IR 05000445/1997016
| ML20217K437 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/13/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20217K425 | List: |
| References | |
| 50-445-97-16, 50-446-97-16, NUDOCS 9708150245 | |
| Download: ML20217K437 (22) | |
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UtqlOSjlEE U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket ths.:
50 445 50 440 License Nos.:
NPF 87
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NPF-89 Report No.:
50 445/97 10
50 440/97 10 Licensee:
TU Electric Facility:
Comanche Peak Steam Electric Station, Units 1 and 2 Location:
FM 50 Glen Rose, Texas Dates:
July 22 25,1997 Inspectors:
Gail M. Good, Senior Emergency Preparedness Analyst, Team Leader Rebecca L. Nease, Technical Assistant Thomas H. Andrews Jr., Radiation Specialist Michael Hay, Radiation Specialist Approved By:
Blaine Murray, Chief, Plant Support Branch ATTACHMENT:
Supplemental Inf ormation 9708150245 970813 PDR ADOCK 05000445
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QXECUTIVE SUMMARY
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Comanche Peak Steam Electric Station, Units I and 2 l
NRC Inspection Report 50 445/97 16;50 446/97 16
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i A routine, :snntiunwd inspection of the licensee's performance and capabilities during the
j full scale viennson exercise of the emergency plan and implementing proceduros was
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performet. The inspection team observed activities in the control room simulator,
technical support conter, operations support center, and emergency operations f acility.
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Piant Sup_pgu i
An unresolved item was identified involving the description of the emergency i
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response organization in the emergency plan (Section P3).
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i Overall, control room staff's performance was good. Olisite agency notifications
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were timely. Onsite announcements regarding equipment operation and radiological
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conditions were proactive and timely. Analysis of plant conditions was very good i
and personnel demonstrated a questionlag attitude throughout the exercise. Facility briefings were infrequent and unstructured. The control room staff demonstrated
1ood coordination and communication with the technical support center, operations support center, and emergency operations f acility (Section P4.2).
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l Overall, the technical support center staff's performance was good. The center
was promptly activated and emergency classifications were correct and timely. The i
technical support center manager exhibited good command and control. Briefings were frequent, clear, and concise with good participation by center coordinators.
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The staff worked well as a team to identify actions necessary to cope with scenario
. events. Noise levels and equipment problems degraded some communications
(Section P4.3).
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Overall, the operatior;s support center staff's performance was satisf actory. The
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use of the " prompt" team to staff the emergency response and damage control
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teams expedited team dispatch, damage assessments, and corrective measures.
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Teams were organized and dispatched in proper order to effectively handle repair
priorities. An exercise weakness was identified for failure to provide proper radiation protection coverage for teams performing tasks outside the power blocks
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als required by procedures. One other instance of inappropriate implementation of a
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procedure was also noted (Section P4.4).
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Overall, the emergency operation's facility staff's performance was generally very good. -The transfer of emergency coordinator duties' was not clearly accomplished.
Personnel worked well as a team to accomplish f acility responsibilities.
- Comprehensive and frequent briefings were' conducted to keep facility members informed of current conditions and to focus attention on facility priorities. Offsite.
agency notifications and protective action recommendation development were
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i 3-correct and timely. Some notification message forms contained minor internal inconsistencies. Changing plant conditions and worst case scenarios were appropriately anticipated and f actored into dose projections. Field teams were effectively controlled to confirm dose projections and determine actual offsite
impact (Section P4.5).
The scenario was sufficiently challenging to test onsite response capabilities.
- Exerciso control was sufficient. Simulator glitches required controller interaction, gaitronics announcements were not always heard in the simulator, and some radiation protection responses were oversimulated (Section P4.6).
Post-exercise critiques were thorough, open, and self critical; good suggestions for
improvement were identified. The management critique was detailed, informative, open, and self critical. Management elevated one improvement item to a weakness.
Overall, the critique process effectively identified weaknesses and improvement items (Section P4.7).
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[L Plant Suppgit P3 Emergency Preparedness Procedures and Documentation
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a.
Lrup3 c tio n s ic_0p_(LL82701 -02. 01 )
The inspecturs reviewed the emergency plan and emergency response organization roster to determine if the emergency plan sufficiently described the licensee's organization for responding to emergencies, b.
Ql2MLYgions and Findinas During the inspection, the inspectors reviewed Section 1.0 of the licensee's emergency plan, which identified and described the emergency response organization;-and the emergency response organization roster, which identified individual positions and personnel assigned to each position. The inspectors observed that there were a number of inconsistencies.
The emergency response organization roster included numerous individuals who were not idontified or discussed in the emergency plan. The roster included engineenng team members, an operations support center communicator, emergency planning advisors, status board keepers, and administrative support personnel who were not identified or described in the emergency plan Some positions were identified on organization charts, but were not described (functions, responsibilities, etc.).
