ML20080C606
| ML20080C606 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/03/1984 |
| From: | Zahler R METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 8402080150 | |
| Download: ML20080C606 (24) | |
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.M NGToN H February 3 1984
,,....e wm,TER. DIRECT DaAL Nu
.f 4 (202) 822-1130 Mr. Samuel J. Chilk Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555 In the Matter of Metropolitan Edison Company (Three Mile Island Nuclear Station Unit No. 1)
Docket No. 50-289 (Restart)
Dear Mr. Chilk:
Enclosed for the information of the Commission, Appeal Board, Licensing Board and parties are materials relating to the adequacy of emergency planning at Three Mile Island, Unit 1 ("TMI-1").
On November 16, 1983, Licensee conducted its annual emergency preparedness exercise at TMI-1.
En-closed is a copy of NRC Inspection Report No. 50-289/83-35 which sets forth the findings and conclusions of the NRC Staff personnel who observed the exercise.
In prepara-tion for the annual exercise, personnel at TMI-l conducted a number of training drills.
During one of these drills on November 2, 1983, GPU Nuclear's Manager for Emergency Preparedness requested that the Institute of Nuclear Power Operations ("INPO") send representatives to observe the drill.
Enclosed is a November 28, 1983 letter from INPO setting forth their findings and conclusions on that drill.
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SHAw, PITTMAN. PoTTs & TROWBRIDGE A PARTNC ASHIP OF PmOFEsseONAL CompomATIONS Mr. Samuel J. Chilk February 3, 1984 Page Two Also enclosed is a February 2, 1984 letter from GPU Nuclear's Vice President-Nuclear Assurance (R. L. Long) to INPO responding to the INPO recommendations and, where appropriate, in its Inspection Report No. referencing findings by the NRC Staff 50-289/83-35.
Respect ully submit ed, Robert E.
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.er Counsel for censee cc:
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Docket No. 50-289
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(Restart)
CIhree Mile Island Nuclear
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Station, Unit No. 1)
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SERVICE LIST Chairman Nunzio J. Palladino Dr. Reginald L. Gotchy U.S. Nuclear Regulatorf Camission Atmic Safety and Licensing Appeal Washington, D.C.
20555 Board U.S. Nuclear Regulatory Ccmnission Ccmnissioner Victor Gilinsky Washington, D.C.
20555 U.S. Nuclear Pegulatory Camission Washington, D.C.
20555 Ivan W. Smith, Esquire Chatzman, Atmic Safety and Licensing Camissioner 'Ihcnas M. Ibberts Board U.S. Nuclear Regulatory Camission U.S. Nuclear Regulatory Ccrmission Washingtcri, D.C.
20555 Washington, D.C.
20555 Camissioner James K. Asselstine Sheldon J. Wolfe, Alternate Chairman U.S. Nuclear Regulatory Camission Atcmic Safety and Licensing Board Washington, D.C.
20555 U.S. Nuclear Peculatory Ccumissicn Washington, D.C.
20555 Ca missioner Frederick M. Bernthal U.S. Nuclear Regulator / Camissicri Mr. Gustave A. Linerterger, Jr.
Washingtcn, D.C.
20555 Atcmic Safety and Licensing Board U.S. Nuclear Fegulatory Ccrmission Docketing and Service Section Washington, D.C.
20555 Office of the Secretarf U.S. Nuclear Regulatory Camission Joseph R. Gray, Esquire Wa<hington, D.C.
20555 Office of Executive I4 gal Director U.S. Nuclear Pegulatory Ca mission Gary J. Edles, Esquire Washington, D.C.
20555 Chairman, Atcmic Safety and Licensing Appeal Board John A. Iavin, Esquire U.S. Nuclear Regulatory Camission Assistant Counsel Washington, D.C.
20555 Pennsylvania Public Utility Ca mission P. O. Box 3265 Dr. John H. Buck Harrisburg, PA 17120 Atcmic Safety and Li nsing Appeal Board Marjorie M. Aamodt U.S. Nuclear Regulatorf Camission R. D. 5 Washington, D.C.
