ML14178A166
| ML14178A166 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 12/02/1991 |
| From: | Boland A, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14178A165 | List: |
| References | |
| 50-261-91-26, NUDOCS 9112120064 | |
| Download: ML14178A166 (30) | |
See also: IR 05000261/1991026
Text
pH REG&
UNITED STATES
'
NUCLEAR REGULATORY COMMISSION
.
fREGION
II
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30323
Report Nos.:
50-261/91-26
Licensee:
Carolina Power and Light Company
P. 0. Box 1551
Raleigh, NC 27602
Docket Nos.:
50-261
License Nos.:
Facility Name:
H. B. Robinson
Inspection Conducted:
November 18-22, 1991
Inspector:
_____________________
/4/4Cz /q/
A. T. Boland
Datfed Si'gned
Accompanying Personnel:
G. Arthur (Sonalysts, Inc.)
E. Fox
R. Haag
L. Garner
K. Clar d-/
W. H. Rankin, Chief
Dated Signed
Emergency Preparedness Section
Radiological Protection and Emergency
Preparedness Branch
Division of Radiation Safety and Safeguards
SUMMARY
Scope:
This routine, announced inspection included observation and
evaluation of the annual emergency preparedness exercise.
Emergency response activities were selectively observed
including:
the Exercise Control Room (ECR); the Technical
Support Center (TSC); the Operational Support Center (OSC); the
Emergency Operations Facility (EOF); the Joint Information Center
(JIC); the onsite Fire Brigade; and damage control teams. The
inspection also included a review of the exercise objectives and
scenario, as well as observation of the licensee's post-exercise
critique activities. The exercise was a partial-scale exercise
with limited participation by the State of South Carolina and
full participation by local emergency response agencies. The
exercise was conducted on November 20, 1991, between the hours of
.
8:30 a.m. and 1:00 p.m.
9112120064 911103
ADOCK 05000261
G
2
Results:
In the areas inspected, one potential repeat violation and four
exercise weaknesses were identified. The violation addressed the
failure to correct weaknesses from the 1989 and 1990 emergency
exercises as well as a violation resulting from the September 11,
1990, toxic gas release event which also cited inadequate
corrective actions for the failure to properly classify emergency
events (Paragraph 5).
The four exercise weaknesses were
identified as follows:
Failure to provide complete information
regarding the simulated emergency to State and local governments
(Paragraph 6); Failure to demonstrate the formulation of
protective action recommendations (Paragraph 10); Failure to
demonstrate adequate assessment of radiological releases
(Paragraph 9); and Failure to demonstrate the ability to conduct
damage control activities in a timely manner (Paragraph 8.c).
Noted exercise strengths included an effective and thorough self
critique, excellent command and control exhibited by the
Emergency Response Manager including the interface with the
State, thorough management turnovers between the ECR/TSC and the
TSC/EOF, efficient setup and staffing of the EOF, implementation
of good health physics practices related to the PORV damage
control team, and effective route planning for emergency
personnel moving between facilities.
REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- R. Barnett, Manager, Outages and Modifications
- R. Chambers, Plant General Manager
- W. Christensen, Supervisor, Environmental and Radiation
Control
- C. Dietz, Vice President, Robinson Nuclear Project
- D. Dixon, Manager, Control and Administration
- T. Dunn, Communications Specialist, Corporate Emergency
Preparedness (EP)
- J. Eaddy, Supervisor, Environmental and Radiological Control
- J. Farrar, Director, Energy Education
- W. Gainey, Manager, Plant Support
- M. Gann, Specialist, Emergency Preparedness
- A. Garrou, Project Specialist, Corporate EP
- R. Goodwin, Project Specialist, Corporate EP
- R. Indelicato, Manager, Corporate Emergency Preparedness
J. Kloosterman, Manager, Regulatory Compliance
- M. Morrow, Senior Specialist, Emergency Preparedness
- M. Page, Manager, Technical Support
- A. Padgett, Manager, Environmental and Radiation Control
- R. Smith, Manager, Maintenance
- D. Taylor, Manager, Materials and Contract Services
- L. Williams, Manager, Emergency Preparedness and Security
Other licensee employees contacted during this inspection
included engineers, operators, mechanics, security force
members, technicians, and administrative personnel.
Nuclear Regulatory Commission
- L. Garner, Senior Resident Inspector
- E. Fox, Senior Emergency Preparedness Inspector, NRR
2.
Exercise Scenario (82302)
The scenario for the emergency exercise was reviewed to
determine that provisions had been made to test an
integrated emergency response capability as well as the
basic elements existing within the licensee, State, and
local Emergency Plans and organizations as required by 10
CFR 50.47(b)(14), 10 CFR 50, Appendix E, Paragraph IV.F, and
the specific criteria in NUREG-0654,Section II.N.
The exercise scenario package including the exercise
objectives was provided to NRC approximately 45 days in
advance of the exercise and was discussed with licensee
representatives prior to the onsite exercise. The
2
inspector's review of the scenario prior to the exercise
revealed no significant technical inconsistencies. During
the exercise, the inspector noted appropriate interactions
between the controllers and players, and no prompting was
observed.
Although the scenario was considered acceptable, the
following items were noted and discussed with the licensee:
(1) Overall, the scenario was short in duration
(approximately 4.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />) and relatively non-complex with
respect to affected equipment and the scenario of events;
(2) A fifteen minute delay was factored into the scenario
during play due to the failure to declare the Alert; rather
than issuing the contingency message as provided for in the
scenario package. Subsequently, the inspector noted that
information, although limited, was apparently received in
the ECR based on the original scenario timeline; (3) The
General Emergency declaration was delayed for 15 minutes by
the controller in order to meet the original scenario
timeline. However, some dose assessment information
supporting the declaration had already been communicated to
the State. This discrepancy was observed to cause some
problems and confusion with the State; (4) The contingency
message issued for the PAR circumvented the licensee's
development of a second PAR. The scenario, even with the
dose assessment inaccuracies, would have supported the
upgraded PAR; and (5) The scenario did not adequately
support the use of the Motor Operated Valve (MOV) mockup.
The problems cited in this paragraph appeared to detract
from the exercise and in some instances, may have
contributed to the performance weaknesses noted elsewhere in
this report. The inspector informed the licensee that this
issue would be tracked as an Inspector Followup Item (IFI).
IFI 50-261/91-26-01:
Improve exercise scenario control and
coordination including the length and complexity.