Regarding th_e engineering team, the emergency plan identified that there was a team but did not specify team composition (positions, numhar of individuals, expertise, etc.). Only one position in the operations support center was described (oporations support center manager). Additional personnel were identified on the operctions support center emergency organization chart (Figure 1.4) but were not described. The actual emergency response organization roster, which is not submitted to the NRC, included a communicator position.
After reviewing the em6rgency plan and roster, the inspectors determined that the licensee could circumvent the 10 CFR 50.54(q) review process by maintaining a roster with positions which were not described in the emergency plan. Positions could be deleted without determining whether the deletions decreased the effectiveness of the emergency plan. Moreover, the licensea stated that the emergency plan could not be implemented using just the individuals described in the emergency plan.
Pertinent to this issue, the Office of Nuclear Reactor Regulation (NRR) was in the process of reviewing Revision 25 to the Comanche Peak Emergency Plan. Revision 25 was transmitted to NRR for review on January 31,1997, via Task interf ace t
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5-Agreement 97TIA001. Since the revision included staffing changes, the inspectors briefly discussed the matter with NRR, prior to the exit meeting, to determine if there were overlapping areas.
Based on those initial discussions, this matter was identified as a potential violation of 10 CFR 50.54(q) during the July 25,1997, exit meeting. Regulations in 10 CFR 50.54(q) require licensco's to follow and maintain in effect emergency plans which meet the standards in 50.47(b) and the requirements of Appendix E. Appendix E.IV.A requires that emergency plans describe the organization for coping with radiological emergencies, including definition of authorities, responsibilities, and duties of individuals assigned to the emergency organization.
Additional discussions with NHR were held on August 6 and 7,1997, to discuss the extent of the linkage between the issue identified during the inspection and the ongoing NRR review. Due to the similarities, a decision was made to address the inspection issue as part of the NRR review. Accordingly, the description of the emergency response organization in the emergency plan is being identified as an unresolved item pending the outcome of NRC's review of Revision 25 to the site's emergency plan 150 445/9716-01; 50 446/9716-01).
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Conclusions An unresolved i'em was identified involving the description of the emergency response organization in the emergency plan.
P4 Staff Knowledge and Performance in Emergency Preparedness P4.1 Exercise Conduct and Scenario Description (82301 and 8230_Z1 The licensee conducted a full-scale, biennial emergency preparedness exercise beginning at 7:30 a.m. on July 30,1997. The exercise was conduaed to test major portions of the onsite (licensee) and offsite emergency response capabilities.
The liconsee activated its emergency response organization and all emergency response facilities. The Federal Emergency Management Agency evaluated the offsite response capabilities of the State of Texas and Hood and somerville counties. The Federal Emergency Management Agency willissue a separate report.
The scenario for the exercise was dynamically simulated using the licensee's control room simulator. The exercise focused on Unit 1. At the beginning of the exercise, Units 1 and 2 were operating at 100 percent power and all plant parameters were normal and stable.
Meteorological conditions initially identified the wind from the southwest at 5 miles per hour. There was no precipitation during the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The wind slowly shif ted to a more southerly direction (winds from south to north) during the exercis _
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At 7:45 a.m., an electrical fire was discovered in the service water intake structure resulting in the loss of Station Servico Water Pump 102. The fire lasted for approximately 15 20 minutos. An alert was declared due to a fire affecting operability of safety related equipment. Emergency response personnel were directed to staff the omorgency responso facilities.
At 9:05 a.m., Unit 1 Steam Generator 2 feedwater regulating valve failed closed resulting in a loss of steam generator level. When atoom Donerator levels approached the LOW LOW level trip setpoint, the operators manually tripped the reactor. The first operator used the switch on panel CBO 7; the switch did not function. The second opuwtor quickly actuated tho trip switch on panel CBO 10.
This led to a successful manual reactor trip.
During the reactor trip transient, throo control rods stuck (failed to fully insert into the core) and ono nod ejected from the reactor causing a loss of coolant accident.
increasing containment radiation lovels indicated fuel damage. A site area omergency was declared based upon plant conditions.
At 9:20 a.m., Station Service Water Pump 1-01 tripped due to a pump selrure.
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This resulted in a completo loss of station service water flow in Unit 1. Cross-connection with Unit 2 station service water was not possible because Valvo XSW-0000 was stuck shut. At 9:25 a.m., the Train A containment spray heat exchanger outlet valvo (1 HV 4776) did not open when containment spray actuated. Repair efforts were initiated to provide interim cooling for containment spray pumps and to return station service water to operation.
