IR 05000305/1985012

Insp Rept 50-305/85-12 on 851021-24.No Violation,Deficiency or Deviation Noted.Major Areas Inspected:Emergency Preparedness Exercise

ML20138S040
Person / Time
Site:	Kewaunee
Issue date:	11/08/1985
From:	Brown G, Phillips M, Shell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20138S035	List: IR 05000305/1985012 ML20138S034
References
50-305-85-12, NUDOCS 8511190418
Download: ML20138S040 (16)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-305/85012(DRSS)

Docket No. 50-305 License No. DPR-43 Licensee: Wisconsin Public Service Corporation Post Office Box 19002 Green Bay, WI 54307-9002 Facility Name: Kewaunee Nuclear Power Plant Inspection At: Kewaunee Site, Two Creeks, WI Inspection Conducted: October 21-24, 1985 Inspectors: W. Mh u /s/as-Team Leader Date own i u/s/af Date Approved By: Ch ef u/s/35 Emergency Preparedness Section Date Inspection Summary Inspection on October 21-24, 1985 (Report No. 50-305/85012(DRSS))

Areas Inspected: Routine, announced inspection of the Kewaunee Nuclear Power Plant emergency preparedness exercise involving observations by six NRC representatives of key functions and locations during the exercis The inspection involved 110 inspector-hours by two NRC inspectors and four consultant Results: No violations, deficiencies, or deviations were identifie PDR ADOCK 05000305 G PDR

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DETAILS 1. Persons Contacted NRC Observers-and Areas Observed D. Schultz, Control Room R. Campbell, Technical Support Center (TSC), Radiological Analysis Facility (RAF)

G. Brown, Emergency Operations Facility (E0F)

T. Lynch, Operational Support Center (OSC), Radiation Protection Office (RP0), RAF, Inplant Teams C. Hawley, Site Access Facility (SAF), Offsite Teams W. Snell, Control Room, TSC, EOF R. Nelson, SRI Wisconsin Public Service Corporation C. Giesler, Vice-President, Power Production D. Hintz, Manager, Nuclear Power C. Steinhardt, Plant Manager D. Seebart, Nuclear Emergency Preparedness Coordinator K. Evers, Assistant Manager, Plant Operations D. Ristau, Superintendent, Nuclear Services R. Pulec, Plant Technical Supervisor J. Morrison, Assistant to Manager, Nuclear Power D. Dow, Securi'y Supervisor D. Nalepka, Nuclear Licensing Projects Supervisor M. Marchi, Assistant Manager, Plant Technical Services W. Bartelme, Emergency Preparedness Specialist A. Ruege, QA Supervisor R. Zube, Nuclear Simulator Supervisor S. Gunn, Nuclear Technical Review Supervisor D. Berg, Superintendent, Plant QC T. Kenaklis, Nuclear Trainir.g Supervisor J. Holly, Nuclear Fuel Analysis Supervisor D. Braun, Operations Supervisor J. Evans, QA Auditor D. Ropson, Nuclear Licensing & Systems Superintendent D. Padula, Plant Health Physicist K. Weinhawer, Superintendent, Plant Maintenance J. Peterson, Shift Supervisor R. Draheim, Superintendent, Nuclear Design Change B. Heitzkey, Nuclear Office Supervisor P. Michalkiewicz, Nuclear Design Change & Licensing Engineer D. Will, Nuclear Design Change Supervisor D. Musarik, Operations Assessment Supervisor M. Lewis, Assistant to Nuclear Licensing & Systems Superintendent C. Smoker, Systems / Reliability Supervisor T. Vukovich, Plant Nuclear Engineer J. Giesler, Plant Nuclear Engineer

