ML20127J133

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Forwards Emergency Preparedness Insp Repts 50-277/92-33, 50-278/92-33,50-352/92-28 & 50-353/92-28 on 921123-25. Emergency Exercise Performance Demonstrated Ability to Protect Public Health & Safety
ML20127J133
Person / Time
Site: Peach Bottom, Limerick  Constellation icon.png
Issue date: 12/16/1992
From: Joyner J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Danni Smith
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
Shared Package
ML20127J139 List:
References
NUDOCS 9301250047
Download: ML20127J133 (3)
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See also: IR 05000277/1992033

Text

{{#Wiki_filter:-t 7r d f DEC.161992 Docket Nos. 50-352 50-353 50-277 50-278 Mr. D. M. Smith Senior Vice President - Nuclear Philadelphia Electric Company Nuclear Goup Headquarters Correspondence Control Desk P. O. Box 195 Wayne, PA 19087-0195 Subject: EMERGENCY PREPAREDNESS INSPECTION 50-352/92 28;50-353/92-28; 50-277/92-33; 50-278/92-33 Dear Mr. Smith: Enclosed is the report of the Movember 23-25,1992 inspection, by Mr. J. Laughlin and others, of the Limerick Generating Station partial-participation, annual EP exercise. The insation also covered Limerick and Peach Bottom Atomic Power Station emergency preparwness (EP) matters. Our inspection findings were based on inspector observations, document reviews, and post-exercise discussions with your staff. The inspection found that Limerick emergency exercise performance demonstrated the ability 4 to protect public health and safety. Exercise strengths included command and control in the Simulator Control Room, Technical Support Center, and Emergency Operations Facility; prompt crew recognition of abnormal plant conditions, and Operations Support Center accountability of personnel. There were no exercise weaknesses. C::r observations also assessed your corrective actions taken on the weaknesses identified during the Peach Bottom annual exercise of August 26,1992 as effective. That resulted in the closing ofInspector Follow-up Items related to those weaknesses. 9301250047 921216 PDR ADOCK 05000277 G PDR. i ,mme w 0FFICIAL RECORD COPY W I - a q d i

_ - =_ . . .3: , bEC.161992 Philadelphia Electric Company 2 Thank you for your cooperation. Sincerely, Original Signed By; James H. Joyner James 11. Joyner, Chief Facilities Radiological Safety and Safeguards Division of Radiation Safety and Safeguards Enclosure: Combined Inspection Report 50-352/92-28; 50-353/92-28; 50-277/92-33; 50-278/92-33 cc w/ encl: R. N. Charles, Chairman, Nuclear Review Board D. R. Helwig, Vice President - Limerick Generating Station D. B. Miller, Vice President - Peach Bottom Atomic Power Station G. Rainey, Vice President, Nuclear Services Department G. Cranston, General Manager, Nuclear Engineering Division C. Schaefer, External Operations - Nuclear, Delmarva Power & Light Co. K. P. Powers, Plant Manager, Peach Bottom Atomic Power Station A. A. Fulvio, Regulatory Engineer, Peach Bottom Atomic Power Station G. J. Beck, Manager - Licensing Section J. W. Durham, Sr., Senior Vice President and General Counsel J. A. Isabella, Director, Generation Projects Department, Atlantic Electric B. W. Gorman, Manager, External Affairs R. McLean, Power Plant Siting, Nuclear Evaluations D. Poulsen, Secretary of Harford County Council R. Ochs, Maryland Safe Energy Coalition J. IL Walter, Chief Engineer, Public Service Commission of Maryland G. Madsen,_ Regulatory Engineer - Limerick Generating Station Secretary, Nuclear Committee of the Board Public Document Room (PDR)- Local Public Document Room (LPDR) Nuclear Safety Information Center (NSIC) K. Abraham, PAO (2) NRC Resident inspector, Limerick NRC Resident Inspector, Peach Bottom Commonwealth of Pennsylvania TMl - Alert (TMIA) i- .0fflCIAL RECORD COPY

__ _ _ ~ , L)- a, ~. , Philadelphia Electric Company 3 bec w/ encl: - Region I Docket Room (with concurrences) E. Wenringer, DRP C. Anderson, DRP N. Perry, SRI, Yankee Rowe DRS/EB SALP Coordinator V. McCree, OEDO Frank Rinaldi, NRR R. Clark, NRR J. Shea, NRR . CONCURRENCES: i L n McC e r 2/// /92 12/1L/92 12//6/92 l OfflCIAL RECORD COPY .. - . . . .. -.

