IR 05000266/1985012

Insp Repts 50-266/85-12 & 50-301/85-12 on 850909-11.No Deficiencies,Noncompliance or Deviation Noted.Major Areas Inspected:Emergency Preparedness Exercise.One Weakness Noted Re Notification of Unusual Event

ML20133E794
Person / Time
Site:	Point Beach
Issue date:	10/03/1985
From:	Brown G, Phillips M, Snell W, Williamsen N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20133E777	List: IR 05000266/1985012 ML20133E772
References
50-266-85-12, 50-301-85-12, NUDOCS 8510100018
Download: ML20133E794 (13)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

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Reports No. 50-266/85012(DRSS); 50-301/85012(DRSS)

Docket Nos. 50-266; 50-301 Licenses No. DPR-24; DPR-27 Licensee: Wisconsin Electric Power Company 231 West Michigan Milwaukee, WI 53201 Facility Name: Point Beach Nuclear Power Plant Inspection At: Point Beach Site, Two Creeks, WI Inspection Conducted: September 9-11, 1985 Inspectors:

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. Snell Team Leader l0!3 Date

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!N. Williamsen / Oh!d'[

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'M G. Brown /8 Date d #/

Approved By: M. Phillips, Chi

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8I Emergency Preparedness Section Date Inspection Summary Inspection on September 9-11,1985 (Reports No. 50-266/85012(DRSS);

No. 50-301/85012(DAT5))

Areas _. Inspected: Routine, announced inspection of the Point Beach Nuclear Plant emergency preparedness exercise involving observations by seven NRC representatives of key functions and locations during the exercise. The inspection involved 168 inspector-hours onsite by three NRC inspectors and four consultant .Re sul ts : No items of noncompitance, deficiencies, or deviations were identi-fled; however, one weakness was identified and is listed in the Appendi ' '

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t DETAILS 1. Persons Contacted NRC Observers and Areas Observed J. Will, Control Room F. Victor, Technical Support Center (TSC)

G. Brown, TSC, Operational Support Center (OSC)

T. Essig, OSC, Inplant Teams N. Williamsen, Emergency Operations Facility (EOF)

J. Davis, EOF, Offsite Teams W. Snell, Control Room, TSC, EOF D. Hague, NRC Resident Inspector Wisconsin Electric Power Company J. Zach, Plant Manager J. Knorr, Regulatory Engineer D. Stevens, Emergency Planning Coordinator J. Reisenbuechler, Superintendent, Engineering Quality and Regulatory Services R. Link, Assistant Manager, System Planning T. Koehler, General Superintendent K. Draska. Duty Shift Superintendent T. Garot, Duty Shift Superintendent F. Flentje, Administration Specialist, Engineering Quality and Regulatory Services Personnel listed above attended the exit interview on September 11, 198 . General An exercise of the licensee's Point Beach Nuclear Plant Emergency Plan was conducted at the Point Beach plant on September 10, 1985, testing the response of the licensee to a hypothetical accident scenario resulting in a major release of radioactive effluent. Attachment I describes the Scope and Objectives of the exercise and Attachment 2 describes the exercise scenario. This was a utility-only exercis . General Observations Procedures This exercise was conducted in accordance with 10 CFR Part 50, Appendix E requirements using the Point Beach Emergency Plan and Emergency Plan Implementing Procedure _ _ _ _ _ _ _ _ _ _ _ _

. Coordination The licensee's response was coordinated, orderly, and generally timely. If the events had been real, the actions taken by the licensee would have been sufficient to permit the State and local authorities to take appropriate actions, Observers Licensee observers monitored and critiqued this exercise along with seven NRC observer Critique A critique was held with the licensee and NRC representatives on September 11, 1985, the day after the exercise. The NRC discussed the observed strengths and weaknesses during the exit intervie . Specific Observations Control Room Control Room personnel were knowledgeable and worked well togethe They were tenacious in their pursuit of problem solutions and coordinated thet: efforts well with the Technical Support Center (TSC), exchanging ideas and recommendations on a timely basi They were consistent in their use of procedures, specifications, and schematic plan The initial offsite notification of the Unusual Event was not timely and the message, as transmitted, could have caused serious reper-cussions because of the licensee's failure to identify the emergency report as a drill. The exercise controller subsequently interjected and required the individual to identify the report as a dril CFR 50, Appendix E, Part D, Section 3 requires that a licensee have the capat111ty to notify responsible State and local govern-mental agencies within 15 minutes after declaring an emergency. The licensee s notification required 25 minutes from the time of the declaration to complete. This is an exercise weakness and will be tracked as Open Item Nos. 266/85012-01 and 301/85012-0 It was noted that the scenario provided for damage to fuel cladding, reactor coolant pump seal failure, and breach of containment. These events constituted a loss of all three fission product barrier In accordance with NUREG-0654 and NRC IE Notice 83-28, there should have been an Emergency Action Level (EAL) which directed the declara-tion of a General Emergency uoon the loss of two fission product barriers (and the potential loss of the third). The licen we's EALs contain no such provision. Had such provisions been available, the General Emergency would have been declared about two hours earlie The licensee must develop EALs to address the loss of fission product

