IR 05000416/1999007

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Insp Rept 50-416/99-07 on 990622-25.Violations Noted.Major Areas Inspected:Announced Insp of Licensee Performance & Capabilities During full-scale,biennial Exercise of Emergency Plan & Implementing Procedures Performed
ML20210E333
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 07/23/1999
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20210E331 List:
References
50-416-99-07, NUDOCS 9907280198
Download: ML20210E333 (17)


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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-416 License No.: NPF-29 Report No.: 50-416/99-07 Licensee: Entergy Operations, In Facility: Grand Gulf Nuclear Station  !

Location: Waterloo Road Port Gibson, Mississippi Dates: June 22 - 25,1999 Inspector (s): Harry A. Freeman, Senior Emergency Preparedness Analyst, I Team Leader Jennifer L. Dixon-Herrity, Senior Resident inspector Paul J. Elkmann, Emergency Preparedness Analyst Wayne L. Britz, Health Physicist Approved By: Gail M. Good, Chief, Plant Support Branch Division of Reactor Safety Attachment: Supplemental Information i

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990728019e 990723 PDR 0 ADOCK 05000416 PM

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l t-2-EXECUTIVE SUMMARY Grand Gulf Nuclear Station NRC Inspection Report No. 50-416/99-07 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 Support

Overall, performance was good. The control room, technical support center, operations support center, and emergency operations facility successfully implemented key emergency plan functions including emergency classifications, protective action recommendations, and dose assessment. A strength was identified in the technical support center concerning implementation of mitigation strategies for plant equipment failures (Sections P4.2, P4.3, P4.4, and P4.5).

Performance in the control room was good. Offsite agency notifications were timel Analysis of plant conditions was good and personnel demonstrated a questioning attitude throughout the exercise. The control room staff demonstrated good coordination and communication with the technical support center, operations support center, and emergency operations facility (Section P4.2).

Some of the emergency notification forms prepared in the control room had confusing or conflicting information. For example, the initial form stated that an alert had been declared based on exceeding Technical Specification allowable levels during a routine discharge but also 1,1dicated that there had been no release. In the exercise, a discharge had occurred but had been secured prior to the notification (Section P4.2).

Performance in the technical support center was good. The facility consistently exhibited strong facility leadership. Noteworthy performance was observed in the development of accident mitigation strategies and prioritization of operations support center work. The technical support center remained focused after the offsite release had been isolated and showed initiative in addressing recovery planning issues (Section P4.3).

An exercise weakness was identified for failure to determine site accountability within 30 minutes (58 minutes from the site area emergency declaration) as required by procedure. Conflicting priorities (accountability versus addressing the accident)

prevented the technical support center personnel from completing the accountabilit Since this issue was also identified by the licensee during the self-critique and entered into the corrective action program as Condition Report 99-0652, no response is required (Section P4.3).

Performance in the operations support center was good. The operations support center was activated in a timely manner. Communication practices observed were good and l

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-3-l contributed to mitigation efforts. The crew was kept informed through frequent briefing Technical information and task priorities were promptly and clearly communicated.

. Repair teams and monitoring teams were organized and dispatched promptly in l accordance with the identified priorities. The health physics organization maintained radiological controls throughout the event (Section P4.4).

e Performance in the emergency operations facility was good. The offsite emergency coordinator demonstrated effective command and control. Coordination by the licensee and the two states dose assessment groups was good (Section P4.5).

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The scenario was sufficiently challenging to test all licensee emergency response facilities and to meet exercise objectives. However, the originally submitted exercise scenario package was incomplete in that radiological and operations information was missing. Overall, licensee exercise controls were evaluated to be good with some examples noted of inadequate attention to d etail in scenario planning (Section P4.6).

  • The licensee's post-exercise critiques were generally thorough, open, and self critical l with input from participants, controllers, and evaluators. The licensee's continued use of

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peer evaluators from other facilities provided additional perspective to the critique process (Section P4.7).

