ML20127F283

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Insp Repts 50-277/92-33,50-278/92-33,50-352/92-28 & 50-353/92-28 on 921123-25.No Violations Noted.Major Areas Inspected:Annual partial-participation Exercise Conducted on 921124
ML20127F283
Person / Time
Site: Peach Bottom, Limerick  Constellation icon.png
Issue date: 12/11/1992
From: Laughlin J, Mccabe E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20127F184 List:
References
50-277-92-33, 50-278-92-33, 50-352-92-28, 50-353-92-28, NUDOCS 9301200190
Download: ML20127F283 (23)


See also: IR 05000277/1992033

Text

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                                     U. S. Nuclear 1(egulatory Commission
                                                     1(eglon I
        Docket /lteport:      50 352/92 28; 50-353/92-28t 50-277/92-33; 50-278/92-33
        Licensee:             l'hlladelphia Electric Company (PECO)
                              l'ost Office llox 195
                              Wayne, l'ennsylvania 19087-0195
        Facilities:           Limerick Generating Station (LGS), Units I and 11
                              Peach llottom Atomic Power Station, Units 2 and 3
        Inspection:           November 23 25,1992
        Inspection At:        Pottstown and Coatesville, Pennsylvania
        instretors:                         cM       .
                                                                                       # 'I 72.
                                                 ergency Preparedness Specialist        date
                              J.    Lauglifin,
                              C. Gordon,      Se   J(/nior Ilmergency Preparedness Specialist
                              J. Lusher, limergency Preparedness Specialist
                               L. lickert, limergency Preparedness Specialist
                              T. Kenny, Senior Resident inspector
                               L. Scholl, Itesident inspector
        Approved:                      $ O. b                                          AtlH b1
                               E. McCabe, Chief, Emergency Preparedness Section          date
                                                  Areas inspected
        The licensee's annual partial-participation exercise conducted on November 24,1992.
                                                       Results
         Limerick emergency exercise performance demonstrated the ability to protect public health and
         safety. Strengths included command and control in the Simulator Control Room, Technical
         Support Center, and limergency Operations Facility (EOF); prompt crew recognition of
         abnormal plant conditions, and Operations Support Center accountability of personnel. There
         were no exercise weaknesses. EOF command and control weaknesses identified during the 1992
         Peach 110ttom emergency exercise were closed out.                                             .
      9301200190 930113
      PDR    ADOCK 0D000277
      O                    PDR
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                                                   TABLE OF CONTENTS
                 1.0    Persons Contacted   .......................................                                      1
                 2.0    Emergency Exercise . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 -    _
                        2.1    Pre-exercise Activities   ................................                                2
                        2.2    Ex e rcise Scenario . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
                        2.3    Activities Observed . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
                 3.0    Exercise Finding Classifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
                 4.0    Exercise Observations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
                        4.1    Simulator Control Room (SCR) . . . . . . . . . . . . . . . . _. . . . . . . . . . . 4
                        4.2    Technical Support Center (TSC)        ..........................                           5
                        4.3    Operational Support Center (OSC) . . . . . . . . . . . . . . . . . . . . . . . . . 5
                        4.4    Emergency Operations Facility (EOF) . . . . . . . . . . . . . . . . . . . . . . . 6
                               4.4.1 Protective Action Recommendations (PARS)               ..............                6
                               4.4.2 Dose Assessment, Field Teams and Air Sampling . . . . . . . . . . .                  7
                        4.5    Emergency News Center (ENC) . . . . . . . . . . . . . . . . . . . . . . . . . . 7
                 5.0     Previously Identified items . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
                  6.0    Emergency Action Level (EAL) Change . . . . . . . . . . . . . . . . . . . . . . . . .           10
                  7.0    Licensee Critique and NRC Exit Meeting . . . . . . . . . . . . . . . . . . . . . . . .          10
                  Attachments
                  1.     Licensee Agenda For Management Meeting with NRC Region I
                  2.     Licensee Corrective Actions List
                  3.     Licensee Release Pathway Assessment Aids

