IR 05000298/1990024
| ML20044B077 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 07/03/1990 |
| From: | Powers D, Spitzberg D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20044B076 | List: |
| References | |
| 50-298-90-24, NUDOCS 9007170280 | |
| Download: ML20044B077 (9) | |
Text
-
-
-
q
,
,
- u
'
y
-
,
.,
,
.
,
-. -
,
'
m'
+
- ,
,
'!
.
,
,
APPENDIX q
e e
U.S. NUCLEAR' REGULATORY COMMISSION l
REGION IV.
]
_NRC-Inspection Report:
50-298/90-24-Operating License: 'DPR-46
Docket:~. 50-298
.
Licensee: Nebraska Public_ Power District (NPPD)
q l
P.O. Box 499'
y Columbus, Nebraska 68602-0499
e
-.
.
f; l Facility Name: Cooper Nuclear Station (CNS)
.
Inspection:At: CNS,LBrownville, Nebraska-
>
,
,
%
I Inspection Conducted: June 11-15, 1990
'a g
,
l Inspector::
.
/
M k
u, 7-J- 90
,
Dr.D.B._SpitzbfrgfEmfrgencyPreparedness Date L
,
Analyst-
'
L. Approved:?
[
- w/44/
7-3-96
'
'
ii Dr. D. A; Powers, Chief, Security.and Date.
L Emergency Preparedness Section y
_
.q LInspection Summary I
,
Inspection Conducted June 11-15,'1990 (Report 50-298/90-24)-
ni Areas Inspected:' ' Routine, unannounced inspection of the operational status of D
the_ emergency-preparedness program,_ including changes-to the emergency plan and implementingfprocedures; and review of emergency' facilities, equipment,.
. instrumentation',- and supplies..'The inspection also 1ncluded organization.and management control, training of emergency response personnel,. knowledge and
- performance of. duties, and independent audits of the-emergency preparedness c
e
'
program;-
g L
Results:. Within. the areas inspected, no violations or deviations were
.
E
- 1dentified.: Emergency response facilities and equipment had been well j
D-maintained and routine surveillances and quality assurance audits had been b
effective in:the emergency preparedness-area. rne emergency plan change l:
.inv'olving~ emergency action levels is still under review as to its effect on the lv emergency plan. This is considered an unresolved item, because it potentially involves:a' degradation,to the effectiveness of the emergency plan. The item is
- discussed in paragraph 2.
Overall knowledge and performance of emergency response personnel interviewed was good, although improvements could be made in Ll 9007170280 900711 Pi
'
li PDR. ADOCK 05000298
'~
>
.Q PDC t
,
,
m
.$
\\
.hI
.
+
,.
- n,
.-
- ,
,
.
,
,-
,
-
!<-
-
- -
s
..
s i
=
- - f.
?
s
_ jt
!
' t.V.:
..
s
'
y ty:
cu
,
,
.
m
.,:'<;.~
y.
a-
.
..
-,
'
.g.:
q
,
_
,
.
,
,
,
, <
.
e c
,
'
1 (
J.
'
t
'l
'
i t
u' '
-the use"of' emergency action level initiating events for classification purposes, and information. flow between control room ~ dose assessors and.the:
,
-emergency director. The licensee's emergency preparedness program was found to
- ;
be'in a state of' operational.-readiness.
'
- 't
,
?
h
!
k t
,
,
' ;.
.
G
'E.
%
,
.
t
- - >
j...
'
!
t l'.'
L l
'
l
\\
L;
'
ll
.
..
t
.,
s
'I h
-a..
q
b
>
4.
<
.
- i (
i L
)
1, f !
(l
,
t
k-
-
.
y%ld'j Lag
,
?in
. :.
j i1.,
y; ;
.
-3-Mgg
,,
y h'y DETAILS y
>
1.
-Persons Contacted
NPPD-
. R. L..Gardner, Acting Division Manager.of Operations
a
- R. Hayden, Emergency Preparedness Coordinator
,
/M M. Krumland, Emergency Preparedness Supervisor h.
- R. Brungardt, Manager,= Operations
- J. Kelsay,; Emergency Preparedness Specialist
>
- G. E. Smith, Quality Assurance Manager
'
3.