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-4-IV. Plant Support P4 Staff Knowledge and Performance in Emergency Preparedness P4.1 Exercise Conduct and Scenario Description (82301 and 82302)

The licensee conducted a full scale, biennial emergency preparedness exercise on Jbne 23,1999. The exercise was conducted to test major portions of the onsite (l.censee) and offsite emergency response plans. The licensee activated its emergency response organization and all emergency response facilities. The Federal Emergency Management Agency evaluated the offsite response capabilities of the states of Louisiana and Mississippi and Tensas Parish (Louisiana) and Claiborne County (Mississippi). The Federal Emergency Management Agency will issue separate report The exercise scenario was conducted using the Unit 1 plant control room simulato The exercise began at 7:30 a.m. Initially, the unit was steady at 100 percent powe The plant had indications of a minor fuelleak. A planned liquid waste discharge was in progress. A steam leak haJ developed on a main steam line basket strainer welded flange. The Division 11 diesel generator, the Stand-by Liquid Control Pump B, and the breaker for Main Steam Line Isolation Valve B21-F098B were unavailable. The following events were simulated:

  • At 7:40 a.m. a high-high radiation alarm was received on the liquid waste discharge line. The line could not be isolated from the control room; therefore, the line was manually isolated. At 8:15 a.m., chemistry determined that the discharge exceeded ten times the Technical Requirements Manual limiting condition for operation limit (10 times the applicable 10 CFR Part 20, Appendix B, limit). An alert emergency classification was declared by the control room at 8:18 a.m., and the emergency response organization was notifie Onsite emergency response facilities were activate * At 9:05 a.m. an inverter breaker failed which caused the loss of the control rod drive control syste * At 9:40 a.m. a trip of the main generator initiated an automatic reactor trip signa However, the reactor failed to trip and resulted in an anticipated transient without scram condition. Because the scram discharge volume became hydraulically locked, removing the reactor protection system fuses did not cause control rods to be driven in. A site area emergency was declared by the technical support center at 9:43 * Following the site area emergency classification, offsite emergency response facilities were activated, site accountability was determined, and nonessential workers were evacuated from the plant. The emergency operations facility took over emergency manager duties at 10:31 .

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At 11 a.m. operators attempted to inject boron into the reactor through the Division I stand-by liquid control system; this attempt failed due to the failure of the storage tank outlet valves to ope *

At 11:11 a.m., radiation monitors in several parts of the plant began to quickly ramp up and a steam leak was reported on the turbine deck. When main steam lines were isolated by the control room, Main Steam Line B did not isolate. A release was determined to be in progress. A general emergency was declared by the emergency operations facility at 11:23 a.m. based on the failure of two fission product barriers and the potentialloss of the third barrier. Protective action recommendations were issued to offsite authorities to evacuate radially i 2 miles and evacuate downwind sectors to 5 mile I

At 12:15 p.m., control rod drive capability was restored. All control rods were inserted at 12:24 * Main Steam Line B was isolated at 1:03 p.m. which terminated the release from the reactor. A build up of unexhausted steam in the turbine building provided a source for the continuing airborne radioactive materia * The exercise was terminated at 2:01 p.m. Post-exercise critiques were conducted in each facility following exercise terminatio P4.2 Control Room Insoection Scope (82301-03.02)

The inspectors evaluated the control room staff as they performed tasks in response to the exercise scenario conditions. These tasks included event detection and classification, analysis and mitigation of plant conditions, offsite agency notifications, adherence to emergency plan implement'ng procedures and emergency operating procedures, command and control, and communications. The inspectors reviewed applicable emergency plan sections and implementing procedures, operator logs, checklists, and notification form Observations and Findinas During the exercise, plant conditions were analyzed and evaluated in a timely manne Operators quickly responded to changing plant conditions. The alert was promptly J classified using the correct emergency action levels. The inspectors determined that identification and classification of emergency conditions was goo The inspectors observed that control room communications were generally effectiv Control room personnel used "three-part" communications consistently throughout the exercise. Three-part communications involved: (1) information communicated by provider, (2) information restated by the receiver, and (3) information confirmed by the provider. In addition to the communications between the operators and shift management, good verbal communications were noted between the control room and the other onsite organization _-

