IR 05000298/1998012
| ML20248J601 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/04/1998 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| 50-298-98-12, NUDOCS 9806090209 | |
| Download: ML20248J601 (5) | |
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June 4, 1998
SUBJECT:
NRC INSPECTION REPORT 50-298/98-12
Dear Mr. Horn:
Thank you for your letter of May 20,1998, in response to the exercise weakness identified in NRC Inspection Report 50-298/98-12, dated April 14,1998. We have reviewed your reply and find it responsive to the concerns raised in our inspection report. We will review the implementation of your corrective actions during a future inspection.
Sincerely, Blaine Murray, Chief (
Plant Support Branch
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Division of Reactor Safety Docket No.:
50-298 License No.: DPR-46 cc:
John R. McPhail, General Counsel Nebraska Public Power District P.O. Box 499 i
Columbus, Nebraska 68602-0499
l J. H. Swailes, Vice President of
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Nuclear Energy
' Nebraska Public Power District i
P.O. Box 98 Brownville, Nebraska 68321 9906090209 990604 PDR ADOCK 05000298 G
PDR l
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Nebraska Public Power District-2-B. L. Houston, Nuclear Licensing and Safety Manager -
Nebraska Public Power District P.O. Box 98 Brownville, Nebraska 68321 Dr. William D. Leech MidAmerican Energy 907 Walnut Street P.O. Box 657 Des Moines, Iowa 50303-0657 Mr. Ron Stoddard Lincoln Electric System 1040 O Street P.O. Box 80869 Lincoln, Nebraska 68501-0869 Randolph Wood, Director Nebraska Department of Environmental Quality P.O. Box 98922 Lincoln, Nebraska 68509-8922 Chairman Nemaha County Board of Commissioners Nemaha County Courthouse 1824 N Street Auburn, Nebraska 68305 Cheryl Rogers, LLRW Program Manager Environmental Protection Section
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I Nebraska Department of Health 301 Centennial Mall, South P.O. Box 95007 Lincoln, Nebraska 68509-5007 l
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R. A. Kucera, Department Director of Intergovemmental Cooperation Department of Natural Resources P.O. Box 176
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Nebraska Public Power District-3-
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DISTRIBUTION w/coov of licensee's letter dated May 20.1991:-
DCD (IE35)
Regional Administrator CNS Resident inspector DRS Director DRS Deputy Director
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DRP Director DRS-PSB Branch Chief (DRP/C)
Branch Chief (DRP/TSS)
Project Engineer (DRP/C)
MIS System RIV File DRS Action item File (98-G-0065)(Goines)
DOCUMENT NAME: R:\\_CNS\\CN812AK.GMG To receive copy of document, indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:PSB E
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064198 06/V98
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OFFICIAL RECORD COPY
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Nebraska Public Power District-3-
DISTRIBUTION w/ copy of licensee's letter dated May 20.1998:
0C0@35)1 Regional Administrator CNS Resident inspector -
DRS Director DRS Deputy Director DRP Director DRS-PSB
. Branch Chief (DRP/C)
Branch Chief (DRP/TSS)
Project Engineer (DRP/C)
MIS System -
RIV File.
'. DRS Action item File (98-G-0065)(Goines)
000004 DOCUMENT NAME: R:\\_CNS\\CN812AK.GMG To receive copy of document, indicate in box:"C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV;PSB
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06%98 06/V98 I
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OFFICIAL RECORD COPY (
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N~LS980074 Wj h.
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May 20,1998 a)y MAY 2 6 :
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U.S. Nuclear Regulatory Commission
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Attention: Document Control Desk ggm pf l
Washington, D.C. 20555-0001
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Gentlemen:
i Subject:
Reply to an Exercise Weakness NRC Inspection Report No. 50-298/98-12 Cooper Nuclear Station, NRC Docket 50-298, DPR-46 Reference:
1. Letter to G. (NPPD) from A. T. Howell (USNRC) dated April 14,1998, "NRC Inspection Report 50-298/98-12"
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By letter dated April 14,1998 (Reference 1), the NRC reported the results of an emergency preparedness inspection at Cooper Nuclear Station. One Exercise Weakness was identified in the referenced repon. This letter, including Attachment 1, constitutes the Nebraska Public Power District's (District) reply to the identified Exercise Weakness. The District acknowledges the Exercise Weakness and has initiated appropriate corrective actions as described in Attachment 1.
Should you have any questions concerning this matter, please contact me.
