ML20133G536
| ML20133G536 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/07/1985 |
| From: | Kers L, Marks M, Patterson J, Phillips M, Williamsen N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20133G528 | List: |
| References | |
| 50-255-85-16, NUDOCS 8510160018 | |
| Download: ML20133G536 (29) | |
See also: IR 05000255/1985016
Text
_-
___.
. . -
-
.
U.S. NUCLEAR REGULATORY COMMISS1vN
REGION III
!
i
Report No. 50-255/85016(DRSS)
'
Docket No. 50-255
License No. DPR-20
Licensee:
Consumers Power Company
212 West Michigan Avenue
Jackson, MI 49201
Facility Name:
Palisades Nuclear Generating Plant
Inspection At:
Palisades Site, Covert, Michigan
Inspection Conducted:
Au ust 19-22, and September 20, 1985
Inspectors:
J. Patterso
M
I
Team Leader
Date
/Of7/f5
'
JLdk
"%
N.
11iamsen
Date
l0 9f'ff
i
Date
Approved By:
ps,' Chief
/0[7//f
Emergency Preparedr.ess Section
Date
!
Inspection Summary
i
Inspection on August 19-22, and September 20, 1985 (Report No. 50-255/85016(DRSS))
Areas Inspected:
Routine, announced, inspection of the Palisades Nuclear
Generating Plant emergency preparedness exercise involving observations by
eight NRC representatives of key functions and locations during the exercise.
The inspection involved 185 inspector-hours onsite by four NRC inspectors and
four consultants.
!
Results:
No violations of NRC requirements, deficiencies, or deviations were
i
identified; however, six weaknesses were identified which are summarized in
!
the Appendix. Most of these weaknesses and the licensee's proposed corrective
actions were discussed at the September 20th meeting.
851016001885gj55
ADOCK O
pg
G
-. , .- . - . _ , _ , .
_ - ,. . - - ____ - .,,- - _._ _ - . -
. - .
_ - . - . . . - . _ - - . - - . . . - . . - , _ .
.
DETAILS
1.
Persons Contacted
a.
Exercise
NRC Observers and Areas Observed
F. Victor, Control Room
G. Arthur, Technical Support Center (TSC)
N. Williamsen, Operational Support Center (OSC) and Post Accident
Sample Monitoring (PASM)
J. Martin, TSC and Emergency Operations Facility (E0F)
L. Kers, E0F
M. Marks, E0F
H. Larson, Offsite Radiological Monitoring Teams
J. Patterson, TSC, OSC and EOF
E. Swanson, Control Room and TSC
Consumers Power Company Personnel
!
J. Firlit, General Manager, Palisades Plant
- D. VanderWalle, Director, Nuclear Licensing-Corporate
P. Loomis, Emergency Planning Administrator-Corporate
D. Fugere, Emergency Planner-Corporate
G. Van Hoof, Superintendent, Nuclear Fuels Department-Corporate
A. Katarsky, Senior Nuclear Planner, Chief Exercise
Controller-Corporate
J. Fontaine, Supervisor, Nuclear Operations Training Department
J. Lewis, Technical Director
R. Rice, Operations Manager
J. Brunet, Emergency Planning Coordinator-Palisades
R. Marusich, Staff Engineer
G. Slade, Director, Quality Assurance-Corporate
C. Axtell, Health Physics Superintendent
M. Hobe, Emergency Planning Trainer
J. Werner, Emergency Planning Coordinator, Big Rock Point Plant
P. Slaughter, General Emergency Planner-Corporate
T. Hollowell, Staff Engineer
K. Haas, Reactor Engineering Superintendent
R. Orosz, Engineering and Maintenance Manager
L. Kenaga, Staff Health Physicist
R. Christie, General Engineer
H. Esch, Administration Superintendent
J. Bouwens, Senior Engineer
R. Fenech, Technical Engineer
B. John, Emergency Planning Trainer
G. Butera, Shift Technical Adviser-Consultant
T. Chartrand, Senior Chemistry Technician
l
- Cenotes those not attending the exercise exit meeting on August 21, 1985.
2
-
-
.
b.
Management Meeting at Region III on September 20, 1985
Consumers Power Company Personnel
J. Firlit, General Manager, Palisades Plant
P. Loomis, Emergency Planning Adminstrator-Corporate
T. Bordine, Staff Engineer-Plant Licensing-Corporate
L. Kenaga, Staff Health Physicist-Palisades
NRC Personnel
J. Hind, Director, Division of Radiation Safety and Safeguards (DRSS)
W. Shafer, Chief, Emergency Preparedness and Radiological
Protection Branch, (EP&RPB), DRSS
M. Phillips, Chief, Emergency Preparedness Section, EP&RPB, DRSS
L. Cohen, Senior Health Physicist, EPS
-Headquarters
J. Patterson, Emergency Preparedness Analyst, EPS
L. Kers, Emergency Response Coordinator
M. Smith, Emergency Preparedness Specialist
2.
Licensee Actions on Previously-Identified Items
(0 pen) Open Item No. 255/84-18-01:
Additional drills and training for
the Post Accident Sample Monitoring (PASM) teams, with emphasis on initial
response functions, presampling requirements, and surveying of sampling
equipment was needed.
Performance of the PASM Team in this 1985 exercise
showed some improvements in these areas, but not enough to warrant closing
this item.
Specific information is provided in Section 5.d.
(Closed) Open Item No. 255/84-18-02:
The use of Teletectors for plume
monitoring should be discontinued.
A more suitable radiation monitoring
device which could measure beta gamma as well as gamma radiation was used.
This new radiation measuring device had been installed in the offsite
monitoring emergency kits.
This item is considered closed.
(Closed) Open Item No. 255/84-18-03:
EI-9 should be revised to include
guidance on radiation surveying for exposure rates for teams passing
through the plume, and Attachment 1 should be more specific in identifying
instruments and other items.
A review of procedural guidance, including
guidance for offsite monitoring teams while passing through the plume, and
specific identification of radiation monitoring instruments and other
items needed by these teams, concluded that the new EI-9, Revision 3 dated
January 29, 1985 was satisfactory.
In addition, the team appeared to
follow this revised procedure, particularly in plume tracking and
identifying the centerline of the plume.
This item is considered closed.
(Closed) Open Item No. 255/85016-08:
Activation of Emergency Plan
on May 23, 1985.
Based on a review of logs, the inspector concluded that
the event was correctly classified.
Also, the review of licensee
documentation confirmed that notifications to State and local governments
were made within the required time.
This item is considered closed.
3
__ __ -
_
--
.
__ _ . _
_
_ _ _
._ _
_
-
-
.
(Closed) Open Item No. 255/85016-09:
Activation of the Emergency Plan
1
on June 21, 1985. The inspector evaluated the emergency conditions
and related EAL for classification as an NUE and found them correct.
.
Also, a review of the chronology of events determined that the NRC, State,
and Van Buren county were notified in the required time.