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D. Morgan, Health Physics Leadman F. Stanaszak, Nuclear Training Supervisor, Operations G. Bernhoft, Nuclear Services Supervisor C. Long, Radiation Protection Supervisor J. Suchecki, QA Program Coordinator All personnel listed above attended the exit interview on October 23, 198 . General An exercise of the licensee's Kewaunee Nuclear Power Plant Emergency Plan was conducted at the Kewaunee Plant on October 22, 1985, testing the response of the licensee to a hypothetical accident scenario resulting in a major release of radioactive effluent. This exercise was integrated with a test of the Kewaunee County, Manitowoc County, State of Wisconsin and NRC Region III Emergency Plan This was a full participation exercise for the Counties and partial for the State of Wisconsi Attachment 1 describes the Scope and Objectives of the exercise and

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Attachment 2 describes the exercise scenari . General Observations

' Procedures This exercise was conducted in accordance with 10 CFR Part 50, Appendix E requirements using the Kewaunee Emergency Plan and Emergency Plan Implementing Procedures.

( Coordination The licensee's response was coordinated, orderly and timely. If the events had been real, the actions taken by the licensee would have been sufficient to permit the State and local authorities to take appropriate actions,

' Observers

Licensee observers monitored and critiqued this exercise along with l six NRC observers and a number of Federal Emergency Management Agency (FEMA) observers. FEMA observations on the responses of State and local organizations will be provided in a separate repor l

^ ' Critique

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A critique was held with the licensee and NRC representatives on October 23, 1985, the day after the exercise. The NRC discussed the observed strengths and weaknesses during the exit intervie t In addition, a public critique was held on October 24, 1985, to present both the onsite and offsite findings by the NRC and FEMA representatives, respectively.

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4. Specific Observations Control Room Emergency Action Levels were promptly identified and evaluate Emergency classifications were promptly made. Plant emergency organization personnel and offsite agencies were notified promptly and correctly with appropriate callback verification Initial notifications for the Unusual Event and Alert were completed within 15 minutes as required. The new positions of Notifier and Communicator produced a significant improvement in the speed and efficiency of notifications and communications and allowed for a much better utilization of plant personnel than observed in previous exercise Control Room personnel were prompt in selection of procedures, evaluation of Technical Specifications, and utilization of other plant documents, such as system flow diagrams to mitigate the consequences of the accident. However, not all steps of the Emergency Operating Procedures (E0P) were followed by Control Room personnel. For example, E0P ECA-0.0, Loss of All AC Power, Paragraph 4.0, Note 2. states, "CSF status trees should be monitored for information only." Although the loss of power occurred at 1100, the utilization of the CSF status trees for information, or otherwise, did not commence until 1225, after power had been restore In two other cases procedural difficulties were noted with the E0P' The first dealt with ECA-0.0. At 1212, the Control Room Supervisor ordered actions to isolate the faulty steam generator (SG) in accordance with Step 11 which involved checking that the SG's were not fault But Step 11 could not logically be reached prior to restoring power per Step 5, and power was still lost at this tim The second case involved E0P FR-P.1, Response to Imminent Pressurized Thermal Shock Condition. Step 21 of this procedure deals with a reactor vessel soaktime of nine hours. Several different operators had different interpretations of the sequencing of tasks in relationship to the soaktime, and the restoration of injection flow, including RCS pressure contro Plant status announcements over the plant PA System were made on a timely and periodic basis with appropriate content. Multiple logkeeping practices were observed to ensure recording of all events, actions, and activities. Excellent liaison occurred between the Control Room and the Technical Support Center due primarily to the Event Operations Director. Assembly and accountability of all nonessential onsite personnel were completed within 30 minutes as require .

