IR 05000313/1998015

Insp Repts 50-313/98-15 & 50-368/98-15 on 980818-21.No Violations Noted.Major Areas Inspected:Licensee Performance & Capabilities During full-scale,biennial Exercise of Emergency Plan & Implementing Procedures

ML20239A308
Person / Time
Site:	Arkansas Nuclear
Issue date:	09/02/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20239A304	List: IR 05000313/1998015 ML20239A303
References
50-313-98-15, 50-368-98-15, NUDOCS 9809080388
Download: ML20239A308 (20)

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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket Nos.: 50-313 50-368 License Nos.: DPR-51 NPF-6 Report No.: 50-313/98-15 50-368/98-15 Licensee: Entergy Operations, In Facility: Arkansas Nuclear One, Units 1 and 2 Location: Junction of Hwy.'64W and Hwy. 333 South Russolville, Arkansas Dates: August 18-21,1998 Inspector (s): Gail M. Good, Senior Emergency Preparedness Analyst, Team Leader Thomas H. Andrews, Emergency Preparedness Analyst Michael P. Shannon, Senior Radiation Specialist Stephen C. Burton, Resident inspector

. Approved By: Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety Attachment: Supplemental Information 9809080388 980902 PDR ADOCK 05000313 G pm

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-2-EXECUTIVE SUMMARY Arkansas Nuclear One, Units 1 and 2 NRC Inspection Report 50-313/98-15; 50-368/98-15 A routine, announced inspection of the licensee's performance and capabilities during the full-scale, biennial exercise of the emergency plan and implementing procedures was performed. The inspection team observed activities in the control room simulator, technical support center, operational support center, and emergency operations facilit Plant Support

• Overall, performance was generally good. The control room (CR), technical support center (TSC), operational support center (OSC), and emergency operations facility (EOF) successfully implemented most essential emergency plan functions including classification, notification, and protective action recommendation * CR crew performance was good. Recognition and declaration of emergency events were timely and accurate. Notifications of offsite agencies were made within required time limits. The crew properly monitored changing plant parameters and anticipated conditions that would result in emergency classification changes. The use of three-part communications and peer checking was infrequent but did not result in performance errors. Control and transfer of operators between the CR and OSC were not well coordinated (Section P4.2).

• The TSC staff's performance was generally good. The TSC was activated in an organized and timely manner. Plant conditions were properly analyzed, and emergency classifications were coordinated with the CR and EOF. Habitability was properly monitored and maintained; however, air sampling results using high-volume air samplers were potentially non-conservative due to air sampler cartridge sealing problems. Prompt corrective actions were taken to address the generic air sampler problem. Status boards were quickly and accurately updated with current informatio Briefings were frequent but were not always effective because some personnel did not pay attention and some inputs could not be heard. An exercise weakness was identified for failure to complete initial accountability within 30 minutes of the site area emergency declaration (Section P4.3).

• The OSC staff's performance was satisfactory. The OSC was staffed and activated in a timely manner. Proper habitability surveys were frequently performed. Work priorities were clearly communicated to OSC personnel and properly monitorect by the OSC director and assistant director. Three-part communications were not used during team briefings and debriefings, and CR and TSC announcements could not be heard. An exercise weakness was identified because radiological protection practices were not properly demonstrated: (1) some briefings did not include expected radiological conditions, (2) forms functioning as radiation work permits were not completed, (3) one team did not stay together, (4) representative surveys in the work areas were not always performed, and (5) proper contamination controls, such as, checking protective clothing and handling contaminated objects without protection, were not always demonstrate Radiological areas were not always consistently posted (Section P4.4).

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The EOF staff's performance was good. Emergency classifications, offsite agency notifications, and protective action recommendations were correct and timely. The frequency.of briefings, the lack of facility priorities, and confusion about release terminology detracted from the facility's efficiency and effectiveness. Dose assessment and field team control activities _ were satisfactorily performed but tended to be -

unorganized and uncontrolled.' interactions with offsite agency representatives were candid and cooperative. Additional guidance for emergency response personnel concoming downgrading from a general emergency was needed to ensure that protective action recommendations were not relaxed until the extent of offsite contamination was determined (Section P4.5).

.. The exercise objectives were appropriate to meet emergency plan requirements. The exercise scenario was challenging from an operations standpoint but inplant radiological conditions did not challenge radiation protection personnel. Some aspects of exercise conduct and control, such as, the use of undesignated site personnel as controllers / participants, exercise preparation in the CR simulator, inconsistent data, and unrealistic /over-simulation, detracted from the training value of the exercise (Sec* ion P4.6). ,

e t Post-exercise critiques were generally well attended, thorough, and self-critica Evaluators in the CR and EOF tended to focus on positive observations. The management critique was superficial and differed from the NRC inspection team's findings in the areas of CR communications (the licensee identified this area as a strength), OSC radiation protection practices, and exercise conduct and control. Peer evaluators and offsite agency participation in the management critique made a positive contribution to an otherwise less than average critique process (Section P4.7).