This item is
considered closed.
j
(Closed) Open Item No. 255/85016-10:
Activation of the Emergency Plan on
!
June 22, 1985 when an oil leak was discovered on one of the Diesel Generators
during a surveillance test. Technical Specifications 3.7.1 was exceeded
since the diesel generator had an inoperable safety feature component.
The Shift Engineer and the Duty and Call Superintendent decided to
,
classify the event as an NUE.
The EAL referred to, should have been the
i
.
one on page 19 of 32 of the EAL table; however, the SE used another
)
reference.
The inspector concluded that the event was conservatively
j
classified.
Necessary notifications were all made in a timely manner.
l
This item is considered closed.
3.
General
An exercise of the Palisades Plant Site Emergency Plan and Emergency
Implementing Procedures (EIPs) was conducted on August 20, 1985.
The
}
exercise tested the response of the licensee to a hypothetical accident
scenario, resulting in a major release of radioactive material to the
environment. Attachment 1 describes the scenario.
This exercise was a
full participation exercise for Van Buren and Allegan counties, and a
partial participation exercise for Berrien County and the State of
4.
General Observations
"
a.
Procedures
This exercise was conducted in accordance with 10 CFR Part 50,
!
Appendix E requirements using the Palisades Nuclear Generating
Plant Emergency Plan and associated implementing procedures.
- b.
Coordination
!
The licensee's response was generally coordinated, orderly, and
,
i
timely.
If these events had been real, actions taken by the
licensee would have been sufficient to permit State and local
authorities to take appropriate actions.
5
c.
Observers
f
Licensee observers monitored and critiqued this exercise, as did
eight NRC observers and observers from the Federal Emergency
.
Management Agency (FEMA).
FEMA observations on the responses of
!
State and local authorities will be provided in a separate report.
I,
!
4
i
_ _ _ _ _ . .
,
.
--
-_-
-
, . -
- - _ , - - - - . -
. , . _ - .
.
. . - -
.
-
d.
Critique
The licensee held a critique at the Palisades Plant on August 21, 1985.
The NRC critique followed immediately after the licensee's critique.
Personnel who attended are listed in Section 1.
The licensee and NRC
each identified weaknesses in their respective critiques as detailed
in this report.
The NRC Team Leader presented the exercise findings
in a joint public critique with FEMA-Region V at Lawrence, Michigan
on August 22, 1985.
5.
Specific Observations
a.
Control Room
This portion of the exercise was conducted from an office adjacent
to the Control Room.
It was not possible to utilize the Control Room
display panels due to reactor operations conducting critical path
procedures prior to startup.
A chronological event log with key
information was maintained throughout the exercise in the Control
Room.
Technical Specifications, Operating Procedures, Emergency Operating
Procedures, and the Emergency Plan Implementing Procedures were
utilized properly in most instances throughout the exercise by
cognizant Control Room staff including the Shift Engineer / Shift
Technical Advisor (SE/STA).
Notifications to offsite agencies were
made within the required 15 minutes for both Notification of Unusual
Events (NUEs) and the Alert declaration.
Emergency Implementing
Procedure EI-3 and its notification form were followed each time.
Information exchange and coordination of effort within the Control
Room (CR) was effective.
Operational and technical problems were
thoroughly analyzed prior to decisionmaking.
Transition of command from the Shift Engineer as initial Site
Emergency Director (SED) to the Plant General Manager as SED in the
TSC was done in a clear, effective manner.
Meaningful discussions
on plant conditions were held on several occasions between the SS,
SE, and Operations Supervisor of the CR, and their counterparts in
the TSC.
However, several requests from the TSC for actions to
mitigate the event were not only challenged by the Control Room,
but actually rejected.
One example was when the SED ordered the
contaminated steam generator dump valve opened to cool down the plant.
This action was rejected by the CR.
However, the final resolutions of
the TSC's proposed actions or counter suggestions were not
communicated back to the SED in the TSC and his operations and
technical staffs.
The TSC and Control Room personnel did not
adequately coordinate efforts to mitigate the accident.
The second NUE declared at approximately 0835 was correctly
classified based on release of a toxic gas / aerosol (H 50 ) which
2 4
could affect plant operations.
At 0845, the Control Room controller
notified the SE that "For purposes of the drill, toxic gas is
5
..
..
=.
.
.
-
'
.
e
sufficient to call an Alert." This Controller message preempted
,
'
CR emergency personnel from being allowed to analyze and evaluate
this information, relate it to the proper EAL, and make a classifi-
cation decision.
This obvious prompting by a controller is an
4
exercise weakness.
(0 pen Item No. 255/85016-01).
Although chemical analyses were frequently requested by the CR to
confirm that the boron concentration in the primary coolant was high
enough to maintain a sub-critical condition, the results were never
received by the CR staff.
As late as 1215, some of the CR staff
thought that both steam generators had significant primary to
i
secondary leaks, while actually only the "B" steam generator had a
primary to secondary leak.
Although internal communications and interchange of information
within the Control Room were excellent, communications with the TSC,
which were overly dependent on using the TSC Operations Support
Group Leader as a runner, were not always adequate.
!
b.
Technical Support Center (TSC)
,
The TSC was officially activated in less than 15 minutes; however,
several key participants were already in the TSC prior to the Alert
being declared.
Some of the participants prematurely present had
4
exercise-identifying arm bands on prior to TSC activation.
A more
'
disciplined, realistic approach to activation is recommended for
future exercises.
Assembly, accountability, and evacuation were
initiated and completed successfully within approximately 35 minutes
after the Alert was declared.
Briefings by the SED were held several
times an hour with the support group leaders.
However, not all TSC
personnel were adequately informed by the SED on all plant problems,
or which objectives were being pursued by the TSC.
Primary to secondary leak rate was not determined by the TSC, either
by the Operations Support Group or the Engineering and Maintenance
Support Group.
Primary plant temperatures and pressures, subcooling
1
temperatures, and steam generator temperatures and pressures were
i
all in various states of uncertainty during most of the exercise.
There was no trending of these parameters, at least prior to 1030.
,
Trend graphs for plotting were available, but were too small in size
and too large in scale to be effective.
They were located against
a wall, below waist level, where they were very awkward to use.
Clocks in the TSC were never synchronized.
The problem with the
five stuck control rods did not appear to be actively pursued by
,
the TSC, although it occurred about 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br />.
The SED's meeting
with his support teams at 1040 did not address this event.
Some of the exercise data sheets were confusing to the participants.
The pressure operated relief valves (PORVs), closed in the early
i
stages of the exercise, were opened at 1002, whereas plant data sheets
i
had these closed for the entire exercise.
l
l
t
6
_.---
--
--
- - . .- .
. -
. , . . .
. . - - -
..- - -
- _ _ - _ . . - . _
..
. _ _ . -
.
-
._ . . _ _ _ _
_ _ _ _ .
_
_.
_ . ..
.
-
1
1
.
