ML16342A582
| ML16342A582 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 11/20/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML16342A581 | List: |
| References | |
| 50-275-98-15, 50-323-98-15, NUDOCS 9811240085 | |
| Download: ML16342A582 (44) | |
See also: IR 05000275/1998015
Text
ENCLOSURE
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.:
50-275
50-323
License Nos.:
DPR-82
Report No.:
Licensee:
Facility:
Location:
Dates:
Inspector(s):
Approved By:
Attachment:
50-275/98-15
50-323/98-15
Pacific Gas and Electric Company
Diablo Canyon Nuclear Power Plant, Units 1 and 2
7 'la miles NW of Avila Beach
Avila Beach, California
November 3-6, 1998
Gail M. Good, Senior Emergency Preparedness
Analyst, Team
Leader
Thomas H. Andrews, Jr., Emergency Preparedness
Analyst
Scott A. Boynton, Senior Resident Inspector (WNP-2)
Larry T. Ricketson, Senior Radiation Specialist
Blaine Murray, Chief, Plant Support Branch
Division of Reactor Safety
~
Supplemental Information
98ii240085 98ii20
ADQCK 05000275
,6
-2-
EXECUTIVE SUMMARY
Diablo Canyon Nuclear Power Plant, Units 1 and 2
NRC Inspection Report 50-275/98-15; 50-323/98-15
A routine, announced inspection of the licensee's performance and capabilities during the
full-scale, biennial exercise of the emergency plan and implementing procedures was
performed.
The inspection team observed activities in the control room simulator, technical
support center, operational support center, and emergency operations facility.
'verall,
performance was good. The control room, technical support center, operational
support center, and emergency operations facilitysuccessfully implemented key
emergency plan functions including emergency classifications, protective action
recommendations,
and dose assessment.
The control room staff's performance was generally very good. The staff effectively
implemented the emergency plan; recognition, declaration, and notification of the alert
were all timely. Accountability was quickly determined and dose assessments
of the
gas decay tank release were accurate and timely. A strength was identified concerning
implementation of mitigation strategies for plant equipment failures.
Both internal and
external communications. were generally good; however, on several occasions
communications lacked appropriate detail and/or were inaccurate.
The frequency of
control room briefings declined during the latter part of the exercise.
Response
to plant
annunciators was inconsistent (Section P4.2).
The technical support center staff's performance was good. Activation was slow to
occur even though minimum staffing was quickly achieved.
The untimely activation was
identified as part of an exercise weakness identified in the emergency operations facility.
Analysis of plant conditions and corrective actions were appropriate for the scenario
conditions.
Offsite agency notifications for the site area emergency were transmitted
within regulatory requirements, and followup notifications were made frequently.
Dose
assessments
were performed correctly. Protective action recommendations for the site
area emergency were appropriate for the scenario conditions. There was generally
good coordination and communications with the other emergency response facilities to
discuss status, priorities, and potential issues.
The change in wind direction during the
release was not communicated to plant personnel and could have resulted in higher
personnel exposures (Section P4.3).
The operational support center staff's performance
was good. The center was
activated with appropriate personnel, and it was equipped properly to perform its
function. Briefings were concise, informative, and'regularly performed; however,
participants sometimes did not attend because
they were having telephone discussions
with counterparts.
High priorityjobs were clearly identified. Information sharing was
timely, and the repair team status board was well maintained.
Radiological controls and
team briefings were generally good; however, other safety information, such as, team
-3-
routing and heat stress considerations were not'adequately addressed.
One repair
team member did not meet respiratory protection program requirements (Section P4A).
The emergency operations facilitystaff's performance was generally'good.
The facility
was promptly staffed, but activation and transfer of direction and control duties was
unnecessarily delayed.
The untimely activation of both the technical support center and
emergency operations facilitywas identified as an exercise weakness.
The general
emergency was quickly recognized and correctly classified, and protective action
recommendations
were correctly determined.
Offsite agency notifications made by the
emergency operations facilitywere timely. However, an exercise weakness was
identified for failure to notify the offsite agencies of the site area emergency. declaration
within the required time limit (initiated by the technical support center but coordinated
through the emergency operations facilitystaff). Since the licensee identified this
exercise weakness,
no response
is required.
Opportunities for improvement included:
(1) communication and information flowwere ineffective at times and contributed to the
late notification; and (2) the event classification, description,.and status were confusing,
unclear, and incomplete on notification forms. Dose assessment
and field team control
activities were well managed, controlled, and implemented (Section P4.5).
The originally submitted exercise scenario package was of poor quality because
objectives were vague and not measurable,
offsite radiological plume maps were
missing, a scenario event was not properly coordinated with security personnel and had
to be rewritten, and a list of simulated events was not developed or provided. The
revised objectives were improved (Section P4.6).
Post-exercise
critiques were not fullyeffective because
inplant repair team members did
not participate in the OSC critique, and the CR and EOF critiques tended to focus more
on positive performance and had limited participant involvement.
In contrast, the
management
critique was very thorough and self-critical. Three weaknesses
were
identified along with numerous opportunities for improvement.
The integrated critique
process demonstrated
an effective program for identifying areas in need of correction,
but exercise participants tended to be passive members in the process (Section P4.7).
Correction of two emergency action levels was untimely (Section P8).
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IV. Plant Su
ort
p4
Staff Knowledge and Performance in Emergency Preparedness
P4.1
Exercise Conduct and Scenario Descri tion 82301 and 82302
The licensee conducted a full-scale, biennial emergency preparedness
exercise on
November 4, 1998. The exercise was conducted to test major portions of the onsite
(licensee) and offsite emergency response plans.
The licensee activated its emergency
response organization and all emergency response facilities. The Federal Emergency
Management Agency evaluated the offsite response capabilities of the State of
California and San Luis Obispo county. The Federal Emergency Management Agency
will issue a separate
report.
