ML20125C057
| ML20125C057 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/07/1992 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20125C056 | List: |
| References | |
| 50-445-92-46, 50-446-92-46, NUDOCS 9212110024 | |
| Download: ML20125C057 (14) | |
See also: IR 05000445/1992046
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APPENDIX
U.S. NUCLEAR REGULATORY COMMISSION
REGION-IV
Inspection Report: 50-445/92-46
50-446/92-46
Operating License: NPF-87
Constructiun Permit: CPPR-127
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Licensee: TV Electric
Skyway Tower
400 North Olive Street, L.B. 81
Dallas, Texas 75201
Facility Name: Comanche Peak Steam Electric Station l
Inspection At: Glen Rose, Texas
Inspection Conducted: November 16 through 20, 1992
Inspectors: D. Blair Spitzberg, Ph.D., Emergency Preparedness Analyst,
-Team Leader
K. M. Kennedy, Project Engineer j
0. Barss, Emergency Preparedness Specialist, Office of Nuclear
Reactor Regulation (NRR)
Accompanying
Personnel: J. D. Jamison, Senior Staff Scientist, Battelle Laboratories
G. W. Bethke, Comex Corporation-
R. Emch, Section Chief, Emergency Preparedness Branch, NRR
M. L. Thomas, Radiation Specialist, Office of Nuclear Regulatory
Research
Approved: 8 /([i [d 8kg
B hine Murray, Cthef, Facil ties
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Inspection Programs Soft on
Inspection Summary
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Areas Inspected: Routine, announced inspection of the licensee's performance
and capabilities during an annual exercise of the emrgency plan and
implementing procedures. The team observed activities in the control room
(simulator), Technical Support Center, Operational Support Center, and the
Emergency Operations Facility.
9212:r v024 921207
PDR !. DOCK 05000445
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Results:
e The control room staff performance was strong during the exercise
(Section 2).
e The Technical Support Center was staffed and activated promptly
(Section 3),
e An exercise weakness was identified for delays in detecting and
classifying two emergency classes (Section 3.1).
- An exercise weakness was identified for failure to make prompt
notifications to offsite authorities of an emergency classification
(Section 3.1).
e The Operational Support Center was staffed and activated promptly.
Information flow within the Operational Support Center and between the
Operational Support Center and other facilities was good. Repair teams
followed proper safety controls and were well briefed (Section 4).
e The Emergency Operations Facility was staffed and activated promptly,
and personnel were proficient in carrying out their assigned duties.
The press conference'did not clearly convey essential information which
was available at the time to the media (Section 5).
e An exercise weakness was identified for several examples of weak
emergency command and control (Section 6.1).
e The sccaarlo and exercise preparation provided sufficient challenge to
demonstrate the exercise objectives (Section 7).
e The licensee's self-critique process was excellent in identifying areas
in need of corrective action (Section 8).
Summary of Inspection Findinas:
- Exercise Weakness 445/9246-01; 445/9246-01 was opened (Section 3.1).
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- Exercise Weakness 445/9246-02; 446/9246-02 was opened (Section 3.1).
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e Exercise Weakness 445/9246-03; 446/9246-03 was opened (Section 6.1).
Attachment:
Attachment 1 - Persons Contacted and Exit Meeting
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DETAILS
1 PROGRAM AREAS INSPECTED (82301)
' The licensee's annual emergency preparedness exercise began at 2 a.m. on
November 18, 1992. The exercise start time had been withheld from exercise
participants. The exercise did not involve participation by offsite agencies.
Initial conditions for the exercise included full power operations in Unit I
with Diesel Generator 2 removed from service. Unit 2 was undergoing
pre-operational testing, and its equipment and systems were unavailable for
use during the exercise. The exercise began with a small steam generator tube
r Mture meeting the conditions for a Notification of Unusual Event. A short
tir..a later, a fire alarm was received in the control room (simulator)
indicating a fire in the Emergency Diesel Generator 1-01 Day Tank Room. This
would lead to conditions corresponding to an Alert classification. Following
several subsequent minor events, the scenario presented a significant increase
in the size of the steam generator tube rupture concurrent with an unisolable
steam break uutside of containment on the affected steam generator. These
events led to conditions corresponding to a Site Area Emergency, with activity
in the primary coolant being released to the environment. About 40 minutes
later, the final significant event occurred with the rupture of a waste gas
decay tank drain line. The scenario called for the emergency to be terminated
while in the Site Area Emergency classification with two offsite release
pathways. The releases were not of a magnitude to cause offsite dose
projections to exceed Environmental Protection Agency protective action
guidelines.
