ML20195H469
| ML20195H469 | |
| Person / Time | |
|---|---|
| Issue date: | 11/17/1998 |
| From: | Stewart Magruder NRC (Affiliation Not Assigned) |
| To: | Essig T NRC (Affiliation Not Assigned) |
| References | |
| PROJECT-689 NUDOCS 9811230364 | |
| Download: ML20195H469 (73) | |
Text
' _ , }'
hfygd NIU un g 4 UNITED STATES j j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20066 4 001 4
\*****/ November 17, 1998 MEMORANDUM TO: Thomas H. Essig, Acting Chief Generic issues and Environmental Projects Branch i Division of Reactor Program Management Office of Nuclear Reactor Regulation FROM: Stewart L. Magruder, Project Manager Str M d. .h .
Generic issues and Environmental Projects Branch ;
Division of Reactor Program Management ;
Office of Nuclear Reactor Regulation j
SUBJECT:
SUMMARY
OF OCTOBER 29,1998, MEETING WITH THE NUCLEAR ENERGY INSTITUTE (NEI) REGARDING EMERGENCY PLANNING ,
PERFORMANCE MEASURES I On October 29,1998, representatives of the Nuclear Energy Institute (NEI) met with representatives of the Nuclear Regulatory Commission (NRC) at the NRC's offices in Rockville, Maryland. Attachment 1 provides a list of meeting attendees.
Ti;9 purpose of the meeting was to discuss the development of performance measures to be used by NRC to aid in assessing emergency preparedness at operating nuclear plants. The handouts from the meeting are included as attachment 2.
The following topics and actions were discussed at the meeting:
The group discussed the draft NRC document on Emergency Preparedness (EP)
Performance Indicators (PI's) (Attached)
Action: NRC to collect comments and revise for next meeting (11/5/98)
NEl discussed industry acceptance of the draft PI's and the scope of the existing regulatory burden.
NEl questioned the interface between these PI's and the proposed use of PI's to replace the 10 CFR 50.54(t) audit function. There was consensus that the pending change in regulations should not impact this effort.
NEl suggested that NRC discuss with the Federal Emergency Management Agency
}/
(FEMA) the use PI's to assess the efficacy of offsite EP programs. NRC stated that g should FEMA decide to use PI's it would be acceptable, but that the decision to do so would be FEMA's and this working group has no influence with the FEMA process. NEl y(0' provided a copy of their comments on the FEMA Program Strategic Review httached).
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9811230364 981117 "#
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- The group discussed the selection of failures under the draft P1 process. There was agreement that some selection criteria for risk significant failures was appropdate.
Action: NRC to address in future revision of draft PI's.
The group discussed the weighting of Pl statistics for the more risk significant items.
Some consensus was reached that elaborate formulas were counterproductive and each individual event should be simply counted in the gathering of statistics.
NRC discussed how the number of drills and other opportunities to gather Pl statistics affects the voracity of the PI, i.e., the more opportunities, the more certainty that the Pi is accurate. There was recognition that this was appropriate.
NEl questioned how self assessment contributes to the Pl and how this could compensate for a lower number of statistical opportunities. Consensus was reached that self assessment was an important element in several areas and could contribute to the quality of an EP program and thereby compensate for a lower number of statistical opportunities. But it was recognized that modification of PI numerical values based on the efficacy of a self assessment program was not being considered.
=
NEl stated that industry was concerned that the implementation of this process be done by a core inspection team to ensure consistency. They were concerned that differences between regional management and individual inspectors not negate the beneficial aspects of the Pi initiative.
Action: NRC to relate that concern to the Pl working group.
NRC and NEl discussed historical data related to the proposed PI's that could be obtained from past inspections. Data from 1997-98 was available and supplied by NEl (attached). A brief review of the data was performed by the group and there was consensus that development of thresholds for PI's could be based on the historical data.
Action: NRC and NEl to analyze data before the 11/5/98 meeting and meet with personnel with knowledge of the statistical use of such data to determine if the process could work to set threshnids.
Project No. 689 Attachments: As stated cc w/att: See next page s.
.=
The group discussed the selection of failures under the draft PI process. There was agreement that some selection criteria for risk significant failures was appropriate.
Action: NRC to address in future revision of draft PI's.
r l .
The group discussed the weighting of Pl statistics for the more risk significant items.
Some consensus was reached that elaborate formulas were counterproductive and each individual event should be simply counted in the gathering of statistics.
l l
l NRC discussed how the number of drills and other opportunities to gather Pl statistics l l affects the voracity of the PI, i.e., the more opportunities, the more certainty that the PI is accurate. There was recognition that this was appropriate. -
. NEl questioned how self assessment contributes to the Pl and how this could l
compensate for a lower number of statistical opportunities. Consensus was reached that self assessment was an important element in several areas and could contribute to the quality of an EP program and thereby compensate for a lower number of statistical opportunities. But it was recognized that modification of PI numerical values based on the efficacy of a self assessment program was not being considered.
NEl stated that industry was concerned that the implementation of this process be done by a core inspection team to ensure consistency. They were concerned that differences between regional management and individual inspectors not negate the beneficial aspects of the Pl initiative.
Action: NRC to relate that concern to the PI working group.
l
+
NRC and NEl discussed historical data related to the proposed PI's that could be obtained from past inspections. Data from 1997-98 was available and supplied by NEl (attached). A brief review of the data was performed by the group and there was consensus that development of thresholds for PI's could be based on the historical data.
Action: NRC and NEl to analyze data before the 11/5/98 meeting and meet with personnel with knowledge of the statistical use of such data to determine if the process could work to set thresholds.
Project No. 689 Attachments: As stated cc w/att: See next page !
DISTRIBUTION: See attached page OFFICE PM:PGEB PERB SC:PGEB NAME SMagruder$w# RSullivan E h Mlebcz DATE 11/ Q /98 11/13/98 11/ ///98 i'
I i
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Distribution:. Mtg. Summary w/ NEl re EP Performance Measures Dated November 17, 1998 Hard Cooy PUBLIC .
PERB R/F OGC ACRS SMagruder RSullivan
-py9a4 9.t4 ,
EMail . .
SCollins/FMiraglia ;
BSheron -
BBoger. j
'JRoe -
DMatthews TEssig '
I CMiller PZalcman RSullivan '
FKantor SRoudier SMagruder GTracy, EDO 1
4 ee
L'o. - _ . .
t
! NEl/NRC MEETING ON EP PERFORMANCE MEASURES 10/29/98 List of Attendees Name Oraanization
~ A. Nelson NEl 4 B. McBride VEPCo b D. Stellfox McGraw-Hill ~
R. Sullivan NRC/NRR
- F. Kantor NRC/NRR S. Roudier NRC/NRR i
1 Attachment 1 1
I r.
- u. - - -
.- .. . . .-_ , -- __ ___. ~ _.
_ - .. . . _ . - . . . - .. . . . ~ . . . -
. t Total Emergency Preparednese Findings 1997-1998 5
0 5 10 15 20 25 f ,
Stowns Ferry Conn,Yattee i
Byron --
Crystalber a came Canyon -
I Quane ArnoW M onna <-
McGuye .. I kne Mile Pomt -
Prune ishand :-.
. Robeson v.--
San Onotre -
geanroon ......
Sequoyah w South Tesas - ~ -
Surry M susquehanna <
j vermont Yartes ~
Beaver Valey Brunswek Dreseen ---
Indian Pont 2 M umenck g33lx3 Monticelle a--
Pegnm ~~~.
Ouad Ca.s -
TMI --v v-vogtie WoM Creek --
Bradwood -
has - - - - -
Kewaunee --
Oysist Creek -- -
Perry -
Turkey Poet -
Artusnsas k-- -
co. - - -
Dave 4este - - - -
I River Sand - -
whp3 -
Calvet Ces ---
Fort Caboun a saa.
Paio verse Zen -
cp, .
Grand out -
Watodord - -
Maastone -
Caiaw., -
, - Comanene Pe. ,
! Chmen l
Attachment 2
l ' s ,. + c.
Emergency Preparedntss Findings /
} l
- 1997 - 1998 //
L sE30'estlytinsp ^ i_ -,Mr#4}s ^ Z V2alIFilURl[#loistion Weaknees l l Accident Assessment Exercises - 4 4
~ ~ ~
Ic2ident Assessme5~~ Inspections 2
~ ~~ * '
l ~8 -
Emergency Action Level IExercises 1 1
- d. -4 Emergency Action Level Inspections 4
2 U- ~~~ ~
- { Emergency Action Level Real- Eventsil5)if 1 j
' Event Recognition " Exercises 1 1 2
~
- Event Recognition inspections 1-
~ ~ *
- Event Recognition *Ne~al Events LERs 2 -
" ~
-:: 3.7.ct Interface wrm - - 9 ^ * == - 2 Offsite Agencies !
Direct interface with ilns 1 I Offs,ite. Agencies _[ pections L,,,,,,,
f Direct Interface with
,_ , i
!Real Events LERs 1 !
/. ,Offsite Agencies _,l _
l
- I Adequate Communication Exercises ,1 1 2 l
)
~
Channels
- Alert and Notification
- Exercises 1 I 3 System _
j Alert and Notification _Real Events LERs 1 2 1
- i. . System t_,,, _ ,, .
Direct Interface to Offsite Exercises 1} 1 3
- * * *~~
Direct Interface to Offsite Inspections 1
. 4 Direct Interface to Offsite Real Events LERs l 2
- - . - + . . - .
- 1 .
Direct Interface with Exercises 1 O
i _ffsite Agencies _ _ _
Direct Interface with Real Events LERs 15 Offsite_ Age,nc,ies,, . . ._.,
I Exercises
- ll1 Direct Interface with l 1
.Offsite Agencies ,,,,,__ _ ! ,'
Accident Assessment Exercises 2 i 1 4 Accident Assessment *Inspectioris 1 ,2 1
~~ * *
- Activation of Emergency *5xercises 1
?g\
,, Response Organization ,
Adequate Communication Exercises 1 Channels Direct Interface with Exercises 2 Offsite Agencies , 3 Other Exercises, 1 f
. a . .
j .
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Page1 10/28/98
o ,.. - ..
Emergency Preperedness Findings 1997 - 1998 Category ]unneSub Categorylite 4l l:Sut> Category 22 l IFl l URt l Violation l Weakness ill Other jinspections 1
~ *
Protection of Emergency Exercises 1 1 8 Workers *
- 1 i
Protection of Emergency Inspections 2 Workers Protection of Emergency !Real Events LERs Workers i 1 *I IV Activation of Emergency 'sxercises 5 1 4 Response Organization _ _ , ,
1
]
3 Activation of Emergency inspections 2' 8
, .. Response Organization , ,
Activation of Emergency Real Events LERs 3' 2 O9 ,_
Response
Adequacy Organization of Facilities , . . . Exercises 2 1
1 Adequacyof Facilities inspections 4 3 11 l
} Adequacy of Facilities Real Events LERs 1 Other Exercises 6 1 1 2
~~* * * '
Other Inspections 5 2 18
[ Other Real Events LERs # fT j 2
i I V Other Real Events LERs 1f i l
. 1 -
J J
l l
Page 2 10/28/98
Em rgency Preparedness Findings )
1997 - 1998 Exercise Summary l
- s ;hExercise.!Typea sese:4%mberk Annual drill 5
' Biennial Exercise 18 Null-Participation Exercise 12 i
Plume Exposure Exercise 12;
$I?$k5bh5b Drill b$$S5$j $N$ 26 7
Medical Emergency Drill --i 2
,R
- i. adiation Protection /Fie'id Team Drill 1 1
@emediat OSC Exercise ISimulator Walkthrough 9
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1 Page 3 10/28/98
l s ,. ..
l l Emergency Prep: redness Findings l
1997 - 1998 Plant Summary
+ gSitmName aliFilVRilViolabon]WeaknessDsTotainl .
Browns Ferry 0 Conn. Yankee 0
' Crystal River 1 1 Duane AmoM 1 1
- ~
Ginna 1 1 McGuire 1 1 g
[ ine Mile Point 1 l 1 Oconee l l 0 Prairie Island 1 1
~
1 1
[ Robinson 1 1 1 gan Onofre Seabrook .
1 1 i
' ~ ~ '
Sequoyah 1 i 1 ISouth Texas
- 1 1 (Susquehanna 1 L 1 1
Vermont Yankeej_,,,, J '
1 Beaver Valley 1 1 1 2 Iilrunswick l .
1 1 2 Byron }1 I 1 Diablo Canyon j_,,,, 1 j 1 Dresden i1 1 2 Indian Point 2 l1 i 1 2
((imerick [ 1 1 2 "Monticello
- j. 2 ...-
.- .a .
I l 2 g
Surry ,
2
[ 1 1 2
TMI i l
Vogtle 1 1 l l '
2 t
Wolf Creek i~ ~' [^ 2 2
[Braidw'ood 72
- 1 l 3 Harris i 2 i 1 3 Kewaunee g,,i_ 3
, Oyster Creek 2 1 1 i 3
[5'erry 2 l 1 3
~
Igilgrim. 2' 2 Turkey Point 1 1 1 3 5
River Bend 1 1 i 1 4 Arkansas 1 [
3 4 I Fort Calhoun 1 2 2 5 l Palo Verde 3 2 5 l 'Iion I~I' 1 5 3 I^ 1 5
[Calvert diiffs ]1 ,
jCook j3 1i j 4 Page 4 - 10/28/98
i Emergency Preparedness Findings ;
. 1997 - 1998 1
- es Sao Nemo millR]URil Violation l Weakness le 6 Total 42 {
l Cooper 1 5 j 6 Davis-Besse 4 4 J
1 5 6
[ Grand Gulf
. ila Salle 2 1 2 5
'Waterford _
-3 3 j 6 WNP2 3 4 E D 008- l
{_.J 5 1
i 7
}Callaway
.1 ! ,,,,,,,,,,3
[.3.. {26 }
j 3
3 8
10 Comanche Peak {,,,,1 ;
9.linion ,p5L3, ,
5 _,[ j 23 l
i l
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Page 5 10/28/98
_.e m. e. , - ~ - - . v- t w w e--= , -
- Emergency Preprredness Findings l . 1997 -1998 l
Inspection Tcategory< subcategory 1 $ sutwategory 2;l lFl l URi l Violation l Wednew I Accident Assessment Exercises 4 4
> + -
Accident Assessment in~spections 2 i l
- I Emergency Action Level Exercises 1 i 1 l
Emergency Action Level Inspections 2
- 5mergency Action Level 'Real Events LERs I 1 I
' ~~"
svent Recognition Exercises 1 i 1 2 i*
- C Event Recognition ilnspections 1 l
Event Recognition Real Events LERs 2 I
Accident Assessment Exercises IFI Dresden 97 14 Duplicate No Date Entered 10/26/9 Safety No 8
Dunng the licensee's later review of the emergency implementing procedures for the loss of annunciator Alert classificanon. they idennfied that the basis for this Alert EAL lacked clancy on whether the loss of one of three control roorn monitoring s> stems or loss of au three systems were required in addition to the loss of annunciators to declare an Alert. Licensee actions to clanfy the EAL basis will be tracked as an IFl.
IF1 Grand Gulf 97 15 Duplicate No Date Entered 10/27/9 Safety No 8
he licensee's dose assessment methodology wiu be reviewed in a future emergency preparedness inspection to detenmne if the potennal for non<onservanve protective action recommendations exists. Dose from the pre-exisung plume within the emergency planrung zone was ignored,thereby yielding non-conservauve dose projections.
IFl Ginna 97-04 Duplicate No i
Date Entered 10/27/9 Safety No 8
( The Maintenance Auessment M.mager, and Radiation ProtectiorKhemistry Manger missed this opportunity to leam and document important information available from team memters. For example the (scenan%eneral area dose rate around the A residual heat removal pump breaker was esumated to be 40 IWr. De healt physics tech.
Page 6 10/28/98
- Emergency Preptrednzss Findings I
! . 1997 - 1998 Found actual (scenario) dose rate to be 25 R/hr in the area. This infonnanon was not reported to, or logged by, I the RP, Chem Manager. This information would have been valuable in planrung and preparation for other possible I I
entnes mio this area. %e health physics technician did later in the excretse document survey information.
however,these surveys were not provided to the RP/ Chem Manager in the TSC/OSC, he failure to perform debriefings, desenhed in the licensees procedure EPIP l 12," Repair and Correcnve Acnon Guidelines Dunng Emergency Situations " Section 6.6,
- Debriefings," is considered an inspection follow up item.
IFl Monticello 97 16 Duplicate No Date Entered 10/26n Safety No 8
Field Monitoring team pioblems. Teams had difficult finding their present locanon and their assigned destinations because their maps did not accurately reflect the roads in the area.
Weakness Comanche Peak 9744 Duplicate Yes Date Entered 10/27s Safety No 8
9744-02: he inspector concluded that the emergency coorduiator did not demonstrate confidence or full fanutianty with established process or procedures for determuung protecuve accon recommendanons to the extent that it resuited in an untimely nottfication and protecnve acuon recornmendation. Moreover,had this been a real emergency, the licensee's credibility with the offsite agencies could have been diminished given the display ofindecisiveness. he failure to make a tunely notificanon and protective action recornmendation was identified as an exercise weakness due to the potennal impact Weakness Turkey Point 97-05 Duplicate No Date Entered 10/26n Safety No 8
Failure to perfonn a prompt damage assessment of safety-related equipment Page1 10/27/98 Page 7 10/28/98
Emergency Preparedness Findings 1997 - 1998 I
Accident Assessment
- Weakness Grand Gulf 97-09 Duplicate No Date Entered 10/27N Safety No 8
Failure to satisfaaori!y perform dose assessment activities to support emergency classificanons. Dose assessment acovities were not sansfactonly performed by the shift chemists dunng the walkthroughs; some dose projections were untimely, incorrect, and incomplete, and results were not correctly comrnunicated to the emergency director.
Weakness Wolf Creek 98-07 Duplicate No Date Entered 10/22 S Safety Yes 8
A performance weakness was identified involving one crew that failed to property assess plant conditions which required upgradmg to a general emergency. he second crew properly dec ared the emergency but required 18 minutes to assess plant condmons, exceeding the 15 mmute goat inspeCdons IFl Callaway 98 14 Duplicate No Date Entered 10/22 S Safety Yes 8
The failure of the pnmary nonfication system and the transuion to the backup system caused some minor delays in offaite agency noufications during the first walkthmugh. De second crew did not clustfy one of three events in a timely manner because an emergency operanng procedure conflicted with an emergency implemennng procedure. De procedure for emerlency operanng procedure usage stated that emergency action level determinanon commences after exitmg the reactor tnp procedure. He classtficanon procedure required clautficaton when abnonnal readings indicate an emergency situanon has occurred. The first crew did not have the same problem because it entered the reactor inp procedure later in the scenario. he delayed clasnfication was idennfied as a performance weakness.
IFl Crystal River 97 08 Duplicate No Date Entered 10/26M Safety No 8
Unacceptable variance in classtfying scenarios among a representative sample of Emergency Coordinators.
Inspectors noted different classtficanons in 10 of he 13 scenarios presented to the interviews.
Emergency Action Level Exercises IFl Monticello 97-16 Duplicate No Date Entered 10/26s Safety No 8
Clanfication needed to EAL Guideline 28. His delayed the GE declaration by approx. 20 minutes Weakness Robinson 97 13 Duplicate No Date Entered 10/26n Safety No 8
NOUE declaration was not timely snade when EAL was exceeded InspeCdons Page 8 10/28/98
i 1
Emergency Preparedness Findings '
1997 - 1998 l I
i Emergency Action Level
"!F1 Susquehanna 97-01 Duplicate No Date Entered 10n6B Safety No 8
During the inspection the inspector detemuned that the licensee contmued to make changes to the current (hTREG 0654) EALs to meet the NUREG 654 EAL guidance throughout the period. The Licensee indicated to the inspector that it is uncertain about whether it will continue to seek NRC approval for the NUMARC NESP007 EALs or update the current EALs. This maneris being tracked as an IFI.
I IFI Quad Cities 97-26 Duplicate Yes 1
Date Entered 10/26M Safety ' No l 8
IFI 97-026-05 During scenano the shift manager declared an unusual event. However the dnll controllers prompted the shift manager to declare an alert. During the recent 1997 Dresdea exercise, the corporate office of Come Ed determined the basis for the EAL MA6 needed clanficanon on whether the loss of one of three control room monitoring systems or loss of all three systems required,in addition to the loss of annunciators,to declare an ;
alert. 1 Real Events LERs weakness Sequoyah 97 15 Duplicate No Date Entered 10n6s Safety No 8
1he delay in dectanng a NOUE dunng the October 5,1996 transfonner explosion was a weakness in the plant's emergency preparedness response. The NOUE was declared 59 minutes after the event was initiated and 33 minutes after the control room was returned to normal.
l Event Recognition Exercises IF1 Oyster Creek 97-08 Duplicate No Date Entered lon6s Safety No 8
Emergency Control Center crew's decision to shut the MSV's with an existmg A1WS was an NRC concem Wiation TMI 97-02 Duplicate Yes Date Entered lonos Safety No 8
Dunng the Mi-panicipation exert:ise on March 5.1997, the EPIP procedure TMI. 01 was not followed in that the Emergency Director failed to classify a general emergency when such a declaranon was warranted due to the simulated loss of the three fission product barners, as of March 5,1997, emergency response trauung was not adequate and procedures contained insufficient guidance for considenng protecove action recommendations (PARS) teyond the 10Lmile EPZ. As a result, emergency response management did not communicate recommendanons for PARS forresidents beyond the lanule EPZ when plume dose projections appeared to indicate ihat protecnve acuon giudehnes would be exceeded beyond that zone dunng the full participanon exercise on March 5,1997.
