IR 05000382/1993028

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Insp Rept 50-382/93-28 on 931025-28.Exercise Weakness Noted. Major Areas Inspected:Licensee Performance & Capabilities During Annual Exercise of Emergency Plan & Implementing Procedures
ML20058B883
Person / Time
Site: Waterford Entergy icon.png
Issue date: 11/16/1993
From: Murray B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20058B860 List:
References
50-382-93-28, NUDOCS 9312020267
Download: ML20058B883 (13)


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i APPENDIX U.S. NUCLEAR REGULATORY COMMISSION.

REGION IV

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Inspection Report:

50-382/93-28 Operating Licensed: NPF-38

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Licensee:

Entergy Operations, Inc.

P.O. Box B i

Killona, Louisiana 70066

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Facility Name: Waterford Steam Electric Station, Unit 3 Inspection At: Killona, Louisiana Inspection Conducted: October 25-28, 1993 Inspectors:

D. Blair Spitzberg, Ph.D., Emergency Preparedness Analyst

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(Co-Team Leader)

Wesley L. Holley, Senior Radiation Specialist (Co-Team Leader)

Ryan E. Lantz, Reactor Engineer Blaine Murray, Chief, Facilities Inspection Programs Section James B. O'Brien, Emergency Preparedness Analyst, Office of Nuclear Reactor Regulation

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Accompanying Personnel:

Larry L. Sherfey, Battelle Pacific Northwest Laboratories

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Approved:

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b Blaine Murray, Chief, ilities D/te

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Inspection Programs ction Inspection Summary Areas Inspected:

Routine, announced inspection of the lir.ensee's performance and capabilities during an annual exercise of the emergency plan and

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implementing procedures. The team observed activities in the Control Room, Technical Support Center, Operational Support Center, and the Emergency i

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Operations Facility.

Results:

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i The Control Room staff performed well during the exercise demonstrating

good teamwork and command and control (Section 2.1).

The Technical Support Center was staffed and activated promptly, and the

response staff _ appeared to understand their duties and responsibilities.

  • An exercise weakness was identified concerning the technical staff not 9312O20267 931124 PDR ADOCK 05000382 G

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consequences of the accident. A second exercise weakness was identified for problems involving the issuance of Protective Action Recommendations (Section 3.1).

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The Operational Support Center performed their emergency response

activities in an effective, professional, and timely manner. The facility supervisor maintained excellent command and control.

Response personnel were well trained and thoroughly familiar with their assigned.

responsibilities. Some problems were noted with the facilities and lack of challenges in the exercise scenario (Section 4.1).

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The exercise weakness in the area of poor assessment of plant conditions

and mitigation strategies referenced above (Section 3.1) also involved Emergency Operations Facility activities.

In general, Emergency Operations Facility functions were performed effectively during the exercise (Section 5.1).

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The scenario and exercise preparation were sufficient to demonstrate the

exercise objectives (Section 6.1).

The inspection team determined that the licensee's critique process was

excellent and had properly identified and characterized weak areas t

(Section 7.1). '

Summary of Inspection Findings:

Exercise Weakness 50-382/9328-01 was opened (Sections 3.1 and 5.1).

  • Exercise Weakness 50-382/9328-02 was opened (Section 3.1).
  • Exercise Weakness 50-382/9213-01 was closed (Section 8.1).

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Attachment:

Attachment 1 - Persons Contacted and Exit Meeting

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DETAILS i

1 PROGRAM AREAS INSPECTED (82301)

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Tne licensee's annual emergency preparedness exercise began at 7 a.m. on October 26, 1993. The exercise was a full offsite participation exercise and was evaluated by the Federal Emergency Management Agency. The NRC did not participate in the exercise.

Initial conditions for the exercise included the plant having been operating at 100 percent power for the past 60 days and was at the end of core life. Also, the Reactor Coolant System had a leak rate

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calculated to be 3.8 gallons per minute.

Major events in the scenario included a reactor coolant system leak which could not be isolated and increased until fuel damage occurred causing radiation levels to increase in containment. During the reactor coolant system leak, the "A" containment fan cooler and the "A" essential chiller failed. Also, a loss of offsite power occurred, the reactor tripped, and the

"A" emergency diesel generator became inoperable. A penetration leak

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increased the annulus pressure and caused cycling of the shield building i

ventilation system from recirculation to exhaust, developing a release pathway to the plant stack. Dose assessment personnel performed offsite dose calculations resulting in the issuance of offsite Protective Action Recommendations.