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-4-IV. Plant Support P4 Staff Knowledge and Performance in Emergency Preparedness P Exercise Conduct and Scenario Description (82301 and 82302)

The licenseo conducted a full-scale, biennial emergency preparedness exercise on August 19,1998. The exercise was conducted to test major portions of the onsite (licensee) and offsite emergency response organizations, and all primary emergency response facilities. The Federal Emergency Management Agency evaluated the offsite response capabilities of the State of Arkansas and Conway, Pope, Johnson, Logan, and Yell counties. The Federal Emergency Management Agency willissue a separate repor ' The exercise scenario was run using the CR simulator in a dynamic mode. The exercise scenario began at 8 a.m. with Unit 1 at 100 percent power. Unit 2 was in an unscheduled outage during the exercise scenario. Normal week day personnel were available for duties. Initial conditions for Unit 1 had Steam Admission Valve CV-2617, steam supply to the turbine driven emergency feedwater pump from Steam Generator B, closed with trouble shooting in progres At 8:17 a.m., the CR received indications of high vibrations on Reactor Coolant Pump After investigation, the CR attributed the condition to decreasing pump oil leve Operators ordered a power reduction to facilitate tripping the affected reactor coolant pum At 8:28 a.m., Reactor Coolant Pump C tripped, operators received a vibration / loose parts alarm, and a third stage seat failed. Operators immediately noted that the seal had failed and subsequently identified the loose parts alarm at 8:40 a.m. The crew took actions to stabilize power operations for three-pump operations and to investigate the reactor coolant pump seal failur At 9 a.m., CR personnelidentified indications of a tube leak on Steam Generator The crew could not determine the exact leak rate because power changes were being made due to the loss of Reactor Coolant Pump C. The crew determined that the leak rate was greater than 10 gpm. The shift superintendent immediately declared a notification of unusual event but, upon re-evaluation, changed the classification to an alert. The alert declaration prompted the activation of the emergency response organizatio The crew tripped the reactor at 9:24 a.m. A leak occurred in the condensate header at 9:52 a.m. which forced the crew to transfer steam generator feed from the auxiliary feedwater pump to the electric emergency feedwater pum At 10:10 a.m., the electric emergency feedwater pump tripped, prompting a discussion about the use of the turbine driven emergency feedwater pump with steam supplied i

from the faulted steam generator. The crew decided to attempt high pressure injection cooling and not to use steam from the faulted steam generator. This decision l

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5-constituted a loss of all feedwater and prompted the EOF to declare a site area emergency at 10:16 a.m. Since high pressure injection cooling was ineffective, the crew switched the cooldown to the turbine driven emergency feedwater pump using steam from the faulted steam generator. This action occurred at 10:17 a.m. and created an unmonitored release path. The release was insignificant because there was no fuel damag At 10:50 a.m., the CR received indications of fuel damage and immediately determined that, with the turbine driven emergency feedwater pump running, a loss of three fission product barriers existed (a radioactive release was in progress). This information was communicated to the EOF and prompted a 10:56 a.m. general emergency declaratio At 12 noon, a fire was reported in the turbine building. The CR assessed the situation and dispatched the fire brigade. The fire was extinguished in about 15 minute Repair efforts continued until the steam supply to the turbine driven emergency feedwater pump for Steam Generator B was restored, stopping the radioactive releas The exercise was terminated at 1:48 P4.2 . Control Room (CR) Inspection Scooe (82301-03.02)

The inspectors observed and evaluated the CR shif t staff as they performed tasks in )

response to the exercise scenario conditions. These tasks incruded event detection, diagnosis, and classification; offsite agency notifications; internal and external communications; and adherence to procedures. The inspectors reviewed applicable emergency plan sections and procedures, logs, and notification forms, Observations and Findinas The crew conducted a thorough review and demonstrated a good questioning attitude of initial conditions prior to assuming the responsibilities of the watch. The crew's review led to a re-evaluation of Emergency Feedwater Pump P7A. The crew conservatively reclassified the failure as a 72-hour limiting condition for operation until further analysis of the condition could occu During the exercise, the CR crew was immediately aware of changing plant condition l The crew properly diagnosed emergency events and made the correct emergency i classification (s). Corresponding offsite agency notifications were made within regulatory !

time limits. Following the alert declaration, the crew promptly activated the I computerized notification system to call out the emergency response organization. The crew continuously reminded each other of conditions that had the potential to change the emergency classification.

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Procedural compliance was observed throughout the exercise. The shift superintendent and CR supervisor assisted each othef in execution, review, and performance of the ,

emergency operating procedures. The inspectors observed good place-keeping  ;

techniques as the operators marked executed procedures.