20555 Coatesville, PA 19320
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Douglas R. Blazey, Esquire Chief Counsel Steven C. Shally Department of Environmental Resources Union of Concerned Scientists 514 Executive House, P. O. Box 2357 1346 Connecticut Avenue, N.W.,
- 1101 Washington, D.C.
20036 Harrisburg, PA 17120 Ms. Icuise Bradford ANGRY / M PIPC M ALERr 1037 Maclay Street 1011 Green Stmet Harrisburg, PA 17103 Harrisbur*g, PA 17102 Chauncey Kepford Ellyn R. Weiss, Esquire Judith H. Johrsn:d i
Har:ron & Weiss Erwironmntal Coalition on Nuclear her 1725 Eye St., NW, Suite 506 433 Orlando Avenue Washington, D.C.
20006 State College, PA 16801 l
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NUCLEAR REIULATORY COMMISSION 9
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.g4 ((g _7 AH :44 GPU Nuclear Corporation ATTN: Mr. H. D. Hukill f7Q~~ [_ %
Vice President and Director of TMI-l
._, o P. O. Box 480 Middletown, Pennsylvania 17057 Gentlemen:
Subject:
Inspection Report No. 50-289/83-35 This refers to the routine safety inspection conducted by Mr. N. M. Terc of this office on November 15-18, 1983 of activities authorized by NRC License No.
DPR-50 and to the discussions of our findings held by Mr. N. M. Tere with Mr.
H. D. Hukill of your staff at the conclusion of the inspection.
The area examined during this inspection was limited to observation of your Emergency Exercise, conducted on November 16, 1983. Within this area, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.
The emergency response actions of your staff during the exercise demonstrated the capability to adequately implement your emergency plans and procedures to provide protective measures for the health and safety of the public.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Room unless you notify this office, by telephone, withiri ten days of the date of this letter and submit written application to withheld information contained therein within thirty days of the date of this letter.
Such application must be consistent with the requirements of 2.790(b)(1).
The telephone notification of your intent to request withholding, or any request for an extension of the 10 day period which you believe necessary, should be made to the Supervisor, Files, Mail and Records, USNRC Region I, at (215) 337-5223.
No reply to this letter is required.
Your cooperation with us in this matter is appreciated.
Sincerely, Thomas T. Martin, Director Division of Engineering and Technical Programs
Enclosure:
NRC Region I Inspection Report No. 50-289/83-35
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GPU Nuclear Corporaticn 2
cc w/ encl:
R. J. Toole, Operations and Maintenance Director, TMI-l C. W. Smyth, Supervisor, TMI-l Licensing E. G. Wallace, Manager, PWR Licensing J. B. Liberman,. Esquire G. F. Trowbridge, Esquire Public Document Room (POR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector Commonwealth of Pennsylvania Ms. Mary V. Southard, Co-Chairman, Citizens for a Safe Environment (Without Report) bec w/ encl:
Region I Docket Roch (with concurrences)
L. Barrett, Deputy Program Director, TMI Program Office J. Goldberg, OELD: HQ Senior Operations Officer (w/o encis)
Ms. Mary V. Southard, Co-Chairman, Citizens for a Safe Environment DPRP Section Chief J. Van Vliet, PM, NRR 4'
U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No.
50-289/83-35 Docket No.
50-289 License No.
DPR-50 Priority Category C
Licensee: GPU Nuclear Corporation Facility Name: Three Mile Is1.and Nuclear Station, Unit 1 Inspection At: Three Mile Island, Pennsylvania Inspection Conducted:
November 15-18, 1983 Inspectors:
M' JL
- /72/#-]k N. M. Terc, Exercisej eam~ Leader, EPS, DETP
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J. J. Hawxhurst, NRC, RI L. H. Thonus, Resident Inspector THI-2, NRC J. A. Thomas, NRR, NRC, TMS-1 K. Abraham, PAO, NRC K. R. Barr, RS, TMI-I, NRC J. M. Pisarcik, PNL F. N. Carlson, PNL F. W. Vo bury Wes x, PNL Approved by:e h
/MX*/#.5 H. W. Crocker?-Chief EPS, DETP date
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Inspection Summary: Inspection on November 15-18, 1983. Report No. 50-289/83-31)
Areas Inspected:
Routine, announced emergency preparedness inspection and observation of the Licensee Emergency Exercise performed on November 16, 1983.
