• J. Tucker, Site Emergency Planning Coordinator

• W. Knapp, Corporate Health Physics Supervisor In addition, the inspectors interviewed or observed the actions of numerous licensee personne .0 Licensee Action on previous Inspection Findings 2.1 (Closed) 50-277/83-33-07; 50-278/83-31-06: Consider possible ground level release pathways in the dose assessment calculation; for example, an unmonitored release from a steam-line break acciden The inspector reviewed PBAPS EP-316 and found it had been modified to include potential ground level release pathway .0 Emergency Exercise The Peach Bottom Atomic Power Station partial-scale exercise was conducted on October 17, 1985, from 8:00 a.m. until 6:45 p.m. which included a one hour dela .1 Exercise Activities Pre-Exercise Activities Prior to the emergency exercise, NRC Region I representatives had telephone discussions with licensee representatives to review the scope and content of the exercise scenari In addition, NRC observers attended a licensee briefing for licensee controllers and observers on October 16, 1985, and participated in the discussion of emergency response actions expected during the various phases of the scenario. The licensee stated that certain emergency response activities would be simulated and that controllers would intercede in activities to prevent disturbing normal plant operation . - . -

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4 Exercise Scenario The exercise scenario included the following events:

• Units 2 and 3 are operating normally;

• High pressure oxygen bottle rockets into Unit #3 condenser, plant trips;

MSIV closure, high pressure coolant injection (HPIC) and reactor core isolation cooling (RCIC) initiate on low-low reactor level;

• .0perator opens a safety / relief valve (SRV) and the dis-charge fails the torus wall in the vicinity of the SRV line support pad;

Torus level drops and,HPCI and RCIC pumps trip out due to flooding;

Fire in 480V EMER and control room annunciator indicates power failure for the ECCS trips units;

. Reactor level drops to -270 inches and reactor pressure is reduced to 960 psig (fuel failure);

Major release of radioactivity thru standby gas treatment system (SGTS) and out the main stack;

Torus water level recovers and minimizes releases out of primary containment; and

Plant.is stabilized and recovery actions [ postulated] are discussed [ objective outside scope of scenario].

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The above events resulted in the activation of the licensee's emergency facilities, Actual Event (Delay of Exercise)

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At approximately 9:21 during the PBAPS emergency exercise, an actual plant trip occurred. The Peach Bottom Unit #2 plant was operating close to full power when an automatic plant trip occurred on low reactor water level (0 inches); consequently,.

the emergency exercise was delayed and resumed approximately an

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hour later at 10:30 The details of the actual incident are provided in combined Inspection Report Nos. 50-277/85-29 and 50-278/85-33.

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T 3.2 Exercise Observation During the conduct of the licensee's exercise, NRC team members made detailed observations of the activation and augmentation of the emergency organization; activation of emergency response facilities; and actions of emergency response personnel during the operation of the emergency response facilities. The follow-ing activities were observed:

(1) Detection, classification, and assessment of the scenario events; (2) Direction and coordination of the emergency response; (3) Notification of licensee personnel and offsite agencies of pertinent information; (4) Communications /information flow, and record keeping;

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(5) Assessment and projection of radiological (dose) data and j consideration of protective action; t

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(6) Provision of in plant radiation protection;

(7) Performance of offsite and in plant radiological surveys; (8) Performance of technical support; (9) Performance of security; l

(10) Performance of repair and corrective actions; (11) Response to a Medical Emergency (Contaminated / Injured

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individual)

(12) Activation and operation of EOF;.

(13) Fire Team and offsite fire assistance; (14) Assembly and accountability of personnel; (15) Management of Accident recovery operations; and

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(16) Dissemination of public information, The NRC team noted that the licensee's activation and aug-mentation of the emergency organization; activation of the emergency response facilities; and actions and use of the facilities were generally consistent with their emergency response plan and implementing procedures. The team also noted the following areas where the licensee's activities were efficiently implemented:

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• The objectives and scenario package were submitted to the NRC in a timely manner for review. Appropriate changes were made to reflect NRC concern * The actual UE (10/17, 9:21 a.m.) was well handled and it appears all applicable emergency procedures were followe * Communications always included, "This is a Drill."

