IR 05000443/1998003

Insp Rept 50-443/98-03 on 980602-04.No Violations Noted. Major Areas Inspected:Insp Observed & Evaluated Licensee Biennial full-participation Exercise in Simulator Control Room,Technical Support Ctr & Operations Support Ctr

ML20236N906
Person / Time
Site:	Seabrook
Issue date:	07/09/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236N899	List: IR 05000443/1998003 ML20236N896
References
50-443-98-03, 50-443-98-3, NUDOCS 9807160051
Download: ML20236N906 (12)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket No:

50-443 License No:

NPF-86 Report No:

50-443/98-03 i

Licensee:

North Atlantic Energy Service Company Facility:

Seabrook Generating Station, Unit 1 Dates:

June 2-4,1998

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l inspectors:

D. Silk, Senior Emergency Preparedness Specialist W. Maier, Emergency Preparedness Specialist R. Lorson, Senior Resident inspector, Seabrook Station J. Brand, Resident inspector, Seabrook Station l

R. Ragland, Radiation Specialist

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Approved by:

Michael C. Modes, Chief Emergency Preparedness and Safeguards Branch Division of Reactor Safety

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9907160051 980709

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PDR ADOCK 05000443 G

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TABLE OF CONTENTS PAGE EX EC UTIVE S U M M A R Y............................................. iii l

R e p o rt D e t a i l s.................................................... 1 P4 Staff Knowledge and Performance................................. 1 P8 Miscellaneous EP Issues........................................ 5 P8.1 Scenario Preparation and Control............................. 5 P8.2 Updated Final Safety Analysis Report (UFSAR) Review.............. 5 P8.3 Review of Licensee Changes to the Emergency Plan and implementing Procedures

...........................................5 V. M ana g em ent Meeting s........................................... 6 X1 Exit Meeting...........................................6 INSPECTION PROCED URES USED...................................... 7 ITEMS OPENED, CLOSEL). AN D DISC USS ED............................... 7 LI ST O F ACRO NYM S U S ED........................................... 8 ATTACHMENT 1..................................................9 ii

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EXECUTIVE SUMMARY Seabrook Station Full-Participation Emergency Preparedness Exercise Evaluation June 2-4,1998

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I Inspection Report 50-443/98-03 l-

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l Overall licensee performance during this exercise was adequate as the licensee

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demonstrated it could implement the emergency plan. Facilities were activated in a timely manner. Classifications and notifications were accurate and timely. Protective action recommendations were appropriate. However, the licensee did not relay important information promptly and was not aggressive in pursuing issues. There was a three hour delay in initiating actions to secure an open steam generator safety relief valve (which was

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the radiological release path); there were no discussions that correlated increased radiation monitor readings with fuel damage; and reactor coolant chemistry results, indicative of fuel damage, were not actively sought or disseminated once available.

The licensee's critique process was very good. Post-exercise facility debriefs were candid.

At the formal critique, the licensee identified numerous issues, in addition to those

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l identified by the NRC. There were good discussions at the critique to develop solutions for the significant issues. Overall, the critique was balanced with positive and negative findings and was appropriately self-critical.

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Report Details P4 Staff Knowledge and Performance a.

Exercise Evaluation Scope During this inspection, the inspectors observed and evaluated the licensee's biennial i

full-participation exercise in the simulator control room, the technical support center, the operations support center, the emergency operations facility, and the media center. The inspectors assessed licensee recognition of abnormal plant conditions, classification of emergency conditions, notification of offsite agencies, development of protective action recommendations, command and control, communications, and the overall implementation of the emergency plan. In addition, the inspectors observed the post-exercise critique to evaluate the licensee's self-assessment of the exercise.

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Emeraency Resoonse Facility Observations and Critiaue Simulator Control Room (SCR)

The SCR crew quickly recognized and appropriately classified the simulated increase in radiation levels in the primary auxiliary building (PAB) as an alert. Activation of the emergency response organization (ERO) was performed promptly. The states were notified within 15 minutes of event declaration and the NRC was notified within one hour as required. The crew appropriately activated the emergency response data system at the alert classification. Crew members reviewed the emergency action levels to anticipate potential classification escalation. There was also good discussion about detecting increases in reactor coolant system (RCS)

activity since the letdown radiation monitor was being affected by the high radiation levels in the PAB.

