ML20148J972
| 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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= JAN 2 2 KE8
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.
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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
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L J. CALLAN
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L. J. Callan, Director
Division of Reactor Projects
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Guy Horn, Division Manager-
of Nuclear.0perations
Cooper Nuclear Station
P. 0. Box 98
Brownville, Nebraska
68321
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Program Manager
FEMA Region 7
911 Walnut Street, Room 200
64106
Director
-Nebraska' Civil Defense Agency.
'1300 Military Road
Lincoln, Nebraska 68508
Kansas Radiation Control Program Director
Nebraska Radiation Control Program Director
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R. D. Martin, RA
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L. Shea, RM/ALF
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Project Engineer, DRP/C
RSTS Operator
W. Long, NRR Project Manager
R. E. Hall
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W. L. Fisher
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GENERAL OFFICE
Nebraska Public Power District
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NLS8700649
December 10, 1987
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U.S. Nuclear Regulatory Commission
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Attention:
Document Control Desk
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Washington, DC 20555
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Gentlemen:
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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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.U.S. Nuctsar R1gulctory Commission
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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.
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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,
and as a consequence the valve inspection team was not dispatched until
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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
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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
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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.
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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
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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
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U.S. Nuclear Regulatory Commission
Regional Office, Region IV
NRC Resident Inspector
Cooper Nuclear Station
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