ML17228A229

Details of these

observations

are presented

in Paragraph

8.

No violations or deviations

were identified.

Emergency

Response .Support

and Resources

(82301)

This area

was observed to determine

whether arrangements

for requesting

and effectively using assistance

resources

were made,

whether

arrangements

to accommodate

State

and local personnel

at the

EOF were

adequate,

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

and guidance

promulgated

in Section II.C of NUREG-0654 (Revision 1).

The inspector

noted that the

REP and

EPIPs identified other

organizations

capable of augmenting

the planned

response.

Licensee

involvement

and contact with Federal,

State,

and local support

organizations

occurred in accordance

with applicable

EPIPs

and were

consistent with the scope of the exercise.

Assistance

resources

from

local offsite support

agencies

were available to the licensee

and were

tested during the exercise

in the cases

of the local

ambulance

service,

which was called to treat

and transport

a contaminated

injured worker,

and the

Lawnwood Regional

Medical Center,

where the subject individual

was further treated

and decontaminated.

These activities were not

observed

by the inspectors.

No violations or deviations

were identified.

Emergency Classification

System

(82301)

This area

was observed to verify that

a standard

emergency

classification

and action level

scheme

was in use

by the licensee

as

required

by 10 CFR 50.47(b)(4)

and Paragraph

IV.C of Appendix

E to

and to determine

whether that

scheme

was adequately

implemented.

An EAL matrix was available in EPIP-3100022E,

"Classification of

Emergencies,"

(Revision 21,

approved

September

18,

1992) to identify and

properly classify

an emergency

and escalate it to more severe

classifications if warranted

by the progression

of the accident..

The

licensee's

use of the

EALs in deriving each of the emergency

classifications

was methodical

and appropriately conservative,

with

results

as follows:

~

The initial classification

was Alert, based

upon exceeding

the

applicable

EAL for RCS iodine activity.

The Alert was declared

at

4:03 a.m.

by the

NPS,

who at that time became

the interim EC.

At 6: 18 a.m., the

EC (at the

TSC, which was activated at

5:08 a.m.) declared

a Site Area Emergency

based

on the occurrence

of a

LOCA greater

than charging

pump capacity.

At 7: 16 a.m., the

EC declared

a General

Emergency

based

on loss of

two of the three=fission

product barriers with imminent loss of

the third.

The declarations

of emergency classifications

during the exercise

were

timely and consistent with the procedurally defined

EALs.

No violations or deviations

were identified.

Notification Hethods

and Procedures

(82301)

This area

was observed to determine

whether procedures

had

been

established

for notification by the licensee of State

and local response

organizations

and emergency

personnel,

and the content of initial and

follow-up 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)

and Paragraph

IV.D of Appendix

E to 10 CFR Part 50.

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 implementing procedures

for

notifications

had

been established

and were-adequate

to provide guidance

to personnel

for initial notification to State

and local authorities of

each

emergency declaration.

The notifications made during the exerc'ise

were timely and provided the appropriate

information to offsite

authorities.

However,

a performance

problem was identified with respect

to follow-up notifications.

EPIP-3100031E,

"Duties and Responsibilities

of the

Emergency Coordinator"

(Revision 29,

approved

January

15,

1993),

specified that offsite authorities

would be updated

regarding

any

significant changes

in plant conditions,

and that appropriate

notification forms would be used for all updates

(reference:

"Note"

appearing

on pages

18 and 22).

However, offsite authorities

were not

informed of a plant shutdown which commenced shortly after the Alert

'eclaration.

Licensee representatives

agreed that

an update

should

have

been

issued

when the shutdown

was initiated,

and identified this during

the critique as

a performance deficiency requiring corrective action.

Furthermore,

during the player critique at the

EOF,

a representative

of

the State of Florida expressed

concern that

no updates

had

been provided

to the State

between

4: 12 a.m.

and 6:25 a.m.

(the notification times for

the Alert and Site Area Emergency declarations,

respectively).

