IR 05000352/1986007

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Emergency Preparedness Insp Repts 50-352/86-07 & 50-353/86-08 on 860402-04.No Violations Noted.Major Areas inspected:full-scale Emergency Exercise & Accountability Drill Conducted on 860403
ML20198D340
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 05/07/1986
From: Harpster T, Hawxhurst J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20198D309 List:
References
50-352-86-07, 50-352-86-7, 50-353-86-08, 50-353-86-8, NUDOCS 8605230222
Download: ML20198D340 (8)


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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report Nos. 50-352/86-07; 50-353/86-08 Docket Nos. 50-352/353 License Nos. NPF-29/CP-PR-107 Category C

Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name:

Limerick Generating Station Inspection At:

Limerick, Pennsylvania Inspection Conducted: Ayril 2-4, 1986

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Inspectors:

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st, Team Leader date B. Hillman, NRC/RI G. Kelly, Sr. Resident Inspector R. Meck, NRC/HQ D. Vito, NRC/RI H. Williams, Resident Inspector, Peach Bottom Approved by:

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f T. L. H/rpster,, Chief

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Inspection Summary:

Inspection on April 2-4,1986 (Cor.bined Report Numbers 50-352/86-07; 50-353/86-08)

Areas Inspected: Routine unannounced emergency preparedness inspection to observe the licensee's full-scale emergency exercise performed the afternoon of April 3, 1986 and accountability drill the morning of the same day.

Results: No violations were identified.

The licensee's emergency response actions demonstrated during the exercise were adequate to provide appropriate protective measures for the health and safety of the public. Three open items were closed, one was modified and one new item open.

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DETAILS 1.

Persons Contacted

  • J. A. Basilio, Administrative Engineer
  • E. D. Cosgrove, Shift Superintendent
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L. Daltroff, Vice President - Electric Production

  • J. F. Franz, Assistant Supervisor
  • R. H. Geiger, Senior Energy Information Representative
  • R. L. Harper, Special Assistant to Vice President Corporate Commission
  • A. J. Hogan, Staff Engineer

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  • J. S. Kemper, VP, Engineering and Research W. Knapp, Director, Radiation Protection
  • G. M. Leitch, Station Superintendent
  • R. H. Logue, Superintendent Nuclear Service
  • G. J. Madsen, ISEG Engineer
  • C. J. McDermott, Management Public Information
  • F. H. Pennell, Energy Information Representative
  • M. J. Roache, LGS Site EP Coordinator
  • J. W. Spencer, Superintendent Services
  • J. J. Tucker, PBAPS Site EP Coordinator
  • W.' T. Ullrich, Superintendent Nuclear Generation The inspectors also observed several licensed operators, health physicists, administrative and training personnel.
  • Denotes those present at the exit interview.

2.

Accountability Drill The Limerick Generating Station Unit 2 accountability drill was conducted on April 3, 1985 from 9:55 a.m. until 10:30 a.m.

2.1 Background The ASLB left final resolution of whether PECo can account for "all" onsite personnel to future emergency preparedness exercises (Second PID, 20 NRC).

The Regional staff, after holding discussions with the licensee, concluded two drills were necessary to fully demonstrate an adequate assembly and accountability capability. A representative sample of both Unit 1 onsite personnel and Unit 2 construction personnel were to be accounted for 'and evacuated. The second drill would accommodate later growth of a larger number of Unit 2 construction personnel.

The results of the first drill, conducted on July 17, 1985 (Inspection Report Nos. 50-352/85-31; 53-353/85-08) were found to be satisfactory. Within the last few months, Unit 2 construction site personnel have reached a point

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where the second drill was deemed necessary. The drill was scheduled the same day as the annual emergency preparedness exercise. No additional growth in the number of Unit 2 site construction personnel is anticipated.

2.2 Pre-drill Activities Prior to the accountability drill, two NRC Region I inspectors met with licensee representatives to discuss the scope of the drill.

Approximately 250 persons were scheduled to participate.

