IR 05000440/1992023

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Insp Rept 50-440/92-23 on 921208-11.Violations Noted.Major Areas Inspected:Annual Emergency Preparedness Exercise, Involving Review of Exercise Scenario,Observations by NRC of Key Functions & Locations During Exercise & Followup
ML20126H194
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 12/23/1992
From: Mccormickbarge, Steven Orth
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20126H178 List:
References
50-440-92-23, NUDOCS 9301050097
Download: ML20126H194 (24)


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U.S. NUCLEAR REGULATORY COMMISSION .

REGION 111 Report No. 50-440/92023(DRSS)

Docket No. 50-440 License No. NPF-58 Licensee: Cleveland Electric illuminating C Center Road Perry, OH 44081 Facility Name: Perry Nuclear Power Plant, Unit 1 Inspection At: Perry Site, Perry, Ohio inspection Conducted: Occember 8-11, 1992 ,

inspectors: _

< N /3 / # * /9 P CS(K. Orth Date Accompanying Personnel: A. Vogel R. Walton L. Cohen C. Zelig M. Bielby J. Hopkins E. Duncan

/// md .$aAF/ / 2/A3/9 t Approved By:fj0. W. McCormick-Barger, thief Dato'

V Emergency Preparedness and Non-Power Reactor Section Inspection Summary inspection on December 8-11. 1992 (Report No. 50-440/92023(DRSS))

Areas Inspected: Routine, announced inspection of the Perry Nuclear Power Plant's annual emergency preparedness exercise, involving: review of the exercise scenario (IP 82302), observations by eight NRC representatives of key functions and locations during the exercise (IP 82301), and followup of ' *

identified items (IP 82701).

Results: One violation was identified concerning the licensee's failure to properly implement procedures to test the operability of the technical support center (TSC) and emergency operations facility (f0F's) emergency ventilation system (Section 3).. The licensee had completed corrective actions to correct the problem and prevent recurrenc PDR ADOCK 05000440 G PDR

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The licensee demonstrated a very good overall response to a challenging scenario which included multiple medical casualties, multiple equipment failures, and a simulated release warranting a General Emergency declaratio The overall performance of the emergency response organization was very goo The interface between the EOF staff and the state and local government representatives was excellent. Communications and emergency management were very well demonstrate ;

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DETAlls IRC Observers and Areas Observed S. Orth, Operational Support Center (OSC), Hedical Drill, Emergency Operations facility (E0F)

A. Vegel, Control Room Simulator (CRS) <

M. Bielby, CRS R. Walton, Technical Support Center (TSC) '

C. Zelig, TSC J. Ho) kins, OSC and inplant teams L. Colen, EOF Persons Contacte * R. Stratman, Vice President

    • ' D. Igyarto, General Manager
  • R. Vondrasek, Manager, Emergency Planning
  • B. Beyer, Director, Perry Administrative Services Department
  • M. Gmyrek, Operations Manager
  • E. Riley, Director, Perry Nuclear Assurance Department

' M. Roseum, Supervisor, Emergency Planning

' F. VonAhn, Supervisor, Mechanical Engineering Unit

  • K. Donovan, Manager, Licensing Compliance Section
      • J. Anderson, Emergency Planning Coordinator

D. Traverso Emergency Planner

D. Perko, Emergency Planner

' A. Pusateri, Systems Engineering Section

D. Conran, Compliance Engineer

The above and other licensee representatives attended the exit interview on December 10, 199 '

The above and additional licensee representatives attended the meeting on December 11, 199 The inspectors also contacted other licensee personnel during the course -

of the inspectio . Licensee Actions on Previous inspection Findinas (IP 82701)

(Closed) Inspection Follow-un Item No. 440/92008-01: The licensee was-to resolve the issues concerning the access to the EOF, and maintenance of

. controlled drawings and operating procedures for E0F equipment. .

The licensee had completed a number of. actions to' ensure that the E0F was adequately accessible and maintained. The licensee-had changed ~the locks so that all areas of the facility could be accessed with a singl ke The licensee also established a controlled set of. drawings for the=

facility and designated the facility as a generating facility via PAP-0302, Revision 0. November 13,-1992 to ensure they were mattitaine . ..

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Additionally, the licensee trained security personnel on alarm responses to the E0F. This item is close (Closed) Unresolved Item f(o. 440/92008-021 The inspector identified that the periodic test instructions, Pil-M52-P0003 and PTI-M53-P0002, for the emergency heating ventilation and air cond_itioning (HVAC)

systems in the EOF and TSC, respectively, had not been implemented in accordance with indicated frequency of the procedure. The procedure stated the frequency to be 366 days; however, records indicated that a period of 18 and 16 months had elapsed prior to the latest tests of the E0F and TSC systems, respectively. Additionally, the EOF system had failed the test instruction on 10/2/91 and 3/29/90 without a l re-performance of the test instruction as required. The licensee was to '