These exercise

issues

prompted

an

NRC review of the

REP commitments

and

procedural

requirements

with regard to updates

during an emergency

situation.

Section

3 of the

REP, stated that licensee

actions at

a

classification of Alert or higher would include the'following:

"Provide

periodic plant status

updates

in accordance

with plant procedures."

Section 4.2. 1 of the

REP stated

the following with respect

to

communications with the State Division of Emergency

Management:

"The

initial notification may be brief with certain information not

available.

Follow-up messages

from the

Emergency Coordinator to the

Division of Emergency

Management will include the required information

as it becomes available...

The Emergency Coordinator will maintain

periodic contact with the State

Warning Point, located at the State

EOC

in Tallahassee,

via the Hot Ring Down network."

The inspector

determined that the licensee's

previously delineated

procedural

requirement for plant status

updates

did not appear to be consistent

with the intent of the approved

Plan,

NRC guidance,

or industry

practice.

As noted

above,

the

REP required "periodic" updates,

but the

EPIPs did not establish

any fixed or variable time interval that would

implement the commitment to such periodicity.

NRC guidance states that

periodic updates

should occur "at least every

15 minutes" at the Alert

classification

(NUREG-0654,

Appendix 1,

page 1-8).

Standard practice at

most nuclear

power plants (including the licensee's

other nuclear plant,

Turkey Point) requires

updates

at

a periodicity of 30-60 minutes.

Licensee

management

agreed to review the applicable

guidance

and

requirements,

and to discuss this matter with cognizant State

representatives,

in order to ensure

at

a minimum that all parties

clearly understand

what is meant

by "significant changes"

in

plant'onditions.

Completion of the licensee's

corrective action for this

matter will be tracked

as

an IFI.

IFI 50-335,

50-389/93-16-02:

Reviewing

REP and

EPIP guidance

and

requirements

related to the provision of periodic plant status

updates

to offsite authorities during an Alert or higher emergency

classification.

EPIP-3100021E

contained in Section 4.0

a list of precautions,

one of

which stated

the following with respect

to offsite notifications:

"If

one unit is in

a classified

event

and the

same or the other unit enters

into an event where the

same or lesser

emergency class

would apply,

a

new classification

should

NOT be declared.

The event should

be issued

as

a update at the earliest practical time.

No regulatory time limits

would apply to the update."

The inspector indicated during discussions

with licensee

representatives

that the last sentence

of this

precautionary

statement

did not appear to constitute

appropriate

guidance,

and noted that it was not based

on any specific commitment or

specification

in, the Emergency

Plan'.

Licensee

management

agreed to

evaluate

the prudence of this approach.

This matter will be tracked

as

an'FI.

IFI 50-335,

50-389/93-16-03:

Evaluating procedural

requirements

with.

respect to conveying information to offsite authorities regarding

classifiable incidents of lesser severity occurring during

an extant

emergency classification.

No violations or deviations-were identified.

Emergency

Communications

(82301)

This area

was observed to verify that provisions existed for prompt

communications

among principal response

organizations

and emergency

personnel.

Requirements

applicable to this area

are found in

10 CFR 50.47(b)(6),

Paragraph

IV.E of Appendix

E to

and

the

The inspector

observed that adequate

communications capability existed

with offsite authorities,

as well

as

between

and

among the licensee's

emergency

organizations

and personnel,

with one significant exception.

Because of lack of attention to detail, the automated

system for

notifying EOF personnel

was not properly configured to achieve

an

expeditious call-out (this was not an exercise artificiality).

As

a

result,

the time required to make the

EOF operational

was excessive.

This issue is discussed

further in Paragraph

B.d, below.

No violations or deviations

were identified.

Emergency Facilities

and

Equipment

(82301)

This area

was observed

to determine

whether adequate

emergency

facilities and equipment to support

an emergency

response

were provided

and maintained

as required

by 10 CFR 50.47(b)(8), 'Paragraph

IV.E of

Appendix

E to

and the

Emergency Operations Facility

The inspector

observed activation, staffing,

and operation of the

ERFs

as well

as the use of equipment therein.

