ML17284A784
| ML17284A784 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 10/08/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17284A782 | List: |
| References | |
| 50-397-98-18, NUDOCS 9810140214 | |
| Download: ML17284A784 (32) | |
See also: IR 05000397/1998018
Text
ENCLOSURE
U.S. NUCLEAR REGULATORYCOMMISSION
REGION IV
Docket No.:
License No.:
Report No.:
Licensee:
Facility:
Location:
Dates:
Inspector(s):
Approved By:
Attachment:
50-397
50-397/98-18
Washington Public Power Supply System
Washington Nuclear Project-2
Richland, Washington
September
15-1 8, 1998
Gail M. Good, Senior Emergency Preparedness
Analyst, Team
Leader
Thomas H. Andrews, Jr., Emergency Preparedness
Analyst
Francis L. Brush, Resident Inspector (Callaway)
Louis C. Carson II, Health Physicist
J. Blair Nicholas, Ph.D., Senior Radiation Specialist
Blaine Murray, Chief, Plant Support Branch
Division of Reactor Safety
Supplemental Information
98iOi402i4 981008
ADQCK 05000397
8
-2-
EXECUTIVE SUMMARY
Washington Nuclear Project-2
NRC Inspection Report 50-397/98-18
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, operations support center, and emergency operations facility.
Plant Su
ort
Overall, performance was good. The control room (CR), technical support center
(TSC), and emergency operations facility (EOF) successfully implemented most
essential emergency plan functions including classification, protective action
recommendations,
and dose assessment.
The CR staff's performance was very good. The initiating emergency event was
promptly recognized and properly classified.
Corresponding offsite agency notifications
were timely. Operators quickly recognized changing plant conditions and took
appropriate corrective actions.
Three-part communications were consistently used, and
good periodic briefings were conducted (Section P4.2).
The TSC staff's performance was good. Changing plant conditions were promptly and
correctly analyzed to support EOF emergency classifications.
Staff briefings and
technical discussions were effective.
Some key technical issues, including recirculation
pump vibration, reactor coolant makeup and leak rate, and standby gas treatment
performance were not aggressively pursued.
The method used to assign and track
repair team priorities was unclear and hampered the operations support centers,
(OSCAR ability to manage repair team resources.
Habitability was challenged because:
(1) the outer airlock door was not fullyclosed, (2) at least one person did not frisk prior
to reentry, and (3) emergency ventilation system operation was not verified until late in
the exercise (Section P4.3).
The OSC staff's performance was generally satisfactory.
An exercise weakness was
identified for failure to properly monitor habitability. Airborne, contamination, and area
surveys were either never performed or were not regularly performed in all OSC areas.
The fire brigade's performance was degraded because
the respoiise was delayed and
some fire-fighting actions were inappropriate.
The OSC was activated in a timely
manner.
Three-part communications were frequently used.
Facility briefings were
frequent and contained sufficient detail. Health physics briefings tended to delay repair
team dispatch because only one person conducted the briefings. The process used to
select field team members for tasks requiring self-contained breathing apparatus did not
verify corrective lense availability. Repair team documentation was incomplete and
could have affected airborne dose reconstruction.
There was no emergency lighting
installed in the OSC, although emergency electrical generators were available.
Appropriate corrective actions were taken to address the lack of battery-powered air
samplers.
Public address announcements
and station alarms could not be heard in all
-3-
areas of the plant. A health physics emergency locker contained degraded supplies and
insufficient quantities of protective clothing (Section P4.4).
The EOF staff's performance was good.
Emergency classifications and protective
action recommendations
were correct and timely. Offsite agency notifications were
timely with one licensee-identified exception.
The Department of Energy notification for
the site area emergency was slightly delayed due to the loss of the primary notification
system and incorrect backup telephone numbers.
One notification form was not
properly completed; the date and time were omitted from the site area emergency
notification form. The error was quickly recognized and verbally corrected.
A
discrepancy between the emergency plan and implementing procedures was identified
concerning followup notifications. Appropriate corrective actions were taken to resolve
the discrepancy.
Dose assessment
and field team control activities were properly
performed to support protective action recommendations
and validate dose projections.
Interactions with offsite agency representatives
were candid and supportive
(Section P4.5).
The exercise objectives were appropriate to meet emergency plan requirements.
The
initiallysubmitted scenario was not acceptable because
offsite doses were not
challenging and would limitdemonstration of some exercise objectives.
Projected
offsite doses were increased to an acceptable
level in the revised scenario; however,
the scenario developers incorrectly computed the offsite field team sample data.
As a
result, the offsite doses were not consistent with expected projected doses and did not
challenge the dose assessment
staff, field team members, and decision-makers.
Scenario development has been a historical problem.
In addition, the scenario
developers failed to recognize that the loss of offsite power would affect OSC
operations.
Last minute contioller instructions and impromptu controller actions during
the exercise were thorough and conscientious (Section P4.6).