The inspector noted that the licensee did not use the
simulator for the exercise, instead; the ECR was established
and paper messages were used to distribute plant parameters.
The inspector discussed the positive training aspects
associated with the simulator and encouraged its use in the
future.
The attachment to this report documents the licensee's
exercise objectives and presents a narrative summary of the
scenario timeline.
No violations or deviations were identified.
3
3.
Onsite Emergency Organization (82301)
This area was observed to determine that primary
responsibilities for emergency response by the licensee had
been specifically established and that adequate staff was
available to respond to an emergency as required by 10 CFR
50.47(b)(1), 10 CFR 50.47 (b)(2), 10 CFR 50, Appendix E,
Paragraph IV.A, and the specific criteria in NUREG-0654,
Section II.A.
Through a review of the licensee's Emergency Plan and
Implementing Procedures, the inspector determined that the
initial onsite emergency organization was adequately defined
and that primary and alternate assignments for the positions
in the augmented emergency organization were clearly
designated. During the exercise the inspector observed that
staff members were available to fill key functional
positions within the initial onsite emergency organization.
Augmentation of the initial organization was accomplished
through the mobilization of additional day shift personnel.
During the course of the exercise, facility managers
discussed and simulated preparations for long term staffing;
however, because of the scenario scope and objectives,
continuous staffing of the emergency response facilitates
was not required. Minor problems associated with the EOF
staffing plan were identified by the licensee's critique
process; however, staffing arrangements for the other
facilities appeared satisfactory. The inspector noted that
this process was implemented effectively particularly in the
OSC where long-term staffing considerations were discussed
very early on in the scenario timeline.
The inspector discussed with licensee representatives the
staffing for the position of the Radiological Control
Manager in the EOF. The licensee stated that this position
as well as associated support positions are staffed using
personnel from the Corporate Office in Raleigh. Until
arrival of the Corporate staff, onsite personnel fill the
role of Radiological Control Manager in order to meet EOF
activation requirements; however, the dose assessment
function remains a responsibility of the TSC until EOF
staffing from the Corporate Office is complete. The Raleigh
personnel for this exercise were pre-staged in Hartsville;
therefore, their actual response time was not tested. The
inspector observed that the dose assessment function was
fully transferred from the TSC at 11:43 a.m., approximately
49 minutes after official EOF activation. The inspector
concluded that this staffing process was conducted in
accordance with the licensee's Emergency Plan.
4
The inspector also observed the participation of
"assistants" to the Emergency Response Manager (ERM) and the
Site Emergency Coordinator (SEC) in the exercise, although
these positions are not specifically delineated in the
Emergency Plan. The positions were staffed by a qualified
ERM and SEC, and served to support the facility managers in
the performance of their duties, including assumption of the
manager positions when the primary ERM or SEC was absent
from the facility. The inspector observed that the
integration of these personnel into the response
organization during the exercise was effective, and no
concerns were noted.
The inspector noted activation, staffing, and operation of
the emergency organization in the TSC, OSC, EOF, and JIC.
At each response facility the required staffing and
assignment of responsibility was consistent with the
licensee's approved Emergency Plan and Implementing
Procedures.
No violations or deviations were identified.
4.
Emergency Response Support and Resources (82301)
This area was observed to determine whether arrangements for
requesting and effectively using assistance resources were
made, that arrangements to accommodate State and local staff
at the EOF were made, and whether other organizations
capable of augmenting the planned response were identified
as specified by 10 CFR 50.47(b)(3), Paragraph IV.A of
Appendix E to 10 CFR Part 50, and the guidance promulgated
in Section II.C of NUREG-0654.
The inspector confirmed that the licensee had made adequate
provisions in the Emergency Plan for interfacing with
Federal and State response organizations. During the
exercise, activities related to the Federal interface were
not observed beyond notification; however, functionally the
licensee appeared prepared for an onscene response. During
observation of activities in the EOF, the inspector noted
the licensee's awareness of the Federal Radiological
Emergency Response Plan and that this interface was factored
into response discussions. Licensee involvement and contact
with State and county organizations occurred in accordance
with applicable Emergency Plan procedures. Although the
State of South Carolina did not send a liaison to the EOF
for this exercise, adequate provisions have been made for
accommodating State responders in the Room 132 of the EOF.
Assistance resources from offsite support agencies such as
fire, hospital, and ambulance services were not observed
5
during this exercise; however, the inspector noted that
appropriate provisions existed in the Emergency Plan and
procedures for acquiring these resources if needed.
No violations or deviations were identified.
5.
Emergency Classification System (82301)
This area was observed to assure that a standard emergency
classification and action level scheme was in use by the
nuclear facility licensee pursuant to 10 CFR 50.47(b)(4),
Paragraph IV.C of Appendix E to 10 CFR 50, specific guidance
promulgated in Section II.D of NUREG-0654, and guidance
recommended in NRC Information Notice 83-28.
The inspector verified that Plant Emergency Procedure (PEP)
101, Initial Emergency Actions, Revision 3, dated January
18, 1991, had been established to support the emergency
classification process. The classification guidance, in the
form of a logic flowchart, appeared adequate and contained
the elements required by NUREG-0654.
With the exception of the initial classification of the
fire, emergency declarations were made appropriately by
decisionmakers based on the information available to them.
The Alert was declared by the Shift Supervisor (SS) at 9:26
a.m. based on primary to secondary leakage greater than 50
gallons per minute (gpm).
The Site Area Emergency was
declared by the SEC at 10:38 a.m. based on a primary to
secondary leakage greater than 50 gpm coincident with a
stuck open power operated relief valve (PORV).
The General
Emergency was initially declared by the SEC at 11:19 a.m.
based on a projected thyroid dose of 19 Rem, although this
information was incorrect as discussed in Paragraph 9.
The initiating event for the scenario was a fire in the
Component Cooling Water (CCW) Pump Room. As contemplated by
the scenario developers, a declaration of an Alert was
expected for the simulated event based on the EAL, Fire has
potential to affect safety equipment. However, the SS
declared a Notification of Unusual Event utilizing the EAL,
Fire lasting greater than 10 minutes.
