IR 05000348/1998010

Insp Repts 50-348/98-10 & 50-364/98-10 on 980908-11.No Violations Noted.Major Areas Inspected:Observation & Evaluation of Biennial Emergency Preparedness Exercise & Response in Control Room Simulator & Technical Support Ctr

ML20155G881
Person / Time
Site:	Farley
Issue date:	11/03/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20155G875	List: IR 05000348/1998010 ML20155G871
References
50-348-98-10, 50-364-98-10, NUDOCS 9811090238
Download: ML20155G881 (13)

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U. S. NUCLEAR REGULATORY COMMISSION I REGION 11 i'

l Docket Nos: 50-348,50-364 License Nos: NPF-2, NPF-8 Report No: 50-348/98-10,50-364/98-10 Licer.see: Southern Nuclear Opercaing Company, In Facility: Farley Nuclear Plant Location: 7388 N. State Highway 95 Columbia AL 36319 Dates: September 8-11,1998 Inspectors: W. Sartor, Senior Radiation Specialist (Team Leader)

J. Kreh, Radiation Specialist G. Satyers, Emergency Preparedness Specialist J. Bartley, Resident inspector l

Approved by: K. Barr, Chief, Plant Support Branch Division of Reactor Safety i

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9811090238 981103 M l PDR ADOCK 05000348 l

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l EXECUTIVE SUMMARY FARLEY NUCLEAR PLANT NRC Inspection Report Nos. 50-348/98-10,50-364/98-10 This routine, announced inspection involved the observation and evaluation of the biennial emergency preparedness exercise for the Farley Nuclear Plant. This NRC/ FEMA-evaluated exercise was a p!t.ua exposure pathway exercise with offsite participation by the States of '

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Alabama, Georgia, and Florida, and local governments within the plume exposure pathwa The exercise was conducted on September 9,1998 frorn 8:05 a.m. to 12:30 p.m. This report summarizes the observations of the four-person NRC team that assessed the adequacy of the licensee's emergency preparedness program as it implemented its emergency plan and procedures in response to the simulated accident. A separate FEMA report will be issued that evaluates the perfoimance of the States and countie The NRC team observed the licensee's response in the Control Room Simulator (CRS), the Technical Support Center (TSC), the Operational Support Center (OSC), and the Emergency Operations Facility (EOF). Based on the performance observed, the team concluded that the licensee successfully demonstrated its ability to implement the Emergency Plan and implementing Procedure Proaram Areas Evaluated and RestMs Scenario - The scenario developed for this exercise was effective for testing the integrated emergency response capability of the onsite and offsite emergency organizations (Section P4.1).

Control Room Simulator - Because the exercise was not driven by an active simulator, CRS observation was limited to initial classification and notification. These functions were accomplished in a satisfactory manner (Section P4.2.b.1).

Tshnical Support Center - Command and control of TSC operations were effective. The TSC staff was proactive in formulating mitigation strategies to minimize offsite releases (Section P4.2.b.2).

Operational Support Center - TSC - OSC communications were not fully effective in communicating important plant conditions. The potential radiological hazard from a radioactive plume to site personnel using the Secondary Access Point (SAP) was not considered by the TSC or the OSC. High priority tearns were not dispatched from the OSC in a timely manner (Section P4.2.b.3).

Emeraency Operations Facility - Command and control of EOF operations by the Recovery Manager was generally very good. Effective working relationships were observed between licensee personnel and State and county representatives at the EOF (Section P4.2.b.4).

Licensee Critiaue - The licensee's controller / evaluator organization was effective in identifying most minor performance issues. Although a sufficient number of monitors was used, some of the more significant performance issues observed by the NRC, particulariy in the OSC, were not identified by the licensee monitors (Section P4.2.b.5).

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l L Reoort Details IV. Plant Sucoort

P4 Staff Knowledge and Performance in Emergency Preparedness (EP)

L P Exercise Scenario Insoection Scope (82302]

l The inspectors reviewed the exercise scenario to determine whether provisions had L

been made to test the integrated capability and a major portion of the basic elements of the licensee's pla l L Observations and Findinas The licensee submitted the scope and objectives for the biennial emergency exercise to the NRC with a letter dated June 3,1998. The exercise scenario package was j ' submitted with a letter dated July 24,1998. A review of the package indicated that the L scenario was adequate to exercise the onsite and offsite emergency organizations of I the licensee and provided sufficient information to the offsite agencies for their l

participation in the exercise.