-. .. - .. - . . . - , .- .. --- . . - . - ~, . W . s , U.' S. Nuclear Regulatory Conunission Region I- Docket / Report: 50-352/92-28; 50-353/92-28; 50-277/92-33; 50-278/92-33 Licensee: Philadelphia Electric Company (PECO). Post Office Box 195 Wayne, Pennsylvania 19087-0195 Facilities: Limerick Generating Station (LGS), Units I and 11 Peach Bottom Atomic Power Station, Units 2 and 3 1 Inspection: November 23-25,1992 Inspection At: Pottstown and Coatesville, Pennsylvania Inspectors: M - bl 72. J. LaugMin, rgency Preparedness Specialist 'dat'e - C. Gordon, nior Emergency Preparedness Specialist J. Lusher, Emergency Preparedness Specialist ' L. Eckert, Emergency Preparedness Specialist -T. Kenny, Senior Resident Inspector L. Scholl, Resident inspector ~ Approved: OdeO b O lElla I9 t 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- n _ safety. Strengths included command and control in the Simulator Control Room,' Technical;- 1 1 Support Center, and Emergency Operations Facility(EOF); prompt crew recognitionLof- abnormal plant conditions, and Operations Support Center accountability of personnel.- There; ~ were no exercise weaknesses. EOF com' mand and control weaknesses identified during the 1992- + ~ Peach Bottom emergency exercise were closed out. , . = == . . -. . - -

. i; , TAllLE OF CONTENTS 1.0 Persons Contacted I ....................................... 2.0 E m e rgen cy E x e rc i se . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . I 2.1 Pre-exercise Activities 2 .......,........................ 2.2 Exercise 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 i 1. Licensee Agenda For Management Meeting with NRC Region i 2. Licensee Corrective Actions List - 3. Licensee Release Pathway Assessment Aids .- . .-

_ _ B s , DETAILS 1.0 Persons Contacted The following individuals attended the exit meeting on November %,1992. C. Adams, Emergency Preparedness Manager R. Bohner, Emergency Preparedness Instructor R. Brown, Supervisor, Site Emergency Preparedness ' R. Charles, Manager, Nuclear Support Division J. Clymer, Engineer, Chesterbrook Emergency Preparedness V. Cwietniewicz, Superintendent of Training J. Doering, Plant Manager J. Gerhart, Physicist, Emergency Preparedness M. Hammaker, Emergency Preparedness D. Helwig, Vice President, Limerick L. Hopkin , 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 4 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 i

A. Parducci, Limerick Emergency Preparedness D. RiFay, Nuclear Quality Assurance, Technical Monitor W. Russell, Limerick Emergency Preparedness Planner - l 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 Commonwealth of Pennsylvania partially _ participated in the exercise by sending representatives to the Emergency Operations Facility. Off-site activities were not inspected. d

_ - _ - _ _ - _ _ - g .., 2 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 licensee'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 licensee 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 pro,*ided a challenging test of the LGS 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 shufDe. Increase in off-gas activity to 5050 Ci/sec.

Break in a freeze 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 I A inlet valve to open.

Steam Relief Valve failed open.

Total loss of annunciators (a Site Area Emergency).

l l ! - _ _ _ _ _ _ _ _ _ _ _ _ _ _

m , 3 Trip of all condensate pumps due to ruptured discharge line.

Break in Residual Heat Removal 18 discharge line to the reactor vessel, resulting in a

Loss of Coolant Accident. General Emergency condition involving high drywell radiation.

Release of radioactive material from the drywell via a hydrogen recombiner, resulting

in a stack release to the environment.

Exercise termination. 2.3 Activities Observed The NRC observed the activation and augmentation of the Emergency Response Organization, activation of Emergency Response Facilities, and actions of emergency response personnel. The following were observed: 1. Selection and use of control room procedures. 2. Detection, classification, and assessment of scenario events. 3. Direction and coordination of emergency response. 4. Notification of licensee personnel and off-site agencies. 5. Communications /information Dow, and record keeping. 6. Assessment of off-site consequences, and protective action recommendations (PARS). 7. Technical support, repairs and corrective actions. 8. Communication with the media and the public. 9. Accident analysis and mitigation. 10. Accountability of personnel. I1. 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 implement the Emergency Plan. Exercise Weakness: - Less than effective Emergency Plan implementation which did not ofitself constitute overall resoonse inadequacy. ' Area for Improvemtat: An aspect which did not significantly detract from the licensee's response, but which merits licensee evaluation for corrective action.