• The controller briefing in the TSC was exceptionally well

done.

• The OSC and the Auxiliary OSC were activated and fully

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staffed in a timely manne * The OSC Coordinator exercised good control of the OSC and provided good briefings to repair team * The survey team entry to the Torus Room was carefully planned and coordinated by the Aux. OSC coordinator and his

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staf Entry routes were carefully selected and survey

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instruments were properly chosen.

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The local fire department arrived promptly (~23 minutes).

l Security was waiting for them and provided an escort and dosimetry. It took less than one minute for both trucks to gain site access.

l l * The offsite monitoring teams were well trained in the use of their equipment and the drivers / monitors were familiar with the local area (EPZ).

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Initial and ongoing dose projections appeared to be

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accurate and corroborated field measurements.

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The Muddy Run Media Center was well staffed, organized and actively worked to compensate for faulty tele-communication equipmen *

Corporate HQ staff was highly motivate The following are the NRC Team findings in areas requiring

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additional licensee attention. Most of these findings were also identified by the licensee as part of their critiqu Certain practices related to control room activities that could have contributed to a degraded response were:

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The players did not recognize that the air release pathway

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through primary containment was mitigated after 3:30 p.m.

i by raising the water level in the toros room above the

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torus break. In addition, it is not clear that personnel in the CR were aware of the torus room height safety available for flooding prior to effecting ECCS rooms;

• The control room operator manually lifted a safety / relief valve before the UE and never entered this information into the drill log; and,

The status board in the control room was at times not updated in a timely manner and sometimes contained wrong information. Similar problems occurred during the previous exercise at Peach Botto These concerns are collectively designated as an Open Item (50-277/85-36-01; 50-278/85-34-01) and will be reviewed during a subsequent NRC:RI Inspectio Certain practices conducted within the Technical Support Center and prior to the exercise (training provided to key emergency personnel, and responsibilities designated in the PBAPS Emergency Plan, Section 5.2) contributed to a degraded response. The significant areas of concern and some details relating to the exercise are described belo *

A lack of overall direction for approximately 45 minutes, along with the form and content of EP-101, the event classification procedure, led to a delay in coupling plant information with offsite concerns and taking appropriate actions to mitigate the consequences offsit *

It was not clear after observing key management positions in the PBAPS emergency organization (both TSC and EOF) who was in charge. At ~1132 the Emergency Director (ED)

announced that the EOF had been activated at 1116. The SEC assumed his position at 1205. Between 1116 to 1205, it is not clear which manager was in charge of the site emergency response. Furthermore, these responsibilities were not clearly defined in the Emergency Pla *

The NRC guidelines for declaring a general emergency based on plant conditions degrading and of potential significant releases expected offsite were not followed; consequently, PARS were issued only after a significant amount of radio-activity was release *

At ~1105 the Emergency Director was aware of the potential for an atmospheric release of radioactivit Primary containment had been breached and reactor water level continued to drop after ~1115. Offsite radiation levels were measuraaie and increasing and a General Emergency was not declared until 1306. Protective action recommendations followed at ~131 .

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These concerns are identified as an Unresolved Item (50-277/85-36-02; 50-278/85-34-02) and will be reviewed after

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completion as stated in the Confirmatory Action Letter dated November 5, 198 In addition, several other activities conducted in the TSC that

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could have contributed to the degraded response were:

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• The Emergency Director (ED) made frequent reports on particular aspects of the incidents during the exercise; however, specific problem areas were not always clearly identified and priorities established (i.e., LOCA - 6" reactor coolant leak);

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Technical requests were made for PECo headquarters support (flood of ECCS) and no priorities established. Technicat

information provided was not effectively used (leave pumps [HPCI and RCIC] running after 1500 to cover break in torus);

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• Technical personnel trended torus level but did not associate the level stabilizing at approximately 5.5 ft.

as a possibility that the crack in the torus was at that height; and

TSC status boards did not list all important happenings, and different parameters and systems status were an hour or more behind actual' status.