The inspection team identified various concerns during the course of the
exercise; however, none were of the significance of a deficiency as defined in
10 CFR 50.54(s)(2)(ii). Each observed concern is characterized as an exercise
weakness or as an area recommended for improvement. An exercise weakness is a
finding that a licensee's demonstrated level of preparedness could have
precluded effective implementation of the emergency plan in the event of an
actual emergency. An exercise weakness 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
still should be evaluated and corrected as appropriate by the licensee.
l 2 CONTr10L ROOM (82301-03.02.b.1)
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,- The inspection team observed and evaluated the control room staff as they
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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.
2.1 Discussion
The control room simulator was used to initiate the exercise. Dynamic
simulation of the exercise was accomplished throughout the exercise.
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Overall, the control room staff performance was observed to be strong during
the exercise. The crew successfully detected abnormal events, analyzed plant
conditions, and aggressively pursued corrective actions and alternate success
paths. Augmentation of the control room staff by offsite personnel assigned
to Emergency Organization positions occurred within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> following the Alert
declaration. The Notice of Unusual Event and the Alert classifications were
both made from the control room during the exercise. The inspectors observed
that the classification of the Alert was delayed by the control room crew
after confirming that a fire in the protected area which lasted more than 10
minutes was potentially affecting a safety system. This observation is
discussed in detail in Section 3.1 as part of an exercise weakness in
detection and classification. Notifications to offsite authorities from the
control room were timely and accurate. The inspection team noted that the
control room crew performed prompt and appropriate offsite dose projections
based on the small steam generator tube leak.
The following observations made in the control room did not significantly
detract from the overall effectiveness of the licensee's response and are
identified as potential areas for improvement:
e following the declaration of a Notification of Unusual Event and the
subsequent activation of the pager system, the control room received
numerous phone calls requesting information from offsite personnel with
pagers. These phone calls were handled by the two control room
communicators and the Emergency Coordinator which caused a distraction
to the performance of their duties.
e Control room logs were not maintained during the late stages of the
exercise between 5:09 a.m. and the termination of the exercise at 6:09
a.m. During this time period, events which were not logged by the
control room included the rupture of a waste gas decay tank and the loss
of an offsite power distribution line.
2.2 Conclusions
The performance of the control room staff was observed to be strong during the
exercise. A delay in the classification of the Alert contributed to an
exercise weakness in detection and classification (Section 3.1).
3 TECHNICAL SUPPORT CENTER (82301-03.02.b.2)
The inspectors observed the operatiu of the Technical Support Center from
activation through termination of the exercise. The inspectors evaluated
staffing, command and control, technical assessment and support of operations,
classifications and notifications, dose assessment, formulation of protective
action recommendations, and adherence to the emergency plan and implementing
procedures.
3.1 Discussion
The Technical Support Center was staffed and activated promptly within I hour
of the Alert declaration. The transition of emergency command from th:
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control room to the Emergency Coordinator in the Technical Support Center was
noted to be inefficient and confusing. Inspector observations related.to the-
transfer of Emergency Coordinator duties to the Technical Support Center are
discussed in further detail in Section 6.1 as part of an exercise weakness in
emergency comand and control .
Technical Support Center briefings were held approximately every half hour.