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The control room staff conducted frequent, short briefings to ensure that operators were aware of changing plant conditions. The inspectors noted that the operators would augment the shift superintendents briefing where appropriate. For example, during a briefing following the loss of a component cooling water pump, an operator read the immediate actions for a loss of a second pump to the other operator Follow;ng the aled declaration at 8:18 a.m., offsite notifications were made in a timely manner, and the technical support center and operations support center were manned in the required tim l The inspectors noted that information regarding the cause of the alert was not pavided to plant personnel as specified in Procedure 10-S-01-6. This procedure states that plant personnel are notified via the public address system concerning the nature and location of an event. While this lack of information did not affect any of the actions taken by the response organizations, since the discharge of effluents had already been secured, in a different situation it could have delayed the response organization's corrective action Until formal communications were established, the technical support center and the operations support center responders speculated on the cause of the aler Notifications to the state and local agencies were made within 7 minutes following the alert declaration. However, the release information section of the notification form stated that there was no release, while the incident description section indicated that the I alert was declared based on a discharge exceeding allowable values. The release had actually been secured prior to the alert declaration and the emergency director had incorrectly completed the release information section of the form. The director had concluded that an airborne release had not occurred and checked the "no release" block. This incorrect information caused some minor confusion but did not affect actions taken by the offsite facilitie Conclusions l

Performance in the control room was good. Offsite agency notifications were timel Analysis of plant conditions was good and personnel demonstrated a questioning l

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attitude throughout the exercise. The controi room staff demonstrated good coordination and communication with the technical support center, operations support center, and emergency operations facilit Some of the emergency notification forms prepared in the control room had confusing or conflicting information. For example, the initial form stated that an alert had been declared based on exceeding Technical Specification allowable levels during a routine discharge but also indicated that there had been no release. In the exercise, a discharge had occurred but had been secured prior to the notificatio P4.3 Technical Support Center 1 Insoection Scope (82301-03.03) l l

l The inspectors observed and evaluated the technical support center staff as they responded to the exercise scenario. This response included staffing and activation, j

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7-facility management and control, accident assessment, classification, dose assessment, protective action decision making, notifications and communications, and dispatch and coordination of in-plant mitigation teams. The inspectors reviewed applicable sections of the emergency plan, procedures, checklists, and log b. Observations and Findinas The technical support center was promptly staffed following the alert classificatio Personnel began arriving within 5 minutes of notification via the public address syste Minimum staffing was achieved with the arrival of the emergency director 23 minutes j after initial notificatio Upon facility activation, the emergency director assumed responsibility for classifying emergency events. The facility immediately verified the basis for the alert declaration and verified that conditions did not require entry into additional emergency action level The technical support center correctly classified the site area emergency and independently verified that the correct general emergency classification was made by the emergency operations facility (following transfer of this responsibility). After the site area emergency classification, the radiation protection manager closely monitored entry points into the radiological emergency action levels that would result in a general emergency classificatio Offsite notifications made from the technical support center were timely and in accordance with procedural requirements. Inspectors observed that facility staff had difficulty interpreting how to complete utility message No. 2 to correctly characterize the previous high activity in the radwaste discharge. As a result, message No. 2 was transmitted with some information blocks not completed. inspectors determined that the lack of procedural guidance for the completion of the utility message form for liquid i releases contributed to the difficulty. Participants recognized and discussed whether liquid releases required additional offsite notifications beyond those for the emergency plan (e.g., hazardous materials, state or Federal Environmental Protection Agency).

