ML20129F470
| ML20129F470 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 10/23/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20129F473 | List: |
| References | |
| 50-213-96-07, 50-213-96-7, NUDOCS 9610290132 | |
| Download: ML20129F470 (19) | |
See also: IR 05000213/1996007
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U. S. NUCLEAR REGULATORY COMMISSION )
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REGION I )
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Docket No: 50-213
License No: DPR-61
Report No: 50 213/96-07 l
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Licensee: Connecticut Yankee Atomic Power Company
P.O. Box 270
Hartford, CT 06141-0270
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Facility: Haddam Neck Plant
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Dates: August 13 - August 16,1996 l
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Inspectors: J. Lusher, Emergency Preparedness Specialist, Region I
N. McNamara, Emergency Preparedness Specialist, Region I i
D. Silk, Senior Emergency Preparedness Specialist, Region I i
W. Raymond, Senior Resident inspector, Haddam Neck Plant l
P. Habighorst, Resident inspector, Haddam Neck Plant :
A. Burritt, Resident inspector, Millstone Unit 1 l
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Approved by: Richard R. Keimig, Chief l
Emergency Preparedness and Safeguards Branch
Division of Reactor Safety
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9610290132 961023
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O ADOCK 05000213
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TABLE OF CONTENTS
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EX EC UTIV E S U M M ARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii
P4 Staff Knowledge and Performance ................................ 1
a. Exercise Evaluation Scope ................................. 1
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b. Emergency Response Facility Observations and Critique . . . . . . . . . . . . 2 j
c. Overall Exercise Conclusions .............................. 10 3
P8 Miscellaneous EP Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
P8.1 In-Office Review of Licensee Procedure Changes . . . . . . . . . . . . . . . . 11 )
P8.2 Inspector Review of Licensee's Adverse Condition
Report for the May 23,1996, Training Drill . . . . . . . . . . . . . . . . . . . . 11
a. Inspection Scope . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
b. Observation and Findings . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
c. Conclusions ..................................... 12 ;
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M AN AG EM ENT M EETI N G S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 l
X1 Exit Me e tin g . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 l
PARTI AL LIST OF PERSONS CONTACTED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
LIST OF INSPECTION PROCEDURES USED .............................. 13
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED . . . . . . . . . . . . . . . . . . . . . . . 13
LI ST O F AC RO NYMS U S ED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
Attachment 1: List of the Emergency Plan and implementing Procedures Reviewed
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EXECUTIVE SUMMARY
Haddam Neck Plant
Full-participation Emergency Preparedness Exercise Evaluation
August 13-16,1996
inspection Report 50-213/96-007
This inspection evaluated the licensee's performance during its biennial emergency
preparedness exercise. The inspectors observed emergency facility staffing, procedure
implementation, effectiveness of mitigation actions, communications, direction and control,
emergency classifications, and off-site notifications.
During the exercise, two weaknesses were observed: 1) failure to recognize the need for
an Alert declaration early in the exercise (which consequently was prompted by the lead
controller) and confusion with the use of emergency action level tables prior to the
declaration of the General Emergency; and 2) failure to implement protective actions for
the SERO at the EOF and site personnel, and consider protective action recommendations )
beyond the 10 mile emergency planning zone, based upon the dose projections used in ;
support of those protective actions. These exercise weaknesses are being considered for
enforcement action sirce they may constitute violations of 10 CFR 50.47(b) and Appendix '
E. (eel 50-213/96-07-01: GI 50-213/06-07-02)
The inspectors also observed that: 1) the overstaffing of key SERO positioris with two and
three individuals very early in the exercise caused confusion and problems for other
individuals initially assigned to the SERO, and made it extremely difficult for the NRC
inspectors to assess the true performance of the individuals actually assigned to those
positions; and 2) the over-staffing also may have affected the ability of the SERO to
communicate effectively within and among the facilities and with the State. The latter two
situations severely limited the inspectors' ability to determine if the SERO could effectively
implement the emergency plan and implementing procedures.
At the completion of the licensee's critique, the licensee's staff committed 1) to take
timely and appropriate corrective action for the weaknesses identified, 2) to have a
management meeting at the NRC Region I office to discuss those corrective actions, and 3)
to perform a drill onsite of sufficient scope to demonstrate the effectiveness of those
corrective actions prior to the restart of the Haddam Neck Plant.
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f REPORT DETAILS
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P4 Staff Knowledge and Performance
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a. Exercise Evaluation Scoce
, During this inspection, the NRC inspectors observed and evaluated the licensee's
l biennial full-participation exercise in the simulator control room (SCR), technical j
support center (TSC), operations support center (OSC), and the emergency
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operations facility (EOF). The inspectors assessed licensee recognition of abnormal
plant conditions, classification of emergency conditians, notification of off-site i
4 agencies, development of protective action recommendations, command and I
i control, communications, and the overall implementation of the emergency plan. In
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addition, the inspectors attended the post-exercise critique to evaluate the
4 licensee's self-assessment of the exercise.