Sincerely, l
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I eP sident of Nuclear Energy
/lb Attachmen cc: Regional Administrator
USNRC - Region IV
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Senior Project Manager USNRC - NRR Project Directorate IV-1 Senior Resident Inspector USNRC NPG Distribution g
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Attachment 1
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REPLY TO IR 50-298/98-12, EXERCISE WEAKNESS l
COOPER NUCLEAR STATION, j
NRC DOCKET NO. 50-298, LICENSE DPR-46 i
During NRC inspection activities conducted from March 16,1998, through March 19,1998, one Exercise Weakness was identified. The particular weakness and the District's reply are set forth below:
Exercise Weakness The second crewfailed to adequately demonstrate the ability to effectively implement key elements of the emergencyplan. The inspectors based thisfinding on thefollowing observations:
(1)
Due to an apparentpreoccupation with event mitigation efforts and crew briefings, the shift supervisor did not effectivelyperform required emergency director responsibilities. There was insufficient supervisory oversight of those performing emergencyplan duties (shift technical engineer, radiationprotection technician, and communicator).
(2)
The crewfailed to make default protectis e action recommendations aspart of the offsite agency notificationsfollowing the general emergency declaration. The default recommendations were to evacuate a 2-mile radius /5 miles downwind andshelter the remainder of the 10-mile emergencyplanning:one. The defaultprotective action recommendations were iswed after controllerprompting.
(3)
When dose calculations indicated the need to upgrade the protective action recommendations (evacuate 5-10 miles downwind), the crew did not inform the offsite agencies in a timely manner (22 minutes elapsed).
(4)
Important changes in plant conditions were not communicated to offsite authorities in
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a timely manner. Forty-three minutes elapsed before the offsite agencies were informed of the radiological release.
(5)
The shift technical engineer recogni:ed that conditions warranted the declaration of a site area emergency but did not discuss the declaration with the emergency director.
As a resudt, the site area emergency was not declared. The shift technical engineer inappropriately instructed the communicator to inform the emergency response organi:ation (viapagers) of the site area emergency condition. The communicator completed this notification. The emergency director declared a general emergency 9 minutes later.
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Attachment 1 to NLS980074 Page 2 of 7 (6)
The communicator did not demonst> atefamiliarity with the position responsibilities:
(a) Pagers were not activatedfor the notification ofununtal event in accordance with procedures.
(b) The communicator used the wrong telephone number to contact the public affairs duty ofpcer.
(c) 1he notipcation ofunusual event offsite agency notipcations were madeprior to j,
obtaining emergency director approval (theform was not signed). As a result,
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unauthorizedinformation was commumcated to the offsite agencies.
(d) 1he communicator didnot understandaffectedsectors andhow to determine them, or how topil out the protective action recommendation / projected dose information sections ofthe notificationform. Interactions with the radiation v
protection technician contributed to the communicator 's difficulties.
(e) The communicator mistakenly thought that the NRC (both the resident inspector and headquarters operations officer) had copies of the site 's notificationform.
Information was communicated by referencingform sections (fill-in the blanks).
(7)
Inspectors also made thefollowing less sigmficant, but notable, observations:
(a) 1he pager code used at the alert classipcation level was confusing and could have restdtedin an unwanted response. 7he transmitted code indicated that an alert had been declared, emergency responsefacilities were being activated, but emergency response personnel were not to respond. Simulated conditions included hazardous conditions (winds at 95 milesper hour). The crew did create a voice-mail message (retrievable bypager holders) that explained the reasonfor the code.
(b) The emergency director didnot addan event description to the notificationform completed by the communicator. Theform only referenced an emergency action level number. As a restdt, on several occasions the communicator had toput the telephone down to refer to the emergency action levelsfor a narrative description of the event.
(c) Plant announcementforms were not completedas expected i
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Attachment I to NLS980074 Page 3 of 7 (d) Boilerplateplant announcementforms were incomplete in that there were no cautions or optional wordingfor security events / severe weather conditions.
Thefaihire of the second crew to effectively implement key elements of the emergencyplan l
was identyled as an exercise weakness (50-298/98012-02).
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Root Canae of Exercise Waaleneu While the failures ofvarious crew members contributed to the overr.ll failure, the ultimate responsibility for crew pedormance and the protection of the public health and safety lies with
the Shift Supervisor filling the role of Emergency Director. The Shift Supervisor involved in the observed drill failed to sK=r*ively poderm Emergency Director duties In January 1998, the Operations Manager introduced new expectations for the Shift Supervisor to lead Control Room briefs during emergency preparedness (EP) drills / events. The new briefing expectations were not'cleady~ understood by the Shift Supervisor on Crew"A" (the crew involved in the NRC observed drill). The NRC-evaluated performance was the first time the Crew "A" Shin Supervisor had performed on his own with the new expectations. In the past, the briefings had been performed by the Control Room Supervisor (CRS) and included discussion of detailed plant information. The Shift Supervisor believed that in' order to lead the type of briefings previously conducted by the CRS, he needed to be involved in the details of plant actions to mitigate / terminate the event. When questioned, the Shift Supervisor stated that his
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primary focus during this drill was on plant actions, not Emergency Director responsibilities.