Technical Suocort Center (TSC)

The TSC was staffed in accordance with the emergency plan and activated 40 minutes after the alert declaration. Command and control of the TSC staff was generally good. The technical services coordinator, responsible for overall coordination and prioritization of maintenance activities and radiation protection, showed excellent command and control of the resources at his disposal. The site emergency director (SED) classified emergency conditions, with the counsel of operations department members of his staff, in a timely and accurate manner. The SED appropriately evaluated the possibility of de-escalatir,g the emergency classification. The SED reminded the TSC staff on occasion to keep the noise level to a minimum. He conducted facility briefings at regular intervals and was flexible to interrupt briefings when required by plant conditions and to relax the frequency of briefings when this practice was appropriate. On one occasion, however, he failed to explicitly request a core damage assessrnent based on available RCS chemistry data.

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While adequate protective actions for site workers were automatically taken when the site was evacuated at the alert declaration, the TSC was slow to direct a detailed characterization of the radblogical hazards onsite. The TSC did not organize onsite radiological survey teams until three hours after the beginning of the release. Also, the health physics coordinator (HPC) did not update the radiological status boards in the TSC beyond the initially reported radiation levels in the PAB.

Only informal habitability surveys in the TSC were conducted. The HPC did not survey the entire area of the TSC and the control room. He did not issue dosimetry until 80 minutes after TSC activation, which was after the initiation of the radiological release. The inspectors noted that a significant portion of the HPC's l

time was spent communicating with the OSC and analyzing radiation monitor

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channel readings, such that the above listed tasks were not adequately performed.

There was some confusion on the part of the operations technician as to whether the TSC was responsible for developing a protective action recommendation (PAR)

when the site area emergency was declared. Although the other facility managers in the TSC agreed that responsibility for PAR development rested with the response manager in the emergency operations facility, Step 2.1.7 of Technical Support l

Center Operations, ER 3.1, indicates that PARS to offsite authorities is a SED responsibility that may not be delegated. The inspectors informed the licensee of the procedural discrepancy.

l The TSC staff took a protracted amount of time to evaluate the radiological release and formulate a plan to stop it. The release path was via a stuck open safety relief l

valve (SRV) on the steam line of a steam geneiator (SG) with a ruptured U-tube.

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Although the TSC staff received a report that the SRV was open shortly after the release began, a team was not dispatched to verify that the SRV was stuck open until nearly three hours after the release began and nearly one hour after the radiological consequences of the release exceeded the general emergency (GE)

threshold. Early confirmation of the release path and timely action to stop the release could have precluded the GE condition. The failure of the TSC staff to take timely action to assess'and mitigate the release is considered an exercise weakness (IFl 50-443/98-03-01).

The TSC staff also delayed approximately 45 minutes from the time that RCS radiochemistry results were available until they used that information to calculate a l

core damage assessment. The HPC had received the information in the TSC but did not announce it until the facility brief was conducted 15 minutes later. When he did announce the information, he did not announce all of the sample results. The SED did not to order a core damage assessment as soon as he was informed that the chemistry results were available. The engineering coordinator, also aware that the results were available, did not to pursue the data so that a immediate core damage assessment could be performed. Although not a time critical activity, better coordination of the data from the RCS sample would have eliminated the delays in obtaining core damage assessmen _

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Operations Sucoort Center (OSC)

The OSC was staffed and activated in a timely manner following the alert declaration. Generally there was good command and control demonstrated as repair team status was tracked, priorities were assigned and changed as plant conditions changed, and frequent and informative briefings were provided by the OSC

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coordinator. Some minor communications discrepancies were observed in the OSC.

There was some initial confusion between the OSC and security regarding the number of personnel at the 25 foot level in the PAB shortly after the demineralized filter was dropped. There was lack of specificity when referring to emergency feedwater pumps (turbine driven versus motor driven) since both had been experiencing problems simultaneously. Finally, no one corrected the OSC comrnunicator when he referred to the SRV valve as the atmospheric dump valve.

There were no adverse effects caused by these communications discrepancies.