provide additional information, not available at the time of the j inspection, including justification for_ delaying the testing, documentation for followup testing, and any followup corrective action The licensee's response and further discussions indicated that the periodic test instructions were not pro >erly implemented, as noted above. The responsible engineer made tie decision to delay the test instruction but did not initiate the proper method of justification and documentation required by the licensee's procedure, PAP-Il0 Additionally, the failures of the E0F's ventilation system were corrected via work requests; however, the system was not fully retested nor was a test verification sheet completed as required by the procedure. Both systems were successfully retested via the PTis in May and September of 1992 for the EOF and TSC, respectively. Finally, the engineers noted that the test instruction required a specific test which was beyond the basis of the system and, subsequently, caused the system to fail the test instruction. Although the inadequacy was first determined in March of 1990, it had not been corrected. Since the licensee's Technical Specification 6.8.1.b require the implementation and maintenance of procedures PTI-M53-P0002 and PTI-MS2-P0003 to meet the requirements of NUREG-0737 and its supplements, this is a violation (Violation No. 50-440/92023-01).

In order to correct these problems and prevent recurrence, the licensee had raised their staff's level of attention to these periodic-test instructions through training and tracking systems and revised the test instructions. The licensee provided training to all System Engineering Section engineers to address the failure to properly implement periodic test instructions and to instruct them on the proper methods of delaying the performance of the instructions. The licensee also implemented a tracking system which provided all department-managers with a listing of pTIs which have not been completed as required. The listing should increase managements level of involvement in ensuring .that the PTIs have been properly implemented. Finally, a Quality Assurance surveillance was completed on July 31, 1992, which verified that the corrective actions had been effective and that PTIs were properly being implemente . . _ _ . _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ -. _ _ _

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The licensee also revised both PTis to adequately address the performance basis of the system. An appro1riate engineering evaluation i was completed to address the adequacy of t1e PTis and identify the  ;

changes necessary. These revisions included the removal of a smoke  !

stick test and the addition of several damper position verification In response to the inspector's concerns for changing the test frequency, 3 the licensee also committed to performing abbreviated tests of the  ;

system during all of the emergency preparedness drills and exercise These tests will be documented and will have defined criteria for  ;

successful completion. Discussions with the licensee indicated that  !

these abbreviated tests would be effective in determining system '

performance and would be followed with the ap)ropriate level of testing if the system was malfunctioning. Based on tiese corrective actions,  ;

the violation is close !

One violation was identifie .

4 Seneral (IP 82301) .

An announced, daytime exercise of the Perry Nuclear Power Plant's emergency plan was conducted at the Perry site on December 9,1992. The exercise tested the capabilities of the licensee's emergency  !

organization to respond to an accident scenario involving the simulated  !

release of radioactive effluent. The attachments to this inspection -

report summarize the licensee's scape of participation and the exercise scenario,  ! General Observations (IP 82301)

The licensee's response was coordinated, orderly and timely. If the scenario events had been real, the actions taken by the licensee would have been sufficient to mitigate the accident and permit state and local authorities to take appropriate actions to protect the public's health  ;

and safety, j Specific Observations flP 82301) [.pntrol Room Simulator (CRS)

The CRS staff's performance was very goo The staff promptly identified plant conditions and implemented corrective action .

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The shift supervisor (SS) promptly_ identified changing conditions i and declared the Alert in accordance with the emergency action levels (EAl.s). Notifications to state and counties were completed within the regulatory time limits.

Communications in the CRS were very goo .

The SS held frequent L and detailed briefing The SS properly utilized the CRS communicators to answer questions of the NRC, state, and counties instead of being called to the telephones and.being distracted from responding to the even l l

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The SS, acting as emergency coordinator (EC), demonstrated good command and control. 1he SS properly directed plant activities to i mitigate the scenario events. After the loss of CRS annunciators, the SS was very aware of the need to avoid plant transients. When confronted with the Limiting Condition of Operation (LCO) for the '

failure to isolate the containment purge system, the SS requested for his staff to be doubled if a plant shutdown was necessary. He was not in favor of such an evolution, but he identified his needs

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should a plant shutdown be initiate The communications into the CRS were-adequat The CRS staff had a practice of reducing the volume of the plant public aodress (PA)

system to eliminate distractions from normal plant announcement However, this reduced the staff s ability to monitor the announcements made in other facilities. Additionally, the information concerning the simulated fire and contaminated injured aerson in the Intermediate Building was slow in reaching the CR Iowever, the CRS staff demonstrated good follow up of the status ;

of these event No violations or deviations were identified, b. Jechnical Support Center (TSC)