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                                                  DETAILS
       1.0     Persons Contacted
       The following individuals attended the exit meeting on November 25,1992.
               C. Adams, Emergency Preparedness hianager
               R. Bohner, Emergency Preparedness Instructor
               R. Brown, Supervisor, Site Emergency Preparedness
               R. Charles, Manager, Nuclear Support Division
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               J. Clymer, Engineer, Chesterbrook Emergency Preparedness
               V. Cwietniewicz, Superintendent of Training
               J. Doering, Plant hianager
               J. Gerhart, Physicist, Emergency Preparedness                                           ,
               M. Ilammaker, Emergency Preparedness
               D. IIelwig, Vice President, Limerick
               L. Ilopkins, Manager of Operations
               J. Jankauskas, Emergency Preparedness
               S. Keenan, Supervisor, Chesterbrook Emergency Preparedness
               R. Kinard, Supervisor, Chesterbrook Emergency Preparedness
               S. Mainai, Nuclear Engineer, PA Bureau of Radiation Protection
               R. Mandik, Supervisor, Chesterbrook Emergency Preparedness
               A. Mantey, Engineer, Chesterbrook Nuclear Maintenance
               T. McFadden, Supervisor, Dosimetry Branch
               N. McKenney, Senior Instructor, Chesterbrook Emergency Preparedness
               M. Moore, Emergency Medical Assistance Program
               J. Muntz, Technical Superintendent
               D. Oltmans, Director, Nuclear Chemistry
               A. Parducci, Limerick Emergency Preparedness
               D. RiFay, Nuclear Quality Assurance, Technical Monitor
               W. Russell, Limerick Emergency Preparedness Planner
               K. Schlecker, Physicist, Limerick Emergency Preparedness
               M. Shuler, Physicist, Nuclear Support Division
               D. Smith, Senior Vice President, Nuclear
               J. Waddington, Jr., Coordinator, Emergency Communications
       The inspectors also interviewed and/or observed the actions of other licensee personnel.
       2.0     Emergency Exercise
       The Limerick Generating Station (LGS) partial-participation exercise was conducted on
       November 24,1992, from 8:00 a.m. to 2:00 p.m. The Comr9nwealth of Pennsylvania partially
       participated in the exercise by sending representatives to the Emergency Operations Facility.
       Off-site activities were not inspected.
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   2.1     Pre-exercise Activities
   Exercise objectives were submitted to NRC Region I on August 21, 1992 and the complete
   scenario package on September 23, 1992 for NRC review and evaluation.                          Region I
   representatives discussed the scenario with the licensec's emergency preparedness staff on
   October 23,1992. The scenario was assessed as an adequate test of the major portions of the
   Emergency Plan and Implementing Procedures.
   NRC exercise observers attended a licensee scenario briefing on November 23,1992. The
   scenario was discussed in depth and all NRC observer questions were answered. The lleensee
   stated that certain emergency response activities would be simulated and that controllers would
   intercede in exercise activities to prevent disrupting normal plant activities.
   2.2     Exercise Scenario                                                                                 ;
   The scenario provided a challenging test of the I.GS Emergency Response Organization's
   (ERO's) ability to analyze and mitigate a severe accident. Information in the scenario package
   was excellently presented.
   The exercise scenario included the following simulated events:
   *       Initial conditions: Unit I was operating at 100% power for the last 150 days. Low
           Pressure Coolant Injection Loop 1 A, Standby Liquid Control Pump IC, and the Reactor
           Core Isolation Cooling System were out of service. Fuel pin leakage resulted in off gas
           noble gas activity of 700 uCi/sec, which increased after a recent rod shuffle.
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   *       Increase in off-gas activity to 5C50 pCi/sec.
   *       Break in a frecic seal supply line, resulting in release of nitrogen inside the power block,
           and an Alert.
   *       Clogged Control Rod Drive Pump suction filter.
   *       Spurious High Pressure Coolant Injection actuation due to a failed controller, resulting
           in minor clad damage, reactor scram, and Group 1 Main Steam Isolation Valve closure.
   *       Failure of Source Range Monitors and Intermediate Range Monitors to insert into the
           Core.
   *       Failure of Residual Heat Removal System heat exchanger l A inlet valve to open.
   *       Steam Relief Valve failed open.                                                                   ,
   *       Total loss of annunciators (a Site Area Emergency).

