ML20034H320
| ML20034H320 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 03/10/1993 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20034H318 | List: |
| References | |
| 50-458-93-01, 50-458-93-1, NUDOCS 9303170114 | |
| Download: ML20034H320 (13) | |
See also: IR 05000458/1993001
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APPENDIX
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U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Inspection Report: 50-458/93-01
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Operating License: NPF-47
Licensee: Gulf States Utilities
P.O. Box 220
St. Francisville, Louisiana 70775
Facility Name:
River Bend Station
Inspection At: St. Francisville, Louisiana
Inspection Conducted:
February 22-26, 1993
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Inspectors:
D. Blair Spitzberg, Ph.D., Emergency Preparedness Analyst
L. Wilborn, Radiation Specialist
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W. Holley, Senior Radiation Specialist
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E. Collins, Project Engineer
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Accompanying
Personnel:
G. Cicotte, Research Engineer, Battelle Laboratories
F. McManus, Comex Corporation
Approved:
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Blain #Murray, Chief', Facilities
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Inspection Programs Section
Inspection Summary
Areas Inspected: Routine, announced inspection of the licensee's performance
and capabilities during an annual exercise of the emergency plan and
implementing procedures. The inspection team observed activities in the
control room (simulator), Technical Support Center, Operational Support
Center, and the Emergency Operations Facility.
Results:
The control room staff performed well during the exercise in assessing
plant conditions, making classifications and notifications, and in
implementing procedures.
Realism and challenge for the control room
staff was reduced by not using the control room simulator in the dynamic
mode to drive scenario events (Section 2.1)
9303170114 930311
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The Technical Support Center staff performed well as an organization and
demonstrated a good understanding of plant systems. An exercise
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weakness was identified for failure to take prompt action to mitigate a
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radiological release (Section 3.1).
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The operations support center management staff performed well during the
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exercise.
In-plant response teams briefings were organized and
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effective. An exercise weakr4 esses was identified for improper
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radiological procedures utilized in the collection of the postaccident
sampling system sample. A second exercise weakness was identified for
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the failure to collect and analyze a postaccident sample in a timely and
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efficient manner (Section 4.1).
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The Emergency Operations Facility was staffed and activated promptly and
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personnel were proficient in carrying out their assigned duties. An
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exercise weakness was identified for failure to make a prompt
notification of significant plant changes and issuance of notification
messages with conflicting information (Section 5.1).
The scenario and exercise preparation provided sufficient challenge to
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demonstrate the exercise objectives.
Better exercise preparation would
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have improved the training benefits of the exercise (Section 6.1).
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The licensee's self-critique process was successful in identifying areas
in need of corrective action (Section 7.1).
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Summary of Inspection Findings:
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Exercise Weakness 458/9301-01 was opened (Section 3.1).
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Exercise Weakness 458/9301-02 was opened (Section 4.1).
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Exercise Weakness 458/9301-03 was opened (Section 4.1).
Exercise Weakness 458/9301-04 was opened (Section 5.1).
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Exercise Weakness 458/9201-01 was closed (Section 8.1).
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Exercise Weakness 458/9201-02 was closed (Section 8.2).
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Attachment:
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Attachment - Persons Contacted and Exit Meeting
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DETAILS
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1 PROGRAM AREAS INSPECTED (82301)
The licensee's annual emergency preparedness exercise began at 7:30 a.m. on
February 24, 1993. The exercise start time had been_ withheld from _ exercise
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participants. The exercise included limited participation by offsite agencies
but was not a full participation exercise. The exercise was not evaluated by
the Federal Emergency Management Administration.
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The exercise scenario began with a recirculation pump failure and subsequent
degradation of a jet pump which caused mechanical fuel damage from the-loose
parts.
Following a reactor scram due to main steam radiation levels, a loss
of coolant accident occurred and lev to an inability to maintain reactor water
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level. A loss of offsite power was also experienced, but this event did not
significantly contribute to the accident sequence.- One containment unit
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cooler was previously out of service and another failed which caused
containment temperature and pressure to increase. A radiological release to-
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the reactor auxiliary building began when a supply line to a containment
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pressure transmitter failed downstream of the manual isolation valve. This
resulted in a small filtered release to the environment via the Standby Gas
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Treatment System.