These violations in Section IV represent a Seventy Level III problem (Supplement 1). Civil Penalty . S55/200.
Weakness Cooter 98 12 Duplicate Yes Date Entered lon2s Safety Yes 8
The failure of one crew to effecuvely implement key elements of the emergency plan (e.g., emergency director oversight,protecove action recommendations,offnte agency nottficanons, and emergency classificanon) dunng simulator walkthroughs was identified as an exercise weakness.
Page 9 10/28/98
Em:rgency Preparedness Findings 4 -
1997 - 1998 I l Event Recognition
- Weakness Palo Venie 97 10 Duplicate No
- Date Entered 10/26S Safety No 8
Failure to recognize and classify the notification of unusual event inspections
!F1 Quad Cities 97-26 Duplicate Yes Date Entered 10/26s Safety No 8
IFI 97-02645. Dunng scenario the shift manager declared an unusual event. However the dnll controllers prompted the shift manager to declare an alert. During the recent 1997 Dresden exercise, the corporse office of Come Ed detemuned the basis for the EAL MA6 needed clarification on whether the loss of one of three control room momtonng systems or loss of all three systems required,in addition to the loss of annunciators, to declare an alert.
Real Events LERs Violation River Bend 97-08 Duplicate No Date Entered 10/273 Safety No 8
On May 6.1997, the licensee failed to follow Procedure EIP-20)I in that the licensee entered Technical Specificsion Laiting Condition for Operation 3.4.5 upon detemunation that pressure boundary leakage existed, but did not declare a Notificanon of Unusual Event until prompted by the inspectors on May 7,1997.
His is a Seventy LevelIV violation Violation Hams 97-01 Dopticate No Date Entered 10/27S Safety No 8
Maintenance personnel found a cat wire in the rnotor control cabinet for the turbine building vent stack radiatiori
, morutor at 1:2.5 p.m. He wire had been pilled out of a winns bundle, cut, twisted together, and left in the front of the panel Secunty declared a Secunty Alert at 2:00 p m. based on the cut wtre and that tampenng could not be ruled out.
De NRC was notified of the physical secunty event under 10 CFR 73.71 s 2:25 p.m., A Secunty guard was posted at the motor control panel, personnel access entnes to the protected ases were reviewed, and a search of the protected area was conduced.
De operations stuft supenntendent had worked through the Emergency Action Level (EAL) Flow Path from PEP 110 with the Secunty Manager pnor to the 2:25 p.m. NRC notification. De understanding of the shift superintendent was that a Secunty Emergency had not been declared, and therefore the flow path (side 1) did not requut an EAL flow path declarmion. In discussing the security event classificsion at approximsely 3:00 p.m.
with the mspector,the shift supennten:iant found out that a Secur:ty Alert had been declared. He immedimely confumed this with the Secunty Manager.J at 305 p.m. declared a Notice of Unusual Event (NOUE).
Notificanon Worksheet sent from Security to the Main Control Room did not identify that the ev:nt had been classified as a Secunty Alert,the bcensee determined that the shift supenntendent has sufficient information conununicsed to him to have declared an NOUE at the time of the 10 CFR 73.71 declared and notification (2:25 p.m.).
His licensee identified and wnected violation is being tresed as a Non-Cited Violanon.
Page 10 10/28/98
1 Emergency Prep; redness Findings 1997 - 1958 II D Category h Sutwategory 1re it sutWategory 231 IFi l URI I Violation Weekness 11 Direct interface with Exercises 2
.Offsite Agencies ,
Direct Interface with inspcctions 1
~ Offsite Agencies
- i Direct interface with ~5 eat Events LERs 1 Offsite Agencies _
Adequate Communication _. Exercises 1 1 2 Channels Alert and Notification System Exercises ~~ T 1 I~~~3
_ _ _,_..1 1 -
Alert and Notification jReal Events LERs 1 2 1 i System .L .
Direct Interface to Offsite Exercises 1 3
^ '
"~*' Direct interface to Offsite " Inspections 1
' ^ *
- Direct interface to Offsite 5eal Events L555~'~5'
)
~
Direct Interface with ' Exercises i 1 !
..Offsite Agencies ..
I j
Direct Interface with Real Events LERs 1 Offsite Agencies i 1
I 1
1 Direct Interface with Offsite Agencies l Exercises Weakness Palo Verde 97 10 Dupucate No Date Entered 10/26 S Safety No 8
Failure to make required offute agency notificanon Weakness Oyster Creek 97-08 DupUcate No Date Entered 10/26/9 Safety No 8
Failure to noufy state authonties wnhin 15 nunutes of the Site Area Declarcion InSpeCdons Violanon Palo Verde 97 21 DupUcate No l
Date Entered 10/26/9 Safety No 8 2 Late notification of state and local officials dunns Feb 25.1996 notdication of unusual event Real Events LERs i Violation Diablo Canyon 97 19 DupUcate No Date Entered 10/26/9 Safety No j 8 1 During the reactor inp and safety injection event of October 24,1997, the bcensee declared a NOt rE at 8:32 am.
I Page 11 10/28/98 l
L ,
Emergency Prepiredness Findings 1997 - 1998 ;
Although Procedure EP G-3 required the licenses to pmytde updmes to state and county officials every 30 minutes when the entergency plan was activated, the hcensee provided no other follow up communications to state and local agencies untd the event was terminated. As a result, these agencies were not provided with updates for approximsely I hour.
County officials were nottfied at 9:52 a m. (14 minutes) and state officials at 9:54 a.m. (16 minutest. However Procedure EP G.3 required that same and local authorities be nonfied within 15 nunutes.
- The failure to update state and local officials every 30 minutes, and to nonfy state oDicials c! termination of the emergency plan within 15 nunutes. is a violation of Procedure EP G-3 and 10 CFR 50.54 (q). This non-repennve.
licensee-idenafied and corrected violation is being tremed as a non<:ited violation.
l Adequate Communication Channels Exercises IF1 La Saue 98-08 Duplicate No Date Entered 10/22/9 Safety No 8
The initial notification to the Staae and local agencies was completed within the regulatory time hmits. However, the Emergency Notification System (ENS) nonficatka to the NRC conceming the Alert declaration was not made unmediately fouowing the notification of appropnate offsite officials as required.
I Page 5 10/27/98 l
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Page 12 10/28/98
l.. .
Emergency Preparedness Findings 1
1997 - 1998
! H 1 l
Adequate Communication Channels
- Violation Comanche Peak 97 04 Duplicate Yes l
l Date Entered 10/27B Safety No 8 l as of February 12,1997, the licensee had not coneaed a weakness involvsng implementation of site evacuation I procedures that was identified dunns an emergency preparedness inspection conducted dunng the penod Sepember l 25 29.1995. Dunna the Sepember 1995 inspecnon, the emergency coordnator did not consider wind direction I when evacuating personnel from the site; personnel were instructed to evaluate through the simulated plume.
Dunng this inspection. a site evacuanon was not ordered in a timely manner. Both faalures were attnbuted to procedural adherence. l This is a Seventy Level IV violation (Supplement VIII) (50-445S704-03: 50 446S704-03). j Weakness Wolf Creek 97-02 Duplicate No l l
Date Entered 10/26 9 Safety No 8
Five examples ofineffective intemal and external techmcal support center communicanons. Two instances where communications between the control room and techrucal support center resulted in the TSC not berig aware of plant conditions. TSC management did not bnef center staff on probable failure paths in the emergency acnon levels of conditions that would cause event escalanon. The commurucanon between the control room and the j
'13C concenung the condensate storage tank damage was not clearly conununicated. The tenninology used to 1 descnbe the main steam hne break to technical support center personnel caused some confusion. The failure to accurately communicate that the RHR system was to be sampled, rather than the post-accident sampling system, funher delayed the reactor coolant system cooldown and release terminanon.
1 1
Weakness Arkansas 97-10 Duplicate Yes ;
Date Entered 10/26 S Safety No 8
97 1(M)2 De failure to satisfacionly implement site evacuation procedures was idenafied as an exercise weakness due to the potennal impact to plant personnel Alert and Notification System Exercises l 1
URI Fort Calhoun 97-04 Duplicate No I Safety l Date Entered 10/27B No 8 l Dunng the exertise, the inspecton observed that one of the nonficanon forms did not have an authonzation signature,but the nonficanon to offsite agencies had been made. When the forms were reviewed after the exercise, all of the fonns had been signed. The signature on the form that was originally unsigned was significandy different from the rest. The Emergency director stated that it was not his signa:ure.
1 Weakness Callaway 97 13 Duplicate Yes Date Entered 10/279 Safety No 8
97-13-01 The inspectors detennined that programmatic factors caused a delay in making timely offsite agency i
nottfications (I.e., within the 15 nunute regulatory hmit). In response, the licensee considered the nonfication
! timely based on the alert declaranon los entry (15 minutes vs.17 minutes). The inspectors concluded that there l
! were programmatic reasons for the delays: 1) lack of clear understanding about when the nonfication period starts.
- 2) the use of communicators who were not stationed in the control room, and 3) a lack of familianty with the i new electronic nonficanon system. Due to the programmanc factors,the inspectors identified the failure to make I timely offsite agency notificanons as an exercise weakness I
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Emsrgency Prep rzdness Findings 1997 - 1998 11 Alert and Notification System
-Weakness Brunswick 98-01 Duplicate No Date Entered 1042/9 Safety Yes 8
The EOF failed to fulfill a prunary facility responsibtlity by not providing off site agencies with off site Protecnve l Action Recommendations (PARS)in a tunely manner. This failure was identified as an Exercise Weakness.
Weakness Cooper 98 12 Duplicate Yes Date Entered 10a2s Safety Yes 8
The failure of one crew to effectively unplement key elements of the emergency plan (e.g., emergency director ,
oversight, protecuve action recommendaions, offsite agency nonfications, and emergency classtfication) during sunulator walktluoughs was identified as an exercise weakness.
Real Events LERs IFI Chnton 98-09 Duplicate No I Date Entered 1042S Safety Yes 8
The licensee detemuned that the non-hcensed operator (NLO) assigned to make initial offsite notificanons was unsurs of his dunes for making offsite notifications and was communicating with some dtfficulty.
URI Clinton 98-03 Duplicate No Date Entered 10/22/9 Safety Yes 8
Approximately two hours elapsed between the time the discrepancy (ND 6685 computer had stopped updating the buffer computer) was identified and the tune current radiologmal and meteorological information was transnutted to the NRC,lDNS, and the EOF. The inability to transmit current radiological and meteorological data wittun one hour of dectanns an emergency classificanon is considered an Unresolved item.
URI Clinton 98-03 Duplicate No Date Entered 10a2s Safety Yes 8
The licensee detennined that the N10 assigned to make initial nonfications was unsure of his duties for making offsite noufications. The shift technical advisor (STA) was required to relieve the NLO and perform the iruttal offsite notifications. The inappropriate use of the STA to perform off site noufications was previously documented in NRC Inspecuon reports 9610 and 97-02.
Violation Chnton 98-09 Du,nlicate No Date Entered 10/22M Safety Yes 8
he ERDS system was not initiated within one hour of the declaration of an Alert. Specifically, ERDS was initied one hout and seventeen nunutes after the event declaration.
His is a Seventy Level IV violation (Supplement 8)
DirectInterface to Offsite Exercises I
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Emergency Preparedness Findings 1997 - 1998 H
DirectInterface to Offsite "lF1 Z .on 97 29 Dupucate No Date Entered 10/26 S Safety No 8
IFI 97 29 01 The communicator initially did not follow available guidance and initially contacted towa officials regarding the Unusual event declarmion. The communicator son cormaed his error and rnade use of the available guidance when making this and subsequent irunal nonfications of Illinois and Wisconsin officials within the regulatory nme hmit. Conect use of the nonfica: ion procedure and checklist was an IF1 1
i Weakness Callaway 97 13 DupUcate Yes Date Entered 10/27 S Safety . No I 8
97 13-01.ne inspeaors determined that programmnic facors caused a delay in making timely offsite agency nouficanons (I.e., within the 15 minute regulatory limit). In response, the licensee considered the nonficanon timely based on the alert declaration los entry (15 nunutes vs.17 minutes). he inspectors concluded that th re were programmanc reamaa fa the Mays: 1) lack cf clear understandsig about when the nonfication period as, j
- 2) the use of communicators who were not stationed at the control room, and 3) a lack of fanulianty with th new electronic notificanon systent Due to the programmatic factors,the inspectors idenuried the failure to n ,
turnely offsite agency notificanons as an exercise weakness I
Weakness Suny 97-08 Dupbcan. No Date Entered 10n6s Safety No 8 ;
An Exercise Weakness was idenafied regarding news releases that did not accursely portray release informanon and wm not coordinated with the Recovery Manager.
Weakness Comanche Peak 97.ru Dupucate Yes Date Entered 10/27/9 Safety No l 8
974u12: he inspector concluded that the emergency coordmator did not demonstrate confidence or full l familianry with established process or procedures for determining protecuve acnon recommendanons to the !
extent that it resulted in an untimely nonficanon and protecnve acnon recommendation. Moreover, had this been a real emergency, the hcensee's credibility with the offsits agencies could have been dimuushed given the display of indecisiveness he failure to make a tunely nonficanon and protective action recommendation was idenafied as an exercise weakness due to the potennal unpact.
Inspections Violation Fort Calhoun 47 02 Dupucate No Date Entered 1047S Safety No 8
During review of licensee documents relsed to the nonficanon of unusual event that was declared on December 31,19%, the inspectors discovered that the bcensee expenenced commtmicanon problems notifying the state and local authonties during the initial nottfication. De control room communicator attempted to make the required nonfications to the state and local govemment agencies approximately 14 minutes after the event declaranon.
However, the conference operations network phone dtat was used as a pnmary method of nonfication was " dead."
he communicator uutimed the notifications using the backup method of contacting each agency via the commercial phone system. Dunng the call to the first offsite agency,the communicator nonced that the phone line was disconnected from the conference opersions network phone. He communicator plugged the phone Ime into the phone and completed the noufications usms the conference operations network phone.
10 O'R Part 50, Appendix E.Section IV.D.3, states,in part. " . .a licensee shall have the capabihty to noufy responsible State and local governmental agencies within 15 nunutes after declaring an emergency." As a result of the phone problem. De nonfication to the State of Iowa occurred 17 mmutes after the event declaration.
"Ihe late nonficanon was a violanon of 10 CFR Part 50, Appendix E. Accordmgly, the violanon is bemg treated as a Non-Crted Violanon, violation .
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l 1997- 1998 11 DirectInterface to Offsite Real Events LERs F1 Zion 97-08 Duplicate No Date Entered 10a6s Safety No 8
EPIP 1942,"Communicsors " hem 10 of Attachment A,"NARS Fonn, lastructions for Use,* indicated that the individual completing the fonn should,in the addmonal information section of the form, provide additional informaion that will be helpful to personnel evaluation the event . The hcensee had recognized that the communicuor's response was imprnper (Urut number not included) and had wntten a PF Corrective actions in response to this PF will be an E1.
El Zion 97-08 Duplicate No Date Entered 10a6s Safety No 8
The review of tM 2/24S7 Unusual Event conduaed by the Emergency Preparedness Coordinnor noted that the Bulk Power opersions officer did not answer the Ilhnois Nuclear Accident Reporting System telephone DirectInterface with Offsite Agencies Exercises Weakness McGuire 97-12 Duplicate No Date Entered 10a7S Safety No 8
Messages 3 through 6, which were follow-up nordications to the Alert classification, all indicated that the plant condition was stable. In actuality, the plant conditions contmued to degrade during this period of time. Tius failure to provide a conect prognosis to the plant conditwns to the offsite govemmental agencies was iden tfied as an exercise weakness, Real Events LERs FI Chnson 98 03 Duplicate No Date Entered 10a2s Safety No A
The licensee identified that a follow-up message was not relayed to the IDNS for a change in command authonty from the shift supervisor to the Techmcal Sunmn Center . Station Emergency Director. The inspectors identified that the uutial NARS Form was sent at 4:35 tm.: however, the first follow-up telephone call was not made until 6:1Ia.m., a period of I hour and 36 minutes.
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Emergency Prcpnedn:ss Findings 1997 - 1998 LII Category?If* ' Sut>Categoryits %l Sut> Category 2K1 IFt [ URil Violation 1. Weakness-ll1 Direct Interface with ' Exercises 1 Offsite_ Agencies ,
Accident Assessment Exercises 2 1 4
~ ~ * }
Accident Assessment Il~nspections 1 2 1 l
l i Activationof Emergency I Exercises *~~[~~
- f 1
, Response Organization j {
Adequate Communication Exercises 1 Channels * *
- direct Interface with ^5xercises 2 Offsite Agencies Other Exercises 1 Ill *Dther Inspections 1 Protection of Emergency " Exercises I 8 Workers 1l !
P Pidiehtion of Emergency Inspections Workers 2lj Protection of Emergency Real Events LERs 1 Workers ,, , , ,
DirectInterface with Offsite Agencies Exercises Weakness Waretford 97 18 Duplicate No Date Entered 10/26/9 Safety No 8
An exercise weakness was identi5ed because a protective action recommendation upgrade decision was unnecessanly delayed. The decisbn to follow the procedure and make the recommendation in the three additional areas was not made until 3:45 p.m. (20 minutes after the information first became available.
Accident Assessment Page 17 10/28/98
Emergency Preparedness Findings 1997 1998 HI ,
Accident Assessment Exercises IF1 Cook 97 13 Duplicate No Date Entered 10n73 Safety No 8
97013-02De licensee identified that a controller had to intervene dunns PAR development for the second Par when Containment radianon levels exceeded 25,000 R/hrin the containment building. Licenses review of the procedure for possible clanfication is an inspecnon follow-up item.
IFl Kewaunee 97 13 Duplicate No Date Entered 10a7s Safety - No 8
Dunng technically competent discussions in the TSC, accident mitigation items or tasks were desenbed as
prionues." but these were neither listed nor tracked, creanng the potennal that an item or task could be overlooked. Likewise, pnonnes were not utilized in usociauon with the inplant repair teams.
Vioimion TM1 97-(r2 Duplicate Yes Date Entered lon6s Safety No 8
Dunns the full-participation exercise on March 5,1997,the EPIP procedure TMI .01 was not followed in that the Emergency Director failed to classtfy a general emergency when such a declarahon wu warranted due to the sunulated loss of the three fission product barners.
as of March 5,1997, emergency response trauung was not adequate and procedures contained insufficient guidance for considenng protective acuan recommendanons (PARS) beyond the 10 nute EPZ, As a result, emergency response management did not communicate recommendations forPARs forresidents beyond the 10 nule EPZ when plume dose projections appeared to indicate that protecove accon guidelines would be exceeded beyond that zone during the full panicipauon exercise on March 5.1997.
%ese violations in Secnon IV represent a Seventy Level III problem (Supplement 11. Civil Penalty 555,00a Weakness Hams 97 11 Duplicate No Date Entered 10/27s Safety No 8
he inspectors in the TSC observed that the failure of the 13 staff to promptly detect and evaluate the waste gas decay tank leak delayed onsite protecove actions. Despite clae.rindications of an ongoing release in progress, there was no tunely initiation of protective accons for TSC personnel and no sitewide PA announcement to infonn personnel of the release.
Weakness Arkansas 97 10 Duplicate No Date Entered 10C6N Safety No 8
9710 03 he failure to properly asses the amount of fuel damage was identified as an exercise weakriess due to the potential impact on the abihty to accurately make protecnve acnon recommendations.
Weakness Seabrook 98-03 Duplicate No Date Entered 10c2n Safety Yes 8
The licensee did not relay important information promptly and was not aggressive in pursuing issues. There was a three hour delay in irutiating actions to secure an open stearn generator safety relief valve (which was the radiological release path): there were no discussions that correlated increased radiation monitor readings with fuel damage; and reactor coolant chenustry results. indicative of fuel damage, were not acuvely sought or disseminated once available.
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1 Ennrg:ncy Preparedness Findings 1997 - 1998 IH Accident Assessment
" Weakness WNP2 9814 Duplicate No 4
Date Entered 10/22 S Safety Yes 8
A performance weakness was identified for failure of one of two enws to recognize that dose projections indicmed a need for protective maion re-~idons beyond 10 miles.
