IR 05000397/1991033
| ML17286B233 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 12/04/1991 |
| From: | Mcqueen A, Qualls P, Reese J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17286B232 | List: |
| References | |
| 50-397-91-33, NUDOCS 9201090216 | |
| Download: ML17286B233 (24) | |
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NUCLEAR REGULATORY COMMISSION
REGION V
Report No.
50-397/91-33 License No.
NPF-21 Licensee:
Washington Public Power Supply System P.O.
Box 968 3000 George Washington Way Richland, Washington 99352 Facility Name:
Washington Nuclear Project, Unit 2 (WNP-2)
Inspection at:
WNP-2 Site, Benton County, Washington Inspection Conducted:
November 18 - 22, 1991 Inspectors:
Q gC ouse c ueen, merg cy repare ness na ys
/
Iz/s/e i a
e
>gne ua s,
eac or nspec or a
e igne L.
K. Cohen, Senior Emergency Preparedness Specialist, NRR/PEPB T.
H. Essig, Chief, Central and Western Section, NRR/PEPB A,
K.
Loposer Comex Approved by:
ames
.
eese, ie
,
a eguar s, mergency a
e igne Preparedness, and Non-Power Reactor Branch,
~Summar:
Areas Ins ected:
Announced inspection to examine the following portions of the licensee s emergency preparedness program:
follow-up on Open Items identified during previous emergency preparedness inspections and observe the 1991 annual emergency preparedness exercise and associated critiques; and Inspector Identified Items.
During this inspection, Inspection Procedures 82301, 92700 and 92701 were used.
Results:
In the areas inspected, the licensee's emergency preparedness program appeared adequate to protect the public health and safety.
The licensee was found to be in compliance with NRC requirements within the areas examined during this inspection.
One item was identified as an exercise weakness and several areas were indicated to the licensee for improvement.
The exercise weakness is described in section 8.
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Ke Persons Contacted INSPECTION DETAILS C. Fies, Lead Compliance, MPPSS
"L. Harrold, Assistant Plant Manager
~A. Klauss, Supervisor, Emergency Planning
- J.
Landon, Emergency Preparedness (Scenario Author)
"D. Larsen, Manager, Emergency Preparedness C.
Lawrence, Mashington Department of Health
- M. Monopoli, Manager, Support Services
- G. Sorensen, Manager, Regulato.y Programs
"R. Utter, Supervisor, Emergency Preparedness Training The above individuals denoted with an asterisk were present during the exit meeting.
The inspectors also contacted other members of the licensee's emergency preparedness, administrative, and technical staff and management during the course of the inspection.
NRC Personnel at Exit Interview L.
K. Cohen, Senior Emergency Preparedness Specialist, NRR/PEPB T.
H. Essig, Chief, Central and Western Section, NRR/PEPB A.
K. Loposer, Comex A.
D. Mcgueen, Emergency Preparedness Analyst, RV P.
M. squalls, Reactor Inspector, RV C.
Sorensen, Senior Resident Inspector, RV 2.
Follow u on Previous Ins ection Findin s (92701)
(Closed)
Follow-up Item (91-02-03).
NRC Concerns Re ardin the Licensee's Accountabilit Procedure (
.
.
ec son During a previous inspection (Inspection Report 50-397/91-02 dated February 19, 1991), it was indicated that the previous revision of Emergency Plan Implementing Procedure (EPIP) 13.5.5 stated that accountability would be initiated "upon activation of the OSC."
The OSC is activated at the Alert classification level.
The current revision of 13.5.5 states that protected area accountability
"may (emphasis added)
be initiated upon activation of the OSC."
IX further indicates that accountability is required at the SAE and GE classifications, and that the 30 minute requirement for completing accountability begins with the declaration of an SAE or a GE, and
"when the OSC is activated."
Since the previous revision required accountability at the Alert level, and the current revision makes accountability optional at the Alert level (mandatory at the SAE and GE), the change constitutes a reduction from a previously approved procedure.
