ML20148J972

Ack Receipt of NRC Re Six Deficiencies Noted in Insp Rept 50-298/87-25.One Area Needs Clarification.Three Events Observed During Emergency Exercise.Requests Schedule for Correcting Deficiency 298/8725-02 within 30 Days

ML20148J972
Person / Time
Site:	Cooper
Issue date:	01/22/1988
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Trevors G NEBRASKA PUBLIC POWER DISTRICT
References
NUDOCS 8801270518
Download: ML20148J972 (2)

See also: IR 05000298/1987025

Text

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In Reply Refer To:

Docket: 50-298/87-25-

Nebraska Public Power District

ATTN:. George A. Trevors

Division Manager - Nuclear Support

P. 0.-Box 499

Columbus, NE 68601'  ;

Gentlemen:

Thank you for your letter of December 10, 1987, in response to our letter. l

dated November 6, 1987. We have reviewed your reply to the six deficiencies

identified in our report. The response in your letter was duscussed with

Mr. R. Hayden of your staff on December 30, 1987. In your response, there is

one area that needs additional clarification.

In your response to deficiency number 298/8725-02,- you quoted NUREG-0696 and

the need for face-to-face communications between Technical Support

Center (TSC) and Control Room (CR) personnel. The face-to-face method of

communicating is beneficial, but not a substitute for the primary method of

information exchange between Emergency Response Facilities (ERF), which should

be by direct telephone from the TSC to the Control Room.

The three events ob. served during the emergency exercise highlighted weaknesses

in the exchange of vital information between CR and TSC staffs, We believe

that a review of this area is in order. This review should identify kinds

of information that need to be exchanged between ERFs, the~ organizational

elements in charge of transmitting and receiving various types of information,

and the means used to transmit and receive each type of information,

Additionally, procedures should designate responsibilities and describe

necessary actions and equipment.

It is requested that within 30 days after the receipt of this letter you

provide this office with a schedule for correcting deficiency number

298/8725-02.

Your reply to the other five deficiencies identified was considered adequate.

We will review the implementation of your corrective actions during a future

inspection.

Sincerely,

M S e nt Bp

%[2{gy g$ e L J. CALLAN

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L. J. Callan, Director

Division of Reactor Projects

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Guy Horn, Division Manager-

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Cooper Nuclear Station

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Program Manager

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911 Walnut Street, Room 200

Kansas City, Missouri 64106

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Lincoln, Nebraska 68508

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RSTS Operator W. Long, NRR Project Manager

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GENERAL OFFICE

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December 10, 1987

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U.S. Nuclear Regulatory Commission j EC l 8 %I

Attention: Document Control Desk l

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Washington, DC 20555 -

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Gentlemen: -

Subject: NPPD Response to Inspection Report 50-298/87-25

This letter is written in response to your letter (undated), transmitting

Inspection Report 50-298/87-25. Therein you identified six (6) deficiencies

in our emergency preparedness program observed during the 1987 annual emergency

exercise. The following is our response to the deficiencies noted:

Deficiency 1 (285/8725-01)

The NRC inspector noted that not all notifications originating from the Control

Room (CR) to offsite authorities were made in a timely or consistent manner.

The Emergency Director (ED) declared the Alert at 8:34 a.m.i however:

The authorities of the State of Nebraska were notified of the Alert at

8:51 a.m.

The authorities of the State of Missouri were notified of the Alert at

8:55 a.m.

The ED did not declare a Site Area Emergency until about 26 minutes after

plant conditions warranted the same. As a consequence, notifications

to offsite authorities pertaining to this escalation in accident severity

were delayed.

Response

The Emergency Director was fully aware of simulated plant conditions during

the time frame immediately preceding the declaration of a Site Area Emergency.

Time was spent in confirming all indications. Regulations do not dictate

the amount of time to be used in classification and verification of an

emergency. It is felt that an erroneous or premature declaration of a Site

Area Emergency would not be prudent.

Notification procedures will be revised to make the exact time of an emergency

declaration for an alert or higher classification a part of the plant public

address emergency announcement. It will also be reflected in the notification

form used by the Control Room Communicator. This will be completed by February

29, 1988.

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Deficiency 2 (285/8725-02)

Information . ' pertaining to. plant status was not conveyed from the CR to the

TSC in a timely manner, as follows:

Information about the discharge-volume drain valve being inoperative at

9:15 a.m. was not received in the TSC until 9:27 a.m.

At 10:03 a.m., the CR mandated through -the public address system the

evacuation of the Reactor Building due to high radiation levels. At 10:09

a.m., the ED called the CR to find out why this evacuation took place, ',

indicating lack of continuous flow of information from the CR to the TSC.

