IR 05000331/1986015

Insp Rept 50-331/86-15 on 861117-19.No Violations,Deviations or Deficiencies Noted.Major Areas Inspected:Emergency Preparedness Exercise.Exercise Scenario & Objectives Encl

ML20211Q330
Person / Time
Site:	Duane Arnold
Issue date:	12/08/1986
From:	Foster J, Ploski T, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20211Q278	List: IR 05000331/1986015 ML20211Q274
References
50-331-86-15, NUDOCS 8612190242
Download: ML20211Q330 (21)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-331/86015(DRSS)

Docket No. 50-331 License No. DPR-49 Licensee: Iowa Electric Light and Power Company IE Towers Post Office Box 351 Cedar Rapids, IA 52406 Facility Name: Duane Arnold Energy Center Inspection At: Duane Arnold Site, Palo, Iowa Inspection Conducted: Nover;ber 17-19, 1986 Inspectors: Tho s # /cf8 Date fjmuhN '

James E. Foster M f[#8 Date ( L)M<$>.M Approved By: WiTl'iam Snell, Chief /s/4dsf-Emergency Preparedness Section Date Inspection Summary Inspection on November 17-19, 1986 (Report No. 50-331/86015(DRSS))

Areas Inspected: Routine, announced inspection of the Duane Arnold Energy Center emergency preparedness exercise, involving observations by two NRC inspectors and six consultants of key fu;ictions and locations during the exercis Results: No violations, deficiencies, or deviations were identifie %}g 2

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DETAILS 1. Persons Contacted NRC Observers and Areas Observed

- Ploski, Control Room (CR), Technical Support Center (TSC),

Operational Support Center (OSC)

D. Schultz, CR T. Essig, TSC, OSC, Inplant Teams J. Foster, Offsite Monitoring Teams T. Sanquist, TSC, Emergency Operations Facility (E0F)

G. Stoetzel, EOF K. McBride, E0F V. Ramsdell, E0F Licensee Personnel and Exercise Roles R. McGaughy, Manager - Nuclear Generation, Corporate Management Representative D. Mineck, Plant Superintendent, Observer R. Merlino, CR Controller K.' Huber, CR Controller R. Anderson, CR Coordinator M. O' Hare, TSC Controller M. Hunemueller, TSC Controller R. Hannen, Emergency Coordinator G. Van Middlesworth, TSC Supervisor H. Giorgio, Radiation Protection Coordinator B. Thomas, OSC Controller

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J. Lischinsky, OSC Controller B. Liemkuehler, OSC Controller P. swafford, OSC Supervisor

D. Keast, Offsite Monitoring Team Controller

! W. Nodean, E0F Controller i C. Losinger, EOF Controller i

D. Wilson, Emergency Response and Recovery Director R. Lessly, Emergency Support Manager M. McDermott, Technical and Engineering Support Supervisor

! L. Vavra, Emergency News Center (ENC) Controller l D. Langer, Emergency Public Information Manager l N. Dougherty, ENC Staff l C. Meigs, ENC Staff D. Hingtgen, Emergency Planning Coordinator, Observer S. Marshall, Emergency Planner, Observer l G. Harper, Emergency Planner, Observer l B. Sligh, Emergency Planner, Observer E. Matthews, Manager, Quality Assurance J. West, Quality Assurance Engineer The above personnel attended the exit interview on November 19, 198 l

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2. Licensee Action on Previously Identified Items (Closed) Open Item No. 50-331/86016-02: Loss of communications with offsite monitoring teams during the previous exercis During the 1986 exercise, communications between the teams and the TSC or EOF were adequate, with the exception of minor comniunications problems (dead spots) which were easily corrected by switching to alternate radio channel This item is close (Closed) Open Item No. 50-331/86016-03: Failure of offsite teams to follow EPIPs 2.6 and 3.2 during the previous exercise. During the 1986 exercise, team members demonstrated adequate familiarity with these procedures and adhered to procedural guidance. Relevant procedures were available in their vehicles for reference during the exercise. This item is close . General An evening exercise of the licensee's Duane Arnold Energy Center and Corporate Emergency Plans was conducted on November 18, 1986, testing the integrated responses of the licensee, State, and local government organizations to a simulated emergency involving a radiological release to the environment. The attachments to this report describe the exercise scope and objectives and the sequence of scenario events. This exercise was a full participation exercise for the State of Iowa and for Linn and Benton Countie . General Observations Procedures l The exercise was conducted in accordance with 10 CFR Part 50, l Appendix E requirements using the emergency plans and implementing procedures of the licensee's onsite and offsite emergency