In addition, the prerequisite of OSC activation is not appropriate since the activation of the OSC could be delayed during off-normal hours, resulting in possible delay in the decision to search for potentially injured individuals.
This change was evaluated against the criteria specified in NUREG-0654 (Planning Standards II.J.4 and 5) and discussed with the NRC Emergency
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Preparedness Branch.
Making accountability optional at the Alert level was considered to be acceptable.
The other changes were considered not acceptable.
Changes that decrease the effectiveness of the Plan require prior NRC approval in accordance with 10 CFR 50.54(q).
The licensee proposed to modify the procedure to eliminate the requirement to activate the OSC before initiating accountability and to modify the procedure to extend the 30 minute accountability goal to the Alert level, if the process was initiated at that level.
This response was considered acceptable.
It was determined during this inspection that changes were made in Revision 7 to appropriately address NRC concerns.
(Closed)
Enforcement Item (91-25-01).
Deficiencies in Res iratory Re uglification of Emer enc Res onse Personne
.
The Emergency Plan requires that training for all individuals assigned to emergency organization positions will be successfully completed prior to their initial assignment to the emergency organization.
Contrary to this requirement, a licensee Problem Evaluation Request, initiated in February 1991, found that a review of respiratory training and medical status for emergency workers has identified multiple deficiencies for Plant Emergency Personnel.
A root cause analysis was completed in July 1991 which made recommendations for near term and longer term solutions to the problem.
The licensee had further indicated at the exit meeting for the last NRC emergency preparedness inspection for this site (Report Number 50-397/91-25, dated August 15, 1991) that this had been listed as a "start-up" item to be verified as corrected with all personnel properly qualified for emergency positions prior to plant restart.
Thereafter, it will be the responsibility of emergency and plant managers to insure that personnel remain qualified. It was determined during this inspection that necessary training was accomplished prior to plant start-up and management responsibilities to insure proper qualification in the future have been documented.
(Closed)
Follow-up Item (91-25-02).
Addition to Procedure to Ensure Radiation Monitors are Turned on en is c iva e
.
During the NRC inspection in August 1991 (see item b immediately above),
the TSC radiation monitors were found to be de-energized.
When discussed with the licensee, it was indicated that no procedure existed to remind TSC personnel to energize the radiation monitors when the TSC is activated.
The licensee stated that they would make an addition to one their procedures to ensure that the radiation monitoring equipment is turned on when the TSC is activated.
It was determined during this inspection that Emergency Preparedness Implementing Procedure 13. 10.4 in Revision 7 specifically assigned the function of energizing the TSC radiation monitoring equipment to the Radiation Protection Manage ~
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3.
Exercise Plannin (res onsibilit scenario/ob'ectives develo ment con ro o
scenario The Manager, Emergency Planning (EP)
has the overall responsibility for developing, conducting and evaluating the annual emergency preparedness exercise.
The EP staff developed the scenario with the assistance of licensee staff from other organizations possessing appropriate expertise (e.g.
reactor operations, health physics, maintenance, etc.).
In an effort to maintain strict security over the scenario, individuals who had been involved in the exercise scenario development were not participants in the exercise.
NRC Region V was provided an opportunity to comment on the proposed scenario and objectives.
The complete exercise document included objectives and guidelines, exercise scenario and necessary
, messages and data (plant parameters and radiological information).
The exercise document was tightly controlled before the exercise.
Advance copies of the exercise document were provided to the NRC evaluators and other per sons having a specific need.
The players did not have access to the exercise document or information on scenario events.
This exercise was intended to meet the requirements of IV.F 3 of Appendix E to 10 CFR Part 50.
Exercise Scenario 5.
The exercise objectives and scenario were evaluated by the NRC and considered appropriate as a method to demonstrate the Washington Public Power Supply System (WPPSS) capabilities to respond to an emergency in accordance with their Emergency Plan and implementing procedures.
The exercise scenario started with an event classified as an Alert and ultimately escalated to a General Emergency (GE) classification.