.__ _ _ _ - . _ _ ., . _ . . . _ . __ _ _ _ _. _. __ _ > _ s 4 -4 4.0 Exercise Observations Activation and utilization of the Emergency Response Organization (ERO) and Emergency Response Facilities (ERFs) were consistent with the Emergency Plan and Emergency Plan Implementing Procedures. The licensee used their control room simulator in the dynamic mode. The lack of significant exercise control discrepancies (i.e. controller communications allowed timely removal of simulated faults based on player responses) showed attention to detail in scenario development and prediction of player responses. The Vice President of Limerick was present in the ERFs during the exercise and the Senior Vice President, Nuclear, attended the critique and exit meeting, showing licensee management commitment to EP. 4.1 Simulator Control Room (SCR) SCR operator response to simulated casualties was prompt and effective. Good teamwork was demonstrated. The crew quickly recognized abnormal conditions such as the inadvertent High Pressure Ccolant Injection System initiation, stuck open safety-relief valve, failure of the source and intermediate range detectors to insert, and failure of two Low Pressure Coolant injection System valves to open. Procedure use was excellent. Operators effectively e .blished response priorities for equipment failures. The Shift Manager (SM) and Shift Supervisor (SS) exercised excellent command and control. The SM correctly classified the Alert, and notifications by the shift were timely. SCR internal communications and those with the Technical Support Center (TSC) were good. However, the SM did not inform his crew when he became the Emergency Director or when that duty was transferred to the TSC. The SCR controller noted that Procedure ERP-101, " Classification of Emergencies," was not the correct revision. The correct revision was located 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 exercir.e weaknesses were observed. The following area for improvement was identified: Assuring use of current procedures.

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.. . .. . _ - _ _ - _ _ _ _ _ _ . _ _ _ _ - _ _ , s i } 5 4.2 Technical Support Center (TSC) The TSC was prepared for use by procedure and activated in a timely manner, The Emergency Director (ED) briefed his staff and ensured status boards were up-to-date before activation. The ED exhibited strong command and control. He maintained good communications with the Simulator Control Room and the Emergency Operations Facility, conducted regular team leader meetings with his staff, and gave frequent and thorough brienngs to facility personnel. The six team leaders provided excellent feedback that resulted in sound decision-making and proper establishment of prioritics. Event classifications for the Site Area Emergency and General Emergency were correct and notifications of off-site officials and the NRC were timely. Status boards were frequently updated and accurately presentated event data. The following exercise strengths were observed:

ED command and control. e ED use of staff for decision-making. No exercise weaknesses or areas for improvement were identified. 4.3 Operational Support Center (OSC) OSC activation was timely. The OSC Coordinator (OSCC) demonstrated good command and 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. The OSC demonstrated excellent accountability. Personnel were required to check in and out with the OSCC, who maintained a list of available people for maintenance and health physics functions. Personnel also posted accountability cards on the OSC tagboard and carded in and out when entering and leaving. Further, personnel were logged in and out on thejob assignment status board. The OSCC gave periodic briefings to OSC personnel, but these were brief and cursory. No information was provided on event classification, status of events, work priorities, recommended protective actions, or dispatched team updates. The OSCC was very busy with phone calls, radio communications, log-keeping, team briefings, and facility briefings, in addition to command and control duties. Also, the only record of team briefings and debriefings was maintained on status boards, and no permanent records were kept. I i - - - - _ - _ - - - _ - - - - - - - - - - - _ - - - - - - _ _ - - - - - - - - - - - - - - - _ - - - - - - - - - - - - - - - - - - - - - _ - - - .J _ _ .

s- s 6 The following strength was observed: Accountability of personnel.

No exercise weaknesses were identified. The following areas for improvement were noted: Facility status briefing quality.

Number of duties assigned to the OSCC. Permanent records of team briefings / debriefings.

