IR 05000416/1997015
| ML20217H310 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 10/09/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20217H308 | List: |
| References | |
| 50-416-97-15, NUDOCS 9710150118 | |
| Download: ML20217H310 (25) | |
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l ENELOsuBE-i
- U.S. NUCLEAR REGULATORY COMMISSION
! REGION IV
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i Docket No.: 50-416
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i, Licence No.: NPF 29 Report No.: 50-416/97-15
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l Licensee: Entergy Opeiations,-Inc.
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} Facility: Grand Gulf Nuclear Station-
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- Location
- nNaterloo Road j- Port Gibson, Mississippi i
f Dates: September 16-19, 1997 Inspectors: Gail M. Good, Senior Emergency Preparedness Analyst, Team Leader i- Thomas O. McKernon, Reactor Engineer 4 William H. Rankin, Technical Assistant, Region ll Thomas H. Andrews, Radiation Specialist j_
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Approved By: Blaine Murray, Chief, Plant Support Branch
Division of Reactor Safaty
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. Attachment: Supplemental Inspection Inf ormation
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{ 9710150118 971009 i PDR ADOCK 05000416 j G PDR i
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2-EXECUTIVE SUMMARY Grand Gulf Nuclear Station NRC Inspection Report 50-416/97-15 A routine, announced inspection of the licensee's performance and capabilities during the full scale, biennial exercise of the emergency plan and implementing procedures was performed. The inspection team observed activities in the control room simulator, technical support center, operations support center, and emergency operations facilit Plant Suooort
- Overall, the control room staff's performance was good. Communication practices met management's expectations (three-part communications, peer checks, and self-verifications) and contributed to mitigation efforts. The crew was kept well informed through frequent briefings. Emergency conditions were quickly recognized and classified. Offsite agency notifications were made in a timely manner. Some -
- - inaccurate information was documented on offsite agency forms which could have
[ affected event reconstruction, and some outgoing information was unclear j (Section P4.2).
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- Overall, the technical support center staff's performance was good. - Good technical l
analysis resulted in timely and proper emergency classification. Effective mitigating 1- strategies were developed and good command and control were demonstrated.
j Offsite notifications and protective action recommendations were correct and -
l- timely. Internal communications was ineffective at times and could have affected
! response efforts. _ Briefings were frequent, but content occa*ionally lacked key information, such as center activation time and changing radiological conditions -
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L -(Section P4.3).
- Overall, the operations support center staff's performance was generally satisf actory. Two exercise weaknesses were identified: one for f ailure to monitor and maintain supplies of self-contained breathing apparatus for long term center operation, and one for f ailure to establish protective measures for security personnel. Habitability surveys within the operations support' center were performed often and correctly. Response team dispatch was delayed by fragmented and
_ prolonged briefings (Section P4.4).
- Overall, the emergency operations f acility staff's performance was generally satisisctory. Offsite agency notifications were timely and generally correct. An exercise weakness was identified for f ailure to make protective action recommendations in three affected sectors during the wind shif t. Briefings, communications, and information flow generally suppo:ted response efforts. Dose P
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[ assessment personnel were initia:ly unaware of the general emergency declaratio Dose assessment activities were generally good Release duration times used in _
dose projections were not always accurate, anu the methodology used was not fully consistent with Federal guidance. Facility habitability, field team control, and interactions with of fsite responso teams were ef fectively demonstrated
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- A lim;tation in the emergency action levels was identified during the scenario review.
- Appropriate corrective actions were taken prior to the exercise. The scenario was sufficiently challenging to test onsite response capabilities. Exercise control was
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good. Appropriate action was taken to resolve a simulator modeling problem (Section P4.6).
- Post-exercise critiques were thorough, open, and self critical. The management I
critique was comprehensive and self critical but used a low threshold for identifying strengths. The peer group identified several very good issues. Management support 4 and input was evident. Overall, the critique process was identified as a strength (Section P4.7).
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[ P4 Staff Knowledge and Performance in Emergency Preparedness P Exercise Conduct and Scenario Descriotion (82301 and 82302)
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l The licensee conducted a full scale, biennial emergency preparedness exercise
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beginning at 8 a.m. on September 17,1997. The exercise was conducted to test
- major portions of the onsite (licensee) and offsite emergency response capabilities, The licensee activated its emergency response organization and all emergency j response facilities. The Federal Emergency Management Agency evaluated the j offsite response capabilities of the States of Louisiana and Mississippi, and Claiborne j county (Mississippi) and Tensas parish (Louisiana). The Federal Emergency
[ Management Agency willissue a separate report, s The scenario for the exercise was dynamically simulau.d using the licensee's plant-
- _ specific simulator. The initial scenario conditions. included the unit operating at 100
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percent power near the end of its current operating cycle. The Division I diesel l generator failed a surveillance 23.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> earlier and was out of servic : Maintenance found a bad bearing and was expected to return the diesel to service
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e The 115 kilovolt transmission line from Port Gibson was out of service due to a i logging accident. Entergy repair crews were dispatched to repair the damage.