Results:
The inspection involved 330 hours0.00382 days <br />0.0917 hours <br />5.456349e-4 weeks <br />1.25565e-4 months <br /> by a team of nine Region I inspectors and NRC contractor personnel.
The licensee's emergency response actions for this exercise were adequate to provide protective measures for the health and safety of the public.
No violations were identified.
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OETAILS 1.
Persons Contacted The following licensee representatives attended the exit meeting on November 18, 1983.
Name Title Baker, G.G.
Manager Environmental Controls Danahy, R. J.
Environmental Control Staff Giangi, G. J.
Emergency Preparedness Manager, TMI Hukill, H. D.
Director TMI-I Levin, L.
Site Operations Director, TMI-2 Long, R. C.
Vice President Nuclear Assurance Rogan, R. E.
Manager Emergency Preparedness, GPUN Smyth, C. W.
Licensing Manager, TMI-I Toole, R. J.
D&M Director - TMI-1 2.
Emergency Exercise The Three Mile Island Nuclear Station, Unit I fu11 scale exercise was conducted on November 16, 1983 from 12:30 p.m. until 8:30 p.m.
a.
pre-Exercise Activities Prior to the emergency exercise, NRC Region I representatives had telephone discussions with licensee representatives to review the scope and content of the exercise scenario. As a result, revisions were made by the licensee to add certain operational events (e.g.
control rod mechanism failure) and modify-operational and radiological data.
In addition, NRC observers attended a licensee briefing for licensee controllers and observers on November 15, 1983, and participated in the discussion of emergency response actions expected during the various phases of the scenario.
The licensee stated that certain emergency response activities would be simulated and that controllers would intercede in activities to prevent disturbing normal plant operations.
The exercise scenario included the following events:
- multiple primary to secondary systems leaks (e.g. steam generators failures)
- significant amount of failed fuel
- 1arge offsite releases of radioactivity
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3
- contaminated and injured individual
- radiography incident and fire The above events caused the activation of the licensee's emergency facilities and also permitted the state and counties to exercise their Emergency Plans.
b.
Exercise Observation During the conduct of the licensee's exercise, NRC team members made detailed observations of the activation and augmentation of the emer-gency organization; activation of emergency response facilities; and actions of emergency response personnel during the operation of the emergency response facilities.
The following activities were observed:
(1) Detection, classification, and operational assessment of scenario events; (2) Direction and coordination of the emergency response; (3) Notification of licensee personnel and offsitt agencies; (4) Communications, information flow, record keeping, and sample distribution; (5) Assessment and projection of radiological doses and protective actions, and recommendations; (6) Provision for in plant radiation protection; (7) Offsite and in plant radiological surveys; (8) Maintenance of site security and access control; I
(9) Technical support to operations; (10) Repair and corrective actions; (11) First aid and rescue; (12) Assembly and accountability of personnel.
The NRC team noted that the licensee's activation and augmentation of the emergency organization; activation of the emergency response facilities; and actions and use of the facilities were generally consistent with their emergency response plan and implementing procedures.
The team also noted the following areas where the licensee's activities were thoroughly planned and efficiently implemented:
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- Individuals in the Emergency Control Center (ECC) assigned to perform source-term, dose and dose projections calculations were efficient.
- Briefings and communications used for post-accident sampling were excellent. Radiological controls were very good.
In general the team performed very efficiently.
- Emergency Response Facilities (e.g. OSC, TSC, EOF) showed a marked improvement from previous emergency exercise.
Tne new and upgrad-ed facilities contributed to an overall very good accident response.
In addition, the organization and noise level control in the Emergency Control Center (ECC) contributed to an efficient coordination of the onsite emergency response.
- Repair and corrective action teams performed well.