ERFs used

by the licensee

during the exercise

included the Control

Room simulator,

TSC,

OSC,

EOF,

and

ENC.

a 4

Control

Room Simulator

The Control

Room simulator was used in lieu of the actual

Control

Room for the exercise.

Emergency

communications

equipment 'that

had

been installed in the simulator functioned effectively to

fully support the initial emergency

response

prior to the turnover

of communications

to the TSC.

The

NPS was very decisive in

declaring the Alert upon receipt of coolant chemistry

sample

results

which indicated elevated

iodine levels.

He was likewise

firm in making the decision to commence

a plant .shutdown,

and i'

directing his crew in that evolution.

His turnover of duties to

the designated

EC at the

TSC was very thorough.

The entire Control

Room simulator crew functioned extremely well

in terms of coordinating operations

and emergency

response

activities.

The crew's professionalism

extended to details

such

as: (I) correcting the improper communications

protocol

used

by

some field personnel

reporting their in-plant. component

manipulations,

(2) warning

HP and .Auxiliary Operator personnel

of

suspected

increases

in plant radiation levels which would be

caused

as

systems

were configured for the plant shutdown,

and

(3) maintaining excellent log-keeping practices.

Technical

Support Center

The inspector

observed

the initial activation

and personnel

response

in the staffing of the

TSC for this off-hour exercise.

The process of notifying personnel

to report to the plant to staff

the

TSC began within about five minutes of the Alert declaration.

In the absence

of specific licensee

acceptance

criteria associated

with the indeterminate

commitment in the

Emergency

Plan to "staff

the

TSC in a timely manner"

(Section 2.4.2)

and exercise

objective C.3 *to "Demonstrate

the timely activation of the

Technical

Support Center...;"

the inspector

used

NRC guidance

in

Supplement

I to NUREG-0737 to formulate acceptance

criteria

relative to the timeliness of TSC activation.

This guidance

specifies that the

TSC is to be staffed

by appropriate technical,

engineering,

and senior

management

personnel

and fully operational

'ithin

approximately

one hour after activation of the facility is

required

(item 8.2. l.j).

The

TSC was declared

operational

at

5:08 a.m.,

65 minutes after the Alert declaration.

This result

was considered

to be consistent with the referenced

equivocal

Plan

commitment

and exercise objective,

as interpreted

above.

Facility personnel

appeared

to be cognizant of their emergency

duties, authorities,

and responsibilities.

The periodic (every

30 minutes)

TSC briefings were short

and to the point, thus

allowing personnel

maximum time to perform productive work between

briefings.

No major technical

errors

were noted in any of the

several

briefings observed.

There were

no major facility or

equipment

problems identified at the

TSC during the exercise.

Operational

Support Center

The

OSC was activated in a timely manner

and was declared

operational

60 minutes after the Alert declaration.

Initial

response

was

by on-shift personnel,

who accomplished

most of the

physical

OSC room set-up,

including tables,

chairs,

and

telephones.

A new room arrangement

diagram

and activation

checklist aided in the

OSC activation.

Dispatch

and control of emergency repair teams

and other

postevacuation

re-entry teams

were notably improved in comparison

with the

1992 exercise.

Improvements

included:

Re-Entry Team

Request

Forms (including task description,

special

instructions,

communication

methods,

and

OSC supervisor approval);

streamlined

HP forms; better preparation of standby personnel

awaiting team

assignments

(dressed

out in anticontamination'clothing,

provided

with dosimetry);

and rearrangement

of OSC tables

(improving

command

and control

by providing better supervisor

access

to other

OSC personnel).

In general,

teams, were dispatched

from the

OSC in

a timely manner.

Priority teams

were clearly identified on the

team status

board,

and teams

were well controlled.

The following

inspector observations

suggested

possible

areas for improvement:

One priority team (the first aid team)

was dispatched

significantly faster than all of the others.