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Control Rod Drive Pump A was out of service for maintenance and was expected
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back the next day. The low pressure core spray pump was out of service due to
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motor problems and was not expected back for several days. The weather was partly cloudy with variable winds from the southwes Subsequent simulated events were as follows:
- At 8:40 a.m., a single contro! ro-1 drif ted into the core untilit reached notch Position 36. The operating crew took actions directed by Offnormal Procedure 051-02-IV 1, " Control Rod / Drive Malfunctions," Revision 103, and applicable technical specification * At 9 a.m., high radiation alarms were received on the offgas pretreatment radiation monitors. The crew continued to reduce power, taking actions directed by Offnormal Procedure 051-0211-2, "Offgas Activity High,"
Revision 19, while the shift superintendent reviewed Emergency Plan Procedure 10 S 01-1, " Activation of the Emergency Plan," Revision 10 >
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. * At 9:05 a.m.- the shift superintendent declared an unusual event, based on
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the offgas pretreatment monitor reading greater than 1,400 millirem per hour, and assumed the duties of the emergency directo * Main steam line high radiation alarms and high.high off gas protreatment radiation alarms were received a 9:14 a.m. The operating crew manuall scrammed the reactor at 9:15 a.m., closed the main steam isolation valves and the main steam line drains, and entered Emergency Operating Procedure EP- * At 9:17 a.m., the shif t superintendent declared an alert based on main steam line radiation levels exceeding the radiation monitor trip setpoint. - The operating crew controlled reactor pressure, using the safety relief valves and reactor level, by feeding with the condensate booster pumps and Control Rod Drive Pump * At 9:26 a.m., the plant supervisor directed the crew to place Residual Heat Removal Systems A and B in suppression pool cooling mode and to initiate the reactor core isolation cooling pump. The reactor core isolation cooling pump tripped on overspeed at 9:28 a.m. Attempts to restart the pump were unsuccessfu * A loss of offsite power occurred at 9:50 a.m. Division 111 diesel generator started and tied onto the Division 111 bus. All Division'llt support systems ran as expected. Divisions I and il engineered safety features buses were not powere * The emergency classification was upgraded to a site area emergency at 10:22 a.m. due to the inability to isolate the^ reactor core isolation cooling steam line and increasing indications of steam leakage into the reactor core isolation cooling pump room (high radiation levels and visual verification of steam leaking from the room).
- Control room operators were directed to start the high pressure core spray pump to maintain reactor level; however, the pump tripped, from overcurrent, upon star * A steam release from a blowout panel on the east side of the auxiliary building was reported at 10:43 * Reactor water level decreased to top of active fuel and emergency depressurization criteria were me .- s
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- At 10:54 a.m., the emergency classification was upgraded to a general emergency due to a loss of two fission product barriers with a potential for loss of the thir * Reactor level decreased below active fuel level at about 11:00 a.m. The high pressure core spray jockey pump was used to inject water into the vesse * The 115. kilovolt line was returned at 12:20 p.m. The crew energized the engineered safety features buses and started Residue.1 Heat Removal Pumps A and B, and Control Rod Drive Pump B. The control rod drive pump tripped and the emergency core cooling systern suction strainers were clogge * At 12:30 p.m., the operatir< arew aligned Standby Service Water Loop B to Residual Heat Removal Loop r3 and began injecting into the reactor vessel at 8,500 gallons per minute. Reactor vessel water level returned to the normal band by 12:38 * The Reactor Core Isolatien Cooling System Valve E51F0063 was closed at 1:27 p.m. The valve closuie and reactor pressure (0 pounds per square inch
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gage) terminated the releas * Exercise activities were terminated at 1:52 P4.2 Control Room insoection Scone (82301-03.02)
The inspectors observed and evaluated the control room operating crew in the plant-specific simulator as they performed tasks in response to the exercise scenario
+ conditions. These tasks included event detection and classification, diagnosis of plant conditions, offsite agency notifications, internal and external communications, and adherence to the emergency plan and procedures. The inspectors reviewed applicable emergency plan sections, procedures, conduct of operations guidance, logs, checklists, and notification forms generated during the exercis Observations and Findinas The operating crew recogn:ted actions required by the technical specifications and acted promptly to implement them. For example, af ter performing a quick start surveillance of the Division 11 diesel generator which tripped on overspeed, the operators realized they were in a shutdown action statement and started reducing power by reducing reactor recirculation flow and by driving control rods into the cor J
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The simulator control room craw quickly recognized emergency conditions and correctly used emergency action evels to classify the unusual event and alert scenario events. The shif t superintendent declared an unusual event based on the offgas pretreatment system reading 2000 millirem per hour at 9:05 a.m. and assumed the duties of the emergency director. At 9:17 a.m., the shift superintendent declared an alert based on main steam line radiation levels exceeding the radiation monitor trip setpoint. Oifsite agency notifications were made within the required time limits.