- G. R. Smith,-Licensing Supervisor f *,
- R. D.1 Black,40perations Supervisor
- L.' E. Bray, Regulatory Compliance Specialist a
<
.
-
- M.:A. Gillani Acting' Training: Manager
.
Y-NRC 1'
- W.? Bennett,' Senior RJsident Inspector (CNS)
'
.
?)
- G. Pick,. Resident:In;pector (CNS)-
m
- Denotes those present at the exit interview.
'
,The inspector also held discussions with other station and cor' orate q
p l
. personnel.in the areas of security, health physicsi operations, training,
,
,.and emergency response.
-2.
- Emergency Plan and-Implementing Procedures (82701-02.01)
l&
.
.
i
- The inspector. reviewed changes.to:the emergency plan and implementing-
' procedures to verify that these changes have~not adversely affected the-licensee'stoverall state of emergency preparedness. The inspector.also-F-reviewed the licensee't emergency preparedness program to verify if major
,
ort significant' changes to the emergency _ plan and implementing. procedures had been reviewed, approved,:and. distributed in accordance-with licensee's
,!
procedures _and 10 CFR 50.54(q) requirements.
j s
-
-1
.-
Since!the previous inspection.in~ February 1989, two emergency plan" changes l}
have-been implemented and a' total of 24 changes to the emergency pla'n_
l qm
- implementing procedures (EPIPs) were made.
The inspector reviewed.the-L
- dates'of submittal of-the changes-to NRC and determined compliance with
.
=the filing requirements of 10 CFR 50.54(q) and 10 CFR 50, Appendix E.V.
,.
- y
,
'The inspector reviewed Procedure 0.4, " Preparation, Review, and Approval R
of' Procedures," whicF describes development of new procedures, revisions,
!
[(,
deletions, and revit and. approval. All emergency plan revisions were
,
subjected to a review by the station operations review committee and were
'
determined not to decrease the effectiveness of the plan as specified.in 10 CFR 50.54(q).
U C r
-
. -
m g
-
J f.
,,
.,
.,-
..
i
.
y
._4
,
b:
'One emergency.' plan change submitted to NRC on September 19, 1989, involved changes to.the licensee's emergency action levels (EALs)., These changes-were-determined by the licensee to not decrease the effectiveness of the i'
plan and, therefore, were implemented on August 31, 1989, without prior
'
a NRC approval according to the provisions of 10 CFR 50.54(q).
- Subsequently, upon review by NRC, additional information was requested by letter dated March 16, 1990, concerning nine of the EAL changes to determine whether those changes decreased the effectiveness of the plan.
<v>
The licensee responded by letter dated May 1, 1990; This issue remains
?
under review by NRC and is considered-an unresolved item (298/9024-01)-
i
.pending completion of this review.
'
.No. violations or deviations were identified in the program area;
"
E 3.
Emergency Facilities,-Equipment, Instrumentation, and Supplies l
(82701-02.02)
'
h The inspector toured key emergency facilities and inspected dedicated
'
emergency. equipment to ver1fy that they were adequately maintained and to i
' determine;if changes made since the last inspection were technically
adequate, met'NRC requirements, met licensee commitments, were
appropriately incorporated into the emergercy plans and implementing
"'
'
procedures, and had no adverse effect on the licensee's emergency readiness.
'
.
S The facilities were'noted to be secure, orderly, and' stocked with adequate
- equipment and supplies. :The inspector verified that emergency radiation-
'
- monitoring equipment.were calibrated and operational and that designated
,
- inventories were in' storage as specified in EPIP 5.7.21.
The inspector
"
' reviewed documentation of the licensee's inventories of emergency
'
eq^uipment', and function tests of siren and communications equipment,.and
ufound the 11censee's activities to-have been performed at the specified
,
frequencies.
- No ~ violations or deviations were identified in this program area.
4..
Organization and Management-Control (82701-02.03)
'
Theiinspector reviewed the emergency organization and management control
,
system to determine 1f changes have been properly incorporated into the
'
emergency plan-and implementing procedures and have not adversely affected the: licensee's emergency response readiness.
The-emergency' planning department had remained unchanged since the previous inspection and consisted of two emergency preparedness
'
specialists and'an emergency preparedness coordinator all reporting to the corporate emergency preparedness supervisor.