The technical support center provided backup dose assessment capabilities and peer checking after the emergency operations facility activated. The inspectors observed the dose assessment staff as they analyzed whether the emergency action level for general l emergency was met because of the radiological releele. The dose assessment staff was competent and knowledgeable in performing these functions. The radiation {

j protection manager properly peer checked the emergency operations facility's proposed protective action recommendations for the general emergency. Protective actions were periodically reviewed in the facility during the remainder of the exercise to determine i whether changes were require The technical manager and the technical coordinator worked effectively together to manage the accident mitigation process. Emerging conditions were continually evaluated, resulting in quick recognition of the need for new repair teams. Facility communicators provided useful assistance and suggestions. The engineering staff was very active in using plant instrumentation to evaluate plant conditions (e.g., valve indications on the scram discharge header). The engineering staff was very inventive in proposing solutions to restore control rod drive movement following the anticipated

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-8-transient without scram. The effectiveness of the technical staff was impacted by erroneous information that out-of-service equipment could be restored by clearing out-of-service tag The technical support center showed good awareness of the status of operations support center teams. Initial confusion over the status of workers dispatched prior to facility activation was quickly cleared. The technical support center drove the need to clarify the status of instrument control technicians dispatched to the control room. Work was frequently assessed and prioritized by the key facility managers. The operations support center tracking board was well maintained and accurately reflected changes in work priority. Work priorities were accurately transmitted to the operations support center by the dedicated communicator. Emergency worker health and safety issues were consistently considered in assigning in-plant work and routing worker The emergency director maintained good facility focus following reactor shut down and isolation of the leaking main steam line. This was done through facility briefings, reprioritizing existing work, procedure checking, and peer review. The emergency director led the facility in an extensive brainstorming session considering the recovery and reentry procedures. Each key director was asked to identify functional area medium and long-term activities. Issues were listed on a status board and prioritize The emergency director discussed issues identified in the facility with the emergency operations facilit Facility briefings were timely and numerous and were effectively supplemented by short announcements. Advance warnings and a bell were used to focus attention on the briefings. Briefings were consistent in format with an introduction and overview by the emergency coordinator, supplemented by each key facility director, and closed by the emergency director. Important information was repeated and emphasized at each briefing (e.g., the current emergency classification and the need to check procedures for missed action steps).

Facility priorities were discussed during most briefings. During the initial facility briefing, the emergency director discussed and emphasized expectations regarding facility operations. Immediately following the assumption and turnover of emergency manager duties, the emergency director and coordinator briefed the facility on the nondelegable duties being assumed and transferred. Briefings were generally audible throughout the facility, and background noise was minima i Facility briefings were also supplemented by plant page announcements made from the i control room, technical support center, and emergency operations facility. In contrast to the facility briefings, these announcements generally could to be heard in the technical support center due to background noise and low speaker t Site evacuation sirens were activated from the technical support center at 9:58 a.m.,

15 minutes after the declaration of a site area emergency. Station accountability was completed at 10:41 a.m. The inspectors identified that the total time to complete accountability was 43 minutes from the sounding of evacuation sirens and 58 minutes from the emergency declaratiori Procedure 10-S-01-11, Revision 12, " Evacuation of

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Onsite Personnel," stated that the accountability process is to be completed in

"approximately thirty minutes from the declaration of the emergency."

The technical manager and staff were responsible for completing accountability. The limited engineering staff in the technical support center had difficulty handling the conflicting priorities to complete accountability and to combat the loss of control rod drive control (conditions) at the same time. Untimely site accountability was also identified by the licensee during the self-critique and entered into the corrective action program as Condition Report 99-0652. The failure to complete site accountability within 30 minutes was identified as an exercise weakness (50-416/9907-01).

Inspectors observed that personnellogs in the facility were generally good. However, checklists were generally completed using grease pencils on laminated sheets, dose assessment information was posted on status boards without paper documentation, and data from the operations support center priorities status board and engineering status board were not recorded. Forms for initiating and recording messages were available but not used. The inspectors determined that the degree of documentation within the facility could have hampered a thorough post-event analysi Conclusions Performance in the technical support center was good. The facility consistently exhibited strong facility leadership. Noteworthy performance was observed in the development of accident mitigation strategies, ar,d prioritization of operations support center work. The technical support center remained focused after the offsite release had been isolated and showed initiative in addressing recovery planning issue Documentation of facility activities could have hampered event reconstruction. The failure to complete site accountability within 30 minutes was identified as an exercise weaknes P4.4 Operations Sucoort Center Inspection Scope (82301-03.05)

The inspectors observed and evaluated the operations support system 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 requectc. The inspectors reviewed applicable emergency plan sections, procedures, logs, checklists, and forms generated during the exercis Observations and Findinas The operations support center was staffed in a timely manner. Following the 8:18 alert declaration, the control room made an 8:32 a.m. announcement to staff the emergency response facilities. The operations support center was declared activated at 9:07 a.m. when minimum required staffing levels were met and the required communication links were mad ..