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organization Coordination The licensee's response was coordinated, orderly, and timely. If scenario events had been real, actions taken by the licensee would have been sufficient to permit State and local authorities to take appropriate actions to protect public health and safet Observers Licensee observers monitored and critiqued this exercise along with eight NRC observers and a number of observers representing the Federal Emergency Management Agency (FEMA). FEMA observations on the responses of State and local government officials will be provided in a separate repor _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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. Critiques Licensee observers critiqued the performances of the licensee's exercise participants immediately following the exercise, and presented their preliminary findings on November 19, 1986 to an audience comprised of key participants, observers, controllers, and the inspectors. This was followed by the NRC inspection team's presentation of its preliminary exercise findings. In addition, a public critique was held during the evening of November 19, 1986, to present the preliminary findings of both the NRC and FEMA exercise observation team . Specific Observations Control Room (CR)

The Operations Shift Supervisor (OSS) quickly and correctly declared an Unusual Event and an Alert based on changing plant condition The associated initial notifications to Linn and Benton Counties, the State of Iowa, and the NRC Headquarters Duty Officer were accurate, completed in a timely manner, and adequately docuruented. CR supervisory personnel kept the on-call Emergency Coordinator (EC)

and Emergency Response and Recovery Director (ER and RD) informed of plant conditions and corrective actions in progress prior to activation of the Technical Support Center (TSC) and Emergency Operations Facility (E0F). CR staff also ensured that the system used to alert other members of the emergency organization was promptly activated as appropriate for each emergency declaratio In accordance with procedures, the plant public address (PA) system was utilized to inform onsite personnel of the Alert, Site Area Emergency, and General Emergency declarations. However, the initial PA announcement associated with the Site Area Emergency was confusing in that persons were told that an " Alert Site Emergency" had been declared. A corrected announcement was soon mad However, the PA announcements included the following potentially misleading (especially to visitors and contractors) order, per the wording in EPIP 1.3, Section 4.1.3: "All personnel onsite shall evacuate to their designated evacuation centers." The real intent of the statement is that all onsite personnel must assemble in their designated onsite assembly area Verification callbacks to the CR were well handled for the Unusual Event, Alert, and Site Emergency declarations. However, the callbacks associated witn the Site Emergency declaration went to the CR, althouph the initial notification calls had originated in the TS This caused confusion in the CR, as CR communicators did not have access to the initial notification message form for the Site Emergency declaration. The CR correctly routed these return calls to the TS .

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CR personnel exhibited good teamwork and responded promptly to plant alarm They typically showed anticipatory and innovative responses to scenario events. For example, they attempted to initiate shutdown in an orderly manner upon realizing that a 24-hour Limiting Condition for Operation (LCO) existed due to equipment failures. They were also well aware of the potential adverse effects of operating the emergency diesel generators unloaded, following their automatic start due to a high drywell pressure signal. However, CR and TSC staff did not exhibit the same thoroughness in pursuing repairs to the Reactor Core Isolation Cooling (RCIC) system as was exhibited to restoring the High Pressure Coolant Injection (HPCI) system to operational statu The OSS ordered onsite assembly following the Alert declaratio Accountability was completed within twenty minutes, with the determination that no nonessential persons were onsite and that any onsice emergency organization personnel had reported to their duty stations. CR staff augmentation was timely, and included a CR Coordinator and several communicator The OSS provided a well-detailed initial briefing to the EC upon the latter's arrival in the C The inspectors noted that EPIP 1.1, Determination of Emergency Action Levels, had been revised in early November 1986. It included a condition that " loss of two of three fission product barriers" warranted a General Emergency declaration, whereas the guidance in Revision 1 to NUREG-0654 indicates that a General Emergency declaration is appropriate for the loss of two of three fission product barriers with the potential loss of the third barrie Based on the above findings, this portion of the licensee's program was acceptable; however, the following items should be considered for improvement:

• To avoid possible confusion and unnecessary alarm, especially to onsite contractors and visitors, the wording of the PA message given to initiate onsite assembly should be revised to indicate that personnel are to assemble in their predesignated assembly areas, rather than to " evacuate to their designated evacuation centers."