, Conclusion t

l The~ scenario developed for this exercise was effective for testing the integrated emergency capability of the onsite and offsite emergency organizations.

L P4.2 Emeraency Resoonse Facility (ERF) Observations and Critiaue a .- Exercise Evaluation Scoce l During this inspection, the inspectors observed and evaluated the licensee's biennial 1 l full-participation, emergency preparedness exercise in the Technical Support Center l l (TSC), Operational Support Center (OSC), and the Emergency Operations Facility L (EOF).' The inspectors asserted licensee recognition of abnormal plant conditions, classification of emergency conditions, notification of offsite agencies, development of

, protective action recommendations (PARS), command and control, communications,

!: and the overallimplementation of the Emergency Plan. Observations in the Control Room Simulator (CRS) consisted only of the initial classification and notification. In l:

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-addition, the inspectors attended the post-exercise critique to evaluate the licensee's self-assessment of the exercise Acceptance criteria are contained in Appendix E to i

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10 CFR Part 50, site Emergency Plan, Emergency Plan implementing procedures, and

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industry guidance in NUREG-0654/ FEMA REP-1, Revision (Rev.) 1, " Criteria for i l ' Preparations and Evaluation of Radiological Emergency Response Plans and I

. Preparedness in Support of Nuclear Power Plants."

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1 ERF Observations. Findinas, and Facility Critiaues Control Room Simulator (CRS)

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l Observations and Findinas l

The initial emergency response was observed by the inspector in the CRS. The simulator was not active, therefore plant parameters were provided by the controller

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t staff. The initial event of the exercise occurred at 8:08 a.m. when a phone call was received in the CRS that damage to a fuel assembly had occurred during movement and there was high radiation in the Auxiliary Building. The Unit 2 Shift Supervisor promptly classified the Alert condition and assumed the responsibilities as the

, Emergency Director (ED). Notifications were directed by the ED and a turnover briefing i

was made shortly thereafter. No further observations were made by the NRC team from l the CR Conclusion Because the exercise was not driven by an active simulator, CRS observation was l limited to initial classification and notification. These functions were accomplished in a satisfactory manne Technical Suonort Center Observations and Findinas Staffing of the TSC was initiated with the public address announcement for the Alert emergency classification made at 8:21 a.m. Twenty minutes later the ED for the TSC completed the turnover briefing from the U2 Shift Supervisor who was the ED in the Control Room Simulator. With the activation of the TSC, the ED assumed the responsibilities for making notifications, emergency classification, PARS, and dose assessment. The ED promptly upgraded the emergency classification to a Site Area Emergency (SAE) at 9:42 a.m. due to the reactor coolant system (RCS) leak greater than 130 gallons per minute (gpm) and an RCS activity greater than 300 microcuries/ gram dose equivalent I-131 (DEI). The responsibility for dose assessment and follow-up notificatiens to the States and counties transferred to the EOF at approximately 10:10 a.m. The General Emergency (GE) declaration was made at 10:52 a.m. with the loss of the three fission product barriors. The inspector observed that the ED exercised effective command and control and his staff was proactive in formulating mitigation strategies to minimize offsite release Conclusion Command and control of TSC operations were effective. The TSC staff was proactive in formulating mitigation strategies to minimize offsite releases.

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3 Operational Sucoort Center i Observations and Findinas The inspector observed several instances where TSC - OSC communications were not fully effective:

e- A SAE was declared at 9:42 a.m. The inspector observed and the OSC logs -

confirm that the OSC was not aware of the plant conditions which led to the declaration of the SAE (Greater than 130 g.p.m. leak, DEI of 300

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microcuries/ gram and radiation monitor - R27 reading of 14.6 R/hr). At 9:45 a.m., the inspector observed that OSC discussion continued to focus on the

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damaged fuel in the spent fuel pool which occurred at 8:08 a.m.