At 10:00 a.m., high pressure inside the Unit 1 containment resulted in a failure of the Unit 1 containment equipment batch seals. This initiated a radioactivity release directly to the environment and prompted escalation to a general emergency.
At 12:30 p.m., a fire started due to a phase short in the XST1 transformer. The fire brigado responded to extinguish the fire. While taking care of the fire, a fire brigade member exhibited symptoms of heat exhaustion and required medical attention.
The exerciso ended at approximately 1:30 p.m..
P4.2 Control Room a.
Inspection Scone (8230103.02)
The inspectors observed and ovaluated the control room simulator staff as they performed tasks in rosponse to the exerciso scenario conditions. These tasks included event detection and classification, analysis of plant conditions, offsite
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agency notifications, internal and external communications, and adherence to the emergency plan and procedures. The inspectors reviewed applicable emergency plan sections, emergency plan procedures, logs, checklists, and notification forms, b.
Qhstr.yalions and Findinns During the exercise, plant conditions were analyzed and evaluated in a timely manner The alert was promptly classified using the correct emergency action levels. The shif t manager discussed plant conditions with the technical support center and emergency operations f acility and discussed the need to escalate when conditions developed. The inspectors determined that identification and classification of emergency conditions was good.
Notifications to the state and local agencies were made within 5 minutes following the alert declaration. The NRC was notified immediately following notification to the state and local agencies. The responsibility to make notifications to offsite agencies was transferred from the control room to the technical support center prior to the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> post-declaration followup notification time limit. The inspectors determined that notifications to offsite agencies from the control room were timely and correct.
Formal control room briefings were infrequent and unstructured. Inspectors observed the following examples:
Several impromptu briefings were conducted immediately af ter the fire in the
service water structure was reported. However, some operators were unable to listen to the briefings because of ongoing plant conditions.
Information provided during briefings was not always complete or accurate.
- The alert declaration time was incorrect and emergency response f acility activation time and status were not discussed.
Briefings quickly broke down to individual discussions and did not have a
clear endpoint. Briefings appeared to end when participants returned to their assigned duties.
There were no briefings where everyone attended or listened the entire time.
- On certain occasions, telephone calls, radio conversations, and discussions between participants made it difficult to hear the ccotrol room supervisor.
Apart from the briefings, control room communications were effective. Control room personnel used three part" communications consistently throughout the exercise. Three part communications involve: (1)information communicated by provider 12)information restated by the receiver, and (3)information confirmed by the provider. Plant conditions and equipment status changes were promptly communicated to plant personnel. Examples included the announcement of the fire,
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8-reactor trip, syvi6m actuation, etc. On several occasions, the shift manager
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announced that radiological conditions within the plant were subject to change based on wyatem actuation. The inspectors determined that the process for making announcements to maintain worker awareness of plant conditions was well implemented.
The shift manager implemented 10 CFR 50.54(x) to override licensing conditions associated with plant security following the decision to evacuate the alternate access control point. The shift manager contacted the technical support center and the emergency operations facility to inform them of the decision and to remind them that a notification to the NRC was required. Af ter reviewing Procedure SEC 610
" Security Response During Personnel and Operatirig Emergencies," Revisiun 11, the inspectors determined that the licensee had properly implemented 10 CFR 50.54(x).
Good coordination was exercised between the technical support center and the control room staf fs to determine a safe maximum operating temperature for the bearings affected by the loss of station service water. The control room staff trended the data and made estimates of time remaining before exceeding applicable lirnits, The operators simulated connecting the fire protection system to the station service water system to provide cooling water to the containment spray oil coolers.
This action was performed in accordance with Procedure ABN 501, " Station Service Water System Malfunction," Revision 6. The licensee noted that the procedure provided a lineup sequence to connect fire protection but did not provide a method for reinitiating the normal station service water system lineup.
To compensate, an operator developed a valve lineup sequence to disconnect the fire protection system and restore the normal station service water system lineup.
The operator determined the proper sequence, by reversing the lineup procedure, and obtained verbal concurrence from the shif t manager. The control room operator contacted a senior reactor operator in the operations support center and requested that the lineup be verified.
The control room operator transmitted a copy of the lineup, by facsimile, to the operations support center, but the senior reactor operator did not receive the transmitted copy. The control room operator started to read the lineup sequence to the senior reactor operator over the telephone. When the control room operator was reading Step 5 of 6, an announcement was made that fire protection had been disconnected from the service water system and that normallineup had been restored.
The inspectors reviewed the lineup to connect fire protection to the station service water system and compared it to the sequence used to disconnect fire protection.