• Licensee personnel making offsite notification calls should state their location to better ensure that verification callbacks are made to that locatio * The licensee should reevaluate the Emergency Action Levels (EALs)

associated with loss of multiple fission product barriers to ensure that these EALs conform to the guidance in NUREG-0654, Revision 1.

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. Technical Support Center (TSC)

Essentially all TSC staff were present and ready to ass L their

< emergency duties within about 45 mi wtes of the Alert declaration, at which time the EC had arrived f: a the CR. 'The EC and TSC Supervisor presented thorough initial briefings to the TSC staf Subsequent briefings were concise and were provided when the EC noted significant' changes in plant status or in offsite emergency response activities. Staff briefings could have been more efficiently done with the aid of a public address system, as engineering support personnel'and others in the dose assessment room tended to drift towards the EC's table to hear his briefing The Station Radiation Protection Coordinator (SRPC) ordered two field survey teams formed due to deteriorating plant conditions. The team were dispatched prior to any simulated release. The SRPC's staff adequately controlled these teams and a " perimeter team" that was later. dispatched until the E0F had assumed control of offsite monitoring activities. The staff also made good use of 10-mile EPZ maps to plot the progress of the offsite teams and the approximate locations of the plum The SRPC showed good knowledge of relevant EALs and proper aggressiveness in convincing the EC that a Site-Area Emergency declaration was warranted based on a rapid increase in the off gas stack radiation monitor's reading. The EC finally made the declaration within ten minutes after the SRPC had informed him of the change in release rat Once he had declared the. Site Emergency, the EC was so concerned with initiating offsite notifications that he did not allow the SRPC-adequate time to formulate and present the associated offsite protective-' action recommendation or to personally review the initial

. notification message form for accuracy. Instead, the EC directed a communicator to immediately begin making separate initial notification calls to both counties and the Stat As a result of his haste to begin the offsite notifications, the EC soon had to locate and stop his communicator, who was in the midst of the second of three calls, in order to inform him of a change in i offsite protective action recommendations and to correct an error on

the message form regarding the status cf the radiological releas The communicator then did a good job in ensuring that both counties

! and the State received the corrected message within about 15 minutes j of event declaratio The offsite recommendation associated with the Site Emergency was i conservative, and was formulated in accordance with procedural guidance with one important exception. Although EPIP 3.3 states that forecast weather conditions should be considered in protective

, action decisionmaking, neither the SRPC nor his staff sought a weather

forecast prior to the transfer of protective action decisionmaking

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responsibility to.the E0F. Subsequent review of relevant procedures led the inspector to conclude that:no one in the TSC was specifically tasked with obtaining a weather forecast or for comparing current to

. forecast weather conditions, both actions which were later adequately demonstrated by EOF staff. The failure of TSC staff to consider forecast weather information during offsite protective action decisionmaking is an Exercise Weakness (50-331/86015-01).

Different status boards were effectively utilized to_ list.the assignments and the departure and return times of_inplant teams; the emergency classification chronology;.and current meteorological conditions. Prior to a period when a power loss was simulated in the TSC, plant status information, Area Radiathn Monitor (ARM) data, and critical plant parameter trends were displayed using two overhead projectors. As the exercise progressed, however, it became apparent the " Event Record" sheets taken from a flip chart were becoming overly relied upon to post too many categories of information, including:

protective actions recommended and being implemented offsite; plant

. parameter data points; major decisions by TSC and E0F staffs; and the results achieved by inplant teams. Only two large " Event Record"-

sheets were visible to TSC staff at any given time - the sheet being filled out and the previous sheet. At times, the sheets were completely. filled out within 30 to 45 minutes. Thus, important pieces of information regarding protective actions and plant parameter data points were not only scattered amcng a wide variety of information on the " Event Record" sheets,-but they were soon buried under more