These briefings included a presentation by each major technical area
coordinator and served to keep all Technical Support Center personnel apprised
of plant conditions and priorities. The classification and declaration of the
Site Area Emergency was made from the Technical Support Center approximately
18 minutes following this facility's activation. The inspectors noted
unnecessary delays associated with the detection and classification of the
initiating conditions for two of the three emergency classifications made
during the exercise as follows:
e In the control room, the Emergency Coordinhtor failed to *.mplement
correctly Procedure EPP-201, " Assessment of Emergency Action Levels,
Emergency Classification and Plan Activation," Chart 11, " Fire." This
chart indicated that a fire inside the protected area lasting-greater
than 10 minutes for which safety systems were potentially affected by
the fire would result in an Alert classification. The Emergency
Coordinator failed to declare an Alert 10 cinutes after the Diesel
Generator 1-01 Day Tank Room fire alarm was received in the control
room. Instead, the declaration was made 10 minutes after the existence
of the fire was confirmed by an auxiliary operator dispatched to the
scene. This resulted in a 6-minute delay in the Alert classification.
Through player interviews, the inspectors determined that the Emergency
Coordinator began the 10-minute countdown at the time when the fire was
confirmed by the auxiliary cperator. The operator confirmation took
6 minutes from the receipt of the alarm. During this 6 minutes, the
fire potentially affected safety systems. Under the conditions of this
scenario, following the operator's confirmation of the fire, the Alert
classification conditions were met 10 minutes after the receipt of the
fire alarm.
e in the Technical Support Center, declaration of the Site Area Emergency
following the major steam generator tube rupture and main steam line
break was not made promptly following reports of ihese conditions. At
4:28 a.m., the Technical Support Center staff becam aware that the
steam generator tube rupture had significantly increcsed concurrent with
reports of an unisolable steam line break outside of tor,tainment on the
affected steam line. According to the licensee's classification scheme
contained in Procedura EPP-201, " Assessment of Emergency Action Levels,
Emergency Classification and Plan Activation," Chart 4, these conditions
correspond to a Site Area Emergency. The declaration of the Site Area
Emergency was not made by the Technical Support Center until 4:49 a.m.,
or 21 minutes following Technical Support Center staff awareness of
these conditions. The inspectors noted that a briefing was being
started at 4:30 a.m. in the Technical Support. Center as information of
the main steam line break was received. Rather than take action on this
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event, the managers took another 5 to 10 minutes to complete the
briefing. The control-room finally prompted the Technical Support
Center concerning the need to upgrade to Site Area Emergency at about
4:47 a.m.
Delays in detecting and classifying emergency conditions ware identified as an
exercise weakness (445/9246-01; 446/9246-01).
Following the declaration of the Site Area Emergency at 4:49 a.m., the
notifications to offsite authorities of this classification were not completed
until 25 minutes later at 5:14 a.m. According to 10 CFR 50, Appendix E.IV.D.3
and EPP-203, " Notifications," Section 4.1.2.2, notifications are to be made
within 15 minutes after declaring the emergency. The licensee's failure to
make prompt offsite notifications of the Site Area Emergency was identified as
an exercise weakness (445/9246-02; 446/9246-02).
The inspectors made the following observations from the Technical Support
Center which were determined not to have significantly detracted from the
overall effectiveness of the licensee's response and are identified as areas
for improvement:
- Status boards in the Technical Support Center were often late in being
updated or were never annotated in sections pertinent to the exercise
scenario data. Specific examples include:
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At 3:55 a.m., the Sequence of Events status board attributed the
ALERT to " Primary to Secondary Leakage" versus the actual cause
which was the Train "A" diesel day tank fire.
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At 4:17 a.m., the Sequence of Events status board did not
indicate that the Operational Support Center and Technical
Support Center were activated.
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The Radiological status board was never updated to reflect
offsite monitoring team data or the results of dose projections
made,
e The inspectors noted difficulties in the Technical Support Center
associated with use of the "Offsite Release. Consequence. Assessment
System" (0RCAS). Fifteen minutes following activation of the Technical
Support Center, there was still no operator available for the ORCAS
computer system. Because of this, the Technical Support Center Onsite
Radiological Assessment Coordinator decided that he would have to
operate the ORCAS instead of occupying his position at the management
table. At about 4:30 a.m., a newly arrived individual was assigned to-
the ORCAS but this individual stated that he had only operated ORCAS
once before.
Throughout the exercise, the Technical Support Center ORCAS was operated
under only one accident scenario assumption, " Steam Generator Tube
Rupture." All dose projections performed used data from the main steam
line radiation monitors. These monitors are installed on the steam
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lines between the relief valves and the ma'n steam isolation valves.