The emergency preparedness responsibilities fall under the division manager of nuclear support. The inspector reviewed the position descriptions and education and experience
.l of.those holding the emergency preparedness positions and found the staff tolbe appropriately qualified and in accordance with the description of (
c
hM M
">
"
'
(
gi s Q;; ;M. p; s
,
'
-
.
kh..,,
-5-
]
.
w6
=
'f i -i g
u
' @n the. emergency. preparedness department contained in Section 8.3 of the
. emergency plan.'
.;
n, M'W
&
'The inspector.noted that effective July 1, 1990,'a new division manager
,
- @y for nuclear support will be assigned.
This individual has previously
!
-
$gi served as assistant plant manager and until'1982, was an emergency i
,.
p preparedness coordinator.
@]M h4j The emergency response organization (ERO) was reviewed and-it was (
q-
determined that no posi.tions or responsibilities had been deleted since
- the previous inspection.
The inspector noted that adequate staffing J 4 appeared to be assigned for each ERO position,
)
u
.
!
No violations or deviations were. identified in this program area.
>
.
- i
'
H 5.
Training (82701-02.04)
,s Th'e. inspector met with training staff personnel, reviewed training
- S 'y
'
procedures, ar.d: documentation of training of personnel assigned to the-b
'
,
emergency organization'to determine compliance-with the requirements of
>=l
'.
10 CFR 50.4?(b)(15); 10:CFR 50, Appendix E.IV.F; and the emergency plan
s s(
Jand implementing procedures.
]
kE Emergency preparedness training has been conducted by-one full. time H
instructor and has been augmented by support from the emergency planning
-
. group..The emergency preparedness-training lesson plans were reviewed and
'
'
L were found-to be well written and to cover the. initial and-refresher 6,y" training requirements for ERO positions specified in'Section 8.0 of the
,
. emergency plan. The inspector reviewed the. qualifications and experience
,(,
'
W'
of the: errergency p. eparedness instructor, and-found them to -be ladequate.
'
. m "'
s d[T * a
"
The inspector discussed the tracking of ~ emergency, preparedness training
&'
with~ cognizant; personnel and-found that the system for tracking individual
$
training in emergency preparedness is in_the process of being upgraded. A
'
printout of the ER0's training status was reviewed by the inspector and it I
p J
o
..swas noted 'that all assigned personnel had' received the required emergency e
preparedness training and that the' training was current.
The emergency l;
.
preparedness department has been responsible for' assuring that training is C
's
'
i y
adequate and current for all assigned members of the:ERO.
i sy o x; Q %.
' The inspector reviewed-documentation of emergency response drills and yn F
exercises conducted since the previous inspection to determine compliance
'
y g;,
with 10 CFR 50, Appendix'E.IV.F, Section 8.2 of the' emergency plan, and M %
,g" Surveillance Procedure 6.3.11.1, "CNS Emergency Drill and Exercise Plan."
fN Drills and exercise's were found to have been conducted at specified
.l
'
?
_ frequencies and appeared to involve appropriate. staff and target groups.
p'.lu
- Documentation of these training activities were noted to include critiques
,
l gg '
,
,
'
- < 7 and identification of weaknesses and deficiencies as required by
'
1,'
'10.CFR 50, Appendix E.IV.F.5.
- y
,
&
No violations or deviations were identified in this prcgram area.
,p
-
,\\
t t
,
,
q
0
,
,
I l6
,
lt s
YY.
$
.
Q aw.
-
.
-
-
.
- - - -
t m
,
i
, _
M '. -,
'
'
l
+
.
[
- '
.
,
.
,
-6-~
l
'
.
.
!
'
,
!$
[,[
- 6. -
Knowledge and Performance of Duties (82206)
'
- -
The inspector conducted a series of walkthrough interviews of teams.of
?
critical emergency response personnel to determine whether the basic. level o
~
,
of training, understanding of emergency preparedness, and abilities to-n implement emergency actions were adequate to' satisfy the requirements of-the emergency' plan.
The inspector interviewed.four teams.
Three-of.the-teams consisted ~of l
'
'
' control room shift personnel including a shift supervisor / emergency
)
y".