The opening event in the exercise involved a Refueling Machine failure which caused a fuel bundle in the Spent Fuel Pool to become sheared, resulting in a release of radioactive qases from the Spent Fuel Pool.
This met requirements for classification of the incident as an Alert based on the radiation signal received in the reactor building.
Contractors working on a Control Rod Drive (CRD) changeout evacuated as directed after announcement of the Alert, causing a
CRD mechanism to fall with failure to seal.
This resulted in water level dropping at a fast rate and within 15 minutes nearly 55,000 gallons of water had drained out of the reactor vessel.
When the reactor water level had reached minus 161 (-161) inches, conditions for a Site Area Emergency (SAE) were met.
Reactor water level continued to decrease and at about noon, radioactive gases were released to a point of activating various monitors in the reactor building.
When discovered, conditions for declaration of a GE were met.
At about 1:00pm, recovery from the emergency began when the CRD mechanism leak was healed and 30 minutes later standby water began to flow into the reactor.
Conditions were met to downgrade the emergency at about 2:30pm soon after water had recovered the core.
Federal Observers Five NRC inspectors evaluated the licensee's response to the scenario.
Inspectors were stationed in the Control Room/Simulator (CR), Technical Support Center (TSC), Operational Support Center (OSC),
and in the Emergency Operations Facility (EOF).
An inspector in the OSC also accompanied a repair/monitoring tea II
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Exercise Obser vations (82301)
The following observations, as appropriate, are intended to be suggestions for improving the emergency preparedness program.
An exercise weakness is a finding identified as needing corrective action in accordance with 10 CFR 50, Appendix E, Paragraph IV.F.5.
All exercise times and other times indicated in this report are Pacific Standard Time (PST).
7.
Control Room/Simulator (CR)
The following aspects of CR operations were observed during the exercise:
detection and classification of emergency events, notification, frequent use of emergency procedures, and innovative attempts to mitigate the accident.
The following are observations by the NRC inspector in the CR.
a.
Observations o
The notification sheet for "Alert" under
"Release Info:" had
"unknown" checked.
The Shift Manager should have recognized that some amount of airborne had been released, and checked that block, even though it was not quantified.
o At 10: liam the Shift Manager (SM) was told by the Plant Emergency Director (PED)
sn the TSC that a Site Area Emergency
'ad been declared.
The Public Address announcement of thss event was not heard until 10: 18am, 7 minutes later.
o The operator, in responding to the Shift Supervisor's (SS)
direction at 9: 15am to line up service water (SM) to inject, down to the last valve, actually left shut (or did not attempt to open)
RHR-V-116 (residual heat removal),
as well as the injection valve.
It was not certain whether this was the SS desire or not, but it did result in a delay, until 9:34am, in finding that RHR-V-116 was frozen shut.
o There 'are no status boards in the control room (simulator) to display equipment operability/condition status (e.g.,
containment hatches open),
estimated repair time, emergency declaration status, problems, trends, etc.
It was recommended plant consider the use of such boards.
b.
~Stren the:
o The SM was prompt to recognize and classify the alert, and to direct evacuation of the reactor building.
o Operators were familiar with and prompt to use Operating Procedures, Emergency Operating Procedures, EPIPs and symptomatic Emergency Action Levels (EALs),
o Status updates were frequent and informativ l
o The Shift Supervisor properly ordered the plant emergency team to check the RHR-2C pump breaker trip status and to check the shaft problem with the RHR-2B pump/motor.
He also added a
caution regarding high radiation.
o The Shift Technical Advisor (STA) did a qualitative calculation and reported to the PED that as long as Stand By Gas Treatment (SBGT) was operating, any release would be minimal.
But if SBGT were lost, release levels would increase to 20 - 200 mrem/hr.
o The turnover of PED from the SM to the Plant Manager (PM) was formal and was announced and logged in the control room.
o After being relieved as the PED, the SM and his CR crew continued scoping the situation and making suggestions and recommendations to the PED (included among these was the recommendation to drape fire hoses over the vessel cavity to add water).
8.