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The TSC staff demonstrated a very good response to the scenario events. Personnel quickly identified degrading plant conditions and properly impicmented the emergency plan. Site assembly and accountability was completed within the licensee's 30 minute time goa The TSt. staff activated the facility in a very timely manne The staff was well coordinated and followed appropriate activation procedures. A formal announcement of the activation was r.1ade by the operations manager (OH) at the time of the declared activatio The OM, acting as EC, demonstrated good command and control .of emergency actions.. Command and control'was-properly passed from the SS to the OH once the OM was properly briefed and the TSC was staffed. The OM established priorities for-plant activities _and pursued the completion of those activities. The engineering staff _

provided good technical support and recommendations to the O The OM declared the Site Area Emergency (SAE) in!1ess than five minutes following the initiating event, which was the trip of the reactor feed pump turbine. The notification of the declaration was'made in a timely manner to the state and counties.- The notifications- appeared ' complete and correct. However, one exception was noted in the first followup notification following the Alert declaration. The update notification incorrectly-indicated that nonessential site personnel had'been evacuate _ _ _ __. _____- _ - - _

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'A This notification was quickly corrected by the communicato All subsequent notifications were accurate in conten Overall, the communication between the OH and TSC staff was goo The OM appeared to effectively communicate with his staff. They were aware of the current conditions and their current ~ course of action. On one occasion, the radiation protection coordinator (RPC) imposed a minor delay of the manual isolation of the fuel '

pool surge tank because of high radiation levels. The RPC improperly instructed the maintenance coordinator to delay the local closing of a manual isolation valve until remote closing of an electrical isolation valve was attempted. This was contrary to the repair priorities assigned by the OM and briefed to the TSC

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staff. Once the OM realized the cause of the delay, he corrected the situation and approved radiation exposure extensions to initiate the task. Had the RPC informed the OM of the radiation concerns, this repair team could have been sont out more '

expeditiousl Some information was not effectively communicated to the TSC staff. The TSC staff was not notified of the obstruction at the plant exit caused by the simulated gravel spill. Although the shift security supervisor was cognizant of the occurrence, this information was not forwarded to the TSC staff. Information of .

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this nature would be instrumental for site evacuation purposes and for obtaining assistance from offsite personnel. However, the security personnel mitigated the obstruction well and directed personnel to alternative exit The TSC staff failed to monitor the meteorology during the latter stages of the event. At 1330 hours0.0154 days <br />0.369 hours <br />0.0022 weeks <br />5.06065e-4 months <br />, the direction of the wind shifted from 29 degrees to 312 degree Since the E0F had-assumed the responsibility for offsite protective actions, there were no offsite consequences. However, since the TSC staff did not 1 carn of the wind shift until 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br />, the potential existed for t exposing onsite perso.inel to the radioactive plume. -Fortuitously, no onsite personnel were directed-into the new plume's path during -i this time interva Status boards were frequently updated and effectively utilized by  !

the TSC staff..-Generally, the staff monitored this data closel One minor exception occurred after the simulator had to be reset because it did not properly model the method by which the loss of coolant accident (LOCA)'was terminated. The staff did not recognize that the main steam isolation valves (MSIVs) were identified as "open" on the status boards and emergency response information system (ERIS). This would-have indicated that their efforts to inject water into the reactor vessel could have ,

resulted in flooding through the steam lines. However, personnel monitored other indicators which proved that this was not the case and that the MSIVs were closed. This was an isolated instance, as most status boards were frequently monitored and data was evaluate _- $,.i ,.pv -,.y-- --p- -y .-aw+7 _y. - - - , .y 9 9 --y y $, -

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The TSC staff held good recovery discussions. Radiation protection personnel were sensitive to ALARA concerns. They effectively worked together with maintenance to support repair effort No violations or deviations were identifie Operational Eupport Center (OSC) and Inplant Teams -

The OSC staff provided good support to effect repair activities to mitigate the scenario event Priorities were well maintained in the OSC. The OSC coordinator communicated frequently with the TSC staff. He verified priorities on a regular basis. Higher prior';ty teams appeared to be dispatched from the facility on a timely basis. However, the HP supervisor had some difficulty locating personnel who were not assigned to the main OSC area. Overall, these delays were minimal and did not effect team dispatc Briefings and debriefings of repair teams were very good. Team members were made very aware of their tasks and the associated health physics concerns. Returning teams also reported pertinent information to the health physics superviso Briefings of the OSC staff were not very frequent. The OSC director relied on the ISC's staff briefings, which were audible on the facility's PA system, to brief OSC staff. However, not all of the OSC personnel, specifically, personnel not in the main OSC area, could hear the PA announcements. These personnel should be briefed on the overall changes in plant conditions and changes in prioritie Team tracking was very good. Team status was well maintained on status boards. Information on status boards was accurate and updated in a very timely manner. Communications between re) air teams and other facilities was good, with one exception. T1e team assigned to replace a circuit breaker for the annunciators did not notify the CRS staff that they were ready for testing the breake Instead, they notified the engineer, assigned by the OSC to oversee the repair. This created a slight delay in completing the repai No viclations or deviations were identifie Medical Drill The licensees demonstration of the response to a contaminated injured person was goo The response team provided good care to the simulated contaminated injured person. The radiation protection technicians (RPIs)

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" responded within five minutes of the initial call. They maintained conversations with the injured person until first' aid providers responded. The lead fire brigade responder (FBR)

provided good first aid.to the victi The lead fBR maintained good command and control-at the accident scene. He directed personnel to perfotm necessary actions. At times the large number of responders and cumbersome location made this direction difficult. However, the lead FBR provided good direction to RPTs and others in the are The safety concerns of the injured person were given proper .