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l-6-Although communications between the CR and inplant personnel consistently f demonstrated strong three-part communications, internal CR communications and peer I checking were infrequent but did not result in performance errors. The inspectors noted f that the phrase "OK" was regularly used for second-part repeat backs on critical orders

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and that the third part was often not used. Peer checks were often incomplete or unable to be obtained. One example occurred when an operator requested a peer check while initiating high pressure injection cooling but was unable to obtain one. The individual resorted to self checking. A second example occurred when an operator secured the reactor coolant pump. The act of securing the pump and the corresponding communications occurred simultaneously and without a peer chec While the CR was dispatching operators to perform inplant tasks, the CR operators i demonstrated good awareness of unknown and changing inplant conditions. Because

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the conditions were changing, the OSC elected to take control of the operators to better dispatch teams and monitor exposure. This situation was centrary to what was l expected by the operators and led to some confusion. The inspectors determined that I the control and transfer of operators between the CR and OSC were not well

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coordinate l The operators displayed some confusion during solid plant operations. During high pressure injection cooling, the crew was slow to recognize the relationship between flow, pressure, and subcooling margin. Conditions were slowly forcing the crew to a continually higher pressure condition to maintain adequate subcooling margi l Additionally, while attempting to draw a pressurizer bubble upon restoration from high pressure injection cooling, the crew assumed that a bubble would form with a 40-degree temperature difference between core exit and pressurizer temperature. Saturation ;

conditions in the pressurizer were not considered until shift superintendent intercede l The crew appropriately discussed both of these observations during its self critiqu '

' Conclusions CR crew performance was good. Recognition and declaration of emergency events were timely and accurate. Notifications of offsite agencies were made within required time limits. The crew properly monitored changing plant parameters and anticipated conditions that would result in emergency classification changes. The use of three-part communications and peer checking was infrequent but did not result in performance errors. The operators displayed some confusion regarding solid plant operations which

were acknowledged during the post-exercise critique. Control and transfer of operators between the CR and OSC were not well coordinate P4.3 Technical Support Center (TSC)  ! Insoettion Scope (82301-03.03)

The inspectors observed and evaluated the TSC staff as they performed tasks necessary to respond to the exercise scenario conditions. These tasks included staffing ;

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and activation, accident assessment, personnel accountability, facility management and l control, onsite protective action decisions and implementation, internal and external

communications, assistance and support to the CR, and prioritization of mitigating i l

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i 7-actions. The inspectors reviewed applicable emergency plan sections, procedures, and logs.

l b. Observations and Findinas The TSC was activated rapidly and efficiently following the declaration of the alert. An announcement was made to the facility when the TSC director determined that a

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sufficient number of people with the appropriate expertise were present to declare the facility operational. An announcement was made when the EOF was activated and emergency direction and control were assumed by the EOF directo A shift staffing roster, using a 12-hour shift rotation, was properly developed to provide 24-hour coverage capability. The work rotation was announced in the facility. No problems were identified with the shift roster in the TS Plant conditions were properly analyzed and evaluated in a timely manner. The exercise scenario challenged exercise participants to develop alternative methods to deal with plant problems. The number of alternative methods identified during the exercise reflected good teamwork between participants.

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Status boards were quickly and accurately updated with current information. TSC personnel trended critical parameters and anticipated potential problems that would escalate the emergency. When changing plant conditions warranted an upgrade in the emergency classification, the information was appropriately discussed with the CR and EO Inplant corrective actions / repairs were properly identified and assigned to the OSC. The TSC director emphasized priorities during briefings with TSC and OSC personne l

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Priorities were reviewed frequently and modified as necessar Although center briefings were frequent and focused cn priority tasks, the following aspects of the briefings were not effective:

• To varying degrees, telephone conversations or conversations between participants continued during the briefing * Personnel who were outside of the main TSC room were not routinely included in the facility briefing * Participants entered and left the main TSC room during briefings (i.e., individuals continued performing other tasks).

• Some Individuals who provided input to the briefings did not speak loud enough to '

be heard throughout the room.

f * OSC briefings conducted by the TSC were difficult to hear and sounded i fragmented. At times, the briefings were conducted similar to the TSC briefings, with input from different personnel; however, since the microphone was not passed f

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-8-around the room, the input was not heard. In addition, there were occasions when the TSC director walked away from the microphone but continued the briefin Habitability was properly monitorpd and maintained. Area radiation surveys and contamination surveys of the TSC and surrounding areas, including the security access point, were frequently conducted. A continuous air monitor was placed in operation near the TSC entrance. This location was considered appropriate since it was near the primary entrance and in a position to take a representative sample of the breathing are High-volume air samples were also taken in this are However, while the high volume air sampler was being prepared for use, inspectors noticed that the charcoal cartridge did not fit securely in the filter head (the cartridge rattled when the filter head was shaken). This configuration permitted air flow to bypass the cartridge and resulted in a lower adsorption per amount of air flow, making the sample non-conservative. The licensee's program specified that silver-zeolite cartridges .

were used for emergency air sampling; however, due to the cost of silver-zeolite cartridges, charcoal cartridges were used during the exercise (a common practice).