For the exercise scenario, the inspectors found that these monitors
could have been unrepresentative of release concentration because of
such conditions as being positioned downstream of the break, because of
damage by high temperature and humidity, or because of being subjected
to physical damage caused by pipe whip, etc.
Scenario selections are not available on the ORCAS computer program for
releases via the condenser offgas stack or for ground level releases
created by main steam line breaks with a steam generator tube rupture.
- Several personnel in the Technical Support Center stated that the
Gaitronics/All Page system was unreliable or would not work from the
Technical Support Center. This was explained by the licensee as being a
drill artificiality caused by the additional load on the system of the
remote simulator facility. The inspectors noted that the loading
problem did not appear to affect transmission from the simulator to the
plant speaker systems; therefore, the problem may not be one of system
over-loading.
3.2 Conclusions
The Technical Support Center was staffed and activated promptly. An exercise
weakness was identified for delays in detecting and classifying two emergency
classes. Another exercise weakness was identified for failure to make prompt
notifications to offsite authorities of an emergency classification.
The transition of emergency command from the control room to the Emergency
Coordinator in the Technical Support Center contributed to an exercise
weakness discussed in Section 6.1 in the area of emergency command and
control.
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4 OPERATIONAL SUPPORT CENTER (82301-03.02.b.4)
The inspectors evaluated the performance of the Operational Support Center
staff as they performed tasks in response to the exercise to determine whether
the Operational Support Center would be effective in providing emergency
support to operations.
4.1 Discussion
The inspectors observed the activation and operation of the Operational
Support Center and repair teams dispatched to in-plant locations. The
Operational Support Center was initially staffed by personnel who were on site
at the time the Alert was declared, and the facility was operational with
minimum staffing 12 minutes after the declaration of the alert. The
Operational Support Center was officially declared operational 33 minutes
after the Alert declaration.
Personnel appeared generally to be acquainted with their responsibilities and
duties. Procedural guidance was available and used by individuals in the
Operational Support Center. The inspectors noted that on one occasion an
auxiliary operator who was dispatched to investigate the fire alarn needed to
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be instructed in immediate entry procedures at the access control point.
Radios, telephones, and plant page systems were effectively used to maintain
communication between emergency response facilities and teams dispatched to
in-plant and onsite locations.
Key emergency responders kept logs of ongoing activitier. A status board for
plant events was maintained. The inspectors noted that reports of in-plant
radiation monitors were posted on a dry erase board while another status board
specifically provided for this information was not utilized. Also, results of
radiological surveys were not posted on plant maps provided in the Operational
Support Center.
The comand and control of the Operational Support Center was fragmented and
somewhat uncoordinated. Early in the exercise, it appeared that no single
individual was clearly in control of assigning 2nd dispatching teams. The
licensee did manage to dispatch teams needed to respond to emergency events in
For example,
a timely manner; however, it was not done in an orderly fashion.
the licensee failed to maintain adequate administrative controls over teams
dispatched in response to emergency conditions as specified in
Procedure EPP-16. " Emergency Repair & Damage Control and Imediate Entries."
This finding is discussed in Section 6.1 as part of the exercise weakness in
emergency command and control.
Repair team priorities were frequently discussed by tbs Operational Support
Center Manager with Technical Support Center management. These priorities
were clearly posted on a status board in the Operational Support Center.
Briefings of emergency respo se damage control teams were good. Team members
were adequately informed of existing or expected radiological conditions.
Appropriate radiological controls were prescribed and gcad radiological
practices were followed by team members. Team tasks were clearly explained.
4.2 Conclusions
The Operational Support Center was staffed and activated promptly.
Information flow within the Operational Support Center and betwaen the
Operational Support Center and other facilities was good. Repair teams
followed proper safety controls and were well briefea. Failure of the
Operational Support Center to exercise specified administrative controls over
repair teams is discussed in Section 6.1 as part of a weakness identified in
the area of emergency command and control.
5 EMERGENCY OPERATIONS FACILITY (82301-03.02.b.3)
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,
of fsite dose assessment, protective action decisionmaking, notifications, and
interactions with offsite field monitoring teams.
