IR 05000352/1993019
| ML20058A471 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/10/1993 |
| From: | Keimig R, David Silk NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20058A465 | List: |
| References | |
| 50-352-93-19, 50-353-93-19, NUDOCS 9312010095 | |
| Download: ML20058A471 (11) | |
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U. S. Nuclear Regulatory Conunission Region I Docket / Report:
50-352/93-19, 50-353/93-19
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Licenses:
Philadelphia Electric Company (PECO)
Post Office Box 195 Wayne, Pennsylvania 19087-0195 Facility Name:
Limerick Generating Station, Units 1 & 2 Dates:
September 28-30,1993 Inspectors:
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"//oN S D. Silk, Senior Emergency Preparedness Specialist date J. Lusher, Emergency Preparedness Specialist A. Mohseni, Emergency Preparedness Specialist, NRR/PEPB T. Eastick, Resident Inspector, Limerick N. Perry, Senior Resident Inspector, Limerick R. Fuhrmeister, Senior Allegation Coordinator Approved:
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- '/o -f 3 jlt. Keimig, Chie?,~Emerpdney Preparedness Section date Division of Radiatior[Sdfety and Safeguards v
SCOPE Announced inspection of the annual, full-participation emergency preparedness exercise.
RESULTS Overall, the on-site response to the exercise scenario was very good. The crew corrvtly identified, classified, and declared the events using the appropriate Emergency Action levels (EALs) in a timely manner. Overall exercise strengths were communications and command and control. No exercise weaknesses were identified. Identified areas for potential improvement included better responsiveness to reported iodine doses and upgrading the common dose model calculator to provide accurate protective action recommendations.
9312010095 931112 PDR ADOCK 05000352 O
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TABLE OF CONTENTS l
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1.
Persons Contacted
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2.
Scenario Planning
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Exercise Scenario............
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Activities Observed................................
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Exercise Finding Classifications............................... 4 l
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Simulator Control Room (SCR).....................
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Technical Support Center (TSC).
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Operations Support Center (OSC)
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i Emergency Operat'uns Facility (EOF)
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9.1 Command and Control
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i 9.2 Dose A ssess ment..................................
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Overall Response Timing 9-
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Licensee Critique..................
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Conclusions..........................................10 13.
Ex i t Meeti n g........................................
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DETAILS 1.
Persons Contacted The following licensee personnel attended the exit meeting on September 30,1993.
C. Adams, Site Support B. Alejnikov, Emergency Preparedness M. Berner, Security R. Brown, Emergency Preparedness J. Backes, Corporate and Public Affairs S. Baker, Station Support R. Bohner, Training B. Boyce, Plant Manger J. Clymer, Emergency Preparedness B. Faulkner, Emergency Preparedness E. Frick, Chemistry J. Gerhart, Station Support D. Helwig, Vice President Limerick V. Hydro, Simulator Support J. JanKauskas, Emergency Preparedness D. Lerch, Emergency Preparedness S. Keenan, Emergency Preparedness R. Kinard, Emergency Preparedness A. Mantey, Nuclear Services R. Mandik, Emergency Preparedness D. Neff, Regulatory A. Parducci, Emergency Preparedness G. Paton, Operations R. Ruffe, Training B. Semple, Security W. Shych, Corporate Emergency Preparedness M. Shuler, Emergency Preparedness D. Smith, Senior Vice President Nuclear W. Waddington, Corporate and Public Affairs D. Weaver, Simulator Support L. Weikel, Security B. Winters, Simulator Support The inspectors also interviewed and observed other licensee personne _
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2.
Scenario Planning
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Exercise objectives were submitted to NRC Region I on June 24, 1993. The scenano was submitted to the NRC on July 28,1993. The objectives and the scenario were reviewed by the
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NRC and the final scenario adequately tested the major portions of the Emergency Plan and Implementing Procedures.
On September 28, 1993, the NRC team attended a licensee briefing on the scenario. The licensee stated that certain emergency response activities would be simulated and that controllers would intercede in exercise activities to prevent disrupting plant activities. Also, several minor modifications to the scenario were presented to the NRC.
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Exercise Scenario The scenario included the following simulated events:
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Unit I has been at 100% power for the last 300 days. The 1A and 1D Residual Heat Removal (RHR) Pumps are out of service (OOS). The 1C Standby Liquid Control (SLC)
Pump is OOS. Unit 2 has been at 100% power for 150 days and all equipment is operable. Spent fuel is being shuffled in the Unit I spent fuel pool.