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recently completed sheets of information. This could be troublesome during attempts to brief newly arriving licensee or NRC Site Team personnel and could result in current TSC staff forgetting important pieces of information that can literally be lost from sight within an hour of receip Noise levels-were generally acceptable in the TSC. However, there were several instances when the engineering support staff began group discussions in close proximity to the EC's work station. This may have been contributed to a communicator's decision to find a phone in a less congested area to accomplish offsite notifications for the Site Emergency c .:laration. As the exercise progressed, the engineering staff utilized a number of sets of large scale drawings which were spread open on the floor of the TSC as well as on top of several desk During the exercise, TSC staff did a good job in identifying possible release paths and in deciding how best to utilize inplant teams. The staff conducted an adequate initial recovery discussion prior to exercise terminatio In addition to the Exercise Weakness, the following items should be considered for improvement:

• The TSC should be equipped with a public address system so that staff in remote corners of the TSC or in side rooms can hear the briefings without leaving their work station '

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• The EC should allow his staff adequate time to formblote offsite protective action recommendations and should closely review the offsite notification form for accuracy prior to having a communicator begin offsite notification * The TSC should be equipped with a. separate status board for trending critical plant parameters and for displaying offsite protective action recommendation informatio * Engineering support staff should conduct group discussions in an area remote from the EC's workstatio * Additional desk or tabletop space should be provided in the TSC for the review of plant drawing c. Operational Support Center (OSC)

Activation of the OSC was initiated along with the Alert declaratio Considering that the exercise was conducted in the evening, the OSC was fully operational within an acceptable 45 minutes after the Alert declaration. Inplant team members donned anti-contamination clothing upon arrival in the OSC in accordance with procedure Command and control within the OSC was very goo Decisionmaking and directing of OSC staff by the OSC Supervisor and his assistant was crisp and clear. Inplant team briefings were thorough, with respect to both technical and radiation protection aspects. Good use was made of plant layout drawings and ARM data received from the CR's "back panel communicator" via the TSC's radiation protection staf However, the ARM data were typically about 15 minutes old when finally available in the OSC. At the conclusion of inplant team briefings, the briefers aggressively quizzed the team members to better ensure that the team clearly understood their assignments, potential radiation hazards, and any exposure restrictions placed on them. Inplant teams returning to the OSC were checked for any contamination at the access control point. Briefings of outgoing teams usually took priority over debriefings of returning team OSC supervisory personnel ensured that returning team members reported their exposures to a recordskeeper. OSC personnel were also given occasional overview briefings on plant status, emergency classifications, and even the status of offsite protective actions by the Security and Technical Support Supervisor who came from the TSC and would leave his briefing notes by the OSC's " tag board" for future referenc Habitability surveys were periodically performed in the OSC. An ARM was installed and operable in the rear of the OSC. However, while an air sampler was occasionally brought into the OSC, it was not operated. A Continuous Air Monitor (CAM) was installed and oper, tad in the rear of the TSC. However, a CAM was not made available in the OS t

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Based on the above findings, this portion of the licensee's program was acceptable; however, the following item should be considered for improvement:

• The OSC should be equipped with a CAM to improve the capability to detect any airborne _ radioactive materials that may enter the facilit d. Emergency Operations Facility (EOF)

In accordance'with procedures, the E0F was placed in " standby" when the Alert was declared. " Standby" meant that personnel reported to the facility, rearranged the workspace from its normal to its EOF configuration, checked equipment, established communications with TSC counterparts, and awaited either a Site Emergency declaration or a decision by the ER and RD that the E0F go to a fully operational status. In t'.iis exercise, the E0F was declared fully operational about 15 minutes after the Site Emergency was declared. The minor delay in reaching operational status was due to telephone equipment problems which were soon correcte Transfer of overall command and control of emergency responsibilities from the EC to the ER and RD was adequate, as was the transfer of offsite notification responsibility and offsite monitoring team control from TSC to EOF staffs. In general, the EOF' staff performed adequately during the exercise. Offsite dose projections were efficiently generated and properly evaluated. Dose assessment staff demonstrated the capability to acquire a meteorological forecast and to compare current weather data to the forecast. There was good sharing of information regarding the locations and survey results reported by the licensee's and State's field survey teams. E0F staff were kept adequately informed of changing plant status and corrective actions in progress through the use of up-to-date status board information supplemented by verbal briefings given by the ER and RD or his key aids. However, a microphone would have been useful to improve the audibility of these briefings to persons inside the dose assessment room or in relatively remote areas of the EOF workplac The General Emergency was declared by the ER and R0 in a timely manne The associated initial and revised offsite protective action recommendations were appropriate and were discussed with representatives of State and county governments in the E0F prior to their transmittal to the various Emergency Operations Centers (E0Cs).