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                           *         Trip of all condensate pumps due to ruptured discharge line.
                           *         Break in Residual lleat Removal 111 discharge lira to the reactor vessel, resulting in a                              l
                                     Loss of Coolant Accident.
                           *         General Emergency condition involving high dryw:ll radiation.                                                         !
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                           *         Release of radioactive material from the drywell via a hydrogen recc.abiner, resuhin                                  i
                                     in a stack release to the environment.
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                           *         Exercise termination.
                          2.3        Activities Observed                                                                                                   !
                          The NRC observed the activation and hugmentation of the Emergency Response Organization,
                          activation of Emergency Response Pacilities, and actions of emergency response personnel. The
                           following were observed:
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                           1.        Selection and use of control room procedures.
                          2.         Detection, classification, and assessment of scenario events.
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                          3.         Direction and coordination of emergency response.
                          4          Notincation of licensec personnel and off-site agencies.
                          5.         Communications /information flow, and record keeping.
                           6.        Assessment of off site consequences, and protective action recommendations (PARS).
                           7.        Technical support, repalts and corrective actions.                                                                  ;
                           8.        Communication with the media and the public.                                                                        ,
                          9..        Accident analysis and mitigation.                                                                                   ;
                           10.       Accountability of personnel.
                           11.       Post-exercise critique by the licensee.
                          3.0        Exercise Finding Classifications                                                                                    *
                           Emergency preparedness exercise findings were classified as follows.
                           Exercise Strength: A strong positive indicator of the licensee's ability to cope with abnormal
                           plant conditions and impicment the Emergency Plan.
                           Exercise Weakness: Less than effective Emergency Plan implementation which did not ofitself
                          constitute overall response inadequacy.
                           Area for Improvement: An aspect which did not significantly detract from the licensee's
                           response, but which merits licensee evaluation for corrective action.

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                     4.0       Esercise Obwrvalloa
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                     Activatkr and utilization of the Emergency Response Organization (ERO) and Emergency
                     Response racilities (EAFs) weie consisters. with 'he Emergency Pian and Emergency Plan
                     Implementing Procedura.                                                                                ,e
                     The licensee used their control nmm simulator in the dynamic mode, The lack ofignlGeant
                     exercise control discrepancies (i.e. com 'ter communications allowed timely removal of

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                     simulated faults based on player resport       .iowed attention to detail in scenario development
                     and prediction of player responses. The / ice President of Limerick was present in the ems
                     during the exercise and the Senig Vice President, Nuclear, attended the critique and exit              _
                     meeting, showing licensee management commitment to EP.
                     4.1       Simulator Control Moom (FCR)

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                      SCR operator response to simubled casualties was prompt and effective. Good teamwork was
                     demonstrated. The crew quickly recognized abnormal conditions such as the inadvertent High
                      Pressure Coelant injection System initiation, stuck open safety relief valve, failure of the source
                      and intermediate ange detectors to insert, and tailure of two law Pressure Coolant injection
                      System valves to yen. Procedure use was excellent. Operators effectively established response
                      priori'i's for equipment failures.
                      The Eft branager (SM) and Shift Supervisor (SS) exercised excellent command and untrol.
                      The SM correctly classiGed the Alert, and notifications by the shift were timely. SCR internal
                      communications arp those with the Technical Support Center (TSC) were good. Ilowever, the
                      SM did not imht.u bis crew when he became the Emergency Director or when that duty was
                      transferred to the TSC.                                                                                  _
                      The SCR controller noted that Procedure ERP-101, "Clanincation of Emergencies," was not
                      the correct revision. The carect revision was krated and provided to the operators.
                      The following exercise strengths were observed:
                       *        SCR command and control.
                       *        Prompt recognition of abnormal plant conditions.
                       *        Use of procedures.
                       No exercise weaknesses were observed.                                                                    ,
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                       The following area for improvement was identined:
                       *        Assuring use of current procedures.
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, 4.2 Technleal Support Center (TSC)  ;

                             The TSC was prepred for um by procedure and activated in 9 timely manner. The Emergency           ,
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                             Director (ED) briefed his staff and ensured status boards were up to-date beibre activation. The
                             ED exhibited stroag command and control. He maintained r,ood communications with the
                             Simulator Control Room and the Emergency Operations Facility, conducted regular team leader
                             rnectings with his staff, and gave frequent and thorough brienngs to facility personnel. The sit  i
                             team leaders provided excellent feedback that resulted in sound decision making and proper
                             establishment of priorities.                                                                      l
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                             Evrti; c!assi!kations for the Site Area Emergency and General Ernergency were correct and         I
                             notineatons of off site ofncials and the NRC were timely. Status boards wc:e frequently           l
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                             ugJawd and accurately prescitated event data.
                             The following exercise strengths were cbserved:
                             *              ED command and control.
                             *              ED use of staff for decision-making.
                             No exercise weaknesses or areas for imprevement were identified.
                             4.3           Operational Support Center (OSC)
                             OSC activation was timely. The OSC Coordinator (OSCC) demonstrated good command and