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O barriers as specified in NUREG-0654 and NRC IE Notice 83-28. This weakness in the EALs was identified during the July 1984 routine inspection (266/84-13; 301/84-11) and again addressed in the May 1985 routine inspection (266/85005; 301/85005), and is already being tracked as part of Open Item 266/84-13-04; 301/84-11-0 b. Technical Support Center (TSC)

Offsite notification of the Alert was completed well within the required 15 minutes. All personnel were accounted for within 20 minutes of the direction for assembly / accountabilit TSC staff received frequent, thorough briefings which were well organized and effective. They were also kept informed of events by a summary of details maintained on the blackboard in the TS The individual responsible for making offsite notifications was not familiar with the several phones he was required to use, in particular, he did not know which phone was the National Warning System (NAWAS) telephone ringdown lin Acquisition of meteorological data during the first several hours after activation of the TSC was slow. For example, at 0815 hours0.00943 days <br />0.226 hours <br />0.00135 weeks <br />3.101075e-4 months <br /> the TSC Manager used 0733 hours0.00848 days <br />0.204 hours <br />0.00121 weeks <br />2.789065e-4 months <br /> meteorological data to fill out the Status Update form. Considering winds of 80 mph and severe weather conditions that had been occurring, meteorological data should have been updated more frequentl The Radiation and Environmental Status Board was not always updated in a timely manner. It was over an hour before the 0733 hours0.00848 days <br />0.204 hours <br />0.00121 weeks <br />2.789065e-4 months <br /> meteorological conditions were update The TSC radio was left unmanned several time On one occasion the ESF made a telephone call to the TSC to verify that the radio was operable because they were unable to establish communication Radiological control for access to the TSC was not established in a timely manner. For instance, the start of the release was established at 0900, but radiological control was not established until over two hours late c. Operational Support Center (OSC)

The OSC was activated in a timely manner and made good utilization of procedures throughout the exercise. Habitability monitoring of the TSC/OSC complex was timely and thorough. Briefings of the OSC staff were frequent and informative. All instruments were noted to -

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have current calibration stickers and were given operability and source checks prior to use. A continuous air monitor and a portable area radiation monitor were set up within approximately 15 ninutes after the OSC was activated and operated continuously during the exercis F

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Iodine and particulate air sampling could have been timed to better support certain plant entries. For example, between 1050 and 1130 hours0.0131 days <br />0.314 hours <br />0.00187 weeks <br />4.29965e-4 months <br />, Maintenance Team No. I was at the facade for the purpose of visually examining the containment exterior to determine the source of containment leakage. At this time major releases of radioiodine were occurring from the containment into the area where the team was working, yet no air samples ware collected in direct support of this activity. Had air samples been taken and results calculated, it would have been discovered that the respiratory protective equipment, which the workers were simulated to have been wearing, was inadequate to protect the Employee radiation exposure history data were not conveniently available in the OS d. Emergency Operations Facility (E0F)

The EOF was properly set up and activated within about one hour of the declaration of Site Area Emergency. Access control and account-ability were maintained throughout the exercise. The ventilation system was properly switched to " Emergency," per EpIP Habitability of the EOF was ensured by three types of monitoring:

permanently installed detectors with readout in the EOF, continuous air sampling, and pocket dosimeters for all personnel. Additionally, the staff was periodically reminded to read their dosimeters and report any significant readings. Dose projections were made and updated frequently, using forecasts of meteorological data and forecasts of plant conditions. Protective Action Recommendations were based on the forecasts above and also utilized evacuation time estimate Notifications to the offsite authorities were not timel Specifi-cally, a General Emergency was identified at 1137 hours0.0132 days <br />0.316 hours <br />0.00188 weeks <br />4.326285e-4 months <br /> and declared at 1145 hours0.0133 days <br />0.318 hours <br />0.00189 weeks <br />4.356725e-4 months <br />; however, notifications to the State and the two counties were not concluded until 1205 hours0.0139 days <br />0.335 hours <br />0.00199 weeks <br />4.585025e-4 months <br />. This was in excess of the required 15 minute time limit. Part of the reason for the delay was that the ESM delayed delegating the remaining notifications until he finished making the first call himself. 10 CFR 50, Appendix E, Section IV.D.3, requires that a licensee have the capability to notify responsible state and local agencies within 15 minutes after declaring an emergency. The licensee took 20 minutes to make the required call This failure in timely notification is an exercise weakness and will be tracked as Open Item Nos. 266/85012-01 and 301/85012-0 Radiological monitoring of the incoming personnel was not consistent,