-The inspectors noted that a sequence of 12 3 4 5 6 was used to connect fire protection and 6 5 4-1 2 3 was used to disconnect fire protection. Therefore, it
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was not a simple reversal of procedure steps. The inspectors reviewed the system piping diagram and determined that the sequence used to disconnect fire protection was acceptable.
The inspectors initially determinert that the process was an improper procedure change. Section 6.4 of Procedure STA 205, " Changes to Procedures," Revision 17, provided guidance as follows: "If the change does not change the intent of the procedure and the change must be implemented immediately, interim approval may be obtained as follows and shall be documented in Section 11 of Form STA 2051."
The inspectors observed that the steps contained in Section 6.4 were not completed, in response, the licensee provided a copy of Procedure ODA 407, " Guideline on Use of Procedures," Revision 6. This procedure provided additional guidance associated with use of abnormal procedures. Attachment 8.B. Rule 16 stated:
Occasions may exist where ections may be taken that deviate from the procedural requirements. Under these circumstances, the following requirements should be met:
All deviations shall be approved by an SRO isenior reactor
operatori licensed individual.
Deviations shall be logged in the unit log of the affected unit.
- Management should be notified as soon as practical.
- If possible prior to performing the action, the deviation
flowchart should be reviewed to ensure appropriate actions are taken.
The inspectors reviewed the logs and observed that there was no notation associated with the deviation. The licensee stated that this was an artificiality of the exercise and that, during an actual event, the logs would be reconstructed at the end of the shift and a notation would have been made. Further, the licensee pointed out that Section 6.4.A of Procedure ODA 407 stated: "During an emergency or abnormal condition which presents a hazard to personnel or equipment or which could result in a release of radioactivity to the environment, operators may take any action deemed necessary to protect personnel or equipment.
The inspectors discussed this procedure section with the licensee to determine how thic differed from a 10 CFR Part 50.54(x) situation. The licensee stated that 10 CFR 50.54(x) applied to license conditions and technical specifications and that this guidance involved lower levelissues. The licensee stated that it would review this guidance to determine if it was appropriate. The inspectors determined that this
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10-response was satisf actory. Considering the existing procedural guidance, the
inspectors determined that the operator's actions during the exercise did not constitute an improper procedure change.
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Conclusigna r
r Overall, control room staff's performance was good. Offsite agency notifications were timely. Onsite announcements regarding equipment operation and radiological conditions were proactive and timely. Analysis of plant conditions was very good
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and personnel demonstrated a questioning attitude throughout the exercise. Facility briefings were infrequent and unstructured. The control room staff demonstrated good coordination and communication with the technical support center, operations support center, and emergency operations facility.
P4.3 Technical Suonort Center a.
inspection Scope 182301-03.03)
The inspectors observed and evaluated the technical support center staff as they performed tasks necessary for response to exercise scenario conditions. These tasks included staffing and activation, accident assessment end event classification, NRC notifications, personnel accountability, f acility management and control, onsite protective action decisions and implementation, internal and external communications, assistance and support to the control room, and prioritization of mitigating actions. The inspectors reviewed applicable emergency plan sections, emergency plan procedures, position assistance documents, and logs, b.
Observations and Findinna The technical support center was promptly staffed an.1 activated after the alert classification. During initial activation, technical support center staff correctly used the card reader for accountability purposes as required by Procedure EPP-314
" Evacuation and Accountability," Revision 6. In addition, technical support center staff properly signed in and out on the technical support center staffing board to maintain continuous accountability. The iodine monitor and area radiation monitor were properly actuated in eccordance with Procedure EPP 204, "Activetion and Operation of the Technical Support Center," Revision 12.
Upon activation, the emergency coordinator in the technical support center assumed the responsibility to chssify emergency events from the control room. The technical support center manager, acting as the emergency coordinator, promptly and correctly classified the site area and general emergencies. The technical support center staff wurked well as a team to help determine event classifications.
Communications within the technical support center were mixed. Briefings and announcements were usually clear; however, at times, noise levels and equipment
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11-problems degraded the effectiveness of communications. Inspectors observed the following examples of degraded communications:
On occasion, briefings continued while the all page announcements were
being conducted. As a result, some participants had to ask for information to be repaated.
At times, the operations coordinator could not clearly hear the control room
staff while using the headset. Midway through the exercise, the headset stopped working. The individual replaced the batteries, but the volume remained low.
There was confusion concerning the destination of the simulated injured
person. The initial report was that the individual was transported to a hospital in Stephenville. A later report indicated the individual was transported to Glen Rose.
The onsite radiological assesstnent coordinator could not immediately get the
weather service recording. The unit was not properly connected to the outlet.
The technical support center manager exercised very good comrnand and control.
With the above exceptions, briefings were clear, thorough, concise, and frequent.