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                             control. Telephone and radio communications were timely for maintenance team coordination.
                             Sufficient personnel were available for plant needs, and the OSCC was proactive in dispatching
                             teams for repairs and investigation.
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                             The OSC demonstrated excellent accountability. Personnel were required to check in and out

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                             with the OSCC, who maintained a list of available people for maintenan:e and health physics
                             functions. Personnel also p&ed accountability cards on the OSC tagboard and carded in and
                             out when entering and leaving. Furthe , personnel were logged in and out on thejob assignment

( stitus board. 1 L The OSCC gave periodic bne6ugs to OSC personnel, but these were brief and cursory. No L information was provided on event dassification, status of events, work prioritit.s, recommended

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                             protective actions, or dispatei4ed tean updates. The OSCC was very busy with phone chils,
                             radio communications, log keeping, team briefings, and facility briefings, in addition to
                             command and control duties. AH, the ordy record of team briefings and debriefings was

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                             maintained on status boards, ar4 w permanent records were kept.

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          The following strength was observed:
          *       Accountability of personnel.
          No exercise weaknesses were identified. The following areas for improven*?r;! were noted:
          *       Facility status briefing quality.
          *       Number of duties assigned to the OSCC.
          *       Permanent records of team briefings / debriefings.
          4A      Emergency Operations Facility (EOF)
          Personnel staffed the EOl at the Alert level, and the facility was activated ai use Site Area
          Emergency. The EGF was activated in a tims.y manner. The Emergency Response Manager
          (ERM) assumed control after a thorough turnover from the ED, providing a plant status update
          to EOF staff, and receiving reports from his team leaders that sufficient personne) were
          avidlable.

. The ERM used his staff effectively to assess plant problems, core draage, and radiological

