IR 05000341/1989019

Insp Rept 50-341/89-19 on 890613-15.No Violations,Deviations or Deficiencies Noted.Exercise Weakness Noted.Major Areas Inspected:Annual Emergency Preparedness Exercise

ML20245H421
Person / Time
Site:	Fermi
Issue date:	06/23/1989
From:	Patterson J, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20245H408	List: IR 05000341/1989019 ML20245H402
References
50-341-89-19, NUDOCS 8906290482
Download: ML20245H421 (13)

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k U. S. NUCLEAR REGULATORY COMMISSION'

REGION III'

Report No'.- 50-341/89019(DRSS)

Docket No. 50-341- License No. NPF-43 Licensee: The. Detroit Edison. Company 6400 North Dixie Highway L

Newport, MI 48166 Facility'Name: Enrico Fermi Nuclear Power Plant, Unit 2 Inspection at: Fermi 2 Site, Newport, Mich1gan Inspection con ucted: June 13-15, 1989 Inspectors: # -

Team Leader trate

Approved by

Ld.~ M W. Snell, Chief (,/2.3/41 Emergency Preparedness Section Date

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' Inspection Summary:

Inspection on June 13-15, 1989 (Report No. 50-341/89019(DRSS)

Areas Inspected: Routine, announced inspection of the annual Fermi Unit 2 Emergency Preparedness Exercise involving observations by four NRC representatives of key functions and locations during the exercise (IP 82301).

Resultsi The licensee demonstrated a good response to a simulated accident scenario involving a large release of radioactivity. No violations, deficiencies or deviations were identified. However, one Exercise Weakness, involving an unacceptable assembly / accountability drill, was identifie ~

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DETAILS

. Persons Contacted NRC Observers and Aree- Observed J. Patterson, Control Room (CR) Simulator, Technical Support l Center (TSC)

W. Snell - Emergency Operations Facility (EOF) and CR-Simulator {

S. Hawley - TSC and EOF

• S. Stasek - CR Simulator Detroit Edison Company B. Sylvia, Senior Vice President S. Catola, Vice President, Nuclear Engineering and Services D. Gipson, Plant Manager R. McKeon, Superintendent - Operations R. Eberhardt, Superintendent, Radiation Protection J. Mulvehill, Supervisor, Radiological Emergency Response Organization (RERO)

K. Morris, Emergency Response Planner - RERO J. Sweeney - Emergency Response Specialist - RERO L. Goodman, Director - Nuclear Licensing (NL)

T. Riley, Supervisor - Compliance NL J. Pendergast - Licensing Engineer - NL G. Trahey, Director, Special Projects J. Koste - General Supervisor - Security Operations T. Stack - Security Shift Supervisor M. Karmol - Computer Engineer, Nuclear Training S, Booker - Principal Engineer l

• All names listed above with the one exception noted (*), attended l the exit interview on June 15, 1989.

I General l An exercise of the licensee's Radiological Emergency Response Preparedness I (RERP) plan was conducted et the Enrict Ferni Nuclear Power Plant on

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June 14, 1989. The exercise tested the licensee's capabilities to j respond to a hypothetical accident scer.ario resulting in a major release of radioactivity. This was a utility only exercise conducted with Controllers role playing as local, State and Canadian officials for the purpose of demonstrating the capability of establishing communications and coordination with these governmental response agencie Attachments to this report describe the exercise scope and objectives and the sequence of event L - - - - - - - - - - - - - - . -

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3. General Observations Procedure The exercise was conducted in accordance with 10 CFR 50, Appendix E requirements using the Radiological Emergency Response Preparedness (RERP) Plan and the Emergency Plan Implementing Procedures (EPIPs).

1 Coordination f The licensee's response was coordinated, orderly, and timely. If the events had been real, the actions taken by the licensee would 1 have been sufficient to permit the State and local authorities to take appropriate actions to protect the health and safety of the I publi Observers Licensee observers monitored and critiqued this exercise along with four NRC observer i Exercise Critiques j The licensee held facility and Controller critiques at the Emergency Operations Facility after the exercise on June 14, 198 The NRC observer team discussed the strengths and weaknesses identified during the exercise at the exit interview held on June 15, 198 Personnel who attended the NRC exit interview are listed in Section . Specific Observations Control Room (CR)/ Simulator The CR staff worked well together, demonstrating good teamwork and coordination. The protocol in the CR was well disciplined with j personnel repeating the pertinent information and directives as ,