The exercise scenario was conducted using the plant control room (CR) simulator. The
exercise began at 7:45 a.m. with Unit 1 at 100 percent power.
Emergency response
Team D was on-call for augmentation of the onshift staff. The following initial conditions
were simulated for Unit 1: residual heat removal Pump 1-1 was unavailable because of
an ongoing inspection of the associated
pump motor breaker, and emergency diesel
Generator 1-2 was also inoperable with troubleshooting in progress.
At 7:58 a.m., the CR was notified by the auxiliary building operator of a potential bomb
located in residual heat removal pump Room 1-1. With concurrence from the watch
commander, the shift supervisor directed the evacuation of the auxiliary building at
8:05 a.m.
- At 8:06 a.m., the shift supervisor declared an alert because of the ongoing security
event that threatened the operability of safety-related equipment and assumed
the
duties of interim site emergency coordinator.
Implementation of the emergency plan at
the alert level prompted the activation of both the onsite and offsite emergency response
facilities.
At 8:13 a.m., a second bomb was simulated to detonate in the vicinityof gas decay
Tank 1-1, initiating a release of the tank's contents to the plant vent. The crew took
action to isolate the tank's filllineup and to assess
the dose consequences
of the
release.
The results of the CR staff's dose assessments
showed that offsite
- onsequences
from the release were minimal. At 8:41 a.m., lhe'CR staff commenced a
normal shutdown of Unit 1 based upon the ongoing security threat.
At 9:19 a.m., chemistry notified the CR that diesel fuel oil day tanks for all three
emergency diesel generators were contaminated beyond acceptance
limits. This
rendered all three emergency diesel generators inoperable.
At 9:23 a.m., the technical support center (TSC) was activated and the site emergency
coordinator functions were transferred to the TSC. The site emergency coordinator
used position-authorized judgment to immediately upgrade the event to a site area
emergency based upon the uncertainties of the security threat.
0
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'At 9:50 a.m., a 500kV grid disturbance caused a turbine trip and reactor trip. All4160V
vital busses transferred to startup power. At 9:59 a.m., startup power was also lost and
1-1 and 1-3 started and loaded on to their respective
busses.
However, because of the fuel oil contamination, the diesels failed within several
minutes initiating a loss of all AC power.
Utilizing the emergency operating procedures,
the CR crew maintained core cooling through use of the turbine driven auxiliary
feedwater pump and the atmospheric steam dumps.
Actions were also initiated to
cross-connect power from Unit 2 and to'establish backfeed from the 500kV grid through
the main transformers.
At 10:15 a.m., the CR crew implemented the requirements of 10 CFR 50.54(x) and (y) to
deviate from the plant's license and close the steam admission valve to the auxiliary
feedwater pump turbine to prevent the steam generators from overfilling. Subsequently,
local manual control was established for the individual steam generator level control
valves and the turbine driven auxiliary feedwater pump was restarted.
At 11:22 a.m., the capability to backfeed from the 500kV grid was established and the
4160V vital busses were reenergized.
Operators then implemented emergency
contingency actions for AC power restoration with safety injection required (due to low
reactor coolant system pressure).
Actions were also initiated to restore vital plant loads
At 12:05 p.m., a break in reactor coolant Loop 1-3 initiated a loss of coolant accident
and a safety injection actuation signal. Although the centrifugal charging pumps and the
safety injection pumps properly started, residual heat removal Pump 1-1 was still out of
service and residual heat removal Pump 1-2 failed to start because
its associated
motor
breaker failed to close.
The lack of low pressure injection sources resulted in
inadequate core cooling and subsequent
fuel damage.
The'pressure
spike in
containment from the reactor coolant system blowdown also caused the containment
purge valves to open, initiating a radiological release to the environment via the plant
vent.
At 1:10 p.m., the CR crew was able to manually close the breaker for residual heat
removal Pump 1-2. Residual heat removal Pump 1-1 was also returned to service at
1:30 p.m. At 1:33 p.m., containment spray was initiated to assist in iodine 'removal in
containment and to reduce containment pressure to minimize.the release rate. At 1:45
p.m., the CR crew transitioned the emergency core cooling system to cold leg
recirculation and completed containment spraying using both containment spray pumps.
At 3:35 p.m., maintenance personnel were able to close a manual damper in series with
the containment purge valves to terminate the radiological release.
The exercise was
terminated at 3:45 p.m.
Control Room
CR
Ins ection Sco
e 82301-03.02
The inspectors evaluated the CR shift staff as they performed tasks in response
to the
exercise scenario conditions.
These tasks included event detection and classification;
-6-
analysis and mitigation of plant conditions; offsite agency notifications; adherence
to
emergency plan implementing procedures and emergency operating procedures;
command and control; and communications.
The inspectors reviewed applicable
emergency plan sections and implementing procedures, operator logs, checklists, and
notification forms.
Observations and Findin s
The CR staff effectively analyzed and mitigated the effects of the simulated plant and
equipment failures. The operators quickly recognized and classified the alert based
upon the identification of a simulated bomb in residual heat removal pump Room 1-1.
The CR staff was notified of the bomb at 7:58 a.m. and declared the alert at 8:06 a.m.
Offsite agency notifications of the alert declaration were promptly made at 8:15 a.m.
The operating crew was proactive in its implementation of mitigation strategies for the
simulated plant casualties.
Upon notification of the bomb in residual heat removal pump
Room 1-1, the shift foreman directed the closure of the residual heat removal Pump 1-1
suction valve from the refueling water storage tank (Valve 8700A). The action was
designed to protect the integrity of the refueling water storage tank in the event the
simulated bomb detonated.