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The scenario began with the plant operating at 100% power, with electrical bus 8 1
out of service for replacement of bus work fasteners. Additionally, severe l
thunderstorms had been forecast for the area. At 3:25 p.m., lightning struck the
intake structure exhaust pipe from the diesel fire pump and caused a momentary
- loss of semi-vital power. The shift manager received information that the intake
structure, diesel fire pump, and D circulating water pump had been damaged. An
Alert declaration should have been made on visible damage to vital structures and
equipment. This was not done until prompted by the controller. At 4:30 p.m., a
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small reactor coolant leak began through the head vent and shortly after that there ;
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was a loss of all semi-vital power due to a faulty breaker, requiring a manual reactor !
trip due to loss of feedwater. This caused the shift crew to transition to Function l
Restoration Procedure (FR-H1) when feed flow could not be established within
15 minutes and the shift manager declared a Site Area Emergency (SAE) based on
potential loss of two barriers (i.e., reactor coolant system and fuel). When safety i
injection was actuated for feed and bleed the "B" High Pressure Safety injection )'
(HPSI) pump failed to start and the running HPSI pump experienced a break in the
HPSI common injection line in containment. At 3:35 p.m., a steam generator tube
rupture occurred due to a high differential pressure across the number 4 steam
generator. Additionally, at 5:40 p.m., reactor coolant pump seals failed. Due to the
loss of reactor coolant system inventory, the core exit thermocouples and
containment radiation monitor readings began to increase. At about 5:55 p.m., the
steam generator code safety lifted releasing reactor coolant system secondary and
primary coolant water directly to the atmosphere, requiring a General Emergency
(GE) to be declared on loss of three barriers (fuel, reactor coolant system, and
containment).
The SERO had been expected to pursue multiple success paths to restore core
cooling and the electrical repair team was able to restore power to emergency bus
8. Additionally, the SERO isolated the reactor coolant system loop to the faulted
steam generator and terminated the release.
At the time the exercise was terminated (about 8:30 p.m.), the State of Connecticut
was in the process of evacuating the ten mile emergency planning zone (EPZ).
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b. Emeraency Response Facility Observations and Critiaue
b.1 Simulator Control Room (SCR)
The control room shift manager (SM) improperly classified the initiating event as a
unusual event. Both the SM and the duty officer reviewed the emergency action
levels (EALs) table and failed to identify that the reported structural damage to the
intake structure and the "D" service water pump warranted an Alert classification.
Subsequently, the SM was prompted to classify the event as an Alert by the drill
controller. However, even after a second review of the EAL table, the SM was still
uncertain about the basis for the Alert classification. This was assessed an exercise
weakness. Following the activation of the EOF and further equipment degradation,
the SM and duty officer made a timely and correct recommendation to the Director
of Site Emergency Operation (DSEO) to upgrade the event classification.
The crew implemented the initial emergency response plan procedures appropriately
and offsite notifications were made within the required time limits following the
event classification. However, during the initial activation of the emergency
response organization, the emergency notification system phone was not
continuously manned for approximately one-half hour. Further, the SM did not
adequately implement procedure 1.5-26, " Manager of Control Room Operations"
following his relief as DSEO. For example, control room ventilation was not verified
to be in the fallout mode, health physics support for plant operator act!ons in
radiological areas was not requested, and the assistant dire.; tor, technical support
(ADTS) was not kept informed of the deployment of operr.tions personnel as
specified in the procedure.
Communications between the control room and other emergency response support
facilities was adequately handled by the SM. However, the SM did not keep control
room personnel informed of the changes in event classifications, the EOF activation,
and the duty officer being relieved of his DSEO responsibilities. Although not
evident in the scenario, the demands of maintaining an effective flow of information
to external support facilities and personnel could become a distraction for the SM
who also needs to maintain oversight of control room activities while acting as the
shift technical advisor. The licensee plans to re-evaluate the use of the SM as the
principle communications link between the control room and other emergency
response facilities.
The implementation of 10 CFR 50.54(x) to perform actions contrary to emergency
operating procedures (EOPs) and other guidance was not adequately controlled or
documented. The SM identified cases in which 10 CFR 50.54(x) was necessary;
however, the review and concurrence by the TSC was informal. The SM directed
that the safety injection relays be reset per 10 CFR 50.54(x) to prevent automatic
opening of the core deluge valves when the reactor vessel depressurized. The
rationale for this action was to minimize the potential for an inter-system leak if the
system check valves leaked and this action was not questioned by the TSC staff.
The resetting of the safety injection relays was later determined to be inappropriate
following discussions between the inspector and the operations manager. In most
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cases,10 CFR 50.54(x) declarations were not articulated to the crew and were not
logged in the SCR. Although most declarations of 10 CFR 50.54(x) were logged at
the TSC or EOF, including the notification of the NRC, the actions taken and their l
justifications were typically not documented. In one case, the SM implemented !
actions to bleed steam from a steam generator following a tube rupture, as allowed
by 10 CFR 50.54(x), without the action being logged or NRC notification being
made. The control of actions under 10 CFR 50.54(x) is also discussed as a
, command and control issue in the TSC area in Section b.2 of this report.
