IR 05000400/1992016
| ML18010A794 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 09/10/1992 |
| From: | Rankin W, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18010A793 | List: |
| References | |
| 50-400-92-16, NUDOCS 9209290139 | |
| Download: ML18010A794 (30) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.IN.
ATLANTA,GEORGIA 30323 sEP 83 19S2 Report Nos.:
50-400/92-16 Licensee:
Carolina Power and Light Company P.
O. Box 1551 Raleigh, NC 27602 Docket Nos.:
50-400 License No.: NPF-63 Facility Name:
Shearon Harris Nuclear Power Plant Inspection Conducted:
August 24-28, 1992 Inspector:
F.
. Wright, earn Le der
Z D te Signed D te igned Team Members:
W. Gloersen
. W. Guilfoil R. Prevatte Approved by.
W. H. Rankin, Ch'ef Emergency Preparedness Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
This routine, announced inspection involved the observation and evaluation of the annual emergency preparedness exercise.
This full participation exercise was conducted on August 24, 1992 between the hours of 8:00 a.m.
and 4:00 p.m.
Emergency organization activation and response were selectively observed in the licensee's Emergency Response Facilities including: the Drill Control Room; Technical Support Center; Operational Support Center; and Emergency Operations Facility.
The inspection also included a review of the exercise scenario and observation of the licensee's post exercise critique.
Results:
In the areas inspected, no violations or exercise weaknesses were identified.'xercise strengths included: excellent controller critique and strong command and control in the Technical Support Center and the Emergency Response Facility.
Participating employees were innovative, exhibited good attitude, and worked 9209290l39 920922 PDR ADOCK 05000400
well as a team.
Overall, the licensee's performance during the exercise was good, with the licensee meeting their exercise objectives and demonstrating a capability to protect the public health and safety in the event of a radiological emergenc REPORT DETAILS Persons Contacted Licensee Employees
-+R. Baldwin, Lead Controller, Technical Support Center (TSC)
H. Barnes, Dose Projection Team Leader
- R. Bassett, Scenario Controller, Senior Emergency Preparedness (EP) Specialist, Harris EP
- J. Collins, Plant Operations Director T. Dunn, Lead Controller, Emergency Operations Facility (EOF)
- C. Gibson, Logistics Support Director
- C. Hinnant, Site Emergency Director, Plant General Manager T. Hobbs, Senior Control Room Operator B. Houston, Senior EP Specialist, Brunswick EP
- R. Indelicato, Drill Director, Manager EP (Corporate)
- B. Meyer, Radiological Controls Director
- T. Morton, Emergency Repair Coordinator
- J. Newton, Control Room Operator
- C. Olexik, Emergency Communicator A. Poland, Assistant Radiological Controls Director S. Sewell, Plant Operations Controller
- H. Stroup, Shift Technical Advisor J. Trogden, Emergency Communicator G. Vaughn, Emergency Response Manager
- M. Wallace, Senior Specialist, Regulatory Compliance B. Wibalda, Control Room Operator A. Williams, Shift Supervisor Other licensee employees contacted during this inspection included engineers, operators, mechanics, security force members, technicians, and administrative personnel.
Nuclear Regulatory Commission
- J. Tedrow, Senior Resident Inspector
- M. Shannon, Resident Inspector
- Attended exit interview Exercise Scenario (82302)
The scenario for the emergency exercise was reviewed to determine that provisions had been made to test the integrated response capability and a major portion of the basic elements existing within the licensee's Emergency Plan and organization as required by 10 CFR 50.47(b)(14),
CFR 50, Appendix E, Paragraph IV.F, and specific criteria in NUREG-0654,Section II.N; The scenario was reviewed in
advance of the scheduled exercise date and was discussed with licensee representatives.
The scenario was adequate to exercise the onsite and offsite emergency organizations of the licensee and provided sufficient emergency information to the State for their limited participation in the exercise.
The scenario utilized the staff in resolving emergency problems until the exercise was terminated.
During the exercise a problem with scenario data, provided to the Accident Assessment Team, was identified.
The inspector determined that the scenario developers had failed to verify the data utilized in core damage assessment procedures.
Licensee employees using approved procedure; Plant Emergency Procedure (PEP)-362, Core Damage Assessment, Revision (Rev.)
4, April 13, 1987; properly calculated the percent fuel cladding failure to be approximately 110 percent.
The calculated value was approximately 100 times the amount expected.
The amount of cladding failure was supposed to be approximately 1.5 percent.
The inspector learned that the problem had been created when the scenario developers utilized the core damage methodology described in the FSAR, which was different from the one utilized in the licensee's procedure PEP-362.
The licensee's core damage assessment procedure PEP-362, utilized methodology specified in the Westinghouse Owners Group Document, Core Damage Assessment Methodology, Rev.
2, November, 1984.
The inspector determined that there is a factor of about 100 difference for the Gap activities in the two documents.
Therefore when the procedure was used with data developed from the FSAR data the core damage was approximately 100 times higher that expected by the scenario developers.
The licensee identified the error in their critique process as
- an area needing review and corrective action.
The licensee documented the problem in their Adverse Condition Report (ACR) system with two objectives for corrective action.,
The first corrective action objective required'n assessment of the scenario review and data verification process and was documented in ACR number 92-362.