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In at least one case an incoming team walked past the monitoring station, without frisking, to the door of the Site Boundary Control Center before being told to return to the monitoring station for friskin _ _ ____ _ _ ____________ _ __

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Communications were sometimes inadequate between the E0F and the TSC and within the EOF proper. For example, the ESM was not aware that core spray had been ordered by the TSC and was being used until two hours after the fac Further, the ESM was never advised as to the source of the containment leak. An example of a lack of communica-tions within the EOF occurred during de-escalation. At that time two communicators were notifying the offsite authorities that there were no remaining protective actions recommended, while the Rtd Con / Waste Director was requesting more samples from the field in order to decide if and when the populace could return to their home The overall impression of the EOF was that they failed to perform as a cohesive group with a common objectiv The players lacked direction and motivation. For example, none of the staff began to look into the EALs until they were directed by the EM to do s Similarly, lacking directions to keep the status boards updated, the players allowed them to lag behind exercise dat Site _ Boundary Control Center (SBCC)/Offsite Teams The onsite Health Physics Director (HPD) gave good briefings to each team apprising them of plant conditions and carefully explaining their missions. Prior to being dispatched, the team members properly inventoried kits and checked radios for operabilit Radio communica-tions were adequate. The teams monitored the plume, properly taking and labelling sample The guard outside the Site Boundary Control Center was not wearing a -

self-reading dosimeter although all other participants wore one. He apparently had been overlooked when the dosimetert were issue S. Exercise Scenario and Control At the onset of the exercise, because of the scenario, the TSC/OSC was without light Personnel arriving to staff these areas had to grope their way down dark stairways, thus creating a potentially hazardous situation. Battery powered lights should be provided at the stairwells for use in the event of a real loss of power situatio The scenario data set did not contain window open and window closed measure-ments for use by field teams. Team members frequently asked for the data but were told that only window closed (gamma) data was availabl Radiation levels associated with samples should havn been available. Team members also asked for this information and were provided either no infor-mation or a guess by the controlle There was no specific sample form for gas samples. Even though the samples from the field monitoring teams were properly labeled, there was some confusion because of the lack of a form with which to submit i . _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ .

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. Licensee Action on Previously Identified Violation (Closed) Open Item No. 266/84-13-02; 301/84-11-02: Shift Superintendents (SS), who have the initial responsibility and authority of the Emergency Support Manager to make offsite protective action measures, were incapable of determ bing when and what type of protective measures should be considered outside the site boundary to protect public health and safet This was a repeat violt. tion from the July 23-27, 1984 routine inspection (Reports No. 50-266/84-13; 50-301/84-11) and May 6-9, 1985 routine inspection (Reports No. 50-266/85005; 50-301/85005).

Within two weeks of being advised of the repeat violation at the inspection exit meeting on May 9, 1985, the licensee had completed revising their Emergency Plan Implementing Procedure (EPIP) 1.1., " Plant Operations Manager Initial Response." Organizational inefficiency of the EPIPs had been identified as the major cause of the SS's inability to make proper protective action recommendation The EPIP 1.1 revision was to address this deficiency. The first revision was implemented May 24, 1985 and all SSs were trained in its use within three weeks of the exit meetin Records indicate that a total of 38 SSs were trained between May 24, 1985 and May 30, 1985. Additionally, during the training sessions, as the SSs were using the EPIP, areas were identified which still seemed confusing or inefficient to the SSs, resulting in the EPIP again being revised and the SSs being retrained in the revised EPIP. Lesson Plan LORP 85-4.3, "POM Initial Response Procedure /EPIP Revisions," was reviewed by the inspector and found to be adequate. Subsequently, the EPIP was revised twice since its May 24, 1985 implementation. The current revision was implemented September 3, 1985. Records indicated that a quality assurance evaluation was conducted by the licensee on September 9, 1985 with the conclusion that all participants taking the test performed adequatel Walkthroughs were conducted with two Duty SSs to determine their ability to utilize EPIP 1.1, and in particular make proper protective action recommendation Scenarios were used that included both a release in progress and no release with high activity levels in containment, as well as Site Emergency and General Emergency conditions. In all cases the S$s were able to quickly and appropriately classify the event and make proper protective action recommendations. This item is considered close . Licensee Action on Previously_!dentified Emergency Preparedness Weaknesses (Closed) Open Item No. 266/84-13-05; 301/84-11-05: A review was made of the EPIPs to examine actions taken to correct weaknesses noted during the July 1984 and May 1985 inspection (Reports No. 266/84-10; 301/84-11 and 266/85005; 301/85005). The revisions to the procedures were determined to be adequate. Observations of the licensee's performance during the September 1985 exerciso demonstrated an accept-able use of the procedures. This item is close _ _ - - _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ - - _ _ _ - _ _ _ _ _ - _ - - _ _ _ _ _ _ _ _ _ _ _ - - _ _ - _ _ _ _ - - -