The crew appropriately implemented abnormal operating procedures and EOPs
although many of the events were beyond the guidance provided in the EOPs. The
crew promptly diagnosed most equipment failures; however, a HPSI line break and
failure of the reactor coolant pump seals were not identified during the exercise.
The failure to identify the HPSIline break could have delayed the crew in
establishing an injection source to the vessel; however, an exercise control error
allowed the use of HPSI to reflood the core. In addition, the SM identified a number
of changing plant conditions such as the trip of the "A" HPSI pump and core
uncovery, that were not initially identified by the crew. Throughout the exercise,
the crew anticipated further plant degradation and established contingency plans.
For example, electrical maintenance was directed to restore electrical bus 8
following the notification of impending severe weather.
Additionally, the SCR crew directed plant operator actions in and outside the plant
, without consistently ensuring the approprie.te health physics coordination or
precautions were taken. Health physics personnel were typically not assigned to
accompany the operators while performing tasks in and around areas of radiological
releases. For example, an operator was sent to close the auxiliary feed bypass
valves and to close service water motor operated valves 3 & 4, without
consideration of radiological consequences,
b.2 Technical Sucoort Center (TSC1
The TSC was activated in a timely manner with managers and personnel
representing the appropriate disciplines. Managers and personnel in the TSC, the
accident management team (AMT) and the ADTS staff appeared familiar with
assigned duties and responsibilities. Assigned tasks were performed efficiently.
The TSC assessment tools and support information were readily available and
adequate to support the response efforts. Examples included the drawings,
procedures and computer terminals (offsite facilities information services (OFIS), and
the safety parameter display system (SPDS)) in the TSC.
The communications link established among the TSC, the SCR and the DSEO
worked well to allow the flow of information and the rapid exchange of data to
assess or clarify plant conditions, and to relay changes in mitigation strategies. The
display of status information within the TSC was generally good; plant and event
information boards were updated and used by the staff. The communication links
with the DSEO were also effective in communicating emergency response status
information and corrective actions. Examples included the responses following the
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loss of semi-vital power / reactor trip, the steam generator tube rupture, and the
communication of estimates for degraded core conditions. However, not all
important status information was effectively shared with personnel needing that
information. For example, key members of the AMT were not aware of the
restoration time for Bus 8, even thougn this information was readily available within
the TSC. This information deficierey contributed to an incorrect PAR made to the
State.
The TSC was effective in working with the manager, control room operations
(MCRO) to assess plant status as conditions degraded, and to identify actions
needed to restore core cooling and minimize releases. The ADTS coordinated well
with the manager, technical support center (MTSC) and manager, operational
support center (MOSC) to establish and prioritize repair tasks. The coordination
was particularly effective during periods when plant conditions were degrading to
reassess task priority real-time with changing plant status. Examples included the
coordination to assess the conditions at the intake structure and the status of HPSI
following restoration of power. The mitigation actions in response to degraded
equipment were generally appropriate, as were the strategies to identify the success
paths to stabilize the plant.
The TSC staff was generally aware of plant conditions, including the systems in a
degraded status. Two exceptions were noted. The TSC failed to assess the status
of the reactor coolant pressure boundary fully, and did not note the failure of the
reactor coolant pump seals or the failure of HPSI injection when safety injection first ,
occurred. Although the symptoms of increased reactor coolant system (RCS) i
leakage were noted, the TSC failed to pursue this information to establish the
cause(s) or assess the significance. While these f ailuren did not impact the
successful mitigation of this event, the failure to diagnose these conditions
impacted the quality of the information provided to the AMT for use in core damage
predictions.
The TSC was somewhat effective in diagnosing events, providing recommendations ;
to . mitigate degraded conditions, and implementing the E-plan (classification of plant
damage status). There was a duplication of effort in the review of EALs. This was
done by both the TSC engineers and the ADTS support staff. Once stable plant
conditions were achieved to assure core cooling, the TSC staff performed wellin
reviewing plant conditions and assessing plant and equipment vulnerabilities. These
evaluations included " brainstorming" and the development of "what-if" scenarios
, along with recommended contingencies. An example included the recommendation
to rack the breaker open for RH-MOV-22.