The second corrective action objective was to assess, clarify and document the most appropriate core damage assessment methodology to be utilized for given plant conditions in the licensee's procedures.
The second objective was documented ACR number 92-367.
The scenario developers also failed 'to develop containment air PASS sample data prior to the exercise.
Exercise controllers were quick to generate requested data during the exercise without any consequences.
However, the data should have been developed prior to the exercise play.
The inspector stated that a review of the licensee's corrective actions would be performed in a future inspection and tracked as an Inspector Followup Item (IFI).
IFI 50-400/92-16-01:
Review the licensee's methods for verifying Emergency Preparedness exercise scenario data and review the licensee's assessment and documentation for selected core damage assessment methodologies in a future inspection.
No violations or deviations were identified.
Assignment of Responsibility (82301)
This area was observed to determine that primary responsibilities for emergency'esponse by the licensee had been specifically established and that adequate staff was available to respond'to an emergency as required by
CFR 50.47(b)(1),
CFR 50, Appendix E, Paragraph IV.A, and specified criteria in NUREG-0654,Section II.A.
h The. inspector observed that the onsite and offsite emergency organizations were adequately described and the responsibilities for key organization positions were clearly defined in approved plans and implementing procedures.
A No violations or deviations were identified.
Onsite Emergency Organization (82301)
The licensee's 'onsite emergency organization was observed to determine that the. responsibilities for emergency response were unambiguously defined, that adequate staffing was provided to insure initial facility accident response in key functional areas at all times, and that the interfaces were specified as required by 10 CFR 50.47(b)(2),
CFR 50, Appendix E, Paragraph IV.A, and specific criteria in NUREG-0654,Section II.B.
The inspector observed that the initial onsite emergency organization was adequately defined; the responsibility and authority for directing actions necessary to respond to the emergency were clear; that staff were available to fillkey functional positions within the organization; and that onsite and offsite interactions and responsibilities were clearly defined.
The licensee adequately demonstrated the ability to alert, notify, and mobilize Carolina Power and Light (CPEL)
response personnel.
Augmentation of the initial onsite emergency response organizations was accomplished through mobilization of additional day-shift personnel.
Following the Alert declaration, the on-shift emergency organization was augmented with the activations of the Emergency Response Facilities (ERFs).
The inspector observed the activation, staffing, and operation of the emergency organizations in
/
N
the DCR, TSC, OSC, and the EOF.
The inspector determined that the licensee was 'able to staff and activate the facilities in a timely manner.
Because-of the scenario scope and conditions, long term or continuous staffing of the emergency response organization was not required.
A management control problem was identified with Damage Control Team (DCT) task prioritization.
During the exercise the inspector determined that the priorities for DCTs in the TSC and OSC did not match.
PEP-202, Emergency Repair Director, Rev.
4, August 1, 1992, stated, in part, that the Emergency Repair Director directs the implementation of necessary maintenance and repair actions such that priority is placed on reduction of unplanned radiological releases, placing the plant in a safe configuration and minimizing radiological exposure of maintenance personnel.
At approximately 10:15 the DCT task priorities in the TSC were:
2.
3.
"B Residual Heat Removal (RHR)
pump auto trip flag on over current
"A" Auxiliary Feed Water (AFW) lockout and over-current on AEB phases-bridge 9 megger Restoration of TSC electrical power At the same time the OSC DCT status board listed the following priorities:
A.
B.
C.
"B" RHR pump auto trip flag on over current, A AFW-86 lockout and over-current on A&B phases-bridge E megger Troubleshoot Emergency Response Facilities Information System (ERFIS) problem in the TSC Troubleshoot loss of TSC power The licensee corrected the OSC DCT status board in the OSC at about 12 noon to agree with the priority order established in the TSC.
The OSC continued to use alphabetic characters to rank the tasks.
The inspector discussed the need to maintain the task priorities during an emergency with licensee representatives.
The inspector noted that the errors in the priority order had not resulted in any difficulties in the exercise since there were only a few DCT missions and the OSC staff was not significantly challenged during the exercise.
However, the inspector pointed out the importance of good communications and clear objectives in mitigating accident conditions.
The licensee identified the problem in their critique process as an area needing review and corrective action.
The licensee documented the problem in ACR number 92-366.
The inspector stated that a review of
the licensee's corrective actions would be made in a future inspection as an IFI.
IFI 50-400/92-16-02:
Review the licensee's methods for establishing, communicating, and controlling DCT priorities in a future inspection.
No violations or deviations were identified.
Emergency Classification System (82301)
This area was observed to determine that a standard emergency classification and action level scheme was in use by the nuclear facility licensee as required by
CFR 50.47(b)(4),
CFR 50, Appendix E, Paragraph IV.C, and specific criteria in NUREG-0654,Section II.D.
PEP 101, Emergency Classification and Initial Emergency Actions, Rev.
5, August 3, 1990, was used to promptly identify and properly classify the scenario simulated events.
. The licensee utilized the procedure to make the following emergency classifications.
o The Alert was declared at about 08:15 a.m.,
due to a seismic event.
The Site Area Emergency was declared at about 10:06 a.m.,
due to breach of fuel and reactor coolant barriers.
o A General Emergency was declared at about 12:02 a.m.,
as a precautionary measure, based on existing plant conditions with large inventory of radioactive coolant in containment building, to make protective action recommendations to the State and local authorities.