-10-Overall, command and controlin the operations support center was good. Noise levels and distractions were kept to a minimum throughout the exercise. Habitability was

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regularly checked by conducting surveys. Tasks were properly prioritized and modified according to changing simulated plant conditions. Personnel used good communications skills (three-part communication). The communications network between the facilities functioned well. The operations support center communicator maintained a continuous communications link with the technical support center and control room. Through this link, communicators passed current plant status, requests for teams, status of work, etc. A second individual in the facility listened in and updated a plant status board. In addition, the operations support center coordinator had a wireless telephone to allow easy communication with the emergency director. The priorities were assigned to tasks promptly, and personnel accurately applied the ,

priorities, changing work plans as necessar The operations support center coordinator provided regular, detailed briefs to personne The inspectors observed one concern. Due to facility layout, the briefs were given in the three main spaces, one after the other. The operations support center included a large portion of the maintenance building, the main spaces including a main control center, a briefing room, and a large break room. As a result, not all of the details were included in the different briefs. There was a potential to leave out information or to miss an opportunity to address all personnel. One example of this concern was that the main

< control center for the operations support center was briefed on the declaration of a general emergency at 11:20 a.m. At this time, the coordinator announced no eating or drinking. When the coordinator went to the break room at 11:28 a.m. to brief repair personnel, they were all eating lunch. This delay in communication, could have led to internal contamination of personnel during an actual releas The briefings were detailed and covered all the topics required in Procedure 10-S-01-29, Revision 12. " Operations Support Center Operations." However, the inspectors observed two suggestions in the procedure that were not being practiced. The procedure suggests that the operations support center coordinator periodically brief the technical support center on the availability and status of emergency response teams, including the number of available qualified personnel and the remaining radiation exposure margins. This information was not included in the briefings. It was not I necessarily important in the scenario for this exercise but could become important depending on the scenario and the people availabl Toward the end of the exercise, the operations support center had to go outside of normal practice and procedure and dispatch an operator from the control room rather than from the operations support center, because no operators were availabl Personnel were not aware of this problem, and it may have eliminated some confusion and distraction if personnel availability was briefed periodically as suggested in the l procedure. The procedure stated that the health physics coordinator and the operations j support center coordinator should periodically brief the dispatched emergency response teams on current radiological conditions and plant status. The inspectors observed that briefs of this nature were not provided. As a result, teams were confused as to why they i were left waiting in the field. For example, Team 6, a team put together to work on the l standby liquid control system, ran out of air waiting at the entrance to containment and were not given an explanation for the delay over the radi ,.

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Inplant response teams were sufficiently briefed for each assigned task. A total of 11 teams was formed in the operations support center and 9 teams were sent out. Three teams were identified as having gone out before the alert was declared to allow for tracking personnel. The briefings were thorough and included a technical brief, a personnel safety brief, and a health physics brief. All teams were promptly sent out into I the field within approximately 30 minutes of receiving the request. The team communicator generally maintained good radio contact with the teams and relayed team reports to the operations support center coordinator for dissemination to personnel in i the technical support center. The team status tracking board was well maintained. It included all personnel available, the personnel assigned to teams, the tasks assigned, the status, et Conclusions Performance in the operations support center was good. The operations support center was activated in a timely manner. Communication practices observed were good and contributed to mitigation efforts. The crew was kept informed through frequent briefing l Technical information and task priorities were promptly and clearly comniunicate )

