IR 05000315/1997013

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EP Exercise Insp Repts 50-315/97-13 & 50-316/97-13 on 970721-24.No Violations Noted.Major Areas Inspected: Evaluation of Plant Performance During Biennial Exercise of Emergency Plan & Previous EP Open Items
ML17333B001
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 08/15/1997
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17333B000 List:
References
50-315-97-13, 50-316-97-13, NUDOCS 9708220326
Download: ML17333B001 (22)


Text

U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket Nos:

Licenses No:

50-315; 50-316 DPR-58; DPR-74 Reports No:

50-31 5/9701 3(DRS); 50-31 6/9701 3(DRS)

Licensee:

Indiana Michigan Power Company Facility:

Donald C. Cook Nuclear Generating Plant, Units 1 5. 2 Location:

1 Cook Place Bridgman, MI 49106 Dates:

July 21-24, 1997 Inspectors:

James Foster, Senior Emergency Preparedness Analyst Robert Jickling, Emergency Preparedness Analyst Bruce Bartlett, Senior Resident Inspector Thomas Ploski, Emergency Response Coordinator Donald Funk, Emergency Preparedness Analyst Approved by:

James R. Creed, Chief, Plant Support Branch

Division of Reactor Safety 9708220326 9708i5 PDR ADQCK 05000$ i5

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EXECUTIVE SUMMARY D. C. Cook, Units 1 5. 2 NRC Inspection Reports 50-315/97013; 50-316/97013 This inspection included evaluation of performance during the plant's biennial exercise of the Emergency Plan and review of previous emergency preparedness open items by regional emergency preparedness inspectors and the plant resident staff.

Plant Su ort Overall performance during the 1997 Emergency Preparedness exercise demonstrated that the onsite emergency plan was adequate and that licensee personnel were capable of implementing it by correctly classifying scenario emergencies, notifying offsite agencies of the classified events, activating emergency facilities, providing protective action recommendations when warranted and taking accident mitigation actions.

Interfacility transfers of command and control of event response were orderly and timely.

Performance in the Control Room Simulator was exceptional as evidenced by strong operator communications.

"Repeat back" communications were evident.

Operator statements and actions indicated a detailed understanding of plant conditions.

The Shift Supervisor demonstrated excellent command and control of the operators.

(Section P4.1.b.1)

Overall performance in the Technical Support Center (TSC) was also strong.

Personnel were professional, and teamwork and communications were very good.

Staff were proactive and demonstrated

"heads-up" emergency mitigation activities.

(Section P4.1.b.2)

The overall performances of Operations Staging Area (OSA) management and staff were competent.

Teams were quickly assembled and dispatched from the OSA. Teams were well controlled and team exposure was properly monitored.

Communications between teams and OSA personnel were good.

However, the degree of participation by Performance Assurance personnel in emergency inplant teams had not been specified.

(Section P4.1.b.3)

Overall performance in the Emergency Operations Facility (EOF) was very able.

An attachment to the Protective Action Recommendation procedure needed clarification.

(Section P4.1.b.4)

The scenario was adequate; Exercise Control was adequate despite the identification of some controller problems.

Controllers were required to simulate some teams to preserve the scenario timeline without advising all involved facilities. (Section P4.1.b,6)

Re ort Details IV. Plant Su ort P3 Emergency Preparedness Procedures and Documentation P3.1 Review of Exercise Ob'ectives and Scenario 82302 The inspectors reviewed the 1997 exercise objectives and scenario and determined that they were acceptable.

The scenario provided an appropriate framework to support demonstration of the licensee's capabilities to implement its emergency plan.

The scenario included a large radiological release and several equipment failures.

P4 Staff Knowledge and Performance in Emergency Preparedness P4.1 1997 Evaluated Biennial Emer enc Pre aredness Exercise a.

Ins ection Sco e 82301 On July 22, 1997, the licensee conducted a biennial exercise involving partial State participation and full county participation.

The exercise was conducted to test major portions of the onsite and offsite emergency response capabilities.

The emergency response organization and emergency response facilities were activated.