          conditions on-site and off site. Ile interfaced well with the Dose Assessment Team Leader and
          the Dose Assessment Group Leader to keep them apprited of changirig plant > conditions, and
          thoroughly discussed protective actior recommendations (PARS) with thena before issmtnce. He
          frequently communicated with the Commonwealth of Pennsylvania representative.s from the
          Bureau of Radiation Protection and the Emergency Management Agency by briefing them on
          plant conditions, discussing PAR declarations and their bases, and resporJing tci requestb for
          information.
          The following exercise strength was identified:
           e      ERM command, control, and communications.
          There were no EOF exercise weaknesses or areas for improvement.
          4 A,1 Protectise Action Recommendations (PARS)
          A loss of Coolant Accident (LOCA) occurred at 1056. At 1110, orywell radiation levels
          reached 10,000 R/hr., leading to a General Emergency declaration. After thomugia discussion
          wlth his staff, the ERM issued a PAR for evacuation of thc two mile radius and five miles
          downwind. Pour downwind sectors were relected based an a projecte41 wird shift to th: south.
          This PAR was consistent with federal guidance and licensee procedures.
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  At 1132 the Commonwealth of Pennsylvanir declared a State of Disaster. At 1140 the ERhi
  announced that the Commonwealth of Penn 'vania had decided to evacuate the full ten-mile
  Emergency Planning Zone.
  At 1146 discussions between the ERh1 and Dose Assessment Team Leader (DATL) concluded
  that a PAR change was needed to reflect the change in wind direction. Additionally, drywell
  radiation levels were increasing, so the ERht discussed with the DATL whether a PAR extension
  was warranted. The ERh1 and DATL decided to wait until drywell radiaticn levels reached
  50,000 R/hr. before extending the PAR. The existing PAR was changed by rotating the
  downwind sectors north by two sectors. To do so, a recommendation of evacuation was
  withdrawn in two sectors and provided in two others. No release was in progress at this time.
   EPA-520, "hianual Of Protective Actions For Nuclear incidents," Chapter 5 Section 5.2, points
  out that " Withdrawal of protective actions from areas where they have already been implemented
   is usually not advisable during the early phase because of the potential for changing conditions
  and confusion."           Inspector review found no procedural direction concerning
   withdrawal /rnodlGcation of PARS due to wind shifts.
   At 1200 the release started. With main stack readings increasing, the ERhi discussed updating
   the PAR with the DATL. When drywell radiation levels exceeded 50,000 R/hr., the ERhi
   issued a PAR of evacuation of the nye mile radius and ten miles downwind. This PAR was
   consistent with licensee procedures.
   The PAR change due to the wind shift and the absence of procedural guidance for this action
    was assessed as an area for impravement.
    4.4.2 Dose Assessment, Field Teams and Air Sampling
    Overall, the dose assessment staff parformed well. They proactively projected doses based on
    postulated failures, and good figures were available prior to the Loss of Coolant Accident
  -(LOCA). The ERhi directed the DATL to provide a dose projection dt.e to a planned drywell
    purge. This was initiated based on a four-hour release. The DATL later decided to confer with
    the engineering staff for a more accurate release duration.
    Licensee field team samples verined the validity of projected doses. Severallicensee air samples
    were taken to determine the iodine release. The DATL remained cognizant of possible
    protective actions for emergency workers in the plume. (t his scenario did not necessitate the
    use of potassium iodide.) The Field Survey Group Leader maintained good control of the field
    teams. No field team communication discrepancies were observed.
    4.5     Emergency News Center (r.NC)
     ENC activation was timely. All news releases were reviewed for accuracy and approved by the
     ERhi before release, hiedia briefings were held frequently and the information presented was
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         discussed with Pennsylv mia representatives beforehand. The Corporate Spokesperson conferred
         with the ERM prior to each media briefing to ensure that his information was correct and up to
         date. News briefings were conducted in a controlled manner and the simulated media asked
         gcal questions. The one actual media person present, his, hielissa Dribben of the Philadelphia
         Enquirer, was given a facility tour by the licensee.
         5.0           Previously identitled items
         Closed (IFI 50-277/9212 01)
         The NRC had identified two weaknesses in EOF / ENC performance at the Peach Bottom annual
         exercise on August 26,1992 (Inspection Report 50-277,-278/92-19). As a result, the licensee
         scheduled a management meeting with the NRC on September 17,1992 (Agenda attached) to
         discuss corrective actions. An NRC inspector observed the Limerick dress rehearsal drill from
         the common Peach Bottom / Limerick EOF / ENC on October 14,1992 to observe the effectiveness
         of correcuve actions. At that time, the licensee gave the inspector a more detailed list of
         planned corrective actions (copy attacted) for the EOF / ENC, and draft copies of planned
         procedure changes to be used in the dress rehearsal and the Limerick November 24,1992 annual
         exercise. NRC inspection of EOF performance during the Limerick exercise assessed EOF
         performance in relation to the Peach Bottom exercise weaknesses.
         The following is a summary of specific corrective actions observed during the Limerick dress
         rehearsal and annual exercise.
         *             Company vice presidents and one general manager were trained to be Emergency
                       Response hianagers (ERhts) instead of senior plant management. The Vice President,
                       Peach Bottom functioned as ERht for both drills, and there was notable improvement:
                       ERh! command, control, and communications was a strength in the Limerick exercise.
         *             New Corporate Spokespersons (css) were trained: A newly trained CS filled that
                       position for both drills, with marked improvement in Emergency News Center function.
         *             Training for ERMs, Assistant ERMs, and dose assessment teams in the areas of
                       protective action recommendation (PAR) development, PAR upgrade, and release
                       pathway assessment was improved as follows.
                       a.      PAR procedures were changed to reflect current guidance (NRC Response
                              Technical hianual, RTht-91) for severe core damage, and to require the ERht to
                               consider plant status and dose assessment in PAR development as well as to
                               provide a copy of the PAR development sheet to State representatives.
                       b.      Canned PAR upgrades were provided consistent with NUREG-0654 guidance,
                       c.      Assessment aids for release pathway analysis were developed and placed in the
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                                   EOF and TSC for use by dose assessment teams (Attachment 3).
                        d.        The interface between EOF and TSC dose assessment was clarified. The TSC
                                  team now continues as a dose assessment resource after turnover to the EOF.
                *       ERh1 review of press releases is now required. This brought good results. The CS
                        regularly conferred with the ERhi for plant status updates and approval of press releases.
                *       The following emergency response procedures (ERPs) were revised to clarify expected
                        actions such as potassium lodide prioritization, PAR development and upgrading, EOF-
                        TSC dose assessment team interfaces, and ERh! approval of press releases,
                        a.         ERP-101, Classification of Emergencies
                        b.        ERP-C-1200, Emergency Response hianager
                        c.         ERP-C 1300, Emergency Operations Facility (EOF) Dose Assessment Team
                                   leader
                        d.         ERP-C-1310, Emergency Operations Facility (EOF) Dose Assessment Group
                        c.         ERP.C-1320, Emergency Operations Facility (EOF) Field Survey Group leader
                During the Peach Bottom exercise, EOF command, control and communications problems
                resulted in non-recognition of the release pathway, in PAR formulation Daws, and in absence
                of consideration of potassium iodide for use by Held teams. During the Limerick exercise, EOF
                command, control and communications were an exercise strength. The release pathway was
                correctly diagnosed, PARS were appropriate and, although iodine was not a factor in this
                scenario, its potential use was discussed and the licensee had changed procedures to highlight
                the importance of potassium iodide for personnel safety. Therefore, the Peach Bottom exercise
                weakness was shown to have been corrected.
                Closed (IFI 50-277/92-19-02) Accuracy of information disseminated. During this exercise,
                news releases were accurate and were approved by the ERhi before dissemination.
                The following areas for improvement identined during the previous annual Limerick emergency
                exercise (Inspection Report 50 352/91-07; 50-353/91-08) were acceptably demonstrated.
                Simulator Control Room:
                *       Senior Emergency Response Organization manager prepositioning.
                *       Delay in requesting off-site emergency services due to communications burden.
                *       Entries not made in bound log books when events occurred.
                Technical Support Center:
                *       Uncertainty of low Pressure Safety System set point pressure.
                *       Consideration of useful operational life of Stand-By Gas Treatment System.