Upon initiation of the fire at 08:46 a.m., the ECR staff
recognized that the "A" CCW Pump and "A" Charging Pump were
not safety related and surveyed the control boards for
indicators of damage to safety related equipment. When
damage to such equipment was not confirmed, the NOUE was
declared. The inspector noted that the classification
assessment process appeared to be inappropriate in that the
evaluation was based on the lack of observable damage rather
0
than the potential for damage. The inspector further noted,
6
that when the NOUE was declared, the fire had not been
extinguished or fully characterized by the ECR staff;
therefore, the true magnitude or potential to affect the
nearby "B" and "C" CCW pumps or the cabling directly above
was not fully known. The ECR staff was not observed to
request a local damage assessment until approximately 6
minutes after extinguishing the fire (12 minutes after NOUE
declaration).
The inspector discussed with licensee representatives in
detail the circumstances involved with the missed
classification. The licensee stated that the quick response
by the fire brigade and an apparent interpretation error by
the ECR staff indicating that the "Fire was on the A CCW
Pump" rather than "in the area of the A CCW Pump" may have
contributed to the misclassification. However, the intent
of the EAL, Fire has potential to affect safety equipment,
does not require actual damage to equipment, and due to the
close proximity of safety related equipment to the simulated
fire, the EAL was clearly satisfied.
In addition, the inspector reviewed the guidance available
to the SS in making classification decisions. Operations
Management Manual Procedure (OMM)-031, Revision 3, dated
September 13, 1991, provides interpretations for emergency
classification. Although this procedure does not provide
explanatory guidance for classification of fires at the
Alert level, the inspector noted that Site Emergency
Coordinator Training Module, EP-LP-02, stated that "If the
fire is in the same fire zone (room) as a safety related
component, then it has the potential to affect the
equipment" [unless the fire is determined to be incipient].
The inspector noted that the interpretation presented in
this document was consistent with regulatory guidance, and
was consistent with the conditions postulated during the
exercise for the Alert condition.
Based on the above, the inspector informed licensee
representatives that the failure to identify the simulated
fire as an Alert emergency condition was an Exercise
Weakness. However, because exercise weaknesses related to
the failure to properly classify emergency events had been
identified during the 1989 (NOUE) and 1990 (General
Emergency) exercises, the inspector determined that the
failure to correct these weaknesses during the 1991 exercise
was an apparent violation of 10 CFR 50, Appendix E, Section
IV.F.5.
In addition, a similar violation for inadequate
corrective actions on a weakness identified during the 1989
exercise was cited for the September 11, 1990, toxic gas
release event resulting from the failure to properly
recognize an actual emergency Alert condition.
7
Repeat Violation 50-261/91-26-02:
Failure to demonstrate
adequate corrective action for previously identified
exercise weaknesses regarding the inability to properly
classify emergency events.
One violation was identified.
6.
Notifications Methods and Procedures (82301)
This area was observed to determine that procedures had been
established for notification by the licensee of State and
local response organizations and emergency personnel, and
the content of initial and followup messages to response
organizations had been established; and a means to provide
early notification to the population within the plume
exposure pathway had been established as required by 10 CFR
50.47(b)(5), 10 CFR 50, Appendix E, Paragraph IV.d, and the
specific criteria in NUREG-0654,Section II.E.
The inspector reviewed the licensee's procedures for
providing emergency information to Federal, State, and local
response organizations, and for alerting and mobilizing the
licensee's augmented emergency response organization. The
inspector noted that PEP-171, Emergency Communicator and
Staff, Revision 26, dated August 22, 1991, had been
established and appeared adequate to provide guidance to
personnel responsible for initial notification and
continuing communications.
During the exercise, the inspector observed that
notifications to the State and local governments as well as
the NRC were completed by ECR, TSC, and EOF personnel in a
timely manner. Notifications of the State and local
governments and NRC were initiated by the appropriate plant
personnel within 15 minutes and one hour, respectively,
following the declaration of each emergency class. In
addition, formal updates were completed at the required
frequency.
Although the notifications to the State and local
governments and NRC were observed to be timely, the
inspector noted that the information contained on the
emergency message forms which were ultimately transmitted to
these groups were often incomplete and did not always
contain the required information for offsite authorities.
Most significantly, after transmission of Message #4 at
10:46 a.m., the three following emergency messages to State
and local governments did not contain radiological release
information and dose projections, even though a release was
occurring. The licensee did not provide this information
until transmission of Message #8 at 12:51 p.m.,
approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 5 minutes later.
In addition,
8
Message #6, notifying the State and locals of the General
Emergency, described that the declaration was based on a
thyroid dose projection at the site boundary of 19 Rem but
did not provide the range of dose projections for the 10
mile EPZ nor the plant conditions which led to the emergency
upgrade. The plant conditions associated with the General
Emergency were never transmitted to the State and local
governments during the course of the exercise.
Other items associated with the emergency messages noted by
the inspector included:
Failure to provide transmission
time on NRC Messages #3, #4, and #5; Message #2 to the
State/locals contained conflicting information on reactor
shutdown status and did not contain time of airborne release
initiation; Message #7 to the State/locals did not contain
reactor status, PAR information or meteorological
information; and Message #8 transmitting dose projection
information did not provide any explanation or clarification
for the unusually high values.
Based on the observations discussed above, the licensee was
informed that the failure to demonstrate Exercise Objective
B.3 for providing emergency information to State and local
governments was an Exercise Weakness for which corrective
actions are required.
Exercise Weakness 50-261/91-26-03:
Failure to provide
complete information regarding the simulated emergency to
State and local governments, as required.
The inspector also observed the licensee's implementation of
notification of onsite and augmentation personnel utilizing
the plant public address system (PA) and personal pagers.
Facility activation announcements and pages were implemented
as appropriate. The inspector noted that several of the EOF
staff members did not respond to the emergency page and had
to be notified individually by telephone; however, overall
response and staffing goals for the facility were not
impacted due to need for the personal notifications.
The Alert Notification System (ANS) for alerting the public
within the plume exposure pathway emergency planning zone
(EPZ) was actuated during this exercise. As a result of a
post-exercise survey in Chesterfield County, initial
information provided indicated that several sirens in the
County did not sound during the exercise. Because the
licensee had recently performed a full cycle test of the ANS
demonstrating greater than 90% operability and demonstration
of the ANS was not required for this exercise, FEMA did not
identify the potential failure in Chesterfield County as an
offsite deficiency. The licensee was continuing to evaluate
the circumstances surrounding the potential failure;
9
however, later information from FEMA indicated that the
apparent failures may have been due to flaws in the survey
process instead of actual siren inoperability. FEMA
certifies the ANS system and is working to resolve any
potential problems with the licensee
No violations or deviation were identified.