Repair teams and monitoring teams were organized and dispatched promptly in accordance with the identified priorities. The health physics organization maintained radiological controls throughout the event. The inspectors identified a number of areas where briefing could be improved but determined that the overall response of personnel was not affecte P4.5 Emeraency Operations Facility 1 Inspection Scoce (82301-03.04)

The inspectors observed the emergency operations facility staff as they performed tasks in response to the exercise. These tasks included facility activation, recognition and classification of emergency events, notification of state and local response agencies, development and issuance of protective action recommendations, dose projections, field team control, and direct interactions with offsite agency response personnel. The inspectors reviewed applicable emergency plan sections and procedures, forms, dose projections, logs, and press release Observations and Findinas The emergency operations facility was promptly staffed and activated following the 9:43 a.m. site area emergency declaration. Upon arrival, facility personnel readied the facility for operation. The f acility was declared activated at 10:31 Status briefings were held approximately every 70 minutes. These briefings were held in a separate room in the emergency operations f acir.ty with the coordinator, the lead managers of each section, and with the company spokesperson by telephone. Each lead manager briefed the group on functional area activities. However, unlike the other f acilities, objectives or priorities were not discussed during the briefings. To improve efficiency, the licensee had recently changed its practice from briefing the entire f acilit Now the lead managers had the responsibility to inform their respective work groups on

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-12-what was considered pertinent information. The inspectcrs concluded that while the change in the briefing process may improve the facility's efficiency, it held the potential for important information to not be disseminated to all personnel. To compensate, the coordinator conducted short briefings with the entire facility whenever significant changes occurre The ploe tracking specialist and the dose calculator were both located adjacent to the state sp cialists from Louisiana and Mississippi. Assessments and recommendations by the Ik9nsee were frequently shared with and compared to the assessments by the state specialist Conclusions Performance in the emergency operations facility was good. The offsite emergency coordinator demonstrated effective command and control. Coordination by the licensee

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and the two states' dose assessment groups appeared to be goo P4.6 Scenario and Exercise Control Inspection Scoce (82301)

The inspectors evaluated the licensee's exercise objectives and scenario to assess the ability of the exercise to meet exercise objectives. The inspectors also made observations during the exercise to assess the challenge and realism of the scenario and to evaluate exercise contro Observations and Findinas The licensee submitted the exercise objectives and scenario for review on March 29 and April 22,1999, respectively. The exercise objectives were evaluated as appropriate for the scope of the exercise. The exercise scenario did not contain complete radiological and operations information. During follow-up discussions, the licensee indicated that some scenario development in these areas would not be complete until approximately 2 weeks prior to the exercise and supplied verbal descriptions of the planned scenario contents. This lack of complete information hampered scenario evaluation. The inspectors determined that the scenario, augmented by the planned additional scenario information, was sufficient to test the onsite emergency response organizatio !

The inspectors determined that the exercise scenario was sufficiently challenging to test onsite emergency response capabilities. Overall, licensee exercise control was determined to be good with the following exceptions:

  • Based on past practice, and the guidance provided in Procedure 01-S-18-1,

" Work Planning and Coordination," Revision 2, the initial conditions identified were not realistic. Maintenance was required to be planned and scheduled such that, for example, multiple safety system / component outages were not scheduled concurrently and emergent conditions should have been considered prior to starting planned outages. In this case, the scenario had the Division ll emergency diesel generator and a safety-related breaker (which prevented a

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-13-main steam isolation valve from being isolated) out of service for planned maintenance and an emergent problem caused the standby liquid control Pump B to be out of servic *

The participants were given insufficient data to make decisions at the beginning of the exercise. No information was available on the status of equipment described in initial conditions as being out of service. For much of the exercise, participants believed that equipment could be returned to service by removing out-of-service tags. This confusion was caused by incomplete preparation of the initial condition work package * A participant in the operations support center was observed to copy initial condition information onto a status board from a source other than the exercise plan of the day or from information supplied through a communicato * Contrary to exercise ground rules, an operations support center evaluator was observed questioning a participan * Real-time computer data used by the particirants sometimes differed from data available in the simulator. This caused confusion among participants in diagnosing the hydraulic lock of the scram discharge volum *