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                                                                                                         i
 Operations Support Center:
 *        Sufficient emergency communications equipment availability.                                    l
 Emergency Operations Facility:                                                                          ;
 e        implementing Procedure uw.
 6.0      Emergency Action Level (EAL) Change
 The licensee revised ERP-101, "Classincation of Emergencies," Table 4.2, Appendix 11,
 "lloundary Degradation /LOCA" prior to the exercise. The nrst General Emergency (GE)
 condition in this category previously read:
          1) Scram with LOCA M no ECCS, Indicated by:
            a. Failure to bring Reactor level above -129" after 3 minutes,
            b. m Containment pressure greater than 20 psig.
                                                                                                        .
 The revision (Revision 1) changed Rem "a" to read:
            a. Failure to bring Reactor level above -161".
 NRC review concluded that Item "a" in the new revision was potentially confusing since it is
 unclear as to when the condition is met. The revision provides no literal obligation to declare
 a General Emergency if reactor water level drops below -161" (i.e., top of active fuel) as long
 as level is restored to that value in some unspecified time period. This concern was expressed
 to the licensee at the exit meeting. Also, the licensee identified this item as an important area
 for improvement during their formal critique of the exercise. The NRC subsequently requested
 and received from the licensee their 10 CFR 50.54(q) review and 10 CFR 50.59 safety
 evaluation for this change. This issue will be further reviewed (IFl 50-352,353/92-28-01).
 7.0      Licensee Critique and NRC Exit Meeting
 On November 25,1992 the NRC team attended the licensee's exercise critique. Lead controller:;
 summarized the licensce's observations. Each area was evaluated for: strengths /significant
 improvements, areas for improvement, and recommendations. The critique was thorough,
 identined most NRC findings, and was assessed as a good self-examination.
 After the critique, the NRC team met with the licensee (see Detail 1.0 for attendees) to discuss
 the inspection findings.      The team leader summarized exercise strengths and areas for
 improvement. The lleensee was informed that there were no exercise weaknesses and that their
 exercise performance demonstrated the ability to implement the Emergency - Plan and
 implementing Procedures to protect public health and safety.                    Licensee management
 acknowledged NRC findings. The licensee concurred with the NRC areas for improvement
 associated with the OSC, said that the OSC was already being evaluated for improvement, and
 commented that all NRC findings would be evaluated for appropriate action.
                                               . . . .-                  .. - - _ - - _ - . -        -.
            -   = _       . -    _ _ _ - .     . _ - - .       . - .          . . . _ .         .-       . - . . _ - - .
  *