- Personnel coordinating Emergency Response Facilities (ERFs) showed above average proficiency in the perfonnance of their emergency duties.
- Offsite emergency monitoring teams performed well (e.g., good radiation protection, technical proficiency, highly motivated).
- News Media Center communication and equipment were good.
Staff generally was properly trained.
- Record keeping and sample disposition were generally efficiently performed.
The NRC team findings in areas for licensee improvement were as l
follows (the licensee also identified most of these areas in their critique of the exercise):
Concept of Operations The Technical Support Center (TSC) failed to perform an active role supporting the operations group and the command and control functions l
after the initial stages of the simulated accident (i.e., the initial 45 minutes). There were various instances in which the TSC staff did not provide indepth diagnostic and corrective engineering assistance.
These were as follows:
- After a primary to secondary system leakage was reported, the TSC failed to take actions in order to ascertain the source of the l
leakage.
- When reported that there was inability to borate the primary system, the TSC staff failed to assist operators in establishing the restoration of boration systems.
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- The TSC staff failed to independently confirm chemistry results which indicated.that the B once through steam generator was leaking..
- The TSC staff failed to determine the leak rate and its source.
- When informed that'there was 22% failed fuel, no efforts were made by the.TSC to verify the extent of fuel damage, and no recommenda-tions were made by the TSC staff pertaining to the implications of the fuel failure concerning habitability of plant operating areas.
- The TSC staff failed to interact with the Radiological Assessment Group to evaluate the implications of steaming through bypass valves and the offsite release resulting as a consequence of this action.
- When informed of projected radiation levels at the site boundary i
which were inconsistent with 22% of failed fuel, the TSC staff failed to question or take action in this regard.
The TSC staff was provided very little direction by the Emergency Control Center or the Emergency Operations Facility. They were not assigned specific tasks and were left on their own initiative.
Although the staff was knowledgeable and talented, they remained underutilized for the most part of the exercise.
Information Flow
- Environmental Assessment Control Center (EACC) staff was slow in responding to offsite teams and failed to provide direction to mobilize teams to low background areas.
EACC also failed to report data back to verify its accuracy, and to inform teams con-cerning changing accident and plant conditions.
- A protocol for radio-communication between ERFs and offsite teams is needed to improve the extent and quality of information exchanges
- The Emergency Support Director (ES0) failed to brief personnel in the Emergency Operations Facility (EOF) concerning follow-up of certain items (e.g. state actions on Protective Action Recommenda-tions).
I
- Post-accident sample request from Emergency Control Center to Oper-l tions Support Center (OSC) staff was unnecessarily delayed.
Information from Repair-Teams concerning the status of repairs were delayed; and communication between in plant teams and the OSC staff was poor.
- Translation of technical terminology to plain English by News Media briefer was poor.
9 6
Scenario and Controllers
- Operating and obtaining Post-Accident samples were simulated.
Controller in this area lacked specific information for players.
- Scenario inconsistencies resulted in confusion and time delays (e.g. concerning amount of fuel damage; declaration of general emergencies).
- Controllers failed to follow inplant teams during the initial phases of the simulated accident and up to one hour after the ALERT classification announcement.
- No forecast meteorological data was available, so that the scenario was limited to persistence of similar meteorological con-ditions rather than using a standard Nation Weather Service Foremat forecast.
- Meteorological data from only one distance above the ground surface was provided to players.
This limited amount of free play in this area.
Organizationel Control and Protective Action Recommendations
- Some confusion resulted from the decision of maintaining a full double staff assigned to the EOF.
- Verification of significant offsite and site perimeter radiological dose rate readings was lacking.
Dose Assessment
- The emergency procedure used for dose projections had no provi-sions for calculating elevated releases, and as a consequence l
performance in this area could not be properly evaluated.
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- The distance scale used in tracking offsite teams at the EOF was too large.
This resulted in difficulties in tracking teams close l
to the site.
- The radioactive plume was misrepresented as a " puff" by the Emer-gency Support Director.
- The release pathway for gaseous radionuclides was identified as a ground level release.