This potentially generic problem was discussed with the licensee after the exercis I Licensee personnel stated that charcoal cartridges were used for routine sampling but that the cartridges were used for " flow restriction" rather than for iodine adsorption. The licensee checked filter heads stored at the radiologically controlled access point and found that 29 of 33 would not securely hold a charcoal cartridge in plac Althou@ the licensee speculated that dimensional variations between multiple vendors and different manufacturing lots for both the cartridges and the sampler filter heads had combined to create a condition where cartridges did not properly fit in the filter heads, the inspectors also noted that an internal gasket on the inlet end of the filter head was missing. The licensee obtained a new replacement unit from the warehouse and showed that the "as delivered" product from the manufacturer did not have the internal gasket. The licensee contacted its test facility and learned that the filter head used for testing and calibration purposes did have an internal gasket. The licensee appropriately issued a condition report to investigate and correct this proble During the exercise, localized evacuations were appropriately recommended for emerging conditions. However, the process of announcing the site evacuation and the subsequent accountability of onsite personnel were prolonged. Inspectors observed the following sequence:

• ,The site area emergency was declared at approximately 10:16 * khe decision to evacuate the site was made at approximately 10:25 a.m., i evidenced by preliminary notification call to security (a warning about the pending site evacuation).

• At about 10:30 a.m., the assistant TSC director called the CR to request the site evacuation announcement be made but canceled the request due to concerns l l

about a potential radiological release and the impact on evacuation route !

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The site evacuation announcement was made at about 10:40 *

At about 11:08 a.m., the TSC support superintendent obtained a list from I

security personnel that identified individuals who were not accounted fo >

Generating the list completed initial accountabilit )

In analyzing the circumstances and regulatory significance, the inspectors identified the following pertinent information:

Evaluation Criterion J.5 of NUREG-0654/ FEMA REP-1, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Nuclear Power Plants," Revision 1, specifies the need to account for all individuals onsite "at the time of the emergency" and to ascertain the names of missing individuals "within 30 minutes of the start of an emergency."

Section J.1.3 of the Arkansas Nuclear One Emergency Plan, Revision 24, stated that a plant evacuation is considered for non-essential personnel if a site area emergency or general emergency is involved. Certain extenuating conditions may preclude or delay plant evacuation. The decision is based on the action which presents the least risk to non-essential personne *

Section J.1.6.2 of the emergency plan stated that the licensee's goal is to achieve initial accountability within 30 minutes of the declaration of a plant evacuatio * Section 6.3.1.a of Procedure 1903.030, " Evacuations," Revision 22, stated that the objective of initial accountability is to ascertain the names of missing individuals within 30 minutes following the declaration of a plant evacuatio *

Section 6.3.1.d of Procedure 1903.030, stated that a list of missing individuals will be generated by the security computers and shall be available no later than 30 minutes after the decision is made to evacuate non-essential personne During the exercise, the licensee delayed the start of the evacuation because there were concerns about a potential release affecting one of the evacuation routes. The initial announcement to e'eacuate non-essential personnel from the site did not occur until 24 minutes after the site area emergency declaration. As a result, initial accountability was not started until the evacuation was underwa The inspectors recognized that conditions, such as, an ongoing security event, severe weather, toxic gas release, etc., may preclude safe evacuation and warrant a delay in a j site evacuation. However, evacuation and initial accountability were considered separate but supporting activities. Therefore, the justification for the site evacuation delay did not mean that initial accountability could be delaye )

The inspectors concluded that: (1) based on NUREG-0654, site accountability was not

- completed within 30 minutes of the site area emergency declaration (actual time was 52 minutes); (2) based on Procedure 1903.030, accountability was not completed within 30 minutes of the decision to conduct a site evacuation (actual time was 43 minutes); (3)

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-10-the 24-minute delay in making the site evacuation announcement contributed to the delay in completing initial accountability; (4) the phrase, " declaration of a site evacuation" in Procedure 1903.030 was unclear and could be interpreted to mean declaration of an emergency, a decision to conduct an evacuation, or the time of the site evacuation announcement (the licensee's interpretation); (5) the emergency plan and procedure were not consistent with NUREG-0654; and (6) the emergency plan and procedure were not internally consisten While the initial accountability was completed about 28 minutes after the announcement, the 24-minute announcement delay made the initial accountability untimely. Although actual accountability was simulated during this exercise, the demonstrated level of performance indicated that a delay in the announcement of an evacuation would subsequently delay initial accountability. Due to the potential impact on personnel safety, the failure to perform initial accountability within 30 minutes of the site area emergency declaration was identified as an exercise weakness (50-313; 368/98015-01). Conclusions The TSC staff's performance was generally good. The TSC was activated in an organized and timely manner. A shift staffing roster was developed and announced within the facility. Plant conditions were properly analyzed, and emergency classifications were coordinated with the CR and EOF. Habitability was properly monitored and maintained; however, air sampling results using high-volume air samplers were potentially non-conservative due to air sampler cartridge sealing problems. Prompt corrective actions were taken to address the generic air sampler problem. Status boards were quickly and accurately updated with current informatio Briefings were frequent but were not always effective because some personnel did not pay attention and some inputs could not be heard. An exercise weakness was identified for failure to complete initial accountability within 30 minutes of the site area emergency declaratio P4.4 Operational Sucoort Center (OSC) Inspection Scope (82301-03.05)

The inspectors observed and evaluated the OSC staff as they performed tasks in response to the exercise scenario conditions. These tasks included facility activation and staffing, emergency response team dispatch, response to CR and TSC requests, and fire brigade response. The inspectors reviewed applicable emergency plan sections, procedures, logs, checklists, and form Observations and Findinas The OSC was promptly activated and properly staffed after the alert declaratio Personnel arrived at the OSC, signed in on the OSC staffing board, and filled assigned positions in a timely manner. Position guides used by functional area supervisors provided clear guidance for OSC setup.

