ML20128D431
| ML20128D431 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 02/01/1993 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20128D391 | List: |
| References | |
| 50-298-93-03, 50-298-93-3, NUDOCS 9302100144 | |
| Download: ML20128D431 (12) | |
See also: IR 05000298/1993003
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APPENDIX 8
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION IV
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Inspection Report:
50-298/93-03
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Operating License:
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Licensee: Nebraska Public Power District
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P.O. Box 499
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Columbus, Nebraska 68602-0499
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Facility Name: Cooper Nuclear Station
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Inspection At: Brownville, Nebraska
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Inspection Conducted: January 18-22, 1993
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Inspectors:
D. Blair Spitzberg, Ph.D. Emergency Preparedness' Analyst
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(Lead Inspector) Facilities Intpection Programs Section
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Jack M. Keeton, Reactor Engineer (Examiner), Operations
Inspection Section
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Approved:
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if,G i'e f,
Tlities Inspection Programs
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Inspection Summarv
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Areas Inspected:
Routine, announced inspection of the operational-status of
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the Emergency Preparedness Program, including changes to the Emergency Plan
and Implementing Procedures; emergency facilities, equipment, and supplies;
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organuation and management control; training; and internal reviews and
audits. A regional inspection initiative was performed in the area of
knowledge and performance of duties of emergency response personnel.
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Results:
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Changes made to the Emergency Plan were found not to' have decreased the
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effectiveness of emergency planning and had been properly reviewed and-
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submitted to NRC. One noncited violation was identified and corrected
by the licensee for failure to submit to NRC one emergency plan
implementing procedure revision within the1 required timeframe-(Section
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.The emergency response facilities had been maintained in a state of
operational: readiness.
A violation was . identified for failure to
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conduct tests of the Emergency Response Organization pager system as
required by the Emergency Plan (Section 2.2).
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A good number of trained personnel had been assigned to the Emergency
Response Organization.
Procedures for callout of the Emergency Response
Organization appeared adequate, although as noted with the violation
mentioned above, sufficient tests had not been conducted to ensure the
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reliability of the licensee's Emergency Response Organization callout
capabilities.
The Emergency Planning Organization was well staffed with
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qualified individuals (Section 3.2).
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A good program of emergency response training had been administered to
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provide personnel with specialized training specific to their response
duties and responsibilities.
A violation 6 4s . identified for not
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performing a critique following one training drill.and not pursuing
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followup action to weaknesses identified during another drill
(Section4.2).
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Operatir.g crsws evaluated in the control room simulator performed well-
in detecting and classifying sinulated emergency conditions.
Notifications to offsite authorities were accurate-and timely.
Protective action recommendations were conservative and appropriate.
The operating crews demonstrated an improved knowledge and performance
of duties in all areas found to be weak in recent inspections of '
emergency preparedness (Section 5.2)..
Quality assurance audits of emergency preparedness were of good scope
and depth.
Quality assurance survei'. lances performed of emergency
preparedness wer.e well targeted and effective (Section 6.2).
Summar_v of insoection Findinas:
Violation 298/9303-01 was identified for failure to conduct required-
tests of the pagers used to notify members of the Emergency Response
Organization (Section 2.1).
Violation 298/9303-02 was identified for failure-to conduct a drill
critique and for failure to followup as required on drill weaknesses
(Section 4.1).
Exercise Weakness 298/9214-01 was closed (Section 7.1).
Weakness 298/9201-01 was closed (Section 7.2).
Weakness 298/9201-02 was closed (Section 7.3).
Weakness 298/9201-03 was closed (Section 7.4).
Weakness 298/9201-04 was' closed (Section 7.5).
Attachment
Attachment --Persons Contacted and Exit Meeting
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DETAILS
1 EMERGENCY PLAN AND IMPLEMENTING PROCEDURES
(82701-02.01)
The inspectors reviewed changes in the licensee's Emergency Plan and
implementing Procedures to verify that these changes had not decreased the
effectiveness of emergency planning and that the changes had been reviewed
properly and submitted to NRC.
1.1 Discussion
Since the previous inspection in this functional area, the licensee had made
four revisions to the Emergency Plan.