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The inspection team identified various concerns during the course of the-
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exercise; however, none were of the significance of a deficiency as defined in
Each observed concern can be characterized as an
exercise weakness or as an area recommended for improvement. An exercise
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weakness is a finding that a licensee's demonstrated level of preparedness
could have precluded effective implementation of the emergency plan in the
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event of an actual emergency.
It is a finding that needs licensee corrective
action. Other observations are documented which did not have a significant
negative impact on overall performance during the exercise but are provided
for consideration for program improvement as deemed appropriate by the
licensee.
2 CONTROL ROOM (82301-03.02.b.1)
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The inspection team observed and evaluated the control room staff as they
performed tasks in response to the exercise. These tasks included detection
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and classification of events, analysis of plant conditions, implementation of
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corrective measures, notifications of offsite authorities, and adherence to
the emergency plan and implementing procedures.
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2.1 Discussion
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The control room simulator was used for the exercise but only in the static
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mode (i.e., dynamic simulation of scenario events was not used).
The inspectors observed that the Alert classification was made promptly from
the control room and that notifications to offsite authorities were timely.
Control room operators demonstrated a good level of proficiency and' knowledge
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of the emergency operating, abnormal, and emergency implementing procedures.
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Throughout the exercise, control room operators were effective in the
operational and technical assessments of plant conditions.
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The inspectors noted that the shift supervisor demonstrated that he was
anticipatory and was thinking ahead as he considered possible courses of
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action.
For example, he recognized early that continued increasing
containment radiation levels would singularly lead to a general emergency
condition. He also anticipated the restoration of electrical power by
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planning a restoration sequence. The shift supervisor frequently made
assessments of. plant radiation levels and factored these assessments into
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appropriate precautions for plant operators.
Excellent logs were maintained
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by the control room staff.
The inspectors noted that the shift supervisor's use of the control room
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communicator was not consistent or efficient. The communicator sat at
opposite ends of a large table as opposed to locating close to the shift
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supervisor. The inspectors observed that much of the routine exchange of
information that took place between the shift supervisor and the Technical
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Support Center was of such a nature that it could more appropriately be
handled by the communicator, thus freeing the shift supervisor for more
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important functions. The shift supervisor was also frequently distracted to
answer incoming telephone calls, a responsibility which could have been
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assigned to others.
The scenario did not anticipate that the operators would enter the reactor
pressure vessel flood sequence. This operation resulted in action taken to
vent the reactor pressure vessel through the Reactor Core Isolation Cooling
system. During this operation, the inspectors noted that Emergency Operating
Procedure E0P-0005, Revision 5, Enclosure 2, " Bypassing RCIC' Low RPV Pressure
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Isolation Interlock" did not support the action taken to vent the reactor
pressure vessel through Reactor Cort holation Cooling. After the exercise,
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licensee personnel expressed their intent to implement corrective action to
revise Procedure E0P-0005, Enclosure 2, to precisely specify the reactor
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pressure vessel vent path through the reactor core isolation cooling system.
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2.2
Conclusions
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The control room staff performed well during the exercise in assessing plant
conditions, making classifications and notifications, and in implementing
procedures. Realism and challenge for the control room staff was reduced by
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not using the control room . simulator in the dynamic mode to drive scenario
events.
3 TECHNICAL SUPPORT CENTER (82301-03.02.b.2)
The inspection team observed and evaluated the Technical Support Center staff
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as they performed tasks in response to the e arcise scenario. These tasks
included detection and classification of events; notification of Federal, .
State, and local response agencies; analysis of plant conditions; formulation
of corrective action plans; briefing of repair teams; and protective action
decisionmaking and implementation.
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3.1 Discussion
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The inspection team observed that the Technical Support Center staff worked
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well as an organization. Notification of events to State and local emergency-
response agencies were promptly ordered by the emergency director and
implemented by the communicator. The emergency director demonstrated the use
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of protective action recommendation decisionmaking procedures and flow charts,
and protective action recommendations were promptly communicated to the
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offsite response agencies.
The emergency director and Technical Support Center staff demonstrated a good
understanding of plant systems and properly used appropriate procedures to
develop repair plans and corrective measures. Plant status briefings were
conducted frequently to detail plant conditions and establish action
priorities.