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-11-The OSC director demonstrated good command and control of the facility. Briefings were timely and clearly focused. Work center priorities were clearly communicated to OSC personnel and properly monitored by the OSC director. However, TSC and CR announcements could not be heard in the OSC, unless the OSC microphone was held within 4 inches of the overhead speaker The OSC plant and team status boards were properly maintained and appropriately l updated in a timely manner. OSC functional area supervisors assigned an appropriate number of experienced personnel to repair teams. Repair teams were dispatched in a timely manner using the priority listed on the team tracking board. However, three-part 4 communications were not used during team briefings and debriefing Radiological protection practices were not properly demonstrated by station workers,  ;

including radiation protection personnel. Inspectors observed the following examples: 4

. The health physics supervisor did not enter estimated work area dose rates, estimated work area derived air concentrations, and/or estimated work area contamination levels on 16 of 24 OSC Team Briefing Forms (1903.0338).

. Although the majority of observed radiological briefings provided repair teams with proper radiological information and controls needed to complete assigned tasks in a radiologically safe manner, some briefings were not thorough. For example, Team 23 (assigned to check the electromatic relief valve switch on Panel C47 in the auxiliary building) was not informed of the expected radiation, airborne, and contamination levels in the assigned work are . The radiation protection technician assigned to Team 9 allowed the team to become separated. Two mechanical maintenance workers were allowed to travel between the maintenance shop area and the job site without radiation protection personnel, even though a release was in progress. A post-exercise interview revealed that the radiation protection technician was not aware that a release was in progress. Although the health physics supervisor briefed the team on expected radiation and contamination levels in the work area, the team was not informed that a release was in progres * Electronic dosimeter settings did not accurately reflect expected radiation work area dose rates. All electronic dosimeter alarm settings were 4,000 millirem integrated dose and 50,000 millrem per hour dose rate, regardless of expected general area radiation dose rates and projected time at the job site. The general area radiation dose rates for work performed during this exercise ranged from less than 1 millirem to as high as 200 millirems. The inspectors concluded that setting the electronic dosimeters at levels greatly above the expected area radiation levels were not representative of actual radiation level * Repair teams were not given radiological levellimits to help the radiation protection technician know when to exit the area or contact radiation protection supervision for additional directions / instructions.

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Radiological surveys performed were not representative of radiological conditions in the work area. At about 10 a.m., Teams 1 and 2 obtained an air sample at the frisking area of the turbine building train bay, rather than the

" bowling alley" area of the turbine building where the leak was located. A representative general work area sample was not taken until about 11:35 a.m.,

30 minutes after Team 9 entered the area to investigate and fix the source of the lea .

Teams 1 and 2, which consisted of only radiation protection personnel, did not dress properly to enter a potentially contaminated area of the Unit 1 turbine building " bowling alley" (known to have water on the floor). Both radiation protection technicians wore latex gloves and placed a plastic bag on each foot, instead of rubber booties and shoe covers. Coveralls were not donned. The gloves and bags were not checked for holes and tears prior to donning. In addition, one team member removed a glove and transferred a portable survey instrument between the gloved and ungloved hand numerous times before exiting the area. Since significant contamination levels were present (60,000 dpm/100cm*), the portable survey instrument was potentially contaminate .

No one on Team 9 (four members, including one radiation protection technician)

checked protective clothing prior to dressing. The team was sent to the " bowling alley" area to identify and fix the source of the lea The failure to implement proper radiological protection practices was identified as an exercise weakness (50-313; 368/98015-02).

In general, radiological postings were proper; however, postings for the Unit 1 turbine building " bowling alley" area were inconsistent. The area had three entrances: (1) the south entrance was posted," Caution, Radiation Area, Contaminated Area;"(2) the north entrance was posted, " Caution, Radioactive Material, Radiation Area, Contaminated Area, Radiation Work Permit Required;" and (3) the stairway that led from the 386'

elevation was posted," Grave Danger, Radiation Area, Contaminated Area." Radiation survey results indicated that the highest radiation levels in the above area were 15 millirem per hour at 30 centimeters; whereas,10 CFR 20 defines a " Grave Danger" area as greater than 500 rads per hour at 1 meter. Inspectors concluded that inconsistent radiological postings could cause confusion about radiological conditions or requirement The inspectors observed the fire brigade's response to a fire on the 372' elevation of the Unit 1 turbine building (in the area of the Cardox system). In general, the fire brigade leader demonstrated good command and control of the fire scene. Team members wore appropriate fire protection clothing and were assigned job responsibilities in a timely manner. However, two problems were noted during the fire brigade's respons First, one of the two fire brigade members who fought the fire did not tuck the "Nomex"

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helmet hood into the jacket collar to protect the neck. Second, the other fire brigade member who fought the fire did not have the face shield down to protect the face in case of flashback.