Inspections
- IFI Clinton 97 02 Duplicate No Date Entered 10/27 S Safety No 8
i IFt 97-02 02. The E-plan did not contain specific -.e.w.ts for on-shift dose assessment. Procedures i provided methodology for the dose calculation. The procedure currently does not include a requirement to unlize the actual meteorological stabibty class, but unlizes default adverse weather conditions meant to be conservative.
Licensee personnel had previously been advised that this was unacceptable, and a commitment was made to revise
' the procedure followmg the current refuel outage. Licensee personnel commstied to modifying the E-plan and appropnate secuons of procedures addressing dose assessment capabibty following the current refuel outage. This wdl be an i ispection follow-up item.
a j Vioiston Chnton 97-02 Duplicate Yes l
l Date Entered 10/27 S Safety No 8
a Condiuon Report (194 10 002) dated September 30,1994, and issued October 3,1994. indicated the the backup meteurological tower wind speed and wmd direction sensors were inoperable. This condition had not been j corrected. The wmd speed and wind direction sensors have been unavulable since October 1994.
This is a Severity Level IV violation (Supplement VIII).
1 Violmion Calvert Chffs 97 08 Duplicate No J
Date Entered 10/269 Safety No 8
97-08-06 'on January 15,1998, methods and techniques for assessing and monitonng actual or potential offsite consequences of a radiological emergency condition were not adequately implemented, dunng tabletop a walkthroughs,in that two technicians functioning as insertm Radiological Assessment Directors, assumed incorrect 4- isotopic concentrations of the radioactive material release source term which resulted in non conservative offsite dose projections.
i This is a Seventy LevelIV viotaion. (Supplement VW Emergency Preparedness)
Weakness Calvert Chffs 97-09 Duplicate No
)
Date Entered 10/26/9 Safety No l 8
j An exercise weakness was identified in the dose assenment area at the Emergency Operanons Fanlity, The dose assessment team produced unreasonable projections due to the operator's lack of understanding and knowledge of i how to manipulate and interpret bcensees automated dose assessment models. Because of this, the hcensee could i not adequately demonstrate that they were able to make a technically sound PAR bued on radiological conditions. I Activation of Emergency Response Organization Exercises I Weakness Arkansas 97 10 Duplicate Yes Date Entered 10/26S Safety No 8
97 10 02 The falute to sansfactonly implement site evacuation procedures was identified as an exercise weakness due to the potennal unpact to plant personnel Page 19 10/28/98 1
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Emergency Prep redness Findings 1997 - 1998 III Adequate Communication Channels Exercises Weakness Grand Gulf 97 09 Duplicate No Date Entered 1047S Safety No 8
Failure to sansfactortly implement site evacuanon procedures. Both crews had core damage and an uncontrolledAmmorutored release for 23 minutes before sounding the site evacuanon alarm. Inspectors used 15 minutes as a reasonable time. He emergency director faded to infonn security of evacuanon routes, areas to be evacuated, and the deshnation of evacuees.
DirectInterface with Offsite Agencies -
Exercises Weaknas Grand Gulf 97 15 Duplicate No Date Entered 10479 Safety No 8
Dunng the wind shift, protective acnon recommendations for three affected sectors (IUK) were not comme *>-A t o offsite authonties as required by the emergency plan and implementing procedures.
Weakness Cooper 98-12 Duplicate Yes Date Entered 1042S Safety Yes 8
he failure of one crew to effecovely unplement key elements of the emergency plan (e.g., emergency director oversight. protective action recommendations.offsite agency notifications and emergency classification) dunna simulator walkthroughs was identified as an exercise weakness.
Other Exercises Violation Comanche Peak 97 4 : Duplicate Ya Date Entered 1047S Safety No 8
as of February 12.1997, the licensee had not correcsed a weakness involving imfementation of site evacuanon procedures that was identtfied dunna an emergency preparedness inspecnon conducted dunng the penod September 25 29.1995. During the September 1995 inspection, the emergency coonhnator did not consider wind direction when evacuatsig personnel frum the site; personnel were instructed to evaluate through the simulated plume.
Dunng this inspection, a site evacuation was not ordered in a tunely manner. Both fattures were attributed to procedural adherence.
His is a Severity Level IV violation (Sumtement VI!D (50445S704-03; 50446S704 03).
Inspections IFI Davis-Besse 97 06 Duplicate No Date Entered 1047S Safety No 8
%e inspectors noted that the projected Lake Erie waterlevel conditions could advenely affect the approved emergency plan evacuation routes dunng certain extreme stonn conditions.
Protection of Emergency Workers I.
Exercises Page 20 10/28/98
Emergtncy Preparedness Findings 1997 - 1998 HI Protection ofEmergency Workers "IFI Davis-Besse 97 07 DupUcate No Date Entered 10/26 s Safety No 8
OSC staff contmued to eat after the OSC Manager had announced that eating, drinking. or chewing ws. nc,s pennised. One ERT member was observed chewing gum across the radiologically restncted area toundary. The poor radialogical control practices during the exercise will be tracked as an IF1.
Weakness Grand Gulf 97 10 Duplicate No Date Entered 10n7S Safety No 8
Failure to estabbsh protecove measures for secunty personnel Failure to perform habitabihty surveys in the secunty island and determine the need for additional protecnve measures was identified as an exercise Weakness.
Weakness Comanche Peak 97 16 Duplicate No Date Entered lon7S Safety No 8
9716-02. An exercise weakness was identif.ed for failure to provide proper radiation protection coverage for teams perfomung tasks outside the power blocks as required by procedures Weakness Indian Point 2 98-07 Duplicate No
, Date Entered 10n2B Safety No 8
A repair team dispatched without them knowing of a sirnulated radiological release in progress.
W akness Fort Calhoun 97-04 Duplicate No Date Entered 10n79 Safety No 8
An esercise weakness was identified related to protective measures (potassium iodide) for onsite personnel. The inspecton determmed that there was a potential for individuals to leave the operanons support center without being bnefed regarding the authonzanon to use potassium iodide.
Weakness Cooper 98 16 Duplicate No Date Entered 10/22n Safety Yes 8
An exercise weakness was identified for the failure to implement proper radiological contamination controls in the TSC and OSC. Additionally,some station workers, including radiation protecnon personnel. did not demonstrate proper ra6harion protecnon practices when respiratory equipment and protecuve clothmg were used.
Weakness Waterford 97 18 Duplicate No Date Entered lonen Safety No 8
An exercise weakness was idenafied for failure of the fire brigade to use required respiratory protectwo while j combanng a fire with toxic smoke in an enclosed space. Personnel did not don the self contamed breathing apparatus before entenng the area as required by the fire emergencyfire report procedure. Not all fire brigade personnel has self-contained breathing apparatus.
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f Emerg:ncy Preparednsss Findings 1997 - 1998 IH Protection ofEmergency Workers Weakness Waterford 97 18 Duplicate No Date Entered 10/26s Safety No o 8
An exerctie weakness was idenafied for failure to unplement proper radiological eaposure controls (dosimetry and contanunation controls). Mulaple examples. Contaminanon controls inconsistent between OSC and the =4 foot l elevanon necess pomt Radiological controls were not property enforced within the OSC. Individuals did not us a l fnsker. Etc.
Weakness Callaway 97-13 Duplicate Yes Date Entered 10/27B Safety _ No 8
9713 02 De inspector observed linuted coordinauon with security personnel concemmg radiological precautions: however, the licensee infonned the inspectors tht radiological precautions were ts.ien for secunty i personnel. Due to the impact on personnel safety,the failure to estabhsh effecuve technical suppon center access
! controls was idenufied as an exercise weakness.
Inspect:ons IFl Arkansas 97 10 Duplicate No l Date Entered 10/26n Safety No l 8 IFl 97 10 01 The inspector concluded that the cunent options of K! distnbution to field tearns were insufficient because they would delay K1 administration and hinder personnel safety. In addition, recalling all field teams could inhibit the licensees abdity to monnorkonfirm offsite consequences.
l I 97 08 Duplicate No l IFl Calven Chffs Date Entered 10/26 S Safety No
[ 8
! The inspectors considered BGE: failure to screen 13C responders for K1 sensioviry to be an oversight wonhy of I
correcove scuon. The inspectors are tracking this item as an inspector follow.up itern to assess BGE's corrective acuons to ensure protection of TSC responders while the control room ve%1 anon is sull degraded.
Real Events LERs IFI Clinton 98-03 Duplicate No Date Entered 10/22/9 Safety No l 8 I The licensee determined that field team mernbers initially brought field samples to the secondary door of the EOF,
! however, since no one was present to answer the door, the field team members brought the field samples into the EOF through the normal EOF entrance. The secondary door is provided to prevent contaminaung the EOF.
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Emerg:ncy Prep redness Findings 1997 - 1998 IV cassoorya w a Meme a lssub category 2;I IFI I URi l Violation i Weakness ]
IV Activationof Emergency Exercises 5 1 1 4 Response Organization Activationof Emergency inspections 2 8 Response Organization .., __.
Activation of Emergency Real Events LERs 3 2 Response _ Organization
, ~
Adequacy of Facilities Exercises 2 1 1_
~* ^
- Adequacy of Facilities inspectionT 4 3 11
~
Adequacy oi Facilities Real Events LERs 1
)
Other '5xercises 6'1 1 2 Other inspections 5 2 18
'Dther Real Events LERs 43 1 i
Activation of Emergency Response Organization Exercises IFl Davis-Besse 97-07 Duplicar.e No ;
Date Entered 10/26 S Safety No 8
None of the welders available to weld the component cooling water hne that was cracked providing a release path to the environment, wers quahfied to wear SCBA respiratory protection. He evaluation of and any subsequent corrective act ons for maintaining sufficient staffing of respirator and SCBA qualdied welders and other personnel i
for emergency response will be tracked as an IF1.
l IFl Oyster Creek 97 09 Duplict.te No l Date Entered 10/26n Safety No 8
Off-hours staffing exercise failed to meet objectives IFl Kewaunee 97-13 Duplicate No Date Entered 10/27S Safety No 8 ,
Use of the "Available Resources" status board was confusing. His status board was intended to provide a rapid overview of available resources forinplant teams. Individuals posted on the board were moved to other locanons on the board. tut not removed from the board.
IF1 Kewaunee 97-13 Duplicate No
(
' i Date Entered 10/27 S Safety No j 8
The inspectors noted that the Auxiliary Operator ( AO) sent to close the stuck open Steam Generator Power Operated Relief Valve was delayed by the Health Physics Process while entenng the Auxiliary building. He AO did not get into the plant for approximately 30 minutes. Procedures did not address expedited dispatch of high prionty repair personnel.
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e Emergency Preparedness Findings 1997 - 1998 IFI Braidwood 98 07 Duplicate No Date Entered 10a2n Safety No 8
(K3 stafnng was slow due to the plant announcement to activate the onsite facihues not being heard dunns the 1998 EP Exercise W Vogtle 97-05 Duplicate No Date Entered loc 6n Safety No 8
At least six indmduals recalled to the site, who responded to the TSC and OSC. failed to sign in on the appropnate emergency response facihty roster data sheet.
Violation Brunswick 98-01 Duplicate No Date Entered 10a2n Safety No 8
Contrary to the above, Revision 46 to the hcensee's emergency plan decreased the effectneness of the plan in that it adoped the regulatory provision for biennial exercises but did not address the requirement in Appendix E to conduct a dnll between tnentual exercises that would involve a combinanon of some of the pnncipal funcuonal areas of the hcensee's onsite emergency response capabihues.
This is a Seventy LevelIV violation Page 24 10/28/98
i Emerg:ncy Prep;redn:ss Findings 1997 - 1998 IV Activation of Emergency Response Organization M/eakness River Bend 98-01 Duplicate No Date Entered 10a2n Safety Yes 8
Due to the potennal impact on nutigation efforts, the failure to promptly and properly dispatch inplant response teams was identified as an exercise weakneas. h took up to an hour to dispatch several teams, and some teams, includmg a high pnonty team, were canceled before the teams could be dispatched.
Weakness Fort Calhoun 97-04 Duplicate No Date Entered lon7s Safety No 8
An exercise weakness was identified related to the failure to demonstrate the abihty to staff emergency response facihties on a prolonged basi Mulople personnel were used to staff positions in the operanons support center.
Penonnel designated to fill rehef shift posinons were allowed to remain in the facihty to support ongoing acovines. Some personnel selected to fill posinons had not completed the necessary training or were disquahfied for medical reasons. Based upon traming anendance rosters, some positions on the work schedule had people idenufied to work the backshift,but were present dunng the exercise with no day shift participanon. As a result no penonnel were present to relieve the individuals so they could be released. Sinular observations were made in the emergency operations facthey.
Weakness La Salle 98 08 Duplicate No Date Entered lon2s Safety No 8
RP personnel conducung team dispatch briefings did not venfy the status of SCBA quahficanons of two personnel auigned to the " Urgent 4" team pnor to dispatch. Addinonally, no readtly available method to venfy SCBA or respirator quahficanons was maintained in the OSC j Weakness La Salle 98-08 Duplicate No Date Entered 10a2n Safety No 8
The dispatch ames of Urgent teams ranged from an appropnate low of five minutes to an unacceptable high of 43 minutes. The inabihty to consistendy dispatch " Urgent" prionty teams in a omely manner was an Exercise Weakness.
InspeCdonS IF1 Perry 97-17 Duplicate No l Date Entered lon6/9 Safety No 8
l IFl 9717-02 An inspector follow-up item was opened to track the potennal impact on program performance of the loss of five expenenced EP I! nit staff members and the EP instructor.
IFl Duane Amold 97-03 Duplicate No Date Entered lon6/9 Safety No
! 8 Ten ERO persons wnh expired quahficanons hsted in the emergency telephone book, one person was o sick leave, f
there were to be deleted from the ERO and not available to respond to an emergency call and five were wainng to
- participate in the next dnl!. . Actions Out of-qualification ERO personnel idennfied in ihe nonficanon and call I list secnon of the Emergency Telephone book will be tracked as an inspection follow-up item.
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Emergency Preparedness Findings 1997 - 1998 IV l Activation ofEmergency Response Organization j Violation Comanche Peak 97 19 Duplicate No Date Entered 10/27/9 Safety No 8
on October 29,1996, the hcensee trade changes to its emergency plan, without Commission approval that decreased the effectiveness of the plan and did not connnue to meet Planmng Standard 50.47(b)(2). Specifically, l
i on-stuft and augmentanon capabihties were reduced as follows:
I - Adequate staffing forirutial response in key functional areas was not maintained when the emergency response organization no longer included a dedicated communicuor to perform offsite agency nonficanons.
Tenely augmentation of response car abilmes was not available when two 40-mmute responders, to help the stuft technical advisor perform dose assessment and engineenng tasks, were deleted.
Tunely augmentanon of response capabihnes was not available when one 40 minute responder. io perform offsite monitoring, was deleted. As a result,offsite momtonog capabihnes would be delayed until the 70 minute l
l responders arnved, smce on-shift res urces were not sufficient to perfonn the momtonng (accordmg to the
! licenseek Timely augmentation of response capabihnes was not available when five 40 minute responders to help perfonn l
stanon surveys, team coverage, onsite surveys, access control, personnel monsonng, and dossnetry were deleted.
This is a Seventy Leve; !V violanan (Supplement VIII).
Violation Nine Mile Point 97-06 Duplicate No l Date Entered 10/27/9 Safety No 8
From June 6.1997 through July 16,1997 mne of the qualified individuals for dose assessment had exceeded the 15 month linut for receiving refresher training,yet conunued to be listed as quahfied members of the Emergency Response Organization.
From November 8,1994, through July I 8,1997, there were no activations of ERO members that involved actual personnel response from offsite to the emergency faci!nies.
In the aggregate, this is a Seventy Level IV Violanon Violation Millstone 98 80 Duplicate No Date Entered 10/22/9 Safety No 8
Because NRC regulations require licensees to follow and maintain in effect emergency plans that meet certain standards, and because the licensee did not follow the Plan by ensunng that only respirator quahfied individuals were assigned to those positions requirms such quahfication, the inspectors concluded that a violation of SRC regulations occuned. This violation was due to the licensee's failure to adequately track respirator qualifications and ensure that only quahfied personnel were assigned to the SERO. However, tius issue was self-idennfied by the hcensee, not a recurrence of a previously idenafied issue, not a willful violation on the part of the licensee, and corrective adions have been irutiated and committed to. "Iherefore, the violation satisfies the enteria of Secnon VII of the NRC's Enforcement Policy and is non-cited l
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Emsrg:ncy Preptredness Findings 1997 - 1998 IV Activation of Emergency Response Organization
'Violmion Comanche Peak 97 19 Duplicate Yes Date Entered 10/27/9 Safety No 8
on October 29,19%, the licensee made the following changes to its emergency plan without Commission approval that did not continue to meet Plannmg Standard 50 47(b)(2), or the requirements of Appendix E. .
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- 1. Changes involving the description of emergency response organization members chd not connnue to meet Planmng Standard 50.47(b)(2) and Appendix E.!V.A requirements. Spectfically, the description and responsibiinies of the following four emergency response organizmion posinons were deleted from Revision 25 but remained on the organization chart and emergency response organization call-out roster- (a) emergency operanons facilny radianon assessment coordinator, (b) technical support center operanons coordinator,(c) operations advisor, and (d) supporting staff for the logisucal support coordmator.
- 2. Changes involving the desenpuon of the emergency response organization trauung program did net conunue to meet Apperxhx E.IV.F.1 reqttuements. Specifically,the desenpuon of the fire bngade and secunty trauung programs were deleted from Revision 25.
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- 3. Changes involving the desenption of offsite decision makers did not continue to meet Appendix E.IV.A.8 requirements. Spectfically, the idenufication of the offsite protective action decision makers for the mgesnon j pathway zone was deleted from Revision 25 to the plan.
This is a Severity Level IV violanon (Supplement VilI).
Violation Callaway 98-% Duplicate No Date Entered 10/22/9 Safety No 8
On May 29,1997, the hcensee made changes to its emergency plan, without Commission approval, that decreased the effectiveness of the plan and did not continue to meet Planmng Standard 50.47(b)(2). Fourteen changes to response goals noted.
Violation San Onofre 97 26 Duplicate No Date Entered 10/26/9 Safety No 8 .
NCV-97-26 01. The licensee identtfied the recover!re-entry pomon of the emergency plan had not been exercised smce 1989. Therefore,the failure to exercise the recovery /re entry pornons of the emergency plan i every 5 years was a violation of the emergency plan and 10 CFR 50.54(q). 'the violanon was hcensee idennfied, l nontepetative, corrected within a reasonable time and non-wdiful. Accordmgly the violation is being treated as a Non-Cited violation.
Violation Turkey Point 97-12 Duplic.te No j Date Entered 10/26/9 Safe.y No 8
NOV-97-12-04 Revision 32 to the hcensee's emergemy plan decreased the effecoveness of the pir.n in that it did not address the regturement in Appendix E to conduo a dnti between bientual exercises that wouM involve a i combinanon of some of the pnncipal funcnonal areas of the hcensee's onnte emergency response capabihties. j
'Ihis is a Severity Level IV violanon (Supplement Vili).
Violanon Limenck 97 10 Duplicate No Date Entered 10/26/9 Safety No 8
NCV-97-10 09: Following an Alert emergency nottficanon or above, the Licensee ER procedures states that six HP technicians must be onsite within a half-hour and six more widun 60 minutes. Following the October 9,1997 alert incident the HP team leader identified the he had dtfficulty in locanng 12 quahfied HP technicians and tunelmess of their response was not acceptable.
Real Evertts LERs i
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Emergency Preparedness Findings 1997 - 1998 IV <
1 0 Activation ofEmergency Response Organization
'IFl Chnson 98-03 Duplicate No Date Entered 10c2/9 Safety Yes 8
The mspectors noted that the OSC was staffed and activsed one hour and 15 minutes after the alert declaration.
De 30 minute positions for mplant surveys, radianon procedion personnel, and supervisor 4echnical or altemme were filled after more than 37 minutes. De 60 minute position for radiation protecuan personnel was filled after more than 75 mmutes. De mechanical engmeer positnn was not filled wnh a daignsed individual, however, personnel were present who could have filled the position. De 60 minute electrical ~" position was filled by a qualified electncian who was not ERO quahfied. Approaimately 1012 mmutes elapsed between emergency classification and nottfications by the autodialer.
IFI Clinton 98-03 Duplicate No Date Entered 10n2/9 Safety No 8
he autodialer operwion started a succession of events which ultunately resulted in unnmely filhng of the TAS posinon. a posinon required to acuvate the 15C.
IFI Chnton 98 03 Duplicate No Date Entered loc 2/9 Safety No 8
he licensee determined that several personnel did not have or were imaware of the need to have an ERO badge.
Not having an ERO badge creased delays in givmg access to the protected area in that security personnel were required to venfy ERO members agamst an non-alphabetical list of ERO personnel.