,
Prior to declaring the Site Area Emergency and the General Emergency
'
there were good discussions and evaluations of the EALs by the SED
i
and his support group leaders.
Notifications to State and Counties,
as well as the Coast Guard for the General Emergency, were completed
within 15 minutes.
A Protective Action Recommendation (PAR) was
correctly issued by the SED and included sheltering up to 2 miles and
also downwind 2-5 miles to include two adjacent sectors within the
i
10 mile EPZ.
This initial PAR followed the PAR Flow Chart of
,'
i
Procedure EI-6.13.
Good rumor control was demonstrated by the SED in
following up on a rumor that an injured man was found at the site of
the toxic gas / acid spill about 0906.
The general design and layout of the TSC area, althcugh used
adequately in earlier annual exercises, appeared awkward and
i
somewhat inefficient this time.
The cubicle design limits the
!
communications within the TSC and definitely hinders eye contact
between SED and his staff.
!
-
The following weakness was identified:
,
i
j
Lack of coordination between the support groups, as well as
with their counterpart groups in the Control Room, was evident.
!
Examples of these incluce. lack of addressing critical plant
'
parameters such as primary to secondary leak rate determinations,
how to release the five stuck control rods, and lack of trending
,
vital plant temperature and pressure parameters.
(0 pen Item
No. 255/85016-02).
.
l
In addition to the above weakness, the following items should be
considered for improvement:
l
The activation process for the TSC should be better disciplined
and coordinated by all participants, including strict adherence
'
to Emergency Implementing Procedure EI-1 and El-2.1.
'
Graphs and charts needed for trending should be mounted where
they can be better utilized by the TSC support groups.
<
c.
Dose Assessment and Other Health Physics Related Activities
j
!
The Health Physics (HP) Support Group Leader in the TSC gave a
{
good briefing to this team on the radiological conditions as
!
they related to operational activities of the emergency.
J
The dose assessment staff in the TSC recognized the potential
]
threat of an offsite release of toxic gas and set up a stability
Class E isopleth to project a plume.
An onsite survey team was
'
,
dispatched which included a Chemistry Technician with a toxic
4
gas monitor to survey onsite conditions.
Habitability surveys
I
were made in the TSC.
Also, the HP leader alerted the offsite
'
l
survey teams to prepare for deployment in the field.
The technical
i
aspects of the emergency were actively considered in anticipation of
j
a probable radioactive release.
The TSC Communicator for the offsite
j
monitoring teams provided plant status information and meteorology
j
data as requested.
!
s
7
i
~
!I. .- .
..
-
-.
-
-
_ -
- -
--
. - -
_ . . - _ - _ - - . _
_ -
4
-
.
!
!
1
i
!
!
Functions were transferred from the TSC to the E0F in a timely manner,
while ensuring that no loss in data or continuity would occur.
Recommendations following the General Emergency were immediately
i
communicated to the State of Michigan.
Following the radiation
'
j
release at 1100, the initial PAR was properly and promptly revised.
i
The offsite teams were properly positioned.
1
Due to elevated dose rates near the EOF, location and staffing of an
!
alternate EOF was discussed, as well as preparation for sheltering
)
within the EOF.
Dosimetry and potassium iodide were brought in for
the EOF staff.
This aspect of the exercise was well done.
The HP
!
group in the E0F, recognizing the higher radiation exposure rates in
j
the field, requested reduced sampling. times for collecting air
!
samples, and based on contamination and ALARA considerations, did a
good job in attempting to reduce exposure to field teams.
Soil,
'
7
vegetation, water, and smear samples were not taken during the
j
exercise; but were recognized as being needed during the recovery
,
!
stage.
i
!
The E0F Director and his support group leaders caucused about
.'
2:00 p.m., and summarized the plant status and took action to
!
i
terminate the exercise.
This concluding portion of the exercise
,
was a joint effort of all E0F staff and was well done.
'
t
.
The weakness in the E0F dose assessment activities related to the
!
failure to meet to Objective No. 9 of the exercise, which was to
I
demonstrate the ability to monitor, assess, and trend radiological
!
field data.
Although the basic technical abilities to monitor and
assess radiological data were demonstrated, the magnitude, location,
i
'
and composition of the radioactive plume were not adequately
,
)
characterized.
l
'
.
1
Between 11:00 a.m. and 2:00 p.m. , the lip Group continually tried to
i
assess plume centerline dose rates, but they succeeded only once.
,
1
At other times, they assumed the reported dose rates were centerline
i
values, when in fact the teams were not at the centerline of the
>
j
plume.
This meant that in some cases, the assumed centerline data
[
]
were more than a factor of 1,000 lower than the actual maximum
'
i
centerline values.
This led the HP Group to believe that the maximum
i
dose rates, as well as the iodine and particulate concentrations,
{
were much lower than the scenario data.
The offsite monitoring data
!
were not tabulated, plotted, or otherwise trended in a way that could
,
l
have revealed this significant underestimate of the plume's intensity.
'
i
Smear data collected later was not recognized as suggesting that
iodine and particulate concentrations must have been higher than
j
earlier considered.
-
1
The release rate at 11:00 a.m. was estimated from the steam dump
'
.
area monitor reading to be about 9200 Ci/sec.
The lip Group recognized
!
that the release was via an unmonitored pathway and they planned to
j
use field radiation data to back-calculate the release rate.
This was
not accomplished in a timely or accurate manner.
Since the release
i
i
t
i
8
,
i
i
-
.
rate was virtually undefined, dose projections and assessments were
infrequent and inadequate.
Neither the field survey data nor the
dose projections adequately characterized the plume; therefore, it
was impossible to compare the protective action recommendations with
the EPA protective action guides.
It was also difficult to resolve
conflicting protective action recommendations with the State of
Michigan, because they were basing their dose projections on the
9200 Ci/sec release rate for a duration of about 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
This
unrealistically high release rate would have warranted evacuation
out to 25 miles.
The E0F-HP group recognized that the offsite monitoring teams would
be grossly contaminated from the release, but directions to the
offsite teams from the E0F-HP Communicator regarding decontamination
plans were apparently never transmitted to the teams because they
failed to report to the designated location for decontamination.
This is further discussed in Section 5.f of this report.
The
following weakness was identified:
The EOF-HP support group failed to adequately demonstrate
assess and trend radiological field data, including the
magnitude, location, and composition of the plume.
(0 pen
Item No. 255/85016-03).
d.
Operational Support Center (OSC)
Assembly, activation, and check out of radiation monitoring and
sampling equipment was adequately performed.
OSC Communicators kept
the onsite, and initially the offsite, monitoring teams well informed
of plant conditions as well as the current status of the emergency.
Radiation survey data was promptly reported by portable radio to the
OSC office.
Status boards were well maintained, with one noteworthy
exception.
There was no status board for equipment out of service.
Both the OSC Director and his counterpart in the Maintenance Support
Center, showed good command and control.