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Communications within the control room were good. Three-part communications, peer checks, and self verification were frequently performed and contributed to evsnt mitigation efforts. Three-part communications involved e statement made by one person, repeated by the person who was listening to the statement, then confirmed as correct by the first perso Although external communications from the corerol room to other response facilities were good, there were occasions when outgoing communications were inaccurate and when incoming communications were incomplete. On one occasion, a miscommunication between the control room and the NRC resulted in the need to repeatedly clarify what injection sources were operating at 9:44 a.m. The control room cominunicator had conveyed to the NRC that reactor level control was accomplished with the high precsure core spray pump. This was later corrected to
indicate that the condensate booster pumps and the control roc drive pump were the injection source ,
On other occasions, it was apparent that the control room was not advised of conditions occurring outside the plant. For example, during one part of the exercise, the wind direction shifted from 335 degrees to 33 degrees. This information was not shared with the control room. Moreover, changes in offsite protective action recommendations and decisions were not provided to control room personnel, in addition to the personal considerations, the informat!on would convey offsite impac Inspectors observed that inaccurate information was documented on some offsite message forms such that event reconstruction would have been affected. For example:
- The control room communicator who made the off aite notifications for tha unusual event erroneously recorded the notification time as 9:17 a.m., using a wristwatch, rather than the simulator clock. The actual time was 9:10 * The shif t superintendent did not complete Block 7 (reactor shutdown block)
before the communicator made the offsite agency noti'ication for the unusual event. The communicator brought the item to the attention of the snift
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. superintendent af ter completing the notifications. The shift superintendent added the information to the form. As a result, the form did not accurately reflect the information provided to offsite agencie The inspectors observed that the operating crew was kept well informed through frequent briefings by the plant supervisor and the shift superintendent. Briefings were well organized, solicited operator's input, as well as questions, and had a definitive end. Briefings also contained discussions about success paths, actions needed to bring needed equipment back into service, and considerations for ( potential environmental hazards for response teams. Af ter the emergency director
! responsibilities were transferred from the control room, the results of these discussions and recommendations were conveyed to the emergency directo The operating crew maintaineci a good, questioning attitude. The crew was briefed on actions that were planned for long term cooling of the reactor core and plannnd activities to recover balance of plant power to take reactor coolant system
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chemistry samples and provide power to the transverse incore probe system to ascertain the geometry of the reactor cor In addition to the above, the inspectors observed good control board manipulations with peer checking routinely performed. Peer checks were also performed for emergency action level determination Conclusions Overall, the control room staff's performance was good. Communication practices met management's expectations (three-part communications, peer checks, and self-verifications) and contributed to mitigation efforts. The crew was kept well informed through frequent briefings, Emergency conditions were quickly recognized and classified. Offsite agency notifications were made in a timely manner. Some inaccurate information was documented on offsite agency forms which could have affected event reconstructior', and some outgoing information was unclea P4.3 Technical Suocort Center insoection Scone (82301-03.03)
The inspectors observed and evaluated the technical support center staff as they performed tasks necessary for response to exercise scenario conditions. These tasks included staffing and activation, accident assessment and mitigation strategies, event classification, offsite notifications, f acility management and control, onsite protective action decisions and implementation, internal and external cornmunications, assistance and support to other activated emergency response f acilities, and prioritization cf response activities for accident mitigation. The
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r-9-inspectors reviewed applicable emergency plan sections, emergency plan implementing procedures, checklists, and logs, b. Observations and Findinas l- The technical support center was promptly staffed and activated af ter the alert classification. Personnel arrived within minutes of the alert,and the center was fully activated within 40 minutes. Technical support center staff properly used the staffing board to maintain continuous accountabilit I Upon activation, the emergency director in the technical support center assumed the responsibility to classify emergency events from the control room. The technical support center manager, acting as the emergency director, promptly and correctly classified the site area and the general emergoncie The inspectors observed that the technical support center staff worked well as a team to identify degrading plant conditions that would' warrant upgrading the emergency classification. The coordination between the emergency director and the technical support center coordinator in the utilization of the emergency action levels for emergency classification purposes was particularly effectiv All offsite notifications made fro.n the technical support center were timely, in accordance with procedural and regulatory requirements, and contained sufficient information to f acilitate the implementation of offsite protective actions. Technical support conter communications personnel were proactive in resolving delays in message concurrence that may have adversely affected timely offsite notification The emergency director generally e'xercised effective command and control. The emergency director delegated the responsibility for conducting briefings to the technical support center coordinator. Most of the status briefings were generally clear, concise, and sufficiently frequent. Briefings were announced approximately 5 minutes in advance to allow center personnel ar. opportunity to prepare. Priorities,
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based on changing plant conditions, were revised as necessary with input sought from technical staf Some shortcomings were noud with respect to the content of the technical support center briefings. The briefings lacked certain information which was available to the emergency director and to the center coordinator but which was not adequately conveyed to center personnelin a timely manner. For example, although the technical support center was activated at 9:54 a.m., according to the coordinator's logbook, there was no clear statement to all emergency response personnel that the technical support center was activated and in the lead role for response action Also, although the emergency operations f acility became operational at approximately 11:05 a.m., technical support center personnel were not briefed regarding transferred responsibilities. Also, the status of protective action