In accordance with the Emergency Plan and PEP's, the Site Emergency Coordinator (SEC) retained the responsibility for making emergency classifications after the EOF was activated.
Around noon the SEC knew that the core had been damaged and the plant was experiencing problems with some plant systems.
Two concerns regarding the SEC's decision to enter the General emergency classification were discussed with licensee personnel in the critique process.
The first.concern involved the appropriateness
'of the General Emergency classification when only two fuel barriers had been breached.
When the classification was made, there was no apparent containment (third barrier) breach.
The SEC knew that he'ad significant amount of failed fuel and that containment radiation monitors were continuing to. climb.
During the critique process, the inspector learned that the SEC was also concerned about the integrity of plant systems, components and structures following the seismic even PEP-101 permitted the SEC to go to an General Emergency classification when radiological conditions warranted recommendation to evacuate or shelter the public.
The inspector determined that the licensee's emergency classification was permissible and in accordance with the licensee's emergency procedures.
Another concern involving the appropriateness of the General Emergency classification had to do with the dialogue between the Emergency Response Manager (ERM) and State representatives in the EOF and their influence on the SEC's decision to enter the General Emergency classification.
It appeared that the SEC may have been persuaded to enter the General Emergency classification based upon offsite
~
concerns.
The inspector in the EOF determined that the ERM was concerned about degrading plant conditions and discussed potential protective action recommendations with State representatives.
The discussions also included the status of offsite conditions.
During the critique process, the inspector determined that it was the SEC that made the decision. to go to a General Emergency classification based on his assessment of existing plant conditions.
The inspector determined that the SEC's decision was made in accordance with licensee procedures.
The inspector reported to licensee representatives that offsite conditions should not influence or determine an onsite emergency classification which should be based upon plant conditions.
The inspector also stated that it was the offsite agencies responsibility to evaluate the licensee's recommended PARs and to appropriately respond to the offsite public and ensure safety.
The emergency classifications were correct and made in a timely manner.-
No violations or deviations were identified.
Notification Methods and Procedures (82301)
This area was observed to assure that procedures were established for notification of State and local response organizations and emergency personnel by the licensee, and that the content of initial and follow up messages to response organizations was 'established.
This area was further observed to assure that means to'provide early notification to the population within the plume exposure pathway were established pursuant to 10 CFR 50.47(b)(5),
Paragraph IV.D of Appendix E to 10 CFR 50, and specific guidance promulgated in Section II.E of NUREG-065 The inspector reviewed the licensee procedure PEP-301, Notification of Non CPEL Emergency Response Organizations, Rev.
6, dated 7/1/90.
~1 The inspector identified numerous but minor errors or omissions in offsite agency notification messages, during the emergency exercise.
Problems identified included the following:
Onsite fire requiring offsite assistance was known prior to issuance of notification message number 1, but was not documented on a notification message until after the fire response was over.
Site evacuation of non-essential personnel was not documented in a notification message.
Notification message number 1 did not document a
notification to Chatham County.
o Prior to the declaration of a General Emergency, notification messages 3 through 6 did not indicate that no protective actions were being recommended (block 15.A.).
Authentication (block 4)
was not completed for notification message number 7.
Notification messages 7 indicated degrading conditions in block 8 without an explanation of changing conditions.
Message number 9 indicated a release was in progress but did not provide any offsite dose projections.
Dose projection information was available at 1:40 a.m.
The message was approved at 1:45 a.m. with transmission at 1:52 a.m.
Message number 10, Estimate of Projected Offsite Dose, New or Unchanged (Block 13),
was not indicated for updated dose projections.
o Message number 11 indicated that the plant stack release rate information was decreasing but the release magnitude shown in block 12 was the same as shown on message number 10.
Other offsite notification problems identified included the following:
Wrong phone numbers were utilized to contact Wake Count o The ERM provided preliminary information to the State authorities but did not provide similar information to the affected counties.
o Harnett and Chatham counties and the State were not on the selective signal system during the transmission of message number 4.
The agencies were.contacted individually by the Assistant Emergency Communicator number 1 to transmit the message.
Many of the followup notifications were close to or slightly in excess of one hour despite significant changes in plant conditions during the interim period.
o Initial messages number 5 {Site Area Emergency)
and.
number
(General Emergency)
were completed in 15 and 14 minutes respectively.
Followup notification messages number 6 and 11 were completed within 63 and 62 minutes of their previous message respectively.
Those notification messages slightly exceeded a licensee procedure requirement for completing notification message updates every 30-60 minutes.
The TSC notifications communicator indicated notification message transmission completion when as few as one of the offsite agencies was contacted.
The inspector reported to licensee personnel that all offsite agencies should be contacted, the message completed and receipt acknowledged within the fifteen minute notification period.
The licensee's controller staff identified most of the notification problems in their critique process.
Due to the nature and number of issues identified, the licensee documented the need to improve notification message process and content-in ACR number 92-365.
The inspector stated that a review of the licensee's offsite emergency preparedness agency notification process and procedures would be reviewed in a future inspection as an IFI.
IFI 50-400/92-16-03:
Review licensee's corrective actions for improved notification message content and timeliness, to offsite emergency agencies.