7.
Emergency Communications (82301)
This area was observed to verify that provisions existed for
prompt communications among principal response organizations
and emergency personnel as required by 10 CFR 50.47(b)(6),
10 CFR 50, Appendix E, Paragraph IV.E, and the specific
criteria in NUREG-0654,Section II.F.
The inspector observed that adequate communications
capability existed among the licensee's emergency
organizations, and between the licensee's emergency response
personnel and offsite authorities.
The inspector did not note any significant problems with the
communications equipment utilized during the exercise.
Backup systems were not required to be implemented.
However, due to the use of the ECR which did not have an
Emergency Notification System telephone and the use of CP&L
personnel to simulate the NRC Operations Center, commercial
telephone was used to notify NRC. No concerns were noted
with the use of this methodology and the licensee fully
demonstrated the use of the equipment. Minor problems were
observed in the ECR with respect to the facsimile which is
used to supplement verbal communications to the State and
locals. These problems did not impact the ECR staff's
ability to complete timely notifications.
Radio communications with the fire brigade and environmental
monitoring teams were observed to be effective with no
interference identified. In addition, the inspector
observed satisfactory communications with the inplant
chemistry team utilizing the plant public address system.
The licensee did not employ the use of the Emergency
Response Facility Information System (ERFIS) during the
exercise. Although the licensee utilized paper messages to
supply plant parameter data in the ECR, TSC, OSC, and EOF,
exercise participants were required to "earn" the paper data
by adequately demonstrating the ability to access ERFIS. No
problems with ERFIS demonstration were noted with the
exception of the OSC.
For reasons not identified by the
inspector, the OSC staff were unable to access the ERFIS
system; however, upon demonstration of the ability to
10
acquire emergency data from the TSC via facsimile, the OSC
was ultimately provided plant information directly from the
exercise controllers.
No violations or deviations were identified.
8.
Emergency Facilities and Equipment (82301)
This area was observed to determine that adequate emergency
facilities and equipment to support an emergency response
are provided and maintained as required by 10 CFR
50.47(b)(8), 10 CFR 50, Appendix E, Paragraph IV.E, and the
specific criteria in NUREG-0654,Section II.H.
The inspector observed activation, staffing, and operation
of the emergency response facilities including the Exercise
Control Room, TSC, OSC, EOF, and JIC.
In addition, the
inspector observed the fire drill and the PORV repair team
activities.
a.
Control Room
The Control Room used for the exercise was a simulated
Exercise Control Room (ECR) housed in one of the
exterior rooms of the TSC. The facility was configured
with communications, procedures, and mock control
boards to simulate, as closely as possible, the actual
Control Room. The SS assigned to the exercise assumed
the duties of SEC promptly upon initiation of the
simulated emergency. With the exception noted in
Paragraph 5, the SS demonstrated a clear understanding
of the Emergency Plan requirements and his role as Site
Emergency Coordinator. The SS demonstrated effective
command and control of the ECR staff, and after
turnover of SEC responsibility to the TSC, he continued
to maintain management of ECR activities and
priorities.
A particular strength was noted by the inspector
regarding the turnover of SEC responsibilities to the
TSC. This process was considered to be excellent, and
the detailed and specific use of the turnover checkoff
list by the SS coupled with the use of the conference
call feature of the telephone system enabled TSC
personnel to be thoroughly knowledgeable of plant
conditions and ongoing activities at the time of TSC
activation.
b.
Technical Support Center (TSC)
The inspector observed the incorporation of the TSC
into the Protected area prior to the initiation of the
exercise. No concerns were noted regarding this
process, and security was posted outside the TSC
throughout the exercise to maintain the required double
contingency.
The TSC was declared operational approximately 47
minutes after the Alert classification. As discussed
previously, the turnover of the SEC functions was
accomplished in an outstanding manner and provided for
a smooth transition of responsibility. The facility
staff appeared cognizant of their duties, authorities,
and responsibilities, and demonstrated knowledge of
the Emergency Plan and Implementing Procedures. The
SEC maintained a clear understanding of the plant
status and ongoing events during the exercise. Repair
priorities were appropriately established by the SEC;
however, these actions were not always implemented in a
timely manner. This area is discussed further in
Paragraph 8.c.
The SEC was clearly in charge of TSC activities, and
staff briefings were conducted appropriately. Status
boards and other graphical aids were maintained
throughout the exercise by support personnel, and
generally contained information appropriate to the
scenario sequence of events.
The following items were brought to the licensee's
attention for program improvement:
-
Consider using the public address system to
broadcast TSC management briefings to personnel in
the exterior work areas.
-
Key plant and system parameters were not always
displayed on TSC status boards. This information
included: core damage assessment, projected source
term, and the reinsertion of the control rods.
c.
Operational Support Center (OSC)
The OSC was activated approximately 21 minutes after
the Alert declaration. The OSC was located in the
Maintenance Shop outside of the Protected Area adjacent
to the east security entrance. Licensee
representatives stated that plans were in place to move
the OSC into the Protected Area following completion of
the new Maintenance Shop projected for 1992.
12
In general, the staffing for the OSC was timely and no
prestaging of personnel was noted.
The inspector
observed, however, that the OSC sign-in process
appeared cumbersome and resulted in formation of a very
long line for entering personnel. Overall, the
transition into OSC activation was satisfactory, and
command and control in the OSC was considered adequate.
The OSC leader provided periodic briefings to facility
personnel and communicated well with his direct staff.
However, the inspector observed that the OSC Leader
spent little time in the main work area, thus,
potentially limiting his first hand knowledge of
implementation of priority directives.
After activation of the OSC only three damage control
teams were dispatched into the field, and significant
time delays were noted in initiating the missions. At
10:30 a.m. the TSC clearly established and communicated
the three priority damage control actions to the OSC;
however, the following was observed by the inspector:
-
The PORV Team was not dispatched from the OSC
until 11:40 a.m. (Number one priority) -
1
hour and 10 minutes.
-
The Steam Dump Team was not dispatched until
12:13 p.m. (Number two priority) -
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and
43 minutes.
-
The CCW Pump Clearance Team was not
dispatched until 11:25 p.m (Number 3
priority) -
55 minutes.
-
The Loose Parts Monitor Team was never
dispatched, as contemplated by the scenario,
even though the monitor alarm was injected
into the exercise early at the Site Area
Emergency.