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10-recommendations and changing radiological conditions onsite and offsite were not adequately addressed in technical support center briefing The technical support center emergency director, coordinator, and supporting technical staff generally worked as an effective team to determine feasible accident mitigating actions. Discussions were open such that subordinate technical staff questioned certain actions and offered alternatives. Recommendations were generally based on good technical analysis leading to conservative decision makin Communications between the technical support center coordinator and the radiation protection manager were ineffective at times. For example, at approximately 10:43 a.m., the technical support center coordinator was informed that an auxiliary building blowout panel had lif ted due to pressure from a steam leak creating an unmonitored release pathway. The radiation protection manager was not promptly informed of this and only became aware of a release in progress wher levated radiation levels were detected by field monitoring teams approximatel; 10 minutes later. The technical support center coordinator did not inform the rachtion protection manager when a reactor core isolation cooling sy': tem isolation valve was repaired and shut. These actions terminated the unmonitored release. Overall, the radiation protection manager and supporting technical staff adequately performed
! their assigned functions but improved communications and increased awareness of changing plant conditions were areas identified for improvemen The technical support center layout generally provided for an efficient work environment. At times, the inspectors noted that background noise levels, largely due to air conditioning and ventilation systems, were detrimental to the conduct of briefings and verbai communication A board used to monitor the status of operational support center teams was kept current and provided essentialinformation to the emergency director concerning completed missions and changing priorities for dispatched teams. However, some technical support center status boards were not maintained current with changing conditions and significant exercise events. For example, during the period between 12:46 p.m. and 1:51 p.m., the radiological status board was not updated for changing radiological condi* ions. During this period, there were significant changes with respect to the release in progress, shifting wind directions, and protective action recommendations. The radiologica' status board was not updated for protective action rect mmendations at any time during the exercis During the technical support center initial activation the inspectors observed radiation protection personnel performing habitability surveys, including the setup and operation of an air sampler. Following the radiological release the inspectors confirmed that a barricade, proper posting, and a frisking station were established at the entrance to the center. Radiation protection personnel performed routine
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t habitability surveys on a sufficient frequency. The inspectors concluded that habitability within the center was p'operly monitored and maintaine ' Conclusions
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Overall, the technical support center's performance was good. Good technical analysis resulted in timely and proper emergency classification. Effective mitigating
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strategies were developed and good command and control demonstrated. Offsite notifications and protective action recommendations were correct and timel Internal communications were ineffective at times and cou'd have affected response efforts. Briefings were frequent, but content occasionally lacked. key information, such as center activation time and changing radiological conditions.
- P4.4 Ooerations Suonort Centet I Insoection Scone (82301-03.05)
The inspectors observed and evaluated the operations support center staff as they performed tasks in response to the scenario conditions. These tasks included functional staffing and inplant emergency response team dispatch and coordination in support of control room and technical support center requests. The inspectors reviewed applicable emergency plan sections, departmental procedures, instructional
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guides, logs, checklists, and forms generated during the exercis Observations and Findings The operations support center was quickly staffed and activated within 35 minutes
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of the alert declaration. Center setup and communication links with other facilities were done in accordance with procedures. The operations support center coordinator announced when the center was declared operationa The inspectors observed preparation, briefing, dispatch, control, and debriefing of emergency response teams. Fifteen teams were formed and 9 teams were dispatched during the exercise. Two of the teams were monitoring teams; 1 for onsite monitoring, and the other for offsite monitoring. Six of the teams were not dispatched due to changing priorities or termination of the exercis Accountability of personnel assigned to teams was performed using a team tracking board. There was space for recording the departure and return times for the tea Forms were maintained for the teams to document briefings and task assignment The inspectors determined that continuous accountability was being properly maintained for the operations support cente _.
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-12 The inspectors reviewed documentation associated with emergency response teams to assess the timeliness of team dispatch. The briefing times recorded on the briefing forms were compared to the time the team departed from the facility. In two cases (both critical tasks), the inspectors observed that there was approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> between the briefing and dispatch times. During the exercise, the inspectors noted that the times recorded on the briefing forms were not consistently applied in that for some briefings, it was the start time, for others, it was the time the briefing was complete Team briefings were typically performed in tvio parts. One briefing would involve radiological conditions, protective clothing requirements, and precautions. The other briefing discussed the task and work related precautions. These briefings were performed at separate times. The inspectors observed instances where briefings had to be reperformed due to changing plant and radiological conditions or changing task scope. As a result, the inspectors determined that team dispatch was delayed due to the fragmented and prolonged briefing process. Because the task planning process was not observed, the inspectors cc,uld not determine if the planning of the task was a contributing f actor. This issue was not identified as an exercise weakness because the teams were dispatched and able to mitigate the consequences of the acciden The inspectors reviewed the documentation associated with the of ? site monitoring team dispatched from the operations support center. Control of this team was subsequently turned over to the emergency operations f acility. The following observations were identified as areas for improvement:
- According to Procedure 10-S-01-29, Revision 9, " Operations Support Center," Section 6.3.5, personnel on the offsite monitoring team were to have appropriate dosimetry and appropriate dosimetry setpoints. The inspectors could not identify -where this information was recorde * 10 S-01-17, Revision 12. " Emergency Personnel Exposure Control,"
Section 6.4.1 discussed exposure controls for offsite monitoring teams and required a separate emergency dose monitoring form be filled out for each offsite monitoring team member. No documentation could be produced to demonstrate that this was performed for the offsite monitoring team dispatched from the operations support cente During the exercise, a simulated release occurred. The licensee established radiation control boundaries at the entrance to the operations support center. These included establishing a boundary for contamination control, f acilities for personnel and equipment monitoring, and the establishment of habitability controls within the operations support center. The inspectors observed these activities and determined that they were properly performe J
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-13- I After the simulated release, teams dispatched from the operations support center were required to wear protective clothing and respiratory protection. The form of respiratory protection selected was the seif contained breathing apparatus. The licensee maintained a supply of self contained breathing apparatus bottles and face pieces within the operations support cente According to Procedure _10-S-01-29, Revision 9, " Operations Support Center,"
Step 6.3.1.a(2), supplies of protective clothing and self contained breathing apparatus air reservea were to be monitored and replenished as necessary. The inspectors observed the following:
- Air bottles were being used as teams were dispatched from the operations support center, and no efforts were initiated to replenish the supp%s. The inspectors determined that had the exercise progressed, the supply of air '
bottles within the operations support center would have been consume * Teams dispatched into the plant would monitor the supply of air in the bottles. When the bottle volume was used, the team would simulate using bottles from various locations within the plant. Use of these spare bottles was not tracked to ensure that people would not be directed to go to a location where there were no remaining air bottles. Personnel were not briefed on the location of spare bottles of air; therefore, it was up to the individual to find the location of spare bottle * Face pieces for self-contained breathing apparatus were being used as teams were dispatched from the operations support center. Late in the exercise, supplies of face pieces were depleted in the operations support center.-
At one poiu, inspectors observed that f ace pieces were being reissued to teams. The team members were told that the face pieces had been frisked and were considered to be non-contaminated, if an individual had been
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issued a face piece earlier in the day, as part of ar'other team, the individual was told that this was the same face piece that they had been issued earlier in the day. A tracking mechanism was not used to ensure that people were issued the same face piece. Reissue of face pieces in this f ashion was inappropriat One of the last teams dispatched prior to exercise termination was asked to obtain some extra face pieces and bring them to the operations support
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center after they had completed their assigned task. There was no guidance provided regarding an adequate number or mix of sizes. Furthermore, there
. was no assurance that the team would not be delayed in returning to the center.
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! - The inspectors determined that the licensee did not demonstrate adequate control
! over the use of respiratory protection equipment by monitoring the quantities of face 2 pieces and use of air bottles, and subsequently replenishing these supplius as
- needed. As such. the capability to dispatch response teams frorn the operations
! support center with adequate respiratory protection could have been jeopardized,
- Furthermore, teams within the plant could have been at risk of depleting their air supplies without adequate information regarding the location of replacement air
- - bottles. This issue was identified as an exercise weakness (50-416/9715-01).
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Although, a site evacuation was not performed (identified as an activity that would l
[ be simulated), inspectors focused on protective measures taken for security i personnel. According to Procedure 10-S-01 11, Revision 10, " Evacuation of Onsite i Personnel," Section 6.1.1,b(1), during a site evacuation, the protected area except I for the control room, technical support center, operations support center, central
! alarm station, secondary alarm station, and the security island would be evacuated, j The security island was the primary access point for the plant. It was located l- adjacent to, but outside of the operations support center. The inspectors j determined that during the simulated evacuation, the security'istand would continue- to be occupied until it was determined _that udditional evacuation was necessar No additional protective measures were specified for personnellocated in this area.
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The inspe sors determined that there were no habitability surveys performed in the
! security island area during the exercise, therefore, adequate protection of personnel located in the security island was not considered.
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j Protective measures, such as the use of protective clothing and use of self-j contained breathing apparatus, were being required within the protected area for
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personnel outside of areas where habitability surveys were performed. Therefore, l orrstective measures for personnelin the security island were inconsistent with those-required for other areas of the protected area.
! According to the regulatory guidance provided in NUREG-0654/ FEMA-REP-1, Revision 1. " Criteria for Preparation and Evaluation of Radiological Emergency
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Response Plans and Preparedness in Support of Nuclear Power Plants,' Planning
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Standard J 6, each licensee shall, for individuals remaining or arriving onsite during
. the emergency, make provisions for individual respiratory orotection and use of -
j protective clothing. Incumbent with this is the need to sesure that people are i ' advised when it is necessary to use the equipment. The f ailure to perform j
- habitability surveys in the ' security island to determine the need for additional protective measures was identified as an exercise weakness (50-416/9715-02).