This level and the resulting radiological projections were n:t consistent with recommendations in Regulatory Guide 1.23 for a ground level release. Since Emergency Procedure 1004.7 was not consistent with the guide, there would be a risk l
of underestimating actual concentrations of radioactivity and in i
estimating correct plume trajectories.
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1 Radiation Protection and First Aid
. Personnel monitoring, surface contamination and air sampling, were lacking in the EOF.
- Procedures to recount air samples in the field, for checking personnel and equipment for radioactive. contamination, were lacking for offsite teams.
In addition, data forms to maintain dose rates for backup personnel exposure estimates were not in place.
- Pre planning for onsite surveys personnel assignments was deficient. A member of the onsite/ perimeter survey team had not been fitted to wear a respirator.
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- Personnel failed to check that the vehicle to be used had a voltage convertor that would allow the taking of air samples.
This resulted in loss of time.
- One of the repair teams was unnecessarily exposed to radiation while suiting up in a control tower stairwell; an area reading 20 mr/hr.
In addition, PA announcements could not be heard in that area.
Security, Access Control and Notification
- Access and egress from the main assembly area, prior to site evac-uation was not properly controlled. As a consequence account-ability and control of personnel in these areas during accident conditions were poor.
c.
Exercise Critique The NRC team attended the licensee's post-exercise critique on November 17, 1983, during which key licensee controllers discussed their observations of the exercise.
The licensee participants high-lighted areas for improvement which the licensee indicated would be evaluated and appropriate action taken.
3.
Exit Meeting and NRC Critique The NRC team met with the licensee representatives listed in Section 1 on November 18, 1983.
The team le der summarized the observations made a
during the' exercise and discussed the areas described in Section 2.b.
The licensee was informed that no violations were observed and although there were areas identified for improvement, the NRC team determined that within the scope and limitations of the scenario, the licensee's perfor-mance demonstrated that they could implement their Emergency Plan and Emergency Plan Implementing Procedures in a manner which would adequately provide protective measures for the health and safety of the public.
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Licensee management acknowledged the findings and indicated that appro-priate action would be taken regarding the identified improvement areas.
- At no time during the inspection, did the inspectors provide any written information to the licensee.
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institute of Nuclear Power w
Operations y
1100 Circle 75 Parkway J
Suite 1SM Atlanta. Georgia 30339 Telephone 404 953 3600
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qp' November 28, 1983 i
l Mr. John R. Thorpe Director, Licensing and Regulatory Affairs GPU Nuclear Corporation 100 Interpace Parkway Parsippany, NJ 07054 Dear Mr pe:
At the request of Mr. Robert Rogan, a special assistance visit to Three Mile Island-Unit 1 (TMI-1) was conducted on November 1-2, 1983.
We asked our representatives to return to INPO and discuss their thoughts with other experienced personnel before any written recommendations were forwarded.
Attached is a copy of our representatives' report.
It is provided to you independent of our evaluation program and is intended solely for your assistance and use as desired.
I hope you find this information useful.
Please do not hesitate to contact me or have your staff contact Mr. P. W. Lyon, Director, Radiological Protection and Emergency Preparedness Division, at (404) 953-5350 directly on this matter.
Sincerely, d
Zack T. Pate Executive Vice President ZTP:jkc Attachment ec:
Mr. Herman M. Dieckamp Mr.
P. W. Lyon
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1-9- @ f-h Institute of 3
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Nuclerr Power 3
Operations L
i Memorandum D*:
November 15, 1983 P. W. Lyon/A. S. Howard gj From:
R.
oody; P.
Hayes; W.
. Carnes suc ect:
TRIP REPORT - TEREE MILE ISLAND-UNIT 1 (TMI-1) r SPECIAL ASSISTANCE VISIT I.
Purpose As a result of a request from Mr. Robert Rogan, Manager -
Emergency Preparedness, General Public Utilities Nuclear Corporation (GPU), a special assistance visit was made to the Three Mile Island-Unit 1 (TMI-1) on November 1-2, 1983.
The purpose of the trip was to observe a practice emergency preparedness drill and provide recommendations for improving their response in preparation for a graded full-scale exercise.