The inspectors determined that these
revisions had been reviewed and submitted to NRC in accordance with Emergency
Preparedness Department Procedure 06, " Emergency Plan Revisions," and
The Emergency Plan changes were found not to decrease the
effectiveness of emergency planning.
The inspectors reviewed documentation of Emergency Plan Implementing Procedure
revisions implemented since toe previous inspection.
Approximately 30 such
changes had been made.
Five Emergency Plan Implementing Procedures revisions
had not been submitted to NRC within 30 days of their effective date; however,
four of these were only editorial or typographical corrections with no change
in the substance of the procedure. One of these five changes involved
Emergency Plan implementing Procedure 5.7.24, Revision 9, " Medical
(Radiological Contaminated Medical Emergency).
This revision was implemented
on March 12, 1992 but was not submitted to NRC within 30 days of this date as
required by 10 CFR Part 50, Appendix E.V.
NRC submittal date of this revision
was May 27, 1992. This violation of HRC regulations had been identified by
the licensee and discussed at the time of discovery with the lead inspector by
telephone.
During the inspection, the inspectors reviewed the Licensee's
Nonconformance Report 92-059 initiated following the late submittal.
This
documentation showed that prompt and effective corrective action was taken in
response to this self-identified violation.
This violation is not being cited
because the criteria in paragraph Vll.B.2 of Appendix C to 10 CFR Part 2 of
NRC's " Rules of Practice" were satisfied. This violation was an isolated
occurrence, and the licensee's staff took prompt and effective actions to
correct the problem.
1.2 Conclusions
Changes made to the Emergency Plan were found not to have decreased the
effectiveness of emergency planning and had been properly reviewed and
submitted to NRC. One noncited violation was identified and corrected by the
licensee for failure to submit to NRC one Emergency Plan Implementing
Procedure revision within the required timeframe.
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2 EMERGENCY FACILITIES, EQUIPMENT, INSTRUMENTATION, AND SUPPLIES
(82701-02.02)
The inspectors toured onsite emergency facilities and reviewed the licensee's
emergency equipment inventories and maintenance to determine whether
facilities and equipment had been kept in a state of operational readiness.
2.1
Discussion
All primary nearsite Emergency Response Facilities were found to be
operationally ready. A recently approved facility change had combined three
Operational Support Center areas previously utilized into a single Operational
Support Center connected with the Technical Support Center.
The inspectors
noted that this facility was observed to be as depicted in the plan revision.
The alternate Operational Support Center was inspected, and it was determined
that the licensee was in the process of determining the emergency supplies
that would need to be prestocked in this facility.
All primary Emergency
Response facilities were noted to have current controlled copies of the
Emergency Plan and Emergency Plan implementing Procedures.
The new alternate
Operational Support Center had not yet been supplied with these documents.
Emergency equipment lockers located in the principle nearsite emergency
response facilities were found to be secure and stocked with the inventoried
equipment and supplies listed in Emergency Plan Implementing Procedure 5.7.21,
" Emergency Equipment Inventory." The inspectors did note that two R0-2A
survey instruments located in the field survey Lits in the Emergency
Operations facility were not labelled as to the date of last calibration.
Af ter checking with the health physics organization, the inspectors found
documentation showing that these instruments were in calibration.
The
inspectors reviewed documentation of Technical Support Center and Emergency
Operations facility emergency ventilation systems tests.
The tests had been
conducted in accordance with Station Surveillance Procedures by outside
contractors.
Testing was specified to conform with Regulatory Guide 1.52.
The July 1992 Technical Support Center system tests and the September 1991
Emergency Operations Facility system tests showed that these systems met tne
applicable test criteria and were capable of performing their designed
function.
The inspectors reviewed documentation of 30 Preventative Maintenance
Surveillance Procedures which had been performed at designated frequencies in
order to ensure the maintenance and readiness of emergency equipment. One
such preventive maintenance surveillanc.e had not been performed monthly as
specified in the Preventive Maintenance Procedure since April 1992.
This
Preventive Maintenance Surveillance 4634 was for the purpose of testing the
licensee's pager system for calling out Emergency Response Organization
personnel assigned to Emergency Response facility minimum staffing positions.