EOF staff kept well aware of any changes to their recommended protective actions that were being implemented by government official No formal individual logs were maintained by the ER and RD or his principal aids to enhance later reconstruction of E0F staff activities, major decisions, and conversations with TSC counterpart Instead, over-reliance was placed on status board information and dose projection printouts to serve as sufficient documentation of EOF activities.

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The ER and RD conducted on adequate, initial recovery decision in the EOF shortly before exercise terminatio Based on the above findings, this portion of the licensee's program was acceptable; however, the following items should be considered

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for improvement:

I * The E0F should be equipped with a microphone to improve the audibility of briefings given to all persons in the E0 * Principal EOF staff should maintain individual logs of their conversations and decisions to enhance later reconstruction of EOF activitie e. Offsite Monitoring Teams Offsite team members began arriving at the OSC within twenty-five minutes of the Alert declaratio Two teams were ready for dispatch, with equipment checks having been completed and vehicles loaded, thirty minutes later. As the scenario progressed, a " perimeter team" was also formed and dispatched to cover near-site location The teams were adequately briefed prior to dispatch by OSC supervisory personne The inspector accompanied Team "A", which demonstrated good knowledge of local roads and conditions, radiation monitoring and reporting procedures, and ALARA practice The licensee had established pre-designated survey and sampling points, which greatly simplified direction of the teams to designated locations. No problems were observed with collecting, handling and labeling of samples, tracking of exposures, or practices to limit the potential spread of contaminatio The team adequately demonstrated the ability to perform general radiation surveys, collect and field-analyze an air sample, change out air filters at fixed environmental monitoring stations, and properly collect environmental sample The team leader utilized the auxiliary 12 volt automotive battery

to power the air sampler instead of the vehicle battery, as specified in EPIP 3.2, Section 4.4.3. This appeared to be a sound decision,

! which made sample collection more convenient and avoided the underhood and radiator areas of the vehicle (potentially contaminated areas).

The team was kept advised (via radio) meteorological information, changes in emergency class, and protective action recommendations.

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Information regarding plant status was relatively sketchy, and the l teams were unaware that a minor release (which was undetectable on survey instrumentation) had begun until approximately an hour and a half after the fact.

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Late in the exercise, an environmental sample was transferred to a

" sample runner" at a " traffic control point." The runner was asked for identification and was adequately briefed as to the type of sample and associated radiation hazard The sample was placed in the trunk of the sample runner's vehicle to minimize radiation exposure during transpor Based on the above findings, this portion of the licensee's program was acceptable; however, the following item should be considered for improvement:

• EPIP 3.2 should be revised to indicate that either the vehicle's battery or the auxiliary battery could be used to power the air sample f. Exercise Scenario and Controller Actions The exercise was submitted for NRC review in a timely manner. The licensee was adequately responsive to questions resulting from the review, and provided revised scenario information to the inspection team. The scenario was adequately challenging to the licensee's emergency organization, and included wind direction data that varied significantly during the simulated releas The licensee's exercise controllers acted appropriately during the exercise, with one minor exception. Several minutes after EOF staff questioned the validity of a report from an offsite monitoring team, a controller volunteered the fact that the data were erroneous. In the~NRC observer's opinion, the EOF staff were already coming to that conclusion and should have been allowed to determine the accuracy of the questionable information without controller interferenc In contrast, a TSC controller had earlier showed proper self-restraint in letting TSC staff identify and correct an improper protective action recommendation and an incorrect initial notification message form prepared after the Site Emergency declaratio Based on the above findings, this portion of the licensee's program was acceptabl g. Licensee Critiques The inspector observed a number of critiques conducted by the exercise controllers immediately after the exercise within the various emergency response facilities. On November 19, the inspectors attended a formal critique session conducted by several principal controllers, which was also attended by about three dozen persons who were either players or had observed the exercise. Audience feedback was solicited during both types of critique session The critiques were objective. The licensee's own conclusions on the players' performances were generally in agreement with those of the inspection tea Based on the above findings, this portion of the licensee's program was acceptabl . - - - _ - -