Violation - Chnton 98-09 DupUcate No ]
Date Entered 10/22/9 Safety No 8
On the moming of February 13,1998, there was only one electncal mamtenance personnel on shift, who was trained and assigned as a member ef the emergency response organizanon. Specifically, one of the two electncal maintenance personnel on shift was not tramed his is a Seventy LevelIV violation Violation Clinton 98-09 Duplicate No Date Entered 10c2/9 Safety No 8
The issued emergency access badges did not allow entry in the event of an emergency because on the n.oming of Februaay 13,1998. following the declarsion of an Alert. several reportmg emergency response organization members failed to have the badges in their possession. he regtnred other rneans of access identificanon to be unhzed, delaysig emergency facihty access and acuvation. Specifically, Technical Support Center acavanon was delayed.
His is a Seventy LevelIV violanon
- Adequacy of Facilities Exercises IFl Clinton 98 09 Duplicate No Date Entered 10c2/9 Safety No 8
he inspectors observed that the cait signs throughout the EOF / simulator / training facility failed to illuminate on loss of power.
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Emsrgency Preperedness Findings 4
- 1997 - 1998 IV Adequacy ofFacilities '
1FI Chaton 98 09 Duplicate No ]
Date Entered 1042S Safety Yes 8
Dree + .4ble power soun:es (UPS) located in the EOF failed. Failure of the field team's radio UPS had the impact of maidng commurucation widi the field teams from the EOF ddficult if not impossible.
URI Pilgrim 97-10 Duplicate No ,
1 Date Entered lon6s . Safety No l 8
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Lack of administrative control over SCBA fit tests resuhing in shonage of quahfied SCBA wearers i 1
Weakness Grand Gulf 97 15 Duplicate No Date Entered 10n7n Safety No 8.
Failure to monitor and mamtain supphes of self-contained breathing apparatus for long term center operation.
De licensee did not demonstrate adequale control over the use of respiratory protection eqmpment by monitoring the quantities of face pieces and use of aar bottles, and subsequendy replenishing these supplies as needed.
1 Inspections I IFI Clinton 97 15 Duplicate No Date Entered 10a7s Safety No 8
IFl 97-15-07. he inspectors noted that the main access to the EOF was through a set of airlock doors.
However, an ahemate access to the facihty for field teams had not been controlled with airlock doors. E-plan personnel initiated a work request to install door seals on field team access doors. Procedures specified that the EOF area HVAC subsystem provides a positive pressure in relation to the rest of the building and the outside. De inspectors determined that without door seals on the field access team doors, the HVAC system may not have the abthty to develop the pressure needed to satufy the procedure. %is maner will be tracked as an Inspection follow-up item.
IF1 Perry 97 17 Duplicate No Date Entered 10n6s Safety No 8
IFl 9717-01 An inspector follow up item was opened to track the operabihty of the Emergency Operations Facihty's Emergency venulation system which was found to be leaking dunns the inspecuen -
IFl La Salle 98 03 Duplicate No Date Entered 10a2n Safety No 8
Servia building public address system capabihties. PA not audible in the service building.
IFI Callaway 98 14 Duplicate No Date Entered 10 cts Safety No 3
he need to perform additional NRC review of backup emergency operations facihty capabihees was identified because a radio base station to communicate with offsne field monitonng teams was not available at the backup facility.
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Emergency Preparedness Findings 1997 - 1998 ,
IV Adequacy ofFacilities .
I URI Ptignm 97-02 Duplicate No Dse Entered 10c7S Safety No l 8 l The esisting configuration of radiation monitors on the refuel floor does not satisfy the requirements of 10 CFR 70.24."Crincahty accident requirements." In addnion BEco has not conducted evacuation dnlis as required by this pan. Tlus problem has minenal safety consequences.
liRI Beaver Valley 97 01 Duplicate No Date Entered 10/27 S Safety No 8
URI 97-0104: Loss of power to the emergency mponse facility. The event indicated potennal weaknesses in operstmg procedures for the ERF building, delegation of responsibility among site orgaruzations for the ERF.and ,
follow up of corrective accons for previous similar events. Deficiencies associated with the loss of power to the !
ERF are unresolved item pending completion of DLC evaluanon and subsequent NRC revicw.
i URI %11 stone 98 80 Duplicate No Date Entered 10c2B Safety No 8
Numerous longstanding problems were found to esist in the post accident samphng system. Due to the nature of the problems, these findmgs are being made an unresolved item and will be documented in a subsequent inspecnon report.
Violanon Praine Island 97 11 Duplicate No Date Entered loc 7S Safety No 8
On June 24.1997. 8-hour emergency lightmg was not provided for access and egress routes to the safeguards bus No.15 room, which conramed equiprnent needed for operation of safe shutdown equipment.
This is a Seventy LevelIV violation Violanon Braidwood 97 04 Duplicate No Date Entered 1047S Safety No 8
Site Quahty Verification Audit Report QAA420 96-05. Emergency Plan and Implemennns Procedures." dated March 22.19%.the 12 month review of the emergency preparedness program did not include an evaluanon of the adequacy of interface with the State of Illinois. (50 457/97004-01)
This is a Seventy I evel IV violation (Supplement VIIfL Violanon Waterford 97 15 Duplicate No Date Entered 10/26 S Safety No 8
Emergency lighting units wit at least an 8-hour battery power supply were not provided for the reactor auxiliary buildmg stairwell leading to the 46-foot chiller water system room, an access and egress soute for an area needed for operation of safe shutdown equipment Violanon Waterford 98-03 Duplicate No i
Date Entered 10/22S Safety No 8
The inspector reviewed infonnanon for the two crews where the number of small or large face-pieces was i madequate. In one crew,the shift supervisor and a reactor operator were affected. In the other crew, a control room supervisor and a reactor operator were affectal There were no controls estabhshed to address the shortage
) of properly sized air-supplied respirators.
The inspector determmed that the supply of air-supphed respirator face-pieces was inadequate and prevented the
- brensee from being able to unplement procedure OP 901 520. The violation is being treated as a non-cited
- violanon.
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Emergency Preptredness Findings 1997 - 1998 IV Adequacy of Facilities Niciation Vermont Yankee 97 11 Duplicate No Date Entered 10/27 s Safety No 8
his issue involved the failure to have in place either a enticahty monitonng system for storage and handling of new (non-irradiated) fuel or an NRC approved exemption to this requirement contained m 10 CFR 70.24.
The NRC has also determined that numerous other hcensees have sinular cucumstances that were caused by confusion regardmg the continuanon of an exempoon to 10 CFR 70.24 origmally issued prior to issuance of the Part 50 hcense. After considenng all the factors that resulted in these violations, the NRC has concluded that while a violation did exist, it is approprise to exercue 'enforcement discronon for Violanons involving Special Circumstances in accordance with Section VII.B.6 of the " General Statement of Pohey and Procedures for NRC Enforcement Acuens" (Enforcement Policy). NUREG 1600. Pending the amendment to 10 CFR 70.24. funher enforcement action will not be taken for failure to meet 10 CFR 70.24. provided an enforcement action will not be taken for failure to meet 10 CTR 70.24, pmvided an exempnon to this regulanon is obtained before the next
- receipt of fresh fuel or before the next planned movement of fresh fuel. NCV 9711-04 and unresolved item URI 97-03-07 are closed. NCV included in EP section of report.
Violanon Millstone 97-81 Duplicate No Date Entered 10/27/9 Safety No 8
As of August 29,1997, adequate facihties and eqmpment were not being maintamed,in that the TSCAlsC reference hbrary contamed uncontrolled drawings and other documents relateJ co the response effon were in the facihty but were not snarked as controlled documents.
His is a Seventy LevelIV violation Violation Cimton 97 02 Duplicate Yes Date Entered 10/27/9 - Safety No 8
a Condition Report (l 94-10 002) dated September 30.1994, and issued October 3.1994. indicated that the backup meteorological tower wnd speed and wmd direction sensors were inoperable. His condition had not been corrected. De wmd speed and wind direcnon sensors have been unavailable since October lo94.
His is a Seventy Level IV violanon (Supplement VI!f).
Violation Beaver Valley 97-09 Duplicate No Date Entered 10/26N Safety No 8
l VlO 97 09-03 the hoensee had not tested twenty of twenty seven direct lines at its Altemate EOF in Cornopobs.
PA. Rese imes would be used to perform the funcuons desenbed in Section IV.E.9.a-d of Appendix E in the event of an acuvanon of that facihty.
This is a Seventy level IV violation (Supplement VH!) applicable to Unit I and Urut 2.
l Violanon Calvert Chffs 97-08 Duplicate No l Date Entered 10/26/9 Safety No 8
l 97 08 from September.1996 to September 1997:
- a. BGE tested the direct hne nceification communicanon link with the contiguous State / local governmenu quanerty instead of monthly.
- b. BGE tested the Health Physics Network communication hnk with NRC Headquaners and the Region I i Operations Center quanerty instead of mornhly.
T1us is a Severity Level IV violanon (Supplement Vill-Emergency Preparedness (EP).
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Emergency Prep redn:ss Findings 1997 - 1998 IV ,
i Adequacy ofFacilities Yiolation WWP2 97-18 Duplicate No Date Entered loc 6n Safety No 8
NCV-97 184. The failure to perform a monthly check of the control room facsimile machine is a violation of TS 6 8.1, which requires the hcensee to follow procedtres that implement the emergency plan. This i non-non-repeonve, hcensee idennfied and corrected violation is being treated as a Non-Cited violanon.
Violation Palo Verde 97-21 Duplicate No Date Entered lon6s Safety No 8
Failure to perform emergency kit inventone:
Real Events LERs IFl Clinton 98-03 Duplicate No Date Entered 10c2n Safety Yes 8
Extended periods of time may have existed when the licensee did not possess the capabihty to transmit radiological and meteorological data to the NRC. !DNS, or EOF. b hcensee's corrective actions to irnprov e the reliabihty of the ND-6685 computer will be reviewed dunns a future inspection.
Other Exercises i
IFl River Bend 98-01 Duplicate No l
I Date Entered 10a2n Safety No 8 l Plant access training did not include a discussion of regulatory limits, instructions for frisking, protection of the embryo / fetus per the declared pregnant female program, etc. Since these topics were only discussed in radiation wotker traming, inspectors questioned whether emergency response organizanon members received traarung 4 consistent with 10 CFR Part 19.12. ]
IFI Braidwood 98 07 Duplicate No Date Entered lon:n Safety No 8
An RI'I' was observed posting a high radiation area dunng the 1998 EP exercise which does not support ALARA pracoces.
IFl Indum Point 2 98-07 Duplicate No ;
Date Entered 10/22/9 Safety No 8
Dunng the course of this inspection, the inspectors found several areas where EP programmatic controls were lacking. E.g No documentation of wrnplecon of shared offsite responsibthties with Indian Pomt 3 EP personnel.
IFl Davis-besse 97-07 Duplicate No Date Entered 10a6!9 Safety No 8
The poor simulation of ruhological data by controllers affected the abihty of the inspectors to evaluate rahological control practices by the parucipants and will be tracked as an IFL Page 32 10/28/98 l
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Emergency Preparedness Findings 1997 - 1998
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"!FI Cook 97 13 Duplicate No Date Entered 10n7s Safety No j 8 IFI- 9713 A potential performance anomaly was identified in relation to repair team response. Emergency Response team I was given a lughest pnonty designation. Plant perfonnance assessment (PA) support was requested for this team. PA was contacted and provided an indrvidual. However. since this team was designated highest priorty there was discussion that the team would have to be sent out without waiting for PA support.
Inclusion of a rep from the PA group in an emergency response team had the potential to delay the teams dispatch. Plant personnel were requested to clarify the desired degree of PA mvolvement in emergency inplant team activities. The degree of PA involvement in emergency response teams will be an inspecnon follow-upitem.
IF1 Zion 97-29 Duplicate No Date Entered 10n6/9 Safety No 8
IFI 97-29 02 The Inspector noted several problems with the control of the scenano and the over simulation of activitiec On one occasios a control allowed a response team to enter and stay in a steam envirorunent without providmg any simulation for e coxunately 3 minutes. On several occasions a the request of RITs controllers provided dose rate information without venfying that the RIis were conectly utilizing the instruments to i sunulate obtaining the requested information or that the instruments were properly setup. An example of such over sunulation was idenafied while accompanying the tearn. On one occasion a controller allowed a non-licensed operator to simulate donning high voltage protective gear for breaker racking operations. On numerous occasions controllers allowed personnel to simulate donning respirators and ,rotective clothing. j Licensee actions to determine and specify the correct level of exercise simulanon was an IF1. ;
1 URI River Bend 98-01 Duplicate No Date Entered 10/22n Safety No 8
An Iintesolved item was idenufied conceming whether Regulatory Guide 8.13 training (protection of the embryo / fetus) was conducted in accordance with the Updated Safety Analysis Report ,
Violation Perry 98-03 Duplicate No Date Entered 10/22S Safety Yes 8
During this penod. neither the control room simulator crew not the TSC staff were able to determine a procedural method to ernergency depressurize the reactor vessel to reduce the radianon release to the environment.
The procedure inadequacy of PEl-D17 is a violation of 10 CFR 50 Appendix B Criterion V, Instructions -
Procedures and Drawmss. in that a safety-related procedure was inadequate. This non-repetitive, licensee-identified and mrrected violation is being treated as a Non-Cited violation.
Weakness Lunerick 9745 Duplicate No Date Entered 10/27 s safety No 8
An exercise weakness was identified in the 13C. The Emergency Director (ED) and Assistant Emergency Directoh (AED) strong command and control tended to promote a " reactive" response rather than a "proacuve" response from the engmeenng staff for performing "what d" strategies and providing altemative suggestions to i the ED. This resulted in the licensee not fully demonstranng an integrated response in the TSC. Also,the duties I of the Maintenace Team Coordinator (MTC) were not effectively demonstrated.
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l Emergency Preparedness Findings 1997 - 1998 l
l IV Other
" Weakness Cooper 98 12 Dupucate Yes Date Entered 10/22 S Safety Yes l 8
1he failure of one crew to effectively unplement key elements of the emergency plan (e g emergency duector j oversight, protective action recommendations, offsite agency nonficanons. and emergency classificanon) during l simulator walkthroughs was idenufied as an exercise weakness. l Inspections IFl Cook 97 13 DupUcate No Date Entered 10/27s Safety ' No 8
IFI 971343 It was subsequently determined that the licensee's exercise controllers simulated response teams. To fix needed equipment to keep the exercise timeline on track. Controllers injected this mformation without infomung participants in TSC. The omission of exercise controllers to communicate information regardia a the simulated response teams to the TSC controllers will be tracked as an Inspection follow-up item.
IFl Cooper 98 12 DupUcate No Date Entered 10/22 s Safety No 8
Based on a review of selected ponions of the emergency plan and implementing procedures, the inspector l identified the following areas that needed additional review:(1) inconsistencies with NUREG454. Table B-I minunum staffing levels (2) adequacy of radianon protection training provided to operators who perform health '
l physics duties specified in NUREG-0654 (3) determine whether the emergency plan sufficiently desenbed the responsibibties of certam on-shift personnel.
IFl Callaway 98-10 DupUcate No Date Entered 10/22n Safety No 8
In addinon to the actual drill / exercise participants, the licensee also allowed dnll/ exercise participation credit for training for the controllers and evaluators.
IFI Byron 98-02 Duplicate No Date Entered 10/22S Safety No 8
1 raining module S 25.*ODCS Specialist." was found to have a revision date of December 21.1994. The training module was also out of date in that it did not provide training on MESOREM% which is the dose calculanon program currently used.
IFI Millstone 98 80 Duplicate No Date Entered 10/22n Safety No 8
Based upon the assessment made by audit MP 97 Al2-02, the inspectors concluded that additional corncuve actions were required on the pan of the EPSD in order to certify the EP function as ready for plant restart. The inspectors noted that the EPSD had outhne a correcuve acnon plan in response to the audit and that sorne correenve acuons had already been completed. The NRC will evaluate the licensee's complenon of these acnons and the need for enforcement, dunng a future inspection.
URI Comanche Peak 97 16 Duplicate No Date Entered 10/27 s Safety No 8
URI 97-16 1intesolved item involving the descnption of the ERO in the E-Plan is being idenufied as an Page 34 10/28/98
1 Emergency Prep redness Findings
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1997 - 1998 I unresolved item penduig outcome of NRCs review of Revision 25 so the sne's emergency plan.
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l Emergency Preperedness Findings 1997 - 1998 IV Other
- l1RI Cook 97 15 Duplicate No Date Entered 10/27 S Safety No 8
URI 971542.Not all memben of the ERO maintained current respirator quahfications. Some members of the operating crews had not been respirator fit tested in over a year. 81 of 235 members of the ERO had current respirator quahfications.
Violation Dresden 97 23 Duplicate No l l
Date Entered 10/26 s Safety No .
8 l In May 1997, the SQV staffs idenufied that management anennon was needed in the area of EP, specifically in the area of maintaining emergency procedures. Four findings were idennfied in SQV's audit related to EPIPs not i bemg maintained cunent with the changes made to the GSEP Manual (specifically the EPIPs containing the PAR l
procedures had not been revised to reflect the more conservanve PARS developed from the revised GSEP manual ;
which were currently agreed upon by the State of Illinois), the GSEP Augmentanon and Notification Phone List ;
not being adequately maintained, specific trasting records were not readdy retrievable, and a lack of attention to i detail of GSEP Eqmpment Surveillances, he fadure to update the PAR EPIPs within four months of a GSEP Manual revision as stated in the GSEP Manual, Revision 71, Section 8.5 is a violation of 10 CFR 50.54(q)," Conditions of Licenses." his non-repeonve, licensee-idenufied and corrected violation is being treated as a Nonfited Violanon.
Violation Fort Calhoun 97-02 Duplicate No Date Entered 10/27/9 Safety No 8
On May 6,1997, the NRC inspecton discovered that there were no instruaions or procedures to ensure that all licensed operaton, who were required to wear correcove lenses as a condinon of their mdividual licenses, had correenve lenses of the appropriate type available should these individuals trs required to wear self<:ontained breathing apparatus while performing licensed duties. ,
his is a Seventy levelIV Violation j Violanon Palo Verde 97 21 Duplicate No Date Entered 10/26s Safety No 8
Failure to submit emergency plan procedures to the bRC within 30 days of change Violation Millstone 97-81 Duplicate No Date Entered 10/27 S Safety No 8
the Audit Report No. A25 tl3, enntled" Connecticut Yankee / Millstone Emergency Plan Audit and 10CFR50.54(t) Review for 1996" dated January 24,1997, did not include all elements of 10CFR50.54(t) such as adequacy of interfaces with state and local govemments, emergency preparedness program caphhnes, and procedures.
His is a Seventy Level!V violanon This is a Seventy LevelIV violation his is a Seventy LevelIV violation Violation Comanche Peak 97-04 Duplicate No
! Date Entered 10/27B Safety No 8
- 97-04 01: Emergency plan provisions for penodic reviews of offsite agreement lenen were unclear and inconsistent with procedural requirements. A Non-Cited violanon was idenufied for failure to conduct an annual review of the emergency action levels with offsite authonties. he fadure to review the emergency action levels i wnh the stase and local authonties was idennfied as a violation. He violanon was licensee idenufied, nonrepetanve, corrected within a reasonable ame and non-willful
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- . *s Emergency Prep 2r:dness Findings 1997 - 1998 IV l
Other
- Violanon La Salle 98-03 Dupbcate No Date Entered 10a2n Safety No 8
Licensee records idenedied that approaimately 110 maintenance personnel had not received annual requahficanon i
training in 1997 and were not qualdied for emergency response in 1998, he failm to tram maintenance l personnel as stated in the GSEP Manual is a Violanon. his non-repetinve, hcensee. identified and conected j violanon is being treated as a Non-Cited Violanon.
Violanon Calvert Chffs 97-08 DupUcate No Date Entered 10n6s Safety, No 8
l NCV.97-08 07 he ITS AR descnhed the emergency radios onsite as having digital voice protection. but BGE had removed this feature to impmve reception quahiy BGE revised its ERPIP for malung changes to the EP program to include a review of proposed changes against the LTS AR but failed to correct the Identtfied devia ion (Identified as an IIRI in 19%). The inspectors concluded that BGE had failed to update the iTSAR in a tunely fashion for a change affecung the (TS AR.