10 CFR 50.54(q) requires that the licensee follow its emergency plans.
Section 8.6 of the licensee's Emergency Plan, " Maintenance and Inventory of
Emergency Equipment and Supplies," requires that quarterly inspections of the
operational readiness of items of emergency equipment and supplies are
conducted on a departmental basis.
The use of inventory procedures in
conjunction with the licensee's Preventative Maintenance Tracking System and
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followup actions ensured that equipment was ready for use.
The inspectors
determined that as of January 22, 1993, tests of the licensee's Emergency
Response Organization pager system had not been performed monthly in
accordance with Preventive Maintenance Procedure 4634 since April 1992.
During this period of time, only one test to ensure that the licensee's pager
system was ready for use had been conducted, and this test was conducted by a
different test procedure than that outlined in Preventive Maintenance
Procedure 0434.
This was identified as a violation of 10 CFR 50.54(q) and
Section 8.6 of the Emergency Plan (298/9303-01).
2.2 Conclusions
The Emergency Response Facilities had been maintained in a state of
operational readiness.
A violation was identified for failure to conduct
tests of the Emergency Response Organization pager system as required by the
3 ORGANIZATION AND MANAGEMENT CONTROL (82701-02.03)
The inspectors reviewed the Emergency Response Organization staffing levels to
determine whether sufficient personnel resources were availhble for emergency
response.
The Emergency Planning Organization was reviewed to ensure that an
effective programmatic management system was in place.
3.1 Discussion
A current listing of the Emergency Response Organization positions and staff
assignments was reviewed by the inspectors.
No significant changes in the
Emergency Response Organization position responsibilities or management had
occurred since the previous inspection in this functional area. A good level
of staffing depth was assigned to the Emergency Response Organization to
ensure that trained personnel would be available to respond initially and that
staff augmentation could occur for prolonged responses.
At the time of the
inspection, 249 individuals had been assigned to the Emergency Response
Organization.
The inspectors reviewed procedures and mechanisms for Emergency Response
Organization callout to ensure that prompt activatior, could occur.
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Emergency Response Organization callout capability had been described in the
licensee's Policy Directive 10.
This process called for designated
departmental personnel to carry pagers on a rotating basis.
Upon receiving a
coded page for Emergency Response Organization activation, these on-call
individuals were then assigned to telephone other designated Emergency
Response Organization personnel within their departments until the minimum
staffing levels specified in NUREG 0654 were filled.
The inspectors reviewed
documentation of a November 9, 1992, unannounced test of the on-call
individuals.
This test which attempted to contact only the seven individuals
listed on the on-call pager board was deemed successful by the licensee.
The
results showed that the on-call operations representative and the corporate
representative failed to respond.
As noted in Section 2.1, this was the only
test of the pagers conducted between April 1992 and the date of the
inspection.
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The inspectors reviewed the Emergency Planning Organization and determined
that no changes in personnel or management had occurred since the previous
inspection.
The Emergency Planning Organization consisted of two onsite
planning professionals and one corporate professional all reporting to an
Emergency Planning Supervisor based at the corporate office.
Emergency
planning reported direct 1v to the Division Director of Nuclear Support.
Position descriptions and qualifications for emergency planning staff were
reviewed.
The inspectors found that the Emergency Planning Organization was
well staffed by qualified individuals.
3.2 Conclusions
A good number of trained personnel had been assigned to the Emergency Response
Organization.
Procedures for callout of the Emergency Response Organization
appeared adequate although, as noted with the violation discussed in
Section 2.1, sufficient tests had not been conducted to ensure the reliability
of the licensee's Emergency Response Organization callout capabilities. The
Emergency Planning Organization was well staffed with qualified individuals.
4 TRAINING (82701-02.04)
The inspectors met with personnel responsible for conducting the licensee
Emergency Response Training Program. The training program was reviewed to
determine whether adequate emergency response training had been given to
personnel designated to respond to emergencies and to determine compliance
with the requirements of 10 CFR 50.47(b)(15); 10 CFR Part 50, Appendix E.IV.F;
and the Emergency Plan.
4.1 Discussion
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The inspectors reviewed the licensee's training requirements for emergency
response personnel as specified in Training Program Description 0601.