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Technical Support Center (TSC)/ Radiological Analysis Facility (RAF)

' The TSC manning proceeded quietly, effectively, and timely. Status boards were maintained current with accurate information. The TSC

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Director and TSC Operations Coordinator were well informed of plant l conditions. They actively pursued missing information and took positive action to prevent or minimize damage to the plant. The access to plant data in the TSC via the computer system allowed the

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TSC staff to stay abreast of changing plant conditions and actively pursue technical solutions in a timely manner. Recordkeeping of events and activities in the TSC and RAF was excellen There was a smooth shift of control from the TSC Director to the Emergency Director upon his arrival in the TSC at 1017. The transfer of command and control from the Control Room to the TSC and from the TSC to the Emergency Operations Facility (E0F) was also smoot The rearrangement of the TSC with a central table for all key TSC personnel worked very wel This arrangement allowed for continuous discussions with all personnel being involved which significantly aided in the passing of information among the staf Prior to escalation to a Site Area Emergency, a discussion of all criteria and plant conditions was held between the Emergency Director in the TSC and the Control Roo The RAF was observed to operate efficiently and effectively. Inplant dose rates were adequately monitored from the RAF as was the control of inplant teams. The relocation of the RP0 to the RAF due to the need to coordinate multiple entry team activities went smoothl The Radiological Protection Director did a good job of coordinating the activities and efforts between the TSC and E0 )erational Support Facility (OSF)/ Radiation Protection Office (RPO)/Inplant Teams The OSF was promptly staffed after the declaration of an Alert and the chain of command was quickly establishe Communications between the TSC, Control Room and RP0 were goo Status boards for tracking work requests and the event log in the OSF were kept curren The RPO took appropriate action in directing surveillance teams to monitor the containment and auxiliary building following the Alert declaration as a precautionary measure before any damage was eviden Throughout the exercise the inplant monitoring teams demonstrated proficiency in performing their required tasks. Constant monitoring was conducted and when dose rates were encountered the teams retreated and quickly discussed their approach. The monitoring teams were well briefed on the radiological considerations for their task i

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After the initial dose rate survey in the OSF, no others were observed, including either air samples or continuous air monitorin The procedures call for continuous air monitoring in the OSF, but this was not set up or simulated, and if it had been, the loss of power would have prevented its us Contamination control during the exit of the team which performed the steam generator valve task could have been improved. First, as the anti-Cs were removed, they were simply piled on the floor in close proxin<ity to the clean area. Second, because of the high radiation levels, personnel had to proceed through a clean side area to be surveyed and/or showered. However, no consideration was given in papering the route or taking other measures to minimize the potential spread of contaminatio Observation of a Post-Accident Sampling Team showed that the team was carefully briefed as to its task prior to starting operation The team was provided with adequate respiratory protection and clothing for the task. The team displayed a degree of professional competenc d. Site Access Facility (SAF)/0ffsite Monitoring Teams The SAF was quickly activated and staffed. Security responded promptly, including the establishment of roadblocks. The SAF was in operation within 10 minutes after the declaration of the Aler Teams assembled, were briefed, and inventoried equipment according to procedur Team C was observed in the field and, in general, performed wel Samples were appropriately marked, bagged, and handled with good ALARA practice However, they were unable to determine field Iodine concentrations because they did not have the proper equipmen The wrong probe had been taken from the SAF even though they had inventoried their equipment prior to departure. The only observation of an improper response came when the Controller informed the team that they were in a 20 mr/hr radiation field. The team did not report this even though they had been told to establish a position and wait for a releas All equipment used was observed to be within the prescribed calibration dates. Very good contamination control practices were employed at the SA Good ALARA practices were observed during sample deliver e. Emergency Operations Facility (EOF)

The EOF staff was well organize Each team member performed individual duties well, but also was cognizant of and supported the overall team effort. Personnel covered for each other when phones rang and assisted others in ensuring that all jobs were performe . .