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. (Closed)OpenItemNo. 266/84-16-01; 301/84-14-01: Protective action recommendations were adequately discussed during the exercise, with consideration given to projected plant conditions, evacuation time estimates, and meteorological conditions per EPIP 1.5, " Protective Action Evaluation", dated May 24, 1985. This item is closed, (Closed) Open Item No. 266/84-16-04; 301/84-14-04: Access control and personnel accountability were maintained at the EOF during the exercise by security personnel per EPIP 8.1, " Personnel Assembly and Accountability", dated December 21, 1984. This item is close . Exit Interview The inspectors held an exit interview the day after the exercise on September 11, 1985, with the representatives denoted in Section The NRC Team Leader discussed the scope and findings of the inspectio The licensee was also asked if any of the information discussed during the exit was proprietary. The Itcensee responded that none of the information was proprietar Attachments:

1. Point Beach Exercise Scope and Objectives 2. Point Beach Exercise Scenario Outline i

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2.0 OBJECTIVES * Demonstrate ability to mobilize staff and activate facilities promptl . Wisconsin Electric will mobilize staff and activate all of its emergency response facilities (ERF), technical support

, center (TLJ), operations support center (OSC), and emergency operations facility (EOF). Field survey teams will also be mobilize . A joint public information center (JPIC) will be established at the Two Rivers Community House in Two Rivers, Wisconsin with Wisconsin Electric represente .2 Demonstrate the ability to make decisions and to coordinate' emergency activitie Decision-making will be demonstrated at the utility response facili-ties (T5C, OSC, EOF, JPIC, and control room). Coordination of emergency activities will be demonstrated between the utility ERF' ' Demonstrate the ad*quacy of facilities and displays to support emergency operation The capability of facilities to support emergency operations will be demonstrated at all locations where those facilities are fully acti-vate Haps, displays, and status boards will be demonstrated and used at all fully activated ERT's as appropriat .4 Demonstrate the ability to communicate with all appropriate locations, organizations and field personne FBNF will use various communication systems. These systems could include telephone, radio and microwave. Transfer of information will be accomplished by means of voice or hardcopy as appropriate to communicate with all location Field personnel will be contacted by radi .5 Den.onstrate the ability to mabilize and deploy field monitoring teams in a timely fashio Mobilization and deployrant of field tesns is a State and utility r+5ponsibility. Utility field survey tesms will he mobilized and deployed.

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.. Demonstrate appropriate equipment and procedures for determining *

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ambient radiation level This is a State and utility responsibilit FSNP personnel will deploy two survey teams and or.e shuttle team to demonstrate this objectiv , Demonstrate the appropriate equipment and procedures for measurement of airborne radiciodine in concentrations as low as 10 7 pCi/cc in the presence of noble gase .8 Demonstrate the appropriate equipment and procedures for collection, transport and analysis of samples of soil, vegetation, water and mil This objective is a State and utility responsibilit Some of these samples will be collected, transported and analyzed by FENF personne .9 Demonstrate the ability to project dosage to the public via plume exposure, based on plant and field data and to determine appropriate protective measures, based on protective action guldes (FAG's), a ail-able shelter, evacuation time estimates and all other appropriate factor This will be demonstrated by PENF personnel at the TSC and/or EOF.