-
The CCW Pump Motor Repair Team was canceled
due to the lack of health physics support.
Factors contributing to the delay in team dispatch
appeared to be changing radiological conditions; and
poor coordination of team members for preparation,
muster, and briefings. The problems associated with
the damage control teams were identified, in the
aggregate, to the licensee as an Exercise Weakness for
which corrective actions are required.
13
Exercise Weakness 50-261/91-26-04:
Failure to
demonstrate the ability to conduct damage control
activities in a timely manner.
A strength of the OSC operation was noted regarding
radiological considerations. Habitability monitoring
was initiated early and continued throughout the
exercise based on changing plant radiological
conditions.
In addition, radiation controls were
effectively factored into the routing of personnel from
the TSC to the OSC as well as briefings for the damage
control teams. However, the inspector noted that the
health physics resources were depleted during the
exercise. Although only one damage control team was
affected, a more complex accident mitigation process
may have been adversely affected by the lack of
available health physics technicians. The licensee
also recognized the depletion of HP resources in its
critique.
d.
Emergency Operations Facility (EOF)
The EOF was activated approximately 51 minutes
following the decision to staff the facility. The EOF
is not a dedicated facility and requires
reconfiguration during an emergency. The inspector
observed the setup and staffing of the facility to be
very efficient and in accordance with procedures.
Turnover of management responsibilities from the TSC to
the EOF was also noted to be efficient and thorough.
With the exception of those implementation problems
discussed elsewhere in this report, the facility staff
appeared knowledgeable and familiar with their duties
authorities, and emergency responsibilities. The
command and control exhibited by the ERM was excellent
and considered a strength of the exercise. In
addition, the interface with the State was observed to
be effective. The inspector observed EOF activities
including:
recovery discussions, request for
additional resources; Environmental Monitoring Team
preparation; PAR development; and dose assessment upon
its transfer from the TSC.
The EOF was provided with adequate equipment to support
the assigned staff.
Status boards and other graphical
aids were strategically located and generally
maintained appropriately. Security and access control
were observed to be appropriately established and
maintained throughout the exercise.
14
e.
Joint Information Center (JIC)
The JIC used for the exercise was the CP&L District
Office in Florence, South Carolina. This was the first
time this facility had been activated during an annual
exercise, and it has not yet been accounted for in the
The JIC was activated approximately 57 minutes
following declaration of the Site Area Emergency. The
JIC positions were staffed with personnel as designated
on the emergency response roster. Prior to JIC
activation the Headquarters Communications Center
maintained responsibility for the conduct of public
relations activities (Not observed by NRC).
Activities
at the JIC included the issuance of five simulated news
releases and the conduct of joint State and licensee
news conferences. The inspector observed good
coordination between the licensee and State related to
the issuance of press releases and the conduct of media
briefings; however, coordination was viewed to be
hampered due to the short duration of the exercise
scenario. Media briefings were observed to be
adequate, and the supporting visual aids were good.
The inspector noted that the work areas and resources
designated for the State, licensee, and NRC were
adequate to support an emergency response. However,
the media work area was considered marginally
acceptable. Specifically, the location of media work
area and media monitor (broadcast of television
coverage) has a significant potential for noise
interference with ongoing press briefings due to the
lack of sound barrier protection. The inspector
further noted that the press work area only had five
permanent telephones installed, and no agreements or
plans were in place to acquire additional
communications during emergencies. The inspector
discussed with licensee representatives the need to
establish a mechanism for acquiring additional
communications such that the quantity and timeliness
of installation would be understood. Licensee
representatives were informed that this area would be
tracked as an Inspector Followup Item.
IFI 50-261/91-26-05:
Evaluation of the resources
available to media personnel in the media work area as
well as the potential impact of the media work area
location on the conduct of press briefings.
15
The following areas were identified to the licensee for
program improvement:
-
The initial press release issued at 10:26 a.m. did
not highlight that the site was in an Alert
emergency condition nor did it provide information
regarding the fire in the CCW Pump Room.
-
In response to media questions regarding the
significance of the 19 Rem dose projection,
licensee response personnel characterized the
release based on 10 CFR Part 100 requirements
rather than the associated health hazards.
f.
Fire Drill
The inspector observed the initial response and
mitigation activities associated with the simulated
fire in the CCW Pump Room. The fire brigade's efforts
were both timely and effective. The response to the
initial fire alarm was approximately within minutes
and arrival of the On-scene Commander and other fire
brigade members immediately followed. Fire Brigade
members demonstrated a knowledge of the location of
nearby response equipment as well as the donning and
use of respiratory equipment and turnout gear.
On-scene command and control appeared effective, and
good communications between the On-scene Commander and
the fire brigade members were exhibited. The inspector
noted that health physics and security support were
adequate to support the fire fighting efforts.
No violations or deviations were identified.
9.
Accident Assessment (82301)
This area was observed to assure that methods, systems, and
equipment for assessing and monitoring actual or potential
offsite consequences of a radiological emergency condition
were in use as required by 10 CFR 50.47(b)(9), 10 CFR 50,
appendix E, Paragraph IV.B, and the specific criteria in
The accident assessment program reviewed by the inspector
included an engineering assessment of plant status and an
assessment of radiological hazards to both onsite and
offsite personnel resulting from the simulated accident.
Engineering and core damage assessments were adequately
performed in the TSC; however, one area was brought to the
licensee's attention for program improvement:
Exercise
16
participants stated that the necessary publications and
schematics were not available in the accident assessment
area for use during the exercise. The licensee should
consider incorporation of the needed reference materials, as
feasible, to facilitate the assessment process.
The inspector observed the conduct of dose assessment
activities in both the TSC and EOF. Initially, dose
assessment was performed in the TSC; however, upon
activation of the EOF and arrival of Corporate response
personnel, this function was transferred to the EOF. After
activation of the EOF dose assessment function at 11:43
a.m., the TSC continued to provide support, particularly
with respect to source term determination.
Initial dose projections performed by the TSC appeared
appropriate and consistent with procedure. Specifically,
the inspector observed the performance of a dose calculation
at 10:45 a.m. which confirmed that the licensee was
appropriately in a Site Area Emergency situation. However,
subsequently, the dose assessments appeared to be formulated
without incorporation of appropriate plant conditions
resulting in erroneously high offsite dose values.