. .I

                                                                                        Attachment 1
 ..
                                                         AGENDA
                              MANAGEMENT MEETING WITil NitC REC 10N 1
                                              September 17, 1992
                                                           4
       .      PURPOSE: To discuss the results of the August 26"'                          ...      D.M. Smith
              Peach Bottom Annual Exercise.
       *      Discussion of Identified weaknesses and corrective                          ...      C.L. Adams
              actions.
        *     Review of NRC perspective on the development of                              ...     C.L. Adams
              Protective Action Recommendations (PAR) for the
              Plume Exposure Emergency Planning Zone.
         *    Discussion of PECo Emergency Operations                                      ...     D.M. Smith
              Facility / Emergency News center in NRC
              emergency response.
          .    Conclusion                                                                   ...     D.M. Smith
                     -..                   -.                .
                                                                 .   . . - - .- .-                  ,..
   -_

.

                  C0RRECTIVE
      '
 '
                                               A C T_ I O N S
        EMERGENCY OPERATIONS FACILITY
        -    TABLE TOP DRILLS FOR ALL EMERGENCY RESPONSE
             mat 1 AGERS, ASSISTANT EMERGEllCY RESPONSE MANAGERS,
                    DOSE ASSESSMENT        TEAMS.      FOCUS   ON   PAR
             AND
             DEVELOPMENT,       PAR   ' UPGRADE,    RELEASE    PATHWAY
             ASSESSMENT
        -    CLARIFICATION OF INTERFACE EXPECTATIONS BETWEEN
             E0F AND TSC DOSE ASSESSMENT TEAMS
         -   REVISIONS     OF    PROCEDURES    TO   CLARIFY   EXPECTFD
             i.CTIONS
              +    KI PRIORITIZATION
              +    NOTIFICATION OF PARS
              +    COMMUNICATION OF INGESTION PATHWAY ASSESSMENT
                              COMMUNICATIONS      FOR    FIRE   BRIGADE
          -   ADDITIONAL
              EQUIPMENT ROOM
          -   CATEGORIZING       DRILL     kESULTS    IN    REGARD    TO
              IMPORTANCE
           -   CHANGE   IN    ASSIGNMENT     OF   EMERGENCY    RESPONSE
               MANAGERS
  .   .   -.       .  -.-     .-          - - . - . -                       . - . . .                  - - - . - - . -
 ...' ..
        .                                                                                                                    l
           ~

^

    "
                 C0RRECTIVE                                  ACTIONS                              (CONT.)
                                                                                                                             i
                                                                                                                             1
             _ EMERGENCY NEWS CENTER
                                                                                                                             :
                                                      .
             -   REQUIRE EMERGENCY                    RESPONSE          MANAGER                    REVIEW              0F
                 PRESS RELEASES
                              EMERGENCY                  COMMUNICATIONS                            PLAN              AND
             -   REVISED
                 PROCEDURE
             -   READ     AND           SIGN            FOLLOW-UP            FOR                    CORPORATE
                 SP0KESPERSON,              TECHNICAL              ADVISORS,                        EMERGENCY
                  RESPONSE       MANAGERS,                   AND   ASSISTANT                        EMERGENCY-
                  RESPONSE MANAGERS
  .     .      -          ..-     - ._.          - .     . -     .  - -       . _ _ _ . . . - . -                      .  _-
 -.-.- -.                              -                     .-...._- - - ._-.- -.--.                                   -__.-. -          .-. .- .
    .:           .                                                                                                                                       !
           
                    '
                                                                                                                                                         l
                                                                     PROTECTIVE ACTION                                                                   :
                                                REC 0fEENDATION DEVELOPMENT
                      -        NUREG-0654,                    REV. 1 AND IE IN 83-28                                                                     ,
                                                                                                                                                         .
                                -   MINIMUM PAR 2 MILE SHELTER - CIRCLE
                                                                                 5 MILE SHELTER - DOWNWIND
                                 -  PAR UPGRADE 5 MILE EVACUATION - CIRCLE
                                                                                 10 MILE EVACUATION - DOWNWIND
                      -        RTM 91
                                 -  MINIMUM PAR 2 MILE EVACUATION - CIRCLE
                                                                                  5 MILE EVACUATION - DOWNWIND-
                                 -  PAR UPGRADE LESS                                                     SPECIFIC /MORE       JUDGEMENT
                                                                                   BASED.
                                  - PLANT                CONDITIONS / DOSE ASSESSMENT
                                                                                                                            -
                                                                                                                                  USED TO
                                                                                                                                        -
                                    UPGRADE PAR PROBABLY MORE DOSE                                                               BASED
                                    CONSISTENT WITH EPA PAGS.
                        -       KEY MANAGER JUDGEMENT
          . - . . _       . __         _ _ . _ _ _ _ _ . _ . . _ _ . _ _ _ _ _ . . _ . _ . _ . _ _ _ . _                                           _ _ .