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2.10 Demonstrate the ability to continuously monitor and control emergency worker exposur Monitoring and exposure control for FBNF emergency workers will be carried out in accordance with procedures under direction of FBNF health physics personne .11 Demonstrate the ability to make the decision, based on predetermined criteria, whether to issue KI to FBNF emergency worker The decision to make KI available to emergency workers and transients will be made by the Health Physics Director or the Ser.ior Health Physics Supervisor on site based on evaluation of the radiolodine content of the simulated radioactive plum .12 Demonstrate the ability to supply and administer KI, once the decisto has been made to do s If the decision te rec u end the t.se of AI :s m de besed on the radiological conditions generated by the plant r.cer,ario as stated in objective 2.12 above, K! distribution will te Simu;ate r

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2.13 Demonstrate the ability to brief the media in a clear, accurate and timely manne .1 The JPIC will be located at the Two Rivers Comnunity House, Two Rivers, Wisconsin. All media briefings will be held at the JPI .1 Public information activities will be conducted under the provisions of the Wisconsin Electric Crisis Communications Plan. Wisconsin Electric will provide the technical and clerical support for JPIC operatio .14 Demonstrate the ability to provide advance coordination of information release News releases will be made from the JFIC by utility PIO's. 'Informa-tion content will be developed in coordination with the PBNP EOF. Once operational, all news releases should be made from the JPI Earlier news releases, if made at the local level, will be coordinated with the State DEG and Wisconsin Electric Communications Departmen Coordiration with State and county PIO's will be simulate .15 Demonstrate the ability to establish and operate a rumor control progra Wisconsin Electric will designate telephone lines in the JPIC as rumor control lines and disseminate these numbers (under the provisions of the Crisis communications Plan) for that purpos .16 Demonstrate ability to estimate total population exposur Wisconsin Electric will demonstrate this objectiv .17 Deinonstrate ability to determine and implement appropriate measures for controlled recovery and reentry, FENP will designate a recovery organization for the purpose of planning a recovery of the facility under the provisions of EPIP Section 12.0, " Reentry & Recovery Planning.*

2.18 Demonstrate the ability to evacuate plant persornel to designated assembly areas and account for all persont.e An evacuation will be or dered durir.g the simulated emergency and the accountability procedures will be implamented to demonstrate this objectiv W~

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3.0 SIMULATED EVENTS INITIATING SCENARIO CLASSIFICATIONS Severe weather warnings are issued for an area 40 miles on each side of a line between Wisconsin Kapids and Manitowoc Two 345 KV lines (111 & 121) are knocked down by a possible tornado east of West Bend. Only one 345 KV line (151) remains availabl ' Wind speeds increase to 60-70 mp The remaining 345 KV line (151)

is breached, resulting in a loss of all offsite A (If >15 minutes, an UNUSUAL EVENT Category 8.) A diesel generator (4D) starts and picks up loa . 5= Trimary coolant analysis indicates activity greater than 350 pCi/cc dose equivalent I-131. (ALERT Category 5) Wind speeds at site exceed 90 mp ! If attempts are made to start the gas turbine (SG), it trips on high vibratio .8 High winds tear siding from Unit 1 facad Small flanged access pipe on Unit I contairtment (south vall) is sheared of During the last outage, the inside pipe flange was not replace . Acknowledgement of damage to the access pipe vill be prevented by exercise controller . Fossible SITE EMERGENCY Category 1 .9 Above ground fuel oil storage tank (F05T) is damaged by vind-driven missiles. Initiates an oil leak of approximately 280 gp .10 Wind speeds decrease to near 0 mp .11 Seal failure begins on reactor coolant pump (IP1A) due to extended loss of component coolant water. Leak is greater than 5 gp .12 Contairaent monitor (IRE-102) alarms due to primary coolant leak through RCP sea .13 Seal table monitor (!HE-107) alarms due to primary coolant lea .14 Reactor coolant pump (IP1A) seals fai Frimary coolant leak iricreases to 20 gp *

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3.15 Reactor coolant pump (1PIB) seals fai .16 Fuel oil storage tank (FCST) low level alarm due to damage caused by high wind .17 Unit I facade monitor (1RE-222) alarms due to release through damaged access pip '

3.16 Friskers at south gate alarm due to release through damaged -

access pip .19 Steam line monitor (1RE-232) alarms due to release to facad .20 offsite thyroid dose rate projections exceed 0.25 R/hr at site boundary. (Possible SITE EMERGENCY Category 12)

3.2 Plant evacuation possibl .2 Possible protective action recommendation (None required)

3.21 The gas turbine (SG) becomes availabl .22 Reactor coolant pump seal failure leak reaches 700 gp .23 Unit 1 facade monitor (1RE-211B) fails low due to high background resulting from contairiment releas .24 Dose rate at the site boundary exceeds 1 R/hr whole body and/or 5 R/hr thyroid. GENERAL EMERGENCY Category 1 .2 Protective action recomnendations are require .25 Offsite AC restored via two 345 KV lines (151 and 111).

3.26 JPIC news conference discusses accident and reentry procedure .27 Exercise is terminated by main exercise controller.

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