At approximately 11:15 a.m., an R-31A main steam line
radiation monitor alarm was received indicating
approximately 16 mR/hr (no core damage).
The dose
projection using this monitor reading was formulated based
on the PORV with full steam generator pressure; however, in
accordance with the scenario, the steam generator was
approaching dryness which required the use of a much reduced
PORV flow rate. The resultant dose projection of 19 Rem
thyroid was falsely high indicating a General Emergency
rather than, appropriately, a Site Area Emergency. Although
the conservativeness associated with the dose projection
surrounding the General Emergency declaration was ultimately
recognized by TSC management, the information was not
provided to the dose assessment staff for refinement of
projected dose information.
In addition, subsequent to the General Emergency
declaration, dose assessments performed were also based on
incorrect PORV flow rates, the origin of which could not be
identified by the inspector. The dose projections using the
incorrect PORV flow rates resulted in erroneously high
assessments (up to 10,000 Rem) throughout the remainder of
the exercise.
The inspector observed that personnel in the
EOF recognized that the dose projections were not reasonable
based on the results of environmental monitoring data;
however, no resolution regarding the errors was determined
17
during the exercise. The discrepancy between the dose
projections and the field monitoring data led to confusion
at the EOF as well as the State.
Examination of the dose projection computer model used by
the licensee confirmed that it contained the flexibility to
adjust the flow rate for the PORV based on actual plant
conditions. However, the apparent inadequate interaction
between health physics and plant systems resulted in the
failure to perform realistic dose assessment based on an
accurate characterization of plant conditions.
Based on
these observations, the inspector informed the licensee that
the failure to adequately demonstrate Exercise Objective C.7
was an Exercise Weakness for which corrective actions are
required.
Exercise Weakness 50-261/91-26-06:
Failure to demonstrate
adequate assessment of the radiological consequences of the
simulated accident (dose assessment).
The activities of onsite and offsite radiological monitoring
teams were not directly observed by the inspector. However,
communications with and direction of the Environmental
Monitoring Teams from observation in the EOF appeared
adequate.
In addition to the above, the inspector discussed the
following areas for program improvement with the licensee:
-
Environmental monitoring data was not posted in
either the TSC or the EOF for easy accessibility
by management and technical staff members.
-
Dose projection information was not posted in the
TSC or EOF as frequently as they were performed.
Only two dose projections were posted in each of
the facilities during the exercise.
No violations or deviations were identified.
10.
Protective Responses (82301)
This area was observed to verify that guidelines for
protective actions during the emergency, consistent with
Federal guidance, were developed and in place, and
protective actions for emergency workers, including
evacuation of nonessential personnel, were implemented
promptly as required by 10 CFR 50.47(b)(10), and the
specific criteria in NUREG-0654,Section II.J.
18
The inspector reviewed PEP-105, Emergency Control -
General
Emergency, Revision 20, dated November 30, 1990, to verify
that adequate guidance was provided for the formulation of
offsite protective action recommendations (PARs).
The
inspector noted that the PAR logic flowchart provided
adequate guidance for the decisionmaking process and was
consistent with Agency guidance incorporating decision tree
logic based on plant conditions as well as dose projections.
At the General Emergency declaration, PARs were developed by
the EOF within 15 minutes, as required. Although a PAR
decision was reached, the methodology used to develop the
PAR was observed to be incorrect. The inspector noted that
the formulated PAR was based on plant status (i.e.,
substantial core damage indicated and/or release of fission
products to containment), rather than on the 19 Rem thyroid
dose assessment value.
Due to the premature declaration of
the General Emergency based on dose assessment (see
Paragraph
9), core damage was not indicated at the time of
PAR development. The inspector determined that the plant
conditions used in the PAR development were not applicable
at the time of the decision, and the licensee
inappropriately implemented Note 1 and/or 2 of the PAR flow
diagram. This problem was also identified during the
licensee's self critique.
In addition, the opportunity to upgrade the PAR when core
damage was actually indicated in the scenario was
circumvented by the exercise controllers. Because the
initial PAR developed did not coincide with that required by
offsite agencies to demonstrate their exercise objectives,
the exercise controller injected a contingency message prior
to issuance of the initial PAR to the State. The State
ultimately expanded the scope of the PAR to encompass the
10-mile EPZ; therefore, the licensee exercise participants
were not afforded the opportunity to redemonstrate their
ability to develop PARs appropriately. The failure to
demonstrate adequately Exercise Objective C.5 was identified
to the licensee as an Exercise Weakness for which corrective
actions are required.
Exercise Weakness 50-261/91-26-07:
Failure to fully
demonstrate the formulation of protective action
recommendations.
Accountability and evacuation of onsite non-essential
personnel was not an objective of this exercise. All
actions related to these processes were simulated. The
licensee adequately demonstrated accountability and onsite
evacuation during the 1990 annual exercise. Other
protective response activities observed by the inspector
included simulated use of potassium iodide by inplant and
19
environmental teams, and the demonstration of the use
respirators and protective clothing.
No violations or deviations were identified.
11.
Exercise Critique (82301)
The licensee's critique of the emergency exercise was
observed to determine the deficiencies identified as a
result of the exercise and weaknesses noted in the
licensee's emergency response organization were formally
presented to licensee management for corrective actions as
required by 10 CFR 50.47(b)(14), 10 CFR 50, Appendix E,
Paragraph IV.F.5, and specific criteria in NUREG-0654,
Section II.N.
The licensee conducted player critiques in each emergency
response facility immediately following the exercise. On
November 21, 1991, the licensee also conducted
evaluator/controller critiques in preparation for the formal
presentation to facility management on the following day.
The inspector observed the critique process to include a
review of the exercise objectives for each functional area.
In particular, the critique involving the lead
controllers/evaluators from each facility resulted in a
detailed presentation of positive findings/strengths,
substantive areas requiring corrective actions, and areas
needing improvement. Frank and constructive discussions
based upon observation and knowledge of the plant and
procedures resulted in a comprehensive summary of exercise
performance.
The licensee's critique, in general, identified the exercise
weaknesses highlighted in the details of this report. In
addition, the licensee identified several areas of concern
not directly observed by NRC evaluators. These areas
include:
-
Ability to provide radiological services such a
dosimetry and personnel monitoring. The problems
in this area were primarily related to health
physics support to the Auxiliary Operators and
dose tracking for individuals moving between
response facilities.
-
Ability to control the spread of contamination.