4.4 Emergency Operations Fncility (EOF) Personnel staffed the EOF at the Alert level, and the facility was activated at the Site Area Emergency. The EOF was activated in a timely 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 personnel were available. The ERM used his staff effectively to assess plant problems, core damage, and radiological conditions on-site and off-site. He interfaced well with the Dose Assessment Team Leader and the Dose Assessment Group Leader to keep them apprised of changing plant conditions, and thoroughly discussed protective action recommendations (PARS) with them before issuance. He frequently communicated with the Commonwealth of Pennsylvania representatives from the Bureau of Radiation Protection and the Emergency Management Agency by briefmg them on plant conditions, discussing PAR declarations and their bases, and responding to requests for information. The following exercise strength was identified:

ERM command, control, and communications. There were no EOF exercise weaknesses or areas for improvement. 4.4.1 Protective Action Recommendations (PARS) A Loss of Coolant Accident (LOCA) occurred at 1056. At 1110, drywell radiation levels reached 10,000 R/hr., leading to a General Emergency declaration. After thorough discussion with his staff, the ERM issued a PAR for evacuation of the two mile radius and five miles downwind. Four downwind sectors were selected based on a projected wind shift to the south. This PAR was consistent with federal guidance and licensee procedures. At 1132 the Commonwealth of Pennsylvania declared a State of Disaster. At 1140 the ERM

_ .- - . . . _ . _ _ . ___ _ ,.. . . -. .. s < 7 announced that the Commonwealth of Pennsylvania 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, drywel. radiation levels were increasing, so the ERhi discussed with the DATL whether a PAR extensio was warranted. The ERM and DATL decided to wait until drywell radiation levels reacheo 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, "htanual 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 / modification of PARS due to wind shifts. At 1200 the release started. With main stack readings increasing, the ERh1 discussed updating the PAR with the DATL. When drywel! radiation levels exceeded 50,000 R/hr., the ERh1 issued a PAR of evacuation of the five 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 improvement. 4.4.2 Dose Assessment, Field Teams nnd Air Sampling Overall, the dose assessment staff performed well. They proactively projected doses based on i postulated failures, and good figures were available prior to the Loss of Coolant- Accident (LOCA). The ERh1 directed the DATL to provide a dose projection due 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 verified the validity of projected doses._ Several licensee air samples were taken to determine the iodine release. The DATL remained cognizant _of possible' protective actions for emergency workers in the plume. (This 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 (ENC) 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 discussed with Pennsylvania representatives beforehand. The Corporate Spokesperson conferred

1 l: , , 8 discussed with Pennsylvania representatives beforehand. The Corporate Spokesperson conferred with the ERM prior to each media briefing to ensure that his information wes correct and up to date. News briefings were conducted in a controlled manner and the simulated media asked good questions. The one actual media person present, Ms. Melissa Dribben of the Philadelphia Enquirer, was given a facility tour by the licensee. 5.0 Previously Identified Items Closed (IFl 50-277/92-12-01) 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 corrective 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 Managers (ERMs) instead of senior plant management. The Vice President, Peach Bottom functioned as ERM for both drills, and there was notable improvement: ERM 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 Manual, RTM-91) for severe core damage, and to require the ERM 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 censistent with NUREG-0654 guidance, c. Assessment aids for release pathway analysis were developed and placed in the 1 _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ __ . _ _ . _ _ _ _ _. _ _ _ _

. ._ . .. . _ _ _ _ . _ _ _ . -_ .._ __ _. _ _ __. .. .. 9 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. ERM review of press releases is now required. This brought good results. The CS

regularly conferred with the ERM for plant status updates and approval of press releases. The following emergency response procedures (ERPs) were revised to clarify expected

actions such as potassium iodide prioritization, PAR development and upgrading, EOF- TSC dose assessment team interfaces, and ERM approval of press releases, a. ERP-101, Classification of Emergencies b. ERP-C-1200, Emergency l>spnse Manager c. ERP-C-1300, Emergency Operations Facility (EOF) Dose Assessment Team Leader d. ERP-C-1310, Emergency Operations Facility (EOF) Dose Assessment Group e. 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 field 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 hao 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 ERM before dissemination. The following areas for improvement identified 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 communicatior.s 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.

Operations Support Center: Sufficient emergency communications equipment availability.

, .s._,..

, , 10 Operations Support Center: Suf6cient emergency communications equipment availability.

Emergency Operations Facility: Implementing Procedure use.