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The inspection team identified various concerns during the course of the exercise; however, none were of the significance of a deficiency as defined in 10 CFR 50.54(s)(2)(ii). Each observed concern can be characterized as an exercise weakness or as an area recommended for improvement. An exercise weakness is a finding that a licensee's demonstrated level of preparedness could have precluded effective implementation of the emergency plan in the event of an actual emeigency.

It is a finding that needs licensee's corrective action. Other observations are documented which did not have a significant negative impact on overall performance during the exercise but still could be evaluated and corrected as determined appropriate by the licensee.

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2 CONTROL ROOH (82301-03.02.b.1)

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The inspection team observed and evaluated the Control Room staff as they performed tasks in response to the exercise. These tasks included detection and classification of events, analysis of plant conditions, implementation of corrective measures, notificaticas of offsite authorities, and adherence to

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the emergency plan and implementing procedures.

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2.1 Discussion The Control Room simulator was used to initiate the exercise.

Dynamic simulation of the exercise was accomplished throughout the exercise.

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H Overall, the Control Room staff performed well during the exercise. The shift supervisor and the Control Room supervisor provided good direction of operating staff activities. The shift supervisor anticipated potential

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-4-t contingency actions and prepared the staff to conduct those actions on several occasions. The shift supervisor periodically conducted control board

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I walkthroughs with the Control Room supervisor to keep current on system status, and teamwork and comunications within the Control Room were observed

as strengths. Also, the offsite notifications performed by the Control Room

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were correct and made in a timely manner.

r One area of improvement was noted by the inspectors in the Control Room. The Control Room staff was slow to identify and comunicate to the Technical Support Center that shield building ventilation was associated with the

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radiation release path. Numerous indications in the Control Room such as annulus pressure and frequency of shield building ventilation cycling should have cued the operators earlier of this abnormal condition.

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One simulator infidelity was noted by the inspectors and licensee evaluators.

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The "B" train of shield building ventilation displayed erroneously high demister outlet temperatures. At one point, the "A" train indicated 200 degrees Fahrenheit, while the "B" train indicated 335 degrees Fahrenheit.

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This problem was documented for followup by the licensee and did not

significantly impact the course of the exercise.

2.2 Conclusion j

The Control Room staff performed well during the exercise demonstrating good teamwork and comand and control.

TECHNICAL SUPPORT CENTER (32301-03.02.b.2)

The inspectors observed the operation of the Technical Support Center from

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activation through termination of the exercise. The inspectors evaluated staffing, command and control, technical assessment, formulation of protective action recommendations, and adherence to the emergency plan ar.d implementing procedures.

3.1 Discussion

The Technical Support Center was staffed and activated promptly. Response

staff appeared to be trained and understood their duties and responsibilities.

The offsite health physics monitoring teams were dispatched early and positioned generally downwind from the site in a state of readiness for a

potential release. These monitoring teams were directed in an effective,

safe, and efficient manner. Radiological surveys, contamination controls, and

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habitability checks were effectively p:rformed in the Technical Support Center. Emergency response goals were well formulated and communicated in the

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Technical Support Center.

Emergency classifications were timely and accurate.

Space limitations were noted in the Technical Support Center, but these limitations did not adversely affect licensee emergency response activities.

The Technical Support Center staff did not aggressively pursue the

identification of the source of the penetration leakage through the shield building ventilation system to the plant stack or its termination. At 1:41 p.m., identification of the release path was established as a priority

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for the Technical Support Center and the Emergency Operations Facility. While i

there was much discussion as to possible sources of the release, it was not

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until 2:51 p.m. that a team was dispatched to determine if leakage was j

occurring at suspected penetrations. Throughout the decision process, the Technical Support Center staff considered the possibility of overpressurizing the ventilation system plenum but did not attempt in parallel to dispatch a

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leak search team or attempt to determine the maximum plenum pressure should it i

become necessary to shutdown the shield building exhaust system. At

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3:44 p.m., immediately prior to terminating the scenario, attempts had not been made to isolate the release nor had a decisive mitigation strategy been

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It was not clear from discussions in the Technical Support Center that any assessment of core camage was being performed during the event. Discussions

between the Operations Coordinator and the Health Physics Coordinator i

indicated a concern that some core damage had occurred, but neither indicated that any assessment was being performed to confirm their opinions.