With the exceptions noted above, the licensee's State and local agencies notification messages were accurate and timely.
The licensee's communicators demonstrated the ability to contact the NRC Duty Office No violations or deviations were identified.
Emergency Communications (82301)
This area was observed to determine that provisions existed for prompt communications among principal response organizations and emergency personnel as required by 10 CFR 50.47(b)(6),
CFR 50, Appendix E, Paragraph IV.E, and specific criteria in NUREG-0654,Section II.F.
The inspector observed that adequate communications existed among the licensee's emergency response organization and offsite authorities.
The staff demonstrated good communication techniques by repeating transmitted information.
Exercise players also did an excellent job of declaring messages, as drill messages, during communications
.
No violations or deviations were identified.
Emergency Facilities and Equipment (82301)
This area was observed to determine that adequate emergency facilities and equipment to support an emergency response was provided and maintained as required by 10 CFR 50.47(b)(8),
CFR 50, Appendix E, Paragraph IV.E, and specific criteria in NUREG-0654,Section II.H.
The inspector observed the activation, staffing and operation of key ERFs, including the DCR, TSC, OSC, and EOF.
In addition, the inspector observed a fire drill.
a.
Drill Control Room Overall, operations personnel adequately assessed the problems faced 'during the exercise and their responses were timely and appropriate to the circumstances.
The Shift Foreman delegated responsibilities and redirected team actions as he recognized changing conditions and requirements.
The Shift Foreman effectively managed control room activities with respect to classification, analysis, and mitigation. The. Shift Foreman became the SEC upon implementation of the Emergency Plan.
The SEC classified the emergency according to the Emergency Action Levels (EALs) in PEP-101 and made the required offsite notifications.
No violations or deviations were identifie Technical Support Center The SEC requested activation of the TSC following the Alert classification at 08:15 a.m.
The TSC was staffed at about 08:35 a.m.
and the TSC assumed command of emergency operations at about 08:52 a.m.
TSC Command and Control was excellent.
There was no doubt who was in charge.
The SEC demonstrated the ability to maintain command and control over all emergency response activities conducted from the TSC.
Comprehensive well conducted TSC briefings were conducted approximately every 30 minutes by the SEC and his Directors.
All TSC personnel were attentive to the briefings.
Ambient noise level in the TSC was maintained at a very low level throughout the exercise.
Concurrent briefings of outlying TSC areas (e.g.
Accident Assessment Team)
were accomplished by ensuring an open microphone in the TSC during the briefings.
Formatted public address announcements were made following each TSC briefing.
Good use was made of the status boards in the TSC.
Boards were kept current and out-of-specification data and problem areas were annotated in red.
Initial and follow-up habitability evaluations of the TSC were promptly made.
Public Address (PA) messages were informative, frequent, clearly presented and heard by the inspector throughout the facility.
In general, TSC equipment performed properly, however one of the ERFIS monitors in the licensee's TSC failed to operate when energized.
The licensee repaired the monitor and had it operational before the exercise terminated.
During the exercise the TSC lost electrical power, in accordance with the scenario.
The staff responded appropriately and conti.nued their assigned duties.
Backup lighting in the facility was minimal.
The issue was identified as an improvement item in the licensee s critique process.
While a DCT attempted to restore TSC electrical power, they discovered that the TSC Automatic Bus Transfer bypass switch was not in normal position.
The control room was contacted and the switch was returned to its normal position on 8/25/92.
No violations or deviations were identifie Operational Support. Center The SEC requested activation of the OSC following the Alert classification at 08:15 a.m.
The OSC was fully staffed and,ready to support emergency operations at about 08:31 a.m.
Command and control in the OSC was low key with the OSC Director providing periodic briefings to the staff during the course of the exercise.
The inspectors monitored activities associated with the OSC organization, briefing and dispatching of response teams, and effectiveness in making necessary repairs to plant equipment as required.
It was apparent that personnel were prepared to implement the necessary actions requested by management to assist in the mitigation of problems incurred during the emergency exercise.
During. the course of,the exercise, several teams were dispatched by the.
OSC to provide for damage assessment, equipment repairs, monitor for radiological conditions and to align equipment for operation.
After identification of team requirements, the teams were organized, given thorough briefings, and after verification of readiness, were given permission by the OSC Director to accomplish required tasks.
Appropriate contact with the teams was maintained and a debrief was accomplished after most teams returned to the OSC.
The Radiation Control Coordinator provided excellent briefings, recommendations and route preplanning for dispatched teams.
The radiation protection staff did a very good job in supporting the teams-with planning, controls, surveys and escorts.
While the overall effort and staff performance was very good in the OSC, the licensee's controllers and players in the OSC identified numerous areas for improvement.
The inspector also reported to licensee representatives that the scenario did not provide sufficient equipment failures or tasks to challenge the facility's resources.
Inspector observed good use of repeat back communications in the facility and the noise level in the coordinators area was low.
Health Physics technicians provided periodic habitability surveys and radiation controls for the facility.
No violations or deviations were identified.
I
Emergency Operations Facility (EOF)
The SEC requested early activation of the EOF at 08:56 a.m., in anticipation of media interest.
The EOF was promptly staffed and partially activated with qualified personnel at about 10:02 a.m..