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e A GE was declared at 10:52 a.m. About 20 minutes later at 11:15 a.m., the OSC became aware of the GE by an announcement on the public address (PA)

system made by the Assistant to the E * At 10:35 a.m., radiation monitor - R27 was reading 170 R/hr. The inspector observed and the OSC logs confirm that, through 12:17 p.m., the OSC was not aware that severe fuel damage had occurre During this exercise, the Primary Access Point was out of service and access to the plant was through the Secondary Access Point (SAP). The OSC did not consider this off normal situation and did not establish the necessary radiological controls for exiting the Radiological Controlled Area (RCA) and for entry into the OS '

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During this exercise, a radioactive plume was blowing directly over the SA Maintenance, security, and Emergency Response Organization (ERO) relief personnel walked directly into the plume when entering the protected area through the SAP. The potential radiological hazard to site personnel using the SAP was not considered by the 1SC or the OS During the exercise, the OSC dispatched four re-entry teams. Re-entry teams three and four were designated as priority one teams and assigned to perform an RCS leak

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search of the different elevations of the auxiliary building. Their mission was to identify the source of the known leak and stop the release. Both teams took an excessive

amount of time, over an hour each, to be dispatched from the OSC.

E Conclusion

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TSC - OSC communications were not fully effective in communicating irnportant plant conditions. The potential radiological hazard from a radioactive plume to site personnel using the SAP was not considered by the TSC or the OSC. High priority teams were not

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b.4 Emeroency Ooerations Facility Observations and Findinas Following the Alert declaration at 8:18 a.m., an announcement on the PA directed the activation of the ERFs. Required minimum staffing for the EOF was achieved at 9:05 a.m., at which time the EOF was considered " activated" (i.e., ready to assume its designated functions) Thus, the EOF was activated 47 minutes after the Alert declaration, meeting the established goal of 75 minute At 9:20 a.m., the EOF assumed control of the licensee's offsite radiation monitoring teams. At this same time, a reactor trip with subsequent complications justifiably delayed the EOF's assumption of dose assessment and communications activities from the TSC until 10:10 In general, command and control of EOF operations by the Recovery Manager (RM)

I was very good. Effective working relationships were observed between licensee staff and State and county representatives at the EOF. The EOF staff functioned efficiently

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and professionall The inspectors observed that by 9:40 a.m. (which was actually before the SAE declaration) the status board entitled "Offsite Protective Actions" listed the licensee's PARS as evacuation of zones A, D-5, E 5, F-5 and sheltering of zones D-10, E-10, F-1 Discussion with licensee exercise controllers disclosed that these PARS, written in black ink, were what would be recommended, based on current meteorological conditions, if a GE were declared; actual PARS, when issued, were to be written on the board in re This practice was known only to those personnel who had participated in recent drill Others at the EOF were perplexed by the information. Licensee representatives planned to clarify use of this status boar At 10:25 a.m., with a SAE classification in effect since 9:42 a.m., the licensee concurred in the State's desire to commence evacuation of the 5-mile radius around the plant. The RM indicated that this action was taken to demonstrate a unified effort by the licensee and local governmental agencies. However, this PAR was not developed in accordance with the Guidelines in FNP-0-EIP-9.0, " Emergency Classification and i Actions", Rev. 42, dated May 27,1997. Guideline 2 (for SAE) stated the following in Note 2 near the end of the procedure:

Only the protective actions specified by plant procedures should be recommended, unless there are obvious relevant factors (e.g.,

severe na; oral phenomena) that probably were not anticipated when the PARS were developed and that would make the standard PAR recommendations impractical, or obviously non-conservativ No such " obvious relevant factors" existed at the time the PAR was made. At the end of Guideline 2, step 1 stated that, for an emergency classification based solely on plant conditions and not on dose projections (as was tha case at the time in question), PARS

"are not required; however, they may (at the discretion of the ED) be made as a precautionary measure, depending on the severity of the plant condition." The licensee's PAR at SAE was not in accordance with the applicable procedural L