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5.1 Discussion
The Emergency Operations facility staff arrived promptly and the Emergency
Operations-Facility was declared activated 72 minutes following the Alert
declaration. Some minor security access delays were observed in the Emergency
Operations Facility. It was noted that the authorized access list for the
Emergency Operations Facility was dated September 10, 1992. The first two
responders to the Emergency Operations Facility were not on the list and the
guard responsible for Emergency Operations Facility access control had to
obtain authorization by telephone before admitting them. Later, for the same
reason, the driver assigned to field monitoring team No. I was prevented from
accessing the area where survey team equipment was stored, causing a short
delay in the deployment of the team.
The inspection team noted that Emergency Operations Facility staff appeared to -
be trained and proficient in carrying out their response duties. The
operational status and event sequence status board was kept current and
complete throughout the exercise, it provided a very useful and accurate
summary of plant :onditions for ready reference by all the Emergency
Operations Facility staff. Written logs, however, were not as well
maintained. For example, logs kept by key Emergency Operations Facility
players were in loose-leaf format instead of bound log books. Many
interpersonal and inter-station communications were recorded using scraps of
paper or informal notes. These practices would make event reconstruction from
the records very difficult and legally tenuous.
Control of the offsite monitoring teams and dissemination of the measurement
results they collected were weak. These observation are discussed in further
detail in Section 6.1 as part of the exercise weakness in emergency command
and control. In addition, offsite monitoring team measurement results of the
plume traverse reported as background by the team at 5:39 a.m. were not logged
in the field team communicator log, nor were these, or the later
above-background readings reported about C a.m. recorded on the offsite
monitoring status board.
The inspection team observed the licensee's exercise press conference
conducted in the auditorium adjacent to the Emergency Operations Facilf ty.
The press conference did not clearly convey basic information that was
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available at the time and that both the media and public would need to
! understand. For example, the press briefing apprised'the media of a
I radiological release in progress but failed to convey any clear information as
to the offsite hazards associated with the release. In fact, before the press
conference was held, the licensee's response staff had conducted onsite
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monitoring surveys of the release and had performed detailed dose projections,
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! were minor. In the absence of such information being conveyed, the media was
l left to report only that licensee personnel had been evacuated from the site
but as for the general population, county authorities were working to
formulate offsite protective actions. Further, the press conference did
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little to describe the licensee's response efforts in progress at the time.
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No definition was given for the Site Area Emergency which had been declared,
nor was it differentiated from the other emergency classes. No perspective
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was conveyed relative to whether the emergency was stabilizing or whether
conditions were still degrading.
5.2 Conclusions
The Emergency Operations Facility was staffed and activated promptly and
personnel were proficient in carrying out their assigned duties. Control of
offsite monitoring teams and the information they returned to the Emergency
Operations Facility was part of an exercise weakness discussed in Section 6.1
in the area of emergency comand and control. The press conference did not
clearly convey essential information to the media which was available at the
time.
6 EMERGENCY COMMAND AND CONTROL (82301)
The inspection team evaluated the emergency comand and control exercised in
each emergency response facility to determine whetner clear chains of comand
were in place for effective emergency management, and whether tha emergency
response organization was issued appropriate directives by key decisionmakers.
6.1 Discussion
The Emergency Coordinator position (a.k.a. Emergency Dit ctor) was transferred
twice during the exercise. Between the Alert declaration and the Site Area
Emergency, the Emergency Coordinator position shifted from the control room to-
the Technical Support Center. About 30 minutes after the Site Area Emergency
declaration, the Emergency Coordinator responsibilities were transferred to
the Emergency Operations Facility. The inspection team made the following
observations which, in the aggregate, indicated that overall comand and
control during the exercise was weak:
e The transfer of Emergency Coordinator duties from the control room shift
supervisor to the manager in the Technical Support Center was-
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inefficient and confusing and appeared to leave a vacuum of comand
authority for a period of time.