Some area radiation monitors in the control room simulator do not reflect the ranges of the installed instruments; the monitors in the simulators indicated

" pegged high" at a lower value than do the actual monitor Conclusions The scenario was sufficiently challenging to test all licensee emergency response facilities and to meet exercise objectives. However, the originally submitted exercise scenario package was incomplete in that radiological and operations information was missing. Overall, licensee exercise controls were evaluated to be good with some examples noted of inadequate attention to detail in scenario planning and of potentially inappropriate interactions between licensee evaluators and participants. Minor exercise control problems were not observed to significantly impact exercise performanc P4.7 Licensee Self Critiaue Insoection Scoce (82301)

The inspectors observed and evaluated the licensee's post-exercise facility critiques, the exercise critique on June 24,1999, and the management debrief on June 25,1999, to determine whether the process would identify and characterize weak or deficient areas in need of corrective action Observations and Findinas Post-exercise critiques in all facilities were thorough, open, and self critical. With the exception of the emergency operations facility, post-exercise critiques appropriately i

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-14-included input from participants, controllers, and evaluators. Exercise participants in all facilities identified good suggestions for improvement. The licensee continued to use peer evaluations from other facilities to add depth to the critique process. The inspectors observed the following exceptions:

  • Two different critiques were held for personnel who worked in the operations support center. The craft personnel met first, then other personnel involved met separately. The operations support center coordinator lead both discussion The inspectors observed that holding the critiques separately prevented all members of the operations support center team from being aware of concerns identified, lessons learned, and benefitting from discussions that may improve the team's performanc * The post-exercise critique in the emergency operations facility did not include input from the controllers or evaluators. The licensee held a separate meeting to obtain their input. The inspectors found that the participants did not obtain immediate feedback on their performance in this facility. The licensee planned to provide feedback to the emergency operations facility participants at a later dat During the June 25,1999, management critique, the emergency planning manager presented a compilation of comments from participants, controllers, and evaluator The comments included nine issues characterized as significant improvement items including the failure to complete site accountability within 30 minutes (see Section P above). Conclusions The licensee's post-exercise critiques were generally thorough, open, and self critical with input from participants, controllers, and evaluators. The licensee's continued use of peer evaluators from other facilities provided additional perspective to the critique proces P8 Miscellaneous Emergency Preparedness issues (92904)

P8.1 (Closed) Insoection Followuo item 50-416/9715-01: Exercise Weakness - Failure to monitor and replenish supplies of respiratory protection equipment. During this exercise, the inspectors observed that a status board was maintained at the self-contained breathing apparatus issue point to monitor the supply and location of air bottles. One health physics technician was assigned to maintain the status and to brief teams on the location of replacement air bottles near where they would be workin Personnelin the operations support center tracked the amount of time personnel used 4 the air and had them replace bottles in the field when the air was due to run out. Early in the exercise, extra air bottles were brought in from the warehouse to ensure an adequate supply of air. Face pieces were not actually used but were set aside in a container to simulate that they were in use or had been used. Based on these observations, the inspectors concluded that the licensee had adequately addressed the concer i l

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-15-P (Closed) Inspection Followuo item 50-416/9715-02: Exercise Weakness - Failure to provide protective measures for personnel located in the security island. The inspectors observed that habitability surveys were performed regularly in the security islan Procedure 10-S-01-29 Step 6.3.2.a.(5) required that radiological monitoring be maintained for manned areas. The inspectors concluded that the performance of habitability surveys in the security island adequately addressed the concer P8.3 (Closed) Insosction Followuo item 50-416/9715-03: Exercise Weakness - Failure to properly formulate protective action recommendations. This exercise weakness was the result of a failure to make a protective action recommendation for all sectors affected during a rapid wind shift. While this exercise did not include similar conditions, the licensee had revised Procedure 10-S-01-12," Radiological Assessment and Protective Action Recommendations," Revision 25, to include a note on how to deal with rapidly changing wind conditions, including wind shifts. The inspectors concluded that this corrective action adequately addressed the concer P8.4 (Closed) Inspection Followuo Item 50-416/9715-04: Dose assessment methodology -