The Shin Supervisor recognizes the importance of his Emergency Director duties; however, he -
allowed himself to lose focus during the observed drill. The responsibility for detailed plant actions lies with the CRS, with a big picture overview to be maintained by the Emergency Director. The involvement of the Shin Supervisor in plant details resulted in ineffective execution of Emergency Director responsibilities and inadequate oversight of those performing EP duties.
Although the Operations Manager had conveyed the new expectation for Shin Supervisors to conduct control room briefings, it was not his intent that the Shin Supervisor become involved in plant details and event mitigation in order to perform this function. The expectation is that the Shin Supervisor leads the briefing from a command and control standpoint; however, the CRS is responsible for providing plant details.
The root cause of this event is inadequate communication of expectations with inadequate
- emphasis on EP responsibilities. This allowed the Shift Supervisor to develop tunnel vision with respect to pedorming actions related to event mitigation and termination, rather than his duties as
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Attachment I to NLS980074 Page 4 of 7
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Evminatinn of Specific Attributen of Exercise Waakness The involvement of the Shift Supervisor in event mitigation / termination rather than Emergency Director duties directly led to several of the observations in the Exercise Weakness. The Shift Supervisor's preoccupation with the plant caused him to fail to make default protective action
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recommendations following the general emergency declaration. It also caused him to fail to l
provide direction to the Shift Communicator for making follow-up notifications in a timely manner. It resulted in the failure to complete plant announcement forms, failure to add an event -
description on the notification form, and failure to properly review the notification paperwork completed by the Shift Communicator. It also contributed to the failure to declare a site area emergency. Although the Shift Technical Engineer recognized that conditions warranted the '
declaration of a site area emergency and made an attempt to discuss with the Shift Supervisor, the Shift Supervisor became distracted and did not declare a site area emergency. This resulted in the inappropriate activation of pagers to inform the Emergency Response Organization (ERO)
of the site area emergency condition without the Emergency Director's approval.
The Station Operator was not proficient at performing the duties of Shift Communicator. He had successfully completed this function on his own two times over the past year, however, the infrequency of performing this task led to less than adequate recall during the observed drill.. The infrequent opportunities to perform this function in a training environment led to a degradation in the ability of the Shift Communicator to properly perform his duties.
The individual performing the duties of the Shift Radiological Protection (RP) Technician was not adequately prepared to perform the dose assessment function in the simulator. Incorrect information was verbalized by the Shift RP Technician which distracted the operating crew and led to a certain degree of confusion regarding protective action recommendations. Classroom
' training for Shift RP Technicians had been completed in the third quarter of 1997; however, training in the simulator environment had not been provideri.
Two of the observations in the Exercise Weakness identified untimely follow-up notifications of offsite agencies when plant conditions and protective action recommendations changed. While this is primarily attributed to a failure on the part of the Shift Supervisor, procedural guidance in this regard is also lacking. Emergency Plan Implementing Procedure (EPIP) 5.7.6 currently requires that follow-up offsite notifications be completed approximately every 60 minutes, or sooner if there is a significant change in the status of the emergency. However, as written, the procedure provides no clear definition of expected timeliness requirements. The subject follow-up notifications were completed in 22 minutes and 43 minutes, which were clearly within the 60 minute requirement, but do not meet the intent ofmaking timely notification.s.
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Attachment I to NLS980074 Page 5 of 7
The Dialogics pager system does not contain a code that will allow the declaration of an alert or (
higher classification without activating emergency facilities. This condition caused confusion on
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During the observed drill, a plant announcement was made that an alert was declared, but personnel accountability was not required. Potential confusion existed because there was no explanation why accountability was not required (i.e., weather conditions). EPIP 5.7.2 contains two boilerplate plant announcement forms, one for an emergency announcement with
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accountability and one for an emergency announcement without accountability. The forms i
contain no provisions or optional wording for security events or severe weather conditions.
Shift Supervisors identified a lack of consistency in the standards to which they are held accountable duiing EP simulator scenarios and Emergency Operating Procedure (EOP) simulator scenarios. Normally, one EP simulator scenario is performed dering each training cycle, while several EOP simulator scenarios are performed each training cycle. During a typical EOP scenario, the Shift Supervisor has been required to simply classify the event and disregard other Emergency Director functions for which he would be responsible commensurate with protecting the health and safety of the public, including the determination of protective action recommendations. This results in negative training for the Shift Supervisors.
- l Evalnadon of Generic Irnnlications The identified weaknesses could potentially be applicable to all operating crews. Therefore, the corrective actions and improvement actions discussed below are directed at all operating crews, not just the crew that failed in the observed drill. The Emergency Director performance issue is
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believed to be applicable only to the Shift Supervisors because other individuals filling the role of the Emergency Director do not have responsibility for control of the plant.