An area for improvement was identified relative to the need to take more initiative
to develop and suggest (rather than just concur with) strategies in response to
situations where 50.54(x) may be invoked, and the development of written
strategies for handling these contingencies. As noted in Section b.1 above, the
implementation of 10 CFR 50.54(x) to perform actions contrary to EOPs and other
guidance was not adequately controlled. The TSC staff did not take an active role
in determining, directing or documenting mitigation strategies. In most cases, the
MCRO developed the mitigation strategies even when ample time existed for the
TSC to pre-plan evolutions such as controlling the rate of core and steam generator
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re-flooding following the restoration of electrical power. Typically, the MCRO would
inform the TSC of his planned action and if no objections were immediately voiced,
the action would be implemented. An example included the decision to steam the
No. 4 steam generator in an attempt to prevent a safety valve from lifting and thus
preserve the containment barrier. In this instance, the TSC called the MCRO several
times to question the actions which had already been taken under 10 CFR 50.54(x).
The strategy of deliberately venting a faulted steam generator to delay the onset of
major offsite releases as a trade-off to the preservation of vessel inventory did not
receive full review and concurrence within the TSC. The ADTS was not effective in i
resolving conflicting views within the TSC on the best mitigation strategy that both
preserved inventory and containment, which prompted a differing opinion regarding
the venting of the steam generator. l
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Overall, the TSC functioned adequately to support the SERO in the major actions ;
necessary to mitigate the accident and minimize the risk to plant workers and the
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public. Command and control in the TSC was not fully effective, due to the
problems related to complete diagnosis of RCS conditions, duplication of efforts in l
EAL reviews, the development of written strategies and (most significant) the failure i
to keep the AMT fully integrated in TSC functions. The TSC became too focused !
on the myriad of subscenario details and did not maintain a comprehensive )
overview of overall plant conditions and the TSC input to the overall SERO
response,
b.3 Ooerations Suocort Center (OSC)
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The OSC was activated and fully staffed within one hour of the Alert declaration. '
The MOSC fulfilled the responsibilities of this position as documented in Emergency
Plan Implementing Procedure (EPlP) 1.5-42, " Manager of Operational Support
Center" Section 6.1. The inspector obse;ved good coordination among the MTSC,
ADTS, and the MOSC. The OSC provided appropriate priorities for the emergency
repair teams (ERTs) and the priorities were appropriately changed as plant
conditions degraded.
The inspector noted that individuals fulfilling the OSC positions and their backups
had reported to the center prior to and during activation. Because of the immediate
response by the backup staff, no additional plant status briefings were necessary j
for the relief personnel. The congestion and noise levels were acceptable within the
OSC, however, in the post-drill debriefing, the licensee felt that the OSC )
Maintenance Assistant (OSCMA) should be on a head set for radio communications ;
so as not to impact the TSC functions. ;
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The ERTs wete dispatched in a timely manner. The four ERTs used during the l
exercise were dispatched within one hour of the activation of the OSC. Excellent l
briefings were provided by the Manager of Radiological Consequence Assessment
(MRCA) to the OSC ERTs on changing radiological conditions, estab!ishment of
radiation field criteria to terminate maintenance repair activities, and how often
personnel monitoring devices should be read. Radio communications between the l
OSCMA and the ERTs were generally reliable and, in cases where it became
inoperable, backup phone extensions were appropriately used. The OSC provided
appropriate control and tracking of ERTs and their changing work scope.
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l Inspector observations of one of the ERTs noted a good understanding of the tools
and equipment necessary for troubleshooting and repairing semi-vital power. A
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minor controller issue allowed simulation of acquiring the tools and equipment,
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necessary tools and drawings. Additionally, this simulation hampered the repair
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team's ability to diagnose the loss of semi-vital power problem because they didn't
l have the plant drawings. Minor equipment malfunctions occurred when one of the
personnel monitoring devices failed for an electrician. Additionally, not all radio
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communications with the OSC were followed with "this is a drill."
l The inspector noted that EPIP 1.5-42 required a facsimile of the emergency team
work assignment sheet to be sent to the control room. This did not occur, since the
ADTS was in constant communications with the SCR regarding the status of repair
teams and the ADTS approves the work assignments. This was discussed with the
licensee at the end of the exercise, with the licensee concluding that a procedural
l revision was necessary to reflect the current practices.
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b.4 Emeraency Ooerations Facility (EOF)
] The Alert was declared at 3:52 p.m. and the DSEO in the emergency operations
. center (EOC) assumed and transferred DSEO duties from the SCR at 4:33 p.m. The
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EOC positions were filled and the entire SERO was activated at the EOF at
4:44 p.m. The inspectors considered these to be timely responses as the licensee
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met its one hour activation commitment.
The inspectors observed that there were multiple individuals filling the manager
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positions in the EOC shortly after it was activated. For example, there were
a backups present for the DSEO, the technical information coordinator, and the
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manager of communications positions. There were also two backups for the j
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- manager of public information and there were three backups for the assistant ;
director of the EOF. All of these individuals collectively performed the necessary i
duties of the position they were backing up. However, the licensee's emergency l
- plan does not include backup personnel to implement the plan and, therefore, they
- should not have been present to assist the assigned SERO members during the
exercise. Because of the additional personnel and their contributions to the
exercise, it was difficult for the inspectors to determine if the licensee's emergency
plan could be implemented with the response organization stated in the plan.