II.
Scope November 1, 1983, was spent being trained by GPU emergency preparedness personnel on the scenario and objectives for the drill.
The areas of the emergency preparedness program that were observed during the drill and the respective INPO observers were:
Mr. Robert Moody, control room, technical support center, (TSC), and operational support center (OSC) ; Mr. Paul Hayes, emergency operations facility (EOF), and environmental assessment command center (EACC);
and Mr. Earl Carnes, the GPU media center.
Following the drill, each team member presented his observations at a meeting with Dr. Robert Long, vice president - nuclear assurance, Mr. Robert Rogan, manager - emergency preparedness, and Mr. Sandy Polon, manager - public communications.
III.
Personnel Contacted In addition to those individuuls mentioned in section II, discussions concerning the drill were held with Mr. George Giangi, site emergency preparedness manager.
m
i f A, Trip Report - TMI-l Special Assistance Visit Page Two IV.
Recommendations A.
Control Room 1.
Information flow between the emergency director and the radiological assessment center should be improved with respect to the handling of dose assessment and chemistry data.
2.
Emphasis is needed to help ensure events and actions are properly logged.
3.
Control room operators should practice completing procedure check-off lists during drills and exercises.
4.
The purpose of the status board should be reevaluated.
Very little information was recorded on the status board.
Because of the board's size and location, it takes up potentially valuable space in the control room.
5.
Emergency directors should be more familiar with the emergency classification system and its relationship to protective action recommendations.
B.
Technical Support Center (TSC) 1.
Status boards should be provided for recording plant status; key parameters; events and actions; and trending.
INPO Good Practice EP-802 may be of assistance in this area.
C.
Operational Support Center (OSC) 1.
The OSC coordinator and his immediate supervisors should be organized and located where they can operate effectively as a team for an eight to twelve hour shift.
Consideration should be given to providing a table, chairs, and communications equipment.
2.
The status boards should be improved.
Additional status boards should be considered and the need to keep information for longer periods should be evaluated.
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-b Trip Report - TMI-l Special Assistance Visit Page Three t
D.
Emergency Operations Facility (EOF) 1.
The need to keep logs of events and actions should be re-emphasized for those who staff the EOF.
2.
The cumulative dose charts provided in the main l
portion of the EOF should be used.
E.
Media Center 1.
Some staff did not maintain log sheets to keep track of activities.
These logs are valuable when reconstructing events and actions.
2.
Guidelines should be established to assist in determining what type of technical information should be included in news releases.
This process could be accomplished by assigning a technically qualified individual to assist communications personnel in preparing draft news releases.
3.
The media center should be enlarged, as proposed, to accommodate the number of media representatives that could be expected during a major event.
REM /PEH/WEC:jke l
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GPU Nuclear Corporation
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s pany,Ne v Je sey 07054 201 263-6500 TEt.EX 136-482 Writer's Direct Dial Number:
February 2, 1984 NA/528
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Mr. Zack T. Pate Executive Vice President Institute of Nuclear Power Operations 1100 Circle 75 Parkway Suite 1500 Atlanta, GA 30339
Dear Mr. Pate:
This is in response to your letter to Mr. John R. Thorpe, dated November 28, 1983, which transmitted a copy of the " Trip Report-Three Mile Isla.nd-Unit 1 (TMI-1) Special Assistance Visit".
The Company appreciates the INPO Team's frank discussion and constructive criticism.
The Team's recomendations were helpful in preparing for the TMI Annual Exercise.
We have reviewed the recomendations, looking particularly for evidence of potential programmatic deficiencies--none have been identified.
In addition, while you did not request a response, we have included in Appendix A coments and additional clarifying information bearing on the recommendations addressed in the report.
Subsequent to the visit by the INPO Team, TMI participated in it's annual emergency exercise which was evaluated by the NRC.
The observations of the NRC Inspection Team are reflected in Inspection Report No. 50-289/83-35, dated January 9, 1984, and are referenced in our comments.