The in plant Health Physics Supervisor demonstrated good knowledge
of her emergency duties, and briefed and directed the inplant teams
effectively.
The inplant Communicator, and the person handling
records of inplant radiation level and emergency personnel exposure
information, were efficient.
Messages completed by the Communicator
were never signed nor initialed by anyone.
Adequate radiation
monitoring techniques were followed by the HP technicians accompanying
maintenance teams.
No Controller was present with the team sent out to repair one of
the charging pumps.
One of the maintenance specialists called the
OSC after a
hour time lapse and reported the job had been completed.
After a Controller determined that this repair job on the charging
pump should have taken three hours per the scenario, he then corrected
the time with the OSC.
However, the failure to have a Controller
with each team caused the Control Room to be told initially that this
i
l
l
9
!
l
l
-
-
-
-
-
-
-
-
-
-
-
-
.
-
charging pump was repaired in a
hour.
This uncoordinated event
(pump on vs pump available) also caused confusion in the TSC.
Another weakness was slipshod, erratic self-monitoring techniques,
as demonstrated by the OSC teams prior to reentry to the OSC.
Even
after the double doors to the OSC were closed and a sign was posted,
indicating that the frisking station was moved to the Low Level
Counting Room, participants still peisisted in trying to enter
the OSC through the south doors without frisking.
In addition, the
radiation counter and probe were placed on a chair as a frisking
station.
A more realistic set-up with radiation-type magenta / yellow
tape should be used in conjunction with a qualified individual posted
there to assure that no one stepped into the clean area without
self-monitoring or " frisking" their person.
This weakness is an
indication of inadequate training, poor emergency-related attitudes,
and a breakdown of the discipline needed in a real emergency
environment.
The aforementioned examples of inadaquate contamination
control provisions and practices are an exercise weakness.
(0 pen
Item No. 255/85016-04).
The PA system could not be heard in the OSC or the MSC, and the
respective Directors did not always follow these PA initiated
announcements with a voice announcement.
Also, the TSC was never
informed that PA announcements could not be heard inside the OSC.
Two or three procedural steps were in error or incorrectly done
by the team that was taking liquid and air samples (PASM).
As
a result, the inspectors could not determine whether a sample could
have actually been collected since this activity was simulated.
These steps involved improper flow meter setting, improper handling
of the inner cask lif ting device, and improper sequence in following
the procedure.
The radiological precautions, protective clothing
donning, and use of correct dosimetry including finger dosimeters
were demonstrated satisfactorily.
The total elapsed time from the
initialrequesttopivingtheresultstotheChemistrySupervisor,
was approximately 31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br />, or slightly more than the three hours
recommended by NRC guidance.
In addition to the exercise weakness, the following items should be
considered for improvement:
The PA system should be re-tested to assure reception in certain
areas near the OSC and MSC offices.
All messages, external or internal to the OSC, should be
initialed or signed.
Sufficient controllers should be provided so that no teams are
dispatched without a controller.
10
e.
Emergency Operations Facility (EOF)
Prior to complete activation of the EOF, which included primarily
corporate personnel, an interim position of EOF Leader was
established, per Procedure EI 4.3.
As interim Emergency Director,
this E0F Leader did not exercise his authority and responsibility
satisfactorily to make an effective transition with the EOF Director
and the permanent E0F staff.
The initial General Office Emergency
Response Team arrived about 1022, which is about 70 minutes after
the Alert was declared and within the guidelines of Procedure El-4.3.
However, because of the sporadic arrival times and poor exercising
of authority by the E0F Leader, it was difficult for the NRC
observer to accurately assess the activation time of the E0F.
It
took 21 minutes af ter the Emergency Director's arrival for him to
assume command.
All support teams were staffed at 1030, and the
official activation was not declared until 1050.
This activation
process should be better coordinated for future exercises.
The administrative and clerical support, as part of the initial
contingent prior to activation, performed their functions
adequately; however, the clerical procedure checklist should include
all EOF positions to ensure that logbooks, message forms, telephone
listing, and supplies are available.
The time clocks should have been
synchronized prior to EOF activation.
Although status briefings were held frequently by the E0F Director,
their content and direction did not put enough emphasis on follow-up
on PARS to determine what actions were taken and would be taken by
State and local agencies in conjunction with the plant's recommenda-
tions.
The communications with key State of Michigan personnel
appeared too infrequent.
Reports on plant conditions and related
communications with the TSC, particularly on major problems were well
done. However, the Emergency Director in his briefings did not always
solicit input from the Team Leaders.
The public address system
speaker in the Public Affairs /NRC room was erratic in performance.
Status board information, as posted, reflected the time this
information was sent to the State of Michigan, not the time it was
generated. Meteorological data was updated about every fifteen
minutes.
No records were kept of who received dosimetry or potassium
iodine in the E0F.
The South Haven Conference Center E0F does not presently meet
NUREG-0696 guidance for minimum space and communications for NRC
use.
This document states that office space for at least five NRC
personnel shall be made available and working space for nine NRC
and one FEMA personnel shall also be made available.
It also states
that at least three dial telephone lines shall be made available
for NRC use.
Also, additional HPN and ENS telephones should be
i
relocated at the communications table in the main E0F room, so that
'
communicators will have ready access to plant status and HP data.
This is an exercise weakness. (0 pen Item No. 255/85016-05)
11
About 1130, additional offsite monitoring teams were requested from
the D.C. Cook Nuclear Plant.
However, the decision was made to delay
their meeting the licensee's offsite teams until 2:00 p.m.
This
resulted in Team No.1 not being used effectively for significant
periods of time from 1130 to 1400.
Also, the E0F offsite monitoring
team's communicator was already having difficulty in managing the
movements of the licensee's own two teams.
It is doubtful that he
could have handled two more teams.
Provisions should be made for
one more communicator where more than two teams are to be effectively
used simultaneously in the field.
Requests to obtain approval for sending the two Cook Plant teams led
a communicator to reference the Mutual Agreement with the other
utility.
This agreement listed a Vice President as contact.
The
communicator telephoned that number, but later realized he should
have gone direct to Procedure E0F-4.
This procedure did not list
the D.C. Cook Plant or the correct telephone number.
Procedure
E0F-4, Page 12 of 16 should be updated to include the appropriate
D.C. Cook Plant telephone number.
In addition to the exercise weakness, the following items should be
considered for improvement:
The position of E0F Leaders should be clarified, adequate
training provided, so that the Leader will function as intended
prior to the EOF Director's arrival.
For future drills and exercises, the communications between tne
Emergency Director and his support teams should go both ways;
particularly the ED should always solicit their input as well as
providing his input to them.
Procedure E0F-4 should be revised to include the utility name
and telephone contact for assistance under the Mutual Agreement
Policy.
f.
Offsite Monitoring Teams
Assembly, activation, and check out of monitoring and sampling
equipment were well done at the teams' assembly point in the OSC.
The EOF and OSC communicators kept the teams informed of changing
plant status and the current emergency classification.