The post-exercise and management
critiques were thorough and self-critical. The
critique process effectively identified positive performance and areas that needed to be
corrected or improved (Section P4.7).
-4-
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
September
16, 1998. The exercise was conducted to test major portions of the onsite
(licensee) and offsite emergency response facilities. The licensee activated its
emergency response organization and all emergency response facilities. The Federal
Emergency Management Agency evaluated the offsite response capabilities of the
states of Washington and Oregon, and Benton and Franklin counties.
The Federal
Emergency Management Agency willissue a separate
report.
The exercise scenario was run using the CR simulator in an interactive mode. The
exercise scenario began at about 8:15 a.m. with the plant at 75 percent power; Standby
Gas Treatment System A, the Emergency Diesel Generator 2 motor driven air
compressor, and offsite power for the back-up transformer were out of service.
At 8:20 a.m., the CR received a report of a fire located in Low Pressure Core Spray
Pump 1. The fire brigade was promptly dispatched.
At 8:22 a.m., the shift manager
declared an alert due to a fire in a safeguards
building with confirmed damage.
Announcements were made to activate the emergency response facilities.
At 8:50 a.m., the CR received an alarm indicating that the startup transformer locked
out. This removed the second source of offsite power since the backup transformer was
out of service.
At 9:35 a.m., the CR received indications of a reactor water cleanup system leak outside
the primary containment., The reactor water cleanup system pump suction containment
isolation valves failed to close.
At 9:40 a.m., the CR received a vibration alarm on
Reactor Recirculation Pump 1A and a loose parts monitor alarm. The loose parts
monitor alarm was due to reactor coolant pump impeller damage.
Pieces of the impeller
entered the reactor vessel and caused flow restriction to several fuel assemblies.
At 9:54 a.m., the CR operators scrammed the plant due to an unisolable leak outside
the containment from the reactor water cleanup system.
At 9:55 a.m., Diesel
Generator 2 failed to start when the starting air system piping ruptured.
At 9:54 a.m., the EOF manager/emergency
director declared a site area emergency due
to an unisolable leak outside containment as indicated by any temperature or radiation
exceeding maximum safe operating values.
At 9:57 a.m., primary containment pressure
reached 1.68 psig.
At 10:37 a.m., the high pressure core spray emergency diesel failed. At 11:16 a.m.,
reactor water level decreased
to the top of active fuel. At 11:18 a.m., the EOF
manager/emergency
director declared a general emergency.
-5-
At 11:38 a.m., power to the startup transformer was restored.
Power was then made
available to Residual Heat Removal Pumps 2B and 2C. The pumps auto-started and
restored water level in the reactor vessel.
At 1:41 p.m., the reactor water cleanup system was isolated which terminated the
reactor coolant system leak outside containment.
At 1:42 p.m., plant stack radiological
monitor readings began to decrease.
The exercise was terminated at about 3 p.m.
Control Room
CR
Ins ection Sco
e 82301-03.02
The inspectors observed and evaluated the CR simulator staff as they performed tasks
in response to the exercise scenario conditions.
These tasks included event detection
and classification, analysis of plant conditions, offsite agency notifications, internal and
external communications, and adherence
to the emergency plan and procedures.
The
inspectors reviewed applicable emergency plan sections and procedures, operations
procedures,
logs, and notification forms.
Observations and Findin s
The inspectors observed that the CR staff was attentive to plant parameters,
promptly
recognized changing plant conditions, and took appropriate corrective actions.
Emergency action levels were correctly used to classify the alert condition (fire). Plant
personnel were immediately informed of the fire and the need to evacuate the reactor
building. The fire brigade was assembled
and responded to the fire. State, local, and
NRC notifications were made within required time limits.
The shift manager exhibited very good command and control. The shift manager and
CR supervisor held frequent and detailed briefings. The transfer of command and
control to the EOF was timely (45 minutes after the alert declaration).
The shift
manager promptly announced emergency response facilityactivation status and
the'ransfer
of emergency director duties; however, the site area emergency was not
announced
in the CR.
CR personnel consistently used three-part communications.
The CR operators used
self-checking and peer-checking techniques when manipulating plant equipment.
Control room personnel exhibited good teamwork and coordinatio,i. Communications
between the CR and TSC were clear and focused.
The shift technical engineer made timely offsite agency notifications following the alert
declaration and was an effective member of the CR team.
Personnel accountability was
maintained throughout the exercise.
With one exception, operators maintained good awareness
of plant conditions. The
operators failed to observe an annunciator on the standby gas treatment system
(moisture alarm). As a result, the other emergency response facilities were not aware
0
-6-
that the system was operating in a degraded fashion.
The licensee discussed corrective
actions for this issue during the facilitycritique.
Conclusions
The CR staff's performance was very good. The initiating emergency event was
promptly recognized and properly classified.
Corresponding offsite agency notifications
were timely. Operators quickly recognized changing plant conditions and took
appropriate corrective actions.
Three-part communications were consistently used, and
good periodic briefings were conducted.