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information flow within the EOC was good. Three-part communications were
regularly used during the exercise by the players. The DSEO promptly made
announcements to the EOF regarding changes in plant status and event
classification. The DSEO held manager briefings to disseminate information and the
status of the various response efforts. The DSEO and the backup DSEO kept each
other informed as they individually spoke with managers or responded to telephone
calls.
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Event classifications, declarations and notifications were accurate and timely for the
SAE and the GE. However, there were two discrepancies observed by the
inspectors. The first discrepancy occurred shortly after the SAE declaration while
the DSEO.s were reviewing the EAL barrier failure reference table and logic chart.
The SAE had been declared due to a potential loss of fuel clad and RCS barriers.
The backup DSEO improperly entered the logic chart at the point where a loss of
two barriers requires a GE declaration. He then incorrectly stated that if conditions
worsen such that a loss of the fuel clad and RCS barriers occurred, the criteria for a
GE would be met. The DSEO acknowledged this incorrect statement. The second
discrepancy occurred when a steam generator tube ruptured and the DSEO was
ready to implement the SM's recommendation to declare a GE due to the breaching
of the third barrier - containment. However, other managers immediately informed
him that not all of the criteria had been met for the GE declaration. The DSEO then
- reviewed the EAL table criteria and concurred with their assessment. The
inspectors considered these two potential misclassifications, in conjunction with the
SM's premature recommendation to declare a GE and his failure to classify the Alert
, properly, as a weakness in classifying events using the EAL tables.
The DSEOs also provided an overly conservative protective action recommendation
(PAR) to the State of Connecticut consisting of evacuating 10 miles,360 degrees.
At the time of the GE declaration (6:00 p.m.), the DSEOs were aware that core
uncovery was not projected to occur until about 7:35 p.m. and that a HPSI pump
was to be returned to service at about 6:30 p.m., which would restore core cooling.
The DSEOs should have challenged the PAR because of the restoration of core
cooling which would have precluded the need to evacuate the full 10 miles,360
degrees, which was based upon a " worst case" assumption.
Good teamwork among the various backups precluded several problems in the EOC
and resulted in accurate SAE and GE classifications and timely notifications to the
State. The discrepancies observed regarding the DSEO's EAL usage and the SM's
failure to classify the Alert properly were determined to be an exercise weakness.
The DSEO's failure to incorporate important plant system information resulted in an
overly conservative PAR. The backup managers in the EOC, though each
contributed to fulfilling the duties of the position, made it difficult to determina if the
licensee could implement the emergency plan with the staffing stated in the plan.
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The dose assessment area of the EOF was staffed in 50 minutes from the time of
the Alert classification notification.
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Upon arrival at the EOF, the Manager Radiological Dose Assessment (MRDA) was
quick to assigned priorities to the radiological dose assessment team and kept the
Assistant Director Emergency Operations Facility (ADEOF) staff updated on
changing radiological conditions. The Radiological Dose Engineer (RDE) performed
"what if" dose calculations using a computer-based Accident Dose Assessment
Model (ADAM) and the team participated in useful discussions about potential
radiological release pathways. Field teams were properly briefed, dispatched and
controlled by the Field Team Data Coordinator and status boards were continuously
updated. One coordination discrepancy was observed when three ADEOF
" backups" had reported to the EOF after the Alert declaration and the primary
ADEOF elected to utilize all three " backups" during the exercise. This created
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confusion in the dose assessment area, because the MRDA and the dose
assessment team were responding to multiple and sometimes conflicting requests
from the ADEOF staff. For example, one ADEOF " backup" asked the MRDA to
request a sample from the Post Accident Sampling System (PASS), while another
requested a PASS sample at the discretion of the MRDA. However, no PASS
sample was taken during the exercise. Also, the dose assessment team was asked
by the ADEOF staff to estimate the dose consequences in the EOF in case the
plume changed directions and impacted the EOF. The team could not calculate
doses because they did not have the building specifications for determining
shielding factors and ventilation information. Once the request had been made,
however, the ADEOF staff did not follow up for a reply.
The licensee did not follow the steps described in Procedure NUC EPOP 4428G, for
making a PAR decision. The MRDA is responsible for providing a PAR to the
ADEOF. However, while the MRDA was assessing the radiological and plant
conditions for making that decision, the ADEOF informed the MRDA, (12 minutes
prior to the GE), that he had already decided the PAR would be an evacuation of the
whole EPZ out to 10 miles. This resulted in the removal of the MRDA's expertise
and the licensee not following procedures. The MRDA diligently continued to make
attempts to receive information from the accident management team leaders
(AMTLs) regarding plant conditions before officially concurring with the ADEOF's
decision. The AMTLs stated that the electrical system for the operation of the
HPSI pumps would not be restored and plant conditions were worsening. However,
at that time, there was a communication breakdown in the TSC, and the AMTLs
were not told that the HPSI pumps were expected to be operational within a short
period of time. Not knowing this inforrnation at the time of the GE, the MRDA l
concurred with the ADEOF's PAR decision.