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attention. The RPIs immediately removed the radiation source from the scene to limit the person's exposure. The person was carefully moved from the area affected by the simulated fire, t Contamination control of the accident scene was adequate. Gloves were frequently distributed and changed. However, on one isolated instance the inspectors observed that a torn glove was worn by an RPT and another RPT handled the victim with the same glove worn for taking area surveys. Although the victim was not further contaminated, this presented the possibility of contaminating'the victim. After the victim was moved, a proper contamination boundary was established around the inju .i person. The key FBR violated the contamination boundary once; however, all other times personnel were monitored before entering the non-contaminated are The contaminated injured person was transported to the ambulance-crew in a safe and timely manner. A good briefing was then given to the ambulance crew of the victim's injuries and current condition No violations or deviations were identifie e. Emeraency Doerations Facility (EOF)

The demonstrated response of. the EOF'_ staff was ' excellen The EC demonstrated very good command and control of the E0F staff's response. The EC ensured that the staff were working on an identified' course of action, well informed of plant conditions, and achieving their tasks. Briefings of E0F' personnel were frequent-and detaile The EOF staff quickly and correctly assessed the operational conditi"s and made the proper event classifications. The General Emerge...y:was declared in a timely manner and was made in accordance with the correct EAL, Notifications were made to the state and counties within the regulatory time limits.

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Communications were a major strength of the facility. The EC made complete and' frequent-briefings to the E0F staff and government- .

officials. Two members of. the E0F staff, designated as government liaisons, ensured that the state and county representatives were .

obtaining necessary informatio !

Offsite dose assessment'was excellent.- The offsite. dos .

assessment advisor identified the need to make. instantaneous dose assessments, as opposed to the 15 minute averages performed by the ~I licensee's computer software, when plant conditions rapidly changed. The dose assessment staff also identified the wind shif at 1330 hours0.0154 days <br />0.369 hours <br />0.0022 weeks <br />5.06065e-4 months <br /> and informed the balance of the E0F staff of the change. Offsite monitoring team data was effectively used to verify dose projections. . All of the data was properly used to .

prepare protective action recommendations-in a timely manne The E0F staff maintained good control over offsite monitoring team Communications with the teams were very good. The teams were directed to areas which could be utilized to verify dose projections and assess the effect of changing meteorology. Team members' radiation exposure data was well maintained'.

Recovery actions were properly implemented in the E0F. The recovery director (RD) assembled a recovery-team as required-by

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procedure. The RD and TSC staff assembled a comprehensive recovery plan which included current plant conditions, prioritized list of plant equipment in need of repair, and a list of outside assistance which may be necessary to effect repair No violations or deviations were identifie . . Exercise Ob.iectives and Scenario Review (IP 823021 The licensee submitted its proposed scope of Lxercise participation,-

objectives and copies of the scenario within the established deadline The licensee adequately addressed the inspectors' scenario review question No violations or deviations were identifie . Exercise Scenario and Exercise Control (IP 8230lf The most challenging aspects of the exercise included multiple medical emergencies, loss of annunciators while undergoing a plant transient, and multiple equipment- failures. The scenario was well prepared and contained several equipment mock-ups" which enhanced the exercise simulation.

D Overall, exercise control was very good. No instances of controller prompting were identified. However, minor-instances of controller inadequacies were identified during the medical drill. Upon the arrival of the RPTs, the controller presented the RPT with the victim's .

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contamination data without the RPT performing a survey of the victi This was considered unearned information. Additionally, the controllers at the scene were not readily accessible to the players. This often hindered the players in their full respons No violations or deviations were identifie . Licensee Critigges (IP 8230l).

The licensee's controllers held initial critiques in each facility with participants immediately following the exercise. Several of these critiques were observed and were determined to be detailed. Inputs from all participants were sough The licensee provided a summary of its preliminary, self-identified performance strengths and weaknesses, which were generally in agreement with the inspectors' preliminary finding No violations or deviations were identifie . Exit Interview On December 10 and 11, 1992, the inspectors met with those licensee representatives identified in Section 2 of this report in order to present and discuss the preliminary inspection findings. The inspectors discussed with the licensee the overall very good performance of the exercise. The inspectors also discussed the proposed violation and the licensee's completed corrective action The licensee indicated that none of the matters discussed were proprietary in natur Attachments:

1, Scope of Parthipation and Exercise Objectives Exercise Scenario Summary

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..+." SCOPE AND OBJECTIVES The scope of the exercise is defined in Section.l.l. The exercise objectives are provided as. separate sections, divided into the objectives for the Perry Plant (Section 1.2) and those of the state of Ohio-and Counties of Lake, Ashtabula and Geauga (Section 1.3).