The inspectors evaluated performance in the following emergency response facilities:

Control Room Simulator (CRS)

Technical Support Center (TSC)

Operations Staging Area (OSA)

Emergency Operations Facility (EOF)

The inspectors assessed licensee recognition of abnormal plant conditions,

'lassification of emergency conditions, notification of offsite agencies, development of protective action recommendations, command and control, communications, and the overall implementation of the emergency plan.

In addition, the inspectors attended the post-exercise critiques in each of the facilities and the subsequent controller critique, to evaluate the licensee's self-assessment of exercise performance.

b.

Emer enc Res onse Facilit Observations and Findin s b.1 Control Room Simulator CRS Exercise performance in the CRS was exceptionally effective.

"Repeat back" communications were consistently used by the crew.

Periodic effective briefings kept operations personnel aware of current conditions and clear, desired goal Operator statements and actions indicated a detailed understanding of developing plant conditions.

Close and effective command and control of the operators was consistently displayed by the Shift Supervisor.

Operators utilized their procedures, including abnormal operating procedure, emergency operating procedures, alarm response procedures, emergency plan implementing procedures, proficiently.

Control room shift personnel properly diagnosed reactor events at the Alert and Site Area Emergency levels, and correct emergency classifications were made in a timely manner.

Event notification message forms and verbal messages to State and the NRC were completed in an detailed and timely manner.

Communications between communicators in the CRS and TSC were dependable.

Transfer of command and control of emergency responsibilities from the Acting Site Emergency Coordinator (Shift Supervisor) to the TSC's Site Emergency Coordinator (as the TSC was ready for assumption of Command and Control of response efforts) was orderly and timely.

Initial dose projections were properly made in the CRS utilizing the Dose Assessment Program.

b.2 Technical Su ort Center TSC Overall, the TSC staff's performance was exceptional.

Personnel were professional and teamwork and communications were effective. Staff were proactive and demonstrated

"heads-up" emergency mitigation by looking ahead to events which would lead to increased plant difficulties and higher emergency classifications.

Proper public address announcements were made to plant personnel notifying them of the Alert declaration and proper emergency response instructions.

Activation of the facility was rapid.

The staff immediately signed in on the staffing status board upon arriving at the TSC and proceeded to their stations to activate their equipment and establish their communications links.

Command and control by the Technical Director was effective.

Periodic briefings were provided to the staff and included current changes in emergency conditions.

A good effort was observed when the Technical Director asked the TSC staff for any additional last minute information before ending the briefings.

Transfers of emergency-responsibility from the CRS to the TSC and to the EOF were crisp and occurred in a seamless manner.

The Technical Director ensured the staff was aware of the current status of communications and which facility was responsible for the next notifications.

TSC personnel demonstrated effective communications and teamwork.

They corrected erroneous communications by following up on them.

The Technical

Director provided frequent, comprehensive briefings.

The Site Emergency Director provided periodic phone calls to the State of Michigan and the CRS and EOF to provide and receive current emergency conditions.

The Technical Director, Site Emergency Coordinator, and facility leads were proactive in tracking plant conditions and comparing emergency action levels for possible event paths leading to emergency classification upgrades.

Tasks and priorities were identified for OSA response teams by the Technical Director and Site Emergency Coordinator and quickly communicated to the OSA and CRS.

The Emergency Response Data System was immediately activated following declaration of an Alert. Core damage calculations were performed using a computer program.

Noise levels were appropriately maintained low.

Status boards were effectively maintained and continuously updated.

The Tasks and Priorities status board effectively tracked the OSA repair teams priorities and status.

Protective Action Recommendations (PARs) for the State were proactively made to support the EOF.

Sound teamwork was demonstrated when the upgraded PARs were received by the TSC staff and did not appear correct.

The evacuation distances received from the EOF were questioned and corrected on the status board and an announcement was made to the facility staff to ensure personnel were aware of the correct information.

Protective actions ordered by the State of Michigan were effectively displayed on a wall board map by shading in areas designated for evacuation.

Both protective action status boards were appropriately maintained.

b.3 0 erations Sta in Area OSA and Emer enc Res onse Teams The overall performance of OSA management and staff was generally competent, with several examples of personnel errors.

The OSA was fully staffed and operational very quickly following the Alert declaration.

Status boards were consistently well maintained and effectively used to track personnel in each technical discipline who were available for assignment to emergency response teams.