6.0 Emergency Action Level (EAL) Change The licensee revised ERP-101, " Classification of Emergencies," Table 4.2, Appendix 11, " Boundary Degradation /LOCA" prior to the exercise. The Grst General Emergency (GE) condition in this category previously read: 1) Scram with LOCA AND no ECCS. Indicated by: a. Failure to bring Reactor level above -129" after 3 minutes. b. AND Containment pressure greater than 20 psig. The revision (Revision 1) changed item "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 unspeciRed 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 (IFI 50-332,353/92-28-01). 7.0 Licensee Critique and NRC Exit Meeting On November 25,1992 the NRC team attended the licensee's exercise critique. Lead controllers summarized the licensee's observations. Each area was evaluated for: strengths /signi6 cant improvements, areas for improvement, and recommendations. The critique was thorough, identiRed 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 5 improvement. The licensee was informed that there were no exercise weaknesses and that their exercise performance demonstrated the ability to imptement 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. 1 l _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

' ' . " . ,;s . Attachment 1 , ACENDA MANAGEMENT MEETING WITil NRC REGION 1 September 17, 1992 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 . ... .. .. _ _ _ - _ _ _ _ _ _ _ _ _ _ 1

, . . . , ' C0RRECTIVE ACTIONS EMERGENCY OPERATIONS FACILITY TABLE TOP DRILLS FOR ALL EMERGENCY RESPONSE - MANAGERS, ASSISTANT EMERGENCY RESPONSE MANAGERS, AND DOSE ASSESSMENT TEAMS. FOCUS ON PAR DEVELOPMENT, PAR UPGRADE, RELEASE PATHWAY ASSESSMENT CLARIFICATION OF INTERFACE EXPECTATIONS BETWEEN - E0F AND TSC DOSE ASSESSMENT TEAMS REVISIONS OF PROCEDURES TO CLARIFY EXPECTED - ACTIONS + KI PRIORITIZATION + NOTIFICATION 0F PARS + COMMUNICATION OF INGESTION PATHWAY ASSESSMENT ADDITIONAL COMMUNICATIONS FOR FIRE BRIGADE - EQUIPMENT ROOM CATEGORIZING DRILL RESULTS IN REGARD TO - IMPORTANCE CHANGE IN ASSIGNMENT OF EMERGENCY RESPONSE - MANAGERS

. .-_ - - . - . - - . . . - ,, . . , C O'_R R'E C T I V E- A C T I-0 N S -(CONT.) ' EMERGENCY NEWS CENTER - . REQUIRE EMERGENCY RESPONSE MANAGER REVIEW- 0F- - PRESS RELEASES REVISED EMERGENCY COMMUNICATIONS PLAN- .AND - PROCEDURE READ AND SIGN FOLLOW-UP FOR CORPORATE - SP0KESPERSON, TECHNICAL ADVISORS, EMERGENCY RESPONSE MANAGERS, AND ASSISTANT- EMERGENCY RESPONSE MANAGERS - .

- _ - - _ _ - _ - _ - - _ - _ _ - - _ _ _ _ _ _ _ _ _ _ ____ __ ' PROTECTIVE ACTION REC 0Ff4ENDATION DEVELOPMENT NUREG-0654, REV. 1 AND IE IN 83-28 - MINIMUM PAR 2 MILE SHELTER - CIRCLE .. 5 MILE SHELTER - D0dNWIND 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 . 1 _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

, . ._ _ . . _ . _ _ _ . .. ._ ._ - . _ _ _ _ _ _ _ . _ . _ _ _ . _ . . - _ _ - _ . . _ . _ ' , ' ' Attachment 2 '- . .. CORRECTIVE ACTIONS FOR EOF / ENC 1. ERM/AERM assignment changes. VPs and NQA CM to be ERMs. Train new Corporate Spokespersons. Decision Made 9/14 DMS s STATUS: . Training Scheduled 9/25 S. Keenan . Training: . D.B. Miller Qualified 10/05 .. C.R. Raincy 1st Day Training -10/01- .. J . B . Cotton 1st Day Training 09/29 .. D.R. Helwig- 1st Day Training Sched. 10/12 .. D.R. Helwig and G.R. Rainey Mini-Drill 10/22 J.B. Cotton at INPO, complete training mid-November New Corporate Spokespersons Scheduled 10/09 . to be trained. - 2. Table Tops for existing ERMs to be scheduled and conducted by end of October. Schedule S. Keenan STATUS: . Conduct R.. Mandik/S. Keenan . 3. Table Tops' for DATM. To include release ' pathway assessment, release pathways, and PAR development. Focus on EOF-D ATM interface with TSC-DATM - and EOF-Engineering. 1 Class conducted 10/6 STATUS: . Class conducted- 10/7 . One additional class to be scheduled and- conducted for all . others prior to 10/31. _4 .- Assessment 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 changes 1 and PAR philosophy - for ERMs and-- , D ATL/ DACL.- STATUS: To be issued 10/14 with procedure changes. . . * 6. ERM to be assigned as reviewer of press releases. ., Communications Plan Revised 10/6 - STATUS: . Communications Procedures Revised 10/6 . Read and Sign for Corporate Spokespersons 10/15 . ERM Procedure Change Drafted 10/05 . ERM Procedure Change Final - Scheduled 10/22, . 7. Collateral ERO changes associated with ERM changes: , To be completed approximately 10/31 with exception of J.B. Cotton (at INPO for 5 weeks training) . > 8. Procedure Changes for ERM, DATL: Scheduled for 10/22. .; - Ref. Action items: CTAI A0656968 A0657035 A0660636 EPAIT Q0003178 Q0003179 Q0003180 - ' Q0003181 Q0003182 Q0003183 -Q0003184 Q0003185 Q0003186 Q0003187 . Q0003190 , Q0003191 Q0003192 Q0003193 Q0003194. Q0003196 , , 1 .r'v. ',-