Violation kblistone 97 81 Dupucate No Date Entered lon7s Safety No 8
As of August 29,1997, adequate dose assessment methods were not in use.in that all penonnel responsible for dose assessment couki not adequately perform radiological dose assessment for potennal offnte consequences of l
radiological conditions in a manner necessary to support timely emergency management decision malung for' t protemve scuon recommendmions.
his is a Seventy LevelIV violanon Violanon Callaway 98-06 Dupbcate No
, Date Entered 10c2B Safety No l 8 On May 29,1997, the hcensee made changes to its emergency plan, wuhout Commission approval, that decreased the effectiveness of the plan. Specifically, the requirement to collect and analyze offsite sample media (sohd.
i liquid, gas) was deleted from the desenpuon of the radnlogical morutonng dnll. his resulted in a reduct on in l field rnonitonng team training requirements.
his is a Seventy LevellV violation Violanon NL11 stone 97 81 Dupbcate No i
Date Entered 10/27 s safety No l 8 the NRC detemuned, by direct inspection, that during June 1997 the hcensee implemented Revision 22 to the emergency plan. he hcensee decreased the effectiveness of the emergency plan m Revision 22 and implemented it wuhout pnor NRC approval. Decreases in effecnveness included changing accountabthty ume from 30 to 45 minuies, a provision decreasing the coverage for 4 heahh phyncs pontions from 30 to 60 minutes, and staffing tune reductions for other emergency response staff members.
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his is a Seventy LevelIV violarion Ris is a Seventy LevelIV violanon l
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l Emergency Preparedness Findings 1997 - 1998 IV Other "Violmion Sotah Texas 97 13 Duplicate No Date Entered lon6/9 Safety No 8
On September 3,1997, the inspectors identified two cases in which individuals in the emergency response organization had not received the proper inical or annual traming for their assigned posinon.
One individualidentified by the inspectors was assigned as an assistant radimion manager on the emergency response organizatx>n call +ut roster. The position was not pan of the minimum response orgamzanon identified in the bcensee's emergency plan.
he other individual identified by inspectors was assigned to the c . shift response organization as one of three of four plant operators capable of perfonnmg the state / county communicsor responder function.
Violation Vogde 97-(M Duplicate No Date Entered 10/2719 Safety No 8
On April !$,1997, eight Emergency Plan implementing Procedures in the OSC were identified for which revisions dated tetween November 21,19% and Apnl 7,1997 had not been distnbuted shortly after approval to all required locations.
11us is a Seventy levelIV Violation Violation Waterford 98-03 Duplicate No l
Date Entered 10/22/9 Safety No 8
While reviewing the 1997 emergency preparedness program audit, the inspector observed that there was no mention of the assessment of the enterfaces with state and local govemrnents. The licensee provided a copy of -
the audit checklist showmg that the audnors had interviewed representauves from state and loca! agencies and had received very good response. From the informanon provided, the inspector determined that the offsne interfaces were well maintained.
herefore, the assessment was performed, but not documented. His was identified as a violation of the requirements in 10 GR 50.54(t).
11us failure constitutes a violation of minor sigraficance and is bems treated as a non-cited violsion .
Violation WNP2 98 14 Duplicate No Date Entered 10/22/9 Safety No 8
Contrary to the above, on July 13,1998, the licensee made changes to its emergency plan, wuhout Comrrussion approval, that decreased the effect veness of the emergency plan. Specifically,irutial traming requirements wore reduced from formal classroom instruction, wntren exarnination, and hands-on training where appropriate to formal classroom mstruenon, wnuen examination, or hands-on traming.
And, on July 23,1998,it was determined that the hcensee's emergency plan did not describe the imtial and retrainmg programs. The emergency plan stated that course assignments formembers of the emergency organization may be found in emergency plan implementmg procedures. The course assignments were not found i in implementing procedures, and retraimng courses were only identified in a computer database.
This is a Seventy LevelIV violation.
Violation WNP 2 98-09 Duplicate No Date Entered 10/22/9 Safety No 8
On Apnl 3,1997, the licensee made a change to its emergency plan, wuhout prior NRC approval, that decreased the effectiveness of the plan. Specifically,the change reduced the level of heahh physics experuse on-shift and i overburdened the on-shift chemistry technician with health physics responsibilines.
His is a Severity LevelIV violation i
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Emergency Prep redness Findings 1997 - 1998 :
.IV l Other
" Violation Comanche Peak 97 19 Duplicate Yes Date Entered 10n7/9 Safety No 8
on Oaober 29,1996, the licensee made the followmg changes to its emergency plan wnhout Commission approval that did not contmus to meet Plannmg Standard 5047(b)(2), or the reqtarements of Appendix E.
- 1. Changes involving the descripnon of emergency response organization members did not conunue to meet Planrung Standard 50.47(b)(2) and Appendix E.!V.A requirements. Specifically, the descripnon and responsibihnes of the followmg four emergency response organizamn posinons were deleted from Revision 25 but remamed on the organizanon chart and emergency response organission cau-out rosten (a) emergency opersions facthey radation assessment coordinator (b) technical support center operanons coordmator,(c) opersions advisor, and (d) supportmg staff for the logistical support coordmator. .
- 2. Changes involvmg the desenption of the emergency response organizanon training program did not continue -
to meet Appen6x E.IVF.1 requirements. Specifically,the description of the fire bngade and secunry training programs were deleted from Revision 25.
- 3. Changes involvmg the desenption of offnte decision makers 6d not untinue to meet Appenda E.IV.A.8 requirements. Specifically,the idenuficanon of the offsite protecave acion decision makers for the ingesnon pathway zone was deleted from Revision 25 to the plan.
his is a Seventy 1.evelIV violation (Supplement VIII).
Violsion Harns 97-06 DL,plicate No Date Entered 10/27/9 Safety No 8
The inspectors reviewed the licensee's masnenance of the Emergency Plan (Plan) and selected conmuttnents therein, and reviewed recent revisions to the Plan to determine whether clanges were made in accordance with 10 CFR 50.54(q).
Dunng review of documentation associated with Revision 28 (which comprised editorial " cleanup" only), the irispectors noted that the Plan revision was processed by the licensee's Docurnent Services group and assigned an effecave date of July 31,1996. However, the required final approval of Revision 28 by the Plant Nuclear Safety Comnunce (PNSC) d d not transpire untd August 1,1996 his failure to follow an administranve procedure consatutes a violacon of minor significance and is being treated as Non-Cited Violation.
Violaion Zion 97-08 Duplicate No Date Entered loc 6/9 Safety No 8
Annual reviews of the Emergency Preparedness programs. contained in Site Quality Venfication Audit QAA 22-95-04,"Genersing Station Emergency Plan," dated July 28,1995, and Site Quabty Venficanon QAA 22-96-08," Au6ts of Generating Stanon Emergency Plant (GSEP)," dated July 25.19%,6d not address the adequacy of the offsite interface with the Stue of Illmois.
This is a Severity 1.evelIV violanon Real Events LERs IFl Clinton 98 03 Duplicate No Date Entered lon2/9 Safety No 8
I i ne TSC-SED assumed the lead role but did not direct of coordmate the response eenvities of the facihty.
Essentially, the sift supervisor did not relinquish command authoney over the ERO and connnued to establish the pnonnes for the statios throughout the duration of the Alert.
IFI Chnton 98-03 Duplicate No Date Entered 1042/9 Safety No
- 8 The licensee noted that une wide announcements were infrequendy made and did not include information regardmg Page 39 10/28/98
1 f Emergency Prep:: redness Findings 1997 - 1998 the status of the planc. ;
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Emsrg ncy Preparedn:ss Findings 1997 - 1998 IV' l l
Other 1 1FI Chnson 98-03 Duplicate No Date Entered 10a2/9 Safety Yes 8
The hcensee noted that three.part communications were not used by all ERO personnel and that reminders made during the Alen improved communications for shot duranons. The hcensee noted that communicanons between the main control room and the TSC were dtflicult in that a dedicated communicator was not estabbshed in the conuoi room. Pnonues were not clearly communicated between the TSC and the main control room.
IFl Chnton 984N Duplicate No Date Entered 10/22/9 Safety , No 8
The licensee detenmned that the SED was not always awue of operations teams foimed and dispatched by the stuft supervisor. The lack of oversight by the SED resulted in communication problems regarding restoration of plant equipment.
IIRJ Clinton 98 03 Duplicate No Date Entered 10/22/9 Safety No 8
lhe hcensee detemuned that the SED was not always aware of operations teams formed and dispatched by the stuft supervisor. The lack of oversight by the SED resuhed in communicanon problems regarding restoranon of plant eqinpment.
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1 Emergency PrepIredness Findings 1997 - 1998 V
Category a 1 W Sub Category 14 % l ? Megory 25 ] IFl l URi l Violation l Weakness V Other 1 l lReal Events LERs
.1 ._ . .
Other Real Events LERs IFl Turkey Pomt 98 07 Duplicate No Date Entered 10/22 S Safety No 8
Follow up on the root cause of a motor-generator set fire. (no EP implications noted)
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e Emergency Prepera;dness Findings 1997 - 1998 LER I
Accident Assessment Real Events LERs Event Mdistone 97-060 Duplicate Yes Date Entered 10/22 S Safety No 8
Title:
Incffecove Implementauon of the Post Acadent Sampimg System Program On Nos ember 25,1997, with the umt in Mode 5, a Nuclear Ovemght audit finding identified several Post Accident Samphag System (PASS) program weaknesses wluch quesconed the funcuonahty of the system and the l capabihty of sampling personnel to obtam and analyze reactor coolant, containment atmosphere, and containment rearculanon sump sarnples, following a design basis accident. De audit idennfied specific PASS l programmaric weaknesses in the areas of technician training,mamtenance of equipnent and supphes, matrumentanon cahbranon and prevennve maintenance acuvines, and PASS emergency plan drill performance.
On April 15,1998, results of a February 23 26,1998. Nuclear Regulatory Comnussion (ST(C) assessment j inspecion of the PASS idenufied several additional emergency response related prograrn deficiencies that had not '
been previously addressed in the original report subnuttal (ref. LER 97-060-00). nese defiaencies called into quesnon the effectiveness of the PASS program and the abdity to " ensure the capabihty" to obtain and analyze post-accident samples "under accident conditions." Tlus is a failure to comply with TS 6.8.4.d and is bemg reported pursuant to 10 GR 50.73(a)(2)(i)(B), as a condition or operanon prohibited by the unit's Technical Spectficanons. %e cause of this condition is annbuted to a failure of management to unplement an effecuve i
PASS program that ensured comphance wnh Technical Specificanon reqturements. Although the abthey (f the i l
PASS system to function in comphance with the TS requirements could not be assured, altemate sources could be unlized to make appropnate post-accident minganon and protecuve acnon recommendauons. here were no safety consequences as a result of this event, he corrective acnons associated with these identified deficiencies have been completed with the exception of a correcnve acnon to conduct survedlances that will venfy that PASS sample: can be analyzed to sansfy acceptance cntena.
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Event Recognition l Real Events LERs Event Callaway 97-006 Duplicate Yes Date Entered 10/22S Safety No 8
Title:
Loss of Annunaators and Unusual event Declaranon Due to Lighoung Sinkes l
On 7/1987, at approximately 1600 CDT, two hghtnmg stnkes occurred in the Callaway Plant water treatment l
facihty resultmg in degraded rield power supply voltages and a loss of several Mam Control Board (MCB) i annunciators. At approxunately 1625, unhty Instrurnent and Control O&C) techrucians discovered smokmg connector cards in computer muluplexer cabmet RKGt5DI, rack M 7 and de-energized the rack, thus retumu1g most MCB annunaaton to a funcnonal status. At approximately 2230 CDT, unhty engmeers detennined that although the power supplies had not failed dunng the subject 25-minute period,it could not posinvely be detemuned that the majonty of MCB annunciators had been functional from 1600 to 1625. Notificanon was made that conditions had emisted between 1600 and 1625 which placed Callaway Plant in an Unusual event. This report is being rnade voluntanly to address the root cause and correcave accons for a declared Unusual event. The cause of the post event emergency declaranon was inadequate procedure gtudance. The unhty Nuclear Engineenng departrnent will perform a comprehensive system design review to idennfy probable failure modes and potennal design enhancements. Apphcable procedures have been revised to more clearty define critena for a " failed" p>wer supply. Integrated trairung will be conducted on t!us event with unhty personnel.
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Other Real Events LERs l l
Event WNP 2 97-003 Duplicate F , i l
Date Entered 10/22/9 Safety .o 8
Tide: Nonficsion of Noncomphance with Tedinical Specifications At 1645 on March 20,1997, with the plant operanns at 100% power, NRC staff nonfied the Supply System that WNP-2 Technical Spectfications (TS) Survedlance Requuemenu (SRs) for Response Time Tesung (R1T) were l not being met for spectSed instrumentation in the Reactor Protection System, Pnmary Containment isolation System, and Emergency Core Cochng System. WNP 2 declared the specified equipment inoperable and entered the applicable Technical Specificanon Action Statements (TSAS). This action required subsequent entry into LCO, 3.0.3 necessitating ininanon of a plant shutdown within I hour and placing the reactor mode switch in the startup position within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. At 1740 WNP-2 decland an unusual event based on entry into LCO 3.0.3 and irunated a power reducnon required by the TS. WNP 2 then requested enforcement discretion for a one-time exempnon from the applicable Techrucal Specificsion SRs until Apnl 18.1997 or untd the issuance of a license amendment changing the Technical Specificanons. At 2136 WNP 2 received verbal nonScanon of enforcement discretion.
The TSAS and LCO 3.0.3 were exited at this time. He unusual event was terminated at 2200 based on exit from LCO 3.0.3, The elapsed time the equipment was declared inoperable was 4 hrs. 50 min. The March 20 letter indicated the fadure to meet the SRs was caused by an inconsistency between WNP-2's method of implementing Licensing Topical Repon NEDO 32291 " System Analyses for Ehmination of Response Time Testing Requiremenu" and WNP 2 Technical Spectficanon SRs and R1T definitions. De Supply System's failure to clattfy the staffs expectanons before proceedtng with implementanon was also a cause.
Event Pdgnm 97 007 Duplicate No Date Entered 10/22/9 Safety No 8
Title:
Safeguards Buses De-Energtred and Losses of off-Site Power Dunng Severe Stonn %1ule Shut Down On Apnl I,1997, both 120 volt safeguards buses de energized on two occasions, and subsequently, a loss of prefened off site power (345 kV) followed later by a loss of secondary off-site power (23 kV) occuned while the emergency diesel generators were in operanon dunng a severe storm (bhzzardh An Unusual event was declared at 0349 hours0.00404 days <br />0.0969 hours <br />5.770503e-4 weeks <br />1.327945e-4 months <br /> and was terminated at 2347 hours0.0272 days <br />0.652 hours <br />0.00388 weeks <br />8.930335e-4 months <br /> by which nme the secondary and preferred off-site power sources were re-energized. he cause of the de-energtzmg of the safeguards buses was bnef, severe 345 kV transmission system undervoltage transients that resulted in automane shut downs of the voltage regulating transfonners (480/120 volt) that power the safeguards buses. The transformers
- purchase specification did not address and the manufacturer and suppher documentanon did not idennfy an automatic shut down feature if input voltage was less than 384 volts (greater than zero volts) The separate losses of the offsite power sources were cause by the effecu l.
of the storm. Conective action taken included the replacement of the microprocessor control uruts installed in the voltage regulating transformers. The events occurred while in cold shut down. De reactor mode selector switch was in the REFUEL posinon. The evenu posed no threat to public health and safety.
Event Calven Chffs 97 005 Duplicate No Date Entered 10/22/9 Safety No 8
l
Title:
Reactor Coolant System Leak Due to Failed Compression Fitung On May 29,1997 at 1620, Calvert Chffs Unit I experienced a Reactor Coolant System leak of approximately 810 gallons per minute while operating at
- 00 percent power. Operators implemented Abnormal Operating Procedure-2A, declared an Unusual event, and commenced a rapid unit downpower. %e leakage source was a faded 3/4 inch compression fitting in an lastrument ime from the pressunzer vapor space. The leak w as isolated at 1930. By 1935 tbe plant was in Hot Standby. The cause of the compression ficung fadure was improper assembly. h's ferrule was insufficiently compressed due to insufficient nut advancement. Inspections of cnncal compression fitungs in both Calven Cliffs units was expedinously completed. Other compression finings will be evaluated and addressed during scheduled system maintenance. Additional corrective accons will be implemented based on the resulu of an ongoing root cause analysis.
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d Emergency Preparedness Findings 1997 - 1998 II Other
" Event Arkansas96-009 Duplicate No Date Entered 10/22/9 Safety No 8
Title:
Cracked Weld in an Od Line on a Reactor Coolant Pump A fire was discovered in insulation around the Main Feedwater nozzle nns on "B" Once Arough Steam Generator (OTSO) dunng 'watup of the Reactor Coolant System (RCS). A weld located in the discharge hne of a Reactor Coolant Pump (RCP) motor od hfi pump had cracked due to a fabncation defect. He fadure. believed to have occurred at the start of the outage. resulted in od bemg introduced onto the insulanon. 00 on the insulanon allowed a wickmg effect that reduced the auto-igtunon point of the oil to a value lower than the documented value, he fire ongmated when the RCS temperature was appronunately 439 degrees. Apphcadon of a bght water fog from a fire hose extmguished the fire approximately 16 mmutes after it was discovered. A Nottficanon of Unusual -
event was declared when the fire was not extmgutshed within 10 minutes. De plant returned to cold shutdown condinons to evaluate damage. Other than some minor damage to insulation, the fire did not damage any systems or components. Enhancements were made to the od collecnon systems of all RCP motors, and damaged insulanon was repaired or replaced pnor to the subsequent hearup.
Event Diablo canyon 97-005 Duplicate No Date Entered 10/22/9 Safety No 8
Title:
Reactor Tnp and Safety injection Caused by inadvenent Main Steam isolanon Valve Closure Due to Personnel Enor On 0::tober 24.1997, at 0815 PDT, with Umt 2 in Mode I (Power Opeimon) at 100 percent reactor power, a reactor tnp (RT) and safety injecuan (Sf) occurred due to inadvenent closure of a mam steam isolanon valve.
One power operated rehef valve hfted to reheve reactor coolant system (RCS) pressure seven omes during recovery from the RT and $1. S1 actuanon signal was reses at 0829 PDT. An unusual event (UE) was declared for this event at 0832 PDT. The San Luis Obispo county Shenffs Office Watch Commander was nonfied at 0837 PDT. A 1.hout emergency report was made to the NRC,in accordance with 10 CFR 50.72(a)(1)(i) at 0900 PDT.
l On October 24,1997, at 0938 PDT. followmg stabdiza: ion of Umt 2 in Mode 3 (Hot Standby),the UE wo temunated. His was the twelfth Urut 2 emergency core cooling system actuanon cycle that resulted m a l
discharge of water into the RCS. De cause of the event was inadvenent actuation of the closed postoon switch
! for FCV-44 by a contract laborer removing scaffoldmg adjacent to the valve. Correcove acnons to prevent recunence include: (1) revision of the scaffoldmg program procedure and risk assessment procedure and (2) issuance of a maintenance policy to require a nsk assessment and management approval for non rounne work near cnucal components.
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Other
' Event Mdistone 97-060 Duplicate Yes Date Entered 10/22/9 Safety No l 8
Title:
Ineffecove Implementanon of the Post Accident Sampling System Program
! On November 25,1997, with the unit in Mode 5. a Nuclear Ovecsight audit finding identified several Post
! Accident Samphng System (PASS) program weaknesses which questioned the functionahty of the system and the l capabthty of samphng personnel to obtain and analym reactor coolant, containment atmosphere, and l containment recirculanon sump samples, following a design basis accident. he auda idenufied specific PASS l programmatic weaknesses in the areas of technician training, maintenance of equipment and supphes, instrumentanon cahbranon and preventive maintenance uivines, and PASS emergency plan dnll performance.
l On Apnl 15.1998, resulu of a February 23 26,1998 Nuclear Regulatory Comnussion (NRC) assessment ,
l inspection of the PASS idenufied several addinonal emergency response related program deficiencies that had not i been previously addressed in the onginal report submittal (ref. LER 97-060 00). %ese deficiencies called into i quesnon the effecoveness of the PASS program and the abihty to " ensure the capabibty" to obtain and analyn i post accident samples "under accident conditions." This is a failure to comply wnh TS 6.8.4.d and is being reported pursuant to 10 CFR Sa73(a)(2)(i)(B), u a condition or operation protubited by the unit's Technical '
Specificanons. %e cause of this condition is attnbuted to a failun of management to implement an effecive PASS program that ensured comphance wnh Technical Specificanon requirements. Although the abihty of the PASS system to function in compliance with the TS requirements could not be assured, ahemate sources could be l
unlind to make appropnate post-accident nutigntion and protective acnon recommendanons. Dere were no l safety consequences as a result of this event he conecuve acnons associated wuh these identified deficiencies i
have been completed with the exception of a correaive acnon to conduct surveillances that will venfy that PASS I samples can be analyud to satisfy acceptance entena.