Provisions for reviewing radiation work permits, issuing dosimetry and establishing dose limits were effective.

Simulated exposures received by response team members were effectively tracked.

Noise levels were maintained low.

The priority assigned to each emergency response team by the TSC's Technical Director and SEC was clearly understood by OSA management and communicated to OSA personnel.

Response team briefings were concise and included current information on relevant, simulated radiological conditions.

Team leaders were designated and Radiation Protection Technicians (RPTs) were assigned to response teams when appropriate.

Response teams were issued hand-held radios and were advised to transmit progress reports to OSA managemen Response teams were dispatched within approximately 20-25 minutes of TSC management's requests.

Teams were adequately debriefed and were asked to report any unexpected conditions that they encountered.

Briefings and debriefings were documented according to procedures.

OSA management remained continually aware of response teams'rogress and results.

Communications with the CRS and TSC were well-maintained and displayed activities completed.

Radiological exposure was constantly monitored by the RPT escorting each response team.

The RPT on one observed team ensured that team members checked their dosimeters and double-checked dose rates before allowing the team into an area.

The RPT on another team was proficient at simulating the Self Contained Breathing Apparatus (SCBAs).

He tracked the time, bottle locations, and simulated hearing their 5 minute alarm bells.

The initial sign-in process and the OSA holding area worked well. Personnel were donning anti-contamination clothing in preparation for being sent out.

The OSA teams were professional and focused on their emergency activities.

A potential performance anomaly was identified in relation to repair team response.

Emergency Response Team 1, 2E RHR strainer repair, was given a "highest priority" designation.

Plant Performance Assessment (PA) support was requested for this team.

PA was contacted and provided an individual. However, since this team was designated

"highest priority" there was discussion that the team would have to be sent out without waiting for PA support.

Inclusion of a representative from the PA group in an emergency response team had the potential to delay the teams dispatch.

Procedure PMP 2081 EPP.203 (Revision 4), section 4.2,

"Limitations/Precautions", paragraph 4.2.1, indicated that "Plant procedures and administrative controls used during normal operations should remain in force to the extent consistent with the timely completion of the mission."

This was interpreted to require PA involvement in this response team, as additional guidance on the degree of PA involvement was not provided.

Plant personnel were requested to clarify the desired degree of PA involvement in emergency inplant team activities.

The degree of PA involvement in emergency response teams will be an Inspection Followup Item (IFI 50-315-01; 316/97013-01).

Contaminated waste containers were not set up at either OSA access control points, although these containers were available.

This led to some confusion as to disposition of anticontamination clothing upon return of the PASS team that was identified as being contaminated.

Periodic OSA status briefings by the OSA manager did not occur.

There were side discussions but no full initial or status OSA briefings.

Later discussions with exercise controllers indicated one briefing had occurred early in the exercise.

The two access control points into the OSA were not manned continuously and were not used as sign in/out points, On one occasion a member of the PASS team briefly left the OSA without notifying the resource coordination manager, therefore the status board showed that the individual was in the area when in fact he was

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not. With personnel coming, going and working in the area, the accountability manager had difficulty keeping complete accounting of OSA personnel.

b.4 Emer enc 0 erations Facilit EOF Overall performance in the EOF was very competent.

EOF staff successfully performed required functions while the EOF's Recovery and Control Manager (R&CM) was in command and control of the licensee's event response.

Transfer of command and control from the TSC to the EOF 'was effective and smooth.

EOF staff performed their duties in an orderly and efficient manner.

They were sufficiently briefed on the event and ongoing response actions before the R&CM assumed command of the licensee's response.

Status boards, computerized displays, message forms, and public address announcements were effectively used to keep EOF staff well informed of changing plant conditions, emergency response actions, and decisions.

The General Emergency was correctly declared in a timely manner as the containment radiation level continued to increase.

The Environmental Assessment Director (EAD) correctly formulated an appropriate initial Protective Action Recommendation (PAR) which was promptly communicated to State officials. The initial PAR was appropriately revised when containment radiation levels increased significantly.

EOF staff remained well aware of what protective actions were chosen for

, implementation by the State's decision maker.

Recommended and implemented offsite protective actions were clearly displayed on several status boards within the EOF.