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! l-13- Conclusions l

l The OSC staff's performance was satisfactory. The OSC was staffed and activated in a timely manner. Proper habitability surveys were frequently performed. Work priorities were clearly communicated to OSC personnel and properly monitored by the OSC director and assistant director. Plant status and team status boards were properly maintained. Three-part communications were not used during team briefings and debriefings, and CR and TSC announcements could not be heard. An exercise

weakness was identified because radiological protection practices were not properly '

demonstrated: (1) some briefings did not include expected radiological conditions, (2) forms functioning as radiation work permits were not completed, (3) one team did not stay together, (4) representative surveys in the work areas were not always performed, and (5) proper contamination controls, such as, checking protective clothing and handling contaminated objects without protection, were not always demonstrate l Radiological areas were not always consistently posted. Fire brigade response to a fire i was generally good; however, some equipment problems were note j I

P4.5 Emeraency Operations Facility (EOF) Insoection Scope (82301-03.04)

The inspectors observed the EOF's staff as they performed tasks in response to the exercise scenario. These tasks included facility activation, emergency classification, notification of state and local response agencies, development and issuance of )

protective action recommendations, dose projections, field team control, and direct interactions with offsite agency response personnel. The inspectors reviewed applicable emergency plan sections and procedures, forms, dose projections, press releases, and log Observations and Findinas The EOF was promptly staffed and activated following the 9 a.m. alert declaratio Upon arrival, personnel signed in on the staffing board, established access control (radiological and security), reviewed position-specific procedures and checklists, contacted TSC counterparts, evaluated facility habitability, started the EOF ventilation system, tested equipment, and synchronized the EOF clock. Minimum staffing was present at 9:37 a.m. The EOF was declared operational at 9:41 a.m. Emergency direction and control responsibilities (emergency classification, offsite agency notifications, and protective action recommendations) were transferred to the EOF at 9:52 a.m., following a formal turnove Although management oversight in the EOF was satisfactory, the following practices detracted from the facility's efficiency and effectiveness. First, briefings tended to be too frequent. Briefings were scheduled every half hour and lasted about 15 minutes. This meant that facility personnel had 15 minutes to prepare for the next briefing, rather than time to focus on response efforts. The briefings properly included input from key facility personnel, including offsite agency representatives. Second, facility priorities were never established nor discussed to provide direction to the EOF staff. However, TSC priorities were usually discussed during the briefings. Finally, discrepancies and

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l-14-confusion concerning release status tended to linger rather than be quickly resolved (i.e., the briefings were insufficient to clarify the release status).

The EOF promptly recognized and classified the site area and general emergencie The site area emergency was declared at 10:16 a.m., based on a loss of all feedwater (Emergency Action Level 6.11). The general emergency was declared at 10:56 a.m.,

based on a loss of all three fission product barriers (Emergency Action Level 1.7). The EOF staff meticulously tracked other emergency action levels to ensure that, when an event cleared, it did not result in an incorrect emergency classification (downgrade);

however, the practice of noting all the active emergency action levels on the offsite notification form may be confusing to offsite authoritie Offsite agency notifications were made promptly following the site area and general emergency declarations. The information on the forms was correct, and the EOF director properly reviewed and approved the forms prior to issuance. Appropriate protective action recommendations (based on plant conditions, rather than dose

. projections) were included on the general emergency notification form. The recommendations were to evacuate Zones G, R, and U (2-mile radius and 5 miles downwind), and shelter the remainder of the 10-mile emergency planning zone. Doce assessment information was properly included on regularly issued followup notification form Although dose assessment and field team control activities were satisfactorily performed, the staff tended to function in an unorganized and uncontrolled manne Inspectors observed three examples. First, discrepancies between dose projections and field team results were not aggressively pursued. A scaling factor to correct the noble gas projected data to actual data was not determined until late in the exercise. Second, dose assessment personnel had difficulty explaining and interpreting dose projections, including calculated total effective dose equivalent rates and noble gas versus iodine release rate / projection discrepancies. Third, the radiological / environmental assessment manager provided little support / direction to the dose assessment staff. Contact between the radiological / environmental assessment manager and the dose assessment staff was challenged because the dose assessment staff was physically isolated from the main EOF work area (where the manager sits). Functioning in this manner could affect protective action recommendations if the radiological releases were greate Simulated offsite doses during the exercise were well below Environmental Protection Agency protective action guide Five news releases were issued from the emurgency news center / EOF during the exercise. All of the news releases were properly reviewed by the EOF director / assistant EOF director prior to issuance. The news releases contained accurate informatio Interactions with state response team members who were stationed in the EOF were candid and cooperative. Upon arrival, state and NRC representatives were oriefed on plant conditions and prognosis. The state's input was appropriately solicited during j briefing )

l During the last hour of the exercise, the EOF staff discussed conditions to downgraca l from the general emergency. The exercise was terminated before the decision making