Technical Su
ort Center TSC
Ins ection Sco
e 82301-03.03
The inspectors observed and evaluated the TSC staff as they performed tasks
necessary to respond to the exercise scenario conditions. These tasks included staffing
and activation, accident assessment,
personnel accountability, habitability monitoring,
facility management
and control, onsite protective action decisions and implementation,
internal and external communications, assistance
and support to the CR, and
prioritization of mitigating actions.
The inspectors reviewed applicable emergency plan
sections, procedures, and logs.
Observations and Findin s
The TSC was rapidly activated after the 8:22 a.m. alert declaration.
The TSC had the
minimum staff required to operate within 22 minutes. When full staffing was achieved
after 30 minutes, the TSC manager declared the TSC operational.
The TSC staff
signed in on the TSC staffing board and the accountability log as required by
Procedure 13.10.7, "Plant Administrative Manager Duties," Revision 16. TSC personnel
promptly established co'mmunications with the CR, G~~, and EOF. TSC management
effectively communicated with TSC staff, and the TSC manager demonstrated
effective
command and'control of TSC operations.
Briefings were frequent and included input
from key TSC positions.
The TSC staff generally analyzed and evaluated plant conditions in a timely and
effective manner.
However, the staff did not aggressively pursue three key technical
issues, such as, the recirculation pump vibration, reactor coolant makeup and leak rate,
arid standby gas treatment performance monitoring. First, at 9:50 a.m., the plant status
board showed that reactor recirculation pump RRC-P-1A was vibrating. At 11 a.m., the
TSC staff removed the pump vibration information from the status board; however, the
pump vibration was never investigated.
Second, after the TSC staff established
a
source to makeup reactor coolant and mitigate core damage, the staff did not determine
why reactor coolant inventory continued to be lost. The r'ate of reactor coolant loss was
not determined until the NRC senior resident asked.
The TSC staff estimated that the
reactor coolant leak rate was 350 gallons per minute but never correctly identified the
source of the coolant leak.
Finally, the TSC staff did not monitor the performance of the
0
-7-
standby gas treatment system even after the EOF reported that offsite iodine
concentrations were increasing.
The methods used by the TSC staff to assign and track repair team priorities were
unclear and hampered the OSC's ability to manage repair team resources.
Terms such
as Priority 1, 2, 3, urgent, and more urgent were used.
At times, TSC priorities and
OSC repair team assignments
did not correlate.
Consequently, the TSC may have
delayed the accomplishment of key accident mitigation and repair team tasks.
Some aspects of TSC operations challenged habitability. Procedure 13.10.4, "Radiation
Protection Manager Duties," Revision 16, Section 3.1.6, required that the radiation
protection manager establish, monitor, and maintain the TSC habitable if radiological
conditions warranted.
At 9:36 a.m., the TSC received a report that the reactor water
cleanup system was leaking into secondary containment.
At 9:40 a.m., the radiation
protection manager instructed a health physics technician to establish TSC habitability
by: (1) placing a frisker at TSC door N3, (2) ensuring that the TSC airlock door (N2)
remained sealed to maintain environmental integrity, (3) ensuring that the TSC radiation
monitor was activated, and (4) ensuring that the TSC emergency ventilation monitor was
Although the health physics technician initiallyestablished habitability in a timely manner
(by 9:55 a.m.), continued habitability was threatened by the following conditions:
(1) on
at least on occasion, the health physics technician did not frisk upon reentering the TSC;
(2) the TSC airlock door (N2) was ajar at times (the door would not completely close
without aid); and (3) the TSC emergency ventilation system was not verified as
operating until 11:51 a.m. (a relatively minor release began at 9:54 a.m., and a more
significant release began at 11:18 a.m.). This issue was not considered an exercise
weakness because
habitability was being monitored and the ventilation system was
operating in the isolation mode.
Conclusions
The TSC staff's performance was good. Changing plant conditions were promptly and
correctly analyzed to support EOF emergency classifications.
Staff briefings and
technical discussions were effective. Some key technical issues, including recirculation
pump vibration, reactor coolant makeup and leak rate, and standby gas treatment
performance, were not aggressively pursued.
The method used to assign and track.
~
repair team priorities was unclear and hampered the OSC's ability to manage repair
team resources.
Habitability was challenged because:
(1) the outer airlock door was
not fullyclosed, (2) at least one person did not frisk prior to reentry, and (3) emergency
ventilation system operation was not verified until late in the exercise.
0 erations Su
ort Center
Ins ection Sco
e 82301-03.05
The inspectors observed and evaluated the OSC staff as they performed tasks in
response to the scenario conditions. These tasks included the fire brigade response,
-8-
facilityactivation and staffing, and inplant emergency repair team dispatch and
coordination in support of CR and TSC requests.
The inspectors reviewed applicable
emergency plan implementing procedures,
logs, checklists, and forms.
b.
Observations and Findin s
The fire brigade's response to the fire in the low pressure core spray pump room was
. degraded; the response was delayed and team member safety was potentially
jeopardized.