The responsibilities for offsite dose assessment, environmental monitoring and protective action recommendations remained at the TSC at that time.
Licensee procedure PEP-220, Step 9.2.2, Emergency Response Manager, Rev.
5, June 1,
1989, permitted the ERM to activate the facility without all functional capabilities.
The dose assessment personnel from the corporate office were in the EOF at 10:05 a.m.
and the EOF was fully activated and assumed all responsibilities at 10:15 a.m.,
approxi'mately
minutes after requested.
All staff were available in 69 minutes and the licensee met its commitment to staff the facility in 60-75 minutes.
The ERM demonstrated excellent command and control of the EOF.
The noise level in the EOF was minimal throughout the entire exercise.
The ERM provided informative updates and status of the plant.
Turnover of TSC functions to the EOF was timely and efficient.
The inspector observed that the EOF was properly equipped and staffed to provide technical assistance, dose assessment, and field monitoring team control.
The dose assessment team correctly assessed and integrated information from reactor systems status and trends, radiological monitoring, source term assumptions, and meteorological information to define the magnitude= and area of the offsite impact.
Deployment of.environmental sampling teams was timely and control of team movement for plume tracking was efficient.
Protective action recommendations were made promptly and transmitted to the State after the General Emergency declaration in a timely manner.
i Good State interaction was observed throughout the exercise.
Non-verbal dissemination of data via appropriate arrangement of status boards was good.
Security performance was prompt and effective in the establishment of access controls.
No violations or deviations were identifie Fire Drill A fire drill was conducted during the exercise with onsite and offsite fire fighting units participating.
Smoke began rising near the In-Service Inspection (ISI)
Trailers located outside the Radwaste Building at 08:02 a.m..
At 08:05 ISI trailer occupants evacuated the trailers and the fire alarm was sounded.
At 08:08 a
PA announcement was made for Fire Brigade response.
The fire Brigade arrived at the simulated fire scene at 08:17 on the plant fire truck in full fire fighting gear.
The Fire Brigade leader directed the teams efforts and fire hose lines were positioned to fight the fire.
At 08:23 a.m.
the team began to connect the truck hoses to fire hydrant and the hoses were charged at 08:26 a.m..
At 08:30 a.m.
the licensee's fire truck lost electrical power to the pump and could not get the pump to restart.
This reduced the effectiveness of the fire fighting capabilities of the truck which effectively became a manifold for the fire hoses.
At 08:38 the Holly Springs'ire Truck arrived on the scene and their firemen set up their equipment to fight the fire.
At 08:45 a.m.
the fire is reported out and the drill was terminated.
The inspector determined that the Fire Brigade team members drill quarterly, with 2 drills required each year for each member.
The inspector also determined that the brigade was required to report to the.fire scene in full gear within 15 minutes for satisfactory demonstration of responsiveness.
The plant Fire Brigade had arrived at the fire scene within 10 minutes during the observed drill.
During the fire drill critique, the inspector determined that the plant fire brigade was not aware that they were permitted to energize fire hoses during the drill.
The fire brigade was unable to attend a pre-drill briefing due to shift schedules and was not aware that it could charge fire hoses.
Team members at the critique believed that the fire hoses could have been charged earlier had they known they had permission to do so.
Security personnel processed promptly the Holly Springs fire engine and staff through the security gate and provided security for the fire scene.
The problem with the fire engine pump was identified by the controllers and the licensee documented the problem in ACR 92-368 for corrective action.
No violations or deviations were identifie Accident Assessment (82301)
This area was observed to determine whether adequate methods, systems, and equipment for assessing and monitoring actual or potential off-site consequences of a radiological emergency condition were in use as required by
CFR 50.47(b)(9),
CFR 50, Appendix E, Paragraph IV.B, and specific criteria in NUREG-0654,Section II.I.
The accident assessment program included both an engineering assessment of plant status and an assessment of radiological hazards to both onsite and offsite personnel resulting from the accident.
In general, both programs appeared effective during this exercise in analyzing the plant status so as to make recommendations to the SEC concerning mitigating actions to reduce damage to plant equipment, to prevent release of radioactive materials, and to terminate the emergency condition.
The accident assessment team correctly calculated the percent of core damage in accordance with licensee procedure PEP-362.
However, that calculation resulted in a unexpected fuel cladding failure of 110 percent which was about 100 times higher than expected due to bad scenario data provided to them (see paragraph 2).
During the exercise, the inspector noted that the Accident Assessment team utilized a hand written form for performing the core damage assessment calculation of section 9.4 of PEP-362.
The inspectors determined that the form contained an error in step 9.4.6. to determine the percent fuel over-temperature.
The PEP factor was 0.52 not 0.052 as was written on the form.
This resul'ted in percent fuel over-temperature calculations being in error higher by a factor of 10.
There were no errors that impacted the performance of the drill.
However, the inspector discussed the hazards associated with such forms and the-licensee committed to implementing a similar form into the licensee's controlled procedures if needed.
Licensee management reported that the use of such forms was not acceptable practice.
The dose assessment team correctly assessed and integrated information from reactor systems status and trends, radiological monitoring, source term assumptions, and meteorological information to define the magnitude and area of the offsite impact.
Deployment of environmental sampling teams was timely and control of team movement for plume tracking was efficient.