1.1 SCOPE The 1992 Emergency Preparedness Exercise, to be conducted during normal working-hours as an announced exercise on December 9, 1992, vill simulate accident events culminating.in a radiological accident with resultant -

offsite releases from the Perry Plant, located in North Perry Village, Lake County, Ohio. The exercise. vill involve events that test the effectiveness of the Perry- Plant Emergency Preparedness Program and the integrated capabilities of the emergency organizations of the state of .

Ohio and the counties of Lake, Geauga, and Ashtabula. The Exercise vill include the mobilization of local resources necessary to demonstrate their offsite objectives to the Federal Emergency Management Agency (FEMA).

1.2 ONSITE OBJECTIVES The major objective of the exercise is to demonstrate the response capabilities of the Perry Plant Emergency Response Organization (ERO).

Vithin this overall objective, individual objectives are specified as follows:

ITEM N OBJECTIVE EVENT CLASSIFICATION 1 Demonstrate ability to effectively assess postulated plant-indications, alarms and reports, and correctly classify an emergency event in a timely manne Demonstrate ability to correctly identify a series of postulated emergency events which escalate to a Site Area or General Emergenc classificatio Demonstrate ability to correctly terminate from the emergency phase and enter Recovery per procedural guideline ERO NOTIFICATIONS / RESPONSE 1 Demonstrate ability to notify on-call ERO personnel in a timely _

manner upon (re) classification of an emergency even SECI. 1.0 - 1

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2 Demonstrate ability to effectively direct the activation of emergency facilities in a timely manner when_ required by procedure or varranted based on postulated event Demonstrate ability to adequately staff and activate facilities promptly in support of postulated emergency condition Demonstrate ability to augment staffing in support of postulated emergency condition Demonstrate ability to staff key positions within a facility required by the Emergency Plan on a 24-hour basi Limiting Condition: To be demonstrated through the development and approval of relief roster C. OFFSITE NOTIFICATIONS 1 Demonstrate ability to notify the State of Ohio and local counties within 15_ minutes of initially declaring and reclassifying an emergency even Demonstrate ability to notify the NRC vithin one hour of initially declaring or reclassifying an emergency even Demonstrate ability to periodically update Federal, State and local county officials and agencies on the status of emergency based on available informatio Demonstrate ability to maintain an.open line over the ENS and

"5-vay" circuits and respond to inquiries promptl Demonstrate the ability to effectively transfer responsibility for ENS and "5-vay" circuits between facilitie Demonstrate ability to notify and periodically update utility-support organizations (e.g., INPO, ANI) as require Demonstrate mechanism for recommending protective actions to State and local county authoritie D. EKERGENCY COMMUNICATIONS 1 Demonstrate ability to communicate clearly and effectively between onsite facilitie Demonstrate ability to communicate clearly and effectively with shift and OSC repair / assessment team personnel dispatched in-plan Demonstrate ability to communicate clearly and effectively with RMT SECT. 1.0 - 2

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4 Demonstrate ability to effectively _varn or advise Plant personnel or individuals onsite or in adjacent areas controlled by CEl utilizing the Plant Public Address (PA), Exclusion Area Page, and Tone-Alert Radio System Demonstrate ability to identify the need for and to request Federal assistanc Demonstrate ability to keep Corporate management informed of the emergency status and coordinate Corporate response suppor Limiting condition: Interfaces with Corporate management vill be simulated through the use of controllers or a response cal COMMAND AND C0ffrROL 1 Demonstrate ability of Shift Supervisor to promptly assume and carry out duties of the Emergency Coordinator upon the initial classification of an emergency even Demonstrate the effective and orderly transfer of Emergency Coordinator duties between facilitie Demonstrate ability of key ERO personnel to coordinate emergency assessment and response activitie Demonstrate ability to establish / revise in-plant ERO priorities and effectively utilize ERO personnel to address prioritie Demonstrate ability to effectively coordinate facility activities and to update facility staff on event status, priorities, and expected action Demonstrate the ability to coordinate the assembly, effective briefing / debriefing, and timely dispatching of OSC team Demonstrate ability to promptly access spare / replacement parts and materials and deliver to OSC or in-plant repair tea Demonstrate the effective coordination of on-shift personnel (PP0s/PPAs, Security Officers, etc.) and integration with the Emergency Response Organization (ERO).

9 Demonstrate ability to effectively transfer dose assessment responsibility and control of RHTs between facilitie Demonstrate ability to effectively control RHT movements in relation to the release plum !