Emeraency Ooerations Facility (EOF)

The EOF was staffed and activated within 50 mirides of the alert declaration.

Throughout the exercise, EOF personnel performed their response duties in a calm and orderly manner. However, discrepancies were observed involving the dissemination, display, and updating of plant process and event information. For example, the radiological conditions status board had not been updated prior to 11:12 a.m. to reflect data gathered by the field survey teams (FSTs). Plant parameters were being manually plotted every 15 minutes on small charts that were difficult to interpret from more than a few feet away. Additionally, the infrequent plotting resulted in a loss of information, for example, plots did not reflect that reactor vessel level had temporarily dropped below 100%. Several of the plant data

monitor displays were of poor quality and difficult to interpret. The EOF staff did not display a questioning attitude when reviewing plant data that resulted in one instance where incorrect information was provided to State representatives.

Specifically, pressurizer level indication dropped rapidly just prior to the 11:45 a.m.

briefing with the States. However, when this data was initially presented at the briefing, the States were informed that " plant conditions were stable." This information was corrected later during the same briefing. Also, when offsite dose projections significantly increased, the EOF staff did not brief the States on the possibility of fuel or cladding damage in a timely manner. There was no significant adverse impact observed as a result of these issues.

Staffing of the dose assessment function and FSTs at the EOF was timely in that they were fully staffed within approximately 35 minutes of the alert declaration.

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FST preparations were thorough and methodical, and the teams were dispatched within 70 minutes of the alert declaration. Appropriate radiation protection measures were taken for FST members in that they were supplied with protective clothing, radiation exposures were frequently reported and tracked, and use of potassium iodide was appropriately evaluated. Throughout the drill, communications between FSTs and the EOF were clear, frequent, and included proper repeat backs.

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The dose assessment specialist (DAS) directed the dose assessment function, evaluated meteorological and radiological conditions, and briefed and advised the l

EOF coordinator (EOFC). The EOFC informed the response manager (RM) of changing radiological conditions, advised the RM in developing and communicating the PARS to state representatives. The EOFC kept the DAS apprised of changing l

plant conditions that could affect offsite releases, allowing the meteorological post i

accident computer (METPAC) operator to perform "what if" dose calculations. In one case, the EOFC informed the DAS that high differential pressure across the SG could result in further U-tube damage and increase the radiological release. The METPAC operator.also provided updates of projected off-site dose every 15 minutes.

l-Some discrepancies were identified. It was observed that dose assessment personnel did not immediately react to an initial increase in the main steam line monitor dose rates at 10:00 a.m. when a SG U-tube rupture occurred, as it was ne,t

referenced in logs, discussions were not observed, and no immediate METPAC

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calculations were initiated. When radiation levels significantly increased at l

approximately 11:45 a.m., dose assessment personnel appropriately concentrated j

l on METPAC runs but did not specifically inform the EOFC that fuel damage may

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have occurred. Knowledge of the existence of core damage at that time in the scenario was secondary to responding _to its effects (i.e., high radiation monitor readings). However, the EOF staff should have been informed of the possibility of core damage. Finally, it was observed that radiological boundaries established outside of the EOF were sagging which may have been a causal factor for the i

subsequent radiological boundary violations that licensee personnel observed.

However, the overall performance of the dose assessment team was effective in

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that they were able to make timely projections of offsite dose based on main steam

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line dose rates, allowing for the proper classification of the exercise event as a GE.

Media Center (MC)

This was the first exercise in which the EOF and the MC were co-located and resulted in some re-arrangement of the EOF to accommodate the MC. The MC was well equipped. For example, in addition to television and radio monitoring

capabilities, the licensee has the capability to monitor and to disseminate i

information via the Internet. The licensee implemented positive measures to restrict media personnel from accessing and interfering with the EOF functions. There was

- good media simulation observed in the media response room. Overall, the MC functioned well and did not result in overcrowding of the EOF building.

Licensee Exercise Critiaue.

Immediately following the exercise, the licensee began its critique process with

players, as well as controllers, providing candid debriefs. At the formallicensee critique on June 4,1998, the licensee identified issues in addition to the ones identified by the inspectors. Positive and negative items were noted. Discussions regarding solutions to several significant issues took place. Overall, the critique was thorough and appropriately self-critical and was assessed as very good.