Also, recognizing that emergency diesel Generator 1-2 was
inoperable, the operating crew reviewed the electrical loads supplied by 4160V vital Bus
G to determine plant impact if offsite power was lost. When it was determined that all
three emergency diesel generators were inoperable, the crew took early action to
establish an electrical lineup for cross-connecting
power from Unit 2. Finally, with the
uncertainty of the location of additional bombs in the power block, the operating crew
requested the operational support center (OSC) and security personnel to prioritize
bomb searches
based upon plant equipment needs during the unit shutdown.
As an
example, the crew requested'a
priority search of the auxiliary feedwater pump room
because
of the imminent need for those pumps.
The emergency evaluation coordinator's (shift technical advisor) performance in
assessing
the dose consequences
of the release from the gas decay tank was
excellent.
Challenged by erroneous process radiation monitor data given by a
controller, the emergency evaluation coordinator appropriately questioned the validity of
the data and the error was quickly corrected (this data error is addressed
in
Section P4.6 below). The emergency evaluation coordinator completed three separate
dose assessments.
The results were consistent with the exe;cise scenario and promptly
communicated to the interim site emergency coordinator.
The shift foreman's command and control of CR activities was generally good, including
execution of the emergency operating procedures.
However, on two occasions crew
briefings were not conducted and/or did not provide sufficient detail for implementing
procedural actions.
First, no briefing was provided to the crew for implementing the
Unit 1 plant shutdown.
As a result, operators were not properly positioned for several
evolutions, including opening the feedwater bypass valves, which occurred at a lower
power level than that suggested
by procedural guidance, and removing the condensate
polishers from service.
Second, discussions between the CR staff did not adequately
address contingencies for transitioning to cold leg recirculation. As a result, the shift
'0
-7-
foreman had to direct an operator to locally close the breaker for residual heat removal
Pump 1-2 instead of having the operator prepositioned for that function. This delayed
the completion of the transition.
The operating crew's response
to plant annunciators was inconsistent.
Alarms were not
routinely announced and, in one instance, not properly questioned.
As examples, no
announcements
were made when the axial flux deviation alarm was received during
plant shutdown or when the safety injection actuation signal was received due to low
reactor coolant system pressure following the plant trip. Also, during restoration of the
4160V vital busses,
the operating crew did not question the fact that there was no alarm
for loss of DC control power for Bus G even though reports were received that the DC
knife switches on Bus G were open.
Had the DC control power been available to
components on Bus G, those components could have inadvertently started upon bus
restoration.
Although the CR shift staff demonstrated
effective implementation of the emergency
plan, the use of emergency plan implementing procedures was inconsistent.
Emergency plan implementing checklists for the alert declaration were not routinely
reviewed by the interim site emergency coordinator, the CR assistant, or the emergency
evaluation coordinator.
As a result, the interim site emergency coordinator did not
announce the alert declaration to the CR staff as required by the alert activation
checklist.
In addition, the interim site. emergency coordinator did not sign off completion
of the checklist when emergency coordinator functions were transferred to the TSC.
Communications within the CR and between the CR and other facilities were not always
clear, complete, and accurate.
In the following instances, the communication difficulties
caused confusion regarding'actions to be taken:
After the discovery of the simulated bomb in residual heat removal pump
Room 1-1, the interim site emergency coordinator directed the fire brigade to
respond without providing the location where the brigade was needed.
The fire
brigade leader had to contact the interim site emergency coordinator to seek
clarification.
After the loss of coolant accident, the TSC directed the CR to initiate
However, the TSC did not indicate whether one or both
pumps should be operated, and the shift super visor did not seek clarification until
questioned by the control operator.
There was some confusion about whether the OSC had relocated.
On two
separate occasions, two different backup locations were identified for the OSC.
The OSC never relocated.
News Release
1 (for the alert declaration) was not adequately reviewed.
The
news release erroneously indicated that the bomb was located in the turbine
building and that no injuries were reported.
-8-
Some plant announcements
originating from the CR were contradictory and
presented poorly.
For example, an announcement
was made at 1:47 p.m.
regarding the establishment of residual heat removal circulation. The individual
who made the announcement
made a misstatement and then attempted to
correct it. However, in doing so, the individual confused some exercise
participants.
Inspectors noted that some individuals in the OSC were mistaken
about the availability of residual heat removal Pump 1-1, after the
announcement.
During the latter part of the exercise, the frequency of CR staff briefings
significantly declined.
No briefings were held to update status of events between
11:25 a.m. and 12:32 p.m. No other crew briefings were held after 12:32 p.m.
c.
Conclusions
The CR staff's performance was generally very good. The staff effectively implemented
the emergency plan; recognition, declaration, and notification of the alert were all timely.
Accountability was quickly determined and dose assessments
of the gas decay tank
release were accurate and timely. A strength was identified concerning implementation
of mitigation strategies for plant equipment failures.
Both internal and external
communications were generally good; however, on several occasions communications
lacked appropriate detail and/or were inaccurate.
The frequency of CR briefings
declined during the latter part of the exercise., Response to plant annunciators was
inconsistent.
P4.3
Technical Su
ort Center TSC
a.
Ins ection Sco
e 82301-03.03
The insper ~~<<observed and evaluated the TSC staff as they performed tasks
necessary
to respond to the exercise scenario conditions.
These tasks included staffing
and activation, facility management
and control, accident assessment,
classification,
dose assessment,
protective action decision making, notifications and communications,
assistance
and support to the CR, and dispatch and coordination of monitoring teams..
The inspectors reviewed applicable sections of the emergency plan, procedures,
checklists, and logs.
Observations and Findin s
The TSC met "minimum staffing requirements" approximately 14 minutes after the alert
declaration, but the center was not activated until about 75 minutes after the alert
declaration.