The inspector noted that the licensee's offsite dose status board showed off site doses and not dose rate but did not indicate the exposure period associated with the release and
dose calculation.
The issue was discussed with licensee representatives who committed to review the status board for possible changes to clarify the posting.
.Suggestions discussed by the licensee included: indicating the (one hour) release duration used for making the dose projection; listing offsite doses in dose rate; or listing both the dose rate (rem/hour)
and integrated dose in parallel columns.
No violations or deviations were identified.
Protective Responses (82301)
This area was observed to determine that guidelines for protective actions during the emergency, consistent with Federal guidance, were developed and in place, and protective actions for emergency workers, including evacuation of nonessential personnel, were implemented promptly as required by 10 CFR 50.47(b) (10),
and specific criteria in NUREG-0654,Section II.J.
The inspector verified that the licensee had and used emergency procedures for formulating Protective Action Recommendations (PARs) for off-site populations within the 10 mile Emergency Planning Zone.
Protective action recommendations were made promptly and transmitted to the State after the General Emergency declaration in a timely manner.
PARs were routinely reevaluated for accuracy and status updates were provided to the offsite authorities.
During the exercise the inspector noted that the Evacuation Zone Maps in the EOF did not show the correct status of all zones.
Sections G,H,I,J were shown as sheltered instead of evacuated.
All zones had been evacuated.
The licensee identified the issue in their critique process.
During the exercise the inspector observed that TSC and EOF personnel were not wearing Self-Reading-Pocket-Dosimeters (SRPDs)
or Thermoluminescent Dosimeters (TLDs) and a simulation of TLD/SRPD issuance was not observed.
A review of the licensee's procedures indicated a lack of procedural guidance for personnel radiation monitoring requirements in the EOF and TSC facilities.
Section K, Radiological Exposure Control of NUREG-0654, Criteria for Preparing and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Rev.
1 stated in Section 3.a, that each organization shall make provision for 24-hour-per-day capability to determine the doses received by emergency personnel involved in any Nuclear accident, including volunteers.
Additionally, each organization shall make provisions for distribution of dosimeters, both self-reading
and permanent record devices.
Harris Emergency Plan (HEP) Section 4.6, Protective Actions for On-Site Personnel provided requirements for protecting onsite personnel.
Section 4.6.3.2, Exposure Records for Emergency Workers, stated, in part, that emergency workers will receive SRPDs and TLD badges during an emergency.
The plan was not clear concerning dosimetry requirements for workers in the EOF.
However, HEP, Section 3.5, EOF described the emergency equipment for the EOF and Section 3.5.3, Emergency Equipment Supplies, indicated that dosimeters and TLDs were available in the EOF.
Licensee implementing procedures PEP-223, Radiological Control Manager, Rev.
5, September 5,
1989 and PEP-374, Radiological Controls for the Emergency Operations Facility, Rev.
0, December 20, 1991; did not include any guidance for issuing TLDs and SRPDs to all EOF emergency workers.
PEP-374 required the radiation control technician "... to post dosimetry inside the EOF."
Additionally, PEP-370, Radiological Controls for Technical Support Center, Rev 0, June 23, 1992 did not provide any guidance for issuing TLDs and SRPDs in the TSC.
The inspector observed that emergency workers in the EOF and TSC were never issued TLDs or SRPDs during the exercise and thus, the Radiological Controls Manager did not have the capability to determine the doses to emergency personnel in the EOF and TSC.
The licensee identified the issue in their critique process and documented the finding in ACR number 92-364 for review and corrective action.
The inspector stated that a review of. licensee procedures for personnel radiation dosimetry issuance guidance would be reviewed in a future inspection as an IFI.
IFI 50-400/92-16-04:
Review licensee procedural guidance for issuing emergency workers personnel dosimetry in ERFs.
Demonstration of assembly and accountability procedures were not exercise objectives and were simulated.
No violations or deviations were identified.
11.
Exercise Critique (82301)
The licensee's criti'que of the emergency exercise was observed to determine whether shortcomings in the performance of the exercise were brought to the attention of management and documented for corrective action pursuant to
CFR 50.47(b)(14),
CFR 50, Appendix E, Paragraph IV.E, and specific criteria in NUREG-0654,Section I The licensee conducted facility critiques with exercise players immediately following the exercise termination.
Licensee controllers and observers conducted additional critiques prior to the formal critique to management on
'ugust 28, 1992.
With the exception of the EOF player critique, critiques were excellent, particularly the Lead Controller Critique.
The critique process, including the critique to management, was well organized.
During the controllers critique, detailed findings were openly discussed with the clear objective to find and document problems and make program improvements.
The licensee's critique addressed both substantive deficiencies and improvement areas.
The conduct of the critique was consistent with the regulatory requirements and guidelines cited above and considered a program strength.
The licensee's player critiques were not as good and interaction by players was the lowest in the,EOF player critique.
The licensee recognized the weakness and identified the issue as
=
an area for improvement and documented the finding in ACR number 92-363.
Licensee action on identified findings will be reviewed durin'g subsequent NRC inspections.
No violations or deviations were identified.
12.
Exit Interview The inspection scope and findings were summarized with those persons indicated in Paragraph 1.
The inspector described the areas inspected and discussed in detail the inspection results listed below.
The licensee did not identify any such documents or processes as proprietary.