2.
The Unit 2 Process Computer has been unavailable for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> due to a virus.
(Unusual Event)
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3.
A spent fuel bundle drops from the grapple and falls on other spent fuel, resulting in refuel floor isolation due to high radiation indicated on the vent exhaust monitor. (Alert)
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Control Rod 30-19 drifts in from its full out position. On the subsequent effort to develop a symmetric rod pattern, the rod drive control system fails to allow any rod motion.
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The B Loop Recirculation Line develops a 50 GPM leak and the line eventually ruptures, resulting in a loss of coolant accident (LOCA) (Site Area Emergency)
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Injection valve control power fails due to a blown fuse, preventing injection from the 1 A and IC Core Spray Pumps.
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The IC Low Pressure Coolant Injection (LPCI) Pump breaker trips open.
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The ID Core Spray Pump shaft shears when the pump receives a start signal.
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The IB LPCI injection valve breaker trips open. Only B Core Spray Pump injects, but cannot maintain reactor level. (General Emergency)
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Suppression pool purge line leaks due to a failure of an air operated valve and the incomplete seating of a motor-operated valve. This allows a radiological release to occur.
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Radiological release secured when damage repair team closes one of the suppression pool purge line valves.
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Exercise termination.
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Activities Observed The NRC inspection team observed the activation and augmentation of the Emergency Response Facilities (ERFs) and the actions of the Emergency Response Organization (ERO) staff. The following activities were observed:
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Selection and use of control room procedures.
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Detection, classification, and assessment of scenario events.
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Direction and coordination of emergency response.
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Notification of licensee personnel and off-site agencies.
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Communications /information flow, and record keeping.
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Assessment and projection of off-site radiological doses.
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Protective Action Recommendations (PARS).
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Provisions for in-plant radiation protection.
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Provisions for communicating information to the public.
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Accident analysis and mitigation.
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Accountability of personnel.
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Post-exercise critique by the licensee.
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Exercise Finding Chissifications Inspection findings were classified, where appropriate, as follows:
Exercise Streneth: a strong positive indicator of the licensee's ability to cope with abnormal plant conditions and implement the emergency plan.
Exercise Weakness: less than effective Emergency Plan implementation which did not, alone, constitute overall response inadequacy.
orca for Potentini Improvement: an aspect which did not significantly detract from the licensee's response, but which merits licensee evaluation for possible corrective action.
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6.
Simulator Control Room (SCR)
The SCR crew's responses to simulated equipment problems were prompt and effective. The crew quickly recognized abnormal conditions such as the failure of the IB LPCI pump and the 1 A Core Spray System injection valves to open. Overall, procedure usage was strong. In particular, the implementation of trip procedures and contingency procedures (T-200 series)
caused the drill scenario to be modified to include additional failures to ensure that the reactor core became uncovered. The additional failures were needed since the crew was effective in maintaining reactor water level above the top of active fuel.
The Shift Manager (SM) and Shift Supervisor (SS) exercised excellent command and control throughout the scenario. The SS effectively established response priorities for equipment failures and used a white board to list those priorities. Good teamwork was demonstrated on the part of the crew members. The SS controlled the mitigation of the events, which allowed the SM to handle the communications between the SCR and the Technical Support Center (TSC).
Communications among crew members and with the TSC were good despite the difficulties with the speaker phone operation. The SM correctly classified the Unusual Event (UE) and the Alert.
NRC notifications by the shift were timely. (For details about the sequence of events refer to Section 10, Overall Response Timing.) Both the SS and the SM used frequent shift briefings to ensure the crew understood what events had occurred and the planned mitigation strategy to i
deal with each event.
The following SCR strengths were observed:
SCR command and control.
Prompt recognition of abnormal plant conditions.
Use of plant contingency procedures.
Frequent shift briefings.
- No exercise weaknesses or areas for improvement were observed.
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Technical Support Center (TSC)
The TSC was staffed and activated in a timely manner. The TCS is activated at an Alert declaration. However, the Emergency Director (ED) arrived at the TSC prior to the Alert declaration. The NRC considered this to be an isolated case of poor drillmanship on the part of the ED. Overall, the ED exhibited strong performance. The ED conducted a good turnover from the Shift Manager and ensured that his staff was briefed prior to activation. The ED exhibited strong command and control, and maintained good communications with the SCR and
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the Emergency Operations Facility. During regularly held meetings and briefings, the ED ensured that priorities were properly established and understood by all. The TSC status boards were frequently and appropriately updated throughout the exercise to keep personnel informed.