Both the Site Area Emergency and General Emergency were declared from the
Technical Support Center within a period of about 18 minutes. While both
classifications were conservative and appropriate, the inspectors observed
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that the gathering and evaluation of information prior to the declaration of
the General Emergency was not optimal.
At about 9:02 a.m. while in an Alert, the operations coordinator informed the
Technical Support Center Manager that two fission product barriers were
breached or challenged. The fuel barrier was known to be breached and the
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containment was challenged because of the unknown status of a Main Steam
Isolation Valve which was showing dual control board indications. The
Operations Coordinator indicated to the emergency director that escalation to
a Site Area Emergency might be required due to these indications. At
10:37 a.m., the emergency director declared a Site Area Emer'gency based on
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high drywell pressure and low reactor vessel level following a loss of coolant
accident. Then, at about 10:55 a.m., the emergency director determined that a
General Emergency should be declared. The basis for this classification was
two fission product barriers breached, (i.e., fuel and reactor pressure vessel
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system due to the loss of coolant accident), and the third _ fission product
barrier challenged (containment due to the Main Steam Isolation Valve dual
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indication)-.
Between the time of the declared Site Area Emergency and the
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General Emergency, the scenario presented no change in the status of the
fission product barriers.
It was unclear why the Main Steam Isolation Valve
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problem was applicable for the General Emergency classification but was not
considered applicable 18 minutes earlier when the Site Area Emergency.was
declared.
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At the time the General Emergency was declared, an Operational Support Center
team was actively investigating the Main Steam Isolation Valve problem, but
they were not consulted by the Technical Support Center decisionmakers to
determine why the Main Steam Isolation Valve dual indication existed (i.e.,
was the problem in the indication circuit or an actual valve not shut
condition).
Similarly, the control room was not consulted to ascertain what
they believed to be the problem with the Main Steam Isolation Valve. Based on
later discussions, the control room personnel had reasons to believe that the
problem was with the indication circuit and not the valve.
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Following the exercise, the inspection team held a discussion with the
emergency director to determine the reasons and thought process for the
declarations as stated above. The discussion revealed that the emergency
director's decision to declare the General Emergency included additional
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considerations beyond the specific indicators cited in the emergency' action
level. Notably, the emergency director assessed that the emergency core
cooling system was not indicating effective addition of water to the reactor
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vessel and that the containment challenge (Main Steam Isolation Valve)
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existed. To be censervative, the General Emergency was declared.
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this information, the declaration of Site Area Emergency and General Emergency
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at the times indicated were appropriate. However, the status of the Main
Steam Isolation Valve, which affected the challenge to.the containment, was
not fully ascertained by the key decisionmakers. The inspection team
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concluded that the gathering and evaluation of all relevant information before
declaration of a classification level should be emphasized to improve the use
of the event classification scheme.
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The inspectors observed that the licensee's accident mitigation efforts were
weak following the initial radiological release. At about 12 p.m., the
emergency director was away from his normal position in the Technical Support
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Center and was involved in a telephone dialogue about the protective action
recommendations with state and local agencies. This telephone discussion took
place in the communications room of the Technical Support Center and lasted
between 5 to 7 minutes.
In addition, during this time, the Technical Support
Center Manager was away from his normal position to conduct a relief turnover
briefing. During the period when both the emergency director and Technical
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Support Center Manager were away from the command table, the initial
radiological release began.
The absence of these two key personnel from the main Technical Support Center
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command and control area contributed to confusion about the release.
Subsequent events required a vent of the reactor vessel at about 12:23 p.m.
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which masked the first release; however, the emergency director had been
informed of the 12 p.m. release at about 12:09 p.m.
Also, during this time,
the emergency director was in the process of being relieved which may have
contributed to the incomplete understanding of the radiological release.
Following the initiation of the release at 12 p.m., no action was taken to
locate and stop the source of this release. Failure to take prompt action to
mitigate a radiological release was identified as an exercise weakness
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(458/9301-01).
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3.2 Conclusions
The Technical Support Center staff performed well as an organization and
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demonstrated a good understanding of plant systems. An exercise weakness was
identified for failure to take prompt action to mitigate a radiological
release.
4 OPERATIONAL SUPPORT CENTER (82301-03.02.b.4)
The inspectors evaluated the performance of the Operational Support Center
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staff as they performed tasks in response to the exercise. These tasks
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included activation of the Operations Support Center and its effectiveness in
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providing support to operations, including the coordination of emergency
in-plant response teams.