Finally, it is noteworthy that significant upgrade of existing emergency response facilities was completed and the new Emergency Operations Facility (E0F) was occupied within thirty days preceding the November 2,1983 drill.
Therefore, the drill served as a shakedown of many new improvements in our program.
The Team's coments were helpful in refining our programs and procedures.
We remain confident that our internal audit system, complemented by the INP0 assistance visits, will continue to ensure the maintenance of a high state of emergency preparedness at Three Mile Island.
Sincerely, R. L. Lon Vice Pres ent Nuclear Assurance RLL/mkk Attachment cc:
E. E. Kintner R. E. Rogan J. R. Thorpe GPU Nuclear Corporation is a subsidiary of the General Public Utihties Corporation
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APPENDIX A GPUNUCI.EARRESPONSETOINP0RECOPetENDATIONS A.
Control Room 1.
Recommendation:
Information flow between the emergency director and the radiological assessment center should be improved with respect to the handling of dose assessment and chemistry data.
Response
Prior to the November 2,1983 drill, the RAC area had been relocated behind the Reactor Protection System Panels in the Control Room.
Although this move resulted in many positive features, one setback was the physical separation of the RAC from the ED. Consequently, information flow was hampered. Upon recognition of this problem, it was established that the RAC would consult with the ED on a periodic basis or as a change in status occurred.
This salution proved effective during the Annual Exercise.
Four of eisiit activities identified in the NRC Exercise Report as having been thoroughly planned and efficiently implemented were directly applicable to this activity.
2.
Recommendation:
Emphasis is needed to help ensure events and actions are properly logged.
Response
An internal critique of the drill resulted in a similar conclusion.
As a result, additional information in the form of specific instructions on proper logkeeping and the maintenance of status boards was conveyed to all members of the emergency response organization.
Specific instructions also have been incorporated in the Communications and Recordkeeping Procedure providing i
additional clarification.
It is expected that a formal procedure l
change will be implemented prior to March 1, 1984.
It is noteworthy that recordkeeping also received special note in the NRC Inspection Report as having been " generally efficiently performed".
3.
Reconsnendation:
Control Room Operators should practice completing procedure check-off lists during drills and exercises.
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Response
Control Room Operators subsequently have been advised, as a reaffirmation of current policy, to use the official copies of procedures during drills / exercises in a manner similar to a real emergency.
This problem has been corrected as evidenced by their performance during the Annual Exercise. As noted above, recordkeeping was an activity worthy of special note in the NRC Annual Exercise Report.
APPENDIX A i
Page Two
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4.
Recommendationi The purpose of the status board should be re-evaluated. Very little information was recorded on the status board.
Because of the board's size and location, it takes up potentially valuable space in the Control Room.
Response
The function and value of the status board was reassessed by plant management.
It was determined that it did serve a useful purpose if properly maintained.
Subsequently, the plant operations staff has developed procedures to maintain the status board up-to-date with key plant data throughout the emergency.
Marked improvement was evident during the Annual Exercise.
5.
Recommendation:.v.
Emergency Directors should be more familiar with the emergency
' classification system and its relationship to protective action recommendations.
Response
Emergency Director training will continue to emphasize the emergency classification system and the protective action recommendation (PAR) decision-making process. A procedural change involving the addition of a PAR decision-making logic diagram is currently in place ~and provides a logical approach to the evaluation of
' plant conditions as well as radiation releases in arriving at aidecision concerning protective action recommendations. A
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procedural change dealing with emergency declaration will reformat the emergency action levels so that emergency action levels for all classifications of emergency are displayed on a single s
page.
This change will facilitate the correlation of changing conditions to emergency action, levels and the resultant increase or decrease in the severity of the event leading to reclassification of an emergency.
Procedural changes are expected to be fully implemented in the first quarter 1984.
B.
Technical Support Center (TSC) 1.
Recommendation:
Status boards should be provided for recording plant status; key parameters; events and actions; and trending.
INP0 Good Practice EP-802 may be of assi:tance in this area.
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APPENDIX A Page Three
. Response:
At the time of the November 2,1983 drill, a new primary status board was under development for the TSC.