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-15-process was completed. However, during a post-exercise telephone discussion, the EOF director indicated that if the event had been downgraded to a site area emergency or alert, the corresponding notification form would have indicated there were no protective action recommendations. The practice of downgrading from a general emergency could incorrectly lead to a relaxation of protective action recommendations, prior to determining the extent of offsite contamination (determined in recovery / ingestion phase). Inspectors concluded that planning, training, and procedural guidance in this area could be improve . Conclusions The EOF staff's performance was good. Emergency classifications, offsite agency notifications, and protective action recommendations were correct and timely. The frequency of briefings, the lack of facility priorities, and confusion about release I terminology detracted from the facility's efficiency and effectiveness. Dose assessment {

and field team control activities were satisfactorily performed but tended to be I unorganized and uncontrolled. Interactions with offsite agency representatives were candid and cooperative. Additional guidance for emergency response personnel cor.cerning downgrading from a general emergency was needed to ensure that protective action recommendations were not relaxed until the extent of offsite contamination was determine P4.6 Scenario and Exercise Control Inspection Scope (82301 and 82302)

The inspectors evaluated the exercise to assess the challenge and realism of the scenario and exercise contro Observations and Findinos The licensee submitted the exercise objectives and scenario for NRC review on May 5 and June 12,1998, respectively. Both documents met pre-established schedule goal The exercise objectives and scenario were appropriate to meet emergency plan requirements (reference NRC letters dated June 4 and 25,1998). The exercise scenario was very challenging from an operations standpoint. Dose assessment personnel were challenged because the offsite radiological release consisted of monitored and unmonitored components. Although acceptable, the inplant radiological challenges were below averag The following aspects of exercise conduct and control detracted from the realism and training value of the exercise and were considereo areas for improvement:

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. On several occasions, CR operating crew members had to go to the simulator control area (an adjacent room) to locate a controller to get answers to questions or to obtain clarifications. This action distracted the crew members.

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The simulator was not staged with all of the material necessary to accomplish

the day-to-day business of the crew (telephone books, log books, note pads etc.). The need to ask for these materials distracted the crew members.

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. Announcements made by the TSC and EOF, including anno'incements for emergency classification / direction and control changes, were not heard in the CR, because the public address linkage was not properly established before the

. start ~of the exercise. Crew members had to ask for this informatio * The use of actual plant personnel, versus staged controllers or a control cell, as points of contact for additional support, caused confusion for non-participants

and distracted CR personnel. Controllers had to find out who was contacted and

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followup tc, ensure that requestad information was provided.

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. The objective to demonstrate the use of potassium iodide was not fully satisfied l in the TSC, due to controller intervention. The controller inject message was modified to exclude the decision process. The controller told the exercise participant to request a two-person team to enter an area where use of potassium iodide was required, rather than just providing the radiological data i that would prompt the decision. Special radiological data was prepared to drive this process since the actual scenario radiological data was too low to prompt a l' potassium iodide decision.

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• The radiation acquisition display system computer mockup was not controlled

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properly. At one point, the displayed data was an hour early and could have L prompted premature actions by the exercise participant * A field report of approximately 500 millirem /hr near the equipment hatch was reported to the TSC. The lead controller intervened to tell the participants to ignore the data because the scenario data was written assuming that the release

as on the wrong side of the building. The incorrect data caused confusio . Communications with the NRC were not realistic. The TSC emergency notification system telephone was not continuously staffed. The individual reported to the TSC but was dismissed due to center crowding. This action prompted the EOF offsite communicator to make the NRC notifications instead of the assigned facility / individua . The fire brigade did not don self-contained breathing apparatus face masks as E expected. As a result, inspectors could not determine if lens inserts were available for those who wore prescription glasses or if proper pre-use tests were performe Conclusions The exercise objectives were appropriate to meet emergency plan requirements. The exercise scenario was challenging from an operations standpoint but inplant radiological conditions did not challenge radiation protection personnel. Some aspects of exercise conduct and control, such as, the use of undesignated site personnel as i

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-17-controllers / participants, exercise preparation in the CR simulator, inconsistent data, and unrealistic /over-simulation, detracted from the training value of the exercis P4.7 Licensee Self Critiaue Insoection Scope (82301-03.13.)

The inspectors observed and evaluated the licensee's post-exercise facility critiques and the formal management critique on August 21,1998, to determine whether the process would identify and characterize weak or deficient areas in need of corrective actio Observations and Findinas

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Post-exercise facility critiques were good. The critiques were generally well attended, thorough, and self critical. Inspectors identified the following notable exceptions:

. In the CR simulator, the operators and one controller provided the only critical assessment of performance. The lead evaluator and other controller comments were primarily positiv . The critique in the TSC was very good. The critique was conducted by the lead controller, and input was provided from all participants, controllers, and evaluators. The critique identified a good mixture of positive and negative observation . Most craft personnel did not participate in the OSC critiqu . The post-exercise critique in the EOF tended to be superficial and not very self critical. ~ Many more positives than negatives were identified. Negative observations were only briefly mentioned but positive observations were discussed in detail. With the exception of the dose assessment staff, the critique was well attended, including offsite agency representatives; however, the dose assessment staff held a separate critique, without the radiological / environmental assessment manager. Conducting a separate critique further isolated the group from the EOF team (the dose assessment area was physically separated from the main EOF work area).