Technical Su ort Center (TSC)
The following aspects of TSC operations were observed:
activation, accident assessment/classification, notification, and interactions between the various emergency response facilities.
The following represent the NRC inspector's observations in the TSC.
a.
Exercise Weakness It was noted at the TSC that the online Emergency Notification System (ENS) communicator with the NRC was unable to view status boards from his location.
In discussions with the NRC base team, it was indicated that the line was left unmanned at times up to fifteen minutes while gathering requested data.
This appears contrary to 10 CFR 50.72(c)(3),
which indicates that
"Each licensee shall, during the course of the event:
Maintain an open, continuous communication channel with the NRC Operations Center upon request by the NRC."
This request had been made by the NRC.
Had this been an actual event, this situation could have resulted in violation of regulatory requirements.
EPIP 13. 10.6 assigns numerous duties to the Plant/NRC Liaison position which appears to prohibit his fulltime manning of the ENS.
Action is necessary to insure manning and assignment of duties to provide for fulltime coverage of the ENS.
(91-33-01)
b.
Observations o
One player arrived in the TSC and signed in on the exercise sheet approximately 13 minutes prior to the event declaration announcement which initiated manning of the TSC.
The player signed in at 8:51am and the Alert was announced at 9:04am by the TSC cloc II l',
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o Although TSC noise levels were generally quiet, on several occasions, general background noise became excessive.
o At 12:45pm, the TSC NRC evaluator became aware that an OSC exercise controller had informed an OSC player that attempts to restore water to the reactor would not be successful until 2:00pm.
This appeared to be common knowledge in the TSC.
o At 1:52pm, some confusion existed in the TSC about the status of the Residual Heat Removal (RHR) pumps.
~Stren the o
Good communications existed between the TSC and EOF and the TSC and OSC.
o Throuqhout the exercise the TSC Director conducted periodic briefings of the TSC staff.
o The PED anticipated worsening conditions and directed his staff to monitor dose and reactor pressure vessel (RPV) level closely so he could escalate the event if necessary.
o The TSC staff made frequent and accurate projections for core uncovery time, core damage projection times and core damage assessments.
o The TSC staff continually searched for innovative methods to put water into the reactor.
o The TSC staff issued Potassium Iodide (KI) pills in anticipation of a release.
o TSC Management did a good job preparing a relief list and in evacuating non-essential personnel.
o TSC staff did a good job of identifying and evaluating changes in plant parameters.
o After the core was recovered with water, the PED did a good job of directing the TSC Director to develop a plan for long term water management.
o TSC Management did a good job of prioritizing mitigation efforts and communicating these to the PED and TSC staff.
o The TSC staff effectively kept status boards up to date with timely informatio )I
0 erational Su ort Center (OSC)
The following aspects of OSC operations were observed:
activation of the facility, functional capabilities, and the disposition and management of various in-plant repair/monitoring teams.
Two NRC inspectors observed activities conducted by the OSC.
a.
Observations o
The present size and location of the OSC in the service building resulted in a great deal of congestion and high noise levels.
The removal of non-essential personnel appeared to help the situation.
Keeping support staff outside the OSC will also help lower congestion.
Separation of some functions by moving them into other rooms may lower noise and congestion.
The licensee indicated that they are studying ways to improve OSC operations and facilities, o
A step-off pad and control area should be established to limit spread of contamination prior to entry to the service building when retur ning from containment or other contaminated areas.
b.
Stren ths:
o The OSC Director maintained good command and control of the OSC facility.
He directed the staff in organization of the OSC and establishment of teams and communications with the TSC.
He displayed excellent knowledge of facilities and OSC functions.
o The OSC was staffed and activated within 20 minutes.
Accountability and habitability was completed within 30 minutes.
Habitability was checked and status confirmed at least every 30 minutes.
o Teams were properly briefed, tracked and debriefed.
Team members maintained good communications with the OSC.
Health Physics (HP) coverage was very good.
Routes were provided to keep exposure low.