' director,: reactor operator, control.-room supervisor, shift technical i
n advisor,.and a health physics technician.
The fourth-team consisted off
"
' key emergency responders assigned to the emergency operations facility
. including an emergency director, emergency operations facility (E0F)
,J
,#'
. director,: radiological controls manager, radiological assistant, and an d
operations advisor. The interviews were held in the E0F.
'
.Each interview lasted about 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and consisted of two parts.
One part'
presented 11 questions of a technical nature pertaining.to. fundamental knowledge of the emergency plan and. implementing procedures that
decisionmakers need to know in order to perfc m their duties efficiently.
The other part of,the interview consisted of presenting three accident '
scenarios developediby'the' inspector, which were designed to prompt the-interviewees to detect, classify, notify, perform dose assessments, and l
make protective. action recommendations (PARS).
- The scenarios were developed using the technical assistance of two
,
licensee operations training instructors.
The scenarios'were also
reviewed by the senior resident inspector in advance of the-interviews.
.
Scenario.1 involved indications of an out-of-sequence control rod drop
- accident resulting'in fuel damage and a concurrent failure to fully isolate a main steam.line.
- A monitored.offsite release rate was given for
<
dose assessment purposes, but the source term did not result-in the need
- to make' protective action recommendations.
'
- Scenario 2 involved a pressurized fuel line leak during a test of an
'
emergency diesel: generator.
The leak was deemed to be not readily
- 1'solable, but was not so great as to prevent the diesel generator from performing _its_ intended-function.
This scenario took place during a
- l
. refueling outage =with one diesel generator down.for maintenance. At the
time the leak was reported, wind blew sheet; metal off of a building,
- damaging and shorting the startup and emergency transformers, resulting in m
This scenario was designed to test the interviewees' detection and classification capabilities. The scenario also was intended to test the impact on ERO personnel effectiveness following a recent licensee change in EAL 5.3.2 for a site area emergency (SAE), which occurs due to uncontrolled entry of flammable j
. material into an area where lack of access constituted a safety problem.
The third scenario involved a monitored release from the elevated release
<
point and provided necessary meteorological data to perform offsite dose
,
. - - - -
-
-
- - -
-
-
-
-
-
-
-
- -
-
-
-
-
.
c
.
>
,
'
[
J s'
- I s.
, ;
,
.
, -
,
-7-
+
-
.
..
projections and make protective action recommendations.
The teams were
!
denied use of.the computer based dose assessment programs in order to test i
their capabilities using the manual calculation. method. The release rate (1.06E9 uC1/s) was sufficient to be classified as a general emergency.
,
Overall.the teams = responded well-to the interview questions and
.
,
-demonstrated aLsound understanding of the emergency-plan.
In responding to.. the scenarios, the teams' ultimately arrived at the proper a
classifications although in._some cases, as.noted below, the accident was l
underclassified until, offsite; dose assessments were made.
The teams were
'i found to be proficient iniusing the dose assessment procedures, and made
,
_.
proper protective action recommendations based upon the 'information
p.
"
available; WhileLthe'. teams'. responses to the scenarios demonstrated an.
i
,
~
adequate level of training and proficiency in the emergency. plan and
!
' implementing procedures', the inspector made the following observations
-
- during the scenario walkthroughs.
These observations.are noted for the licensee's use for potential training improvements
.
(
- J
'In-response-to Scenario 3, involving the release of l'.06E9 uti/s of
. radioactivity, the teams did not appear to readily understand the
l significance:of a release of this magnitude. While the objective of this scenario was not classification, three of the teams initially
'
classified this event.as an alert because it met the criterion of i
EAL 1.2.4, " Elevated Release Point Radiation Monitor
'
Exceeds 1.0E7'uC1/s." The teams reclassified the event as a general
!
emergency (GE) after a determination of ~offsite doses were made.-
'
.'These teams clearly did not' initially equate this-release with a
~ breach of three fission. product barriers.
Had they done so the GE could have been called 10-15 minutes earlier in the scenario.
Further, the inspector noted no tendency:of:the: teams.to consider initiating events from the-highest possible classification.
In -response tolScenario 2, the proper classification was' reached but
none of the~ teams: invoked EAL 5.3.2, 'which refers to the uncontrolled
' entry of flammable ~ material into certain areas where lack of access
,
constitutes-a safety problem. -The teams afterward stated that the l
caveat,L" lack of access constitutes a safety problem," was confusing.