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. ' Exit' Interview On November 19, 1986, the inspectors met with those licensee representatives listed in Section 1 to present their preliminary inspection findings. The licensee agreed to consider the items discussed and did not indicate that any matters discussed were proprietary in natur ~

Attachments:

1. Exercise Scope and Objectives Exercise Scenario's Narrative Summary and Sequence of Events

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1.0 SCOPE Ato OBJECTIVES 1.1 Secpe The 1986 Ouane Arnold Energy Center Emergency Preparedness Exercise, to be conducted on November 18, 1986 will test and provide the opportunity to evaluate Iowa Electric Light and Power Company, the State of Iowa and Benton and Linn Counties' ememency plans and procedures. It will also test each emergency response organization's ability to assess and respond to emergency *

conditions and coordinate efforts with other agencies for protection of the health and safety of the publi Whenever practical, the exercise will incomorate provisions for " Free I Play" on the part of the participant W The scenario will depict a simulated sequence of events, resulting in a radiological release of sufficient magnitude to warrant mobilization of State and local agencies to respond to the emergenc ,

1.2 Objectives '

E The Duane Arnold Energy Center (OAEC) 1986 Emergency Preparedness Exercise Program objectives are based on the Nuclear Regulatory Commission (mC) requirements delineated in 10 CFR 50.47 and 10 CFR 50, Appendix E.

g Additional guidance provided in NLREG-0654, FEMA-REP-1, Revision 1, NUREG-0696 lW and NLREG-0737 Stpplement I was utilized in developing these objectives. Upon

! successful demonstration of the capability to respond to an emergency situation between the hours of 6:00 PM and 12:00 midnight, DAEC will have l completed all objectives within the six-year time frame as provided for in NUREG-0654.

l This exercise will include participation from Linn, Benton and Johnson Counties, and the State of Iowa. The formal offsite objectives represent l

either undemonstrated objectives from within the six-year cycle ending with this exercise and/or a corrective action from an earlier exercise (s). State and County participation beyond the stated objectives is intended for training l pumoses only. The warning system sirens and EBS notifications for the emergency planning zone will not be activated during the exercis I 1553/3024h 1-1

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The purpose of the exercise is to evaluate the integrated capability of a major portion of the basic elements existing within the onsite and offsite emergency plans and emergency response organizations. The specific objectives of the exercise to be demonstrated are listed belo .2.1 Iowa Electric Light and Power Company Objectives

. Demonstrate the adequacy of the DAEC Emergency Plan, Emergency Plan I@lementing Procedures, Comorate Emergency Response Plan, and Comorate Plan I@lementing Procedures to ensure co@liance with 10

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CFR 50.47 and NUREG-0654 I Demonstrate the activation, staffing, and operation of emergency response facilitie . Demonstrate the reliability and effective use of emergency communications equipment and procedure . Demonstrate proficiency in recognizing and classifying emergency condition .

E Demonstrate the capability to respond to an emergency situation between the hours of 6:00 PM and 12:00 midnigh . Demonstrate the notification network to Federal, State and local, corporate, and plant personne . Demonstrate coordination with State and local emergency response organization . Demonstrate the ability to perform dose calculations utilizing radiological and meteorological information to determine the magnitude and i m act of the release of radioactive materials to the environmen . Demonstrate the transition of responsibilities between facilities as a result of escalating accident classificatio /3024h 1-2

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1 Demonstrate f amiliarity with Protective Action Guides (PAGs) and recommendation of protective actions to offsite authoritie . Demonstrate the capability to obtain and analyze samples utilizing the post-accident sampling syste . Demonstrate the mobilization of onsite and offsite radiological