Exposure limits were also given as appropriate to reduce exposure.
o The OSC Director provided status reports to OSC as well as staff in other rooms on approximately 15 minute intervals.
Status boards in the OSC were maintained.
The use of the viewgraph for events/status was very effective.
o Participation was realistic and enthusiastic by all players.
o Marnings were given of possible/probable events (e.g
,
projected core uncovering, move of the OSC due to radiation levels, et t
o Evacuation of non-essential personnel went efficiently and appeared effective.
10.
Emer enc 0 erations Facilit (EOF)
The following EOF operations were observed:
activation; functional capabilities; interface with offsite officials; dose assessment; and the formulation of protective action recommendations.
The following are NRC observations of EOF activities.
a.
Observation Approximately 45 minutes prior to the termination of the exercise, following discussions with the NRC Site Team and Operations Center Staff, the Meteorology and Unified Dose Assessment Center (MUDAC)
staff performed a dose consequence assessment of a complete core
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damage scenario.
To perform this assessment, the MUDAC staff utilized the core inventory of radionuclides tabulated in Chapter
of the FSAR and attempted to estimate the response of the elevated release point monitor.
Rather than use the iterative process that was actually used, the MUDAC staff should have had a more efficient method for estimating the offsite consequence of a release of 100K of the core inventory.
Such a method would have facilitated smoother interaction with the NRC site team and operations center staff.
b.
~Stren the o
Following declaration of the Alert, the licensee activated the EOF in an efficient and timely manner.
Only 38 minutes were required to set up, staff the facility, and declare it operational.
o The recovery manager conducted timely and informative briefings of the EOF manaqement staff.
Additionally, the briefings solicited quest>ons from exercise players.
o Sy handling key administrative and routine functions, the Assistant Recovery Manager complemented the Recovery Manager very effectively, thus allowing the Recovery Manager to devote the majority of his efforts to the overall coordination of EOF operations.
Additionally, the management in the EOF/Decision Center made effective use of clerical staff to permit them to perform their own management tasks more efficiently.
o Approximately 75 minutes prior to the declaration of the General Emergency, the Recovery Manager and Radiological Emergency Manager were actively engaged in discussions relative to changing the emergency classification to a General Emergency.
Although they were prevented by controller intervention from taking this action, these individuals pursued the matter and were strongly considerinq recommending precautionary evacuation of the Emergency Planning Zone (EPZ).
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o The Technical Data Center (TOC) manager was knowledgeable and forceful in assuring that the ideas developed by the engineers were documented and displayed, that they were looking at contingencies and developing worst case projections.
o The TOC recommendation to refill the standby liquid coolant injection tanks with service water using fire hoses was good.
o The TDC projection of 12:30pm as the time a General Emergency EAL would be reached was a good input.
o The system of havinq the talker keeping his log on transparencies using a grease pencil, then displaying them on an overhead projector, was very helpful.
11.
~Criti ues A series of exercise critiques was conducted by the licensee upon completion of the exercise.
First, a facility critique was conducted at each emergency response facility with players and controllers immediately following the exercise.
Upon conclusion of these critiques, a player and controller critique was conducted at the Plant Support Facility on November 19, 1991, to review the items surfaced at the facility critiques.
The licensee had noted several of the items also identified by the NRC observers, as well as other exercise strengths and problems for improvement.
The licensee indicated that an additional corporate level critique would be conducted after a thorough review of exercise reports and findings.
13.
Review of Actual Unusual Events of November 4 and
1991 (92700)
On November 4, 1991, the licensee informed the NRC Headquarters Operations Officer (HOO) via the NRC Emergency Notification System (ENS) that a
UE had been. declared at the MNP-2 at 4.55am because of unidentified RCS (Reactor Coolant System)
leakage of approximately 1.5 gpm (gallons per minute), which required a shutdown in accordance with technical specifications, Further details of the event are contained in Region V Preliminary Notification of Event (PN) PNO-V-91-27, dated November 4, 1991.