This area was identified during the removal of the
fire hose from the CCW Pump Room/Radiological
Control Area.
20
-
The failure to release additional emergency
information to the media following the conduct of
the General Emergency press conference.
-
Inappropriate operational assessment performed by
the TSC. The licensee identified two areas of
concern:
direction to feed the faulted steam
generator; and the recommendation to manually
initiate a safety injection.
The inspector observed that the licensee's critique items,
including those discussed above, were appropriately
documented and characterized for licensee management. The
licensee's actions on the identified items will be reviewed
in detail during future inspections. Overall, the licensee's
critique process for this exercise was observed to be
probing, detailed, and effective, and was considered a
strength of the licensee's emergency preparedness program.
Licensee corrective actions on previously identified
exercise weaknesses and areas for improvement were
considered lacking as exemplified by recurrent problems
related to emergency classification and dose assessment. In
general, the licensee's performance during the last three
annual emergency exercises have resulted in various concerns
by NRC. This performance trend will be discussed during the
upcoming Enforcement Conference.
No violations or deviations were identified.
12.
Federal Emergency Management Agency (FEMA) Report
A report on FEMA's evaluation of offsite preparedness will
be issued at a later date and will be provided by NRC under
a separate transmittal.
13.
Exit Interview
The inspection scope and results were summarized on November
22, 1991, with those persons indicated in Paragraph 1. The
Exercise Team Leader described the areas inspected and
discussed in detail the inspection results listed below. In
addition, the inspector reviewed those areas perceived as
exercise strengths and areas for program improvement.
Licensee management committed to evaluate the overall
exercise performance and provide planned corrective actions
to NRC on or about December 2, 1991. Although dissenting
comments were not received from the licensee, licensee
management indicated that a thorough evaluation of the
circumstances regarding the missed classification would be
pursued. Although proprietary information was reviewed
during this inspection, none is contained in this report.
21
On November 27, 1991, the licensee was informed that NRC was
requesting that an Enforcement Conference be held to discuss
the apparent repeat violation as well as the other 1991
exercise weaknesses, the licensee's self-assessment of the
emergency preparedness program, root cause analysis, and
corrective actions to preclude problems in the future. The
Enforcement Conference is scheduled for December 20, 1991,
at 1:00 p.m. in the NRC Region II Office.
Item Number
Description and Reference
50-261/91-26-01
IFI -
Improve exercise scenario
control and coordination including
the length and complexity
(Paragraph 2).
50-261/91-26-02
Repeat Violation -
Failure to
demonstrate adequate corrective
actions for previously identified
exercise weaknesses regarding the
inability to properly classify
emergency events (Paragraph 5).
50-261/91-26-03
Exercise Weakness -
Failure to
provide complete information
regarding the simulated emergency
to State and local governments, as
required (Paragraph 6).
50-261/91-26-04
Exercise Weakness -
Failure
demonstrate the ability to conduct
damage control activities in a
timely manner (Paragraph 8.c).
50-261/91-26-05
IFI -
Evaluation of the resources
available to media personnel in the
media work area as well as the
potential impact of the media work
area location on the conduct of
press briefings (Paragraph 8.e).
50-261/91-26-06
Exercise Weakness -
Failure to
demonstrate adequate assessment of
the radiological consequences of
the simulated accident/dose
assessment (Paragraph 9).
50-261/91-26-07
Exercise Weakness -
Failure to
fully demonstrate the formulation
of protective action
recommendations (Paragraph 10).
0
CD
CD
C,"
(0+
ROBINSON NUCLEAR PROJECT EXERCISE OBJECTIVES
A.
Operational Assessment
1.
Demonstrate the ability of the Control Room to detect accident
conditions,
assess and project radiological
consequences,
and
formulate near term mitigating actions.
2.
Demonstrate
the adequacy
of the Technical
Support Center
in
providing accident assessment and mitigation, dose assessment, and
communication/notification activities.
3.
, Demonstrate the ability to identify and properly classify the
emergency in accordance with the Emergency Plan and Implementing
Procedures.
B.
Communications
1.
Demonstrate the adequacy of procedures for alerting, notifying, and
mobilizing Emergency Response Organization Personnel.
2.
Demonstrate the timeliness of initial and follow-up notifications
to responsible state and local government agencies.
3.
Demonstrate the adequacy of the information provided to responsible
state and local government and agencies in the initial and follow
up notifications.
4.
Demonstrate
the
capability
to
make
timely
and
accurate
notifications
to the Nuclear Regulatory
Commission.
(Actual
participation of the NRC Operations Center may be simulated.)
5.
Demonstrate the ability to effectively communicate with plant
emergency teams and company environmental monitoring teams.
6.
Demonstrate the ability to communicate between emergency response
facilities.
C.
Radiological and Chemical Assessment
1.
Demonstrate the ability to support the radiological assessment
process while maintaining personnel radiation exposure as low as
reasonably achievable (ALARA).
2.
Demonstrate
the capability
to perform radiological monitoring
activities and assessment.
3.
Demonstrate the ability to provide adequate radiation protection
services such as dosimetry and personnel monitoring.
CON-91-2352
RNPD-91-06-RO
2.0-2
4.
Demonstrate
the ability to adequately
control the spread
of
contamination and the radiological exposure of on-site and off-site
emergency workers.
5.
Demonstrate the ability to formulate appropriate protective action
recommendations to off-site government authorities.
6.
Demonstrate the activation, operation,
and reporting of field
monitoring teams.
7.
Demonstrate the assessment of radiological consequences of the
accident and of any releases of radioactive material to the
environment.
D.
Emergency Response Organization and Facilities
1.
Demonstrate the
ability to
augment
the
on-shift emergency
organization within the time limits specified within the Emergency
Plan and its implementing procedures (normal working hours).
2.
Demonstrate that the Technical Support Center, Operational Support
Center, and the Emergency Operations Facility can be activated in
accordance with the Emergency Plan and its implementing procedures.
E.
Public Information
1.
Demonstrate the ability to coordinate news releases and other
public
information
between
and
off-site
government
authorities.
2.
Demonstrate the ability to coordinate the preparation, review, and
release of information for the news media.
3.
Demonstrate the ability to control rumors in accordance with the
public information procedures.
4.
Demonstrate
the ability to prepare for and conduct adequate
briefings concerning plant events for the media.
F.
Fire Brigade
1.
Demonstrate proper response by the fire brigade to the type of fire
chosen for the exercise.