4.1 Discussion
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The inspectors noted that the Operational Support Center management staff
appeared trained and familiar with their responsibilities. The Operational
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Support Center Coordinator and the Radiation Protection Foreman communicated
frequently and effectively with their counterparts.in the Technical Support
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Center.
Frequent briefings of the Technical Support Center and Operational
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Support Center staffs over the public address system and the closed-circuit
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video system by the Emergency Director provided an excellent basis for
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information flow.
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The use of radiological data in team briefings was very good.
Prior to each
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task, team members were given all relevant ambient' dose rates, dose limits,
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and turn back dose rates. The Radiation Protection Foreman instructed his. .
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staff to review actual radiation exposure histories and-gather other related
information needed to support the emergency response. effort. The
instructions / briefings given to team members included airborne iodine-131 -
concentrations and precautions and protective measures for the teams to
implement (including the potential use of potassium iodide).
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One of the objectives of the exercise was to collect and analyze a. sample-
using the postaccident sampling system.
Before the exercise, the inspection
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team was advised that the small volume liquid sampler of postaccident sampling
system was inoperative. A decision was made to collect and analyze a
containment air sample to satisfy the exercise objective. A team consisting
of a radiation technician and two chemistry technicians was dispatched from
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the Operational Support Center to collect the postaccident sampling system air
sample. The team received an adequate briefing necessary to accomplish the'
task in a safe manner.
The inspectors noted several-actions by the
postaccident sampling' system team which caused unnecessary delays as follow:
One team member had to shave so that he could wear the self-contained
breathing apparatus required for entry into radiological controlled
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area.
One team member had to be excessively coached by the radiation
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protection technician on proper dress-out procedures.
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A defective radio had to be exchanged before entry into the radiological.
controlled area.
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The inspectors noted that the volume and weight of the equipment the
team carried to get an air sample was excessive and inhibited the
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progress of the team to the sampling area.
Upon arriving at the postaccident sampling system facility, .the team
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discovered they did not have the required wrench to tighten a connection
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from the compressed nitrogen gas bottle to the postaccident sampling
system purge system.
Thirteen minutes elapsed before a wrench was
obtained.
The switch on the portable air sampler was found to be defective and
15 minutes were expended in replacing the air sampler.
In attempting to collect the postaccident sampling system air sample, a
vacuum on the system could not be drawn and, subsequently, the system
had to be purged with nitrogen.
This procedure took about 15 minutes.
Two attempts were made in collecting the postaccident sampling system
air sample before an inspection of the postaccident sampling system air
sampling equipment revealed that the sample injection needle was bent.
After considerable effort, the needle was straightened before finally
being removed and replaced.
Approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> were expended in collecting and analyzing the
postaccident sampling system air sample. This is in excess of the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> time
frame for collecting and analyzing postaccident sampling system samples
specified in EIP-2-015, " PASS Operations," and NUREG-0737, " Clarification of
TMI Action Plan Requirements." The failure to collect and analyze a
postaccident sampling system sample in an efficient and timely manner was
identified as an exercise weakness (458/9301-02).
During the collection of the postaccident sampling system sample, the
inspectors identified several improper radiological practices as follows:
The postaccident sampling system sampling team removed their
self-contained breathing apparatus equipment before the area air sample
results were known.
No provisions were made for respiratory protection for the postaccident
sampling system team beyond the 30-40 minute air supply provided by the
initial self-contained breathing apparatus air tanks carried by the team
to the postaccident sampling system facility.
The postaccident sampling system sample team did not read their direct
reading dosimeters during the first 30 minutes of their activities.
During the air sampling in the postaccident sampling system facility,
the inspectors noted that one of the air sample filters had a hole in
it. This would have resulted in a significant underestimation of the
airborne radioactivity.
The failure to implement proper radiological controls for in-plant response
teams was identified as an exercise weakness (458/9301-03).
4.2 Conclusions
The operations support center management staff performed well during the
exercise.
In-plant response team briefings were organized and effective. An
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exercise weakness was identified for failure to collect and analyze a
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postaccident sample in a timely and efficient manner. A second exercise
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weakness was identified for improper radiological procedures utilized in the
collection of the postaccident sampling system sample.