Briefings were consistently announced several minutes prior to the beginning to allow center personnel an opportunity to prepare. Each technical support center coordinator participated in the briefings. Priorities were revised as nt cessary. The technical support center manager sought input from all center coordinators in setting and changing priorities and discussed these changes at each briefing.
The technical support center manager and coordinators worked well as a team to determino mitigating actions. Discussions were open; coordinators assertively questioned certain actions and offered alternatives. Recommendations were creative and diverse, and good conse.rvativo decision making was observed, inspectors observed the following examples of conservativo decision making and effective teamwork:
The decision to direct fire hoses on the containment leak to reduce offsite
radiological consequences (primarily iodine doses) was consideied good, although actual dose reductions were only theorized.
Open discussions between the center manager and coordinators led to the
decision to continue direct flow to core cooling rather than containment spray.
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12-Tho onsite radiological assessment coordinator frequently informed the
technical support manager of changing wind conditions, offsite evacuation iones, and areas of potential high airborne contamination.
The impact to security was properly considered. A decision was made to
evacuate the alternato access point as a result of the radiological release, c.
C99qhtsigan Overall, the technical support center staff's performance was good. The center was promptly activated and emergency classifications were correct and timely The technical support center manager exhibited very good command and control.
Briefings were frequent, clear, and concise with good participation by center coordinators. The staff worked well as a toom to identify actions necessary to cope with scenario events. Nolce levels and equipment problems degraded some communications.
P4.4 QRgrations Spocort Center a.
[ningslion Scone (8230103.0.5J The inspectors observed and evaluated the operations support center staff as they performed tasks in response to the exeicise scenario conditions. These tasks included functional staffing and inplant emergency response team dispatch and coordination in support of control room and technical support conter requests. The inspectors rnviewed applicable emergency plan sections, emergency plan procedures, position assistance documents, logs, checklists, and forms.
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QDservations and Findinas The operations support center was promptly activated af ter the alert classification.
The operations support center manager demonstrated effective command and control throughout the exercise. Tasks were appropriately controlled according to the priority status board, thereby expediting the recovery process.
The use of the f acility " prompt" team to staff the emergency response and damage control teams was noted as a strength. The " prompt" team consisted of a group of mechanical, electrical, instrumentation and controls craftsmen, and system engineers that the f acility used for immediate equipment repair needs. As a result, the " prompt" team was extremely efficient in assessing damage and repair activities. This efficient teamwork allowed the operations support center to dispatch approximately 10 emergency response and damage control teams in response to requests from the control room and the technical support center.
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13-Inspectors observed that operations support conter habitability controls were not fully consistent with conter position assistance documents (checklists used to satisfy ernergency plan procedure requirements). Sectinn 4.8.1 of Procedure EPP.
205, " Activation and Operation of the Operations Support Center (OSC),"
Hovision 11, stated. iri part, that * habitability of the operations support center shall be continuously monitored using an area radiation monitor and a portable contmucus radiciodine monitor." The operations support center radiation protection supervisor's position assistance document required that a portable continuous iodine monitor and a Model 300 area radiation monitor be set up adjacent to each other in the 810 hallway and a Merlin Gerin electronic alerrning personnel dosimetry device be worn by the operations support conter radiation protection supervisor.
During the exercise, the inspectors noted that an area radiation monitor was not placed in the hallway When questioned about the monitor, the licensee stated that the operations support center radiation protection supervisor wore the Merlin Gerin electronic alarming dosimetry device in lieu of placing the Model 300 area radiation monitor in the 810 hallway. The inspectors initially determined that warnings associated with changing radiological conditions could have been missed or delayed, since there were no controls to prevent the supervisor from leaving the Center.
On August 5,1997, the licensee provided additional information concerning this matter. The licensee stated that a radiation work permit was used by the operations support center radiation protection supervisor to acquire the electronic alarming personnel dosimetry device. The radiation work permit described the job as, "Ernergency plan exposure monitoring task." The purpose of the task was to
" establish alarm setpoints for the electronic dosimeter alarms for personnel assigned to perform representative exposure monitoring in the technical support center, operations support center, and control room."
The licensee also informed the inspectors that, in addition to the davice worn by the operations support center radiation protection supervisor, the supervisor instructed another individual to sign in on the task and wear the same type of device (so there would be more then one in the center), Since there were no observed periods when the assi ned individuals were not present to monitor conter habitability, the
inspectors could not conclude that lapses in continuous monitoring occurred.