Observations included:
Prior to attacking the fire, the fire brigade determined that 100 feet of hose was
too much hose and removed a 50-foot section.
This determination was made
without measuring the distance to the door and determining how much hose was
needed inside the room with the fire. Once in the room, the fire brigade could
only attack the fire from one side of the pump and had to exit the room to add
the 50-foot section of hose which had previously been removed.
Entry into the room with the fire was delayed because
one fire brigade member
responded to the scene without fire-fighting attire. This individual was needed to
fillthe backup/rescue
fire brigade team.
~
The first attempt to fight the fire was made without adequate backup.
The fourth
fire brigade team member did not arrive until after the first attempt (the one
made with insufficient hose).
The fourth fire brigade team member arrived at the
fire scene prior to donning the self-contained breathing apparatus face piece,
hood, and helmet.
The licensee made similar observations and stated that the fire brigade's performance
was under review by the station fire marshal.
While the fire brigade's performance was
not fullysatisfactory and personnel safety was potentially jeopardized by the attempt to
fight the fire without proper backup, the matter was not considered to be an e~~rcise
weakness because personnel entering the area of the fire were properly attired with
protective clothing.
The fire in the low pressure core spray pump room led to an alert declaration and
emergency response facilitystaffing. The OSC was promptly activated (within
30 minutes of the alert declaration).
Since the OSC command area was routinely used
as a lunch room, tables and chairs had to be rearranged for facility use.
Upon arrival,
craft personnel and functional area leads recorded arrival times on the personnel status
board and quickly setup the facility equipment.
The OSC manager demonstrated
good command and control. Three-part
communications were frequently used, and briefings were frequent and contained
sufficient detail. Information sharing within the OSC was timely, and status boards were
well maintained.
-9-
In contrast, habitability monitoring of the OSC was inadequate to prevent or limitfacility
contamination and minimize personnel exposures.
Observations included:
Habitability surveys (airborne, contamination, and area surveys) were either
never performed or were not regularly performed in all areas occupied by OSC
personnel.
Maps were not used to identify areas surveyed, and different health
physics technicians surveyed different areas.
Survey documentation was
unclear since only one dose reading was recorded for all the areas surveyed.
The continuous air monitor and portable area radiation monitor were not
positioned to provide a representative sample of habitability conditions in the
center.
Moreover, there were multiple ventilation zones and multiple paths for air
to circulate into the center and bypass the monitors.
~
An alternative means of air sampling was not established following the loss of
power and the corresponding loss of the continuous air and portable area
radiation monitors. There were no battery-powered air samplers available for
use within the plant. The licensee properly issued Problem Evaluation
Request 298-1275 to address the lack of equipment.
Potential contamination paths were not properly evaluated or controlled.
For
example:
(1) contamination control boundaries were not established to define
the areas to be monitored; (2) an exterior window in the OSC command area
remained open until 1:22 p.m., about 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> after the start of the release;
(3) exterior doors into the area near the conference room (the area occupied by
craft personnel) was not controlled; and (4) contamination surveys were not
performed in occupied areas after the window was discovered open and the
continuous air monitor alarmed.
When plant conditions worsened and a radiological relea
"- was anticipated,
access to the general services building was not restricted to a single entry point,
and a step off pad and frisker were not staged at this entry point as required by
Procedure 13.10.10, "Health Physics, Chemistry, Operations Support Center
Duties," Revision 12.
Hourly habitability surveys were performed instead of every 30 minutes, as
specified in Procedure 13.10.10, "Health Physics, Chemistry, Operations Support
Center Duties," Revision 12.
The failure to properly monitor habitability in the OSC was identified as an exercise
weakness,
because there was a risk of personnel exposures and facilitycontamination
(50-397/981,8-01).
In response
to TSC requests, the OSC assembled
27 repair teams and dispatched 21.
Three of the six teams that were not dispatched were canceled due to changing
priorities or radiological conditions within the plant; the other three were assembled
at
the end of the exercise but were not dispatched.
The large number of repair teams
dispatched over a short period of time and the limitations associated
with exercise
1
-10-
participation (only a designated number of individuals were selected to participate)
resulted in a shortage of health physics and craft personnel.
The shortage delayed the
dispatch of several priority repair teams.
Additional personnel were requested from the
offsite assembly area; however, there was no response to these requests (simulated or
otherwise).
Although team assembly, dispatch, and tracking were performed satisfactorily, the
following occurrences detracted from the effectiveness of the observed processes:
When repair teams were instructed to use self-contained breathing apparatus,
OSC personnel did not verify that the team members had corrective lense
inserts.
As a result, some repair team members were dispatched without
corrective lense inserts (after a vision test was performed)
~
The health physics briefing process appeared to be a bottleneck for dispatching
repair teams; only one person performed repair team health physics briefings.
Repair team documentation (briefing/debriefing records) was not properly
completed.
Team members listed on the front of repair team briefing/debriefing
forms did not match those listed on back (the dose record/debriefing section).