Victoreen
monitoring equipment, although not calibrated, was used instead of
Teletectors, which had been used in the 1984 exercise.
Self-reading
dosimeters and calculated doses were checked and reported to the OSC
and E0F.
Air samples were correctly taken.
In most cases, cross
contamination was avoided.
Protective clothing was worn at all times.
The team moved out of the plume after taking air samples which
demonstrated good ALARA practices.
The most serious weakness was not decontaminating the van before
returning to the site.
This would have resulted in the spread of
contamination at the site, in addition to other potential
contamination control problems.
This is an exercise weakness.
(0 pen Item No. 255/85016-06).
12
-
__.
.
.
The EPZ map and data sheets provided were difficult to work with in
a moving vehicle.
Drawers in the cabinets in the van should be
secured to prevent equipment damage, as well as possible injury to
the occupants of the van.
~
6.
Management Meetings
a.
Exit Meeting - August 21, 1985
The inspectors met with licensee representatives denoted in
Section 1 at the conclusion of the inspection to present the
NRC's preliminary findings.
Licensee representatives agreed to
consider the items discussed.
In addition, the inspector
discussed the likely content of the inspection report.
The
licensee did not identify any of the materials discussed as
proprietary or safeguards information.
b.
Management Meeting Held in NRC Region III on September 20, 1985
Prior to this meeting an initial meeting was held at the
'
Palisades Plant on September 5, 1985 to discuss Region III's
concern over the plant's general performance in emergency
preparedness and in particular the plant's performance in the
August 20, 1985 annual emergency exercise, (Reference Meeting
Report No. 50-255/85022).
As a result of the initial meeting,
the licensee was instructed to present their goals and
commitments for improving their emergency preparedness program
with a specific time line at the September 20, 1985 meeting at
Region III offices.
These goals and planned corrective actions by the licensee
are included as Attachment 3 to this report, subject to the
understandings described.
It is our understanding that Issue No. 1 of the corrective
action will include a review of all Emergency Action Levels
(EALs) for clarity.
For Issue No. 2, the staff understands
that, in reorganizing the TSC organization, the Control Room
will report through the Operations Support Group to the SED
and either the position of Operations Supervisor or Operations
Manager will be eliminated.
For Issue No. 4 we understand all
the radiation services department personnel and chemistry
personnel associated with PASM will be included in the table-top
exercises / discussions.
For Issue No. 6 we understand that a
generic list of performance standards will be issued to all
plant staff in the emergency organization and not just to
recent exercise participants.
For Issue No. 14 we understand
that, for interim measures, only qualified Health Physicists
will be used as offsite team communicators.
The July, 1986
completion date refers to the long term plan to develop and
implement a new method of controls to review and revise, as
necessary, team procedures.
For Issue No. 15, we understand
13
- -
.
-
--
-
- .-
_ .
._.
_ __
.
J
-
.
!
that the frequency of the planned seminars will be a minimum
4
of twice per year.
In addition, we understand that to support
a date of June,1986 to complete the computer calculations
point, the following milestones will be met: (1) tech. manual
,
and human factors review will be completed by the end of
,
!
October, 1985; (2) the maintenance manual, users manual, and
technical review will be completed by the end of November,
,
j
1985; (3) the software manual will be completed by the end of
j
December, 1985; (4) the appropriate procedures at Big Rock
Point and Palisades (26 total) will be revised by the end of
,
January, 1986, with Plant Review Committee approval completed
by the end of February, 1986; (5) the appropriate training
4
'
modules will be revised by the end of March,1986; and (6) all
training will be completed on the new procedures using the new
module by the end of June, 1986.
NRC Region III will closely monitor all of the licensee's
proposed actions and milestones as described above and in
l
Attachment 3 to this report.
The licensee representatives
were instructed to notify NRC Region III at the earliest
>
possible time if a commitment or milestone would not be met
and provide adequate justification.
Attachments:
1.
Exercise Sequence of Events and Narative Summary
i
2.
Exercise Scope and Objectives
3.
1985 Palisades Evaluated Exercise Corrective Actions
j
i
4
i
i
-
!
1
1
l
14
-- -
.-
. . - .
.-
. , - . - - - - - . - . . _ , _ . - - - , - , - - - - - - . - - . -
,
.
2.0
SCOPE AND OBJECTIVES
2.1
SCOPE
A simulated abnormal radiological incident at the Palisades Plant will
escalate to a General Emergency, and will involve planned response and
recovery actions that include emergency classification, notification of
offsite organizations, notification of plant personnel, simulated
actions to correct the emergency conditions, initiation of accident
assessment and protective action recommendations as to cope with the
accident. The emergency will then de escalate, the recovery phase will
be initiated and the exercise will be terminated.
2.2
OBJECTIVES
The major objective of the exercise is to evaluate the integrated
capability and a major portion of the basic elements existing within
the onsite emergency plans and emergency response organizations.
Specific objectives of the exercise to be demonstrated in various
phases are listed below. The " free play" aspect of the exercise will
be emphasized where practical. The exercise will:
1.
Demonstrate the adequacy of the Site Emergency Plan (SEP) and the
Site Emergency Plan Implementing Procedures to ensure compliance
with 10 CFR 50.47 and NUREG-0654,
i
2.
Demonstrate the activation, staffing and operation of emergency
response facilities.
3.
Demonstrate proficiency in recognizing and classifying emergency
conditions.
4.
Demonstrate the notification network to State, local, Federal,
corporate and plant personnel,
i
5.
Demonstrate a familiarity with Protective Action Guides (PAGs) and
j
determination of protective actions.
1
j
6.
Demonstrate the mobilization of onsite and offsite radiological
i
monitoring teams.
,
f
7.
Demonstrate the capability to utilize the post-accident sampling
system.
4
'
8.
Demonstrate the capability to coordinate news releases, and handle
public inquiries in a timely and accurate fashion.
i
9.
Demonstrate the ability to monitor, assess and trend radiological
i
field data.
10.
Demonstrate the capability of performing a site assembly and
i
accountability of personnel within 30 minutes.
!
NUO685-0020A-TP13
2.1
i
f
I
.- . . _ - - _
.
.
PALEX-85
SEQUENCE OF EVENTS AND NARRATIVE SUTiARY
The plant is operating at 98% power supplying 750 MWe and has been operating
the equivalent of 200 full power days.
Primary Coolant System I-131 DEQ
activity has been at 1.1 pCi/g since 0810 Saturday (LCO condition reached at
0810 today). Latest primary sample showing 1.1 pCi/g taken at 0830 on Monday.
Primary Coolant System leakage is 0.3 gpm unidentified, 0.2 gpm identified and
,
0.01 gpm primary to secondary.
One of the three charging pumps (P-55A) is
inoperable due to normal preventive maintenance.
"B" charging pump is in
service and "C"
is the backup.
P-66A high pressure safety injection pump
(HPSI) is inoperable due to broken oil filter.