Three other

priority teams

were not dispatched

in a significantly

expedited

manner

as

was the first aid team.

~

Two persons

on re-entry teams

were not on the

OSC personnel

accountability forms.

~

Re-entry team

10 (the first aid team) did not go out the

designated

OSC building door.

Team personnel

.bypassed

the

HP control point at that door and were not listed

on the

Emergency

Access Control

Log Sheet.

~

Some re-entry teams returned to the

OSC via the

HP control

point door

and their return

was logged in the

Emergency

Access Control

Log Sheet.

The return of some re-'entry teams

to the

OSC was not logged in the

Emergency 'Access

Control

Log Sheet;

apparently they returned to the

OSC via another

route

and did not report back to the

HP control point.

Early in the exercise,

the

OSC Supervisor

had announced

to

all'OSC personnel

that re-entry teams

were to leave the

OSC

building via the plant side door

(wher'e the

HP control point

was located),

and that teams

were to return to the

OSC

building via another route,

through the garden'side

door.

The injured contaminated

individual was handled well, including

prompt response

by a first aid team,- good contamination control,

and timely transport

from the site by ambulance.

Since the February

1992 exercise,

the licensee

had taken several

steps to designed to improve the activation time for the

A

computer-based

system for notifying EOF personnel

via pagers

was

acquired,

and

a "minimum staffing" concept

(using

a core staff of

0

six persons

plus

a Recovery

Manager) for the Alert level

was

implemented.

The latter measure

entailed anticipatorily

commencing the process of activating the

EOF upon

an Alert

declaration

in order to increase

the likelihood that the facility

would be operational

within about

one hour after

a Site Area

Emergency declaration.

However, the licensee

recognized that this

"cushion" would not be available if the initial classification of

an event were Site Area Emergency or General

Emergency.

The inspector

observed

the initial activation

and personnel

response

in the staffing of the

In the absence

of specific

licensee, acceptance

criteria associated

with the indeterminate

commitment in the Emergency

Plan to "activate the

EOF in a timely

manner"

(Section 2.4.5)

and exercise objective C.4 to "Demonstrate

the timely activation of the Emergency Operations Facility by

Initial Staffing personnel,"

the inspector

used

NRC guidance

in

Supplement

1 to NUREG-0737 to formulate acceptance

criteria

relative to the timeliness of EOF activation.

This guidance

specifies that the

EOF is to be staffed

by a designated

senior

licensee

manager

and appropriate technical staff within one hour

(item 8.4. l.i).

By the licensee's

new methodology,

the process

of

minimum staffing of the

EOF was to commence

upon declaration of an

Alert.

However, the computer-based

paging

system

was erroneously

set

up in a "drill mode" whereby the recorded

message

heard

by

individuals calling the designated

telephone

number in response

to

the page indicated that they were not required to report to the

This was the message

associated

with a "notification only"

drill, and generated

confusion

on the part of the exercise

players,'lthough

ultimately all members of the

"minimum staff"

except the Recovery

Manager

(who was

based

at the corporate office

in Juno

Beach rather than the plant) reported to the

EOF within

about

one hour.

The inspector determined that the licensee's

demonstrated

level of preparedness

to activate the

EOF at the time

of this exercise

could have precluded effective implementation of

the Emergency

Plan in the event of an actual

emergency.

The

EOF

was declared

operational

at 5:52 a.m.,

109 minutes after the Alert

declaration.

This result

was not considered

to be consistent with

the referenced

equivocal, Plan commitment

and exercise objective,

as interpreted

above.

During the exit inter'view, the inspector

commended

the licensee's

efforts to improve the physical

capability to activate the

EOF, since this process

has

historically 'been problematic for the St. Lucie Plant,

but noted

that further system refinements

and practice drills were in order.