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-15- Conclusions Overall, the operations support center staff's performance was generally
- satisfactory. Two exercise weaknesses were identified
- one for failure to monitor and maintain supplies of self-contained breathing apparatus for long term center operation, and one for f ailure to establish protective rueasures for security personnel. Habitability surveys within the operations support center were performed often and correctly. Response team dispatch was delayed by fragmented and prolonged briefing P4.5 Emeraency Ooerations Facilitv Insoection Scooe (82301-03.04)
The inspectors observed the emergency operations f acility's staff as they performed tasks in response to the exercise. These tasks included facility activation, notification of state and local response agencies, development and issuance of protective action recommendations, dose assessment and coordination of field monitoring teams, and direct interactions with offsite agency response personne The inspectors reviewed applicable emergency plan sections, emergency plan procedures, logs, forms, and dose projections, Observations and Findings Partial staffing of the emergency operations f acility began promptly after the 9:17 a.m. alert declaration. Two offsite monitoring team members (a monitor and a driver) and security personnel arrived within about 20 minutes. The offsite monitoring team trembers inventoried field equipment and supplies and performed operability checks of the radiation survey instrumentation, communications equipment, and vehicle. Once completed, the team members waited for dispatch instructions from the operations support cente Responding security officers quickly set-up the access control point and readied the badge rack and log sheets in preparation for full f acility activation. The inspectors observed that a portion of the reference materials for f acility security personnel had not been maintained. The officers used a picture of an NRC badge to verify affiliation and authorize entry. Since the NRC badges had changed, the picture did not match when the comparison was niade. The officers discussed the difference with appropriate personnel and made a note for future reference. The security officers' actions were appropriat In accordance with emergency plan requirements, full f acility activation occurred promptly after the 10:22 a.m. site area emergency declaration, Upon arrival, f acility
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10-personnel readied the f acility for operation, obtained procedures and checklists, end established communication links. Activation was complicated by the simulated loss of offsite power (some computer terminals did not work), the timing of the general emergency declaration (declared by the technical support center at 10:54 a.m.), and the arrival of the NRC site team. The emergency operations facility was declared operationt1 at 11:05 The transfer of responsibilities from the technical support center to the emergency operations f acility was performed in a systematic and controlled manner. Offsite agency notifications were not transferred until the technical support center completed the general emergency notifications. The emergency operations facility assumed control and responsibility for do6e assessment; however, due to the loss of the computer terminal, actual dose projections were performed in the technical support center. Input and assumptions were communicated via telephon Information flow and control were generally effective. The offsite emergency coordinator conducted periodic briefings to ensure that personnel were aware of plant and radiological conditions and f acility priorities. However, inspectors
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observed one instance where important information was not known in the dose assessment area. The radiological assessment coordinatar and dose calculation specialist were unaware of the general emergency declaration for 27 minutes (10:54 a.m. to 11:21 a.m.). The radiological status board had not Lt.sn updated, and the two apparently did not hear the information 6 sting the 11:06 a.m. briefing. The lack of this inforination in the dose assessment area could have affected protective action recommendation Fc;towup notifications to offsite agencies were generally timely aid cortect. During the wind shif t, protective action recommendations for three affected sectors (HJK)
were not communicated to offsite authorities as required by tho emergency plan and implementing procedures. Sector G was added via message Form 6 at 12:03 At 12:17 p.m., while on the way to a r..eeting to discuss protective action recommendations, the radiation emergency manager was informed that Sectors JKL were affected (Sector H was not mentioned). No protective action recommendation was prepared at that tim By the time the rneeting ended (about 16 minutes later), the sffected sectors had changed to LMN, Protective actions for these three sectors were included on Message Form 7. Sectors JKL were initially noted on the form but were marked out and replaced with LMN Protective action recommendations for Sectors HJK were never transmitted to offsite authorities. Due to the potentialimpact on public health and safety, the f ailure to make proper protective action recommendations was identified as an exercise weakness (50 416/9715 03).
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Dose assessment and field team control activities were generally good. The emergency operations facility dose assessment personnelinstructed the technical ;
support center staff to perform numerous dose projections, primarily based on field i team measurements. The use of field team measurements was necessitated by ,
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scenario events (unmonitored release). Field teams were effectively used to define plume centerline and edge ;
However, a 2-hour def ault release duration time was inappropriately used in some dose calculations. Dose assessment personnel continued to use a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> default release duration time even though the release exceeded 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Message Forms 8 and 9 stated that the release duration time was 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, but the release had been ongoing for more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> a1d 17 minutes and 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, respective!y).
This issue was not identified as an exercise weakness because protective action recornmendations were not affecte According to 10 CFR Part 50.47(b)(9), the onsite and offsite emergency response plans must meet the following standards, including ' adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use." Guidance contained in Environmental Protection Agency EPA-400 R 92 001, " Manual of Protective Action Guides and Protective Actions for Nuclear Incidents", Section 2.4, ' Dose Projections" states in part:
Emergency response plans for facilities should make use of Emergency Action Levels based on in plant conditions, to trigger notification of and recommendations to offsite officials to implement prompt evacuation or sheltering in specified areas in the absence of information on actual releases or environmental measurements. Later, when these data become available, dose projections based on measurements may be used, in addition to plant conditions as the basis for implementing further protective action ...