The board essentially duplicates the status board used at the ECF and provides an appropriate format for recording plant status and key plant
- parameters. The status board was installed prior to the Annual Exercise and appeared to provide the information needed for analysis and development of technical information. The Plant Engineering Staff desires to retain an additional, blank status board for use in recording data, as appropriate, for varying scenarios.
- C.
Operational Supoort Center (OSC) 1.
Recommendation:
The OSC Coordinator and his immediate supervisors should be organized and located where they can operate effectively as a team for an eight to twelve hour shift. Consideration should be given to providing a table, chairs, and communications equipment.
Response
Immediately preceeding the November 2,1983 drill, the OSC internal layout was redesigned.
This drill served as a practical test to determine how best to utilize the available space. As a result, the OSC Coordinator's area was permitted to be used as a general thoroughfare for personnel.
This problem was corrected prior to the Annual Exercise.
It also should be noted that the OSC Coordinator has a conference room with a desk, table, and chairs for his use and that of his coordinators. This conference room was used extensively during the Annual Exercise. Again, it is noteworthy that the NRC Exercise Report highlights the significant upgrade of the~ emergency response facilities (ERF's) and the "above average proficiency" demonstrated by the ERF staffs.
2.
Recomendation:
The status board (OSC) should be improved. Additional status boards should be considered and the need to keep information for longer periods should be evaluated.
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Response
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- Sufficient status boards have'been provided in the OSC to reflect emergency team organization and for efficier.t team tracking.
The team tracking board has been upgradef by the addition of space,to record additional data concerning team status, actions
..,'taken, results, other findings and observations.
These upgraded
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status boards will provide a better historical record of team status during extended periods in radiologically hazardous areas or when dispatched in an emergency response role.
The. addition of "as-built" floor plans of the' Turbine Building, expected 7
to be in-place by April 1, 1984, will complete the plant status (f.e., briefing) boards, i
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Emergency Operations Facility (EOF) 1
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,1.
Recommendation:
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s The'need to keep logs of events and actions should be re-emphasized for those who staff the EOF.
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Response
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Recommendation:
.. The cumulatfve dose charts provided in the main portion of the h EOF should De used.
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Response
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t 1The cumulative dose charts were a newly developed innovation v
M in dose data display. Their effective.use is dependent upon computeri enerated date During the November 2. 1983 drill, f
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the offsite monitoring. team base station radio created electrical interferencewhicherasedtheccmfutermemoryandtht}Annualcapability i
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to generate the required data wps lost.
Prior to the
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Exercise, the problem was corrected and cumulative dose data
-displays were effectively stilized. However, as'with all such 44 displays, these boards continue to undergo an iterative upgrading
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7 E.
Media Center, I
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1.
Reconmendation:
r is Some staff did not maintain;1og sheets to keep track of activities.
L; These logs are valuable when reconstructing events and actions.
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- I APPENDIX A Page Five
Response
Specific log books have been designed for use by personnel at the Media Center and at other emergency comunications locations.
These logs were used during the recent Aanual Exercise and are now included in implementing procedures.
2.
Recomendation:
Guidelines should be established to assist in determining what type of technical information should be included in news releases.
This process should be accomplished by assigning a technically qualified individual to assist comunications personnel in preparing draft news releases.
Response
The responsibility for approval of news releases during an emergency -
resides with either the Emergency Director or the Emergency Support Director. Normally the extent to which technical information is contained in news releases is determined in the approval process.
During the Annual Exercise, the staff technical advisors reviewed proposed media releases prior to presentation to the Emergency Director / Emergency Support Director for approval.
This additional review process facilitated timely approval by the senior Company spokesperson.
In addition, the Comunications Division is reviewing its staffing at the new EOF and intends to implement any advisable changes in the near term.
3.
Recommendation:
1 The Media Center should be enlarged, as proposed, to accomodate l
the number of media representatives that could be expected during a major event.
Response
The Vice President-Comunications has initiated the necessary action to implement an existing plan to significantly upgrade the facility and its capabilities.
Expansion of the facility is expected to be completed prior to June 30, 1984.
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