Discrepancies were identified on records for Teams 16, 18, and 20.
The repair team briefing/debriefing form was used to document team personnel
and team tracking. Occasionally, the OSC transferred people from one team to
another in the field. The OSC tracked these changes on the team tracking board
but did not document the changes
in facility logs or on the team
briefing/debriefing forms. Inspectors determined that the observed process
could affect continuous accountability and accumulated airborne doses assigned
to team members.
Applicable emergency plan implementing procedures were
unclear regarding personnel accountability. The licensee acknowledged the
procedural inconsistencies.
The inspectors evaluated supplies, equipment, and communication capabilities for OSC
personnel and field teams.
In general, appropriate supplies and equipment were readily
available and communications capabilities effectively supported field team operations.
However, inspectors identified the following exceptions:
The health physics emergency locker located in the machine shop in the general
services building was not maintained in a state of readiness.
The locker
contained defective and insufficient quantities of protective clothing. The
licensee issued Problem Evaluation Request 298-1275 (the same one issued for
the lack of battery-powered portable air samplers) to address the inventory and
condition of the protective clothing.
Radios and the plant page system were used to contact personnel in the plant;
however, station announcements
and alarms could not be heard in the area
outside the low pressure core spray pump room, in the adjacent stair well, and
0
-11-
on the 441-foot elevation in front of the elevator.
Radio reception was poor in
these areas.
V
Exercise controllers simulated the loss of power by turning off the lights in the
OSC command area and down-powering all electrical equipment:
The
inspectors observed that there was no emergency lighting installed in the OSC
command area.
Since the exercise was conducted during the day, the windows
provided sufficient light in the OSC command area; however, at night, OSC
operations could be hampered.
During post-exercise discussions about this
matter, the emergency preparedness
manager stated that emergency electrical
generators were available to provide power, if needed.
The inspectors noted
that the exercise participants were apparently not aware that the generators
existed, since none were requested during the exercise.
Activities associated with potassium iodide issuance were satisfactorily implemented
during the exercise; however, the inspectors no'.ed one procedural discrepancy.
Procedure 13.2.1, "Emergency Exposure Levels/Protective Action Guides,"
Revision 13, required that the date and time an individual begins and stops taking
potassium be recorded on the personnel accountability log. There was no space on the
form to record this information. The licensee acknowledged this comment.
c.
Conclusions
The OSC staff's performance was generally satisfactory.
An exercise weakness was
identified for failure to properly monitor habitability. Airborne', contamination, and area
surveys were either never performed or were not regularly performed in all OSC areas.
The fire brigade's performance was degraded because
the response was delayed and
some fire-fighting actions were inappropriate.
The OSC was activated in a timely
manner.
Three-part communications were frequently used.
Facility briefings were
frequent and contained sufficient detail. Health physics briefings tended to delay repair
team dispatch because only one person conducted the briefings. The process used to
select field team members for tasks requiring self-contained breathing apparatus did not
verify corrective lense availability. Repair team documentation was incomplete and
could have affected airborne dose reconstruction.
There was no emergency lighting
installed in the OSC, although emergency electrical generators were available.
Appropriate corrective actions were taken to address the lack of battery-powered air
samplers.
Public address announcements
and station alarms could not be heard in all
areas of the plant. A health physics emergency locker contained degraded supplies and
insufficient quantities of protective clothing.
P4.5
Emer enc 0 erations Facilit
a.
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 facility activation, 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
0
-12-
direct interactions with offsite agency response personnel.
The inspectors reviewed
applicable emergency plan sections and procedures, forms, dose projections, logs, and
press releases.
b.
Observations and Findin s
The EOF was promptly staffed following the 8:22 a.m. alert declaration.
Upon arrival,
personnel signed in on the staffing board, initiated position checklists, and established
communications with counterparts.
The EOF manager verified that functional area
staffing levels were met and activated the facilityat 9:01 a.m. -The EOF manager
assumed
the emergency director responsibilities (emergency classification, offsite
agency notifications, dose assessment/protective
action recommendations)
at 9:07 a.m.
The turnover was systematic; however, the turnover checklist was not used.
Briefings were frequent and comprehensive.
Facility members were given a 10-minute
warning to prepare, and all facilitypersonnel participated in the briefings. At times, the
EOF manager had to repeatedly remind facilitypersonnel to stop and pay attention to
the briefings. The briefings appropriately included input from operations, radiation
protection, engineering, administrative, and offsite agency representatives.
At the
conclusion of the briefings, the EOF manager effectively summarized plant conditions
and emphasized facility priorities.
The EOF manager with support from facilityoperations personnel, the CR, and the TSC,
quickly recognized and correctly classified the site area and general emergency
conditions. The site area emergency was declared at 9:54 a.m., and the general
emergency was declared at 11:18 a.m.
Although offsite agency notifications were performed satisfactorily, there were some
occasions when the notifications were not properly completed.