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Event Davis Besse 98-006 Duplicate No I
Date Entered 10/22/9 Safety No 8
Title:
Tomado Damage to Switchyard Causing Loss of Offsite Power l
On June 24.1998, at approximately 2040 hour:, wuh the unit in Mode 1 at 99 percent power, a storm cell moved through the site area, and, at approximately 2044 hours0.0237 days <br />0.568 hours <br />0.00338 weeks <br />7.77742e-4 months <br />, a tomado touched down onsite. he Emergency Diesel Generators were both manually started when the Control Room received a report of a tomado on site. he damage from the tomado, accompanying straight-line winds, rain and lightning, resulted in a complete loss of offsite l
power (LOOP). he LOOP caused the turbine control valves to close in sesponse to a load rejecnon by the main l
generator. %e Reactor Protection System (RPS) initiated a reactor trip on high Reactor Coolant System (RCS) pressure. At 2118 hours0.0245 days <br />0.588 hours <br />0.0035 weeks <br />8.05899e-4 months <br />, an Alert was declared in accordance with procedure RA.EP 01500. Emergency l l l Classificanon, Emergency Action Level (EAL) 8.B.2, Any tomado striking facility. Following restoration of an offsite power source,the Alert was downgraded to an Unusual Event at 0200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> on June 26,1998, and at 1405
! houn, the Unusual Event was terminated. The tomado resuhed in significant darnage to the offsite electncal
<hstnbution system, telecommunications, power to the sirens and other unfornfied structures. Immediate correcnve actions involved the tesung and repainns of the affected electrical and mechanical equipment necessary to restore two offsite power sources and assessing damage to other plant components and structures and initiahng l repairs Plant telecommunications were restored and the siren system was retumed to 90 percent availability pnor l to plant startup. %ere were no adverse effects to the public heahh or safety. Davis Besse Nuclear Power Station Umt I startup was initiated, with reactor enticality reached on July 1,1998, at 2257 hours0.0261 days <br />0.627 hours <br />0.00373 weeks <br />8.587885e-4 months <br />, but wu shutdown due l
to elevated sulfate levels in the stearn generator water chemistry on July 2,1998. Following steam generator fill,
( soak and drains, startup was irutiated on July 5,1998, and at 0400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> on July 7,1998, the Main Generator was synchronized to the gnd.
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Emirgency Preparedness Findings 1997 - 1998 11 Other l Ivent La Salle 97 009 Duplicate No l
i Date Entered 10/22s Safety No
! 8
Title:
Inadequate Understanding of Lake Design Basis Results in Lake Level Higher Than Permined by UFSAR 1,aSalle County Station entered an Unusual event at 19:45 on 3/11S7 when it was desemuned that the 701.8 foot elevanon of the lake level at that tirne wu above the 701 foot maximum level desenbed in the UFSAR and used in plant flooding potential analyses. He high take level resulted principally fmm a lack of knowledge and l consideramon of the design basis for the maxunum take level, his led to operanng and surveillance procedures which provided upper turuts for lake level higher than the UFSAR specified value of 701 ft. Con.nbunns factors were lugh rates of precipitanon, poor malerial condition of the lake makemp and blowdown hnes and the unavailabdity of the lake blowdown valve. Critical plant equipment were confirmed to be operable for the higher j than analyzed take level. However, as prudent measures, plant personnel monitored lower elevanons of the plant, i
and the flood wall on the north side of the condenser pit was effecovely raised by placement of sand bags to an elevation of 701 ft.10 in. Operating procedures were revised and additional revisions are in progress. He take blowdown valve was retumed to full service on 3/13S7 to begin reducing take level to its normal range. He Unusual event was temunated at 17:00 on 3/26/97 with the lake level at 700.68 ft. He lake level was within normal operating range on 4/3/97.
Event Cook 97 005 Duplicate No Date Ente.ed 10/22 S Safety No 8
Title:
Condinon outside Design Basis Resulu in Technical Specificanon Required Shutdown On September 8,1997, at 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br />, with Unit 2 at 96 percent Rated hermal Power, it was discovered that under certam scenanos the volume of water resident in the naive surnp volume of the containment may not be adequate to support long tenn Emergency Core Coolmg Systems (ECCS) or Containment Spray (CTS) pump operation dunng the recirculation phase of a LOCA event. His was determined to be reportable under 10 CFR 50.72(b)(IXti)(B). as a condition outside the design basis. A Technical Specification required shutdown was j undertaken, which was reportable under 10 CFR 50.72(b)(1)(iXA). His intenm LER is bems subnutted in accordance with 10 CFR 50.73(a)(2)(ii) and 10 CFR 50.73(a)(2)(i)(A). He containment drainage system is designed to ensure that water from an RCS break. ECCS injecnon, and ice melt flows back to the recirculation sump in sufficient quannties to provide adequate protection against vortexing in the surnp dunng recirculation following a design basis accident. Exisung analyses were unable to readily confirm that the muumum sump level would be achieved under all potential scenanos, particularly a very small break LOCA. Without sufficient sump level.long term integnty of the ECCS and CTS pumps could not be ensured due to potential air entrainment from vortexing in the sump. A shutdown was conservatively commenced at 1728 hours0.02 days <br />0.48 hours <br />0.00286 weeks <br />6.57504e-4 months <br /> for the unit, and when it became apparent that analysis was not able to confirm sufficient communication, an Unusual event was declared at 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br />. On September 10,1997 at 0015 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> Unit 2 entered Mode 5, cold shutdown. He Unusual event was temunated at 0303 on Septernber 10,1997 when Unit 1, which was also engaged in a Technical Specificanon required shutdown, entered Mode 5 as well. Analy sis is being performed to confirm adequate water volume, and the stysical configuration of the acuve sump volume boundary is being validated.
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1997 - 1998 l l
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Other
" Event Cook 97 017 Duplicate No I
Date Entered 10/22/9 Safety No 8
Title:
Condition outside Design Basis Results in Technical Specification Required Shutdown i
On Sepember 8,1997, at 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br />, with Unit I at 74 percent Rated hermal Power,is was discovered that under certain scenanos the volume of water resident in the active sump volume of the contamment may not be
)
I adequate to support long term Emergency Core Cooling System (ECCS) or Contauunent Spray (CTS) pump I operation dunng the recirculanon phase of a LOCA event. his was determined to be reportable under 10 CFR I 50.72(b)(1)(ii)(B), as a condition outside the design basis. A Technical Spectfication required shutdown was l undertaken, which is reportable under 10 CFR 50.72(b)(1)(iXA). his interim LER is being subnutted in i accordance with 10 CFR 50.73(aX2)(ii) and 10 CFR 50.73(ax2Xi)(A). he containment drainage system is - I designed to ensure that water from an RCS break. ECCS injection, and ice melt flows back to the recirculation I sump in sufficient quanuties to provide adequate protecnon agamst vortexing in the sump during recirculanon following a design basis accident. Existmg analyses were unable to readily confirm that the muumum sump level ,
would be achieved under all potential scenanos, particularly a very small break LOCA. Without sufficient sump i level. long term integnty of the ECCS and CT3 pumps could not be ensured due to potential air entrainment from l vortexmg in the sump. A shutdown was conservatively commenced at 1655 hours0.0192 days <br />0.46 hours <br />0.00274 weeks <br />6.297275e-4 months <br /> for the urut, and when it l became apparent that analysts was not able to confirm sufficient communication, an Unusual event was declared at ,
I 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br />. On September 10,1997 at 0303 hours0.00351 days <br />0.0842 hours <br />5.009921e-4 weeks <br />1.152915e-4 months <br /> Unit I entered Mode 5, cold shutdown, and the Unusual event was ternunated. Analysis is being performed to confinn adequate water volume, and the physical configuranon of the active sump volume boundary is being validated.,
Event Surry 98-009 Duplicate No l Date Entered 10/22/9 Safety No l 8 l
Title:
Non-isolable Leak of Reactor Coolant Pump Seal Injecnon Line Weld On May 9,1998, with Unit I at 100% power, an increase was noted in Reactor Coolant System (RCS) leakage.
Operations personnel entered the containment to investigate and discovered a leak m the area of the 1 1/2" seal injection line to the "C" Reactor Coolant Pump (RCP) at the pump thermal barner. A subsequent contamment entry confinned that a weld or pipe through-wall non isolable leak existed at the seal injection line of the RCP.
he urut was placed at cold shutdown as required by TS 3.1.C.4. On May 9,1998, a Notice of Unusual event was declared and, at 2316, the NRC wu nottfied in accordance with 10CFR50.72(a)(1)(i) and 10CFR50.72(bX1)(i)(A).
De seal injection line was repaired and the urut was prepared for start.up and the unit was returned to service on May 25,1998. A Root Cause Evaluation (RCE) was imtiated to venfy the cause of the leaking "C" RCP seal injecnon weld. The cause has preluninanly been detemuned to be from a pre existmg indicanon at the toe of the weld he most probable cause for the weld failure was a lack of fusion or thermal fatigue coupled with vibration stress due to a loose rod hanger This event is reportable pursuant to 10CFR50.73 (a)(2Xi)(B).
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C Emergency Preparedness Findings 1997 - 1998 i
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Other
~ Event Callaway 97 006 Duplicate Yes Date Entered 10/22N Safety No 8
Title:
Loss of Annunciators and Iinusual event Declaranon Due to Lightning Stnkes On 7/ 987, at approxunately 1600 CDT, two hghtning stnkes occurred in the Callaway Plant water treatment facihty resultmg m degraded field power supply voltages and a lois of several Main Control Board (MCB) annunciators. At approximately 1625, utility lastrument and Control (1&C) technicians discovered smolung connector canis in computer mult plexer cabmet RK045DI, rack M 7 and de-energued the rack thus returning most MCB annunciators to a funcnonal status. At approxirnately 2230 CDT, utihty engineers determined that akhough the power supphes had not faded dunng the subject 25-mmute penod.it could not posinvely be detemuned that the majonty of MCB armunciators had been functional from 1600 to 1625. Nottfication was made that conditions had existed between 1600 and 1625 which placed Callaway Plant in an Unusual event This report is being made voluntanly to address the root cause and correcnve acnons for a declared Unusual event. 'Ihe cause of the post event emergency declaration was madequate procedure guidance.The utihty Nuclear Engincenng depastmer.1 wd! petform a comprehensive system design review to identify probable failure modes and potential design enhancements. Apphcable procedures have been revised to more clearly define entaria for a " failed" power supply. Integrated trauung will be conducted on tius event with unhty personnel Event WNP 2 98 011 DupUcate No Date Entered 10/22 S Safety No 8
At -13:43 on June 17,1998 with the plant shutdown in Mode 4 and RHR A in shutdown coolmg mode, a sigmficant water hammer event m the plant fire protecnon system pipmg resulted m the catastropiuc failure of fire protection valve FP V 29D located in the reactor buildmg northeast stairwell. Water from the ruptured fire protecuon val e flooded the stairwell and the Residual Heat Removal C (RHR C) and Low Pressure Core Spray (LPCS) rooms located on elevanon 422. Due to water covenng the system keep fill pumps, control room personnel started RHR B in suppression pool coolms mode to maintain system operabthry. After venfying no fire or threat of fire,operanons personnel shut off the operanns fire protection pumps and temunated the source of flooding. An Unusual Event was declared, and supplemental fire protection personnel and equipment were called to stareby on-site until the fire protection system operabihty coald be reestabhshed. The cause of event was determined to be inadequate design of the fire protecnon system. Several contnbutmg factors exacerbated the event. Just pnor to the event the plant was shutdown, and dunng the event two systems (one from each electncal division) were mamtatned avadable for shutdown coolmg at all ames. Therefore, the safety consequences of this event was detemune to be low.
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l Emerg:ncy Prcp: redness Findings 1997 - 1998 II Other
' Event Davis-Besse 98-ON Duplicate No Date Entered 10/22/9 Safety No 8
LER 98-004:Tomado Damage to Switchyard Causing Loss of Offsite Power On June 24,1998, at approximately 2040 hours0.0236 days <br />0.567 hours <br />0.00337 weeks <br />7.7622e-4 months <br />, with the unit in Mode I at 99 percent power, a stonn cell moved I through the site area, and, at approxunately 2044 he .. a tomado touched down onsite. De Emergency Diesel j Generators were both manually started sten the C nel Room received a report of a tomado on site. De damage from the tomado, accompanying straight line C s. rain and hghtning, resulted in a complete loss of offsite power (LOOP). The LOOP caused the turbine com 4 valves to close in response to a load rejecnon by the main generator. He Reactor Protecnon System (RPS) inzuated a reactor inp on high Reaaor Coolant System (RCS) ;
pressure. At 2118 hours0.0245 days <br />0.588 hours <br />0.0035 weeks <br />8.05899e-4 months <br />, an Alert was declared in accordance with procedurc RA-EP 01500. Emergency classification, Emergency Action Level (EAL) 8.B2, Any tomado stnking facihty. Following restoration of an offsite power source, the Alert was downgraded to an Unusual event at 0200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> on June 26,1998, and at 1405 hours0.0163 days <br />0.39 hours <br />0.00232 weeks <br />5.346025e-4 months <br />, the Unusual event was terminated. The tomado resuhed ir, sigmficant damage to the offsite electncal distnbution system.telecommunicanons, power to the sirens and other unfortified strucnares. Irnrnediate correenve acnons involved the tesung and repatring of the affected electncal and mechanical equipment necessary to restore two offsite power sources and assessing damage to other plant cc.nponents and struaures and ininanng repairs. Plant telecommunicanons were restored and the siren system was retumed to 90 percent avanlabihty pnor to plant stanup.Here were no adverse effeas to tha public health or safety. Davis-Besse Nuclear Power Stanon Uma 1 startup was imnated, with reactor enticahr.m ied on July 1,1998, at 2257 hours0.0261 days <br />0.627 hours <br />0.00373 weeks <br />8.587885e-4 months <br />, but was shutdown due to elevated sulfate levels in the steam generator water chemistry on July 2,1998. Following steam generator fill, soak and drains, startup was irutiated on July 5.1998, and at 0400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> on July 7,1998, the Main Generator was synchronized to the grid.
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Event Byron 98-017 Duplicate No Date Entered 10/22/9 Safety No 8
LER 98-017: At 0247,on August 4.1998,345 kV Line 0621 between Byron Station and Cherry Valley sensed a fault causing feeder breakers at Cherry Valley Transmission Substanon and Byron Stanon Otl Circuit Breakers (OCB) 4-5 and 54 to trip open [FK). Electnc Operations idenufied the most probable cause of this fault as a hghtning stnke to Line 0621. Electric Operanons had the feeder breaker at Cherry Valley re closed and Line 0621 was re-energized. The Byron Stanon switchyard and relay house were walked down, associated tnp targets reset, and OCB 4-5 and 5-6 visually inspected for damage. At 0347, a reclosure of OCB 54 was attempted. OCB 5-6 immediately tnpped open and gave a Local Breaker Backup (LBB) causing Air Ciremt Breaker ( ACB) 6-7 to snp open resulting in a loss of offsite power to the Unit 1 Stanon Auxiliary Transformers (SAT).The amarent cause l
of the loss of offsite power for Unit I at Byron Station was due to the failure of the 94X relay to reset after the fault cleared. Furthermore, due to the procedural inadequacy of B AR 0 35-Dl.the operator attempted reclosure o' 345 kV OCB 5-6 with the false inp signal on 345 kV OCB 5-6, caused by the failed 94X relay on Line 0621 System 2 relays.11us,in conjuncnon with tne improper pole synchronizanon time on OCB 5-6, led to loss of offsite power to Umt 1 System Auxiliary Transformers. Correcove acnons are to: Invesngate the fadure of the 94X relay to reset, review the annunciator response, r: vise procedure BAR 0-35 131, and review IEN 97 12 for switchyard spare part reviews. An Unusual event was declared and an Emergency Notification was made. his event is reportable per 10rFR50.73 (a)(2)0v).
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Emergency Preparedness Findings 1997 - 1998 H
Other "Other Oconee 97 001 Duplicate No Date Entered 10/22/9 Safety No 8
Title:
Unisolable Reactor Coolant Leak Due to Inadequate Surveillance Program On Apnl 21,1997. Unit 2 was at 100% Full Power (FP). At 2245 hours0.026 days <br />0.624 hours <br />0.00371 weeks <br />8.542225e-4 months <br />, Operators noted indications of a 2.5 gpm Reactor Coolant System (RCS) leak. De source could not be determined, so at 0352 hours0.00407 days <br />0.0978 hours <br />5.820106e-4 weeks <br />1.33936e-4 months <br /> on Apnl 22, power reducnon began. At 20% FP Operators could not idennfy the leak as isolable, so the decision was made to go to cold shutdown. At 1448 hours0.0168 days <br />0.402 hours <br />0.00239 weeks <br />5.50964e-4 months <br />, the reactor was tnpped by a planned tests. At 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br />, a NOUE (Notice i of Unusual event) was declared when the leak exceeded 10 gpm. He NOCE was terminated at 2032 hours0.0235 days <br />0.564 hours <br />0.00336 weeks <br />7.73176e-4 months <br /> after the leak reduced below 10 gpm. He leak was foted to be a crack at the safe end to pipe weld on the High Pressure i Injection to RCS cold leg nonle near Reactor Coolant Pump 2A1. De safe end and pipe were found to be I cracked intemally and the thennal sleeve was found to be loose and damaged. The failures were caused by thermal cy ctmg fatigue, The root causes were determined to be failure to implement an effecove HPI nonle inspection program based on available industry recommendations and failure to effectively evaluate known problems and implement appropriate correcdve actions. Corrective accons include repair of the nonle components and establishing an effecove program to inspect and support nonles. Evaluation shows that the HP! line still had a factor of safety greater than 2 under design basis event loads. Prompt shutdown prevented the develognent of an unsafe condmon.
Other Browns Feny 97-001 Duplicate No Date Entered 10/22/9 Safety No 8
Title:
Loss of Offsne Power on Unit 3 Durmg Refuelmg Outage Resulting From a Shorted Component On March 5,1997, at 1040 hours0.012 days <br />0.289 hours <br />0.00172 weeks <br />3.9572e-4 months <br /> Central Standard Time. (CS O Unit 3 received engineered safety feature systen actuations due to a loss of offsite power. De loss of power was the result of the loss of both the Athens and Trinity 161 kV power hnes. Emergency Diesel Generators 3A,3C. and 3D automatically started and tied to their respeenve shutdown boards. At 1122 hours0.013 days <br />0.312 hours <br />0.00186 weeks <br />4.26921e-4 months <br /> CST. BFN declared a Nonfication of Unusual event (NUE) for Umt 3 due to a loss of offsite power greater than 15 minutes and notified NRC in accordance with 10 CFR 50.72(a)(3).
At 1136 hours0.0131 days <br />0.316 hours <br />0.00188 weeks <br />4.32248e-4 months <br /> CST, following the restoration of the offsite power to Unit 3. BFN terminated the S1'E. and in accordance with 10 CFR 50.72(c)(I)(iii) notified NRC. The root cause of this event was the sensitivity of the auxiliary tripping relays. WA has replaced the relays involved in the event with less sensinve relays. TVA is currently replacmg other Westinghouve AR type relays in similar applications with less sensittve relays. His eventis being reported accordance wnh 10 CFR 50.73(aX2Kiv), as any event or condition that resulted in manual or automatic actuanon of m y eng neered safety feature including the eactor proteccon system.
Other Conn. Yankee 97-013 Duplicate No Date Entered 10n2/9 Safety No 8
Title:
Inadvertent Halon Discharge in Comrol Room Due to Camera Flash Results in Precaunonary Control Room Evact*n On August 7.1997, at approximately 0947 hours0.011 days <br />0.263 hours <br />0.00157 weeks <br />3.603335e-4 months <br />, with the plant in a permanently defueled condition, the control room Halon system was madvertently discharged while a trauung instructor was taking flash camera pictures of the inside of a Halon control panel located in the control room. Becaue prolonged exposure to Halon, a chemical used to exnnguish fires, can result in nausea and dirmness, the control room and the adjacent security central alarm station were evacuated as a precautionary measure. Upon exiting the control room, operators continuously monitored the control board through windows in the viewing area located immediately outside the conuol room.
Operators were not prevented from reentenng to perform nmely actions if they had been required. He control roorn venn! anon system was used to remove the Halon, the air was sampled and the control room reoccupied m approximately 45 minutes. No personnel injuries were sustained. Subsequent testing confirmed that the hght from the camera flash affected a light sensinve cuest (EPROM) located inside the Halon control panel wtuch initiated the actuation of the system wnhout any tune delay. Corrective action consisted of instalhng a protective cover over the EPROM wmdow and evaluating other systems that use EPROM circuits. His event was reported as an Unusual event and is being documented as a voluntary LER.
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1 1
Emergency Preparedness input to the Commission Paper on NRC Performance Assessment. l 1
1.0 Emergency Preparedness Corner Stone 7 ere threshold oflicensee safetyperformance above which the NRC can allow licensees to aHre eaknesses with decreasedNRC action.
J.
NRC Overall Safety Mission Ensure Public Slde a result of civilian nuclear reactor operation Strategic Perfannance Area b
Reactor Safety 9.