CON-91-2352
RNPD-91-06-RO
2.0-3
CD
m)
ROBINSON 1991 EXERCISE SCENARIO NARRATIVE
At 0830 EST on November 20, 1991, Robinson Unit 2 is at 100% power, late in core
life, and the RCS activity is normal.
At 0846, a small fire in the CCW Heat
Exchanger Room occurs at the "A" CCW Pump.
At 0853 the dedicated shutdown power
supply (a power supply in addition to the two safety related power supplies) will
fail as a result of the fire, removing the "A" CCW Pump and "A" Charging Pump
power supplies.
An Alert should be declared around 0900 based upon a fire with potential to
affect safety related equipment.
The fire will be successfully extinguished by
the plant fire brigade and offsite fire assistance will not be required.
At 0915 a 70 gpm primary to secondary leak is
ramped in to the "A" Steam
Generator.
The leak causes alarms in the blowdown radiation monitor for the "A"
Steam Generator and in the Condenser Air Ejector Discharge radiation monitor.
A minor release path to the environment occurs through the Condenser Air Ejector.
The release rate is above the allowable operating limits. The plant begins to
shut down at about 0930.
During the plant shutdown, at 1007, a spurious Turbine Trip occurs, and the Steam
Dump System (designed to relieve steam flow from the Steam Generators to the
Condenser after the Turbine has tripped) fails to operate.
All three Steam
Generator
Power
Operator
Relief
Valves
(PORVs)
open
to
prevent
overpressurization.
When the plant stabilizes and the "B" and "C" PORVs reclose,
the "A" Steam Generator PORV remains partially stuck open.
The turbine trip also
directly results in an automatic reactor trip. Two control rods fail to fully
reinsert into the core in response to the reactor trip.
A Site Area Emergency should be declared around 1015 based upon a 70 gpm leak in
the Reactor Coolant System and the partially stuck open PORV which provides a
direct uncontrolled path to the atmosphere.
At 1116, a Loose Parts Monitoring System (LPMS)
alarm occurs which indicates
loose parts rattling in the Reactor Coolant System. This is followed by a drop
of two previously stuck control rods into the core.
The combination of the loose
parts, along with the dropped rods, results in mechanical damage to a number of
fuel assemblies in the core. Approximately 9% of the fission product activity
normally trapped within a gap between the fuel pellets and the fuel pellet
cladding is released into the reactor coolant. Reactor Coolant related radiation
monitors alarm.
Since the reactor coolant is
leaking into the "A" Steam
Generator, the high activity in the reactor coolant escapes into the atmosphere.
A General Emergency should be declared at around 1130 based upon the fuel damage
in addition to the direct pathway via the Steam Generator leak and open PORV for
releases into the environment.
From 1130 until approximately 1300, the release continues while the Control Room
cools down and depressurizes the Reactor Coolant System to mitigate the release.
CON-91-2352
RNPD-91-06-RO
3.0-1
1991 RNPD Exercise Timeline
TO
0830 Initial conditions: Reactor is at 100% power steady state, RCS
boron concentration is 103ppm, late in core life, normal RCS
activity.
T+16"
0846 Fire alarm in CCW Heat Exchanger Room (one train), Fire Tech.
will be dispatched to investigate.
T+18"
0848 Second train fire alarm actuated in CCW Heat Exchanger Room,
Fire alarm will be sounded and fire brigade response will be
required.
T+21"
0851 Approximate time for status report from CCW Heat Exchanger
Room. Status will be room is full of heavy smoke and flames
appear to be coming from the "A" CCW Pump fire.
T+23"
0853 DS Bus Undervoltage alarm is received on the DS/FP Annunciator
panel A.
"A" CCW Pump and "A" Charging Pump will be lost as
a result of the loss of the DS bus.
"D" Service Water Pump
alternate power supply from the DS bus is lost also.
T+25"
0855 Sprinkler Activated alarm for the CCW Heat Exchanger Room is
received. Approximate time for Fire Brigade at the scene.
.
T+30"
0900 Approximate time for declaring ALERT based on fire with
potential to effect safety related equipment.
T+38"
0908 Approximate time fire is reported out. Actual time for "fire
out" will be after 5 minutes of in room fire fighting.
T+45"
0915 Charging Pump High Speed alarm (APP-001-38)
is received on the
RTGB. Steam Generator Tube Rupture is beginning (70 gpm leak
ramped in over 10 minutes) in "A" Steam Generator.
T+46"
0916 A second Charging Pump will be started and
a leak rate
determination (OST-051) may be started.
T+50"
0920 R-19A (Steam Generator Blowdown) monitor alarms.
T+52"
0922 R-15 (Condenser Air Ejector Discharge) monitor alarms.
T+59"
0929 Start shutdown of the Reactor at 2% a minute,
RCS boration
begins.
T+72"
0942 Approximate
time to recover
DS bus
(actual time to be
determined by player response), this will recover "A" Charging
Pump.
T+75"
0945 Shutdown rate increased to 3% a minute.
3.0-2
1991 RNPD Exercise Timeline (Continued)
T+97"
1007 A spurious Turbine trip causes a Reactor trip,
two control
rods (E7 and E9) are stuck out.
T+98"
1008 Due to a failure of the Steam Dump System to operate all three
Steam Generator PORVs lift to reduce pressure.
T+102"
1012
"A" S/G PORV noted to be open after temperature is returned to
normal.
T+103"
1013 The Main Steam Isolation Valve for "A" S/G is shut.
T+107"
1017 Approximate time to declare SITE AREA EMERGENCY based on two
(RCS and Containment) Fission Product Barriers breached.
T+110"
1020 An anticipated action is for Operations to attempt to use the
MOV-350 valve to borate to cold shutdown. If this happens it
will be noted to be inoperable.
MOV-350 has been failed since
the beginning of the drill.
T+152"
1102
"A" S/G PORV fails full open.
T+166"
1116 LPMS alarm (APP-036-3) is received in the Control Room.
T+167"
1117 Rods E7 and E9 drop into the core creating additional core
damage.
T+168"
1118 R-9 (Letdown line) monitor alarms and continues to increase.
T+171"
1121 R-9 exceeds 5 Rem.
T+175"
1125 Approximate time for GENERAL EMERGENCY declaration.
T+176-END
1126 Cooldown and depressurization to stop release.
T+270"
1300 Approximate end of drill.
3.0-3