The inspectors evaluated all of the information concerning this matter and concluded that the issue was not an exercise weakness because reasonable habitability controls were established in the operations support center, even though the position assistance document was not fully followed. However, f ailure to fully follow the position assistance document was considered inappropriate. The licensee acknowledged this point during its management critique on July 25,1997, and during the August 5,1997, telephone discussions,
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14-Emergency response and damage control team formation, dispatch, and coordination activities were generally effective. Good team briefings were conducted poor to team dispatch. Briefings sufficiently covered the scope of tile job to be performed. Teams were well prepared to handle their assigned tasks.
Proper tools and supporting documentation were brought to the job site minimizing the time of repair activities Good ALARA practices were observed by one team assigned to perform a containment air sample using the post accident sampling system. A radiation protection technician conducted a radiation survey of the job site to identify low dose waiting areas for team members.
The fire brigado demonstrated proficiency in fighting fires and responding to injured personnel. The scenario included two simulated fires, both of which required fire brigade response. Fire brigade members properly donned fire fighting clothing and self contained breathing apparatus. The fire brigado leader demonstrated very good command and control of the fire brigade team; especially when one fire brigade member, assigned to hold the fire hose nozzle, simulated cardiac arrest (planned by the scenario developers). The fire brigade leader immediately reassigned personnel to replace the individual and provide first aid.
Radiation protection coverage was not sufficient for those teams performing tasks outside the power block. Inspectors observed the following examples:
One emergency repair and damage control team was assigned immediate
entry status to spray water on the radiological plume escaping from a failed seal m the containment equipment hatch. This team was not dispatched with continuous radiation protection coverage as required by Section 3.3 of Procedure EPP 116. " Emergency Repair & Damage Control and immediate Entries," Revision 6. The team, which included the fire brigade anu one craf t person, arrived at the scene and began to combat the emergency prior to radiation protection personnel fully assessing the radiological conditions and determining proper radiological controls and protection. Radiological conditions were initially provided to the team at the scene. Intermittent coverage was provided later by a roving onsite radiological survey team.
Following indications of a radiological release to the environment, Team 97-
08 was dispatched to perform work in the service water intake structure without assigned radiation protection personnel as required by Section 4.2.1 of Procedure EPP 116. Inspectors also noted that the team's emergency work permit did not specify the type of radiation protection deemed necessary to protect the team from the simulated radiological hazards. The radiation work permit included a section to document the decision to provide continuous or intermittent radiation protection coverage to dispatched teams, but the section was not completed.
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15-The f ailure to provide sufficient radiation protection coverage for emergency response tcams could ond6nger p6isorinst and degrado smorgency responce efforts.
Accordingly, the issue was identified as an exercise weakness (50 445/9716 02; 50 440/g710-02),
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Conclusigns Overall, the operations support conter staff's performance was satisf actory. The use of the " prompt" team to staff the emergency response and damage control teams expedited team dispatch, damage assessments, and corrective measures.
Teams were organized and dispatched in proper order to effectively handle repair priorities. An exercise weakness was identified for failure to provide proper radiation protection coverage for tenins performing tasks outside the power blocks as required by procedures. One other instance of inappropriate implementation of a procedure was also noted.
P4.5 Emernency Opfrations Facility a.
inspection SqqpsE230103.04)
The inspectors observed the emergency operations facility's staff as they performed tasks in response to the exercise. These tasks included f acility activation, notification of state and local response agencies, development and issuance of protective action recommendations, dose assessment and coordination of field monitoring teams, and direct interactions with offsite agency response personnel.
The inspectors reviewed applicable emergency plan sections, emergency plan procedures, position assistance documents, logs, forms, and dose projections, b,
Observations and Findings The emergency operations f acility was promptly staffed and activated following the 7:53 a.m. alert declaration. Upon arrival, f acility personnel readicd the f acility for operation. Personnel obtained position assistance documents, established communication l inks, relocated copiers and f acsimile machines, determined f acility habitability, and synchronized the f acility clock to the plant computer. The facility was declared activated at 8:27 a.m.
' Although the emergency coordinator duties were quickly transferred from the technical support center to the emergency operations facility at 8:40 a.m., the transfer was not clearly conducted and could have led to confusion about who would complete required emergency response tasks. The emergency operations facility manager informed the technical support center manager that responsibilities would be transferred after the capability to perform offsite agency notifications was verified and reported back by telephone. Notification capabilities were verified, but the final telephone call did not occur before the emergency operations f acility announced the assumption of emergency coordinator dutie. - _ _-
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-16-The emergency operations f acility manager demonstrated of fective command and control techniques. Briefings were frequent and included input from operations, dose assessment, logistical support, security, and offsite agency personnel. Facility prionties were discussed and revised as necessary. Facility personnel worked well as a team to fulfill f acility responsibilities.
Following the transfer of emergency coordinator duties, the emergency operations facility was responsible for ofitite agency notifications. The emergency operations f acility issued 11 notification message forms, including the site area and general emergencies and changes in plant status, onsite response activities, and protective action recommendations. The notifications were correct and performed within required time limits.