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Offsite notification for the " Site Area Emergency" was not

] completed (in that the message confirmation was delayed) in 15

minute These concerns are collectively designated as an Open Item

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(50-277/85-36-03; 50-278/85-34-03) and will be reviewed during a subsequent NRC:RI Inspection.

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' Certain practices related to operational support or in plant activities that could have contributed to a degraded response were:

There were overlapping announcements on the Gai-Tronics syste It was difficult to understand some exercise messages. There were also some " horseplay" announcements that added to the heavy PA traffic;

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The First-Aid / Rescue Team decided to simulate dressing up in protective clothing and left the Aux. OSC without a ( controller (scenario);

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• The OSC was very crowded at times (e.g.,14 people in

~200 ft.2);

• The Aux. OSC was generally overcrowded while the adjacent HP assembly area was not. At one point, an important briefing was conducted in the corridors outside the Au OSC, which was a high noise area, instead of using the quieter, more spacious HP assembly area;

• The ability to perform post-accident sampling and analysis (objectives D.7 and D.9) was not demonstrated; and

• Contamination control of the injured, contaminated person was not adequately implemented (Repeat).

These concerns are collectively designed as an Open Item (50-277/85-36-04; 50-278/85-34-04) and will be reviewed during a subsequent NRC:RI Inspectio Certain activities in the E0F that contributed to a degraded exercise response were:

• During the period from 1116 to 1205, it was not clear which manager was in charge of the offsite emergency response. At 1116 the TSC announced, " EOF activated" and not until 1205 did the Site Emergency Coordinator assume responsibility;

Protective action recommendations (PARS) were not thoroughly '

considered because of the restrictive approach dictated by the existing procedures;

• The input to PARS were also not adequately considered in accordance with EP-317 prior to making these recommenda-tions to the states;

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• EALs and the event classification procedure do not adequately provide guidance for event classification based on projected plant conditions and releases (i.e., IEIN, 83-28);

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• One news release, #5, was poorly writte These concerns are identified as an Unresolved Item (50-277/85-36-05; 50-278/85-34-05) and will be reviewed after completion as stated in the Confirmatory Action Letter dated i November 5, 198 ,

Certain practices related to the dose assessment capability that l

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could have contributed to a degraded response were:

Recommendation of KI for emergency workers was not given l

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• The assumption built into reporting dose rate results of TCS cartridges on a two hour basis was unclear te dose assessment and field team personnel; and

• Based upon the elevated Iodine dose rates at the site boundary, EOF habitability should have been suspect (scenario).

These concerns are collectively designated as an Open Item (50-277/85-36-06; 50-278/85-34-06) and will be reviewed during subsequent NRC:RI Inspectio Activities and practices related to offsite monitoring teams were generally good. Although the communications system has improved, it is the weakest link in the offsite monitoring program. This led to several trips to high places and tele-phones just to communicate with the EOF. The inefficiency is understandable due to the complex terrai There were several repeat problems from last year's exercise, identified in the report. The most significant item dealing with " Classification of Emergencies" which had previously resulted in a violation (Combined Inspection Nos. 50-277/84-33 and 50-278/84-27) and will be open as an unresolved item at this time (50-277/85-36-07; 50-278/85-34-07). This area will be reviewed after completion as stated in the Confirmatory Action Letter dated November 5, 198 .3 Exercise Critique The NRC team attended the licensee's post-exercise critique during which strengths and improvement items were presented by the evaluators. In addition, the NRC team leader was given a written copy of the licensee's finding .0 Exit Meeting and NRC Critique Following the licensee's self-critique, the NRC team met with licensee representatives listed in Section 1 of this report. The team leader summarized the observations made during the exercise and discussed the arets described in Section 2 of this repor The licensee was informed that no violations were observed. In addition, the licensee was informed that certain activities and practices. required a closer inspection and clarification and that a meeting to discuss the details and performance in this emergency preparedness exercise would be held in the futur .

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Licensee management acknowledged the findings and indicated that appro-priate action would be taken regarding the areas identified as being in need of additional licensee attentio At no time during this inspection did the inspectors provide any written information to the license .

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