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The PAR was made within two minutes after the GE declaration, meeting the
15-minute requirement. However, the licensee based its PAR decision on dose
projections for a " worst case" scenario in which 100% of the noble gases were l
released within 15 minutes. The dose projections indicated an integrated whole !
body dose of 6510 rem at the site boundary and 100 rem at 10 miles. Due to this
very high dose projection and to some erroneous information received from the TSC
(that plant conditions were worsening), the licensee made a PAR to evacuate the
general public out to 10 miles, but did not initiate planning for protective actions for
the SERO.
The inspector discussed with the RDE that an 100% noble gas release in
15 minutes was an unrealistic assumption. The RDE stated that he knew the "what
if" assumptions were " overly conservative." The assumption of a total release in
15 minutes from a steam generator tube rupture, through a stuck open safety is ,
unrealistic due to the restricted flow through the safety valve itself. The RDE also l
performed dose projections using current plant conditions, and ADAM (a dose
projection computer code) predicted a whole body dose (cloud shine) of 3 rem at
the site boundary from a noble gas release. Based on this information, he felt it
was reasonable to evacuate out to 10 miles. This lower, more reasonable
projection was not utilized in formulating the PAR, however, nor was this projection
communicated to the State. No recommendations were provided for the onsite
personnel either, who, according to the licensee's dose projections, would receive
-
.
.
9
as much as 6510 rem. Even though the PAR was timely, it was based on a " worst
case" scenario resulting in very high dose projections. If these projections, which
were passed on to the decision-makers and the State, were believed by the
licensee, then the PAR should have extended past the 10 mile EPZ. No
recommendations were made relative to protective actions beyond the 10 mile EPZ.
This is considered an exercise weakness.
Using the NRC dose assessment computer model, " radiological assessment system
for consequence analysis (RASCAL)," in Region I, the inspector ran various "what
if" dose calculations based on plant conditions at the time of the GE declaration.
The results verified the projected doses calculated on ADAM of approximately 3
rem at the site boundary. The inspector concluded that based on the current plant
I
conditions, an evacuation out to a 5 mile radius would have been more reasonable;
however, evacuating out to a 10 mile radius would also have been reasonable. The
inspector cautioned the licensee about moving the general public unnecessarily and
that once a PAR had been provided and a protective action decision made, an
additional PAR can always be made to extend protective actions as additional plant
information is received. A protective action cannot be reduced, however, once it
has been announced, without causing considerable confusion among the members
of the affected public.
The licensee continuously communicated radiological conditions to the State via
telephone and facsimile. However, the facsimiles were often late and update
reports contained ambiguous information. For example, the information received by
the State indicated that "100% release" of core activity was projected, not 100%
of noble gases, as intended. Also, the State had initially received erroneous
information that the release pathway was filtered and through the plant stack, and
not a steam generator tube leak that was released directly to the environment
through a stuck open steam generator safety valve.
Overall, there was good coordination, teamwork and communication among the
dose assessment personnel and offsite teams were effectively managed. The
overstaffing of the ADEOF position created confusion and some dose assessment
tasks were assigned and not completed. However, there were problems noted with
the PAR in that unrealistic radiological release assumptions were made, and
procedures for PAR formation were not followed. Additionally, there were
miscommunications regarding radiological conditions to the State and inaction
relative to protective action beyond 10 miles based on overly conservative
projections used in the PAR.
b.5 Licensee Exercise Critiaue
The licensee's critique was very comprehensive, thorough, identified all of the major
concerns identified by the NRC inspection team and recognized the SERO's poor
performance. During the critique, the licensee committed to take timely and
appropriate corrective actions for the identified items, to participate in a
management meeting at the NRC regional office to discuss the corrective actions,
and to perform another drill / exercise on site to demonstrate the effectiveness of the
corrective actions prior to the restart of the Haddam Neck Plant.
.
.
10
c. Overall Exercise Conclusions
The facilities were staffed and activated in a prompt manner. Adequate direction
and control were observed at all of the facilities. The initial classification of the
simulated event was not recognized by the SCR SM who had to be prompted by the i
lead controller at that facility. The SAE and GE classifications were conect and
timely. However, missing the Alert classification and the discussions on the SAE
and GE declarations are considered an Exercise Weakness (eel 50-213/96-007-01).
Emergency response training, including EAL training, is provided to both the ;
Millstone and Haddam Neck Plant personnel by the Northeast Utilities Nuclear I
training Services Department. Past NRC inspections have identified a history of EAL j
classification problems for both plants. While corrective actions have been taken by
the licensee in cases where these problems were identified, those actions appear
not to have been effective over the long term. The following reports indicate this
trend: Combined Inspection Report 50-245/91-19, 50-336/91-23, and 50-423/91- l
19; Combined Inspection Report 50-245/92-07, 50-336/92-07, and 50-423/92-07;
'
Combined Inspection Report 50-245/94-20, 50-336/94-18 and 50-423/94-17
(escalated enforcement); 50-213/95-17. l
The PAR was given to the State of Connecticut within 15 minutes of the GE.