given by the Shift Supervisor (55) or Assistant SS before taking I action. The Alert was declared at 0930 followed Dy plant alarm and voice announcement for asseably and accountability at approximately 0933. The operttors had already begun to use the Safety Release Valves (SRVs) to maintain pressure and to control the rate of cooldown (time span 0925-1025). These SRVs were still being used as t~ne emergeacy event escalated (1025-1210). This type of SRV used has a known history of rematning cpen; therefore, it may have been better to control pressure and cooldown by using the High Pressure j Coolant Injection (HPCI) System. This would have also provided a

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r,moother cooldow The decision to escalate the pressure reduction at 1210 by using the Automatic Depressurization System (ADS) was a rather late

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' decision. Pressure had already been maintained or reduced gradually j from 0925 to 1210 and was down to 180 psig. This decision was made j to eliminate or. reduce the driving force behind the release. However, ,

l by this time the release rate had already dropped by'a factor of-two "

to three. If it was a good decision to use ADS at 1210; it would have

, been even better to initiate it much earlie While the process began for preparing and completing the offsite notification forms, there was no consideration.given to providing an

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'; additional communicator. The NRC Duty Officer would probably want to maintain continuous communications in a real Alert with a release in process. In anticipation of this, the SS should have requested

.another communicator to help with other communications.

l The interchange of information between the' Assistant SS in the CR and the CR staff person assigned to perform the Reactor Core

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l Isolation Cooling (RCIC). surveillance was well done. Plant announcements were clear, distinct and meaningful. The use of a clerk to expedite completion of ~.certain forms including work -

permits was helpful and innovative. Control Room staff and i management representatives did a good job of quickly analyzing and evaluating plant conditions and taking corrective action The.EALs were promptly reviewed and the most correct one was selected on which to base the Alert declaratio : Based on the above findings, this portion of the licensee's program L was acceptable. However, the following item should be considered for improvemen *

An additional communicator should be available to respond to the CR in tne event the NRC Duty Officer would want to m.31ntain continuous communications with the CR (Ref. NRC Information Notice 87-58). Technical Support Center (TEC)

l-- Activation of the TSC proceeded quickly and efficiently. Prior to l

the Emergency Director's arrival, the Radiation Protection Advisor l' (RPO) initiated dose projcction calculations and took immediate 1 action to the activate the onsite and the offsite monitoring team The initial dose projection from the Emergency Response Information System (ERIS) agreed with the PC Raddose Program. Good assertive leaderstip was demonstrated by the RP0, who at that time was acting

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under the cuthutity of the initial Energency Director, the SS in the ContM Room. A security representative arrived within 2-3 minutes after the Alert was declared and immediately established a sign-in log for all participants to identify themselves. The TSC was declared-functional in approximately 34 minutes after the Alert was declared.

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Habitability surveys started early and continued at' regular intervals throughout the TSC's activity. . Smears.were taken frequently o .

various. surfaces and checks on direct reading dosimeters were made continually throw 1hout the exercise. Habitability procedures in the L TSC were very well performed in a thorough, professional manne From the time it was decided to obtain a grab sample from the Standby Gas Treatment System (SGTS) until the results were available took approximately two and cne-half hours. This. appeared excessively long. Also, it was observed that when results were obtained all the particulars were not always included; particularly the location of the sample. More care.should be taken in reporting sample results-to the TSC so that proper units are included as well as location,

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Good objective and frequent briefings were given by the Emergency Director. Caucuses were frequently held by the Emergency Director

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with his key group leaders. He directly asked.for their input and views on various concerns in the. emergency. The meteorological data was kept current throughout the exercise, including forecast data and lake breeze effect. Several changes in stability class were duly posted on the status boards. All:the. relevant meteorological data was posted 'n a timely manner on all appropriate status board Several worthwhile discussions took place between the Nuclecr Safety Advisor (NS0) and the RPO. The NSO wanted more information before recommending a reactor blowdown (1110). This information requested included more direct radiation surveys. and air samples if possibl The RP0 was . reluctant to send in more survey teams and risk overexposure even with a Self Contained Breathing Apparatus included for each team member. The results from air samples taken earlier arrived some time before 1200. The NSO then felt that he had enaugh information to go ahead with a reactor blowdown recommendation Trenovg of key reactor parameters was being done by the Engineering Support Group. This included, among:others, reactor water level, reactor pressure and reactor coolant system integr'ty. These values were used as input for decisionmaking throughout the exercis Declaration of the Site Area Emergency (SAE) was made by the initial Emergency Director in the Control Room and not by the TSC, since the T3C was not functional at that time. The SAE was correctly declared i