Based on previous EP Department observation of the performance of other operating crews following the change in management expectations, there was some indication ofincreased attention to plant actions on the part of other Shift Supervisors. However, in no case did it result in a failure to adequately implement their Emergency Director duties. All operating crews that have been evaluated since the subject failure have been observed for signs of exhibiting the same problems; none have been identified.
Corrective Mamanres That Have Been Taken As immediate corrective action, the involved Shift Supervisor, Station Operator, and Shift Technical Engineer were removed from watch duties by the Operations Manager.
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Attachment I to NLS980074 Page 6 of 7 l
The entire crew wss provided subsequent remediation two days later. The remediation included a classroom training session discussing applicable EPIPs as well as the failures identified during the observed drill. In addition, as part of the remediation, another EPIP drill was performed and evaluated by Operations Management. The issues identified during the NRC evaluation were not evident during this drill, but some problems were noted with dose assessment. Therefore, additional dose assessment training was provided before the affected crew members resumed watch duties.
Operations Management clarified with all Shift Supervisors expectations for leading briefs in the Control Room during EP drills / events, as well as expectations related to the execution of -
- Emergency Director responsibilities. This clarification emphasized that the duties of the Emergency Director are essential to the successful implementation of the emergency plan and that no other assigned duties should interfere with these duties.
In order to bound the issue, each operating crew participated in a tailgate session conducted by the EP Department that discussed the various issues / failures identified during the evaluated EP scenario, as well as the additional dose assessment concerns noted during the crew remediation.
Each crew member completed a worksheet which involved performing dose assessment and completion of an offsite notification form.
The involved Shift Supervisor was counseled by the EP Manager and the Operations Manager on the importance of the proper performance of his duties as Emergency Director and his legal and moral responsibility to ensure that the public health and safety is protected by properly implementing the Emergency Plan.
The involved Station Operator was counseled by the Crew Shift Supervisor on the importance of the Shift Communicator function and his responsibility to protect the health and safety of the public.
Improvement Actions That Have Been Taken In order to increase the proficiency of the Station Operators who perform as Shift Communicators, additional Shift Communicator training is being provided by assigning Station
. Operators not performing the role of Shift Communicator during EP simulator training to be on the receiving end of notification phone calls. This task requires completion of the notification paperwork and will help to keep communicators proficient in completing notification forms.
New standards have been implemented for conducting EOP simulator scenarios in order to provide consistency with expectations during EP scenarios. During EOP scenarios, the Shift Supervisor / Emergency Director is now required to ensare that appropriate EPIP paperwork is completed for initial notifications, as well as prior to making plant announcements. This will
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l Attachment I to NLS980074 Page 7 of 7 provide additional training for the Shift Supervisors that is consistent with the expectations during an actual event.
The EP Continuous improvement Plan developed at the beginning of 1998 identified an improvement item to develop refresher packages for key ERO members to keep them proficient at their ERO duties, as appropriate. This is a continuous improvement effort that is designed to improve the performance of the ERO.
Improvement Actions That Will Be Taken Additional training has been developed for Shift RP Technicians to perform dose assessment functions in support of the operating crew in the simulator environment. This training is currently in progress and will be completed by June 30,1998.
EPIP 5.7.6 will be revised to include clarification of requirements for making follow-up offsite notifications in a timely manner. It will specify that in certain situations the same time constraints should apply as for the initial notification. This action will be completed by June 30,1998.
A new pager code will be added to the Dialogics conununications system to address the type of event that occurred in the observed drill; i.e., an alert or higher classification has been declared, but emergency response facilities are not being activated. This new code will subsequently be added to EPIP 5.7.6. These actbns will be completed by July 15,1998.
EPIP 5.7.2 will be revised to add provisions for security events and severe weather conditions to the boilerplate plant announcement forms. This action will be completed by June 30,1998.
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,l ATTACHMENT 3 LIST OF MRC COMMITMENTS l
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Correspondence No:
NLS980074 i
The following table identifies those actions committed to by the District in this document.
Any other actions discussed in the submittal represent intended or planned actions by the District.
They are described to the NRC for the NRC's l information and are not regulatory commitments.
Please notify the NL&S Manager at i
Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
COMMITTED DATE COMMITMENT OR OUTAGE Additional training will be completed for Shift RP Tect.nicians to perform dose assessment functions in June 30, 1998 support of the operating crew in a simulator environment.
EPIP 5.7.6 will be revised to include clarification of
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requirements for making follow-up offsite notifications
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in a timely manner.
A new pager code will be added to the Dialogics communication system for declaring an alert or higher July 15, 1998 classification without activating emergency response facilities, and the new code will be added to EPIP 5.7.6.
EPIP 5.7.2 will be revised to add provisions for security June 30, 1998 events and severe weather conditions to the plant announcement forms.
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l PROCEDURE MUMBER 0.42 l
REVISION NUMBER 6 l
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