In reviewing this event during this inspection, it appeared that the event had been properly class>fied at an appropriate Emergency Action Level and that timely notifications had been made to cognizant offsite agencies and the NRC.
b.
On November 19, 1991, the licensee declared an Unusual Event at 7:47am following a low reactor pressure vessel (RPV) level condition with emergency core cooling systems injecting.
Further details of the event are contained in Region V Preliminary Notification of Event (PN) PNO-V-91-31, dated November 19, 1991.
This event occurred during this inspection and upon evaluation, it appeared that the event had been properly classified at an appropriate Emergency Action Level and that timely notifications had been made to cognizant offsite agencies and the NR e
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14.
Unresol ved Issue 15.
A licensee Problem Evaluation Request (PER) 291-892, dated October 30, 1991, indicated that the HEPA and carbon filters of the TSC HVAC unit are currently not being tested to requirements consistent with the desiqn bases.
Burns
Roe Technical Memorandum 1261, FSAR page B.3-4f, and the MNP-2 SER page 12-5 all indicate that postaccident conditions in the TSC will be maintained the same as the control room.
The 2" carbon bed in AMA-FU-52 is claimed to have an efficiency of 95%.
PPM 10.2.83 indicates that AMA-FU-52 is tested to the requirements of Reg Guide 1. 140 which allows 70% efficiency for a 2" carbon bed.
Testing to Reg Guide 1.52 requirements is necessary to obtain 95% efficiency credit.
Technical Memorandum No.
TM-2016 is being issued to further document this need.
Emergency Plan section 10. 2. 2. 2 commits that the TSC "is as habitable as the control room;" but as indicated in the PER, habitability test standards for the TSC were indicated as a
70% criteria whereas the control room criteria was for 95%%u.
A telephone call from the licensee to Region V on November 26, 1991, indicated that they had determined that testing of the TSC habitability had been done at the 95% level all along and in accordance with Regulatory Guide 1.52.
Appropriate documentation of the testing so indicates.
The problem, therefore, appears to be procedure documentation rather than testing failure.
Action is being taken to update procedures to indicate testing of the TSC filters to the same standards as the control room.
This item will be reviewed in a future emergency preparedness inspection at the site.
(91-33-02)
Exit Interview.
On November 22, 1991, at the conclusion of the site visit, the inspectors met with the licensee representatives identified in the attachment hereto to summarize the scope and the preliminary results of this inspection.
The inspectors noted that the previously open items would be closed and one new item was unresolved.
The inspectors reviewed the weakness discussed in section 8 above and the licensee indicated that they would take appropriate action to preclude recurrenc e I
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ATTACHMENT NRC EXIT-INTERVIEW ATTENDEES Aeschliman, WPPSS Albert, WPPSS Armstrong, WPPSS Baker, WPPSS Ball, WPPSS Benham, MPPSS Bouchey, WPPSS Britton, WPPSS Chitwood, MPPSS Chrisler, WPPSS Cohen, NRC Connor, WPPSS Derrer, INPO Dufault, WPPSS Essig, NRC Harmon, VPPSS Hunter, VPPSS Jorgenson, VPPSS Kiel, WPPSS H.
T.
D.
J.
L.
C.
G.
J.
R.
T.
L.
A.
Y ~
T.
T.
J.
J.
R.
W.
Klauss, WPPSS A.
D.
R.
Kobus, WPPSS Koenigs, WPPSS I,andon, WPPSS D. Larson, VPPSS J. Little, WPPSS A. I,oposer, NRC (Comex)
D. Martin, WPPSS A. McQueen, NRC M. Monopoli, WPPSS K. Meehan, WPPSS C. Noyes, WPPSS A. Oxsen, WPPSS D. Pisarcik, WPPSS L. Pritchard, WPPSS P. Quails, NRC G. Ray, WPPSS R. Romanelli, WPPSS V. Schockley, WPPSS C. Sorensen, NRC G. Sorensen, VPPSS C. Stroh, WPPSS R. Utter, WPPSS R. Webring, WPPSS 0. Yonts, WPPSS
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