The Alert was declared at 3:19 a.m. By 3:36 a.m., there were about four
people in the Tech :al Support Center but with no particular individual
in charge. At about 3:42, the Emergency Coordinator's checklist logs
indicated that the individual who would eventually become the Emergency
Coordinator in the Technical Support Center had relieved the control
room shift supervisor of the Emergency Coordinator's duties (while in
l the simulator). By about 4 a.m., one individual in the Technical
l Support Center had taken charge of personnel there but did not claim the
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title of Emergency Coordinator. The Emergency Coordinator arrived .in
the' Technical Support Center from the simulator at about 4:28 a.m. but
did not announce that he was the Emergency Coordinator. Status boards
in the Technical Support Center continued to show that the control room
had comand and control. The Technical Support Center Emergency
Coordinator log showed that the same individual who had-assumed
Emergency Coordinator duties in the simulator again assumed these duties
in the Technical Support Center at 4:50 a.m.
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Because of the distance between the Technical Support Center and the .
simulator, this exercise included an artificially long period of time
(about 10 minutes) to transit between the two facilities. Even giving
consideration to this artificiality, it was unclear who was the
Emergency Coordinator during the 4:30 to.4:50 a.m. timeframe.
e In the Operational' Support Center, the licensee failed to maintain
adequate controls over teams dispatched in response to emergency
conditions. Between 4 and 6:07 a.m., 16 teams were dispatened from the
Operational Support Center. No Emergency Work Permits were completed
for 10 of these teams as required by Procedure EPP-116. "Emernancy
. Repair & Damage Control and immediate Entries," step 4.2.2. ' ema o f
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these teams were recorded on the Operational Support Centw Team Status
board and in various logs but no consistent central record was
maintained of these teams. In addition, as noted in Section 4.1, early
in the exercise it appeared that no individual in the Operational
Support Center was clearly responsible for the control of assigning and
dispatching repair teams.
e In the Emergency Operations Facility, control of the offsite monitoring
teams and utilization of the information developed from them was
inadequate. Neither the results of the 5:39 a.m. plume traverse nor the
later measurements reported to the Emergency Operations Facility about-
6 a.m. that produced above-background readings were recorded on the
offsite monitoring status board or reported to the Emergency Operations
Facility decisionmakers. At the termination of the exercise, the
Radiation Protection Coordinator and the Emergency Coordinator were
unaware of the results of the monitoring team traverse of the plume
3 miles downwind from the plant some 25 minutes before. For an
undetermined period of time around 5:53 a.m., the monitoring team
communicator's station was abandoned leaving no apparent radio
cmmunication or centralized control over the deployed teams during this
t .ne period,
e Staffing of the Emergency Response Facilities was at times disorganized,
as sometimes several qualified individuals shared (or attempted to fill)
the same position. The facility managers were not forceful in directing
the excess staff to be released for other duties. There appeared to be
no standard practice or procedure for staffing the initial response
organization and recording, reassigning or releasing the other personnel
who responded. While three different qualified individuals were signed
in for, and took part in carrying out the duties of the Emergency
Operations Facility Radiation Protection Coordinator position, the
Technical Support Center dose projection capability was suffering for a
lack of experienced personnel.
Emergency command and control was identified as an exercise weakness
(445/9246-03; 446/9246-03).
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6.2 Conclusions
Several examples eT weak emergency command and control were identified in
emergency response facilities.
7 SCENARIO AND EXERCISE CONDUCT (82301)
The inspection team made observations during the exercise to assess the
challengo and realism of the scenario ar.d to evaluate the conduct of the
exercise.
7.1 QIscussio.n
The iwpection team determined that the scenario provided sufficient challenge
to wercise response activities in each of the exercise objectives. P.ealism
was enhanced by utilizirig the contro! room simulator in the dynamic mode to
model the accident segaence.