This
document referenced the specific courses required to qualify individuals for
assigned positions within the Emergency Response Organization.
The
certification of individuals assigned to the Emergency Response Organization
had been in accordance with Nuclear Training Department Procedure 03.
Both of
these documents had received the approval of the division manager responsible
The inspectors found that the training
requirements for Emergency Response Organization positions appeared to
correspond well to the position's response duties and resaonsibilities.
The
inspectors discussed with licensee representatives the scleduling practices
for emergency response training. Qualification sheets and a computer-based
tracking system had been used to provide an ongoing status of emergency
response personnel's training qualifications.
A representative sample of emergency response training lesson plans, student
text, and exams were reviewed, The lesson plans and student text were
organized and well written and included clear lesson objectives.
The multiple
choice exams tracked well with lesson objectives.
The inspectors reviewed the
training qualification status of a randomly selected number of individuals
assigned to the Emergency Response Organization.
The emergency response
training for all individuals reviewed was found to be current.
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The inspectors reviewed documentation of emergency response training drills
and exercises to determine compliance with 10 CFR Part 50, Appendix E.IV.F and
Section 8.2 of the Emergency Plan.
The guidance for conducting drills and
exercises had been proceduralized in Surveillance Procedure 6.3.11.1, "CNS
Emergency Drill and Exere.ise Plan." Documentation showed that the licensee
had conducted the required drills specified in the Emergency Plan.
A total of
seven drills or exercises had been documented during 1992. One of these was a
tabletop drill for the Technical Support Center only.
The following were the
dates of the other six drills and exercises conducted in 1992 with the
operating crew that participated:
June 2, 1992
Hini-drill (Crew E)
August 11, 1992
Mini-drill (Crew C)
August 19, 1992
Mini-drill (Crew C)
September 1, 1992
Exercise dress rehearsal (Crew C)
September 22, 1992 Annual graded exercise (Crew C)
December 14, 1992
Medical drill (Crew D)
As noted above, of the six drills conducted during 1992 using operating crews,
four used the same crew (Crew C, out of six crews).
This operating crew was
the same crew that was selected to be evaluated during the 1992 graded
exercise.
This crew played in the two mini-drills as well as the exercise
dress rehearsal conducted in the 2 months preceding the annual graded
exercise.
This selection of crew participants for drills leading up to the
annual exercise appeared to be nonrandom and was not rotational amonc crews.
This pattern could give the appearance of having been preparing a single crew
for the graded exercise.
Section 8.2 of the licensee's Emergency Plan, " Drills and Exercises," requires
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that drill performance will be critiqued by personnel acting as drill
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observers.
Based on the results of these critiques, followup action is then
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recommended by the Emergency Preparedness Supervisor, with action items
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assigned by the appropriate level of management.
The inspectors determined
from drill documentation that no critique was performed following a June 2,
1992 mini-drill.
This drill progressed for over 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and was repotiedly
terminated because objectives were not being met.and because of poor drill
preparations.
The drill included plant-wide assembly and accountability and
included the participation of at least 22 Emergency Response Organization
personnel in addition to the operating crew and eight evaluators.
The
inspectors also noted from drill documentation that no followup action was
recommended or assigned for three weaknesses identifled during an emergency
exercise dress rehearsal drill conducted on September 1, 1992.
These findings
were identified as a violation of 10 CFR Part 50.54(q) and Section 8.2 of the
Emergency Plan (298/9303-02).
4.2 Conclusion
A good program of emergency response training had been administered to provide
personnel with specialized training specific to their response duties and
responsibilities.
A violation was identified for not performing a critique
following one training drill and for not pursuing. followup action to
weaknesses identified during another drill.
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5 KNOWLEDGE AND PERFORMANCE OF DUTIES (82206)
The inspectors conducted a series of walkthroughs on the plant specific
control room timulator to evaluate the current knowledge and ability of
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personnel assigned energency response duties in the control room.
The
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scenarios used in the evaluations were developed by the inspectors to
determine if control room teams were able to classify events accurately,
perform the required notifications in a timely manner, perform offsite dose
assessments, and make adequate protective action recommendations.
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5.1 Discussion
The inspectors observed three crews during the walkthroughs using the control
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room simulator in the dynamic mode.