Frequent and adequate briefings were provided by the Emergency Response Manager (ERM) to the E0F staf The practice of assigning communicators to eavesdrop on the ERM and record his conversations was very effective. This freed the ERM from clerical burdens and allowed him to effectively utilize his time analyzing event Recordkeeping in the EOF was excellen The Administrative and Logistics Director was able to maintain a log of events that would ,

easily facilitate the recreation of events at a later tim In general, the status boards were kept current, but several occasions were noted where the data was incorrect. For example, the data the ERM was providing the NRC Site Team at 1256 was different from that on the Operations Board, which still gave 1229 dat Communications personnel were able to effectively transfer and receive communications. The required initial notifications for both the Site Area Emergency and the General Emergency were completed within 15 minutes as required. The communicators did a good job of immediately establishing a team to perform individual notifications when the NAWAS phone became inoperabl Communications with offsite State and County agencies were observed to be goo Deployment of the offsite teams and utilization of the results from the teams were very goo Dose assessments and projections were performed based on both field readings and inplant data. Good discussion was observed concerning the validity of the various dose assessments based on the assumptions from which they were generate Although a few dose projections were made based on projected plant conditions, this area could have been strengthened. Moving the dose assessment tasks from down the hall to the main E0F room improved both communications in this area as well as the timeliness of result Protective Action Recommendations (PARS) were well thought out and were appropriate with consideration being given to plant conditions andmeteorological forecast Continuous checks were made with the offsite agencies on the progress of the implementation of the PARS. Meteorological data was updated continuously throughout the exercise. This data included forecast information as well as data from Green Ba At the conclusion of the exercise, the licensee adequately discussed deactivation from a General Emergency, eventually downgrading to an Alert. With consideration being given to the fact that the Three Mile Island Nuclear Plant would have been in an Alert for two years following their accident, it may have been more appropriate to go into a " Recovery" phase as opposed to a lower emergency leve L-..--...--_

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The EOF was not provided an adequate opportunity to input into the decision making process, especially regarding the initiation of shutdown cooling. This appeared to be the result of the licensee's determination that decisionmaking on utilization of plant equipment constituted onsite activities and therefore resides in the TS However, since the earthquake had damaged several portions of the plant, adequate offsite considerations, (e.g., system integrity, release potential, revised protective action recommendations based on release potential) should have been considered and evaluated prior to implementation. The licensee should realize that any activity that can have a bearing on core integrity, containment performance, or release potential have a direct impact on offsite consequences, and should, therefore, include EOF participation and evaluation in the decision making process prior to implementatio . Exercise Scenario and Control The scenario used during this exercise postulated an interesting sequence of events which kept the exercise players adequately involved. The use of the simulator and the IBM-PC computer for data transmission to the emergency response facilities was excellent. The controllers did a good job of controlling the scenario. There were only a few instances observed in which incorrect data was given to the players. In each of these instances, the errors were quickly corrected with actions being taken to avoid any recurrence. No instances of controller prompting were observe The only area of the scenario that should be corrected for future exercises involved the practice of issuing final concentration data to the field monitoring team players as opposed to field data. Radiological data were given to the players in concentration units (uci/cc) rather than in contamination units (dpm/100 sq.cm). Issuing the final data to the field teams precluded their need to make field calculations, and also required the SAF Counting Room personnel to invent contamination levels in order to keep the scenario realisti . Licensee Action on Previously-Identified Emergency Preparedness Weaknesses (Closed) Open Item No. 305/84-17-01: Notifications and Staff Augmentatio The licensee had made both personnel and procedural changes that should ensure that the offsite agencies would be notified within 15 minutes and still maintain timely onsite shift augmentatio A member of the security force will respond to the Control Room immediately following the declaration of an emergency and will assume the position of Notifier to first make offsite notifications and then shift augmentation calls via the pager system. The Notifier will be relieved by a Communicator whom the licensee has committed can respond within 30 minutes. The STA will make the NRC red phone notificatio During the exercise, all notifications and shift augmentations were prompt and were expeditiously implemented within the required time This item is close <