An alarm pertaining to the inoperable scram discharge valve was received

by CR operators at 9:30 a.m. This required visual inspection by procedure.

The CR operators failed to inform the TSC staff about this situation,

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and as a consequence the valve inspection team was not dispatched until

9:53 a.m.

Several face-to-face meetings between the CR and TSC staffs were necessary

to compensate for the shortcomings of other means of communication

throughout the exercise, indicating a possible need for additional

communication hardware between these two emergency response facilities.

Response

Section 2.2 (page 9) of NUREC 0696, Functional Criteria for Emergency Response

Facilities, supports actions taken by CNS Control Room and TSC staff by stating

the need for face-to-face communcitions between TSC and Control Room personnel.

The next cycle of CNS operator requal training will include a thorough review

of this inspection item. In addition, section A of EPIP 5.7.7, Activation

of TSC, will be revised to prompt the Emergency Director to review plant

status with control Room and TSC personnel on a periodic basis. This will

be completed by April 15, 1988.

Deficiency 3 (285/8725-03)

The . NRC inspector noted that the Shift Supervisor (SS) acting as the ED,

in the CR, and the Control Room Supervisor (CRS), became involved with

, administrative details, or failed to delegate functions to the TSC. This

detracted from their ability to direct and coordinate emergency response

activities in an efficient manner.

Response

The District has embarked on an ef fort to develop and implement an improved

emergency response organization training program. This new program will

be position task oriented and will address issues such as those described

l in the stated deficiency. Improved training should help to increase efficiency

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in the coordination of the operational and administrative direction of

emergency situations. The revised emergency response training programs will

be implemented during calendar 1988.

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Deficiency 4 (285/8725-04)

-The NRC inspector noted that Procedure EPIP 5.7.1, "Emergency Classification",

listed Emergency Action Level (EAL) 2.6 as the loss of two fission product

barriers as a Ceneral Emergency. The EAL in some situ ~ations would produce

minimal offsite consequence that would not justify taking mandatory pretective

actions as is the case in a Ceneral Emergency class. Additionally, the

guidance in NUREG 0654, Appendix A, states-that a General Emergency requires

the loss of 2 out of 3 fission product barriers with a potential loss of

the third barrier.

Response

.A proposal. to change the NPPD Emergency Plan for CNS and the corresponding

EPIPs to reflect the guidance in NUREG . 0654 concerning loss of 2 out of 3

fission product barriers will be presented to the appropriate state agencies

for their review and comment. Upon receipt of their comments, the appropriate '

changes will be incorporated into the Emergency Plan, EPIPs, and CNS training

cycle. This will be completed before April 15, 1988.

Deficiency 5 (285/8725-05)

The NRC Inspectors noted that the TSC engineering staff used uncontrolled

copies of plant system diagrams, that could be out of date, for troubleshooting

during the unfolding of the accident scenario.

The status boards in the TSC vere deficient in that:

The status boards were not maintained up-to-date (e.g. equipment status

was not updated from 10:00 a.m. to 3:00 p.m.).

Parameter trends were not indicated. '

Parameters such as valve position for critical systems, like Standby Cas

Treatment and Switch Liquid Control, were not indicated.

Response

Parameters, trends and current system lineups are available on PMIS/SPDS in

the TSC for access by the TSC organization in the event of an actual emergency.

Uncontrolled copies of plant system disgrams have been removed from the TSC

and controlled copies made available. The District will be developing enlarged

TSC status corads having improved capabilities for status and trending displays -

for installation in the new TSC currently under construction. 'the se revised

disploys will be available by the end of June 1988.

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Deficiency 6 (285/8725-06)

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The NRC inspector determined that the medical team failed to take appropriate

first-aid actions to save the life of the injured-contaminated individual,

and was unable to establish priorities between medical and radiological

concerns.

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Dec=bar 10, 1987

Response

The CNS medical training program will be upgraded to provide for Red Cross

Multimedia First-Aid, training for station personnel and the establishment

of EMT qualified squads to improve the station's capability to combat medical

emergencies.

A procedure is under development for medical response to injured,

non-contaminated individuals with renewed emphasis on first aid capabilities.

In addition, the revised emergency response training program will address

the coordinating of medical emergency actions during plant casualty conditions.

These actions will be completed before the end of June, 1988.

Should you have any questions concerning this matter, please contact my office.

Sincerely,

G. A. Trevors

Division Manager

Nuclear Support

CAT /rkrijw

cci U.S. Nuclear Regulatory Commission

Regional Office, Region IV

NRC Resident Inspector

Cooper Nuclear Station

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