release duration. During the previous exercise, the licensee had been using a default duration of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to account for future or projected dose and did not account for integrated dose. By not accounting for the integrated dose, the licensee could have underestimated accrued dose. During this exercise, the inspectors observed the dose calculator revise the projected release duration to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> when the actual duration approached 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The inspectors reviewed Procedure 10-S-01-12 and noted that it contained a note that alerted the dose calculator to consider both integrated and projected dose. The inspectors concluded that this corrective action adequately addressed the concer V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on June 25,1999. The licensee acknowledged the facts presented and stated that demonstrating accountability was not an exercise objective and was not required to be demonstrated at this exercise. The inspectors acknowledged the licensee's comments. During a discussion with the licensee following the exit meeting, the inspector stated that while the licensee did not have an objective to demonstrate accountability (for the 6-year cycle) the activity was performed using a roster developed for the exercise. In addition, an exercise limitation (to indicate that the activity would not be demonstrated) was not pre-identified. No proprietary information was identifie FEMA, Region VI, conducted a public meeting in St. Joseph, Louisiana, on June 24,199 FEMA, Region IV, conducted a public meeting in Port Gibson, Mississippi, on June 25,199 During these meetings, FEMA and NRC representatives were available to present preliminary results of exercise performanc .

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ATTACHMENT SUPPLEMENTAL INFORMATION i

PARTIAL LIST OF PERSONS CONTACTED Licensee A. C. Morgan Manager, Emergency Preparedness M. Withrow Engineering Manager W. M. Shelly Manager, Training & Emergency Planning -

C. Stafford Operations Manager W. Deck Security Superintendent J. 83 edwards Manager, P&S L. Saesser PSE Manager R. Mooman Maintenance Manager A. D. Barfield Manager, Design Engineering J. Roberts Director Quality C. Lambert Director Engineers J. Lewis Manager, Emergency Preparedness, Waterford 3 W. R. Gresham Manager, Emergency Preparedness, Arkansas Nuclear One S. Crawford Supervisor, Emergency Preparedness, Callaway M. Bacherich Manager, Emergency Preparedness, River Bend LIST OF INSPECTION PROCEDURES USED IP 82301 Evaluation of Exercises at Power Reactors IP 82302 Review of Exercise Objectives and Scenarios for Power Reactors IP 92904 Followup - Plant Support LIST OF ITEMS OPENED AND CLOSED Ooened 50-416/9907-01 IFl Exercise Weakness - Failure to complete site accountability in a timely manner (Section P4.3)

Qlsed

50-416/9907-01 IFl Exercise Weakness - Failure to complete site accountability in a i timely manner (Section P4.3)

50-416/9715-01 IFl Exercise Weakness - Failure to monitor and replenish supplies of respiratory protection equipment (Section P8.1)

50-416/9715-02 IFl Exercise Weakness - Failure to provide protective measures for personnel located in the security island (Section P8.2)

.- /9715-03 IFl Exercise Weakness - Failure to properly formulate protective action recommendations (Section P8.3)

50-416/9715-04 IFl Dose assessment methodology - release duration (Section P8.4)

LIST OF DOCUMENTS REVIEWED Emeroency Plan Procedures Procedure 10-S-01-6, " Notification of Offsite Agencies and Plant On-Call Emergency Personnel," Revision 31 Procedure 10-S-01-11, " Evacuation of Onsite Personnel," Revision 12 Procedure 10-S-01-1, " Activation of the Emergency Plan," Revision 104 Procedure 10 S-01-17, " Emergency Personnel Exposure Control," Revision 13 Procedure 10-S-01-12 " Radiological Assessment and Protective Action Recommendations,"

Revision 25 Other Documents Grand Gulf Nuclear Station Emergency Plan, Revision 37 Procedure 01-S-18-1, " Work Planning and Coordination," Revision 2