The following examples
were observed:
The date and time of the site area emergency were not entered on the site area
emergency classification notification form (Form 2). The time and date were
added after the form was approved and transmitted, via facsimile, to the offsite
agencies and after verbal notifications were made.
Once the error was detected
(offsite agencies called to get the declaration time), an information-only form was
prepared and transmitted.
However, the time noted on the form was 10:25 a.m.,
rather than the 9:54 a.m. declaration time. The correct time was verbally
communicated.
As a result, the offsite agencies did not receive a notification
form with the correct site area emergency declaration time,,and the offsite
agencies possessed
a form that was different than the one the licensee would
use as an event record.
~
The licensee identified that the notification to the Department of Energy was
slightly delayed for the site area emergency (19 versus 15 minutes). The delay
'was caused by the loss of the primary notification system (CRASH telephone)
and incorrect backup telephone numbers in the emergency telephone directory.
Once the CRASH system failure occurred, the assistant
EOF manager and the
-13-
EOF manager's secretary each began making the offsite notifications. The
Benton/Franklin county and Washington State emergency operations centers
were notified at 11 and 13 minutes, respectively.
The emergency plan and Procedure
13.4.1, "Emergency Notifications,"
Revision 23, were inconsistent with one another concerning followup
notifications. Section 4.6.6 of the emergency plan required that followup
messages
be transmitted; however, Procedure
13.4.1 did not specifically
mention followup notifications. During the exercise, no classification notifications
forms were transmitted after 11:18 a.m. (the general emergency notification).
Provisions for and content of followup notifications are specified in Evaluation
Criterion E.4 of NUREG-0654, FEMA-REP-1, "Criteria for Preparation and
Evaluation of Radiological Emergency Response
Plans and Preparedness
in
Support of Nuclear Power Plants."
In response,
the licensee issued Problem
Evaluation Request 298-1281 to correct the discrepancy.
The licensee's actions
were considered appropriate.
The automatic protective action recommendations
were issued for the site area and
general emergencies.
At the site area emergency, the recommendations
included
evacuation of the Columbia River, several recreational areas, and schools within the
10-mile emergency planning zone.
At the general emergency, the recommendations
included evacuation of all sections 0-2 miles and 2-10 miles in the affected section
(Section 3).
Dose assessment
and field team control activities were properly performed
to support
protective action recommendations.
The dose assessment
staff calculated numerous
dose projections based on plant conditions and field team data.
Although standby gas
treatment system line-up and flow indicated that the release was filtered, air samples
collected by field teams showed higher levels of iodine than would be expected from a
filtered release.
The dose assessment
staff repeatedly questioned the engineering staff
about the status of the standby treatment system.
Although the system was reported as
operable, the dose assessment
staff correctly concluded that the field team results
meant that the efficiency of the standby gas treatment system was degraded (about
95 percent of normal efficiency).
Since offsite doses (measured and projected) were well below Environmental Protection
Ag ncy protective action guides and the wind direction remained
onstant, additional
protective action recommendations
were not necessary.
The dose assessment
staff
correctly monitored the release duration time to determine its effect on projected
integrated doses.
Based on field team air sample results, even with a 6-hour release
duration time (increased from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />), offsite projected doses were 320 millirem thyroid
committed dose equivalent and 21 millirem total effective dose equivalent at the site
boundary (1.2 miles). There was good coordination between the licensee and offsite
agency dose assessment
and field monitoring teams.
0
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Facility habitability, proximity of the EOF to the radiological plume, and the effect of the
radiological plume on site access routes were appropriately monitored during the
exercise.
Required access controls were established and maintained.
Interactions with offsite response
team representatives
from the states of Washington
and Oregon, Benton and Franklin counties, the Department of Energy, and the NRC
who were stationed in the EOF were candid and supportive.
Upon arrival, offsite agency
representatives
were appropriately briefed on plant conditions and event prognosis.
Offsite agency input was solicited during periodic status briefings.
Conclusions
The EOF staff's performance was good. The facilitywas promptly activated, and
briefings were frequent and comprehensive.
Emergency classifications and protective
action recommendations
were correct and timely. Offsite agency notifications were
timely with one licensee-identified exception.
The Department of Energy notification for
the site area emergency was slightly delayed due to the loss of the primary notification
system and incorrect backup telephone numbers.
One notification form was not
properly completed; the date and time were omitted from the site area emergency
notification form. The error was quickly recognized and verbally corrected.
A
discrepancy between the emergency plan and implementing procedures was identified
concerning followup notifications. Appropriate corrective actions were taken to resolve
the discrepancy.
Dose assessment
and field team control activities were properly
performed to support protective action recommendations
and validate dose projections.
Interactions with offsite agency representatives
were candid and supportive.
Scenario and Exercise Control
Ins ection Sco
e 82301 and 82302
The inspectors evaluated the exercise to assess
the in'allenge and realism of the
scenario and exercise control.
Observations and Findin s
The licensee submitted the exercise objectives and scenario for NRC review on June 10
and July 15, 1998, respectively.