The use of an assistant ED was excellent in that he removed some of the administrative and communication burdens from the ED. However, the assistant ED is not a proceduralized position and is therefore not required to be filled. Practicing with an assistant ED in an exercise may be detrimental if the assistant ED is not present in an actual emergency. The NRC considered the assistant ED as a positive contribution in the ERO's response to the events of the
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exercise, however, the official status of the position merits licensee consideration (IFI 50-352,353/93-19-01).
Event classifications were correct and timely, and notifications to offsite officials were also timely. But in one instance, after the declaration of the Site Area Emergency, the declaration
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was not announced to plant personnel via the Public Address System; however, the associated site evacuation was properly announced.
The NRC noted the presence and overview oflicensee management personnel during the course of the exercise at the TSC and other ERFs. Though not participating in the exercise, their r
presence may cause minor distractions in that they were not specifically identified (e.g., by a
colored shirt) as an observer or controller.
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The following TSC strengths were observed:
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ED command and control.
- No exercises weaknesses were identified.
The following area for potential improvement were identified:
The Site Area Emergency was not announced to the site over the plant PA system.
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Operations Support Center (OSC)
Staffm' g and activation of the OSC was completed in a timely manner after the announcement of the Alert declaration. Personnel tracking and supervision were good. The OSC personnel were logged into the computer while their names and remaining quarterly dose were recorded on a status board. The status board was used to track the location of personnel, expected return times, and allowable doses. When the expected return times were exceeded, actions were taken to locate the individuals and determine the reasons for the delays. New expected return times were then established. The OSC Coordinator routinely briefed personnel on plant status, and i
broadcast the TSC briefings to personnel in the OSC. Further, the OSC Coordinator consulted with the plant survey group before dispatching teams to determine the best routes to use in the plant to minimize the worker doses. Each team was briefed on thejob they were to perform,
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the route to take, and expected radiological conditions. When it was expected that high dose rates would be encountered in the Reactor Enclosure, teams were appropriately detained until
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dose extensions were obtained to avoid dispatching the teams and then having them return for
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the dose extensions when the lower dose limit was reached.
For those actions which were out of the ordinary (such as the manual actuation of motor control center contactors, or lining up the refueling floor pumps to take suction from the CST and discharge to the reactor vessel), the appropriate pages from the procedure were sent from the TSC by facsimile, or a temporary procedure was generated specifically for the job.
The following OSC strengths were observed:
OSC coordinator command and control.
- Personnel tracking and ALARA considerations.
- Frequent plant status briefings.
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No exercise weaknesses or areas for improvement were identified.
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Emergency Operations Facility (EOF)
l The EOF was staffed in a timely manner. The Alert was declared at 1608 hours0.0186 days <br />0.447 hours <br />0.00266 weeks <br />6.11844e-4 months <br />, the auto-notification system was activated at 1620 hours0.0188 days <br />0.45 hours <br />0.00268 weeks <br />6.1641e-4 months <br />, the EOF was staffed at 1730 hours0.02 days <br />0.481 hours <br />0.00286 weeks <br />6.58265e-4 months <br />, and control
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was assumed at 1755 hours0.0203 days <br />0.488 hours <br />0.0029 weeks <br />6.677775e-4 months <br />. The EOF is not required to be staffed until one hour after the declaration of the Site Area Emergency, which occurred at 1830.
The Emergency Response Manager (ERM) demonstrated good command and control and maintained a very good overview of plant conditions.
He performed well in evaluating mitigative actions and kept the EOF staff focused on the proper priorities in assisting the TSC and plant personnel in accident mitigation.
The ERM was very active in ensuring that the Commonwealth of Pennsylvania representatives were kept well informed of plant conditions and mitigating actions. The ERM held several briefings with the Commonwealth of Pennsylvania representatives to keep them up-to-date on activities and to determine if all of their concerns were being addressed. Also, there was a good j
briefing given to inform the Commonwealth of Pemisylvania representatives of the Protective Action Recommendations (PARS) and the bases for the recommendations.
The EOF Dose Assessment Group (DAG) obtained meteorological information and communicated effectively with the engineering staff to comprehend plant conditions and relay questions relevant to dose assessment. The status boards were maintained current so that they
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could be used effectively by Pennsylvania representatives.