Although the TSC was considered functional at the time minimum staffing
requirements were met, it was not considered activated until the emergency coordinator
responsibilities were assumed from the CR. As a result, TSC activation was considered
untimely. The failure to activate the TSC in a timely manner was identified as part of the
exercise weakness discussed
in Section P4.5 below.
-9-
In accordance with procedures,
a site assembly was ordered following the alert
declaration.
When the event escalated to a site area emergency, the accountability
process was initiated; however, it took an exceptionally long time to complete
(75 minutes).
All of the designated assembly areas/facilities were accounted for within
30 minutes, except one (medical facility). In reviewing this matter, inspectors noted that,
prior to the exercise, medical facilitypersonnel were informed that they were not
participating in the exercise.
As a result, the fac.",,',y did not provide information to
security in a timely manner and caused the delay in establishing initial accountability.
The inspectors did not consider the untimely accountability to be an exercise weakness,
because
the delay was due to exercise artificialities. However, the licensee identified
this issue as a weakness during its critique.
Analysis of plant conditions and corrective actions were appropriate for the conditions
presented.
The TSC site emergency coordinator elected to declare a site area
emergency based upon judgment that conditions warranted upgrading from an alert.
There was sufficient discussion among the staff and with the interim site emergency
coordinator to substantiate the decision to upgrade.
Offsite agency notifications were
performed within 15 minutes of the site area emergency declaration, and followup
notifications were made approximately every 30 minutes.
The TSC staff monitored plant conditions to identify negative trends and potential
problems.
The inspectors observed good interactions between engineering and dose
assessment
personnel.
The engineering staff often discussed plant conditions and
potential release paths with the dose assessment
staff. The resulting information was
used to adjust goals or priorities.
The TSC staff correctly performed dose assessments
and used the results to confirm
protective action recommendations
and coordinate offsite monitoring team response.
Protective action recommendations
for the site area emergency were appropriate for the
conditions identified.
Good internal communications and facility briefings helped the TSC staff maintain focus
on goals and priorities. While there was confusion associated
with the security event
early in the exercise, the TSC staff aggressively worked to develop strategies to deal
with existing problems and to minimize affects of potential damage from the remaining
bomb (or bombs).
Later in the exercise, the TSC worked to stop the release by
requesting the use of containment sprays to reduce containment pressure.
The staff
~ cautiously used the refueling water storage tank (to conserve level) by using the sprays
for a short time, then assessing
the impact.
Facility briefings were conducted in the TSC command room every 30 minutes to
provide current plant conditions and task status, and to reassess
goals and priorities.
The assistant site emergency coordinator ensured that all of the command room staff,
attended the briefings, led the briefings, and solicited input/status from each person.
Briefings typically lasted about 10 minutes.
To ensure that the command room staff was
prepared for the briefings, the briefing time was announced shortly before each briefing.
The TSC secretary answered telephone calls and took messages
to limitdistractions
-10-
during the briefings. Following the briefings, the engineering advisor and the radiation
advisor briefed their staffs on status, goals, and priorities.
The TSC staff demonstrated
generally good coordination with the other emergency
response facilities through routine communications to discuss status, priorities, and
potential issues.
Plant personnel were often informed of changing plant conditions;
however, the change in wind direction during the release was not communicated to plant
personnel in a timely manner.
The information was communicated to the OSC
approximately
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after the wind change was observed.
No announcement
was
made to inform personnel in the plant of the change in radiological conditions caused by
the change in wind direction. The failure to communicate this information could have
resulted in higher exposures than expected for personnel working in.or crossing areas
affected by the plume.
The TSC and OSC communicated frequently regarding the need to relocate the OSC.
One discussion occurred when power was lost to the OSC and again later in the
exercise when dose rates increased due to the release.
The TSC staff considered the
need to use potassium iodide but decided that it was not necessary for the given
conditions.
This decision was appropriate.
Conclusions
The TSC staff's performance was good. Activation was slow to occur even though
minimum staffing was quickly achieved.
The untimely activation was identified as part of
an exercise weakness identified in the emergency operations facility. Analysis of plant
conditions and corrective actions were appropriate for the'scenario conditions.
Offsite
agency notifications for the site area emergency were transmitted within regulatory
requirements, and followup notifications were made frequently.
Dose assessments
were performed correctly. Protective action recommendations
for the site area
emergency were appropriate for the scenario conditions.
There was generally good
coordination and communications with the other emergency response facilities to
discuss status, priorities, and potential issues.
The change in wind direction during the
release was not communicated to plant personnel and could have resulted in higher
personnel exposures.
M
0 erational Su
ort Center
Ins ection Sco
e 82301-03.05
The inspectors observed and evaluated the O'SC staff as they. performed tasks in
response
to the exercise scenario conditions. These tasks included response to CR
and TSC requests and emergency response team dispatch.
The inspectors reviewed
applicable emergency plan sections, procedures, checklists, logs, and radiological
surveys.
J
1
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Observations and Findin s
Prior to OSC activation, the inspectors observed an operator (exercise participant)
during a routine equipment inspection tour. As part of the exercise scenario, a
simulated explosive device had been placed in residual heat removal pump Room 1-1.
Scenario developers assumed
that the operator would identify the device and take
actions that would initiate the exercise.
However, even though the simulated explosive
device was not concealed, the operator did not observe it. In order to prevent falling
behind the scenario time line, a controller intervened and informed the operator of the
presence of the device.
The operator immediately informed the operations shift
supervisor, made a quick check of the area to warn other exercise participants. in the
area, and left to brief security personnel.
When the inspectors arrived at the OSC, the center was activated with appropriate
personnel.
The participants'ames
and emergency response function descriptions
were recorded on a sign-in board within the center.
Telephones,
radios, and other
equipment necessary for the OSC to function were in place.