However, the basis for the PAR and the fact that there was not any consideration of l
protective actions beyond the 10 mile EPZ is considered an Exercise Weakness (EEs l
50-213/96-007-02).
The Northeast Utilities Corporate Emergency Operations Center (CEOC) had
previous problems during exercises with timely, correct and appropriate PARS as
indicated in the following reports: 50-213/91-10;50-213/92-06;50-213/93-02;
50-213/95-10. This problem apparently continued even though the CEOC staff was
moved into the SEROs in the EOFs.
SERO staff held many good discussions during the exercise within individual
facilities and among the facilities. However, the extra staffing in all key positions
hampered the ability of the NRC evaluation team to determine whether the
emergency plan and procedures could be implemented, as stated in the emergency
plan, by the key SERO members assigned to the exercise. Even though extra
staffing was present, they were not able to identify all of the problems and provide
corrective actions for mitigation of the simulated events presented during the
scenario. This is considered an inspector follow-up item (IFl 50-213/96-007-03).
The NRC evaluation team also noted that there were communication problems
within the SERO and between the SERO and the State of Connecticut. This is also
considered an inspector follow up item (IFl 50-213/96-007-04).
-. __ -_. _ ._. _ _ . __ __ ._ _ . _ . - _ _ - - . . _ . .__ ._
.
.
11
P8 Miscellaneous EP lasues
P8.1 In-Office Review of Licensee Procedure Chanaes
An in-office review of revisions to the emergency plan and its implementing !
procedures submitted by the licensee was completed. A list of the specific l
revisions reviewed are included in Attachment 1 to this report.
Based on your determination that the changes do not decrease the overall
effectiveness of your emergency plan and after limited review of the changes, no !
NRC approval is required, in accordance with 10 CFR 50.54(q). Implementation of
these changes will be subject to inspection to confirm that the changes have not
decreased the overall effectiveness of your emergency plan.
P8.2 inspector Review of Licensee's Adverse Condition Reoort for the May 23,1996,
Trainina Drill j
a. Inspection Scoce
The inspector reviewed the Licensee's Adverse Condition Report Number 96-0642,
on a May 23,1996 training drill,
b. Observation and Findinas
During the licensee's May 23,1996 training drill, the following eight weaknesses
were identified:
1. Some SERO personnel were unfamiliar with the EOF layout and
manager /f acility location.
2. Some SERO personnel were unfamiliar with their procedures.
.
3. Some persont.el were not aware of their SERO responsibilities, goals, and !
interfaces.
4. Communications of significant events, information and activities within, and
between facilities was weak.
5. Some SERO personnel did not aggressively carry out responsibilities.
6. Emergency repair teams were not deployed in a timely manner.
7. Continuous assessment of the EAL tables was not effectively maintained in
the TSC.
8. Classification of the SAE was late in transmission.
.-
I
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12 !
The licensee performed a root cause analysis to determine the cause of the ,
problems. Items identified by the licensee were as follows: 1) Dilution of the
'
SERO, i.e., too many personnel on the on-call roster; need to reduce to six. 2) Long
time between training and drill participation as player or controller.
Corrective actions were to conduct several facility drills to bring personnel back up l
to desired knowledge level for their positions. These training drills would include
lessons learned from previous drills, facility lay out changes, changes in the SERO 3
due to the incorporation of the corporate organization into the SERO, review of the {
procedures and a discussion on the requirements and responsibilities of the SERO.
c. Conclusions
The licensee conducted three technical and three radiological training drills during
June and July,1996. Based on the performance demonstrated during this graded
exercise, the licensee was successful in correcting some of the weaknesses, such
as the deployment of emergency repair teams and awareness of plant issues.
MANAGEMENT MEETINGS
X1 Exit Meeting l
The inspector presented the inspection results to members of licensee management, j
and verified the commitments presented during the critique at the conclusion of the ;
inspection on August 16,1996. The licensee acknowledged and agreed to the )
inspector's findings, Additionally the inspector restated the licensee's commitments
as indicated during the critique to 1) take timely and appropriate corrective action '
for the identified items,2) to participate in a management meeting at the NRC l
regional office to discuss the corrective actions, and 3) to perform another i
drill / exercise on site to demonstrate the effectiveness of the corrective actions prior
to the restart of the Haddam Neck Plant. !
.