The exercise objectives were appropriate to meet
emergency plan requirements (reference NRC letter dated June 25, 1998).
By letter
dated August 14, 1998, the licensee was informed that both the NRC and the Federal
Emergency Management Agency had determined that the exercise scenario was not
challenging in some areas.
In order to maintain scenario confidentiality, the details were
not included in the letter but were discussed verbally with the emergency preparedness
staff. The licensee was informed that the offsite doses were not sufficient to
demonstrate objectives involving offsite monitoring capabilities (the highest offsite dose
was 1.2 millirem at the site boundary).
In response,
the licensee modified the scenario to fail (degrade) the standby gas
treatment system (due to moisture).
Expected dose projections submitted with the
-15-
revised scenario on September
1, 1998, included exceeding the Environmental
Protection Agency protective action guide for the thyroid (5 rem committed dose
equivalent) out to 7 miles. The changes were considered acceptable.
However, as discussed
in Section P4.5 above, based on field team data, the offsite
doses reached no more than about 320 millirem thyroid committed dose equivalent at
the site boundary.
Since this value was significantly lower than the doses identified in
the revised scenario, the inspectors determined that the scenario developers incorrectly
computed the field team sample data.
The licensee acknowledged that the field team
data was not consistent with the expected dose projections.
The inspectors concluded
that the revised scenario introduced some additional challenges for dose assessment
personnel (determining the degraded operability of the filtration system); however, the
lack of significant offsite doses did not fullychallenge the dose assessment
staff, field
team members, and protective action recommendation decision-makers.
Problems with
scenario development were also identified in 1996 (the last biennial exercise).
In addition to the field team data problem, the scenario developers failed to recognize
that the loss of offsite power would affect the OSC (loss of computer terminals, lights,
and electrical outlets). The licensee took appropriate and conscientious actions once
the issue surfaced (the day before the exercise).
Controllers were instructed to turn off
electrically powered items to simulate the loss of power.
During the exercise, controllers
developed impromptu radiological impacts to account for the open window in the OSC
.- command area, including making the continuous air monitor alarm. The inspectors
determined that these actions were appropriate and showed good response to
unplanned situations.
I
However, the following aspects of exercise control detracted from the realism and
training value of the exercise and, with the exception of the last example, were
inconsistent with pre-established
performance expectations
(all protective clothing and
equipment would be worn, not simulated):
Team 8 was told by the controller to simulate use of protective clothing/self-
contained breathing apparatus.
Team 17 simulated entry into the radiologically controlled area.
The health
physics technician did not dress out in protective clothing or self-contained-
breathing-apparatus.
The technician did not have the appropriate survey
instrumentation for the simulated activities, and team members were directed to
use defective protective clothing (from the locker discussed
in Section P4.4
above).
The Team 22 controller could not immediately locate radiological conditions for
the team's work area.
c.
Conclusions
The exercise objectives were appropriate to meet emergency plan requirements.
The
initiallysubmitted scenario was not acceptable because offsite doses were not
0
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challenging and would limitdemonstration of some exercise objectives.
Projected
offsite doses were increased to an acceptable level in the revised scenario; however,
the scenario developers incorrectly computed the offsite field team sample data.
As a
result, the offsite doses were not consistent with expected projected doses and did not
challenge the dose assessment
staff, field team members, and decision-makers.
Scenario development has been a historical problem.
In addition, the scenario
developers failed to recognize that the loss of offsite power would affect OSC
operations.
Last minute controller instructions and impromptu controller actions during
the exercise were thorough and conscientious.
P4.7
Licensee Self Criti ue
a.
Ins ection Sco
e 82301-03.13
The inspectors observed and evaluated the licensee's post-exercise facilitycritiques and
the formal management critique on September 18, 1998, to determine whether the
process would identify and characterize weak or deficient areas in need of corrective
action.
b.
Observations and Findin s
Post-exercise
critiques in the CR simulator., TSC, OSC, and EOF were thorough, open,
and self critical. With the exception of the OSC, the critiques included input from
controllers, evaluators, and participants.
In the OSC, the critique was divided into two
portions, the craft critique and the management/controller/evaluator
critique. Craft
personnel were dismissed before the second portion of the critique. As a result, the
opportunity for the craft personnel to provide and receive feedback, as part of the OSC
team, was missed.
During the September
18, 1998, management critique, the emergency preparedness
manager presented the preliminary exercise findings to senior management.
The
licensee's evaluation team identified three exercise weaknesses:
(1) fire brigade
response,
(2) OSC habitability, and (3) Department of Energy notifications. Strengths
were identified in all but the TSC, and areas for improvement. were identified in all
facilities. The inspectors concluded that the management
critique was thorough and
self critical.
e
Conclusions
The post-exercise and management critiques were thorough and self-critical. The
critique process effectively identified positive performance and areas that needed to be
corrected or improved.