The scenario consisted of a sequence of
events requiring an escalation of emergency classifications, culminating in a
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General Emergency.
The scenario began with conditions leading to a Notico of
Unusual Event classification for elevated iodine-131 activity in the coolant,
following notifications, the scenario led to a loss of offsite power with a
failure of the reactor to trip automatically.
At this time, high pressure
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coolant injection failed to start.
Because of a reactor coolant level
transient, clad damage occurred yielding initiating conditions for an Alert.
The final scenario event involved an unisolable steam line break in the high
3ressure coolant injection system failing the remaining two fission product
aarriers. This yielded General Emergency conditions with a radiological
release to the environment.
Each walkthrough lasted approximately 90 minutes.
During the walkthroughs,
the inspectors were able to observe the interaction of the response crews to
verify that authorities and responsibilities were clearly defined and
understood.
The walkthroughs also allowed the evaluation of the crews'
abilities to assess and classify accident conditions, perform dose
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assessments, develop protective action recommendations, and make timely and
complete notifications to offsite authorities.
The inspectors noted improvements in crew performance in several areas from
the walkthroughs conducted during the previous inspection.
For example, none
of the classification problems exhibited during the previous inspection were
observed during this inspection as all emergency classifications were made in
a timely manner. Offsite notifications were timely, and the infermation
conveyed was clear and accurate.
Command and control were improved from the
previous walkthroughs and exercises, and communications among operators were
excellent.
The inspectors observed and evaluated the ability of each crew to perform dose
projections and assessments by manual calculations using Emergency Plan
implementing Procedure 5.7.16, " Release Rate Determination," and Emergency
Plan Implementing Procedure 5.7.17, "Dese Assessment." Hanual calculations
were necessitated because the loss of offsite power failed the effluent
monitors which are necessary for implementing the computer-based dose
assessment program.
Two crews used proper plant indications and calculation
methods to assess offsite dose conditions.
One crew incorrectly used
Attachment 3 to Emergency Plan Implementing Procedure 5.7.16 for the release
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rate calculation.
This attachment was to be used only if the primary
containment was intact, a condition not met-during the release phase of the
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scenario.
This crew stated that they understood that high pressure coolant
injection system had been isolated.
The scenario, however, forced the high
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pressure coolant injection system leak to be unisolable.
This error appeared
to be isolated,
and the inspectors concluded it did not represent an
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emergency response training weakness.
Protective action recommendations made by the operating crews were appropriate
for the plant conditions prevailing at the time they were formulated. At the
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General Emergency classification, baseline protective action recommendations
were made which were consistent with NRC guidance specified in Response
Technical Manual 92.
The crews were alert to detect a wind shift midway
through the scenario and to alter the-effected downwind sectors appropriately.
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5.2 Conclusions-
Operating crews ' evaluated in the control room simulator performed well in
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detecting and classifying simulated emergency conditions.- Notifications to
offsite authorities were accurate and timely.
Protective action-
recommendations were conservat ue and appropriate. The operating crews
demonstrated an improved knowledge and performance of duties in all areas
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found to be weak in recent inspections of emergency preparedness.
6 INDEPENDENT AND INTERNAL REVIEWS AND AUDITS (82701-02.05)
The inspectors met with quality assurance personnel and reviewed independent
and internal audits of the Emergency Preparedness-Program performed since the
last inspection to determine compliance with the requirements of
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6.1 Discussion
The last audit performed of emergency preparedness pursuant to 10 CFR 50.54(t)
was reviewed (Audit 92-04). The audit was performed over a 6-week period in
February and March 1992 by a two-person team consisting of a lead auditor and
a technical specialist from another licensed facility. The inspectors
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- reviewed the audit procedure and checklist >for this audit and'found that t ey
had been revised prior to the audit to incorporate NRC inspection findings,-
information notices, and lessons learned from-recent emergency events.
The
audit checklists had received management review and approval prior to- the
audit.
The inspectors reviewed-documentation of the qualifications of the
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lead auditor and found that he was certified to meet lead auditor
qualifications specified in ANSI N45= 2.
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The licensee's audit' findings had been characterized in accordance with
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Quality Assurance Instruction QAl-5.