SECT. 1.0 - 3

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11 Demonstrate ability of Plant, and State and local county governments to vork effectively and in a coordinated manner as specified in the Plant Emergency Pla ACCIDENT ASSESSMEffr/ RESPONSE 1 Demonstrate the timely and effective use of PEls, ONIs, and other operations procedures to respond to postulated indications, alarms and report Demonstrate ability of ERO to assess postulated equipment / component f ailures in a timely manner and ef fectively develop corrective actions to mitigate event Demonstrate the ability to identify the source of an actual or potential radiological release and postulated magnitude based on plant system parameters and effluent monitor Demonstrate ability to mobilize and deploy RMTs in a timely manne Demonstrate appropriate equipment and procedures for determining ambient radiation level Demonstrateappropriatewquipmentandproceduresjormetsuring airborne radioactive concentrations as lov as 10- uCi/cc under field conditions in the presence of noble gase Demonstrate ability to project exposures based on plant effluent monitor readings and field data for various meteorological condition Demonstrate ability to determine appropriate protective action recommendations for the general public based on NUREG-0654, Appendix 1 and EPA Protective Action Guidelines (PAGs).

9 Demonstrate ability to determine the source term of releases of radioactive material within plant systems (i.e., Relationship between Containment radiation monitor readings and radioactive material available for release from containmen Demonstrate ability to effectively track airborne radioactive plume using RMT Demonstrate appropriate equipment and procedures for monitoring ground contanination and for the collection, transport, and analysis of environmental samples (e.g., vater, soil, vegetation).

12 Demonstrate means of relating various measured param&ters (e.g.,

contamination levels, water and air activity levels) to dose rates for key isotopes and gross radioactivity measurement l SECT. 1.0 - 4

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.,s 13 Demonstrate provisions made for estimating integrated (accumulated) i dose from projected 'and actual dose rates and for comparing these ;

estimates with PAG !

14 Demonstrate onsite capability and resources to provide' initial values and continuing assessment throughout the course of an accident, to include:

- post-accident sampling capability

- radiation and effluent monitors

- in-plant radiation monitoring instrumentation

- Containment radiation monitorin Demonstrate ability of security personnel to provide prompt access for emergency equipment and suppor Demonstrate access to fixed or mobile laboratory facilitie FACILITIES AND E0tIIPMFRf 1 Demonstrate the effective operation and adequacy of the-following onsite facilities in the assessment and mitigation of a postulated emergency event:

- Control Room

- Technical Support Center (TSC)

- Operations Support Center (OSC)

- Emergency Operations Facility (EOF)~

- Public Information Response Team (PIRT)-

2 Demonstrate the-ability of key ERO personnel to perform the staffing

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responsibilities outlined in Table 8-1 of the Emergency Plan for the event postulate Demonstrate the ability of facility staff to update / maintain status boards and other dirplays in an aceutate and timely manner.-

4 Demonstrate ability of ERO staff to effectively use the Emergency

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i Response Information System (ERIS) to monitor and assess plant condition Demonstrate ability of ERO staff te properly respond to postulated high area / airborne radiation levels in-one or more facilities or the

[ failure of aLfacility radiation monitor.

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! 6 Demonstrate ability of TSC and EOF staff to place facility HVAC in emergency isolation mod '

7 Demonstrate ability of the TSC and EOF HVAC systems to adequately maintain facility temperature control within established limits.

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l SECT. 1.0 - 5

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8 Demonstrate the availability of equipment (including dosimetry and sampling devices) to effectively support facility operations, OSC teams, and RHT Demonstrate ability to access and acquire data from geophysical phenomena monitors (e.g., meteorology, hydrologic, seismic). ACCOUNTABILITT 1 Demonstrate ability to account for all individuals within the Protected Area upon initiation of personnel accountability by ascertaining the names of missing individuals within 30 minutes an accounting for Protected Area personnel continuously thereafte Demonstrate the organizational ability and resources necessary to deal with impediments to evacuation, such as inclement weather or traffic obstruction Demonstrate the organizational ability and resources necessary to control site acces Demonstrate ability to radiologically monitor individuals evacuating the Protected Are EXPOSURE C0tTTROL 1 Demonstrate ability to effectively monitor and control emergency worker exposures per Plant procedure Demonstrate the ability to authorize extensions for Plant emergency worker exposures in an expeditious manner which takes into account reasonable consideration of relative risk Demonstrate the ability to assign personal dosimetry, effectively monitor exposure at appropriate frequencies, and maintain accurate dose records for Plant emergency worker Demonstrate adequate equipment and procedures for decontamination of Plant emergency workers and equipment, and for vaste disposa Demonstrate onsite contamination control measures, including area access control, drinking vater and food supplies, and criteria for permitting return of areas and items to normal us Demonstrate adequate equipment and procedures for individual respiratory protection and use of protective clothing for individuals remaining or arriving onsite during the postulated emergency even Demonstrate the ability to make decisions, based on predetermined criteria, whether to issue potassium iodine (KI) to Plant emergency worker !