This number was a representative sample of all workers expected onsite during an average day shift on the Unit 2 site.

2.3 Drill Observation The licensee preceded the drill with an announcement over the public address system explaining the purpose and scope.

The drill commenced with the evacuation siren sounding at 9:55 a.m. followed by directions for all participants. The NRC observers noted that 257 individuals, in accordance with the Bechtel evacuation procedure, assembled and were accounted for in 19 minutes.

The inspectors found that the public address system did not appear to provide adequate coverage of the Unit 2 construction site area. This problem was also identified by the licensee. However, alternate means were also employed such as area alerting with bull horns.

In addition, the method to account for small groups on the Unit 2 site, i.e. surveyors, may not be comprehensive in that although a location is established for assembly, a roster may not be available to the group leaders for these individuals.

2.4 Licensee Critique A critique was held after the accountability drill with the Bechtel site safety manager. Observers identified problem areas as discussed above and the safety manager acknowledged that he would followup and take actions as necessary to provide correction for the improvement items. He also stated that presently several means are used to notify workers in addition to the public address system. These are: tele-phone calls to supervisors, area alerting with bull horns, pocket beepers and security patrols with radios.

3.0 Emergency Exercise The Limerick Generating Station full-scale exercise was conducted on April 3, 1986 from 2:30 p.m. until 11:15 p.m.

3.1 Pre-exercise Activities

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Prior to the exercise, NRC Region I representatives had telephone discussions with licensee representatives to review the scope and content of the exercise scenario. As a result, minor revisions were made by the licensee of certain scenario data.

In addition, NRC observers attended a licensee briefing for licensee controllers and observers on April 2, 1986, and participated in the discussion of emergency response actions expected during various phases of the scenario.

The exercise scenario included the following events:

Fire requiring offsite assistance;

Ground in 11 unit aux. bus, resulting in a Reactor (Rx) Scram;

HPCI fails, Bypass valves fail open and Rx water level drops

to -129 inches; Rx recirc. pump seal fails increasing drywell pressure and

temperature; Injured and contaminated individual;

LOCA with loss of all ECCS; and,

Release of radioactivity offsite

The above events caused the activation of all of the licensee's emergency response facilities.

3.2 Exercise Observation During the conduct of the licensee's exercise, NRC team members made detailed observations of the activation and augmentation of the emergency organization; activation of emergency response facilities; and actions of emergency response personnel during the operation of the emergency response facilities. The following activities were observed:

(1) Detection, classification and assessment of scenario events; (2) Direction and coordination of the emergency response; (3) Notification of licensee personnel and off-site agencies; (4) Communications /information flow, record keeping, and sample distribution; (5) Technical support to operations;

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(6) First Aid and rescue; (7) Off-site support and protective action recommendations; and, (8) Security and access controls.

The NRC team noted that the licensee's activation and augmentation of the emergency organization and activation of the emergency response facilities were generally consistent with their emergency plan and implementing pro-cedures. The team also noted the following areas where the licensee's activities were thoroughly planned and efficiently implemented:

The scenario format, conduct of initial briefing to controllers and

evaluators and conduct of the critique were organized and presented in an effective manner. Appropriate changes were made to the scenario to satisfy NRC concerns.

Operations personnel recognized General Emergency conditions

(Loss of 2 fission product barriers with potential loss of the third) with a LOCA, loss of ECCS and a failed purge valve at 1855. This occurred approximately one hour before more specific, parameter-related EAL conditions were met.

Fire team response, status reports and overall communications

were effective and well controlled.

The control room received periodic updates from the technical

support center and clear delineation of responsibility and authority were evident in the transfer of information.

The Emergency Director proved himself very knowledgeable of

plant design which facilitated quick comprehension of system problems.

The Site Emergency Coordinator (SEC) was aware of potential

off-site releases based on status of plant conditions and expeditiously worked with the E0F staff and State Officials on protective. action recommendations.

The NRC Team findings in areas that were repeat findings from last years exercise include:

The Operational Support Center (OSC) was crowded (50-352/

85-17-02(a)),and; The handling of the medical emergency could have been done in a

more ef fective manner (50-352/85-17-02(c)).