The 1992-audit was found to have-been of-
good scope and depth and evaluated the adequacy of-interfaces with state and-
local governments as required by 10 CFR=50.54(t).- There were no negative-
findings identified during the 1992 audit.-
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The inspectors reviewed the licensee's program of surveillances performed of
emergency preparedness by the quality assurance organization. Approximately
16 surveillances were performed during 1992.
The documentation of these
surveillances was reviewed, and it was determined that they had been performed
by qualified individuals using approved checklists.
Three findings had been
made during the surveillances, and appropriate followup action was taken.
Ihe
surveillance strategy was found to be well targeted and effective.
6.2 Conclusion
Quality assurance audits of emergency preparedness were of good scope and
depth. Quality assurance surveillances performed of emergency preparedness
were well targeted and effective.
7 FOLLOWUP ON PREVIOUS INSPECTION FINDINGS
(92702)
7.1
(Closed) Exercise Weakness 298/9214-01:
failure to Take Steps to Ensure
Technical Support Center / Operational Support Center Habitability Durina
a Release.
The inspectors reviewed revised Emergency Plan Im)1ementing
Procedure 5.7.7 which included a revised health p1ysics Coordinator's
checklist requiring activation of emergency ventilation system upon
activation of Technical Support Center / Operational Support Center, and
closing of the entry door after review of habitability surveys.
The
inspectors also observed the relocated Technical Support Center
continuous air monitor.
7.2
(Closed) leakness 298/9201-01:
Failure of Control Room Crews to
Properl_Y Classify Emeroency Events Durina Operatina Crew Walkthroughs,
in the walkthroughs conducted during this inspection, operating crews
promptly and accurately classified emergency events.
7.3
(Closed) Weakness 298/9201-02:
Failure of Control Room Crews to Make
Complete and Accurate Notifications Durina Control Room Walkthroughs.
In the walkthroughs conducted during this inspection, operating crews
made timely and accurate notifications of emergency events.
7.4
(Closed) Weakness 298/9201-03: Weak Performance of Dose Assessments
from the Control Room Durina the Walkthrouahs.
In the walkthroughs conducted during this inspection, two of three
operating crews evaluated performed accurate dose assessment based on
prevailing plant conditions.
The remaining crew made an error in
implementing the manual leak rate determination procedure; however, this
was determined to be an isolated case and did not reflect a training
weakness in this area.
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7.5
(Closed) Weakness 298/9201-04: Weak formulation of Protective Actions
from the Control Room durina Walfthroughs.
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In walkthroughs conducted during this inspection, operating crews made
proper protective action recomendations based on accident conditions.
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ATTACHMENT
1 PERSONS CONTACTED
1.1
Licensee Personnel
- R. Black, Operations _ Supervisor
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- R. Brungardt, Operations Manager
- R. Creason, Supervisor, Licensed Operator Training
- M. Dean, Supervisor, Licensing and Safety
- J. Dutton, Manager, Nuclear Training
- M. Estes, Nuclear Management Trainee
- R. Gardner, Plant Manager
- R. Hayden, Coordinator, E;nergency Preparedness
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- S. Jobe Assistant Manager, Nuclear Training
- M. Kaul, Shift Supervisor
- J. Kelsay, Emergency Preparedness Specialist
- H. Krumland, Supervisor, Emergency. Preparedness
- E. Mace, Senior Manager Site Support
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-J. Meacham, Site Manager
- S. Peterson, Senior Manager, Ooerations
- G. E. Smith, Manager,_ Quality Assurance
- G. R. Smith, Manager, Nuclear Licensing and Safety
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- V. Stairs, Assistant Manager, Operations
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- D. VanDerKamp. Shift Supervisor
- D. Whitman, Division Manager, Nuclear Support
1.2
NRC Personnel
- W. Walker, Resident inspector
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- E. Collins, Region IV Project Engineer
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The inspectors also held discussions with and observed the actions of other
station and corporate personnel.
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2 EXIT MEETING
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An exit meeting was conducted on January 22, 1993.
During this meeting, the
inspectors reviewed the scope and findings of the inspection as presented in
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this report.
The-licensee did not identify as proprietary any of the
materials provided to, or reviewed by, the inspection team during the
inspection.
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