5
13
PARTIAL LIST OF PERSONS CONTAC f ED
Licensee
J. LaPlatney, Unit Director, Connecticut Yankee
P. Stroup, Director, Northeast Utilities Company Nuclear Emergency Planning
Services
J. Deveau, Supervisor, Nuclear Emergency Planning Services
J. Hawxhurst, Senior Scientist, Emergency Planning Services
M. Quinn, Operational Standards
D. McCracken, Assistant Operations Manager
W. Hutchins, Senior Licensing Engineer
J. Sullivan, Manager, General Services, Connecticut Yankee
T. Cleary, Senior Licensing Engineer, Connecticut Yankee
J. Maher, Supervisor Training
R. Sachatello, Health Physics Manager
R. Brown, Staff Assistant, Connecticut Yankee
P. Rainha, Shift Manager, Connecticut Yankee Operations
LIST OF INSPECTION PROCEDURES USED
82301: Evaluation of Exercises for Power Reactors
82302: Review of Exercise Objectives and Scenarios for Power Reactors
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Ooened
50-213/96-007-01 eel Failure to properly classify emergency event
50-213/96-007-02 eel Failure to give correct and appropriate PARS to the State of
50-213/96-007-03 IFl Over staffing of the emergency response facilities
50-213/96-007-04 IFl Communication problems within the SERO and between the
SERO and the State of Connecticut
Closed
None
Discussed
50-21'J 95-10-01 URI MRCA failed to get appropriate approvals for PAR
.
.
14
LIST OF ACRONYMS USED
ADAM Accident Dose Assessment Model
ADEOF Assistant Director Emergency Operations Facility
ADTS Assistant Director Technical Support
AMRDA Assistant Manager Radiological Assessment
AMT Accident Management Team
AMTL Accident Management Team Leader
CEOC Corporate Emergency Operations Center
DSEO Director of Site Emergency Operations
EAL Emergency Action Level
ECL Emergency Classification Level
EOC Emergency Operations Center
EOF Emergency Operations Facility
EOP Emergency Operating Procedure
EPZ Emergency Planning Zone
ERTs Emergency Repair Teams
GE General Emergency
HPSI High Pressure Safety injection
MCRO Manager Control Room Operations
MOSC Manager Operational Support Center
MRCA Manager of Radiological Consequence Assessment
MRDA Manager Radiological Dose Assessment
MTSC Manager Technical Support Center
NRC Nuclear Regulatory Commission
OFIS Offsite Facility Information System
OSC Operations Support Center
OSCMA Operations Support Center Maintenance Assistant
PAR Protective Action Recommendation
PASS Post-Accident Sampling System
RASCAL Radiological Assessment System for Consequence Analysis
RDE Radiological Dose Engineer
SAE Site Area Emergency
SCR Simulator Control Room
SERO Site Emergency Response Organization
SM Shift Manager l
SPDS Safety Parameter Display System
UFSAR Updated Final Safety Analysis Report
i
!
!
l
. ._ - _ . . _ _ _ _ - _ _ _ . . ___ _ _. . . - _ . . .__
.
1
.
.i
Attachment 1
List of the Emergency Plan and implementing Procedures Reviewed
Procedure Procedure title Pevision(s)/ Change (s)
Number Reviewed
_
Haddam Neck Emergency Plan 33
EP!P 1,6-1 A Non-Emergency Event Assessment 6
!
EPIP 1.5-28 Manager of Technical Support Center 17
EFIP 1.5-37 Assistant Manager of Radiological Dose 15
Assessment initial Response
'
EPIP 1.5-48 Control Room Data Coordinator 12
'
.
EPIP 1.5-51 Technical Information Coordinator 4
EPIP 1.5-39 Post Accident Sampling of Reactor 17
Coolant
EPIP 1.5-40 Post Accident Sampling of 15
Containment Atmosphere
NUC EPOP Assistant Director Technical Support O
4411A
NUC EPOP Assistant Director Emergency 0
4411B Operations Facility
NUC EPOP Thermal Hydraulic Evaluation Methods O
4422A
NUC EPOP Radiological Dose Assessment Team O
4428A
NUC EPOP Meteorological Team O
4428D
NUC EPOP Post Accident Release Rates O
4428E
NUC EPOP Refined Dose Assessment O
4428F
NUC EPOP Protective Action Recommendations O
4428G
NUC EPOP Radionuclide Deposition and Dose O
4428H Calculation
NUC EPOP Direction of POSL Field Team Sampling O
44281
. .. . .- , - . - . - - . . . _ -
.
.
Attachment 1 -2-
__
Procedure Procedure title Revision (s)/ Change (s) t
Number Reviewed
'
NUC EPOP Health Physics Network O
4428J Communict s
NUC EPOP Manager of Public Information O
4455
.
NUC EPOP Nuclear News Manager O
4455A
i
NUC EPOP Executive Spokesperson O
445EB
NUC EPOP Technical Assistant O 1
4465C
NUC EPOP News Releases O
_
4455D
NUC EPOP News Conferences O
4465E
NUC E?OP Rumor and inquiry Control O
4455F
NUC EPOP IRG Representative O
4460A
NUC EPOP External Resources Coordinator O
4475A
NUC EPOP Implementation of Recovery Operations O
4490