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The first concern, OSC being very crowded, is based on the observer noting that (1) logging in/out of OSC personnel is not always followed; (2 ) communication between players is difficult; (3) plant status boards are not kept updated; and (4) loss of continuous accountability by persons using the back door of facility. The licensee has also identified this as a problem in other drills and exercises, and committed to examine potential solutions in the near future.

The second concern, handling of a contaminated (injured) individual was again identified during the licensee critique. The licensee has committed to reviewing the training program, make appropriate i

changes, and reschedule another drill to address this concern.

The NRC Team found several areas which require additional licensee attention.

Some of these were noted by the licensee in their self-critique.

ENS communicator was used to perform EOF call-list after NRC

red phone notification, even though his position is dedicated to communicating with the NRC. Also, the licensee used two additional communicators to make other notifications. These communicators may or may not be available, but were shown to be necessary.

Communications and information were not clear and somewhat

confusing following the reactor scram. This was evidenced by (1) Rods were not immediately verified (to supervisors) as full-in for 4 minutes, (2) ADS was not inhibited within required time, and (3) loss of certain ECCS not reiterated.

Damaged equipment status was not clearly known, such as turbine

BPVs, HPCI, RHR/LC pumps and the purge valve 115. A status board may be helpful.

Not all major events were announced, i.e. the drop in reactor

water level was not announced for 5 minutes af ter the report was received. Briefings were very technical, they appeared to revolve around set times versus key events.

No control point was established outside TSC for contamination.

  • Technical briefings would have been more informative if less

jargon or system ID numbers were used. One line diagrams with flow paths may be helpful.

State representatives tended to interrupt more important

conversations, they appeared to distract the ED. A licensee individual functioning as state liaison officer may be useful to interface with the state in the TSC and EO.

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The OSC was very crowded as evidenced by: difficulty in internal

communications; loss of continuous accountability by persons using an alternate exit; log in/out procedure not always followed; plant status boards not kept up, and; overflow OSC area needed.

Initial site accountability of Unit 1 personnel took 35

minutes.

Security Search and Rescue located all personnel in 57 minutes.

The first aid group quickly responded to the medical emergency.

  • However, it took over 10 minutes before any medical attention was given to the victim. An attempt was made to'stop the bleeding from a simulated compound fracture. No vital signs were initially taken even though the victim was pale and appeared to be in shock. The observer later noted that it had taken over an hour before the victim was brought t'o the ambulance (86-07-01).

KI should be immediately available to field monitoring teams.

  • Reports on ground deposition of radionuclides assayed should be

available as soon as practical after a major release.

Inspection findigs during this exercise demonstrates that certain concerns. identified in previous reports as open items did not re-occur, and therefore, are closed. These items include 85-17-01, 03, and 04, concerning exercise observations in the EOF, TSC, and OSC.

Item 85-17-02 is modified to reflect only the problems discussed above on the OSC. One new item (86-07-01) on the handling of an injured / contaminated individual was opened.

3.3 Exercise Critique The NRC team attended the licensee's po.t-exercise critique during which a panel of six observers presented strengths and improvement items which were detected by the evaluators.

In addition, the NRC team members were given a copy of the licensee's findings.

4.0 Exit Meeting and NRC Critique Following the licensee's self-critique, the NRC team met with the licensee representatives listed in Section 1 of this report. The team leader sum-marized the observations made during the exercise and discussed the areas described in Section 2.2 and 3.2 of this report.

The licensee was informed that no violations were identified. Although there were areas identified which require additional attention, the NRC team determined that within the scope and limitations of the scenario, the

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licensee's performance demonstrated that they could implement their Emergency Plan and Emergency Plan Implementing Procedures in a manner which would adequately provide protective measures for the health and safety of the public.

Licensee management acknowledged the findings and indicated that appro-priate action would be taken where necessary.

At no time during this inspection did the inspectors provide any written information to the licensee.