SECT. 1.0 - 6

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8 Demonstrate the organizational ability and resources necessary to supply and sdminister K MEDICAL RESPONSE -

1 Demonstrate the ability of onsite first aid responders to effectively assess a medical emergency and render appropriate medical care within their training in a timely manne Demonstrate the adequacy of health physics support in determining the radiological status of a victim and advising first aid responders on radiological concern Demonstrate the adequacy of facilities and equipment to support first aid responder Demonstrate the ability to promptly notify and request offsite ambulance support for transportation of a victi Demonstrate the organizational ability and procedures for Plant first aid responders, health physics and security officers to effectively coordinates access and egress into the Protected Area of-an offsite ambulance; dress-out and radiological monitoring of the-ambulance and crev; and trancfer of a victi Demonstrate the ability to notify and coordinate with a local medical facility for the care, handling and treatment of a contaminated and injured victi Demonstrate the ability of offsite medical facility to evaluate radiation exposure and uptake to a contaminated victi Demonstrate the organizational ability and procedures for handling situations where offsite ambulance personnel may exceed pre-established exposure limit PUBLIC INFORMATION/ RUMOR CONTR0 Demonstrate points of contact and physical locations for use by news media during an emergenc Demonstrate the organizational ability and procedures which

- designate a spokesperson having access to necessary information

- arrange for a timely exchange of information among designated spokespersons 3 Demonstrate the ability to brief media representatives in a clear, accurate and timely manner.

B SECT. 1.0 - 7

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4 Demonstrate the ability to monitor the media to detect and correct error Demonstrate the ability of Company telephone attendants and personnel to reroute incoming inquiries regarding the emergency to the PIRT/JPI Demonstrate the ability to establish and operate rumor control in a coordinated fashio Demonstrate the ability of the PIRT/JPIC to disseminate information to Company employee RECOVERY l Demonstrate organizational ability and resources to coordinate re-entry into an evacuated are Demonstrate ability to formulate a Recovery Plan and identify a Recovery Organizatio Demonstrate ability to establish a method of periodically updating State and local county officials on Plant recovery activitie POST-ACCIDENT SAMPLING 1 Demonstrate analysis of in-plant liquid samples with simulated or actual elevated radiation levels including use of the Post-Accident Sampling Syste END OF OBJECTIVES l-i t

SECT 1.0 - 8

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s 1992 EVALUATED EXERCISE-PERRY PLANT 6.1 INITIAL CONDITIONS 1. The Perry Plant has been operating continuously at full power for=

approximately the last 12 month . Planning is in progress in preparation for the upcoming refueling outage, scheduled for February 14, 199 .

3. Standby Liquid Control System Pump C41-C001A is out of service for scheduled maintenanc . Control Room Ventilation System B is out of service for scheduled maintenance. It is expected to be returned to service by 100G hour . RHR-A is operating in suppression pool cooling mode to lover suppression pool temperatur . A temporary high radiation area has been established at the Tool Decontamination Room outside the Intermediate Building (IB), 574' leve Valve decontamination is scheduled to begin toda . Condensate Transfer and Storage System-(Pil) is isolated to the Fuel Handling Building for scheduled maintenanc ;

8. Reactor Vater Cleanup _(RVCU) Filter /Demineralizer A vas backvashed:and precoated last shift. Containment Purge (M14) is in operation to reduce containment MPC levels, now at 60%. Chemistry section vill be taking-sample . Diesel fuel oil is scheduled to be delivered later this afternoo . Several tons of "A" stone are scheduled to be delivered to the Shoreline Revetment Project this mornin . All other plant systems and components are operabl . Current meteorological conditions and forecast are as follows:

This morning northeast Ohio can expect partly-cloudy skies with light vinds out of the north. Temperatures vill be in the middle to upper _30's with vinds 5 to 10 mp SECT. 6.1 - 1

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1992 EVALUATED EXERCISE PERRY PLANT-6.2.1 ON-SITE SEQUENCE OF EVENTS SUMMARY ,

Approximate Key 4 Time Events 0715 Start shift turnover in the Control Room Simulato Commence the 1992 Evaluated Exercis A Loose Parts Monitoring System alarm is received. The Shift r Technical Advisor (STA) is dispatched to investigate. I&C may be asked to assis Control Room Ventilation System Supply Fan OM25-C001A trips on-differential pressure when motor vortex damper M25-F260A fails closed. Maintenance should be dispatched to

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investigate / troubleshoot; the System Engineer should be contacte .

0820 A loss of Control Room annunciators occurs due to a power supply

< failure, but the plant does not undergo a transien The Shif t Supervisor should declare an ALERT due to EPI-A1, Condition I.II.1 "Most or all alarms-(annunciators) lost".

The TSC and OSC 'are directed to be activated.

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0900 Chemistry reports that Containment MPC levels are within ,

specifications. Operators should secure containment purge. The outboard supply valves closes; however, the inboard. supply valve IM14-F190 does not close. A team should be dispatched to close this valve.

0915 While moving a temporary lighting fixture outside the Tool Decontamination Area on the 574' level in the' Intermediate Building, a Plant Helper is electrically shocked when he touches a live bare wire. The worker is rendered temporarily unconscious and contaminated when he falls to the floor. A small fire starts in s

the area. A second Plant Helper suffers a heart attack while-reporting the accident to Control Roo The Fire Brigade and First Aid Team are toned ou First aid is

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rendered to employee Perry Township and Madison Fire Departments-(

are called to respon One train of Control Room ventilation is expected to be restored by this tim SECT. 6.2 - 1

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1992 EVALUATED EXERCISE PERRY PLANT 6.2.1 ON-SITE SEQUENCE OF EVENTS SOHHARY Approximate Key Time Events 1020 Reactor Feedvater Pump Turbine A trips due to lov oil pressure because of an oil leak. Reactor power runs back to approximately 68% and the Motor Feedvater Pump auto-starts to recover leve Operators should implement ONI-N27, "Feedvater".