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_ _ . ._- -__ _ . _ _ _ __ _ _ _ - _ _ - . . __ _ __ _ _ _ _ - - _ _ _ _ _ _ _ _ . . . _ _ , _ , . ,. - - ~ t !h'sI384% Docket Nos. 50-352 50-353 50-2T1 50-278 . Mr. D. M. Smith Senior Vlec President - Nuclear Philadelphia Electric Company - Nuclear Group IIcadquarters Correspondence Control Desk P.O. Box 195 . ' Wayne, PA 19087-0195 Subject: EMERGENCY PREPARE 0NESSINSPECTIONNOS.50-352/92 28:50-353/92-28; 50-277/92-33; 50 278/92-33 i r Dear Mr. Smith; ' We recently determined that page number 8 of the report of the subject inspection was transmitted to you with the bottom line cut off. Enclosed is a corrected version of the report. The previously rnissing line appears at the top of page number 9. We apologice for the oversight. No response to this letter is required. Sincerely, Odgkalsaned % Jamn H.Joyner , James H. Joyner, Chief Facilities Radiological Safety 1 and Safeguards Branch Division of Radiation Safety and Safeguards i OFFICIAL RECORD COPY I T o

, . SpAo e I

___ . . . _ .

.- . N 1319L Philadelphia Electric Company 2 cc w/ encl: R. N. Charles, Chairman, Nuclear Review 11oard D. R. liclwig, Vice President - Limerick Generating Station D.11. Miller, Vice President - Peach Bottom Atomic Power Station G. Rainey, Vice President, Nuclear Services Department G. Cranston, General Manager, Nuclear Engineering Division C. Schaefer, External Operations - Nuclear, Delmarva Power & Light Co. K. P. Powers, Plant hianager, Peach Bottom Atomic Power Station A. A. Fulvio, Regulatory Engineer, Peach ik>ttom Atomic Power Station G. J. lleck, hianager - Licensing Section J. W. Durham, Sr. Senior Vice President and General Counsel J. A. Isabella, Director, Generation Projects Department, Atlantic Electric H. W. Gorman, Manager, External Affairs R. hiclean, Power Plant Siting, Nuclear Evaluations D. Poulsen, Secretary of liarford County Council R. Ochs, biaryland Safety Energy Coalition J.11. Walter, Chief Engineer, Public Service Commission of Maryland G. Madsen, Regulatory Engineer - Limerick Generating Station Secretary, Nuclear Committee of the Board Public Document Room (PDR) local Public Document Room (LPDR) Nuclear Safety Information Center (NSIC) K. Abraham, PAO (2) NRC Resident inspector, Limerick NRC Resident inspector, Peach Bottom Commonwealth of Pennsylvania TMl - Alert (TMIA) . . . .. . . . .. . . _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _

- ' - .

  1. A' 131993.

Philadelphia Electric Company 3 . bec w/ encl: Region I Docket Room (with concurrences) E. Wenzinger, DRP C. Anderson, DRP N. Perry, SRI, Yankee Rowe DRS/EB SALP Coordinator V. McCree, OEDO Frank Rinaldi, NRR R. Clark, NRR J. Shea, NRR

___ _ _ _ _ . . , ' A4 13 1933, Philadelphia Electric Company 3 , bec w/ encl: Region I Docket Room (with concurrences) E. Wenzinger, DRP C. Anderson, DRP N. Perry, SRI, Yankee Rowe DRS/EB SALP Coordinator V. McCrec, OFl>O Frank Rinaldi, NRR R. Clark, NRR J. Shea, NRR . . . . . . . . . }}

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