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monitoring team . Demonstrate appropricte equipment, procedures, and communication for onsite and offsite radiological monitorin I 14 Demonstrate the capability for offsite radiological monitoring to include collection and analysis of sample media and provision for communications and record keeping associated with survey and monitoring activitie . Demonstrate the ability to perform site assembly, accountability, and evacuation as appropriate. Note that construction workers in the owner controlled area, but outside the protected area fence will not be evacuated, nor participate in the exercise in any way, I so as not to irrpede construction progres . Demonstrate the ability to monitor and control emergency worker exposure within the plan I Demonstrate adequate equipment and procedures for decontamination 1 of emergency workers and equipment, as require . Demonstrate the ability to coordinate news releases, handle public I inquiries, and control rumor . Demonstrate the ability to plan recovery operations and identify the need for additional resources as require I Demonstrate decision-making and coordination with offsite agencies 2 in de-escalating and terminating the emergenc /3024h 1-3

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6.0 EXERCISE SCENARIO

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6.1 Narrative Summary The scenario for this Exercise is based on a reactor coolant system leak combined with the failure of the standby gas treatment system drywell isolation valves to provide a radiological release of sufficient magnitude to warrant the declaration of a GENERAL EbERGENC The initial conditions establish that the unit is operating at 100% power with full core flow and has been at steady state for five weeks. Due to unplanned outages at Sutherland Station and Prairie Creek Station, the System Controller has informed DAEC that there is a high demand, low reserve situation. The last reactor coolant sample indicated an I-131 dose equivalent level of 0.09 uC1/g. At 1200, a slight increase was noted in drywell unidentified leakage. The leak rate increased from 1.8 gpm to 2.5 gpm. This leakage is from Recirculation Pump IP201A suction valve weld. Earlier today FFCI failed a monthly surveillance test due to a turbine control circuitry proble The faulty part, a Woodward EG-M Control Box, is not available onsite. This part is on special order and will be flown in tomorrow. HPCI was declared out of service at 1700. With HPCI inoperable, a surveillance test has been initiated on RCIC and is currently in progres The Exercise begins with the operators who are performing the RCIC surveillance test reporting that the RCIC trip throttle valve, MOV-2405, failed to open during the test. RCIC is declared incperable and technicians are called in to investigate the problem with the valve. A NOTIFICATION OF UNUSUAL EVENT is declared due to the loss of both HPCI and RCI While attempting to repair RCIC, the minor leakage frcxn the Recirculation Pump 1P201A suction valve weld develops into a 100 gpm leak. Drywell pressure increases to 2 psi at which point the reactor trips and Group 2, 3, 4 and 8 1solations occur with SGTS initiation. The pressure transient from the l reactor scram causes a steam leak from the packing on an outboard MSIV. High steam tunnel temperatures cause a Group 1 isolation with all MSIVs shuttin The steam leak is isolated when the MSIVs shu The SGTS drywell purge outboard valve, CV-4302, fails to shut on Group 3 isolation. This velve is mechanically bound and can't be shut manually. Tne inboard valve does shut to isolate containment. An ALERT is declared due to reactor coolant system leak rate greater than 50 gp f 1553-2/3218h 6-1

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The limit switch for MOV-2405 is repaired and RCIC returned to servic Efforts at this point should be concentrated on stabilizing plant conditions and investigating the problem with the SGTS drywell purge valv An hour and a half af ter the leak occurred, the leak valve suddenly increases to 350 gpm. This is still well within the make-up capacity but drywell pressure increases rapidly. The SGTS drywell purge inboard valve,

~CV-4303, begins leaking at the rubber T-ring seal. A release pathway is established through this valve, the outboard valve which had previously failed

, to shut on drywell isolation, the standby gas treatment system, and out the offgas stack. At this point offsite releases are relatively minor since no fuel has been damaged. However, the release rate is high enough to warrant the declaration of a SITE E ERGENC In an attempt to reduce drywell pressure, containment spray is initiate Containment spray f ails when valves MO-2000 and MO-1902 don't 1 ope At this point ADS may be attempted to reduce reactor pressure. As ADS initiation is atterrpted, the transfer switches fail at the remote shutdown panel to prevent either local or remote operation. The TSC will priaritize repair options and dispatch Repair Teams to investigate these equipment problem An hour later offsite power is lost. Both diesels pick up essential AC loads. However, the feedwater purrps are lost leaving only RCIC and the mD pumps to supply high pressure water. The leak rate again increases and reactor level cannot be maintained. A GENERAL EERGENCY is declared due to the loss of two of three fission product barriers with the potential loss of the thir The core is uncovered. Fuel begins to fail within 45 minutes and offsite releases increas A half hour later offsite power is restored and the reactor level quickly restored to norma The releases continue since the fuel has already been damage The reactor is depressurized and stabilized with the repair of ADS. A

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short time later, a Repair Team successfully opens containment spray valve MO-1902 and containment spray is initiated to reduce drywell pressure.

ii- The release is terminated when drywell pressure is decreased to the point where there is no longer a driving force for the release. Soon the plume dissipates and the Exercise is terminated.