Area radiation surveys
were first performed approximately 10 minutes after dose rates began to rise, and
habitability surveys in the center were performed regularly, thereafter.
OSC personnel
were routinely informed of the radiation dose rates and reminded to check individual
pocket ion chamber doses.
The OSC was under the supervision of the emergency maintenance coordinator.
The
emergency maintenance coordinator demonstrated
good command and control by
effectively communicating plant status and job priorities. Job priorities were not
numerically ranked, as in the TSC; however, the emergency maintenance coordinator
always clearly identified the highest priority assignment.
OSC briefings were concise
and informative. The emergency maintenance coordinator conducted the briefings
regularly and solicited information from all OSC members.
However, during some of the
briefings, some of the OSC leads continued telephone conversations with counterparts
and did not participate in the briefings. Otherwise, information sharing within the OSC
was timely. The only status board maintained in the OSC identified maintenance teams
and team location and status.
The team status board was well maintained.
Typically, good emergency team briefings were conducted prior to team dispatch from
the OSC.
Maintenance and radiation protection OSC leads provided the teams with the
appropriate information so that the teams could properly as~ ~ss equipment conditions
and perform assigned tasks expeditiously, while maintaining radiation doses low.
However, only radiological safety information was addressed
in some briefings.
For
example, the pre-job briefing for the repair team sent to close Manual Damper 35
(Team 33) did not alert the workers to the possible effects of heat stress, even though
the team members were required to wear cloth anti-contamination clothing, plastic anti-
contamination clothing, and self-contained breathing apparatuses.
No maximum stay
time was established based on heat stress considerations for actual or simulated
conditions. Additionally, although identified as a consideration during preliminary
discussions,
the safest route of travel was not provided to Team 33. OSC personnel did
not followthrough on early suggestions
to review plant maps to identify the best route of
travel for the team.
The controller for the team intervened for safety reasons and
-12-
redirected the team so that team members would not have to climb ladders or travel
through narrow passage
ways while wearing self-contained breathing apparatuses.
The inspectors noted that some aspects of the licensee's respiratory protection program
were not met by one individual participating on an emergency maintenance team.
When respiratory protection requirements were discussed during the pre-job briefing for
Team 33, a mechanic mentioned the need to wear corrective lens inserts.
The team
was instructed to proceed to the locker room, together, retrieve the mechanic'
corrective lens inserts, and then wait at the radiological access control access point for
permission to enter the radiological controlled area.
However, the inspectors noted that
the mechanic did not wear corrective lens inserts while wearing a self-contained
breathing apparatus, despite the pre-job briefing instructions.
Additionally, the mechanic assigned to Team 33 failed to perform a negative pressure
functional test to ensure a good seal after donning the respirator face piece.
The other
two team members performed the test appropriately.
Conclusions
The operational support center staff's performance
was good. The center was
activated with appropriate personnel, and it was equipped properly to perform its
function. Briefings were concise, informative, and regularly performed; however,
participants sometimes did not attend because they were having telephone discussions
with counterparts.
High priorityjobs were clearly identified. Information sharing was
timely, and the repair team status board was well maintained.
Radiological controls and
team briefings were generally good; however, other safety information, such as, team
routing and heat stress considerations were not adequately addressed.,
One repair
team member did not meet respiratory protection program requirements.
Emer enc 0 erations Facilit
Ins ection Sco
e 82301-03.04
The inspectors observed the EOF staff as they performed tasks in response to the
exercise.
These tasks included facilityactivation, recognition and classification of
emergency events, notification of state and local response agencies, development and
issuance of protective action recommendations,
dose projections, field team control, and
direct interactions with offsite agency response personnel.
The inspectors reviewed
applicable emergency plan sections and procedures, forms, dose projections, logs, and
press releases.
Observations and Findin s
Although the EOF was quickly staffed after the 8:06 a.m. alert declaration, facility
activation and transfer of emergency direction and control responsibilities was untimely.
At 8:40 a.m., (36 minutes after the alert declaration), the first person arrived at the EOF
(the EOF is about 11 miles northeast of the Diablo Canyon Power Plant). The recovery
manager arrived at 8:55 a.m., and minimum staffing was present at 8:58 a.m.; however,
-13-
the EOF was not declared activated until 9:57 a.m. (almost 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after the alert
declaration), when the recovery manager assumed overall emergency direction and
control responsibilities.
As discussed
in Section P4.3 above, the TSC was promptly staffed but was not
activated until 75 minutes after the alert declaration, even though the exercise was
conducted during normal work hours.
There appeared to be no urgency to activate and
assume direction and control responsibilities from the CR to the TSC and then from TSC
to the EOF. The purpose of these facilities is to free the CR and TSC of emergency
plan functions so that the technical staff can focus on plant mitigation efforts.
In evaluating this matter, the inspectors identified the following pertinent information:
Section 6.1.1.1 of the Diablo Canyon Power Plant Emergency Plan stated that
emergency response facilities "willbe staffed when required within approximately
60 minutes after initiating classification.... "
NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of
Radiological Emergency Response
Plans and Preparedness
in Support of
Nuclear Power Plants," Revision 1, Evaluation Criteria H.1 and 2 specify that a
in accordance
with NUREG-0696.
NUREG-0696, "Functional Criteria for Emergency Response
Facilities,"
Revision
1 specifies that:
(1) the TSC "... achieve full functional operation
within 30 minutes;" and (2) the EOF "achieve fullfunctional operation within
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />."
NUREG-0737, Supplement
1, "Clarification of Three Mile Island Action Plan
Requirements," which superceded
NUREG-0696, requires that the TSC be
~ "Staffed by sufficient... and be fullyoperational within approximately
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />
after activation." The EOF is required to be: "Staffed using Table 2 (previously
approved by the Commission) as a goal. Reasonable
exceptions to goals for the
number of additional staff personnel and response times for their arrival should
be justified and will be considered by NRC staff."