At 0810, an Unusual Event is declared as a result of exceeding 1 pCi/g
Iodine-131 DEQ for more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Plant shutdown continues.
At 0815, maintenance repairman, while loading gas bottles, knocks over several
cylinders of propane with a forklift truck. The valve is severed on one of
the cylinders.
The cylinder is propelled through the metal wall of the
Feedwater Purity Building, striking the sulfuric acid tank. A hole is punched
(
in the tank about half way up.
The sulfuric acid runs to the floor from the
hole. The acid reacts with the water on the floor, causing sulfuric acid
fumes. Toxic sulfuric acid fumes fill the Feedwater Purity Building as a
result of the leaking sulfuric acid reacting with the water in the containment
area around the acid tank.
At 0820, the repairman calls Control Room to report the accident and the
Auxiliary Operator notifies Control Room of toxic gas release (Alert).
At 0830, Control Room notifies Chemistry of toxic gas release.
At 0835, the acid tank has drained down to point of break.
(Leak is secured.)
Between 0835 and 0930, Chemistry neutralizes spill, the Auxiliary Operator
establishes ventilation and cleanup begins.
At 0930, Charging Pump P-55B trips. P-SSB tripped due to a pressure control-
1er (PC-0216B) ruptured (broke off at connection). This caused the pump to
trip on low oil pressure.
P-55C starts but trips immediately due to seized
pump motor caused by low seal cooling flow.
At 0940, Auxiliary Operator notifies Control Room that Feedwater Purity
Building is now habitable; toxic sulfuric acid fumes have dispersed (possible
de-escalation).
!At0950,HPSIPumpP-66BfailsduetoadamagedY-Phaseovercurrentrelay
damage. The damage resulted when a maintenance man inadvertently bumped the
breaker with some tools while on his way to fix the charging pumps. Now there
are no HPSI pumps or charging pumps.
At 1000, the cap on the main steam isolation valve on Steam Generator B opened
up (modelled as a 1.0 ft2
- '
break).
At the same time, 5 steam generator tubes
.
NUO685-0241G-TP13
i
, _ . . _ _ - _ _ . .
-
. _ - - _ .
_
,__--
.
.
.-
_ _ .
. _ - _ _ . _ - _ -
- - - - _ _
_.
_-
. - . _ _ _ _
_
.
-
PALEX-85
ruptured (modelled as a 0.02 ft2 LOCA.
Primary coolant and steam generator
fluid are released to the environment via the door to the roof of the Auxil-
iary Building (the door is about seven feet away and five feet above the
damaged MSIV). Steam and radionuclide also gather in all floors of the
Component Cooling Water Room (the MSIVs are on the second floor; the door to
the roof is on the third floor of this room).
In the opinion of the scenario
writers, a General Emergency condition exists due to the loss of two of three
fission product barriers, with potential for the loss of the third.
The
potential loss of the third is indicated (in the scenario writers' view) by
-
the plant high radiation alarms.
In fairness to the plant, they may believe
that the high radiation is coming from the activity in the primary coolant
with an iodine / noble gas spike, and not from additional failed fuel rods.
j
Therefore, breach of the third barrier is not imminent and the event is a Site
Area Emergency. The Consumers Power Company evaluators and NRC evaluators
will determine if the reasoning not to classify the vent as a General Emer-
gency is adequate. An additional consideration is that there is an Emergency
Action Level of Site Area Emergency, which is defined as a steam line break
and greater than 50 gpm primary to secondary leak rate and indication of fuel
damage, all of which occur here.
l
At 1000 and 15 seconds, there is a reactor trip on high reactor power followed
quickly by low pressurizer pressure and low steam generator pressure trip
1
signals. All but five control rods insert so that the reactor remains
critical.
At 1002, the primary pressure has bottomed out above the low-pressure safety
injection (LPSI) pump head. At this point, there is no safety injection as
bottom HPSI pumps and all three charging pumps are out and the primary system
pressure is too high for LPSI flow or safety injection tonk flow. The pres-
surizer is empty and steam is coming out of the break. Since power generation
is now greater than combination of energy being released out of the break and
the energy transferred to the steam generators, the primary pressures begin to
rise.
l
At 1020, the primary system pressure has peaked at 2400 psi and the pressuri-
zer has refilled due to expansion of the primary coolant.
At 1030, the reactor goes suberitical due to the primary system heatup (nega-
4
tive moderator coefficient of reactivity) and now the energy transferred out
4
j
the break and to the steam generators is greater than decay heat. The primary
coolant begins to cool off, and the pressure and temperatures begin to fall.
At 1100, the core is uncovered and fuel is overheating and failing. HPSI
Pump P-66A is fixed but, by itself, can only stabilize level (flow in : flow
out).
The plant can be cooled in one of three ways. One is to wait for the second
HPSI pump to be fixed (should be fixed about 1200) and reflood. A second way
is to open the bypass around the MSIV and cool using the good steam generator
and turbine bypass valve (or atmospheric dump valves), and a third is to open
the PORVs and depressurize down a pressure at which the LPSI pumps can provide
injection flow. The scenario writers did not think that the PORVs would be
KUO685-0241G-TP13
1
'
_ _ . _ _ _ _ _
_ _ _ _ _
_ _
_ . _ _ _
- .
.
_ _ _ -.
__ _
. . _
.__
_
.
- _ - .
_ _ _ .
_ _. _ _
_
. _ _ _ _ _ _ .
- . _ _ _ _ . _ . _ _
_
_
_ _ .
.. . _ _ _ _ .
_
.
PALEX-85
,
i
used (based on the advice of our simulator instructor) or that the atmospheric
dump valves would be used. Therefore, the scenario was written based on the
plant staff waiting for the second HPSI pump to be fixed.
If the plant staff
elects to use the turbine bypass valve, the cooldown is so slow that the
scenario, as we have drawn it, will not change much. The controllers are
i
prepared, however, to allow the plant staff to cool in any of the three ways
described above.
At 1200, the other HPSI pumps is fixed and plant cooldown can commence. The
core is covered quickly af ter the second llPSI is put into service.
4
Between 1330 and 1400, the drill ceases with the core cooled and covered, and
the release stopped (although the path still exists).
!
!
4
4
6
4
P
1
1
!
l
I
a
i
e
l
1
NUO685-02410-TP13
i
<
i
e
- - - - - - - -
--
.,
, _ - - - _ .
, _ _ . - _ , . -
_ . . . _ , _ _ . _ _ _ _ _ _ _ _
_ _ _ - _ _ _ - _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ -
. - _
-_
_ _ . _
_ _ . _ _ - . _ . - _ _ _ _ _ _ _ _ _ _ _ _ _ _ ,
F
e
1
,
i
u
i
i
I
i
l
I
i
4
!
i
i.
t
1985 PALISADES EVALUATED EXERCISE
!
!
CORRECTIVE ACTIONS
<
,
-
!
i
a
b
,
[
"
a
1
l
!