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5 EMERGENCY OPERATIONS FACILITY (82301-03.02.b.3)
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The inspection team observed the Emergency Operations facility staff as they
performed tasks in response to the exercise. These tasks included activation.
of the Emergency Operations Facility, accident assessment and classification,
offsite dose assessment, protective action decisionmaking, notifications, and
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interactions with offsite field monitoring teams.
5.1
Discussion
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The inspection team observed that the Emergency Operations facility was
promptly activated and maintained in an orderly manner.
Facility briefings
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and information flow was effective.
Habitability checks were performed
regularly. The inspectors noted that dose assessments v re timely and
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accurate and that protective action recommendations wer-
.ppropriate.
Operations assessors assisted the Technical Support Center in monitoring plant
evolutions and were proactive in assessing potential changes in radiological
release conditions.
Some notifications to offsite authorities made during the exercise contained
conflicting information.
For example, Notification Message 5 issued from the
Technical Support Center at 11:05 a.m., indicated protective action
recommendations of evacuation for Sector I and shelter for Sectors 4, 9, and
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16 (Scenario 16).
In the next Notification Hessage 6 issued from the
Technical Support Center at 11:50 a.m.,
Item 5, " Protective Action
Recommendations" gave conflicting information.
The item was checked to
indicate that previously issued protective action recommendations remained
" unchanged." The specific protective action recommendations listed, however,
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were changed from those previously issued. The new protective action
recommendations were to evacuate Sectors 1, 4, 9,and 16, and Shelter
Sectors 2, 3, and 8 (Scenario 26).
This same message gave further conflicting
information in Item 9, " Release Information." This item was marked to
indicate that the release information provided was "new" information, yet the
message information continued to show "no release" as indicated in previous
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messages.
Since the licensee was recommending that offsite populations be
evacuated, Item 9 should have been marked to indicate " potential for release."
A notification message was not promptly issued by the Emergency Operations
Facility following a significant change in plant conditions when the initial
radiological release began.
Beginning about 12:06 p.m., when the radiological
release was recognized, notification to offsite authorities of this
significant change in plant conditions was not made until about 46 minutes
later at 12:52 p.m.
This notification, contained in Message 7, indicated a
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release was in progress which had started at 12:06 p.m.
The incident
conditions and comment Section 6 of this message did not contain any
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amplifying information about the release, regarding its significance or cause,
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Emergency Implementing Procedure EIP-2-006, " Notifications," specifies that
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during a declared emergency, prompt update notification messages will be
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issued to offsite authorities whenever there is a significant change in plant
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conditions.
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The licensee's failure to promptly notify offsite authorities of a significant
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change in plant conditions, and the issuance of notification messages with
conflicting information was identified as an exercise weakness (458/9301-04).
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5.2 Conclusions
The Emergency Operations Facility was staffed and activated promptly and
personnel were proficient in carrying out their assigned duties. An exercise
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weakness was identified for failure to make a prompt notification of
significant plant changes and issuance of notification messages with
conflicting information.
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6 SCENARIO AND EXERCISE CONDUCT (82301)
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The inspection team made observations during the exercise to assess the
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challenge and realism of the scenario and to evaluate the conduct of the
exercise.
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6.1
Discussion
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The inspection team determined that the scenario provided sufficient challenge
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to exercise response activities in each of the exercise. objectives.
Realism
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and challer.ge was reduced, particularly for the control room staff because of
the inability to utilize the control room simulator in the dynamic mode to
model the accident sequence.
The tabletop exercise mode conducted in the
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control room simulator denied the operators the ' challenge and realism of
responding to events in a manner in which they have been-trained.
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cases, the data sheets used to indicate scenario events were saved by the
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operators and used for trending purposes. The personnel did not afford
themselves the opportunity to peruse plant panels for corroborating or
supporting indications.
Before the end of the exercise, the operators were
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observed to be in the mode of keying off of the plant data updates provided at.
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regular intervals rather than continuously assimilating plant data.
The following cbservations related to the scenario and to the conduct of the
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exercise are discussed as potential areas for improvement:
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At 7:45 a.m., 55 minutes before the Alert was declared, the inspector
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noted several plant personnel delivering plant prints and diagrams to
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The inspector was told that the prints
are normally stored in the library, two floors below the Technical
Support Center. This prestaging of required documents did not allow for
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proper evaluation of the Technical Support Center staff's capability to
activate the Technical Support Center in a timely manner.