Cornerstone- Emergency Pre ness Emergency Preparedness (EP) is the mal barrier in the defense in depth NRC regulations provide in ensuring the public health and safety while allowing operation of civilian nuclear reactors. In this way it is related to the Reactor Safety gegic Performance Area.10 CFR Part 50.47 defines the requirements of an EP program.
i Measures taken to protect the public from the effects-@e radiological emergency must necessarily involve action by governmental authorities in the vicinity of the reactor. Generally, the program, procedures and systems maintained to implement such governmental actions are 4 referred to as ofsite EP. The facets of the EP program that involve Ednllion t of the accident, mitigation ofits affects, assessment of the offsite impact and communihtion ofinformation to governmental authorities, including protective action recommendationOe generally referred to as onsite EP. The licensee is responsible for ensuring the development of both aspects of the progrant, but generally will turn over the offsite program to governmental authorities for implementation and maintenance. Similarly, NRC is responsible for ensuring the adequacy of the total program, but has turned over assessment of the offsite program to the Federal Emergency Management Agency (FEMA).
While both aspects are vitally important to ensuring the EP program can serve its intended i function, the offsite portions of the program are maintained by governmental authorities and the collection of data to support performance indicators (PI's) may not be appropriate. However, regular assessments by FEMA of the efficacy of the offsite progmm do take place. The use of these assessments can form the basis for reasonable assurance that the offsite aspects of the i program are capable of taking adequate protective measures should they be necessary.
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, Compliance of EP programs with regulation is largely assessed through observation of response to simulated emergencies. Although routine inspection of onsite programs are currently i conducted to ensure administrative aspects are functioning and FEMA requires an annual I cenification letter from governmental authorities for generally a similar purpose. However, demonstration exercises form the key observational tool currently used to suppon, on a continuing basis, the reasonable assurance that adequateprotective measures can and will be the event ofa radiological emergency. This is true for the most risk significant facets of r EP ogram. This being the case, the PI's contemplated for onsite EP draw significantly m ormance during simulated emergencies but are supplemented by licensee self ment and NRC inspection. Assessment of the adequacy of offsite EP will rely (as it does currently) on FEMA assessment of the biennial exercise and cenifications from governmental authorities. y The dominating r slFsignificant aspects of the onsite EP program have been identified as:
A1 Timelv and accurate classification of events; including the recognition of events as potentially exceeding emergency action levels (EALs), maintenance of the EAL scheme
, in an approved and appro te configuration and any assessment actions necessary to support the classificationj
. Timelv and accurate notfi on of offsite governmental authorities; including the Alert ;
and Notification System 7ade5cy of communication channels and the direct interface with offsite authorities; Timelv and accurate develooment and commuselon of erotective action recommendations to offsite authorities; includ d y accident assessment necessary to support the protective action recommendation lopment, the protection of emergency workers and direct interface with offsite auth s; and Emergency Resoonse Organization readiness; including adequacy of facilities, timely activation of the Emergency Response Organization (ERO), adequate training of the ERO to ensure proficiency, efficacy of the corrective action progrliiitifdentify and correct deficiencies in ERO proficiency and supporting equipment / faci ities.
.1 Statement of Objective Ensure that the licensee capability is maintained to take adequate protective measures in the event of a radiological emergency Scope Onsite EP program is addressed by the proposed PI's and inspection elements.
Offsite EP program is addressed by FEMA related elements Desired Result / Performance Expectation 2
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e i
Demonstration that a reasonable assurance exists that the licensee can effectively implement i emergency plans to adequately protect the public health and safety in the event of a radiological emergency.
l 2.0 Data Requirements 11 site EP Program l l l
Tbe equired comes from the following sources:
l J Licensee self assessment of drills and exercises i- - Lice sessment of the response to actual EP activation events l
= Licen ssessment of shift operating crew response to simulated emergency events
. Lice assessment of plant management recognition of events as contained in LERs A Statistics on drill participation by emergency response organization (ERO) members
- Statistics on ERO duty rosters l
=
Statistics on ERO activa tests j l - Statistics on the conduct related critiques of actual events and training activities
- . - Licensee self assessme remainder of the EP program.
I 2.2 Offsite EP Program l
Results of assessments by FEMA of the biennial exe e annual state EP certification and the absence of FEMA withdrawal of program reasonal 2ssurance.
A 3.0 Onsite EP Program l
3.1 Classification of Emergencies r 1 Basis: Recognition and subsequent classification of events is ask significant activity of an EP program. It is assumed that classification will lead to activation of the ERO l
as appropriate to the emergency class and notification of governmental j authorities. If an EP program consistently recognizes and classifies simulated and actual events in a timely and accurate manner, it indicates that the program is operating at or above the threshold oflicensee safetyperformance above which the NRC can allow licensees to address weaknesses with decreasedNRC action.
3.1.1 Numerical performance indicators:
1 i
. A.
- Percent of timely and accurate classifications of simulated emergency events
, = Number anc' type of opportunities for classification 3
I-
e l-l (OR fru. tion, numerator and denominator, of timely and accurate classifications of l simulated emergency events over number of opportunities) i Requirements: All activities that are formally critiqued for the timely and accurate classification of emergency class shall be included in this statistic. All l simulated emergency events that are identified as opportunities for this PI i
shall be included in the statistics, i.e., a candidate opportunity can not be removed from the data set after actual performance, for instance due to poor performance. This would include the biennial exercise, any other drills of appropriate scope and operating shift simulator evaluations
- conducted by the licensee training organization. The later element would i
,, only be appropriate when the evolution being evaluated is of such a l I
l h character as to require classification ifit were a real event. No minimum l L is set for these observational opportunities, but a statistical analyses l
A rformed on the data will likely recognize that the more opportunities l provided the more accurately the PI numerical value represents licensee l performance. All critiques shall be conducted by an individual (s) that is
, qualified to dge the timeliness and accuracy of the classification j perform e tatistical opportunities may include multiple events during
! a single , 'olution, etc., if supported by the scenario.
l l B. -
Percent of(operationally oriented?) LERs that should have been declared as emergency events, but were not. ,
3 (Or fraction as discussed above)
, ~.
! Requirements: Recognition of actual plant events as warranting classification as an l emergency or not, is a measure of the quality of EP training and its l implementation. While the number of missedTelfaihtions is expected to l
be small, this indicator would reflect program qdlity. Review of these
- events by an individual (s) that is qualified to judge,the timeliness and i accuracy of the classification performance is required to determine the
. statistics.
C. - Percentage of declared emergencies that were timely and accurate.
I - Percentage of declared emergencies that were later found to be inappropriate (or retracted)
I (Or fraction as given above)
Requirements: All declared emergency events must be formally critiqued for compliance
! with approved procedures, at least in the areas identified as risk l significant. All statistics from these events must be reported. Review of i
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l
, these events by an individual (s) that is qualified to judge the timeliness
!- and accuracy of the classification performance is required to determine the statistics.
t l 3.1.2 . Inspection Interface l
l y, -d inspection areas that would be necessary to support these PI's include:
l l 4 erify that the collection ofdata is in compliance with the guidelines above.
. a.
\
l Review the efficacy of the self assessment program to gather valid statistics thought the
! accurat ue of successes and failures during classification opportunities. j i H l Review the ticacy of the corrective action program to correct identified deficiencies in l the risk.dptiTkant areas.
J l
l Review control of the EAL set in an approved and validated configuration.
i 9 Review self assessment events during the inspection period.
Review the scenarios used to evelop PI statistics to verify adequacy of challenge.
Review the licensee's self assessment program,grelates to classification activities.
Review of biennial exercise scenario for adeqt A '
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- 3.2. Notification r 1 Basis
- Timely and accurate notification of offsite authorities is risk significant activity of an EP program. It is assumed that notification will _to activation of the ERO as appropriate to the emergency class and mobilization of governmental authorities. If an EP program consistently performs notifications during simulated and actual events in a timely and accurate manner, it indicates that the program is I operating at or above the threshold oflicensee safetyperformance above which the NRC can allow licensees to address weaknesses with decreasedNRC action.
i i 3.2.1 Numerical performance indicators:
A.
- Percent of timely and accurate notifications during simulated emergency events
=
Number and type of opportunities for notification (OR fraction, numerator and denominator, of timely and accurate notifications during 5
simulated emergency events over number of opportunities)
Requirements: All activities that are formally critiqued for the timely and accurate performance ofnotifications to offsite authorities shall be included in this statistic. All simulated emergency events that are identified as opportunities for this PI shall be included in the statistics, i.e., a candidate
'! opportunity can not be removed from the data set after actual performance, l
for instance due to poor performance. This would include the biennial l
exercise and any other drills of appropriate scope. Operating shift simulator evaluations conducted by the licensee training organization shall be included in the statistic if notification is simulated as a part of the q ., evaluation. Use of operating shift simulator evaluations would only be q appropriate when the evolution being evaluated is of such a character as to require classification of the event and subsequent performance of A tifications. No minimum is set for these observational opponunities, but a statistical analyses performed on the data will likely recognize that the more opportunities provided, the more accurately the PI numerical
, value repre
- ts licensee performance. All critiques shall be conducted by an individpal ) that is qualified tojudge the timeliness and accuracy of notificat' ns. tatistical opportunities may include multiple events during a single 'll,i supported by the scenario. The opportunities for notification would include: initial emergency classification notification, upgrade of emergency class, neHication of PARS, notification of change in PARS and formal periodic u; of offsite authorities if required by procedures.
B.
- Percentage of timely and accurate notifications during declared emergencies.
(Or fraction as given above) r 7 l
Requirements: All declared emergency events must be formall lgitiqued for compliance with approved procedures, at least in the areas identified as risk
, significant. All statistics from these events must be reported. Review of these events by an individual (s) that is qualified to judge the timeliness and accuracy of the notifications is required to determine the statistics.
C.
- Percent availability of Alert and Notification System Requirements: Statistical information gathered in support of system availability reports given to FEMA would form basis of this Pl. However, the reporting of availability is not standardized currently. It is proposed that the following rules be applied to gathering of this data:
- Failure of a siren is indicated by failure of any portion of the 6
-7 f
system that would have prevented it from performing its safety function, i.e., creating its design sound level and pattern.
The period assumed for the failure would be half the time since the last successful test.
Periodic testing is in accordance with FEMA guidance and actually tests the ability of the siren to perform its intended safety function.
A failure will be assumed to last at least on: day (hour?).
D Proposed ins InspectionInterface TBD areas that would be necessary to support these PI's include:
. Y
- Verify the collection of data is in compliance with the guidelines above.
A
- . Review the efficacy of the self assessment program to gather valid statistics thought the accurate critique of successes and failures during notification opportunities.
t
- Review the efficacy of tive action program to correct identified deficiencies in the risk significant are
- Review the critique of actual events during the inspection period.
- Review conduct of Alert and . sotification sireri s M
qtem for compliance with FEMA guidance.
Review licensee self assessment program as it relates to adequacy of communication channel testing, communication systerr availability and timely correction of deficiencies.
r g 1 Review of the licensee self assessment program as it relates to a equacy ofdirect interface with offsite authorities during exercises and drills tha.tjavolve offsite authority participation.
3.3 Protective Action Recommendation Basis: The timely and accurate development of protective action recommendations (PARS) is a risk significhnt activity of an EP program. It requires that several supporting activities be performed including: accident assessment, quantification of radiological release magnitude, projection of the potential dose to the public and communication to government authorities. It is assumed that communication of PARS will lead to actions by governmental authorities to protect the public health and safety. If an EP program consistently develops and communicates PARS in a timely and accurate manner, it indicates that the program is operating at I
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or above the threshold oflicensee safetyperformance above which the NRC can j allow licensees to address weaknesses with decreased NRC action.
3.3.1 Numerical performance indicators: i l
A
- Percent of timely and accurate PARS during simulated emergency events
'q Number and type of opportunities for PAR development ;
i !
' R fraction, numerator and denorr ar, of timely and accurate notifications during
"'] simulated emergency events over number of opportunities) l Requirements:,. All activities that are formally critiqued for the timely and accurate l 1 development of PARS and communication to offsite authorities shall be l , included in this statistic. All simulated emergency events that are a ' entified as opportunities for this PI shall be included in the statistics, i.e.,
a candidate opportunity can not be removed from the data set after actual performance, for instance due to poor performance. This would include j the biennia)%ercise and any other drills of appropriate scope. Operating shift simul [t gevaluations conducted by the licensee training organization shall be c u 4d in the statistic if PAR development is simulated as a part of the ev uation. Use of operating shift simulator evaluations would only be appropriate when the evolution being evaluated is of such a character as to require classification of theevenyd sul, sequent development of PARS. No minimum is set for statistical analyses performed n th<: data will o$*ese observational likely recognize that the opport more opportunities provided, th'emore accurately the PI numerical value represents licensee performance. All critiques shall be conducted by an individual (s) that is qualified to judge the timeliness and accuracy of PAR development. Statistical opportunities may incTp[elultiple events during a single drill, if supported in the scenario by circurnstances that would require modification of the initial PAR. 1 '
3.3.2 Inspection interface Proposed inspection areas that would be necessary to support these PI's include:
- Verify that the collection of data is in compliance with the guidelines above.
l
- Review the efficacy of the self assessment program to gather valid statistics thought the l accurate critique of successes and failures during PAR development opportunities.
- Review the efficacy of the corrective action program to correct identified deficiencies in i
the risk significant areas.
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Review of the licensee self assessment program as it relates to adequacy of direct interface with offsite authorities during exercises and drills that involve offsite authority participation, in the area of PAR communication..
Review of the licensee self assessment program as it relates to adequacy of worker protection during exercises and drills.
'I view of exercise scenarios to ensure they provide and appropriate challenge.
0 1.1 Emergency Response Organintion Readiness Basis: grams ensure the readiness oflicensee personnel, facilities and equipment tc}pu rt response to emergency situations and protect the public health and s# g The previous PI's indicate the performance of segments of the ERO in dsk.s gnificant activities during simulated and actual emergency situations.
However, this PI is meant to indicate the readiness of the total ERO to perform as an integrated organization. There are several supporting activities important to
,. ERO readiness inc ing: ERO activation tests, ERO training and drills, facility and equipment r ss checks, communications channels tests, the licensee corrective acti , licensee self assessment program, management support, effect E implementation by licensed operators, severe accident management guide implementation and ERO ability to diagnose plant accident conditions, formulate mitigating actions % implement them under accident conditions.
i If an EP program consistently ensurer hat the ERO is in a high state of readiness it indicates that the program is operating at or above the threshold oflicensee safetyperformance above which the NRC can allow licensees to address weaknesses with decreased NRC action. T 3 3.4.1 Numerical performance indicators: 1 A
- Percent of ERO that has participated in a drill or exercise in the past 24 months.
Requirements: The ERO participation indicated is that of the essential positions committed to in the Emergency Plan. Plant workers, security personnel, operations shift staff and others that are on shift or may be called in to support the emergency but do not fill positions on EP duty rosters are not intended to be captured in this PI. Positions that are formally on the EP duty roster, but not committed to in the Emergency Plan may be included, but only if this is done completely and consistently. Participation could be either as a drill / exercise participant or as an evaluator (but not as an observer). Signature on a drill / exercise attendance form would be 9
l l'i*
adequate documentation, but the intent is tliat the participation be a I l
meaningful and thorough opportunity to gain proficiency in the assigned )
position. !
I Participation in the biennial exercise and any other drills of appropriate l
scope may be used in statistics, but table top drills that do not provide l meaningful interaction with interfacing ERFs would not be appropriate.
l q! I Multiple assignees to a given ERO position could take credit for the same l
l l
" 'Q F drill / exercise if their participation is a meaningful and thorough opportunity to gain proficiency in the assigned position.
l
- B. -
E t of operating shift crew that have participated in a drill, exercise or ,
l ehl d simulator evolution in the past 12 months. l
- Requirements
- m valuated simulator evolutions contribute to statistics for several PI's.
l 'Ihis PI only indicates the training opportunities provided to operating shift crews and not their success during those opportunities. It assumes that the l , training wi , gontribute to proficiency and overall ERO readiness. It may l be expect t any evaluated evolution would be given to all shifts. That l being th 'cas hhe statistic could be in excess of 100%, e.g., if all shifts had taken 2 evaluated evolutions in the past year the PI would be 200%.
Evaluated evolutions are those simulator based evaluations that provide a j
scenario that includes emergeggnt classification and notification of 1 offsite authorities, are formally c Jtuedri by a qualified individual and are included in the PI's for classifis tidh of emergencies and notifications.
.A.
j C. -
Percentage of essential ERO positions that successfully responded in each of the last 4 pager tests.
l T p 1 l l Requirements: Pager tests indicate the readiness of the ERO to ijl duty roster positions l during emergencies that take place during off-no(gr al hours. Onl '
statistics from tests during off normal hours may be included. The results of all such tests shall be included, i.e., a test may not be removed from the data set due to poor performance. The frequency tests may be set or changed at licensee discretion, but results from the last four must be l included in the Pl. Successful response means that it could reasonably be expected that the position would have been filled within the time goal expected in the Emergency Plan. A position is filled by one qualified individual. Multiple individuals filling a single position can not be used to improve the statistics.
! 3.4.2 Inspection interface i
10
. . _. .- - = . - - _ - - - . - - - . _ = . - . . - . . - _ - _ - .
A i
- Proposed inspection areas that would be necessary to support these PI's include
Verify that the collection of data is in compliance with the guidelines above.
l Review the efficacy of the self assessment program to gather valid statistics thought the l accurate critique of pager test successes and failures.
'l i . view the efficacy of the corrective action program to conect identified deficiencies in
. a.Q3 0, facility and equipment readiness.
l l Review of the licensee self assessment program as it relates to adequacy of facility and I
equipmpadiness checks communications channels tests, the licensee corrective l action prg[ah, managemen,t support, effective EOP implementation by licensed l operatory 39ere accident management guide implementation and ERO ability to diagnosa.planheident conditions, formulate mitigating actions and implement them under accident conditions.
l t
l 4.0 Offsite EP Program TBP, but will be based on: ,
i H
FEMA evaluation of the biennial exercise havjrg no more than 3 deficiencies FEMA acceptance of the annual state certifica' ion of preparedness The absence of FEMA withdrawal of reasonable assurance 7
l i.
dww i
I1 i
l
I ;
- 4. .
e 1
Lynnene Hen &lcks
- cfdraomsm 1
t l
October 23,1998 i Rules Docket Clerk j Office of General Counsel i Federal Emergency Management Agency l
Room 840 500 C Street SW
. Washington, DC 20472
SUBJECT:
" Publication of Radiological Emergency Preparedness (REP) l Program Strategic Review Draft Final Recommendations"
! (63 Esd. Egg. 48222, September 9,1998) l L The Nuclear Energy Institute (NEI),* on behalf of the nuclear energy industry, has l reviewed the " Publication of Radiological Emergency Preparedness (REP)
L Program Strategic Review Draft Final Recommendations,"(63 Eed. e E_eg.48222, e
September 9,1998). The industry strongly supports the FEMA reform initiative to improve efficiency and cost effectiveness. Specific comments regarding the Strategic Review are enclosed.
l In addition to the specific comments provided on FEMA's Strategic Review, l- industry believes initiatives underway at NRC, as presented at the NRC l Performance Assessment Workshop September 28-October 1,1998, provide more L insight for FEMA's regulatory reform initiative. Representatives from FEMA were l in attendance at the workshop. The NRC performance assessment workshop l focused on a new paradigm of risk informed performanced based regulatory p
- NEIis the organization responsible for establishing unified nuclear industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include all utilities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect / engineering firms, fuel
- fabrication facilities, materials licensees, and other organizations and individuals involved in the nuclear energy industry.
Rnles and Docket Clerk l
October 23,1998
{ Page 2 oversight. The~ benefit of a risk-informed oversight approach is the ability to focus resources on areas important to safety. The NEI White Paper describing this process "A New Regulatory Oversight Process,"is enclosed.
l The workshop included a breakout session on Emergency Preparedness.' The goal of this breakout session was to focus on the safety significant onsite performance
- indicators that address the objective of insuring that licensee capability is l'
maintained to take adequate protective measures in the event of a radiological emergency. Information was identified at the breakout session which can be used to adequately assess licensee onsite performance.
I The onsite Emergency Preparedness Performance Indicators are based on the following inputs from actual events and exercises: Emergency Classification (event recognition, emergency action levels, and accident assessment), Notification (alert and notification, adequate communication channels, and direct interface to offsite organizations), Protective Action Recommendations (accident assessment, l protection of emergency workers, and direct interface with offsite agencies), and
, Emergency Response Organization Readiness, (adequacy of facilities, and l activation of the Emergency Response Organization). The industry and the NRC are working to develop threshold reporting levels. Once this has been accomplished NRC inspection procedures will be revised to reflect these changes.
The scope of the NRC workshop was limited to onsite emergency plans; offsite
- emergency plans were not addressed but are believed to be bound by FEMA's l Finding of Reasonable Assurance. The industry encourages FEMA to review this approach as a basis for assessing performance for offsite emergency planning.
i f
The industry's goal is to help achieve comprehensive change in the regulatory process so that the industry can most effectively carry out our mutual responsibilities for public protection.