Earlier, EOF staff were informed when the senior State official declared a

State of Emergency and when a simulated evacuation of nonessential onsite personnel was completed.

Communications between the R&CM and his State counterpart were timely and generally provided valuable supplements to update message forms which were transmitted to State and county emergency operations centers at 15 minute intervals.

The EAD and EOF Manager provided useful inputs during many of these calls.

The R&CM used a headset to monitor and participate, as needed, in conversations between senior responders in the CRS, TSC, and OSA. The R&CM effectively interfaced with the EOF's engineering group lead to discuss accident mitigation options and strategies in support of TSC counterparts.

Protective measures staff effectively directed the licensee's field monitoring teams (FMTs) before and after the release began.

The licensee's FMTs were informed of major changes in plant conditions and emergency reclassifications.

The EAD occasionally conferred with counterparts in the State's emergency operations center and assessed State and licensee FMTs'eported measurements for consistenc The licensee identified that a controller had to intervene during PAR development for the second PAR when containment radiation levels exceeded 25,000 R/hr in the containment building.

Exercise participants were aware that a revised PAR was required, but discussion of attachment 2, "Core/Containment PAR Guidance," to the PAR procedure (PMP 2081 EPP.305, "Protective Action Recommendations"

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delayed formulation of the PAR.

Block 5 of the attachment described conditions where containment pressure exceeds or is equal to 2.9 psig, and this condition was not met, confusing decision makers.

Licensee review of this procedure for possible clarification is an Inspection Followup Item (IFI 50-315-02; 316/97013-02).

EOF staff developed three press releases which were approved by the RSCM.

No erroneous information was identified in these press releases.

b.5 Recove Discussions Recovery discussions observed in the EOF were adequate.

Procedure PMP 2081 EPP.306, Revision 1, "De-escalation or Termination of the Emergency and Recovery" was utilized to guide the discussions.

Section 4.6, "On-site Recovery Actions" broadly addressed short and long-term recovery operations, and assigned responsibility for various concerns.

This procedure did not address NRC involvement in the recovery phase.

b.6 Scenario and Exercise Control The inspectors made observations during the exercise to assess the challenge and realism of the scenario and to evaluate the control of the exercise.

The inspectors determined that the scenario was adequate to test basic emergency capabilities and demonstrate onsite exercise objectives.

The scenario was challenging with respect to how rapidly plant conditions degraded to warrant a General Emergency declaration.

However, required event classification decisions were uncomplicated and based solely on increases in containment radiation level. Simulated "current" and forecast meteorological conditions were essentially constant during the exercise and offered little challenge to those directing FMT activities or considering offsite protective actions.

The scenario did not provide sufficient timeframes for some inplant actions.

Team 3, formed to restore the diesel, was not dispatched.

The controller team was forced to simulate repair of the diesel to preserve the exercise timeline.

Discussion indicated that in the future, additional craft personnel would participate in scenario development in order to ensure more realistic inplant repair timeliness.

Control of the exercise was adequate.

Minor controller prompting and exercise control problems were identifie II II

There were several damage and control response teams that were reported to have completed assignments that were never requested, tracked, or authorized by the TSC.

When information regarding these teams reached the TSC, the staff was unaware and concerned that these teams were in the plant without the TSC tracking them.

The Site Emergency Director and Technical Director responded in an excellent manner by verifying that radiological conditions permitted access to the control room and then proceeding to have a face-to-face discussion with the Shift Supervisor regarding prioritization of response teams and the correct process to request and authorize OSA response teams.

It was subsequently determined that the licensee's exercise controllers simulated these response teams to fix needed equipment to keep the exercise timeline on track.

Controllers injected this information without informing participants in the TSC.

The omission of exercise controllers to communicate information regarding the simulated response teams to the TSC controllers will be tracked as an Inspection Followup Item (IFI 50-315-03; 316/97013-03).

EOF controllers adequately resolved confusion resulting from a statement by a CRS controller that a lightning strike caused the Unit 2 loss of offsite power to Unit 2.

No indications of thunderstorm activity were originally postulated in the scenario's

"current" and forecast weather information.

A controller properly interacted with the EOF's protective measures team when the team received a false report that a State Field Monitoring Team (FMT) had located the simulated plume.

This report was issued prematurely and significantly conflicted with reports received from the licensees'MTs.