During discussions about this matter, the licensee indicated that it interpreted its
emergency plan to mean that the facilities had to be "staffed" within 60 minutes, not
"activated." The licensee acknowledged that the emergency plan did not contain facility
activation times and that neither term was defined in the plan.
Since the emergency plan did'not contain actual activation times, the inspectors had to
rely on the above references as the bases for the evaluation (60 minutes).
Accordingly,
the inspectors identified the untimely activation of the TSC and EOF as an exercise
weakness
(50-275; 323/98015-01).
Prior to EOF activation, the TSC declared a site area emergency at 9:23 a.m.
Since the
county emergency operations center was activated and the advisor to the county
position was filled (a licensee position at the EOF), the notification was coordinated
.
-14-
through the EOF. Notification of the site area emergency declaration was not provided
to the offsite agencies
in a timely manner (within the 15-minute requirement).
County
authorities were not notified until 9:46 a.m. (23 minutes after the site area emergency
declaration).
TSC personnel called the offsite liaison at the EOF; however, the message
was not transmitted to the advisor to the county. The failure to notify the offsite
agencies of the site area emergency declaration in a timely manner was identified as an
exercise weakness
(50-275; 323/98015-02).
The licensee identified the untimely notification as an exercise weakness during the
management critique and discussed preliminary recommendations
(corrective actions).
The preliminary recommendations
included revising the checklists for the liaison advisor
(and assistants),
agency liaison, and advisor to the county. The planned corrective
actions appeared reasonable.
At about 12:09 p.m., the EOF recognized that a loss of coolant accident and radiological
release were in progress.
With input from the TSC, the EOF quickly classified the
general emergency condition based on a loss of coolant accident with containment
radiation levels greater than 100% gap release (General Emergency P2). The recovery
manager declared the general emergency at 12:14 p.m. The corresponding offsite
agency notification was timely, and protective action recommendations
were correctly
determined and quickly communicated.
Although all the general emergency notification and subsequent
followup notifications
made by the EOF were timely, information provided on event notification forms was
unclear, confusing, and incomplete.
Inspectors observed the following examples:
The bases far the emergency declarations was not described in the written
summary section for all three events (including the alert and site area emergency
declarations made by the CR and TSC, respectively).
In the case of the general
emergency (prepared by the EOF), the description simply referred to GEP2,
rather than the actual conditions (loss of coolant accident and containment
radiation levels greater than100% gap release).
Inspectors determined that the
information contained on the form had little value to those who received the
forms (offsite agencies and NRC). Containment radiation levels were not
mentioned until 1:31p.m. (over an hour after the conditions existed).
Closure/termination of the security event was never documented on the forms.
The forms continued to reference bomb threats until the end of the exercise.
Form 10 was confusing in that it stated that the event was a site area emergency
(big bold letters at the top) but the written summary stated that a general
emergency was declared (small print at the bottom of the form). A general
emergency condition actually existed at the time.
Acronyms were used extensively on the notifications forms. The meaning of the
terms would not likely be known by those who received the forms.'he
inspectors determined that the use of acronyms reduced the value of the
information provided and that the information was unclear and confusing.
-15-
~
The written summaries appeared incomplete for Notification Forms 13 and
higher. Summaries ended with: (1) "unfiltered release via plant vent from," (2)
"Charging an", and (3) "Charging a."
Communications and information flow within the EOF were ineffective at times.
Inspectors identified the following examples:
~
Personnel in the command room, including the recovery manager and advisor to
the county, were not informed of the site area emergency declaration in a timely
manner.
This situation may have contributed to or prevented the delay in the site
area emergency notification. The site area emergency was declared at 9:23
a.m. The Unified Dose Assessment Center (UDAC) was informed at 9:33 a.m.,
and the public information staff was preparing a press release at 9:29 a.m. to
address the site area emergency declaration.
The recovery manager was not
informed until about 9:41 a.m. (18 minutes after the declaration).
~
The status of the security event was not clearly communicated to EOF and
UDAC personnel.
At 10:10 a.m., UDAC was informed that there was a third
bomb. This was not consistent with information provided to the recovery
manager from the site emergency coordinator.
Although three-part communications were occasionally used, sometimes even
the three-part communications were ineffective. For example, at 2:37 p.m., a
decision was made in UDAC to have one field team collect a surface water
'ample
at the reservoir and to have another team collect soil and vegetation
samples.
The radiological monitoring director repeated-back
water and soil
samples to the radiological manager.
The radiological manager incorrectly
confirmed the repeat-back instruction. As a result, the field team at the reservoir
was directed to take a water sample (as opposed to a surface water sample),
and the other team was directed to take only a soil sample (not soil and
vegetation samples).
The effectiveness of briefings was challenged by telephone calls and
conversations that occurred in the command room during briefings (the
conversations were distracting). Also, it was not always clear when briefings
were over. At times, the briefings appeared
to continue after an announcement
was made that the briefing was over.
Dose assessment
and field team control activities were effectively performed.
Numerous dose calculations were computed using the emergency assessment
and
response system to evaluate the offsite impact of the radiological release.
Plant
conditions affecting dose assessments,
such as, filtration and core spray status
changes, were quickly determined and factored into the calculations.
The radiological
manager provided detailed briefings and was able to keep the recovery manager
informed of offsite radiological conditions and still provide direction and control to the
utilityUDAC staff. There was very good coordination with the offsite UDAC
representatives.
The decision to recommend potassium iodide to field team members
was properly determined and quickly communicated to offsite field team members.
-16-
In contrast; efforts to validate/confirm the emergency assessment
and response system
thyroid dose projections and protective action recommendations
with field team samples
were unnecessarily delayed.