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requirements because it was issued solely to concur with the State's decision, and was not determined to be necessary based on plant conditions. The licensee's critique also identified this issue for follow-up and possible corrective actio The declarations of Alert, SAE, and GE were correct. However, the inspectors l questioned the licensee's procedure for determining the time at which an emergency is ,

to be declared. Procedure FNP-0-EIP-9.0 specified that the emergency declaration time l was to be recorded as the time at which the ED signed the initial Emergency Notification

form. This practice was inconsistent with NRC guidance found in various documents ,

I and had the potential to undermine the timeliness of emergency notifications. Licensee l management agreed that this procedural direction may be inappropriate and stated that corrective action would be considered to ensure that management expectations and NRC requirements were being me l Conclusion l

l The EOF functioned efficiently and professionally. Command and control of EOF operatione by the RM was generally very good. Procedural and performance issues were identified in the areas of emergency declaration timing and PAR decision-making and presentatio j

b.S Licensee Facility Critiaues Following the exercise, the licensee conducted facility critiques in which the players provided their own assessment of their performance and identified areas that needed improvement. The post-exercise critiques in the TSC, OSC, and EOF were observed to be thorough, open, and self-critical. The licensee controller / evaluator organization then conducted detailed discussions, reviewed documentation, and conducted interviews as required to develop their critique results. On September 11,1998, the Emergency Preparedness Director provided an excellent presentation to licensee management of the critique result Conclusi_o_n A thorough crit:que process was followed with a well-prepared management presentation that summarized the most significant exercise observation V. Manaaement Meetinas X1 Exit Meeting The Team Leader presented the inspection summary to licensee management on September 11,1998. The summary indicated the exercise was fully satisfactory.

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PARTIAL LIST OF PERSONS CONTACTED t-Licensee R. Badham, Site Supervisor, Safety Audit and Engineering Review

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T. Esteve, Supervisor, Planning and Contro!

R. Fucich, Manager, Engineering Support S. Fulmer, Manager, Plant Training and Emergency Planning i D. Grissette, Assistant General Manager, Plant Operations W. Lee, Emergency Planning Coordinator (corporate)

C. Nesbitt, Assistant General Manager, Plant Support -

M. Stinson, General Manager, Farley Nuclear Plant R. Vanderbye, Emergency Planning Coordinator (plant)

G. Wayniire, Manager, Technical Support INSPECTION PROCEDURES USED

> 82301: Evaluation of Exercises for Power Reactors P 82302: Review of Exercise Objectives and Scenarios for Power Reactors Attachment (5 pages):

Exercise Scope, Objectives, Scenario Narrative, and Time Line

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l 1 1998 FARLEY NUCLEAR PLANT EXERCISE CDJECTIVES SEPTEMBER 9.1998 ' Participating Organizations  !

Full Participation: Southem Nuclear Operating Company (SNC), Alabama Power Company (APC), State of Alabama, State of Georgia, Houston / Henry County, and Early Count I Partial Participation: State of Florida I Purpose -

l To meet the requirements of WCFR50, Appendix E,44CFR350.0 and NUREG-0654/ FEMA-REP-1, Re To conduct a full scale plume exposure drill which will include the mobilization of SNC, APC, State and Local personnel and resources adequate to verify the capability of l participating organizations to respond to an accident scenario requiring respons .

11 Southem Nuclear Operating Company and Alabama Power Company Objectives On-site Demonstrate that control room staff can assess the event, classify the event, take corrective measures to control the event and activate emergency response procedure . Demonstrate that plant staff can activate and staff the Technical Support Center (TSC) and perform eccident response activities including:

a. Dose Assessment b. Off-site notification and protective action recommendations c. Reclassification of emergency status d. Personnel Accountability for all personnel on-site e. Radiation Monitoring Team (RMT) Dispatch and Control (if required)

f. Site access control and admittance of assential personnel g. Dispatch and control of re-entry teams Demonstrate the capability to turn over Emergency Operations Facility (EOF)

functions to the EOF staff when the EOF is activated and staffed.

iy Demonstrate that plant staff can activate and staff the EOF and perform accident response activities including:

a. Assuming the dose assessment function and the RMT direction and control

, function from the TSC staff.

! b. Coordinating logistics, engineering functions, licensing functions and manpower I with the TSC and EOC.

I c. Preparing and coordinating news releases and activating' the News Media l Center (NMC).