However, potentially confusing information was provided to offsite agencies on notification message Forms 412. The event description explanation was not consistent with other information on the form. The explanation indicated there was a reactor coolant system leak and fuel damage but did not include information about the loss of containment. Other torm sections indicated there was a containment breach and a release. The descriptive explanation was automatically determined by the computer using the initiating event boxes checked on the form. The licensee acknowledged the discrepancy.
Dose assessment and field team control activities were effectively used to develop and confirm offsite protective action recommendaticns. Numerous dose projections were calculated to estimate the offsite impact using existing and "what if" conditions. Changing meteorological and plant conditions were anticipated and f actored into dose projections. As a result, f acility management appropriately upgraded its protective action recommendations on several occasions. Changes were quickly communicated to offsite authorities.
One area of emergency operations facility performance was identified as particularly strong. Facility personnel established a mechanism for emergency response personnel to obtain information concerning the location of f amily members (i.e., had they arrived at a relocation center). Although concern for family members could distract emergency responders in a real emergency, such personal consideration is rarely recognhed during exercises.
Status boards were generally well maintained during the exercise. The radiological status board keeper used an effective method to convey information; an update time was noted in each section, so f acility personnel could quickly determine whether information was current. Although the operations status board was quickly updated, changing plant conditions were not always immediately communicated to f acility management. For example, information concerning the stuck and ejected
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control rods was entered on the status board but not immediately brought to the attention of the emergency coordinator. Toward the end of the exercise, the plumo location /wmd direction board was not consistently maintained. Several wind shif ts occurred dunng the last 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, c.
Gemgl@pDy Overall the emergency operation's f acility staff's performance was generally very good. The transfer of emergency coordinator duties was not clearly accomplished.
Personnel worked well as a team to accomplish f acility responsibilities.
Comprehensive and frequent briefings were conducted to keep f acility members informed of current conditions and to focus attention on f acility priorities. Offsito agency notifications and protectivo action recommendation development were correct and timely. Some notification message forrns contained minor internal inconsistencies. Changing plant conditions and worst caso scenarios were appropriately anticipated and f actored into dose projections. Field teams were offectively controlled to confirm doso projections and determino actual offsite
impac t.
P4.0 Semio and Exetclio Control e,
innatilon ScoD2.JR2301 and 821Q21 The inspectors evaluated tho exorcise to assess the challenge and realism of the scenario and exerciso control.
b.
Qb1Divations and findinna The inspectors determined that the exerciso scenario was sufficiently challenging to test onsito emergency response capabilities. The following aspects of exercise
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conduct and control detracted from the realism and training value of the exercise and were considered areas for improvement:
Several unanticipated simulator glitches occurreo. Although the glitches
were quickly addressed by the simulator staff, they of ten required cor, troller interaction to assure players that it was a simulator problem. Examples included the inability to reset containment spray isolation and actuation of the startup transformer fire alarm.
The gaitronics speaker volume was very low in the control room / simulator.
- With the high noise level that developed in the lacility, gaitronics announcements were not always heard.
The technical support center staff experienced difficulty in initiating the
emergency response f acility computers due to unavailability of plant data from the simulator. The problem was quickly corrected by shutting down
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+ 18-the computers, reinitiating the connection with the simulator, and tebooting the computers. initially there wufe sumu minor delhys in information flow.
Controllers allowed exerciso participants to oversimulato radiological ropes
and postings at each end of Hallway 810. Onco established, the ropes and postings were moved aside, allowing exerciso participants to bypass posting requirements. Controllets did not requito exercise participants to act as if the barriors were present, c.
Conghtgig,nji The scenario was sufficiently challenging to test onsite responso capabilities.
Exorciso control was sufficient. Simulator glitches required controller interaction, gaitronics announcements were not always heard in the simulator, and some radiation protection responses were oversimulated.
P4.7 Lkemnn.Ec1LClithmn a.
IMDection Scong323DhQ3.13)
The inspectors observed and evaluated the licensee's post exerciso f acility critiques and the formal management critique on July 25,1997, to determine whether the process would identify and characterize wenn or deficient areas in nood of corrective action, b.
Observations and Findinas Post exerciso critiques in all f acilities were thorough, open, and self critical. With the exception of the operations support center, post exerciso critiques appropriately included input from paiticipants, controllers, and evaluaters. Exercise participants in all f acilities identified good suggestions for improvement.
During the July 25,1997, management critique, the Manager, Emergency Planning, presented a compilation of comments from participants, controllers, and evaluators.