P8
Miscellaneous Emergency Preparedness
Issues (92904)
Closed
Ins ection Followu
Item 50-397/96014-02:
Exercise weakness for failure to
make timely and clear offsite notifications. During the 1996 exercise:
(1) conflicting
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protective action recommendations
were communicated via notification forms, (2) an
upgrade in protective action recommendations
was not communicated to the state within
15 minutes, (3) one other notification nearly missed the 15-minute limit, and
(4) notification forms were not sent to offsite agencies, via facsimile, prior to the verbal
notification, as required. The licensee's November 25, 1996, response to the exercise
weakness stated that corrective actions included personnel training and procedure
modifications.
During this exercise, offsite agency notifications were satisfactorily
"
performed.
The licensee identified one instance where the Department of Eriergy was
not notified within 15 minutes (19 minutes for the site area emergency).
The delay was
caused by a loss of the primary notification system (unplanned) and incorrect backup
telephone numbers (the licensee planned to pursue the telephone number issue).
The
state and counties were notified within 15 minutes.
Protective action recommendations
were clearly identified on the notification forms, and forms were sent, via facsimile,
concurrent with verbal notifications.
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 September
18, 1998. The licensee acknowledged the facts
presented.
No proprietary, information was identified.
The Federal Emergency Management Agency conducted a public meeting in Richand,
Washington, on September
18, 1998.
Since there was no media or public attendance
at the
meeting, the meeting was convened and immediately adjourned.
ATTACHMENT
SUPPLEMENTAL INFORMATION
PARTIALLIST OF PERSONS CONTACTED
Licensee
D. Atkinson, Manager, Quality
J. Baker, Vice President, Resource Development
L. Ball, Emergency Planner
R. Barbee, Manager, Work Week
P. Bemis, Vice President, Nuclear Operations
D. Coleman, Manager, Regulatory Affairs
S. Davison, Specialist, Work Control
D. Feldman, Assistant Manager, Operations
J. Hanson, Manager, Chemistry
D. Holmes, Emergency Planner
J. Ittner, Emergency Planner
R. Jorgensen,
Emergency Planner
A. Klauss, Lead, Offsite Emergency Preparedness,
Safety, and Health
T. Messersmith, Corporate Emergency Preparedness,
Safety, and Health Officer
W. Oxenford, Manager, Operations
J. Parrish, Chief Executive Officer
R. Torres, Manager, Reactor/Fuels
Engineering
R. Webring, Vice President, Operations Support
LIST OF INSPECTION PROCEDURES USED
Evaluation of Exercises at Power Reactors
Review of Exercise Objectives and Scenarios for Power Reactors
Operational Status of the Emergency Preparedness
Program
LIST OF ITEMS OPENED AND CLOSED
~oened
50-397/98018-01
IFI
Exercise weakness
- Failure to properly monitor OSC habitability
(Section P4 4)
Closed
50-397/96014-02
IFI
Exercise weakness
- Failure to make timely and clear offsite
notifications (Section P8)
-2-
LIST OF DOCUMENTS REVIEWED
Emer enc
Plan lm lementin
Procedures
13.1.1
13.2.1
1 3.2.2
1 3.4.1
1 3.5.1
13.5.3
13.10.1
13.10.2
13.10.3
13.10.4
13.10.5
13.10.7
'3.10.14
13.10.9
13.10.10
13.10.12
13.10.14
13.11.1
'13.11.2
13.11.3
13.11.7
13.13.2
Classifying the Emergency
Emergency Exposure Levels/Protective Action Guides
Determining Protective Action Recommendations
.
Emergency Notifications
Localized and Protected Area Evacuations
Evacuation of Exclusion Area and/or Nearby Facilities
CR Operations and Shift Manager Duties
TSC Manager Duties
Technical Manager and Staff Duties
Radiation Protection Manager Duties
Operation Manager Duties
Plant Administrative Manager Duties
Maintenance Manager Duties
OSC Manager and Staff Duties
Health Physics, Chemistry, OSC Duties
Repair Team Duties
Maintenance Manager Duties
EOF Manager Duties
Assistant EOF Manager Duties
Site Support Manager and Staff Duties
Radiological Emergency Manager Duties
Emergency Event Termination and Recovery Operations
Revision 25
Revision 13
Revision 10
Revision 23
Revision 14
Revision 17
Revision 16
Revision 14
Revision 17
Revision 16
Revision 10
Revision 16
Revision 3
Rewsion 26
Revision 12
Revision 12
Rewsion 3
Revision 19
Revision 9
Revision 14
Revision 16
Revision 10
Other Procedures
Abnormal Condition Procedure 4.TSC1, TSC1 Annunciator Panel Alarms, Revision 3
System Operating Procedure 2.10.12, Technical Support Center HVAC, Revision 7
Other Documents
Washington Nuclear Project 2 Emergency Plan, Revision 21
Response
to Exercise Weakness,
GO2-96-230, dated November 25, 1396
Problem Evaluation Request 298-1275, dated September
17, 1998
Problem Evaluation Request 298-1280, dated September
17, 1998
Problem Evaluation Request 298-1281, dated September
17, 1998