. _ _ _ . . _ _ _ _ . _ _ _ . . _ _ _ _ . _ _ _ _ _ _. . ._.

      .
        ..%
   ..*        *                                                                                      Attachment 2
 .-      ,,.
    .-
                                                                                                                               *
                                                             CORRECTIVE ACTIONS
                                                                     FOR
                                                                   EOF / ENC
                                                                                                 F
                 1.       ERM/A'..N assignment changes. VPs and NQA-CM to be ERMs.                             Train new
                          Corporme Spokespersons.
                          STATUS:     .      Decision Made 9/114                                                DMS          s
                                      .      Training Scheduled 9/25                                            S. Keenan -
                                      .      Training:
                                                  D.B. Miller         ..       Qualified                        10/06
                                                  G.R. Rainey         ..       1st Day Trr'ning                 10/01
                                                  J.B. Cotton         ..       1st Day Training                 09/29          .
                                                  D.R. Helwig         ..       1st Day Treining Sched.          10/12
                                                  D.R. Helwig and C.R. Rainey Mini-Drill                        10/22
                                                  J.B. Cotton at INPO, complete training
                                                    mid-November
                                       .     New Corporate Spokespersons Schedulea                              10/09
                                             to be trained.
                                                                                                                               ,
                  2.      Tabie Tops for existing ERMs to be scheduled and conducted by end of October.
                          STATUS:      .     Schedule                  S. Keenan
                                       .     Conduct                   R. Mandik/S. Keenan
                  3.      Table Tops for DATM.                  To include release pathway assessment, release
                          pathways, and PAR development. Focus on EOF-DATMinterface with TSC-DATM
                          and EOF-Engineering.
                          STATUS:       .     Class conducted                   10/6
                                         .    Class conducted.                  10/7
                                                                                                                               '
                                         .     One additional cirss to be scheduled and conducted for all
                                              others prior to 10/31.
                     11 .  Assessmcnt aid for release pathway assessment.
                           STATUS:       Being developed                                                S. Keenan
                                         To Be Completed 10/15, af ter drill use                        J. Gerhart/
                                                                                                         N. McKenney.
                , .-                         .. .                                   --. -.-        .  ,
        . - . ~ . . - - .                     . =.     .. .- ~        -
                                                                          _ . _    -      . . - - . . - - , - . . - ~ . -
     .    .
 .
      ;
   .
          .5.           Read and Sign procedure ' changns and PAR philosophy - for ERMs and                                   ;
                      - D ATL/DACL.                                                                                           ?
                        STATUS:     --To be issued 10/14 with procedure changes.
                                                                                                                               -
                                                                              o
            6.          ERM to be assigned as reviewer of press releases.
                        STATUS:         .   Communications Plan Revised                                           10/6
                                        -   Communications Procedures Revised                                     10/6
                                        .   Read and Sign for Corporate Spokespersons                             10/15       ,
                                        .   ERM Procedure Change Draf ted                                         10/05
                                        .   ERM Procedure Change Final - Scheduled                                10/22
            7.          Collateral ERO changes associated with ERM changes:
                                        To be completed approximately 10/11 with
                                        exception of J.B. Cotton (at INPO f cc ti weeks
                                        training).                                                                            ,
            8.           Procedure Changes fer ERM, DATL: Scheduled for 10/22.
                                                     CTAI      A0656968
                                                                                                                              i
                         Ref. Action items:
                                                               A0657035-
                                                               A0660636
                                                     EPAIT     Q0003178
                                                               Q0003179
                                                               Q0003180
                                                               Q0003181
                                                                Q0003182
                                                                Q0003183                                                      [
                                                                Q0003184-
                                                                Q00t,3185
                                                                Q0003186
                                                                Q0003187
                                                                Q0003190
                                                                Q0003191

' Q0003192

                                                                Q0003193

,

                                                                Q0003194
                                                                Q0003196
                                                                                                                              ,
                                    - ,                                                --              -                  , ,
                                                                                                                                                                                                                                  - _ _ _ _ _ _ .
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