' Emergency Communication Organization staff assigned to the EOF and NMC will be prepositioned in the Dothan Area to reduce transport time and thus allow for sufficient time to exercise the facilitie ATTACHMENT

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1990 FNP Exercise Objectives Page 2 i

' Demonstrate the capability to augment EOF staff with plant personne . Demonstrate the adequacy of the plant's communication system including:

a. Communication links to Corporate Emergency Operations Center (EOC)

b. News Media Center (NMC)

c. Interplant communications

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d. Communication links to state and local authorities Demonstrate the capability to perform radiological monitorin Off-Site Demonstrate that the corporate staff can be activated and staff the EO . Demonstrate that Corporate Headquarters Emergency Operations Center (EOC)

staff can provide support for:

a. Activation of facilities b. Logistics (as required)

c. Engineering and Licensing (as required)

d. Support organization notification e. Briefing of company management f. News release preparation Demonstrate that the Public Information Organization can respond to media and public inquir.es, establish a rumor control center, and issue and coordinate news release I State and Local O'ojectives See Attachment 1 (Any State or Local objective that cannot be demonstrated due to conditions inconsistent with the scenario will be demonstrated in a separate drill.)

(Reference Extent of Play Agreements between the States and FEMA.) Joint Objectives (SNC, APC, State of Alabama, State of Georgia, State of Florida, Houston / Henry County and Early County) Demonstrate that all parties can coordinate news releases and conduct a joint news conferenc Demonstrate that adequate technical information can be exchanged among involved

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agencie V Exerciso Limits l

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The plume exposure exercise will be conducted on September 9 and will begin prior to 8 A.M Central and ccaelude by 2:30 P.M. Central, obj099 "8 00CCO3

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EMERGENCY EXERCISE l NARRATIVE SUMMARY

SEPTEMBER 9,1998 I

The drill starts at 0800 with the Unit 1 Control Room staff maintaining reactor power at the current power level of 99.7%. A: 0805 radiation monitor alarms indicate that a vent stack release is occurring and that radiation levels in the Spent Fuel Pool area are i

elevated. At approximately 0808 a report from the SRO in charge of fuel movement indicates that a spent fuel assembly has been deformed due to apparent failure of the Spent Fuel Pool bridge controls. The Spent Fuel Pool area has been evacuated. The Control Room staff shculd follow the appropriate Annunciator Procedure guidance. ~

By approximately 9823 the Control Room staff should declare an ALERT emergency based on EIP-9.0, Guideline 3, step 3.1.d. Plant staff will start taking actions for an Alert

, emergency and the TSC, EOF, EOC, and ECO staffs will be activated. When offsite dose calculations are performed the results should indicate that the NOUE whole body noble gas release limits may have been exceeded but that levels remain less than the ALERT limits. The vent stack release ends at approximately 0923 when all fuel rod gap noble gases have been released from the dunaged spent fuel assembl Within 75 minutes of the Alert declaration, the TSC and EOF should have minimum staff in place ready to perform designated functions. The EOC in Birmingham will also have staff available to support plant operation At approximately 0920 the crew receives indications of increasing reactor power due to increasing steam flow. At approximately 0921 an automatic reactor trip occurs due to resultant overpower condition. All plant rystems function properly except that the #4 Main Turbine governor valve still indicates fully open. Reports from the Turbine Building indicate that a steam release did occur in the vicinity of the Unit 1 Main Turbine high pressure housing. The steam releue was isolated when the Main Turbine tripped and no injuries have been reporte The crew enters und begins following the procedural g"idance of EEP-0 and ESP-0.1. At approximately 0925 indications of increasing Containment sump level lead the crew to reference AOP-1 to deal with potential RCS leakage. By approximately 0930 the crew has indications of excessive RCS leakage and activity levels (DEI > 300 Ci/gm).

By approximately 0945 the Plant Staff should declare a SITE AREA emergency based

on EIP-9.0, Guide!ine 2.0, step 3.1. Once declared the plant staff should begin taking i actions for a Site Area emergency based on the EIPs to include activation of the Plant l Emergency Alarm, assembly, and Protected Area accountability.