The controller confirmed the licensee staff's initial assessment that the State FMT's report was false information.

b.7 Licensee Self-Criti ue Facility critiques including participants and controllers were held immediately after termination of the exercise.

Participants and controllers were self critical and all participants were encouraged to provide feedback.

Controllers requested written comments from the participants to augment the controllers'ocuments.

The conclusions of the controller critique mirrored the NRC evaluation team's conclusions.

The licensee's overall self-assessment was comprehensive.

C.

Overall Conclusions The exercise was a very competent demonstration of the licensee's capabilities to implement its emergency plans and procedures.

Event classifications were correct and timely. Offsite notifications and offsite protective action recommendations were correct and timely. Inplant activities were well-thought-out and well-coordinated.

Transfers of command and control were appropriately coordinated.

However, problems were observed in scenario timeline adequacy and Operations Staging Area performanc The licensee's overall self-assessment comprehensive.

PS Miscellaneous EP Issues 0 en Ins ection Followu Item No. 315/94019-02: Training modules for key incident response personnel did not contain information relative to the NRC Incident Response Program nor that of the Department of Energy.

A training session had been conducted on this information, but the training module had not had this material included.

Discussion indicated that a training module had not been finalized. This item will remain open.

Closed Ins ection Followu Item Nos. 50-315 95007-02 50-316 95007-02 During the 1995 exercise, a correctly formulated PAR was incorrectly verbally communicated to offsite officials, which resulted in temporary confusion.

The EOF manager called the State and clarified the issue, but confusion over the PAR continued for some time. Condition Report 95-115 addressed this problem, indicating that the issue was discussed at length with the parties involved.

It was noted that two full-scale drills had taken place since the error, and the error had not recurred.

During the 1997 exercise, both PARs were correctly formulated and accurately communicated to offsite officials. This item is closed.

V. IVlana ement Meetin s X.1 Exit Meetin Summa The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on July 24, 1997.

The licensee acknowledged the findings presented.

The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary.

No proprietary information was identified.

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Licensee PARTIAL LIST OF PERSONS CONTACTED e

E. Fitzpatrick, Executive Vice-President A. Blind, Site Vice President J. Sampson, Plant Manager D. Noble, Radiation Protection Superintendent J. Allard, Business Systems R. Krieger, Emergency Preparedness Coordinator K. Baker, Production Engineering J ~ Boesch, Maintenance Manager D. Noble, Radiation Protection Superintendent M. Finnissi, Engineering M. Depuyet, Nuclear Licensing D. Mihalik, Emergency Planning J. Smith, Emergency Planning J. Stubblefield, Scheduling K. Pinkowski, Performance Assessment NRC Bruce Bartlett, Senior Resident Inspector INSPECTION PROCEDURES'SED IP 82301 Evaluation of Exercises for Power Reactors IP 82302 Review of Exercise Objectives and Scenarios for Power Reactors ITEMS OPENED AND CLOSED

~Qened 50-31 5-01; 31 6/9701 3-01 50-31 5-02; 31 6/9701 3-02 50-31 5-03; 31 6/9701 3-03 Closed IFI PA involvement in emergency inplant teams.

IFI PAR procedure clarification.

IFI Controller simulation of teams; poor control.

50-315-02; 316/95007-02 IFI Confusion over the initial protective action recommendation in the 1995 Exercise.

LIST OF ACRONYMS USED AEP CFR CRS DRP DRS EAL EAD EOF EPIP ERDS ERO FMT IFI NRC OSA PA PAR PASS PDR RSCM RP RPT SCBA SEC SS TSC American Electric Power Code of Federal Regulations Control Room Simulator Division of Reactor Projects Division of Reactor Safety Emergency Action Level Environmental Assessment Director Emergency Operations Facility Emergency Plan Implementing Procedure Emergency Response Data System Emergency Response Organization Field Monitoring Team Inspection Followup Item Nuclear Regulatory Commission Operations Staging Area Performance Assessment Protective Action Recommendation Post Accident Sampling System NRC Public Document Room Recovery and Control Manager Radiation Protection Radiation Protection Technician Self Contained Breathing Apparatus Site Emergency Coordinator Shift Supervisor Technical Support Center 12