The following observatt mc it Pted to the scenario and to the conduct of the
exercise did not significantly detract from the exercise and are discusse, es
potential areas for improvement:
e The exercise data for the RM-Il was inaccurate for the Steam Gu.erator
Sample (SGS 164) and the Steam Generator Blowdown Process
Monitors (SGB 173). The exercise data for the steam generator blowdown
monitor indicated that the channel would be at the alert level at
2.164E-4 pCi/cc and the alarm level at 4.272E-4 pC1/cc, and the steam
generator sample monitor would be in: alert at-2.524E-4 pCi/cc and in
alarm at 3.779E-4 pCi/ce. The actual alant setpoints for these monitors
are different inan those provided in t1e scenario. In addition, the.
exercise data did not reflect the isolation of the steam generator
blowdown or sample lines when these respective monitors reached the
alarm setpoint.
e Scenario data for the ligad primary coolant sample and the No. 3 steam
generator was inconsistent. At times (e.g., 2:30 to 2:45 a.m.) the
steam generator noble gas and iodine levsls were a factor of 3 to 5
times greater than the coolant activity values, a condition which is a
physical impossibility.
e In-plant survey teams :;imulated the posting of radiological controlled
areas. This was contrary to information presented in the pre-exercise
discussions with the inspection team which indicated that posting would
not be simulated,
e The scenario and exercise control did not provide for realistic feedback
to the Emergency Operations Facility regarding the status of
implementation of the offsite protective actions. County officials
would be expected to. report (or be responsive to queries) on what they
were doing in response to the licensee's recommendations, and licensee
personnel would be expec ed to take that feedback into account when
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7.2 Conclusions
The scenario and exercise preparation provided sufficient cnallenge to
demonstrate the exercise objectives.
O LICENSEE SELF-CRITIQUE (82301-03.02.b.12)
The in;pectors observed and evaluated the licensee's formal self-critique on
November 20, 1992, to determine whether the process would identify and
characterize weak or deficient areas in need of corrective action.
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8.1 Discussion
The licenFee gave a presentation of its Critique findings as Well as a
documented summary. The licensee used terminolngy identical to that used by
the NRC to characte-ize its findings. The licensee identificd the following 2
weaknesses:
e notification was not timely.
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- Command and control was unsatisfactory in some areas.
In addition to the two weaknesses identified, the licensee characterized five
improvement items and a list of proficiencies. Among the improvement items
were the identification of delays in assessing and classifying conditions of
the Alert and Site Area Emergency as well as other observations nated by the
NRC inspection team. The licensee's self-critique process involved
appropriate levels of management review and was determined to be a strength,
8.2 Conclusions
The licensee's self-critique process was excellent in identifying areas in -
need of corrective action.
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ATTACHNEKT 1
1 PERSONS CONTACTED
1.1 Licensee Personnel
- J. Ardizzoni, Supervisor, Administrative Security
- D. Barham, Emergency Planner
- R. Beleckis, Senior Emergency Planner
- G. Bell, Supervisor, Emergency Planning
- H. R. Blevins, Director, Nuclear Overview
- T. A. Carder, Emergency Planner
- D. Davis, Manager, Plant Analysis
- J. Ellard, Senior Emergency Planner
- J. R. Gallman, Manager, Trend Analysis
- W. G. Guldemono, Manager, Independent Safety Engineering Group
- N. Harris, Licensing Engineer
- N. Hood, Manager, Emergency Preparedness
+T. Hope, Manager, Site Licensing
- B. T. Lancaster, Manager, Plant Support
- P. E. Mills, Senior Quality Assurance Specialist
- D. Moore, Manager, Unit 2 Nuclear Operations Transition Organization
- S. Palme, Stipulation Manager
- A. Saunders, Atsessment Manager
- A. J. Scogin, Jr., Manager,-Security
- E. A. Sirois, Senior Engineer
- W. Stengar, Senior Emergency Planner
1.2 NRC Perve9gl
- V. G. Gaddy, Reactor Inspector (Intern)
- D. N. Graves, Senior Resident inspector
- T. P. Gwynn, Deputy Director, Division of Reactor Projects
- B. E. Holian, Project Manager,-NRR
- L. A. Yandell, Chief, Project Section B
1.3 Other Personnel
- 0. L. Thero, Consultant, Citizens for Sound Energy
- T. Mayberry, Senior Staff Consultant, Houston Lighting and Power
- Denotes thost present at the exit interview
2 EXIT MEETING
The inspection team met with the licensee representatives and other personnel
indicated in Section 1 of this-attachment on November 20, 1992, and summarized
the scope and findings of the inspection as presented in this report. The
licensee did not idcti:fy as proprietary any o' the materials provided to, or
reviewed by, the in+.iection team dm'ing the inspection.
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