The licensee's

failure to demonstrate

timely activation of the

EOF

by initial staffing personnel

was determined to constitute

an

exercise

weakness,

for which corrective action is required.

k

Exercise

Weakness

50-335,

50-389/93-16-04:

Failure to activate

the

EOF in a timely manner.

After the

EOF was finally activated,

operations

there principally

involved support to the plant emergency

organization

and interface

10

with cognizant

governmental

authorities;

those tasks

were

accomplished

capably.

The facility was well designed

and

equipped,

enhancing

the staff's capability to support

and

augment

the response

to the simulated

emergency.

The

RN efficiently

coordinated activities

and provided verbal status

reports to the

staff approximately every 30 minutes.

Communications with other

ERFs were reliable.

Status

boards

and other graphic aids were

strategically located

and well maintained.

e.

Emergency

News Center

Activities at the

ENC were not observed

by the

NRC during this

inspection.

One exercise

weakness,

no violations,

and

no deviations

were identified.

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),

Paragraph

IV.B of Appendix

E to

and

the

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.

The major radiological release

in the exercise

scenario

consisted

of a 45-minute release

from containment via the

containment

purge inlet line 48-inch valves.

Dose projections

performed

between

about 7:00 a.m.

and 7:45 a.m., in both the

TSC and the

EOF, were

based

upon

FSAR design basis

containment

leakage rates at elevated

pressure.

The release

rates

computed

by the dose

assessment

code were

approximately

F 7 E-3 Ci/sec iodines

and 4.5 E-2 Ci/sec noble gases.

Simple calculations

would have

shown that one to two containment

volumes

at

STP were released

via an unfiltered path to the environment during

that period (per the scenario

containment

pressure

data).

This

magnitude of release

would have resulted

in the following approximate

release

rates

over the 45-minute period:

Iodine:

1 to

10 Ci/sec

Noble Gas:

10 to 100 Ci/sec

The licensee's

"Emergency

Dose Calculation System"

computer

code

had the

capability for =operators to insert computed release

rates,

but both the

EOF and

TSC operators

chose to select

a default

LOCA program from the

menu which assumed

design basis

containment

leakage.

No one in either

facility seriously questioned

the results,

probably because

the scenario

field monitoring data

had apparently

been

computed using the

same or

similar improper assumptions

and methods

(see

Paragraph

2).

Had this

scenario

been

a real event,

the

TSC and

EOF would have underestimated

the field doses

by about two to three orders of magnitude

(based

on

in-plant parameters

such

as containment

pressure,

containment radiation,

0

and reactor coolant chemistry).

Ideally, field monitoring results

would

always

be immediately available

as

a means of verifying the accuracy of

dose projection assumptions,

but

a licensee

should

be able to make

initial dose projections

based

only on plant parameters.

Although this

appeared

to be substantially

a repeat of a finding from the

1992

exercise

(see

Paragraph

12.c), significant scenario

discrepancies

(as

previously discussed)

precluded

a reliable determination

as to whether

the observed

player performance

problems

were real or artificial (i.e.,

scenario-induced).

The licensee's

performance

in the area of dose

assessment

will be reviewed during

a future exercise.

This issue will

continue to be tracked

as IFI 50-335,

389/92-01-02.

No violations or deviations

were identified.

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

a'

required

by 10 CFR 50.47(b)(10)

and the

The inspector verified that the licensee

had emergency

procedures for

formulating

PARs for the offsite populace within the ten-mile

EPZ.

Protective actions

were quickly formulated

and provided to the State

and

local authorities at the

EOF within 15 minutes of the declaration of the

General

Emergency.

Accountability was accomplished satisfactorily

within 30 minutes;

evacuation of nonessential

personnel

was simulated.

No violations or deviations

were identified.

Exercise Critique (82301)

The licensee's

critique of the emergency

exercise

was observed to

determine

whether weaknesses

or deficiencies identified during the

performance of the exercise

were formally presented

to licensee

management

and documented for corrective action

as required

by

10 CFR 50.47(b)(14),

Paragraph

IV.F of Appendix

E to

and

the