. . (Closed) Open Item No. 305/84-17-02: Staff Augmentation. Procedural changes had been made to make better utilization of the pager syste Instead of individual sequential-phone calls, emergency personnel augmentation will rely on activating the pagers as a means to notify more people in a shorter time period. In addition, the process of processing personnel through the SAF, had been streamline These actions should provide for a faster augmentation of the onsite emergency response facilities. This item is close . Exit Interview The inspectors held an exit interview the day after the exercise on October 23, 1985, with the representatives denoted in Section 1. The NRC Tean. Leader discussed the scope and findings of the inspection. The licensee was also asked if any of the information discussed during the exit was proprietary. The licensee responded that none of the information was proprietar Attachment 1: Kewaunee Exercise Scope and Objectives Attachment 2: Kewaunee Exercise Scenario Outline

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OBJECTIVES FOR THE 1985 KEWAUNEE NUCLEAR POWER PLANT EMERGENCY PREPAREDNESS EXERCISE In order to demonstrate the emergency preparedness of the Kewaunee Nuclear Power Plant and the Wisconsin Public Service Corporation, an emergency preparedness exercise will be conducted. The primary objective of the exercise is to demon-strate the ability to implement the Kewaunee Nuclear Power Plant Emergency Plan which has been developed to ensure that an adequate level of preparedness exists at the Kewaunee Nuclear Power Plant. Specific objectives designed to further define the main objective are as follows: General Demonstrate that communications links exist during declared emergencies between the Divisions of Emergency Government from the St. ate of Wisconsin,

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the Counties of Kewaunee and Manitowoc and the Kewaunee Nuclear Power Plant to the extent of a General Emergenc Accident Assessment

! Demonstrate the ability of personnel to recognize an emergency initiating event and properly characterize and classify the emergency according to ,

the pre-established Emergency Action Levels.

I Provide a simulated release of radioactive material in sufficient quantity I to require the declaration of a general emergenc i Demonstrate that environmental monitoring teams can be dispatched and deployed in a timely manner; that communications are adequate; that radio-

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logical monitoring equipment is functional; that simulated data are i

accurately obtained and transmitted to appropriate emergency response facilitie !

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DR55 . Demonstrate that personnel can perform radiological accident assessment '

and dose projection techniques by using plant monitor readings, environ-mental data, and meteorological parameter !

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, Demonstrate that obtained radiological data results can be used in con-i junction with Protective Action Guides to make the appropriate protective i action recomendations to off-site agencies as well as take appropriate protective action on-sit f

C. Activation of Emergency Response Organization and Facilities Demonstrate familiarity with the emergency response organization and ,

associated responsibilities and duties of plant and corporate personnel, t Demonstrate the ability of plant and corporate personnel to activate i and staff the emergency response facilities as appropriate for the f

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existing emergency class and to transfer functional responsibilities to the appropriate emergency response facilities when escalating or f de-escalating to a different emergency clas j i Demonstrate and test the adequacy and effectiveness of emergency response facilities operations, equipment, and comunications network ,

D. Notification and Communication

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l Demonstrate that plant and corporate notifications and alerting can be l

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updating is verified and logge I Demonstrate effective and proper procedures for notifying, and reporting to the Federal, State, local, and private organization ,

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DRS5 . Demonstrate the ability to communicate with monitoring teams, rescue parties, and other emergency response personnel as neede . Demonstrate that messages are transmitted in an accurate _and timely manner; that messages are properly logged; that status boards are accurately maintained and updated; that appropriate emergency response personnel are briefed and update . Demonstrate that the transfer of information can be coordinated between the Emergency Operations Facility (EOF) and the Joint Public Information Center (JPIC); that the JPIC is capable of handling public information releases and public inquiries; that designated WPS Corporate Communica-tions personnel are implementing their plans and procedure On-Site Actions Demonstrate the ability to account for and evacuate part of the Plant's non-essential staff off the site, Demonstrate the ability to provide adequate radiation protection services, such as personnel dosimetry and personnel monitoring, and the ability to perform radiological surveys of the plant interior and site under emergency condition . Demonstrate the ability to perform high level radiation and contamination area entrie . Demonstrate proper procedures for emergency security measures, including control of access / egress and personnel accountability at the plant sit Demonstrate proficiency in the assessment of plant conditions and radiological consequences to the plant, as well as the general public,