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! At approximately 1036 the crew receives indications of high vibration, seal damage, and seal leakage on the l A Reactor Coolant Pump (RCP). Approximately one minute later NARRATIVE SUMMARY PAGE 1 of 2 1 000006

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the 1 A RCP trips on high current and the crew observes a rapid decrease in pressurizer level, a corresponding increase in Containment pressure, increasing Containment radiation levels and Safety Injection automatically actuates. The cause of the transient is a large break loss of coolant accident on the l A Reactor Coolant loop which causes fuel cladding failure to increase to approximately 80%. Containment pressure peaks at > 27 psig and Containment Spray does automatically actuat The crew reenters EEP-0 in response to the accident. All equipment works properly following the SI except the l A Componerd Cooling Water (CCW) pump does not start automatically and cannot be manually started. When investigated the l A CCW pump motor breaker is damaged and needs repair. The crew may realign the IB CCW pump to the B train to allow use of the B train LHSI and HHSI pump At 1045 indications of release from containment to the environment through the penetration room are observed. By approximately 1100, plant staff should declare a GENERAL EMERGENCY based on plant conditions per EIP-9.0, Guideline 1, step l 2.1. Dose projections, when performed, will also indicate the need to upgrade based on l sight boundary dose. Once declared the plant staff should begin taking actions for a General emergency per EIP-9.0 while the crew continues to stabilize the plant per the l procedural flow path of EEP-0, FRP-Z.1, EEP-1, FRP-P.1, ESP 1.3.

l l At approximately 1107 the Reactor Vessel Level Indication System (RVLIS) indicates

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that water level has been restored in the reactor vessel. By approximately 1140 the crew completes alignment of the Emergency Core Cooling System (ECCS) to the cold leg recirculation mode.

l The release path to environment is from the 139' Electrical Penetration Room via a failed l electrical penetration. It is anticipated that the actual leak source may not be identified l prior to the end of the scenario due to the high energy release tha't is taking place in the Electrical Penetration Room. It is also, therefore, not anticipated that the leak from containment can be stopped prior to the end of the exercise due to the identification l problems, high energy releases, and high dose rates in the area where work would need to be performed.

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i The News Media Center (NMC) will be activated and staffed by representatives from SNC, APC, the State of Alabama, the State of Georgia, the State of Florida, Houston / Henry County, and Early County. Media and public interest will be simulated l7 and news releases will be prepared and release The exercise will terminate once the radiation monitoring teams have tracked the plume, the EOF has been staffed and is perfonning EOF activities and the NMC has conducted a press conference. The termination will be coordinated with the States of Alabama, Georgia, and Florida if occurring prior to 1230 Central time to ensure that all objectives have been demonstrate NARRATIVE SUMMARY PAGE 2 of 2 000007

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FARLEY NUCLEAR PLANT RADIOLOGICAL EMERGENCY '

SCENARIO TIMELINE September 9,1998 L EOF TSCIEOF/EOC EOC STAFFED TSC ACTNATED SITE  :

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NMC MINtMALLY ALERT STAFFED GENERAL l l ! ! l l l l l l l l l l l l l '

l l l l l l l l l 0800 0900 1000 1100 1200 t3 SPENT FUEL ASSEMBLY 1A RCP HIGH INDICATIONS OF CTMT INDICATONS OF VIBRATON &

DE DAMAGED IN HtGH STEAM FLOW LEAKAGE INTO THE SPENT FUEL POOL SEAL LEAKAGE PENETRATION ROOM ,

I l I i VENT STACK REACTOR TRP 1A RCP VENT STACK RELEASE BEGtNS NE TOR T RELEASE BEGINS -

H p M TO STNN AUTOMATIC SAFETY ON THE M ME ttOECTON DUE TO HIGH l CTMT PRESSURE CREW BEGINS TO RECENE l NOTES:

INDICATIONS OF POTENTIAL 1A CCW PUMP RCS LEAK INS 0E CTMT FAILS TO START UNIT 1 IS ACCIDENT UNIT C l  !

VENT STACK RELEASE ENDS INDICATONS OF C WHEN GAP RELEASE FROM DAMAGED HIGH RCS ACTMTY C FUEL RODS COMPELTED AND > 120 GPM RCS LEAKAGE

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