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Overall Exercise Conclusions Overall licensee performance during this exercise was adequate as the licensee demonstrated it could implement the emergency plan. Facilities were activated in a timely manner. Classifications and notifications were accurate and timely.

Protective action recommendations were appropriate. However, the licensee did not rehy important information promptly and was not aggressive in pursuing issues.

There was a three hour delay in initiating actions to secure an ooen steam generator safety relief valve (which was the radiological release path); there were no discussions that correlated increased radiation monitor readings with fuel damage; and reactor coolant chemistry results, indicative of fuel damage, were not actively sought or disseminated once available.

The licensee's critique process was very good. Post-exercise facility debriefs were candid. At the formal critique, the licensee identified numerous issues, in addition to those identified by the NRC. There were good discussions at the critique to develop solutions for the significant issues. Overall, the critique was balanced with positive and negative findings and was appropriately self-critical.

P8 Miscellaneous EP issues P8.1 Scenario Preparation and Control An in-office review of the exercise objectives and scenario was conducted by the inspectors prior to the exercise. It was determined that the scenario supported the demonstration of the stated objectives and satisfactorily exercised a significant portion of the emergency response capabilities.

P8.2 Uodated Final Safety Analysis Reoort (UFSAR) Review A recent discovery of a licensee operating their facility in a manner contrary to the UFSAR description highlighted the need for a special focused review that compares plant practices, procedures, and/or parameters to the UFSAR or the emergency plan. During this exercise, the inspectors observed the licensee's compliance with the emergency plan regarding ERO staffina, facility activation, procedural usage, classification of simulated events, and notification of offsite agencies. No dis,crepancies were observed.

P8.3 Review of Licensee Chances to the Emeraency Plan and implementing Procedures The inspectors conducted an in-office review of changes made to the emergency plan and implementing procedures submitted to the NRC under the provisions of 10 CFR 50.54(q). Based upon the licensee's determination that the changes did not decrease the effectiveness of the emergency plan, no NRC approval is required in accordance with 10 CFR 50.54(q). A list of the changes that were reviewed is included in Attachment 1 to this repor _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.

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. V. Manaaement Meetinas X1 Exit Meeting The inspector presented the inspection results to members of licensee management

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at the conclusion of the inspection on June 4,1998. The licensee acknowledged the inspectors' findings.

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INSPECTION PROCEDURES USED

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82301: Evaluation of Exercises for Power Reactors 82302: Review of Exercise Objectives and Scenarios for Power Reactors l

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ITEMS OPENED, CLOSED, AND DISCUSSED l

Ooened IFl 98-03-01 The TSC did not promptly initiate action to re-seat a stuck open SG l

safety relief valve which could have precluded a GE condition.

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LIST OF ACRONYMS USED DAS Dose Assessment Specialist EOF Emergency Operations Facility EOFC Emergency Operations Facility Coordinator ERO Emergency Response Organization FST Field Survey Team GE General Emergency METPAC Meteorological Post Accident Computer MC Media Center OSC Oper' tens Support Center PAB Primary Auxiliary Building PAR Protective Action Recommendation RCS Rea;: tor Coolant System RM Response Manager SCR Simulator Control Room SED Site Emergency Director SG Steam Generator SRV Safety Relief Valve TSC Technical Support Center UFSAR Update Final Safety Analysis Report

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ATTACHMENT 1 EMERGENCY PLAN AND IMPLEMENTING PROCEDURES REVIEWED Document Document Title Revision (s)

Seabrook Station Radiological Emergency Plan

ER 1.1 Classification of Emergencies 27 Change 1 ER 1.2 Emergency Plan Activation 30 Change 1,31 ER 3.1 Technical Support Center Operations 26 Change 1, 27 ER 3.3 Emergency Operations Facility Operations 21 Changes 1,2,3: 22 ER 3.4 Seabrook Station News Services Operations

ER 3.5 Media Center / Joint Telephone Information Center

ER 3.6 Assembly Area Operations

ER 4.3 Radiation Protection During Emergency Conditions

ER 5.2 Site Perimeter and Offsite Monitoring and Environmental Sampling

ER 5.3 Operation of METPAC System

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