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DRS5 including total population dose calculations and determining appropriate ;

procedures to be used in response to and recovery from an emergenc . Demonstrate the establishment of recovery operation . Demonstrate the capability for self-critique and the ability to identify areas needing improvement in order to make future appropriate plan and procedural change ,

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CONFIDENTIAL: DETAILED KEEUNEE EXERCISE SCENARIO

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INITIAL CONDITIONS ,

Reactor Power 100%

Days of Operation 192 days Reactor Coolant System Activity 205 uc/cc

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1A Steam Generator Activity 1.1 uc/cc 18 Steam Generator Activity 0.011 uc/cc Primary to Secondacy Leakage 200 gal / day E 0.40

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OCTOBER 22, 1985 0730 - Tremor felt at Plant

- Seismic Record Equipment Operating Alarm (47001-45)

- Horizontal event light lit in relay room - lights reset

- Sequential Event Recorder (SER) points 330 and 331 low level vertical trigge University of Wisconsin - Milwaukee Seismic Center confirms a shock has occurred North of Rockford, Illinoi UNUSUAL EVENT-------

0930 - Physical shaking of building is fel Seismic Recording Equipment Operating Alarm (47001-45).

- Horizontal event and low itght lit in relay room - Ilghts rese ,

- SER points 332 and 333, medium level trigge University of Wisconsin - Milwaukee Seismic Center confirms and earth quake has occurred North of Rockford, Illinois, almost to Belof t, Wisconsin, with a 6 Richter scale readin The Condensate Storage Tanks (CST) level begins to decrease due to ruptured seam ...

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ALERT -------

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S!12T CONFIDENTIAL: DETAILED KEWAUNEE EXERCISE SCENARIO

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40 %

1000 - CST Lo-Lo Level alarm (47007-45)

1035 - Roving Security Officer reports steam coming from two safety valves on 18 Steam Generator 1055 - 1A Diesel Generator (DG) Engine Abnormal Alarm (47029-21)

- 18 Diesel Generator (DG) Engine Abnormal Alarm (47031-25)

- 1A DG Starting Air <200 psig at local panel

- 1B DG Starting Air <200 psig at local panel

- 1A DG Startup Air reservoir welded seam ruptured

- IB DG Startup Air reservoir welded seam ruptured 1100 - Earthquake occurs

- Seismic Record Equipment Operating Alarm (47001-45)

- Horizontal event light lit - lights reset

- Lo and Hi lights lit - lights reset

- SER points 334 and 335, high level trigger

- Reactor Trip

- Turbine Trip

- Loss of off-site power

- 345 KV lines (R304 and Q303) and 138 KV lines (Y-51 and F-84) lost

- UW-Madison Seismic Center confirms one earthquake has occurred about 15 miles South and West of Kewaunee, and about 8 miles due west of the Plant. The Richter measurement was A Main Steam Isolation Valve shut

- One safety valve on IA SG opens fully

- Turbine driven Aux. FW Pump f ails to start - Major turbine failure

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SITE EMERGENCY-------

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S112T CONFIDENTIAL: DETAILED KEWAUNEE EXERCISE SCENARIO 1130 - Fuel failure escalates due to the earthquake

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1200 - Seismic Recording Equipment Operating Alarm (47001-45)

- Horizontal event lights lit

- Lo and Hi level lights lit

- SER points 334 and 335, high level trigger

- Large multiple tube rupture in IA SG

- Reactor Coolant Pump seals fail due to loss of cooling

- Fuel failure escalates further due to the earthquake

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GENERAL EMERGENCY-------

1215 - 345 KV line Q-303 returned - energized Tertiary Aux. and Reserve Au Transformer 1300 - 1A SG Safety Valve shut

- (Time approximate) Off-site. plume is determined 1345 - (Time approximate) Reactor Coolant System cooldown on RHR 1400 - (Time approximate) Off-site contaminated area is secured 1430 - Exercise is terminated

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