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Controllers prompted players on several occasions, and scenario
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simulation was adversely affected by controllers assisting and
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volunteering information to players.
Examples of prompting noted by the
inspectors included the following:
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When the Operations Advisor complained that some diagrams were
missing from his copy of emergency procedures, an exercise
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controller promptly left to obtain new copies for the Operations
Advisor.
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An exercise controller in the control room provided printed
plant data sheets to personnel who were not in sight of the
terminal where such information is normally provided, and who
had not indicated a need for the information available.
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When the notification communicator in the control room was
unable to illuminate the monitor of the notification computer,
an exercise controller did it for him. Also, when an exercise
controller was asked by the notification communicator how to use
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the menu selection system on the computer, the controller
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provided the information requested.
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An exercise controller left an open scenario book _ on a control
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room desk unsupervised for extended periods of time and within
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view of the control room staff.
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Several examples of scenario problems were noted as follow:
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The scenario did not recognize that the operators would enter
the reactor pressure vessel flood sequence.
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The scenario had the emergency core cooling systems starting on
the loss of cffsite power.
In reality these systems would not
be expected to start on the loss of offsite power.
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The scenario did not anticipate that the recirculation pump trip
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would place the plant in an operating condition in which the
shift supervisor would likely initiate a manual scram.
6.2 Conclusions
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1he scenario and exercise preparation provided sufficient challenge to
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demonstrate the exercise objectives. Better exercise preparation would have
improved the training benefits of the exercise.
7 LICENSEE SELF-CRITIQUE (82301-0302b12)
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The inspectors observed and evaluated the licensee's formal self-critique on
February 26, 1993, to determine whether the process would identify and
characterize weak or deficient areas in need of corrective action.
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7.1
Discussion
The licensee gave a presentation of the results of its self-critique. Three
exercise weaknesses were identified by the licensee as follows:
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Weak accident assessment associated with events surrounding the initial
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radiological release.
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Failure to make notifications to offsite authorities of the initial
radiological release.
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Failure to obtain a postaccident sampling system sample in a timely
manner.
The licensee's self-critique process was determined to have involved adequate
staff and resources and the participation of higher management. The
licensee's findings were similar to the findings of the inspection team. The
inspectors determined that the licensee was successful in identifying and
characterizing weaknesses in need of corrective action.
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7.2 Conclusions
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The licensee's self-critique process was successful in identifying areas in
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need of corrective action.
8 FOLLOWUP ON PREVIOUS INSPECTION FINDINGS
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8.1
(Closed) Exercise Weakness (458/9201-01):
Failure to Promptly Give
Critical Information to the Emergency Director
During this year's exercise, the ii. rectors noted that key plant information
was promptly communicated to emergency decisionmakers.
8.2
(Closed) Exercise Weakness (458/9201-02):
Failure to Identify and
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Assess an Internal Exposure Pathway Prior to Exposing Repair Teams to
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During this year's exercise, the inspectors noted that team members were
appropriately briefed regarding exposure hazards.
In addition, team members
were briefed on the potential use of potassium iodide should respiratory
protection protective factors be exceeded.
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ATTACHMENT
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1 PERSONS CONTACTED
1.1 Licensee Personnel
- J. E. Booker, Manager, Safety Assessment and Quality Verification
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- J. Cook, Senior Technical Assistant
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- L. A. England, Director, Nuclear Licensing
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- P. Graham, Vice President
- R. Harvin, Communication Specialist
- R. Jobe, Senior Emergency Planner
- C. Rohrmann, Training Systems Coordinator
- J. Schippert, Plant Manager
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- W. M. Smith, Supervisor, Emergency Planning
- X. E. Suhrke, Manager, Site Support
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- X. Swan 2y, Emergency Planner
- K. Zimmermann, Senior Nuclear Communications Specialist
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1.2 NRC Personnel
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- W. Smith, Senior Resident Inspector
- Denotes those present at the exit interview
2 EXIT MEETING
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The inspection team met with the licensee representatives and other personnel
indicated in Section 1 of this Attachment on February 26, 1993, and. summarized
the scope and findings of the inspection as presented in this report.
The
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licensee did not identify as proprietary any of the materials provided to, or
reviewed by, the inspection team during the inspection.
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