The DAG leader was very knowledgeable, proactive and demonstrated familiarity with dose assessment tools and their limitations.
The licensee assessed plant status and developed reasonable PARS using their current procedures.
The licensee also was aware of the protective actions taken by offsite authorities, and was responsive to their questions and needs, as evidenced by the briefings and conferences held with Pennsylvania representatives.
The following EOF strengths were identified:
ERM command and control.
- Interaction with Pennsylvania and local officials.
- No weaknesses were identified.
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9.1 EOF Areas for Potential Improvement l
9.1.1 Responsiveness to Reported Iodine Air Concentrations i
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The DAG correctly assessed the offsite consequences of the fuel handling accident and the subsequent LOCA. Environmental sampling teams were deployed and environmental data were collected. The results of environmental monitoring were used to determine the need to adjust the source term and confirm the release pathway.
However, in one case an iodine air concentration of 1.6 E-5 microCi/cc posted on the status board was not evaluated to determine its validity or reconciled with the known source term and flow path. This level of iodine air concentration, if validated, should have led to KI (potassium iodide) considerations for
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f emergency workers onsite and offsite. This omission was recognized by the DAG staff afterwards. The licensee also identified this concern and corrective actions are being planned.
The licensee's responsiveness to iodine air concentrations will be observed in future exercises (IFI 50-352,353/93-19-02).
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9.1.2 Upgrading the PAR Computer Program Dose assessment functions were performed well. "What if" scenarios were run and explained well to management and offsite representatives. The DAG promptly and correctly projected the g
offsite dose when the major release started.
The licensee and the Commonwealth of Pennsylvania had determined that the correct protective action based on plant conditions was to evacuate. Dose projections were then used to confirm the adequacy of the PARS. However, the PARS that were generated by a computer program associated with a dose of 26 R/hr at the site boundary were stated as " shelter 0 to 10 miles" if the release duration was four hours, and
" evacuate 0 to 10 miles" if the duration was 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The dose assessment of about 100 R over four hours at the site boundary, and about 600 R over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> should have led to further
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discussion about the adequacy of the PAR to shelter. This issue was recognized by the DAG leader, but not adequately addressed by management. This concern was also identified by the licensee and corrective actions are being planned. The upgrading of the PAR determination method will be reviewed during a future inspection (IFI 50-352,353/93-19-03).
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Overall Response Timing Unless not applicable (N.A.), the following table lists the times of significant exercise occurrences and actions for Unusual Event (UE), Alert (Al), Site Area Emergency (SAE), and General Emergency (GE) classifications,. These include simulated emergency occurrence, recognition, declaration, State and local (S & L) notifications, NRC notification, Emergency Response Organization (ERO) callout, and Emergency Response Facility activation and full staffing. This tabie shows timely performance by the ERO.
RFEPONSE PERFORMANCE TIMETABLE MILESTONE UE Al SAE GE Occurrence 1505 1601 1825 2001 Recognition 1507 1602 1825 2001 Declaration 1508 1608 1830 2002
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S & L Notifications 1526 1619 1835 2012 NRC Notification 1512 1617 NA 2013 ERO Callout NA 1620 NA NA TSC Activation NA 1655 NA NA TSC Fully Staffed NA 1650 NA NA OSC Activation NA 1646 NA NA OSC Fully Staffed NA 1630-NA NA EOF Activation NA 1755 NA NA EOF Fully Staffed NA 1730 NA NA PAR Issued NA NA NA 2006 i
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Licensee Critique On September 30,1993 the NRC team attended the licensee's exercise critique. The exercise lead controllers for each facility summarized the licensee's observations. The licensee's critique was assessed as thorough and it identified the NRC's areas for potential improvement, including the areas for potential improvement noted in Sections 9.1.1 and 9.1.2. No licensee critique inadequacies were identified.
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Conclusions Overall, the licensee's performance was assessed as very good. Player drillmanship was generally good throughout the seven hour exercise.
Good communications and effective command and control were demonstrated throughout the exercise in all of the ERFs to prioritize and mitigate simulated equipment problems. The assistant ED in the TSC was considered to be a positive contribution to the licensee's emergency response efforts. However, the iodine oversight issue and the incorrect PAR were items identified as meriting licensee attention.
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Exit Meeting The inspectors met with the licensee personnel listed in Detail 1.0 at the conclusion of the inspection to discuss the scope and findings as mentioned above. The licensee acknowledged the findings and stated that they would be reviewed for appropriate corrective action.
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