Dissenting comments were not received from the licensee.
Item Number Descri tion and Reference 50-400/92-16-01 IFI: Review the licensee's methods for verifying Emergency Preparedness Exercise Scenario data and review the licensee's assessment and documentation for selected core damage assessment methodologies in a future inspection.
{Paragraph 2)
50-400/92-16-02 IFI: Review the licensee's methods for establishing, communicating, and controlling DCT priorities in a future inspection.
(Paragraph 4)
18'0-400/92-16-03 50-400/92-16-,04 IFI:
Review licensee's corre'ctiye actions for improved notification message content arid timeliness to-offsite emergency agencies.
(Paragraph 6)
IFI: Review licensee procedural guidance for issuing emergency workers personnel dosimetry in ERFs.
(Paragraph 10)
Attachments:
Exercise Objectives and Narrative Summary
EXERCISE SCENARIO TIME LINE 08:00 09:00
'10:00 11:00 12:00 13:00 14:00 15:00 DRILLCONTROL ROOM TSC
OSC EOF FACILITY ACTIVATION STATUS RADIOACTIVE RELEASE CLASSIFIC-ATION I
SITE EMERGENCY ALERT L k A A
.A A
@4gO
$ @0 y ~4 ~O Q. ~o P INITIALCONDITIONS: 100% POWER. ALL EQUIPMENT OPERATING PROPERLY, NEAR THE END OF CORE UFE I k {. ~o. 4'go ~+
'x+cP ~+ Q~ yV golgi+ O+ ~O Q'L qQQ Q 0 4<O 4 Q Q+ Q'+ MAJOR SCENARIO EVENTS Q o+ pQ HNP EP EXERCISE AUGUST 25, 1992 INDICATES TIME FRAME OVER WHICH ACTIVATIONOR CLASSIRCATION IS EXPECTED TO OCCU August:25'992 DRILL SCENARIO NMtRATZVE (08 15 30) V 08:00 08: 04 08: 09 08:25 09:20 22 09:34 09:55 Page 1 of 2 The Drill begins in the Drill Control Room (DCR). The plant has been on line for 213 consecutive days. The plant is operating at 1004 power. The Drill Control Room receives indications of a Seismic event on the Seismic Monitor in the Control Room. The SCO will enter AOP-021, "Seismic Disturbances>> and have the 'operators commence walkdowns of all plant areas. A leak in the COi gas storage system and in the site fire header will be identified. This seismic event meets the ALERT emergency action level criteria. It will not require a plant shutdown. A Fire occurs in a trailer west of the K-Bldg, in the protected area. This is a large fire and requires Off-Site assistance. An ALERT should be declared by this time and activation of the TSC and OSC will begin. TSC and OSC activation is anticipated by this time. RMS alarms are received on the RM-11 console which indicate that fuel cladding damage may have occurred. Fuel failure Radiation monitors exceed the Emergency Action Level setpoint for fuel breach indication. The total Fuel Clad damage is 1.54 which is above the EAL threshold of greater than 1%. This will not cause the plant to upgrade to a Site Emergency classification but, will force the plant to remain in an ALERT following completion of the Seismic Event walkdowns. A small Reactor Coolant to atmospheric leak begins inside of Containment. The initial leak rate is 5-10 GPM but increases rapidly. 10:00 The RCS leak rate is increasing and has exceeded 50 gpm. This meets the SITE EMERGENCY criteria due to a breach of the Fuel and the RCS Fission Product Barriers. 10: 04 The RCS leakrate has increased to =300 GPM and the Operators initiate a Safety Injection (or an Automatic SI occurs) due to low Pressurizer Pressure. When the SI actuation occurs, the "B" RHR pump fails to start and cannot be started from the Main Control Board. 'The "A" MDAFW pump fails to start on the Safety Injection signal. A SITE EMERGENCY should be declared by this time and EOF resources will be requeste August 25 '992 DRILL 8cENARzo NARRATxvd t 08: bb . "";XS i 30) 10:25 10:45-10:50 Page 2 of An unexpected Main Steam Line Isolation signal is received resulting in the need to use SG Power Operated Relief Valves to control RCS temperature. ~ L . %hen failed to transfer to the alternate power source as a result of the earlier seismic activity. The Reactor Coolant System cooldown should start at about this time (>10:45 & <11:00). The plant should be cooled down at near the maximum rate of 100 