It was not i

observed that this concern was communicated to the Emergency Coordinator, who i

might have been able to dedicate resources to initiate an assessment. The

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Operations / Engineering Coordinator in the Emergency Operations Facility

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i discussed with the Operations Communicator in the Technical Support Center the need for an assessment of core damage, but there were no followup

communications regarding the assessment. For example, no one requested a Fost Accident Sampling System sample during the exercise to help perform a core damage assessment.

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The above examples of nonaggressive assessnient of plant conditions and

mitigation strategies were identified as an exercise weakness (50-382/9328-01). This exercise weakness was also observed in the Emergency Operations Facility addressed in Section 5.1.

The following problems with the approval and issuance of Protective Action Recommendations were observed by the inspectors in the Technical Support Center:

The initial General Emergency notification made an erroneous Protective

Action Recommendation of sheltering the 2-mile radius and evacuating 2 to 5 miles downwind.

This Protective Action Recommendation was telephonically communicated to the state and parishes via the Operational Hot Line at 11:52 a.m.

The correct Protective Action Recommendation should have been to shelter the 2-mile radius and 2 to 5 miles downwind. This erroneous Protective Action Recommendation was corrected on the message form at 11:55 a.m. by the Technical Support

Center Lead Communicator without acquiring the approval of the Emergency Coordinator or the review of the Health Physics Coordinator. The corrected Protective Action Recommendations were subsequently communicated to the state and parishas several minute: later.

Emergency Preparedness Implementing Procedure EP-002-010, Revision 20,

" Notifications and Communications," Section 5.2, Note 1., specifies that

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the Health Physics Coordinator in the Technical Support Center is responsible for completing the notification message forms. Contrary to

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this procedure, the short notification form for the initial General

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Emergency notification was completed by the Technical Support Center

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Lead Communicator and was reviewed and approved by the Emergency.

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Coordinator prior to issuance. The liealth Physics Coordinator did not complete or review this message form.

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Incorrect Protective Action Recommendations were issued on a second occasion when the wrong procedure attachment was used to determine the

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recommer.dations.

Emergency Preparedness Implementing Procedure EP-002-052, " Protective Action Guidelines," Section 5.2.1,

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requires that "if dose projection information is available, a release is

occurring and the duration of the release is unknown, use Attachment 7.1 and proceed to Step 5.3."

These enabling conditions existed at about i

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12:20 p.m.

Step 5.3 specifies that a Protective Action Recommendation of evacuation from 0 to 2 miles in all sectors and 2 to 5 miles in the affected sectors, and shelter 5 to 10 miles in the affected sectors should be issued. Contrary to this procedure, notification message

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No. F-11 was issued at 12:23 p.m. which incorrectly recommended that all

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affected sectors be sheltered.

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The issuance of incorrect Protective Action Recommendations, the failure to

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follow applicable procedures for completing notification messages containing Protective Action Recommendations, and the failure to receive the Emergency Coordinator's approval to modify previously approved Protective Action Recommendations were identified as an exercise weakness (50-382/9328-02).

The following observations did not significantly effect the licensee's overail

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emergency response and are considered areas for improvement:

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Status Boards in the Technical Support Center for the Protective Action

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Recommendations did not always reflect actual Protective Action Recommendations being communicated to the public.

The inspectors noted that the accountability keycard reader was not

activated until 10 minutes following declaration of an Alert status. As Technical Support Center personnel were reporting to the Technical Support Center, they tried to log in with their keycards not realizing

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that the reader had to be activated. This caused some confusion and slight delays as personnel had to return to the reader to log in when the announcement was made that the reader had been activated. During an

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accountability check, missing persons were identified by name and badge number over the paging system. This practice appeared to shorten the time taken to locate those identified as missing.

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The " red" Emergency Notification System telephone in the Technical

Support Center had to be repaired during the exercise.

During the exercise, announcements establishing priorities and

mitigation strategies did not identify the facility, the individual making the announcement, or the individual establishing priority.