I
i
i
.
d
t
l
i
4
I
f
I
1
-
,
I
'
l
I
,
a
i
I
s
I
i
1
1
I
I
l
EP0985-0001C-NC08
i
l
'i
.
.
.
.
.
.
. .
.
.
1
1985 PALISADES EVALUATED EXERCISE
CORRECTIVE ACTIONS
GD
ISSUE-1
The scenario controllers in the control room had to prompt the players to
issue the " Alert" classification.
CAUSE
Procedural deficiency and scenario deficiency.
RESOLUTIJN
1.
A comprehensive review of the EALs is progressing. This issue will be
used as an example of where a problem exists and the next revision of the
EALs will reflect the resolution.
2.
A review of the PALEX 86 scenario will be performed to ensure the scenario
events clearly define the desired actions and to ensure that proper
contingency messages are present to allow the controllers to perform
satisfactorily.
COMPLETION DATE
1.
December 31, 1985
2.
July 5, 1986
S
ISSUE-2
There was a lack of feedback from the control room to the TSC on the nteam
dump issue.
CAUSE
Communications deficiency
Procedural deficiency.
RESOLUTION
1.
A table top exercine/ discussion will be conducted between all potential
SEDs, Shift Supervisors and Shift Engineers. The purpose in to increase
awareness of the need for the facilities to rely upon each other and use
each other in an emergency situation.
2.
A procedural change will be made to strenmline the reporting mechanism
between the SED and control room.
EP0985-0001C-NC08
-
2
COMPLETION DATE
1.
November 30 1985
2.
September 16, 1985
9
ISSUE-3
There was too much " simulation" on the part of the players. This resulted in
players neglecting certain aspects that would normally have been done had they
not simulated.
CAUSE
Exercise concept deficiency
RESOLUTION
1.
The appropriate SEP training lesson plans will be revised to emphasize
avoiding simulation.
2.
1986 drills and exercises will require performance of tasks that have
heretofore been simulated. Such tasks may be requiring the use of anti-
C's, respiratorn, expanding maintenance activities, etc.
COMP!.ETION DATES
1.
January 15, 1986
2.
Ongoing
(D
ISSUE-4
There was poor contamination control practice. The HP group from the OSC did
not address the simulated contamination problem caused by the plume. Step-off
pads were not used, and contamination and radiation boundaries were not set
up.
There appears to be a general lack of understanding of the real contami-
nation consequences of a plume.
CAUSE
Player performance deficiency
R ES0!.UTION
1.
An on-going effort will be made to stress the reduction in simulation
during drills and exercises and to improve "drillemanship".
2.
A table-top exercine/ discussion of the radiological impact of the PAI.EX 85
acenario with TSC/OSC HP ntaff will be conducted. Emphasis will be placed
upon enhancing player understanding of the events and the renultant
radiological hazards. Analytical approach to problems annociated with
detection and quantification of thene hazards will be presented.
EP0985-0001C-NC08
- -
-
-
- - -
.
3
COMPLETION DATE
1.
Ongoing
2.
Octobe. 31, 1985
GD
ISSUE-5
Post-accident samples were not obtained in a timely fashion.
CAUSE
Player performance deficiency
Controller deficiency
RESOLUTION
1.
Revise the formal SEP training module lesson plan to stress the need for
OSC Director to obtain priorities from TSC lip group leader.
2.
Ensure there is a sufficient number of controllers for future drills and
exercises to avoid delays in player performance.
COMPLETION DATE
1.
October 5. 1985
2.
November 15, 1985
GD
ISSUE-6
Players were observed to exhibit a poor attitude toward the evaluated exer-
cise.
In a few cases, players appeared to be distracted from the primary role
of emergency response by discussing non-work-related matters.
CAUSE
Player expectations not clearly defined
RESOLUTION
1.
A generic list of " performance standards" that is expected of all players
will be distributed to the plant staff. These standards will be geared to
improve "drillamanship".
2.
The " Objectives" of PALEX 86 will be distributed to the plant staff in
advance of the evaluated exercise.
COMPLETION DATE
1.
November 30, 1985
2.
July 30, 1986
EP0985-0001C-NC08
. -
.
. _ . _ . . _ _ _ _ _ _ _ _ . . _ . _ __.__ . _ . _ _ _ _ _ _ _
__._ . _ _ _ _ . _ ._
}
1
-
.
i
4
l
i
!
!
l
9
ISSUE-7
!
j
The Public Address (PA) System cannot be heard in the MSC or OSC.
i
CAUSE
t
Equipment deficiency
RESOLUTION
j
1.
A speaker will be installed in the MSC.
i
2.
The speaker system in the OSC will be upgraded by putting in an additional
j
speaker or increasing the range of the " volume control" of the installed
i
!
speaker.
1
,
}
COMPLETION DATE
'
l
'
)
(1) and (2) December 31, 1985
,
J
j
e
ISSUE-s
-
.
'
The physical layout of the TSC is not conducive to good communication. The
installed room dividers appear to be a barrier to the team leadra and prevent
,
easy access and communication.
L
.j
,
l
CAUSE
!
.:
{
TSC design
i
!
RESOLUTION
l
An evaluation will be conducted to determine if the room dividers should be
I
<
removed.
!
1
e
i
I
l
COMPLETION DATE
I
l
December 31, 1985
!
'
O
ISSUE-9
The trend graphs in the TSC are located at an awkward height.
In addition.
[
they are too small and of insufficient scale to be effectively used.
!
i
'
j
CAUSE
i
Equipment deficiency
i
I
EP0985-0001C-NC08
. - . -
. - .
.
-
__
._
.
_ _ _ _ . .
-.
.
__ _.
_
!
l
.
.
l
5
4
RESOLUTION
l
The trend graphs will be relocated to a more acceptable height. The actual
graphs will be enlarged and modified to accommodate a larger scale.
COMPLETION DATE
4
December 31, 1985
9
ISSUE 10
3
)
Exercise controllers need to be better trained concerning their performance
j
during practice drills and evaluated exercises.
.
CAUSE
J
i
Training deficiency
'
RESOLUTION
i
.
A more comprehensive training program will be provided each controller prior
!
,
-l
to the first practice drill at Palisades in August 1986. A thorough discus-
'
sion will be conducted with each controller regarding the scenario package
'
prior to the evaluated exercise.
!
COMPLETION DATE
1986 Scenario Committee established: October 20, 1985
Controller position organization: November 15, 1985
l
Draft PALEX 86 objectivest November 30, 1985
Comprehensive controller training completed by July 29, 1986
controller training on practice scenario specifics by July 29, 1986
l
Controller discussion regarding exercise specifics by August 15, 1986
i
I
!
J
G
ISSUE 11
!
Lack of controllers in the Maintenance Support Center and Operations Support
1
l
Center.
i
t
!