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6.2 Sequence of Events 1 Approximate Time Key Events

1800 00/00 Initial conditions established:

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1. The unit is operating at 100% power and full core flo The unit has been at steady state for five weeks. The System Controller has informed DAEC that there is a high demand, low reserve situation due to unplanned outages at Sutherland Station and Prairie Creek Statio . The last reactor coolant sample results indicated an I-131 dose equivalent level of .09 uCi/ . HPCI failed a monthly surveillance test due to a turbine governor control circuitry problem. HPCI was declared out of service at 1700 today. The faulty part, a Woodward EG-M Control Box, is not available at DAE This part is on special orcer and will be flown in tomorro I 4. STP No. 45E001 is in progress on RCIC due to HPCI being declared inoperable.

l S. At 1200, a slight increase was noted in drywell unidentified leakage. Leakage increased from 1.8 gpm to 2.5 gp /05 RCIC fails STP No. 45E001 due to a valve limit switch problem l

which results in MOV-2405, trip throttle valve, failing to l

ope A NOTIFICATION OF UNUSUAL EVENT should be declared per EAL A-10, loss of HPCI and either ADS or RCIC.

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l 1553-2/3218h 6-3

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Approximate Time Key Events

1845 00/45 A 100 gpm leak develops in the Recirculation Pump 1P201A suction valve wel .

1850 00/50 The reactor trips on high drywell pressure with group 2, 3, 4

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and 8 isolations and SGTS initiatio i The pressure transient blows out the packing on an outboard MSIV resulting in high steam tunnel temperatures and a

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Gro@ 1 isolation. All MSIVs shut thus isolating the steam lea The SGTS drywell purge outboard valve, CV-4303, fails to shut on Group 3 isolation. This valve is mechanically bound and i

can't be shut manually. The inboard valve does shut to isolate containmen An ALERT should be declared per EAL B-1, Reactor Coolant System leak rate greater than 50 gpm, but within make-up capacit /20 The limit switch for MOV-2405 has been fixed and RCIC returned to servic i i

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2015 02/15 The leak rate suddenly increases to 350 gpm. Reactor level

' is maintained but drywell pressure quickly increases to 14 psi. Containment Spray fails to initiate when valves M0-2000

,l and M0-1902 don't open. MO-2000 has a sheared valve stem and MO-1902 motor operator is bound.

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'1 The SGTS drywell purge inboard valve, CV-4302, begins leaking at the rubber T-ring seal. Offsite releases begin through the Standby Gas Treatment System and out the offgas stac /3218h 6-4

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Approximate Time Key Events

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Upon manual initiation, ADS will fail due to the failure of the ADS transfer switches at the remote shutdown pane A SITE E K RGENCY should be declared per EAL C-25, offgas

monitor reading .75 to 28 uC1/c /25 Offsite power is lost. Both diesels pick up essential AC loads.

I The leak rate again increases with only RCIC and both CRD purrps supplying high pressure water. Reactor water level i

cannot be maintaine /30 Reactor vessel level is dropping rapidl A GENERAL EERGENCY should be declared per EAL D-5, loss of 2 of the 3 fission product barriers with potential loss of the thir /45 The core is uncovere /15 Fuel failure begins and the release rate increases.

I 2235 04/35 Offsite power is restored. Feed and condensate pumps are started to increase reactor leve /45 The core is recovered and level restored to the normal rang /50 One ADS valve is repaired and the reactor depressurized. Low pressure systems start injecting water into the reactor maintaining reactor level in the normal rang /10 Containment Spray Valve MD-1902 is repaired and Containment Spray initiated to reduce drywell pressur /3218h 6-5

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Approximate Time Key Events 2330 05/30 Drywell pressure is reduced to the point where all releases have been terminate .

2400 06/00 The Exarcise is terminate I I

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i 1553-2/3218h 6-6

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