In practical applications, dose projection will usually begin at the time of the anticipated (or actual) initiation of a releas For those situations where significant dose has already occurred prict to implementing protective action, the projected dose for comparison to a PAG should not include this dos The licensee assumed that any exposure prior to the time of the dose calculation was " prior exposure," therefore, unavoidable. As such, it should not be included when making recommendations to protective action guidelines. The licensee stated that their protective actions recommendations would be based upon " avoided dose j
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- 18-only." The projected duration of the release would be from the time of the calculation, not the entire duration of the release. The licenseo stated that if information was available to indicate that a release was projected to last longer than the 'def ault" release duration, then the projected duration would be used, otherwise the default duration of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> would be use The inspectors pointed out that repetitivo dose projection calculations with the same input would yield the same results, and that there was a potential for no conservative protective action recommendations. Typically, dose assessment methodologies assume an integrated dose from a ' plume migration time" plus the time the release has been in progress. In other words, the exposure started when the leading edge plume passes a point and ended when the trailing end passed a point. As such, the projected doses f arther away from the source would have less exposure time, yielding a lower dose estimate. Assuming the release starts at the time of the calculation implied that the leading edge of the plume was released at that time. This m,arit that any dose from the pre existing plume within the emergency planning zone was ignored, thereby yielding non conservative dose projection The inspectors confirmed that no outstanding regulatory issues were identified during this exercise related to this issue. However, the licensee's dose assessment methodology will be reviewed in a future emergency preparedness inspection to determine if the potential for non conservative protective action recommendations exists. This matter was identified as an inspection followup item (50 416/9715 04).
Habitability in the emergency operations facility was properly performed. At 12:42 a.m., the radiation emergency manager gave the order to place the f acility ventilation system in the isolation mode. A radiological control point, with a
"frisket" had already been placed at the f acility entranc Interactions with of f site response teams were good. Upon arrival, the state and NRC retponse teams were briefed on emergency status. Joint discussions concerning protective action recommendations (between the states, NRC, and utility) were especially meaningful.
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c, Conclusions Overall, the emergency operations f acility st.1ff's performance was generally satisfactory. Offsite agency notifications were timely and generally correct. An exercise weakness was identified for f ailure to make proper protective action recommendations during the wind shif t. Protective actions were not recommended for three affected sectors. Briefings, communications, and information flow generally supported the general emergency declaration. Dose assessment activities were generally good. Release duration times used in dose projections were not i
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19-always accurate. Facility habitability, field team control, and interactions with offsite response teams were effectively demonstrate P4.0 Stenario and Exercise Control Insoection Srpoe (82301 and 82M21 The inspectors evaluated the exercise to assess the challenge and realism of the scenario and exercise control, Observallons and Findinas The licensee submitted the exercise objectives and scenario for review on June 17 and July 15,1997, respectively. The exercise objectives were considered appropriate to demonstrate emergency response capabilities and commitment During the exercise scenario review, the NRC identified a limitation concerning the licensee's emergency action levels, in response, the licensee revised its emergency action levels to better define reactor pressure vesselloss criteria to eliminate the need to rely on offsite doses to drive the genera' emergency declaration. The licensee's response was appropriat The inspectors determined that the exercise scenario was sufficiently challenging to test onsite emergency response capabilities. The following aspects of exercise conduct and control detracted from the realism and training value of the exercise
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and were considered areas for improvement:
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- The simulator did not accurately model core flow redistribution when the high pressure core spray jockey pump was used to restore level. Reactor level increased from 320 inches to 200 inches on the fuel zone level indicator in a 5-minute period. Since the high pressure core spray jockey pump capacity is only 40 to 50 gallons por minute, the rapid levelincrease was not credibl The simulator operator promptly corrected the condition, and exercise play was not significantly affected. Deficiency Report 97-0278 was initiated to investigate the modeling proble * One instance of prestaging was identified during review of operations support center exercise records. One exercise participant signed in on the emergency radiation work permit at 6:52 a.m. (prior to exercise start). Conclusions A limitation in the emergency action levels was identified during the scenario revie Appropriate corrective actions were taken prior to the exercise. The scenario was sufficiently challenging to test onsite response capabilities. Exercise control was good. Appropriate action was taken to resolve a simulator modeling problem.
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20-P4.7 Licensee Self Critioue Insocction Scone 182301-03.13)
The inspectors observed and evaluated the licensee's post exercise f acility critiques and the formal management critique on September 18,1997, to determine whether the process would identify and characterize weak or deficient areas in need of corrective actio Qhsgrvations and Findinns Post exercise critiques in all f acilities were thorough, open, and self critical. The following minor exceptions, which detracted from the overall quality of the individual f acility critiques, were observed:
- In the control room, the critNa included input from evaluators and participants (not controllers). Cc,mments made by evaluators and participants were predominantly positive. As a result, the critique appeared incomplete and lacked input which could lead to improved performanc * In the operations support conter, some participants did not directly participate in the critique. Operations suppo t center teams performed a separate mini-critique, independent of the main critique, and only the team leaders were asked to attend the f acility critique. As a result, team members were unaware of overall f acility performance and critique comments from other team * In the emergency operations f acility, the lack of state (and NRC) participation detracted from the overall completenes During the September 19,1997, management critique, the Manager, Emergency Planning, presented the results of the licensee's evaluation. The results included comments from cont'ollers, evaluators, participants, and the emergency planning peer group review. The peer group consisted of three emergency planning managers from other Entergy sites and an individual from the Entergy Corporate Offic The licensee's evaluation team identified two potential exercise weaknesses (both of which were identified by the NRC inspection team), strengths, and numerous improvement items. Common threads between the improvement items were hightghted. The peer group identified several key issues, including one of the exercise weaknesses. The inspectors identified the licensee's critique process,
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including tha participation of the peer group, as a strength. The process was very thorough and self critical Management support and input was evident. During the management critique, participating management commented on the low thresheld used for identifying strengths. The NRC inspection team echoed this comment during the exit meetin Conclusions Post exercise critiques were thorough, open, and self critical. The management critique was comprehensive and self critical but used a low threshold for identifying strengths. The peer group identified several very good issues. Management support and input was evident. Overall, the critique process was identified as a strength.