The radiological release started at about 12:07p.m.;
however, the centerline field team was not directed to take an air sample until 1:45 p.m.
The results were not available until 2:06 p.m.
Facility and functional area staffing were consistent with the emergency plan; however,
inspectors observed that the radiological monitoring director appeared to be excessively
burdened with responsibilities during the exercise.
The individual was challenged to
complete the following assigned tasks:
communicating with field teams, taking new
directions from the radiological manager, logging field team radiological readings and
sample results, performing hand calculations, maintaining a hand-written log, and
maintaining the electronic log.
Conclusions
The emergency o'perations facilitystaff's performance was generally good. The facility
was promptly staffed, but activation and transfer of direction and control duties was
unnecessarily delayed.
The untimely activation of both the technical support center and
emergency operations facilitywas identified as an exercise weakness.
The general
emergency was quickly recognized and correctly classified, and protective action
recommendations
were correctly determined.
Offsite agency notifications made by the
emergency operations facilitywere timely. However, an exercise weakness was
identified for failure to notify the offsite agencies of the site area emergency declaration
within the required time limit (initiated by the technical support center but coordinated
through the emergency operations facilitystaff). Communication and information flow
were ineffective at,times and contributed to the late notification: (1) the recovery
.manager and advisor to the county were not immediately informed of the site area
emergency declaration, (2) the status of the security event was not clearly
'ommuni~~~ed
and disseminated,
and (3) three-part communications were not always
effectively used to ensure that directions were understood.
The event classification,
description, and status were confusing, unclear, and incomplete on notification forms.
Dose assessment
and field team control activities were well managed, controlled, and
implemented.
However, there was a delay in obtaining field team air samples to validate
dose projections and protective action recommendations
results, and the radiological
monitoring director was overburdened with responsibilities.
Scenario and Exercise Control
Ins ection Sco
e 82301 and 82302
The inspectors evaluated the exercise to assess
the challenge and realism of the
scenario and exercise control.
-17-
b.
Observations and Findin s
The licensee submitted the exercise objectives and scenario for NRC review on July 24,
1998. Although the exercise objectives and scenario were considered appropriate to
meet emergency plan requirements (reference NRC letter dated September 22, 1998),
the quality of the scenario package was lacking in the following areas:
~
The exercise objectives were vague and not measurable.
Following the initial
submittal, the exercise objectives were rewritten. The revised objectives were
improved.
~
~ No plume maps/offsite radiological data were provided.
The original security event was not well coordinated with licensee security
personnel and had to be rewritten. Problems with the security event were
identified by the NRC scenario reviewer.
The scenario package did not contain a clear list of simulated actions as
specified by NUREG-0654, Evaluation Criterion N.3.c, and Section 8.1.3.3 of the
In addition to the exercise planning and preparation issues discussed above, the
following aspects of exercise control detracted from the realism and training value of the
exercise:
The process radiation monitor data for the gas decay tank release provided to
the shift technical advisor by a controller was in the wrong units and the units
were not specified. The shift technical advisor appropriately questioned the
validity of the data; however, completion of the initial dose calculation was
unnecessarily delayed.
Weak controller coordination hampered operation of the steam admission valve
for the turbine driven auxiliary feedwater pump. As a result, valve operation was
unrealistic and affected the operator's ability to reinitiate feeding of the steam
'enerators.
Weak controller coordination resulted in delays in c losing the DC control power
knife switches for the emergency core cooling system pump motor breakers and
the racking in of the containment fan cooler breakers.
This situation adversely
affected system response following the loss of coolant accident.
On two separate occasions, the simulator operators provided erroneous
indication of the status of DC control power to 4160V vital Bus G.
-18-
There was some confusion concerning the identification of exercise participants.
The following problems were observed:
(1) the operator identifying the
explosive device had to ask security personnel who the exercise participants
were, (2) while securing areas within the radiological controlled area, security
personnel had to ask plant workers if they were exercise participants, and (3)
access control personnel had to ask if workers were exercise participants.
During a 1:19 p.m. EOF briefing, it was reported that the EOF had simulated
sending the assistant radiological manager to the joint media center.
The
individual remained in the facility, and there was no apparent attempt to call in an
alternate radiological manager to fulfillthe request.
This over-simulated action
was initiated by a participant but was not corrected by controllers.
c.
Conclusions
The originally submitted exercise scenario package was of poor quality because
objectives were vague and not measurable,
offsite radiological plume maps were
missing, a scenario event was not properly coordinated with security personnel and had
to be rewritten, and a list of simulated events was not developed or provided. The
revised objectives were improved.
Some aspects of exercise conduct and control
detracted from the realism and training value of the exercise.
P4.7
Licensee Self Criti ue
Ins ection Sco
e 82301-03.13
The inspectors observ'ed and evaluated the licensee's post-exercise facilitycritiques and
the formal management
critique on November 6, 1998, to determine whether the
process would identify and characterize weak or deficient areas in need of corrective
action.
Observations and Findin s
Post-exercise critiques in the CR, TSC, OSC,.and EOF were generally self-critical and
thorough, with input from participants, controllers, and evaluators.
Inspectors observed
the following exceptions:
In the CR, there was limited input from the exercise participants.
Critique input
was almost exclusively provided by the operations director and the lead
controller. Comments made were predominantly positive.
In the TSC, the critique appeared
to be rushed so that it could be completed
by
5 p.m. As a result, input may have been limited.
Inplant repair team members did not participate in the OSC critique.
-19-
~
The EOF command room critique tended to focus more on positive performance
rather than problem areas needing improvement.
Controllers provided more
input than exercise participants.
During the management
critique, the emergency preparedness
supervisor presented
the
results of the licensee's evaluation process.
The presentation,
accompanied
by a
written report, covered the following topics: exercise summary, performance
competencies,
objectives evaluation, scenario time line, and recommendations.