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i-7-At 11:07 a.m., a dose rate projection generated in the Technical Support

Center produced erroneous Thyroid Dose Commitment results. The results included unintelligible values which caused confusion among the health physics staff who were advising the Emergency Coordinator. This resulted in assessment delays because of the need to direct that the projections be recalculated manually and reverified.

Field Team C reported erroneous field team measurement results at i

approximately 10:58 a.m.

These results'were assessed as indicating a release. The field team erred in the calculation of the air sample activity from the scenario data for Location R6. The exercise monitor gave the scenario data to the team's health physicist with incorrect

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units, and the health physicist interpreted the data wrong and reported

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his calculated results such that the dose assessor's computer program computed an erroneous dose rate.

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3.2 Conclusion The Technical Support Center was staffed and activated prompt'.y, and the response staff appeared to understand their duties and responsibilities. An exercise weakness was identified concerning the technical staff not aggressively assessing the plant conditions and mitigating the consequences of the accident. A second exercise weakness was identified for problems involving the issuance of Protective Action Recommendations.

4 OPERATIONAL SUPPORT CENTER (82301-03.02.b.4)

The inspectors evaluated the performance of the Operational Support Center staff as they performed tasks in response to the exercise to determine whether the Operational Support Center would be effective in providing support to operations. The inspectors observed activation and operation of the Operational Support Center and accompanied a repair team that was dispatched to the plant to perform repair activities.

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4.1 Discussion The' inspectors noted that the Operational Support Center responders quickly and efficiently placed the facility in an operational state of readiness. The

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First Responders removed support equipment such as telephones, status boards, and radios from emergency lockers and installed the equipment at the respective work stations. The support equipment was tested to verify its operational status.

Secondary doors into the Operational Support Center were posted to direct personnel to enter the facility via the primary access door. However, it was observed that the primary access door was not posted so

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as to identify this door as the designated entry, i

Radiological, facility staffing, and repair team status boards were used to display related information. The Operational Support Center Health Physics Liaison maintained frequent contact with the Technical Support Center and the in-plant Radiological Coordinator in order to keep abreast of radiological conditions in the plant. This information was displayed on the radiological status board.

It was noted that the in-plant Radiological Control Coordinator

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did not provide radiological information unless requested by the facility

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Health Physics Liaison.

Information regarding the repair teams dispatched from the Operational Support Center was displayed on the repair team status boards and maintained current.

It was noted that the facility staffing status board had not been updated to reflect recent Operational Support Center staffing changes.

It was also noted that some individuals did not sign in on the staffing board when they reported to the facility to assume their duties.

The Operational Support Center Supervisor demonstrated excellent command and t

control. He provided frequent facility briefings concerning plant conditions, facility goals and priorities, and the status of repair teams. -The designated Electrical, Mechanical, and Instrumentation and Contral Leaders provided -

strong support to the facility supervisor. All personnel assigned.to the Operational Support Center were well trained and thoroughly familiar with their specific tasks. Repair teams were quickly assembled, briefed by the responsible Leader and Health Physics Liaison, and dispatched in a timely manner. Direct radio communication was maintained with each repair team. The previous exercise identified a exercise weakness involving the manipulation of a blowdown valve by an emergency repair team which did not include a qualified operations team member. During this exercise, the inspectors accompanied Repair Team 4 that was dispatched to drain oil from chiller "A."

The inspectors noted that two operational personnel were at the job site to provided technical assistance to the repair team.

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The Operational Support Center was not conducive for conducting emergency work activities. The normal plant Instrument and Control work area was converted into the Operational Support Center for exercise purposes. The layout of this area presented several difficulties in conducting emergency activities.

For example, there was no designated briefing room where repair teams could sit down to receive briefing instructions.

Briefings were held in a congested area where team members were forced to stand around work cubicals during the briefings. Noise levels and personnel traffic within the facility were well maintaintd. Despite poor facility arrangements, work activities were accomplished in an effective manner.

Frequent direct radiation surveys were conducted by a dedicated radiation protection technician to determine radiological conditions in the facility.

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In addition, a continuous air monitor was put in operation to alert personnel of any problems with airborne radiation levels.