CAUSE
I
t
Controller organization deficiency
f
RESOLUTION
1
Lessons learned from PALEX 85 will be incorporated into the 1986 scenario
j
controller organization; additional personnel will be assigned.
l
4
COMPLETION DATE
,
l
November 15, 1985
l
EP0985-0001C-NC08
'
,
i
. .
,. .
_
.
-
.
.
-.
-
.
6
ID
ISSUE-12
The utility, state and local government representatives in the Joint Public
Information Center did not act as a team (sharing all appropriate information,
working out inconsistencies, etc.) behind the scenes (in the Command Center)
prior to scheduled briefings.
CAUSE
J
Player performance
RESOLUTION
This will be stressed with Coneumers Power Company personnel during regularly
scheduled training and again during practice drills scheduled with state and
local officials prior to the August 1986 Palisades exercise.
COMPLETION DATE
July 29, 1986
GD
ISSUE-13
'
Responsibilities and authority within the Emergency Operations Facility (EOF)
were misunderstood by some personnel; ie, EOF Director, HP Team Leader.
CAUSE
Procedural deficiency
Training deficiency
RESOLUTION
1.
Procedure EOF-1 (Emergency Officer) assigns to the Emergency Officer
responsibility for resolving differences between the Site Emergency
Director (SED) and the EOF Director. This responsiiblity will be listed
under actions to be performed (it is not currently); an organizational
diagram of reporting relationships and communications will be incorporated
into Procedure GEN-1 (Overview). EOF-2 (EOF Director) will be revised to
stress priority of responsibilities.
2.
Emergency Planning personnel will conduct hands-on training with appropri-
ate management personnel who work within the EOF to ensure a clear under-
standing of individual and facility responsibilities / authority.
t
3.
The EOF Management Training Module will be enhanced to include more
specifics concerning management roles within the facility.
EP0985-0001C-NC08
l
!
- _ _ .
. _ _
_ .. , . _ _ _ , _ . _ _ _ __..._, . - _ _ . _ . . . . . . . _ .
_.
_
-
-
-
-
. - - .
-
.
7
COMPLETION DATE
1) December 1, 1985
2) December 13, 1985
3) January 1, 1986
GD
ISSUE-14
The magnitude, location and composition of the radioactive plume were not
adequately characterized by the EOF health physics team to satisfy Objective
9, " Demonstrate the ability to monitor, assess, and trend radiological field
data."
CAUSE
1.
Inexperienced offsite team communicator in the EOF.
2.
Lack of a well-defined methodology for controlling offsite monitoring
teams.
3.
Current procedure for trending offsite monitoring team data with calculat-
ed offsite doses is not effective.
RESOLUTION
1.
Involve EOF health physics team members from the General Office in the
plant's offsite monitoring team drills to more thoroughly acquaint them
with the functions and actions of the offsite teams as well as the data
'
being provided by the teams.
2.
A more efficient and more practical methodology for controlling the
offsite teams can be developed. To this end, a meeting between the EOF
health physics team leader and the Palisades offsite monitoring team
members was held on September 12, 1985 to discuss problems with the
current approach.
3.
Revise the current emergency implementing procedure comparing offsite
!
survey data to calculated offsite doses so that it provides an effective
means for trending offsite dose information.
4.
Use knowledgable health physics personnel as offsite team communicators.
COMPLETION DATES
i
!
1.
October 15, 1985
.
2.
July, 1986.
'
3.
July, 1986
4.
December, 1985
GD
ISSUE-15
The EOF health physics team failed to properly perform required dose assese-
ment functions resulting in confusion between the utility and the State of
Michigan on source term, calculated dose rates, and adequate size for the
protective action area.
EP0985-0001C-NC08
i
!
,
__. __
- _ . . , . , , , - _ _
. _ , _ . _ . , _
._-..______.--__,_m-,
, , . - , . . - - . , . . .
..
_
._.
.-
--
.
-
8
CAUSES
1.
Health physics team was not managed effectively by team leader.
2.
Team members were not completely familiar with their roles and functions.
3.
Health physics team did not communicate well with the State of Michigan
health physics group.
4.
The current manual dose assessment procedures did not allow the health
physics team to complete the dose calculations in a timely manner.
RESOLUTION
1.
A table top discussion of the PALEX-85 scenario has been scheduled with
the health physics staff from both the plant and General Office and the
State of Michigan. The intent of this table top is to 1) review the
radiological aspects of the scenario; 2) review actions taken by the
'
health physics teams and management of the teams by the leaders; and 3)
discuss what areas need to be improved and how to improve them.
2.
Enchance the current dose assessment classroom training with additional
,
training seminars for key personnel.
3.
Include, as a minimum, the EOF health physics team in the Palisades TSC
drill scheduled in March / April.
(Evaluate need for full EOF participation
during this drill.)
4.
Computerize the current manual dose assessment procedures for calculating
source terms, decay factors, dose calculations, and notification form
completion.
COMPLETION DATES
1.
October 3, 1985
2.
First seminar during first quarter, 1986
3.
March or April, 1986
4.
June, 1986
ID
ISSUE-16
!
No one was in charge of the EOF until the EOF Director arrived from General
Office.
CAUSE
Player performance deficiency
Procedural deficiency
!
RESOLUTION
1.
The plant person designated as EOF Administrator will assume control of
EOF personnel until arrival of management from General Office. Responsi
bilities prior to arrival of General Office personnel will be delineated
in EOF-3, EOF administrator. Heretofore, initial EOF leader responsibili-
ties were not identified in a procedure.
EP0985-0001C-NC08
1
,
- . - . ,-
,
. - - - . --
-.---~-,---.--,v,-
.y-,w
.-,-,-,,,--,--,-.,,,,-,.,-..-..--c,---+-.-,...,v-
- , - - . - - - -
e
-
- - =.
.
..
_ . .
._.
.
._
- _ .
. _ -
.
-
9
2.
Emergency Planning personnel will conduct hands-on training with appropri-
ate management personnel who work within the EOF to ensure a clear under-
standing of individual ar.d facility responsibilities / authority.
3.
The EOF Management Training Module will be enhanced to include more
specifics concerning management roles withir4 the facility.
COMPLETION DATE
1.
December 1, 1985
2.
December 15, 1985
3.
January 1, 1986
i
l
J
I
-
1
4
)
!
!
i
!
EP0985-0001C-NC08
l
,
.
-
-
-
-
-
.
.
1985 SEP IMPROVEMENT ITEMS
-
More structured SEP training and self study
-
Development of a plant staff SEP training matrix
Fully defined and trained emergency response organization
-
-
Extensive post-accident sampling training for technicians
-
Increased offsite monitoring team training
-
Review and revision of SEP and EIPs to new organization
-
Increased EAL/NUE training for Shift Supervisors and Shift Engineers
-
Indepth EAL review
-
Procurement of two (2) new emergency vans
-
FEMA approval of Public Warning System
-
Increased management support for emergency planning
Improved relations with State Radiological Health Department
-
l
l
EP0985-0001C-NC08
l
l
L