F/Hr until the plant is ready to go on RHR. ll:15 12:05-13:20 EOF activation is anticipated by this time. The Selective Signalling system, primary communications with the State of NC and nearby counties, fails. The public telephone system will need to be used as a back up. >13:15 6 <13:30 RHR cooling is initiated using the "A" RHR loop with the "B" loop still out of service. When the pump fs started a break occurs in the RHR piping in the "A" RHR heat exchanger room. When this occurs a PA announcement to initiate "Branch Alpha" will be made to alert controllers to the fact. The break is on the Bypass line. RHR loop suction valves 1RH-1 and 1RH-2 fail to close when attempted from the Control room. Auxiliary Operators will be dispatched to attempt to isolate the leak in the RHR line. This breach of the RHR system results in a breach of the Containment Fission Product Barrier which is the Third Fission Product Barrier to fail. The loss of all Three Fission Product Barriers meets the criteria of a GENERAL EMERGENCY. 13:50 13:55 A General Emergency should have been declared by this time. Auxiliary Operators or OSC personnel successfully isolate the RHR leak by closing 1RH-19 in the Reactor Auxiliary Building. Efforts should be underway to repair the "B" RHR pump to continue the RCS cooldown to cold shutdown. =14:35 15:00 to 15:30 "B" RHR loop is placed in service to continue the cooldown to less than 200 F between 14:30 & 14:45. It is anticipated that 200 F would be crossed at about 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br />. The Drill will be terminated when the cooldown using "B" RHR loop is in progres <AC ICAU 700 5 Ml 0$)S NtS ~L(I) V.S HVCLCA<tAfGVLATOAYCOMMISSION INSPECTOR'S ACPOAT Off' N clear Reactor Regulation to 40 tlI ttItt0 ' ~ i~ o ~ It <I ~ t'tt'vt +to I WfCWcL ~lr'Irtt~ MC(vstl vtvooa Iaottso(ftOV Irtl ti<$(11 M - Uootlr 0 - 0(ltft A attLAC( OOC ~ IIVo tseO t ~toa V(IVSI 40 tsr tooovC ~t>>)SO<It I~ 1(loaf to 1$ $ 10 V(IIWS~ IC Olll UO IAOM MO. OAT TA. Mo. OAT Ta, t(a too Os v<v($ TICATIOV IIVSt((f 1OV wSIICTtov ~(alolU(00'I 01<<(a I a(CtoVALOIIKC5'TAIS 1($ 10(VT IVSt(CTOA ~ (1IOAMAVC(Att1AISALT(AM oocAV<iaftov Cool ol atcr)v>>% CovovCT. Nto l(1t>>TT ISto t(UC 05)0 Uttrt<rot atootl. wtrtvvlttoortt at<ttttt "i<<<0<v Il<<t<< 'h<< 1(C<OVALACTtot< IC<<r<I other sot ottttt kl( SOALI $$ 1. 1(CIOVALOII<CIll.Tla SAT (1T 07 - W(lo(VT tVIOACIU(41 4<CMT AVO<f 10 tllvI5(C ll wrtv1 v( ~ $ ~ ttv(vf<(stoat I) ot>oal UCMf 'TI$11 5 ~(C<ll a - vtvoaa Ulf l((f Irtt Or ACT<V<IT(ovov(T(ot(<<t<tvr oot owt I ~ wovtar tVT($1KlftOV A ~ C ~t ~ t<<V t * t<< ttt t(<<r<1 o<<t sot otal I Cl(la TOTALvvvBta Ot Tr)LAI<045 lvo OfVIAIKW5 CltlolCtUl4 1 CovllalvC( <<ILO 1(tol'I (Ot<IAW7 107 Wlolltl1<OV lta( IOAUSSI Oa alC l(11(11$ 5V(0 lltoll 5(41 '10 tto Ioa A(1OV L(11(a 01 1(toll I~ AttSU<ITALOaf t 2 - va)LATIOU 0(VLATOII A I C ~041 A ~ C ~) I. TIS l ~ C ~) I 'rts UO OAT ~I Mo Ol' Ta UODVLC <VIOAUl1tot< Uoovlt wloovo ~tov IC Co << X C ~ v u UODvlc VVUItatvst Qg rt <<tt,)o$ Vv<<tv <I 0vv t r ~ V E V 0 0 V ~II ot vrl o oN V UOOVll ~to IOLLOWVt v <<N ov o t~ gV UOOVLfVVUSI~ 1451 bt (o$ Q Vvrt K <<vf tt 0vv v O V vo<< ~lt ~t vrlr1 r v o 1V v g << t Uoovll 110 Ioltowvt ~ ~ Wt I I ~I<It<I ~. ~ I N , rr 1 tr tt, ~ t<< t tt ~tltr tt, I 7) ~ I<AC SOAll 704 IS.III 17 I) 1$ 10 71 17) I 17 tS 1 ~ 1 ~ I'I 71 7I See Reverse side for Examp)e. 0UTST~plgG ITE T OIL) - FOR NBl ITFNS ONLY Fons T-'IIT NIT 2 NIT 3 NIT I UHLT UHlT 2 UHI'f 3 UHlT 4 ll CE ACILITY N% ]NDULE DESCRIPTIVE TITLE RESPNISISLE ISOIVIOuAL RESP INlT l NIT 2 NIIT 3 NIT i CID fmuuLE t ELO DESCRIPTIVE TITLE IilT I INIT 2 NIIT 3 INIT I IZH RESP HZ3 EClZ3 >T VE LE See Reverse side for Example. OUTST~plgG ITE T (Oll) - FOR NN ITFtfS ONLY Form 7-i NIT 1 (NIT 2 tNIT 3 tNIT 4 UHLY UHET 2 UNI't 3 usta ILITY Nh% ]SDULE TYPE Z. / OESCRIPTIVE TITLE RESPNS ISLE INOIVIDUhl RESP lNIT I NIT 2 NIT 3 lNITi )IN/LE t l5Z3 DESCRIPTIVE TITLE RESP UNIT l tNIT 2 LNIT 3 lNIT 1 ERR fNNlLE f ABACA oT VE ITLE RESP ~cTl t