The Operational Support Center maintained excellent communications with other emergency response organizations such as the Technical Support Center, Emergency Operation Facility, and the Radiological Control Coordinator. The Facility Supervisor frequently asked the Technical Support Center if there were any problem areas where he could provide assistance. The exercise scenario exhibited some weaknesses in that the Operational Support Center was not faced with significant challenges, and there were long periods of time where the facility was not involved with any response activities. Ten repair / response teams were assembled, but only five were dispatched to perform tepair work. All of the teams were able to accomplish their repair work in a short period of time. None of the teams were faced with any complex or challenging radiological work conditions.

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4.2 Conclusion The Operational Support Center performed their emergency response activities in an effective, professional, and timely manner. The facility supervisor maintained excellent command and control. Response personnel were well trained and thoroughly familiar with their assigned responsibilities. Some

problems were noted with the facilities and lack of challenges in the exercise scenario.

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5 EMERGENCY OPERATIONS FACILITY (82301-03.02.b.3)

The inspectors observed and evaluated the Emergency Operations Facility staff as they performed tasks in response to the exercise. These tasks included activation of the Emergency Operations Facility, accident assessment, offsite dose assessment, notifications, protective action decisionmaking, and interaction with State and local officials.

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5.1 Discussion

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Staffing of the Emergency Operations Facility was initiated upon the Alert

declaration at 9:05 a.m.

Staffing of the Emergency Operations Facility was

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well organized and efficient. However, two areas for improvement were noted.

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One area concerned failure of the first responder to the Emergency Operations Facility to post signs on Emergency Operations Facility access doors restricting access to the Emergency Operations Facility in accordance with

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Procedure EP-002-102, " Emergency Operations Facility (E0F) Activation Operation, and Deactivation." The second area concerns failure of seve'ral of the early responders to the Emergency Operations facility to follow posted

instruction regarding turning up the volume on the Emergency Operations

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Facility entrance way frisker.

The Emergency Operations Facility was staffed and ready to activate by

9:45 a.m.

At 10:15 a.m., the Emergency Operations Facility Director and the Technical Support Center Emergency Coordinator decided not to transfer responsibility for offsite emergency management activities to the Emergency Operations Facility. No criteria was referenced as the basis for this decision.

Based upon events undergoing at this stage of the exercise, it would have been prudent for the Emergency Operations Facility to assume responsibility for offsite emergency management activities so that the

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Technical Support Center could concentrate on onsite concerns. The development of criteria for deciding when to transfer responsibilities to the Emergency Operations Facility from the Technical Support Center when the

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Emergency Operations Facility is ready to activate during an Alert was considered an area of potential improvement.

A General Emergency was declared at 11':40 a.m.

The Emergency Operations Facility assumed responsibility for offsite emergency management activities, including offsite notifications and protective action decisionmaking at 12:35 p.m.

The transfer of these responsibilities from the Technical Support Center to the Emergency Operations Facility was not well coordinated. For example, a set time was not given for the transfer to occur. Also, the

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of the emergency response, in particular, regarding the status of protective i

action recommendations and the status of plant conditions during the transfer l

operation. The coordination of the transfer of command and control from the

Technical Support Center to the Emergency Operations facility, in particular,

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during times when offsite dose assessments and protective action

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decisionmaking are in progress is considered an area for potential

improvement.

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Offsite notifications were made in a timely manner. The Communications Coordinator kept the Emergency Operations facility Director aware of when i

notifications were due to offsite agenciac and ensured that notification forms were processed efficiently. The coreunications staff worked well together to ensure the notifications were trar.smitted on time. The notifications status board was well maintained throughout the exercise.

Plant status boards were well maintained initially but degraded after the declaration of the General Emergency. Maintenance of status boards is considered an area for improvement.

i The assessment of plant conditions and mitigation of the consequences of the

event were not performed well. The Emergency Operations Facility staff neither aggressively pursued determination of the release path of radioactivity from the containment nor did the Emergency Operations Facility staff aggressively pursue determining the magnitude and composition of the source of radioactivity in containment. The Emergency Operations facility staff did not take aggressive action to terminate the release by promptly investigating the potential for shutting off the shield building ventilation.

l Command and control from the Emergency Operations Facility Director was not

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strong. For example, the Emergency Operations Facility Director did not ensure that the Emergency Operations Facility staff was aggressively pursuing

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completion of high priority assessment and mitigation activities. Also, the

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Emergency Operations Facility Director's briefing to the Emergency Operations

Facility staff were infrequent. He did not identify himself by name and title when making the briefings, and the briefings did not include details concerning the status of the completion of high priority items. The nonaggressive assessment by the Emergency Operations Facility staff of plant conditions and mitigation of the consequences of the event was considered part l

of exercise weakness (50-382/9328-01) previously discussed in Section 3.1.