1030 The Emergency Coordinator should declare a SITE AREA EMERGENCY due to EPI-A1, Condition I.III.1, "Most or all alarms (annunciators)

lost, and a plant transient has initiated or is in progress."

The EOF and JPIC are directed to be activated, and personnel accountability implemente An impediment to site evacuation occurs when a dump truck driver loses control of his truck and spills several tons of stone onto the Vest Gate Access Roa A vorker exiting the Protected Area through the PACP sets off a radiation portal monitor. Health Physics responds, and he is found-to be contaminate The Control Room is notified that contract workers, perforaing a lift test on the Fuel Handling Jib Crane Hovement- Holst (OL51E0059)

in the 620' elevation, Fuel Handling Building,-left a 3000 lb. test veight suspended from the hoist when they evacuated the Protected Area during personnel accountability. An OSC team should be dispatched to secure the hoist and lover the test weigh Vhile securing the hoist, the test weight accidentally drops onto the top of Fuel Pool Cooling and Cleanup (FPCC) Surge Tank A, and

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falls down the_ side of the surge' tank, glancing off the return line from the upper pools.and causing a veld failure at the surge tank penetratio If Control Room staff attempt to isolate the surge tank, the isolation valves do not close. Subsequent investigations show that FPCC System Outboard Isolation Valve G41-F145 does not isolate because of a bent valve stem and stripped stem nut; Inboard

. Isolation Valve G41-F140 does not isolate due to a failed control power fuse; manual isolation valve G41-F513 can not be closed due to faulty ste SECT. 6.2 - 2

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  • ,t 1992 EVALUATED EXERCISE PERRY PLANT

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6.2.1 ON-SITE SEQUENCE OF EVENTS SUMMARY Approximate Key Time Events 1120 FPCC Surge Tank A level vill continue to decrease to 60" by 1220; (Cont.) at this level a direct pathway exists from Containment to the Fuel Handling Building atmosphere via the empty, non-isolated upper pool ~

return lin The annunciator problem is repaired; all annunciators are restore Reactor Recirculation Pump A high vibration alarm is receive Upon reset, the alarm clear Reactor Recirculation Pump A high vibration alarm is received again. The recirculation pump seal has developed a small seal leak into the Dryvell. Upon reset, the alarm does not clea A major loss of coolant accident (LOCA) on the Recirculation Pump A casing occurs. Recirculation System Isolation Valve B33-F023A falls in the intermediate position when its power supply breaker trip Failed fuel is indicated when Reactor water level decreases to below top of active fuel (TAF) before High Pressure Core Spray (HPCS) and feedvater can restore leve Dryvell pressure reaches 20 psig causing several Safety Relief Valle (SRV) tailpipe boot' to fai Containment pressure increases to approximately 8 psi Both volumes equalize at about 7.3 psig and then decreas A radioactive release tc the environment is now occurring via the following pathway:

Recirculation System LOCA in the Dryvell to Containment via the .

blown out SRV tailpipe boots; containment atmosphere through upper fuel pools skimmers to FPCC Surge Tank A via the empty non-isolated system return line; surge tank to the Fuel Handling Building (FHB)

atmosphere via the failed return line, tank vent. and skimmer lines to the lover pools; FHB Ventilation to the Unit 1 Ven The Emergency Coordinator should declare a GENERAL EMERGENCY per EPI-A1, Attachment 2, " Loss of Two Fission Product Barriers with a potential Loss of the Third Barrier."

SECT. 6.2 - 3

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1992 EVALUATED EXERCISE PERRY PLANT G.2.1 ON-SITE SEQUENCE OF EVENTS SUMHARY

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Approximate Key Time Events

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1245 Operators may establish a closed core cooling loop as follows:

HPCS injection from the suppression pool to the reactor; vacer -

exits out the 'A' Recirculation Loop leak to the Dryvell into the -

suppression pool. Residual Heat Removal (RHR) loops A and B are in suppression pool cooling mod The area radiation monitor in the TSC alarms indicating high radiation levels. Troubleshooting later determines that a ground fault caused the alar A wind shift occurs. A new protective action recommendation (PAR)-

should be generate The release is terminated when either Valve G41-F145 or G41-F140 is close The LOCA is terminated when Recirculation System Isolation Valve B33-F023A is closed when its associated breaker is repaire Re s _ very discussions may commence; environmental monitoring should .,

he underwa ,

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1530 Exercise may be terminated at this time at the discretion of the Lead Exercise Controlle _

SECT. 6.2 - 4