The licensee conducted a superficial management critique. The emergency planning manager presented 3 strengths, O weaknesses, and 6 significant areas for improvement (34 areas for improvement were identified but not discussed). There was a notable difference between the licensee's and the NRC inspection team's evaluations. The-following differences were identified. First, the hcensee determined that external and internal CR communications were a strength; however, the NRC team identified numerous examples of incomplete three-part communications. Second, only a few i examples of the OSC problems were identified by the licensee's evalut.ws. Third, only l one exercise conduct and control issue was discussed, but it was attributed to facility performance, rather than exercise conduc _ . - ._------ _ -

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' in addition to the Arkansas Nuclear One controllers and evaluators, a peer evaluation was performed by representatives from other Entergy sites (Waterford, Grand Gulf, and River Bend). Historically, the peer evaluators have identified a number of areas where performance could be improved and have added an objective element to the critique proces For the first time, the licensee invited representatives of the Arkansas State Department of Health to the management critique. Offsite agency participation in the critique process reinforced the bond between the onsite and offsite emergency organization Conclusions -

Post-exercise critiques were generally well attended, thorough, and self-critica Evaluators in the CR and EOF tended to focus on positive observations. The management critique was superficial and differed from the NRC inspection team's findings in the areas of CR communications (the licensee identified this area as a strength), OSC radiation protection practices, and exercise conduct and control. Peer evaluators and offsite agency participation in the management critique made a positive contribution to an otherwise less than average critique proces V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on August 21,1998. The licensee acknowledged the facts presented. No proprietary information was identifie A followup discussion was conducted on August 26,1998, with Mr. Randy Gresham, and others of your staff, to address a change to the inspection findings presented during the inspection exit meetin The Federal Emergency Management Agency scheduled a public meeting on August 20,1998, to discuss the preliminary exercise results. Since there was no media or public attendance at the meeting, the meeting was convened and immediately adjourned.

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ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee C. Anderson, General Manager, Plant Operations G. Ashley, Supervisor, Licensing R. Bement, Plad Manager, Unit 2 S. Cotton, Direct ( r. Training / Emergency Planning J. Crawford, Emergency Planner M. Fletcher, Emergency Planner D. Fowler, Supervisor, Quality Assurance R. Fowler, Senior Emergency Planner ,

R. Fuller, Plant Manager, Unit 1 Operations R Gresham, Manager, Emergency Planning J. Hare, Emergency Planner R. Hutchinson, Vice President D. James, Manager, Nuclear Safety S. Pyle, Licensing Specialist D.' White, Emergency Planner D. Young, Senior Emergency Planner

_OJn M. Bakarich, Manager, Emergency Preparedness, River Bend Station D. Green, Arkansas Department of Health F. Guynn, Emergency Planner, Grand Gulf Nuclear Station C. Meyer, Arkansas Department of Health C. Morgan, Manager, Emergency Preparedness, Grand Gulf Nuclear Station D. Snellings, Arkansas Department of Health NRQ K. Weaver, Resident inspector ,

LIST OF INSPECTION PROCEDURES USED IP 82301 Evaluation of Exercises at Power Reactors IP 82302 Review of Exercise Objectives and Scenarios for Power Reactors J

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, o-2-l LIST OF ITEMS OPENED

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l Ooened 50-313;368/98015-01 IFl Exercise weakness - Failure to perform initial accountability within 30 minutes of a site area emergency declaration (Section P4.3)

50-313;368/98015-02 IFl Exercise weakness - Failure to demonstrate proper -

radiological protection practices (Section P4.4)

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l LIST OF DOCUMENTS REVIEWED Emeraency Plan Imolementina Procedures 1903.010 Emergency Action Level Classification Revision 34 1903.011 Emergency Response / Notifications Revision 23 1903.030 Evacuations Revision 22 1903.033 Protective Action Guidelines for Rescue /

Repair and Damage Control Teams Revision 15 1903.035 Administration of Potassium lodine Revision 6 1903.043 Duties of the Emergency Radiation Team Revision 17 1903.065 Emergency Response Facility - TSC Revision 13 1903.066 Emergency Response Facility - OSC Revision 9 1903.067 Emergency Response Facility - EOF Revision 13 1904.011 Duties of the Dose Assessment Tearn Revision 2 1905.001 Emergency Radiological Controls Revision 11 1905.004 EOF Radiological Controls Revision 6 Other Procedures 1202.004 Overheating Revision 3 1202.006 Tube Rupture Revision 6 1202.011 High Pressure injection Cooldown Revision 3 1203.022 Reactor Coolant Pump Trip Revision 8 1203.045 Rapid Plant Shutdown Revision 2 Other Documents Arkansas Nuclear One Emergency Plan, Revision 24 Objectives for the 1998 Radiological Emergency Preparedness Exercise, dated May 5,1998 Scenario for the 1998 Radiological Emergency Preparedness Exercise, dated June 12,1998

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