5.2 Conclusion Observations were made in the Emergency Operations Facility of items that contributed to the exercise weakness in the area of poor assessment of plant

conditions and mitigation strategies previously referenced. Other Emergency

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Operations Facility functions were performed effectively during the exercise.

6 SCENARIO AND EXERCISE CONDUCT (82301)

The inspection team made observations during the exercise to assess the

challenge and realism of the scenario and to evaluate the conduct of the j

exercise.

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The inspection team determined that the scenario provided sufficient challenge to exercise response activities in each of the exercise objectives. Realism

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was enhanced by utilizing the Control Room Simulator in the dynamic mode to model the accident sequence. The scenario lacked significant challenge, however, for the Operations Support Center. Only five teams were dispatched from the Operations Support Center during the exercise, and there was little

radiological challenge accompanying any repair activities. Realism was diminished by not arranging for the lighting in the Technical Support Center

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to be interrupted at the time of the loss of offsite power. This would have provided immediate feedback to the Technical Support Center staff of problems t

with facility electrical power. These are considered as items for improvement.

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6.2 Conclusion

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The scenario and exercise preparation were sufficient to demonstrate the exercise objectives.

7 LICENSEE SELF-CRITIQUE (82301-0302.b.12)

The inspectors observed and evaluated the licensee's formal self-critique on October 28, 1993, to determine whether the process would identify and characterize weak or deficient areas in need of corrective action.

7.1 Discussion The licensee described its critique process as involving all players, evaluators, and representatives of senior management.

Licensee findings were characterized in terms similar to NRC findings. The licensee identified weaknesses similar to the two identified by the inspectors in this report.

In addition, the licensee's critique process classified the following problem

areas as exercise weaknesses.

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Weak Scenario / Drill Control

Lack of Understanding of Computerized Dose Assessment Results when

using Field Monitoring Inputs Even though the NRC inspection team did not identify the above items as exercise weaknesses, the licensee stated that similar corrective actions will be implemented for all four exercise weaknesses.

In addition to the four exercise weaknesses identified, the licensee identified eight significant

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improvement items and about 74 improvement items.

7.2 Conclusion The licensee's critique process was excellent. The licensee's critique process identified two problem areas as exercise weaknesses that were not

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identified as exercise weaknesses by the inspectors, t

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-12-8 FOLLOWUP (92701)

(Closed) Exercise Weakness (50-382/9213-01): Emeraency reDair team did not include a cualified operations team member During the 1993 emergency exercise, the inspectors verified that repair work activities were properly coordinated with operations and that operations personnel were at the job site to provide technical assistance.

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I ATTACHMENT

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1 PERSONS CONTACTED 1.1 Licensee Personnel

  • R. G. Assarello, Director, Design Engineering
  • F. J. Drummond, Director, Site Support
  • F. J. Englebracht, Manager, Emergency Planning and Administration
  • T. J. Gaudet, Supervisor, Operational Licensing
  • T. R. Leonard, Director, Plant Modifications and Construction
  • J. J. Lewis, Sr., Supervisor, Emergency Planning A. S. Lockhart, Manager, Quality Assurance
  • D. F. Packer, General Manager, Plant Operations G. Scott, Engineer, Licensing
  • C. M. Van Alsdorf, Communications 1.2 NRC Personnel
  • E. J. Ford, Senior Resident inspector
  • R. E. Lantz, Reactor Engineer
  • B. Murray, Chief, Facilities Inspection Programs Section
  • L. L. Sherfey, Battelle Northwest Laboratory
  • Denotes those present at the exit meeting 2 EXIT MEETING The inspection team met with the licensee representatives indicated in Section 1 of this Attachment on October 28, 1993, and summarized the scope and findings of the inspection as presented in this report. The licensee did not identify as proprietary any of the materials provided to, or reviewed by, the inspectors during the inspection.

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