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at 0955 based on a radiation release of > 50 millirem / hour dose rate at the Site Boundary. Notifications were made to offsite agencies and the NRC within the specified time frames. The General Emergency was declared at 1105 based on loss of reactor coolant boundary and potential loss of primary containment integrity. This was a very conservative measure which was not originally intended to happen

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based on scenario conditions. In the interest of free play, the Lead Controller allowed this emergency escalation to procee The -Protective Action Recommendation (PAR) recommended sheltering within a two-mile radius and five miles downwind for sectors J, K, L, M, and N. This PAR was concurred on by the Emergency Officer in the EOF. Recovery activities were addressed briefly before the termination of the exercise. The Emergency Director identified the Recovery Procedure by number, EP-402, and asked each staff member to review it for their inpu Shift relief and routes for relief personnel to enter the area were also discusse Assembly / Accountability was conducted following the Alert notification and Plant Alarm at 0932. At 1002, 30 minutes later, 64 people were still missing. At 1008, the list was down to 50 people. At 1018, 16 were still missing; and at 1033 all were accounted for. It took one hour to account for all those onsite. This exercise objective was not met. A review of the details determined that one list with 50 names to be checked was inadvertently put in with several other sheets already verified. This delay was a large contributor to the shortage. Also, post exercise discussions concluded that those reporting to an assembly area could be more positive and forward in cooperating with the Security Officer assigned this vital tas Lack of successful completion of this assembly / accountability function within the 30 minute goal is an Open Item, No. 50-341/89019-01. Overall, with the exception of the item listed ;

in the preceding paragraph, this was a very well conducted TSC with good coordination and interactions between the Emergency Director and his supporting Staff. Problem solving, dose assessment activities and radiation protection measures were aptly demonstrate Based upon the above findings, with the exception of the Open Item i identified above, this portion of the licensee's program was i acceptabl Emergency Operations Facility (EOF)

The E0F was quickly and efficiently staffed with the facility !

assuming command and control responsibilities from the TSC in about !

30 minutes after the Site Area Emergency declaration. Communications i with the State of Michigan (unofficially participating) were excellen Appropriate PARS were discussed with the State well in advance of the escalation to the General Emergency. As information became available, 1 it was promptly relayed to the State. Responses to questions from the State were also provided for in a timely manne Several times during the exercise, information provided to the staff during briefings or I plant PA announcements conflicted with the information provided on the

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notification forms. In each of these instances the EOF was very prompt in identifying the discrepancy and resolving it to ensure that no misinformation would cause a proble ,

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Dose assessments were quickly carried out using-two' dose models (ERIS and Raddose) _ Comparisons were made between dose projections -

and field. sample readings. An iodine value discrepancy.was identified and resolved between ERIS and IBM codes. Numerous' dose-projections were made based on potential releases to-support current off' site PARS and identify any need to change current: PARS. Although '

the ERIS: printed out the same report in=the E0F as in the TSC, not all EOF. dose assessment people were' aware that the TSC;had: restarted ERIS using sample data from a grab sample. In=this case the practical difference was minimal, but this does create an-uncertainty that is not neede Since a large number of ERIS reports are used, it.would be useful to have the program print in large type, consecutive run numbers on the repor Habitability measures in the EOF were well implemente Frisking techniques were well followed by all entering the EOF. Air samplers were run'and smears taken. Contamination control measures for the environmental samples were acceptabl One exception in the lab was the placing of tne cartridge for the air sample directly in the counter, rather than putting it in a plastic bag before being counte The counting software displayed a problem in that erroneous peak data was printed out for both environmental sample Other portions of the report showed the correct data. This caused