The comments included 1 weakness for f ailure to monitor and control emergency team exposures and 11 improvement items. During the discussion, a decision was made to elevate one element of an improvement item to a weakness. The second weakness involved the f ailure to set up an area radiation monitor to monitor habitability in the operations support center as directed by a position assistance document. The NRC inspection team identified both issues (see Section P4.4 above).
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Cpnclusions Post exercise critiques were thorough, open, and self critical; good suggestions for improvernent were identified. The management critique was detailed, informative, open, and self critical. Management elevated one improvement item to a weakness.
Overall, the critique process effectively identified weaknesses and improvement items.
P8 Miscellaneous Emergency Preparedness issues (92904)
[C_lpled) lagnpStlon Followun item 50 44_5:440/Q524-01: Exercise weakness for f ailur.9 of the operations support center to imolement repair oriorities established)2Y 1!)t_lechnical sW2 cort centeL The operations support center manager effectively controlled emergency response and damage control team dispatch using priorities established by the technical support conter. The operations support center manager reviewed the priority board frequently and, following major changes to priorities, informed the operations support center staff by holding a short briefing. These briefinga focused on the current priorities and corrective actions taken, er needed to be taken, to deal with priority tasks. As mentioned in Section P4.4 above, use of the " prompt" team was considered a strength, because it provided rapid emergency response team formation and dispatch. As a result, tasks on the priority list were expeditiously corrected.
V. Management Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on July 25,1997. The licensee acknowledged the facts presented. No proprietary information was identified. On August 5, 1997, Mr. Norman Hood provided additional information concerning the inspection findings. On August 7,1997, Mr. Connie Wilkerson was informed that the issue involving habitability controls in the operations support center was no longer characterized as an exercise weakness and that the issue involving the description of the emergency response organization in the emergency plan was characterized as an unresolved item rather than a violatio (
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AIIACHMERI
$UPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED jdteDittt C. Terry, Group Vice President, Nuclear D. Barham, Emergency Planner G. Bell, Senior Nuclear Specialist M. Blevins, Plant Manager D. Buschbaum, Manager, Technical Compliance J. Curtis, Manager, Radiation Protection J. Ellard, Emergency Planner D. Fuller, Emergency Planner W. Guidemond, Manager, Shif t Operations N. Hood, manager, Emergency Planning T. Hope, Manager, Regulatory Compliance R. Kidwell, Emergency Planner 8, Lancaster, Manager, Plant Support D Moore, Manager, Operations W. Nix, Emergency Planner T. Robison, Emergency Planner R, Walker, Manager, Regulatory Af fairs C. Wilkerson, Senior Engineer, Regulatory Affairs NRC H. Freeman, Resident inspector J, Tapia, Chief, Projectc Branch G. Werner, Senior Resident inspector L. Yandet!, Technical Support LIST OF INSPECTION PROCEDURES USED IP 82301 Evaluation of Exercises at Power Reactors le 82302 Review of Exercise Objectives and Scenarios for Power Reactors IP 82701 Operational Status of the Emergency Preparedness Program IP 92904 Followup Plant Support LIST OF ITEMS OPENED QPanc.d 50 445;446/9716 01 URi Unresolved hem involving the description of the emergency response organization in the emergency plan (Section P3)
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50 445:440/9710 02 IFl Exercise weakness Failure to provide sufficient radiation protection coverage for emergency teams (Section P4.4)
C191 tid 50 445:440/0524-01 17.
Exercise weakness - Failure of the operations support
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center to implement repair priorition established by the technical support conter ( Section P8)
LIST OF DOCUMENTS REVIEWED Emernency Plan Proraduttti EPP 100 Duties and Responsibilities of the Emergency Coordinator /Rocovery Manager Revision 11 EPP 112 Duties of Control Room Personnel Dunna Emergencies Revision 8 EPP 110 Emergency Repair & Damage Control and immediate Entries Revision 0 EPP 201 Assessment of Emergency Action Levels, Emergency Classification and Plan Activation Revision 10
' EPP 203 Notifications Revson 13 EPP 204 Activation and Operation of the Technical Support Center Revision 12 EPP 205 Activation and Operation of the Operations Support Center Revision 11 EPP 305 Emergency Exposure Guidelines and Personnel Dosimetry Revision 11 EPP-309 Onsitelln Plant Radiological Surveys and Offsite Radiological Monitoring Revision 10 EPP-314 Evacuation and Accountability Revision 0
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Q1hti Proceduras ABN 501 Station Service Water System Malfunction Revision 6 f
ODA 407 Guideline on Use of Procedures Revision 6 SEC 610 Security Response During Personnel and Operating Revision 11
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Emergencies STA 205 Changes to Procedures Revision 17 Q1her Documents
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Comanche Peak Steam Electric Station Emergency Plan, Revision 25
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