The licensee identified three weaknesses
in exercise performance:
(1) the objective to
perform offsite agency notifications within applicable time limits was not met, (2) the
objective to perform assembly and accountability per applicable emergency plan
implementing procedures was not met, and (3) the performance competency to dispatch
offsite field monitoring teams from the CR/TSC per emergency plan implementing
procedures was not met. Preliminary recommendations
to correct the weaknesses
were
discussed,
including revisions to certain position checklists and the need to emphasize
procedural adherence
during drills and training.
In addition to the exercise weaknesses,
the licensee identified areas of positive
performance and areas where there were opportunities for improvement.
The strongest
performance was observed in the UDAC. The inspectors concluded that the licensee
had performed a thorough and self-critical evaluation of its performance but noted the
value of increased participant involvement. There was good overlap between the issues
identified by the licensee evaluators and NRC inspectors.
Conclusions
The integrated critique process demonstrated
an effective program for identifying areas
in need of correction, but exercise participants tended to be passive members in the
process.
Post-exercise
critiques, however, were not fully effective because
inplant
repair team members did not participate in the OSC critique, and the CR and EOF
critiques tended to focus more on positive performance and had limited participant
involvement.
In contrast, the management
critique was very thorough and self-critical.
Three weaknesses
were identified along with numerous opportunities for improvement.
Miscellaneous Emergency Preparedness
Issues (92904)
Closed
Ins ection Followu
Item 50-275 323/97022-02: Verify correction of two
emergency action levels.
During the last operational status inspection, the inspector
identified two emergency action levels in Procedure EP G-1, "Emergency Classification
and Emergency Plan Activation," Revision 25, that were not consistent with NRC
approved emergency action level schemes
(Site Area Emergency ¹6 and General
Emergency ¹4). The two emergency action levels were corrected in Revision 28 to EP
G-1, dated September 29, 1998. The licensee issued Revisions 26 and 27 in the interim
but did not correct the two emergency. action levels in either of the revisions.
Given the
severity of the emergency action levels, correction of the two emergency action levels
was considered untimely.
Cp
-20-
V. Mana ement Meetin s
X1
Exit Meeting Summary
The inspectors presented the inspection results to members of licensee management
at the
conclusion of the inspection on November 6, 1998. The licensee acknowledged the facts
presented.
No proprietary information was identified.
The Federal Emergency Management Agency conducted a public meeting in San Luis Obispo,
California, on November 6, 1998.
Federal Emergency Management Agency representatives
presented preliminary results of evaluated offsite performance.
ATTACHMENT
SUPPLEMENTAL INFORMATION
PARTIALLIST OF PERSONS CONTACTED
Licensee
D. Adams, Supervisor, Nuclear Quality Services
R. Bliss, Emergency Preparedness
Coordinator
R. Cheney, Quality Engineer, Nuclear Quality Services
S. Fridley, Manager, Outage Services
R. Gray, Director, Radiation Protection
A. Halverson, Emergency Preparedness
Coordinator
D. Johnson, Health Physicist
S. Ketelsen, Supervisor, Regulatory Services
M. Lemke, Supervisor, Emergency Preparedness
D. Marsh, Emergency Preparedness
Coordinator
J. Molden, Manager, Operations Services
R. Morris, Emergency Preparedness
Coordinator
D. Oatley, Vice President and Plant Manager
M. Snyder, Emergency Preparedness
Coordinator
E. Waage, Senior Engineer, Emergency Preparedness
NRC
D. Acker, Resident Inspector
D. Proulx, Senior Resident Inspector
LIST OF INSPECTION PROCEDURES USED
Evaluation of Exercises at Power Reactors
Review of Exercise Objectives and Scenarios for Power Reactors
Followup - Plant Support
LIST OF ITEMS OPENED AND CLOSED
~oened
50-275; 323/98015-01
IFI
Failure to activate the TSC and EOF in a timely manner
(Section P4.5)
50-275; 323/98015-02
Closed
IFI
Failure to make a timely offsite agency notification
(Section P4.5)
50-275; 323/97022-02
IFI
Verify correction of two emergency action levels (Section
P8)
-2-
LIST OF DOCUMENTS REVIEWED
Emer enc
Plan lm lementin
Procedures
EP EF-2
EP EF-3
EP G-1
EP G-2
EP G-3
EP G-4
EP G-5
EP MT-27
R-2'P
RB-1
EP RB-3
EP RB-5
EP RB-10
EP RP-4
Activation and Operation of the Operational Support
Center
Activation and Operation of the Emergency
Operations Facility
Emergency Classification and Emergency Plan.
Activation
Activation and Operation of the Interim Site
Emergency Organization (Control Room)
Notification of Off-site Agencies and Emergency
Response Organization Personnel
Personnel Assembly, Accountability and Site
Access Control During Emergencies
Evacuation of Nonessential Personnel
Technical Support Center Emergency Equipment
Inventory
Release of Airborne Radioactive Materials Initial
Assessment
Personnel Dosimetry
Stable Iodine Thyroid Blocking
Personnel Contaminations
Protective Action Recommendations
Access to and Establishment of Controlled Areas
Under Emergency Conditions
Revision 19
Revision 12
Revision 28
Revision 20
Revision 29A
Revision 16C
Revision 6B
Revision 0
Revision 19C
Revision 5B
Revision 3
Revision 4A
Revision 6
Revision 4A
Other Documents
Diablo Canyon Nuclear Power Plant Emergency Plan, Revision 3, Changes
16 and 17
RP1.ID3, Respiratory Protection Program, Revision 3
GRRA-500i, Student Handout for Respiratory Protection, November 1997
Emergency Response
Organization Bi Annual (sic) Graded Exercise Management Summary
November 4, 1998