l S8 Miscellaneous Security and Safeguards issues During the inspection the inspectors observed an incident involving two individuals entering the security door to the control building. One individual was able to use their security key card and open the door. The other individual had difficulty getting ino card reader to read the security key card. The first individual held the door open while waiting on the second person. Af ter several attempts, the second person stated that they would use the card reader inside the door to log into the are When the questioned by the inspectors, the individual used the card reader once more, and successfully accessed the are Because this was considered to be a "+ailgating" event that was prevented by intervention of the inspectors, the inspectors reported the event to the license The liconaee logged the event and initiated an investigation and corrective action The individual was authorized to access the , however the technique proposed was inconsistent with the licensee's proced' ,,s. Because the individual did not actually enter the area while not being officially granted access, tailgating did not occur. However, this identified potentialissues involving training of workers on the proper means of accessing areas and what to do if problems arise accessing an are These issues and the licensee's corrective actions taken for this incident will be reviewed in a future physical security inspection and is being identified as an inspection followup item (50 416/9715-05).
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-22-VJdanagemenLMccilngs X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on September 19,1997. The licensee acknowledged the facts presented. No proprietary information was identifie During the exit rnecting, the inspectors discussed the issue associated with the licensee's dose assessment methodology. Subsequent to the inspection, NRC management decided to characterize this issue as an inspection followup item. On October 7,1997, C. Morgan, Manager, Emergency Preparedness, was informed of this decision by telephon The Federal Emergency Management Agency scheduled public meetings in Mississippi and in Louisiana on September 18,1997, to discuss the exercise result Since there was no media or public attendance at either meeting, the meetings were adjourned without Federal Emergency Management Agency and NRC presentation I
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AUACHMEtLI SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licsnice L. Calvery, Emergency Planning L. Dale, Director, Plant Projects & Support W. Eaton, General Manager D. Ellis, Emergency Planning R. Errington, Technical Manager D. Fearn, Ouality Programs M. Guynn, Radiation Control Supervisor C. Holifield, Licensing D. Janeobe, Director, Training S. Joiner, Consultant C. Lambert, Nuclear Plant Engineering M. Larson, Licensing M. McDowell, Operations W. Middleton, Security C Morgan, Manager, Emergency Preparedness J. Owens, Licensing B. Raines, Emergency Planning J. Roberts, Manager, Management Processes D. Townsend, Emergency Planning J. Venable, Manager, Operations NaC K. Weaver, Resident inspector INSPECTION PROCEDURES USED IP 82301 Evaluation of Exercises at Power Reactors IP 82302 Review of Exercise Objectives and Scenarios for Power Reactors i
ITEMS OPENED AND CLOSED l
Ooened 50-416/9715-01 IFl Exercise Weakness - Failure to monitor and replenish supplies of respiratory protection equipment (Section P4.4)
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t 2-50-410/9715 02 IFl Exercise Weakness Failure to provide protective measures for personnel locate <1 in the security island (Section P4.4)
50 410/9715 03 IFl Exercise Weakness - Failure to properly formulate protective action recommendations (Section P4.5)
50 410/9715-04 IFl Dose assessment methodology release duration (Section P4.5)
50 416/9715 05 IFl Averted Taiigating Incident (Section S8)
List of Documents Reviewed Offnormal Event Procedures:
05102 IV 1, " Control Rod / Drive Malfunctions," Revision 103 06102-lll 3, " Decrease in Recirculation System Flow Rate," Revision 100 05102112, "Offgas Activity High," Revision 19 0510214, " Loss of AC Power," Revision 23 0510211, " Reactor Scram," Revision 103 Principles of Operation Guidelines:
L-001, " Procedural Placekeeping" A-006, "Self Verification / Peer Checks" A 002, " Procedural Use and Maintenance" A 009, " Operations Briefings" A 008, " Control Room Professionalism and Formality" A 004, "Onshif t Communications" Emergency Plan implementing Procedures:
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v 3-10 S 01 1, " Emergency Plan Procedure Activation of the Emergency Plan,"
Revision 102
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10 S 016, " Notification of of fsite Agencies and Plant On Call Emergency Personnel,"
Revision 20 10 S-01 14, * Emergency Radiological Monitoring," Revision 18 10 S 01 17, " Emergency Personnel Exposure Control," Revision 12 10 S-01 11. " Evacuation of Onsite Personnel," Revision 10 10 S 01 12. " Radiological Assessment and Protective Action Recommendations,"
Revision 21 10 S 0128, " Control of Designated Emergency Vehicles," Revision 0 10 S 0129, " Operations Support Center," Revision 9 10 S 0130, " Technical Support Center Operations," Revision 5 10 S 0133, " emergency Operations Facility Operation," Revision 6 Administrative Procedure:
01 S 10-05, " Control of Emergency Response Equipment and Facilities," Revision 3
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