" unnecessary confusion during the emergency. It was determined later that these unplanned peaks represented radon daughter products, that probably showed up due to. rain depositio Very good communications were maintained throughout the exercise between the TSC and the EOF. The decision to transfer command and control to the EOF was thoroughly discussed, and all in the EOF were informed when the EOF became functional. Status boards were well maintained'with no data observed to be in error or untimely at any time. SGTS release rates were plotted which was helpful for evaluation purpose .A post accident sample was taken at about 1144, however, the results were not available by the time the exercise terminated, approximately 1402. Recovery actions including shift turnover were adequately addressed by the EO Based on the above findings, this portion of-the licensee's program was acceptabl . Scenario The scenario was considered to range from average to above average difficulty. The utilization of ERIS plus SPDS through the Simulator was very well done. The ability to enter meteorological data into the simulator using real data from a previous year's weather conditions added a lot to the realism of the scenario. Demonstration by the licensee's participants

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in working with this see ario was very good. . Controllers, where needed, )

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demonstrated good decisionmaking. No prompting by the Controllers was

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observed. : The decision to escalate to a General Emergency, which was -

not predicted by the scenario, was well ' handled by the Controller ,The exercise was allowed to proceed uninhibited until the preselected-E termination tim . ; Exit Intervie The inspection team met on June 15, 1989 with the licensee-representative denoted in Section 1 of this report. The team'. leader discussed the scope o and evaluation.of the exercise. The exercise was well conducted in all-facets' but one, i.e. , the assembly and accountability drill. This action L took 60 minutes!until all individuals were accounted for onsit This was an exercise objective which failed and resulted in an Exercise Weakness being assessed. .The team leader reminded theilicensee representatives that this same item resulted in an Exercise Weakness in the 1987 exercise. Also, in the 1988 exercise the assembly and accountability demonstration was barely acceptable. Some obvious

' improvements, including possible procedural revisions, appear to be in order. The licensee agreed to further investigate the reasons behind this Exercise Weakness and take positive steps to prevent-its reoccurrenc According to the licensee, none of the information discussed during this

'meetfag.was proprietar Attachments:

1. -Exercise Scope and Objectives Sequence of Events

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FERMEX-8 . EXERCISE SCOPE FERMEX-89 will be a * Utility only" exercise that will demonstrate the ability of the Fermi 2 :

Emergency Response Organization to respond to a simulated radiological event with an offsite impact.' ~ Utility and non-utility controllers will act as_ tocal, state and Canadian officials and evaluate the capability of the Emergency Response Organization to establish communications and coordination with offsite governmental response agencie All emergency response facilities will be activated with the exception of the Joir.1 Public Information Center (JPIC). Separate JPIC drills will be conducted during the third quarter of -

,- ' 1989 due..to facility renovation at the Monroe County Community Colleg ,

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FERMEX-89 lf EXERCISE OBJECTIVES During FERMEX-89 the Fermi 2 Emergency Response Organization will demonstrate the i ability to:

. Implement the Radiological Emergency Response Preparedness Plan using existing procedure . Respond to and mitigate the effects of a simulated radiological emergency to protect the

' health and safety of the publi , . Classify events in accordance with the Emergency Action Level ; Activate the Emergency Response Organization commensurate with the emergency classificatio . Nctify state and local governmental agencies within 15 minutes of emergency classification and provide periodic follow-up report . Notify the Nuclear Regulatory Commission with 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of emergency classificatio Account for all personnel in the Protected Area within 30 minutes of ordering assembl h Perform radiological surveys and utilize access and exposure controls to protect the health and safety of plant personne . Use personal dosimetry in the Technical Support Center and the Emergency Operations Facilit . Estabilsh communications between the Emergency Response Facilities (Simulator Control Room, Operational Support Center, Technical Support Center, and Emergency Operations Facility).

.1 Transfer responsibility for offsite notifications, emergency classifications and protective action recommendations from the Simulator Control Room to the Technical Support Cente . . Transfer responsibility for offsite notifications and protective action recommendations from the Technical Support Center to the Emergency Operations Facilit . Perform offsite dose assessment based on plant conditions, potential / actual radiological releases, and meteorological condition . Utilize Offsite Radiological Emergency Teams to locate and track the plume, and collect environmental samples as required by the scenari ' 1 Utilize the Emergency Operations Facility laboratory to analyze offsite environmental samples.

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> ; 16.- Authorize exceeding 10 CFR 20 exposure limits as required by the scenari . Obtain iodine grab samples, analyze, and use the results in offsite dose' assessmen ..- 1 Maintain access control to the Technical Support Center and the Emergency Operations Facility.

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