-
'
'and: difficult to? call. After the interview, two of.the teams considered:EAL 5.3.2 to be applicable-and two did not.
This caveat x
was-one of-the changes to EALs which is under review by NRC as noted in-paragraph 2Lof this report.
'-
-Communications between the dose assessors and the emergency director
,
and other members of his team were weak in establishing certain input parameters for the dose assessment determinations.
In particular, on three of the teams, there was little discussion between these
,
-
!
individuals'concerning estimated duration of release.
,
a
.-
% %, y'y
""
i
<
c3,
- f
-
U%Wl N
fl
- -l
!
+
'
- ~ RDj;
.w
g q ".e
.
j-8-
]
g%,
_
.
.
Q m
O
?
hM The' inspector discussed these and'other observations with each team g:, ;, y-following the. interviews.
,
m
>
C',
No violations -or deviations were identified in this program area.
u M,
.
>
7.: -Independent Audits (82701-02.05)
oy e
"yA The inspector examined independent and internal audit-reports prepared for:
the licensee's emergency preparedness program since the-last inspection to:
determine compliance with the requirements of 10 CFP, 50.54(t), and to
.
determine whether licensee' commitments and protective: actions were implemented in a timely manner.
The inspector also examined-the
1 i
licensee's audit-program to determine if it had a corrective action. system-
',
't, for deficiencies and weaknesses identified during drills and exercises,c j
F
'and to ascertain whether appropriate corrective actions were implemented in a timely manner.
j
-
.o.
.
g
.
The.last annual audits conducted in emergency preparedness were
$y i
Audit 89-03 performed March and April 1989 and Audit 90-03 conducted'
l
'
,yeq
- February through April 1990. The audit reports were reviewed.by the'
?
6" inspector.and were found to have been performed in accordance with
!
S'
~QAP-1900, "QA Plan for Emergency Preparedness." The audits utilized a m
lead auditor and.an emergency preparedness specialist from'another y'
,
licensed facility. The ninspector reviewed the-audit checklists developed
o
!
from the emergency; plan and-noted that they incorporated NRC findings,.
'
,
.
%,
bulletins, notices, and training interviews, and had been approved by the'
. '
L l QA manager. ; The' audits were also noted to include the; adequacy.of
'
'
y interfaces with state and local governments,- drills, exercises, and-
,
L procedures as required by 10 CFR 50.54(t). -The audits captured the
.
a p
,.
findings of routine QA surveillances performed. The' inspector' reviewed
'E $
the schedule.for surveillances to be performed in 1990 by the QA~
1
' department and;noted 18'such surveillances either completed or planned for.
-
i g
the period. Audit--findings'were found-to be characterized according to QA-
- [
procedures and followup and corrective action appropriately. reviewed and
-
m, documented ~1n a timely manner.
'
IThe inspector reviewed documentation of lead auditor training and-
-
%,'
qualifications and found that they met the requirements of Guideline-6.5 f
and. ANSI 45.223.
f gr i
,
W The 1989 audit had identified one finding and one observation, both of h.M u
.which had been closed.
The 1990 audit found one observation and one i
finding which are still being tracked by QA for closure.
The inspector i
$f([u'
- noted that the scope.and depth of the QA audits appeared to-meet the a
M g!
' requirements of 10 CFR 50.54(t).
>
,
ni ff1 No violations or deviations were identified in this program area.
I L
.,
,jr.
l
'I f,,
i
- 7
- b.
.
i O$.
-
-
._.
.
_ _ _ _ _ _ _ _
..
_ _.... -..
o ><
.
.
.
-9-8.
Observations Observations the inspector discussed with licensee representatives are discussed in paragraph 6 of this report.
The observations are not violations, deviations, unresolved items, or open items.
Observations are identified for licensee consideration as program improvement items, but have no specific regulatory requirement.
9.
Exit Interview The inspector met with licensee representatives denoted in paragraph 1 on June 15, 1990, and summarized the scope and findings of the inspection as presented in this report.
The licensee did not identify as proprietary any of the material provided to, or reviewed by, the inspector during the inspection.
.