NEI appreciates the opportunity to comment on this notice and stands ready to meet with you to discuss any of the recommendations presented. Please contact Alan Nelson l
at (202) 739-8110 or by e-mail (apn@nei.org) with any questions on this response.
Sincerely, Lynnette Hendricks Enclosure i
a-yr , * , -- - - g, a
=. .==;. - . . . . = - -
, Enclosure
- SDecific Comments Radiological Emergency PreDaredness (REP) Strategic Review Draft Final Recommendations (63 Fed. R_eg. 48222, September 9,1998)
Recommendation 1: Streamline the REP Program
, a. This set of recommendations is commendable because it de-emphasizes l
FEMA's reliance on biennial exercises to confirm reasonable assurance finding and places equal reliance an self-reporting and FEMA technical assistance.
- b. Industry recommends consolidation of the current FEMA-REP-14 and 15 exercise objectives into the six programmatic areas identified in the draft final recommendation 1.1. The industry also supports elimination of Objectives 23,31,32, and 33.
l
- c. Comments:
- 1. Recommendation 1.1, consolidation of exercise objectives, does not say what guidance will replace the prescriptive and detailed FEMA-REP-14 and 15 exercise evaluation criteria. The recommendation should l address the desired outcomes versus compliance with evaluation
- criteria.
- 2. The "no notice", FEMA initiated, once in six years demonstration of the prompt alert notification system for a fast-breaking scenario would impose a new REP requirement. It is a novel proposalin that no other exercise activity has ever involved a FEMA initiated event without
- notice to any of the parties. There is no NUREG 0654 or other program criteria or requirement driving this activity. The industry opposes this initiative and recommends its removal from the final strategic review recommendations. Industry questions the practicality of such a demonstration,i.e., simulated activation of the public alert system and simulated broadcast of an EAS message with protective l action recommendations within 15 minutes of FEMA contacting a primary warning point. This recommendation is wholly inconsistent with Recommendation 1.7, i.e., scenario realism.
l l
- 3. Recommendation 1.7, should also allow flexibility in the severity of
- ccnditions to include scenarios that stop short of offsite radiological consequences.
a
- 4. Recommendation 1.9 states annualletters of certification should be submitted to support program changes. This recommendation requires clarification. Does this recommendation mean that states will be asked to assess the impact of any program changes on the effectiveness of their plans?
- 5. Recommendation 1.13, consolidation of REP guidance, is very important. Appendix 1 catalogues a myriad of REP series documents, guidance memoranda, policy statements, etc. The recommendation proposes to consolidate these materials into a single REP Program Handbook. The recommendation should state that a primary purpose of this initiative will be to focus REP guidance on expected results and to make it less prescriptive. l Recommendation 2: Increase Federal Participation in Exercises No comments.
Recommendation 3: Use State, Tribal and Local Exercise Evaluators
- a. The industry strongly supports this recommendation. This recommendation should have two specific goals: 1) decreased reliance on contractor personnel to evaluate exercises, and 2) increased opportunities for state and local emergency management personnel to perform structured self-assessments of their programs.
The latter goal is not entirely consistent with the proposed caveat that state, tribal and local evaluators cannot evaluate exercise performance within their own jurisdictions.
- b. FEMA should consider expanding the availability of exercise evaluation training for state, tribal and local personnel through the regional offices to support Recommendation 5 - Enhance the REP Training Program.
Recommendation 4: Include Native American Tribal Nations in the REP Preparedness Process No comments l Recommendation 5: Enhance the REP Training Program l
No comments l
s, .
Le l
l -o i Nuclear Energy institute Project No. 689 i-l cc: Mr. Ralph Beedle Ms. Lynnette Hendricks, Director Senior Vice President . Plant Support and Chief Nuclear CWicer Nuclear Energy Institute Nuclear Energy Instr.ute Suite 400 Suite 400 1776 I Street, NW
, 1776 i Street, NW. Washington, DC 20006-3708 Washington, DC 20006-3708 Mr. Alex Marion, Director ' Mr. Charles B. Brinkman, Director-Programs Washington Operations ;
. Nuclear Energy Institute ABB-Combustion Engineering, Inc. ,
h Suite 400 12300 Twinbrook Parkway, Suite 330 1776 l Street, NW l
Rockville, Maryland 20852 l Washington, DC 20006-3708 l
Mr. David Modeen, Director Engineering l Nuclear Energy Institute Suite 400
! 1776 I Street, NW Washington, DC 20006-3708 l Mr. Anthony Pietrangelo, Director Licensing Nuclear Energy institute Suite 400 1776 l Street, NW Washington, DC 20006-3708 Mr. Nicholas J. Liparuto, Manager Nuclear Safety and Regulatory Activities j
- Nuclear and Advanced Technology Division i
Westinghouse Electric Corporation ;
P.O. Box 355 Pittsburgh, Pennsylvania 15230 Mr. Jim Davis, Director i Operations Nuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708 L
2 l
t L
'e $pauog A
/ t UNITED STATES I ,
- , NUCLEAR REGULATORY COMMISSION
- WASHINGTON, D.C. 20666 4001
- November 17, 1998 l MEMORANDUM TO: Thomas H. Essig, Acting Chief Generic issues and Environmental Projects Branch !
l Division of Reactor Program Management Office of Nuclear Reactor Regulation FROM: Stewart L. Magruder, Project Manager . Mad ;L %
Generic issues and Environmental Projects Branch l Division of Reactor Program Management l Office of Nuclear Reactor Regulation l l
SUBJECT:
SUMMARY
OF OCTOBER 29,1998, MEETING WITH THE NUCLEAR ENERGY INSTITUTE (NEI) REGARDING EMERGENCY PLANNING PERFORMANCE MEASURES l 1
i On October 29,1998, representatives of the Nuclear Energy Institute (NEI) met with j representatives of the Nuclear Regulatory Commission (NRC) at the NRC's offices in Rockville, j Maryland. Attachment 1 provides a list of meeting attendees. i The purpose of the meeting was to discuss the development of performance measures to be 4 used by NRC to aid in assessing emergency preparedness at operating nuclear plants. The handouts from the meeting are included as attachment 2.
The following topics and actions were discussed at the meeting:
The group discussed the draft NRC document on Emergency Preparedness (EP)
Performance Indicators (PI's) (Attached) l Action: NRC to collect comments and revise for next meeting (11/5/98)
NEl discussed industry acceptance of the draft PI's and the scope of the existing regulatory burden.
NEl questioned the interface between these PI's and the proposed use of PI's to replace the 10 CFR 50.54(t) audit function. There was consensus that the pending change in regulations should not impact this effort.
NEl suggested that NRC discuss with the Federal Emergency Management Agency (FEMA) the use PI's to assess the efficacy of offsite EP programs. NRC stated that should FEMA decide to use Pl's it would be acceptable, but that the decision to do so would be FEMA's and this working group has no influence with the FEMA process. NEl j provided a copy of their comments on the FEMA Program Strategic Review (attached).
l l-NII D ^u C3(r'{ 1.}y
c' i %
i T. Essig 2-1 The group discussed the selection of failures under the draft Pl process. There was agreement that some selection criteria for risk significant failures was appropriate.
Action: NRC to address in future revision of draft PI's.
l The group discussed the weighting of Pl statistics for the more risk significant items.
Some consensus was reached that elaborate formulas were counterproductive and each individual event should be simply counted in the gathering of statistics.
l NRC discussed how the number of drills and other opportunities to gather Pi statistics l affects the voracity of the Pl, i.e., the more opportunities, the more certainty that the Pl is accurate. There was recognition that this was appropriate.
NEl questioned how self assessment contributes to the Pl and how this could compensate for a lower number of statistical opportunities. Consensus was reached j that self assessment was an important element in several areas and could contribute to the quality of an EP program and thereby compensate for a lower number of statistical opportunities. But it was recognized that modification of PI numerical values based on the efficacy of a self assessment program was not being considered.
l NEl stated that industry was concemed that the implementation of this process be done l by a core inspection team to ensure consistency. They were concerned that difierences
( between regional management and individualinspectors not negate the beneficial l
aspects of the Piinitiative.
Action: NRC to relate that concern to the PI working group.
- NRC and NEl discussed historical data related to the proposed PI's that could be obtained from past inspections. Data from 1997-98 was available and supplied by NEl (attached). A brief review of the data was performed by the group and there was consensus that development of thresholds for PI's could be based on the historical data.
Action: NRC and NEl to analyze data before the 11/5/98 meeting and meet with i
personnel with knowledge of the statistical use of such data to determine if the process could work to set thresholds.
l l
Project No. 689 Attachments: As stated cc w/att: See next page
+,
l The group discussed the selection of failures under the draft PI process. There was agreement that some selection criteria for risk significant failures was appropriate.
Action: NRC to address in future revision of draft PI's.
The group discussed the weighting of Pl statistics for the more risk significant items.
Some consensus was reached that elaborate formulas were counterproductive and each individual event should be simply counted in the gatharing of statistics. !
l a
NRC discussed how the number of drills and other opportunities to gather PI statistics affects the voracity of the PI, i.e., the more opportunities, the more certainty that the Pl is accurate. There was recognition that this was appropriate.
- NEl questioned how self assessment contributes to the Pl and how this could compensate for a lower number of statistical opportunities. Consensus was reached l that self assessment was an important element in several areas and could contribute to the quality of an EP program and thereby compensate for a lower number of statistical opportunities. But it was recognized that modification of PI numerical values based on '
the efficacy of a self assessment program was not being considered.
NEl stated that industry was concerned that the implementation of this process be done by a core inspection team to ensure consistency. They were concerned that differences l between regional management and individual inspectors not negate the beneficial aspects of the Piinitiative.
Action: NRC to relate that concern to the PI working group.
NRC and NEl discussed historical data related to the proposed PI's that could be obtained from past inspections. Data from 1997-98 was available and supplied by NEl (attached). A brief review of the data was performed by the group and there was consensus that development of thresholds for PI's could be based on the historical data.
I Action: NRC and NEl to analyze data before the 11/5/98 meeting and meet with personnel with knowledge of the statistical use of such data to determine if the process could work to set thresholds.
Project No. 689 ;
Attachments: As stated cc w/att: See next page DISTRIBUTION: See attached page OFFICE PM:PGEB PERB SC:PGEB NAME SMagruder$w# RSullivan U MieE l DATE 11/9/98 11/l3/98 11//7/98 i
t i
l
..- . . =- - _. -
T Distribution: Mtg. Summary w/ NEl re EP Performance Measures Dated November 17, 1998 Hard Cony PUBUC PERB R/F OGC ACRS SMagruder RSullivan EMail SCollins/FMiraglia BSheron BBoger JRoe DMatthews TEssig CMiller BZalcman RSullivan FKantor SRoudier SMagruder GTracy, EDO
._ _ __ .. _ _ ._. - - . - _ _ = - _ _ _ . . _ . .__ _. __ _ ... . _ ._ -.__._ __.. .
o, s
NEl/NRC MEETING ON EP PERFORMANCE MEASURES
-10/29/98 List of Attendees i
i Name Organization A. Nelson NEl l B.' McBride VEPCo l D. Stellfox McGraw-Hill l R. Sullivan NRC/NRR l' l F. Kantor NRC/NRR l S. Roudier NRC/NRR l
I
-)
i Attachment 1 l
l l
1
--- 4--- e _ ,y -- -- - - - r ~ y w-,-g--
-~. . - . - . . . . . . . - ~- . . . ~ . . .
.-- - .=- .. . . - , - _ , -
l
'e.
I Total Emergency Prope*adness Findings 1997 1999
- O 5 10 15 20 25 l
sio.ru Ferry Conn. Vanhoe 'l Oconee J
IP * * '
l CrysalR er M l Omeo Canyon --
Duane Arneed W Onna -
McGuwe -
D4ne Mde Pown --
Preme Island M Reesmon -.
san onee muni gone,,og . . . .
s =ye e i seah Tomas -
s,ry a sw.verenna m v.m nlva,*.e --
J s.a v.s.y - i Sevas.ca w Dresden -
In6en Powit 2 u,r.n.h Monticado Pdgrim Quad Caos -
TWI M vogr.e --
Won Creek i e,s o. .-
Harne -
Kewswees -
Oysest Creek -
Perry .-
Turkey Peat - -- -
Arkansas -
Cook --
e Rwer send -
WNP3 - - - -
i Caw Ct#s -
l Fort Caswun -
u saa.
l Pese veeve -
z.n ce,per .
i o,en. oa -
Wasedord --- --
Mdiatene - -
C. y -
C men P.a=
Cktnen Attachment 2
i
\.h \
., Emergency Preparedness Findings p' l
1997 - 1998 #/
Category ?l) s Sut> Category:1r illSut> Category 2il IFt l URi l Vloiation l Weakness l Accident Assessment ! Exercises j4! 4 i
. .!i : !
Accident Assessment jinspections 2 ,
I
- M'
'[
$mergency Action Level Exercises
- 1. _
i1l l.!_ f 1
} l l Emergency Action Level jinspections 2!
D- m . i 1 ' .
Emergency Action Level Real Events LERs 1
Event Recognition 1 2
) Exercises 1l
[ Event Recognition } inspections 1j f j
f f 3
" i Event Recognition 'Real Events LERs ' } 2 I l
1 M! H5frect interface wnn M-i= - :
! 2 l
! ' l Offsite Agencies ! j Direct Interface with ilnspections i : 1 1 Vf, Offsite Agencies .,!. _,
j.
N Direct Interface with 'Real Events LERs ' : 1 l
/ Offsite_ Agencies Adequate Communication ! Exercises
} _, 1 1j 1 2 l Channels ,
~'
^ '
Alert and Notification ~sxercises }1 3 SY. stem __ L Alert and Notification Real Events LERs ' 1 ! 2 1 '
u System j ,
Direct Interface to Offsite Exercises 1 3
" '"~~'
- Direct Interface to Offsite Ilnspections 1 Direct Interface to Offsite ' heal Events LERs 'TI
' Direct interface with Exercises j 1 Offsite Agencies f Direct Intedice with Real Events LERs 1 1
[ Offsite Agencies _ ,_ , , , , , , _ , , j
! lll _ Direct Interface with Exercises 1 i ,Offsite Agencies , ,
' Accident Assessment Exercises 2' 1 4 j Accident Assessment inspections 1 2 1
, . 1 g Activation of Emergency Exercises 1 l
\ , Response Organization , l Adequate Communication Exercises 1 l
Channels Direct Interface with Exercises 2 j ~, _ _
Offsite Agencies ... , _ . , , ,
Other Exercises, j 1 I
i -
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t Page1 10/28/98
.o 1 Emergency Prep $ redness Findings l 1997 - 1998 Category lRin Sub Catery19 ! l 18ut> Category 2 a l lFl l URi l Violation l Weakness ilnspections 1 j ill Other Protection of Emergency Exercises 1 I 8 Workers ,
5 Protection of Emergency ' Inspections 2 Workers
- TlWorkersrotection of Emergency' heal 1{ Events LERs
^
IV
^
Activationof Emergency { Exercises ~T 1 1 4
);
,.R,espo9se Ofganization,,,,,,,,;
Activation of Emergency inspections 2 8
... Response Organization _
Activation of Emergency lReal Events LERs 3{: 2 0g Response Organization i., _ ,
I Adequacy of Facilities Exercises 2 1 1 Adequacy o"f Facilities ' Inspections 4l3 i 11 Adequacy of Facilities Real Events LERs 11 i
Exercises 6!1 1 2 Other 2]
I Other [ Inspections 5 18 Other Real Events LERs "I{ 1 V I'Other jReal svents LERs ,1
' I-
.I -
i t
l Page 2 10/28/98
l ee l
l ..
Emergency Preparedness Findings 1997 - 1998 Exercise Summary l [4 59 Wah ExerciseType# mr. dl: Nurnberg Annual drill i Sg
[ Biennial Exercise i 18 Full Participation Exercisa 12 Plume Exposure Exercise 12; dIIhsAnS$ k d b Drill b . E Lk NI
- 26 Medical Emergency Drill 2 Radiation Protection / Field Team Drill 1 (semedial OSC Exercise 1 l Simulator Walkthrough 9
, ,. su6ioI5i7
@E',l 1;/ ; ,c.fw,'1, f,. ; .;'8 ll P ' c"; 'E Total : 27'39-am l
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i I
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l i-Page 3 10/28/98 l
l
1 Emergency Preparedness Findings 1997 - 1998 Plant Summary b uSheName- 4tFllURilViolationl-Weakness l kTotalMl Browns Ferry 1 1 1 0
'onn. Yankee j i G i
Grystal River i1 ; 1
'Duane Amold i1 1 Ginna i~i~* }I li 1
1 1 McGuire j
^ }
1 Nine Mile PointT 1
'Oconee l 0
1 Prairie Island i 1 1 !
i 1 1
[5tobinson
[ San Onofre 1 i 1 Seaorook i ! i 1 1* 1 Sequoyah T~I i 1 1
[ South Texas
'Susquehanna
[t1 ! 1 1
1 1
yermont Yankee [,,_,
Beaver Valley l i1 1
1
[
j
]j 1 2
i i 1 1 2 I, Brunswick -
.t
! Byron !1; ! t 1
'6iablo Canyon [~ E 1 ! lI 1 Dresden I~i~ 1 [ 2 I
,IEidiipoint 2 1 i 1 2 Limerick j i I~~~i i 1 2 Monticello T2; i i 2 Quad Cities I~f' j 2 ISurry i . l 1 1 TMI ! 2 l 2 Vogtle j i1 1 j 2 Wolf Creek I~~~ { 2 i 2 IBraidwood i2 1 l 3 Hams ! 2 1 1 3
~
Kewaunee 13 3 Oyster Creek 1 3
[fi Perry 2 1 3
[ Pilgrim 2 l 2 "Tirkey Point 1l 1 i 1 3 River Bend i1 1i 1 i 1 4 b
L A rkansas .,
j1 ]. 4 i 3 4 fort Calhoun ! !1 2 l 2 5 Palo Verde j j 3 2 5
~
'iion I~i' 1 5 Calvert Cliffs 1 .
3 I~ 1 5
[ Cook 3i1 I I ,
4 Page 4 10/28/98
1 i
Emergency Preparedness Findings
, 1997 - 1998 EA Sile Name ne]tFll URil Violation l Weakness is 4 Total s {
Cooper Davis-Besse Q!
- 4l J l 5 j 6 4 !
. Grand Gulf 1l l 5 6
. fLa Salle 2l i 1 i 2 5 l
'Waterford fl 3 3 6 WNP2 E 3 l 1 4
}T'~1 [
~ ~
gMillstone I 5 [ 7
!Callaway l3 ! 21 3 8 IComanche Peak [~' i 1 6 l 3 10 (Clinton 115I3 ,
5 1 23 l
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)
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Emergency Preparedness Findings ..
1997 - 1998 Inspection lfCategorytl4 Sut> Category 1 e ?! tSut> Category 2 i l IFl l URi l Violation l Weakness I ' Accident Assessment ' Exercises 4! 4
! ew r*.e 4w, Accident Assessment inspections 2
! i
- ~
Emergency Action Level [5xercises
'1l i
[
L -.
1 Einergency Action Level l Inspections 2 j j l .. ?
- Emergency Action Level Real Events LERs ! .
1 i
" 1,
$ vent Recognition l Exercises 1 2 i i ;
~
Event Recognition ilnspections 1!
L . . . _
l Event Recognition !Real Events LERs 2 l
f .
l
! I Accident Assessment Exercises IFl Dresden 97 14 Duplicate No Date Entered loc 6s Safety No 8
Dunng the licensee's later review of the emergency implementmg procedures for the loss of annunciator Alert clasnfication, they idenafied that the basis for this Alen EAL lacked clanty on whether the loss of one of three control roorn morutonng systems or loss of all three systems were required m addition to the loss of annunciators to declare an Alert. Licensee actions to clanfy the EAL basis will be tracked as an IFl.
IFI Grand Gulf 97 15 Duplicate No Date Entered lon7s Safety No 8
The hcensee's dose assessment methodology will be reviewed in a future emergency preparedness mspecnon to desemune if the potennal fornon-conservanve protecnve accon m_= aAmons exists. Dose from the pre-existmg plume widun the emergency plannmg zone was ignored, thereby yielding non-conservauve dose projecuont.
IF1 Gmna 97 04 Duplicate No Date Entered 10/27s Safety No 8
he Maintenance Auessment Manager, and Radiation Protecnon/ Chemistry Manger missed stus opporturuty to leam and document unportant mformanon available from tearn members. For example the (scenano) genersi area dose rate around the A residual heat removal pump breaker was esumated to be 40 R/hr. He health physics tech.
Page 6 10/28/98
e, Emergency Preparedness Findings 1997 - 1998 Found actual (scenario) dose rate to be 25 R!hr in the area This infonnanon was not reponed to, or logged by, the RP. Chem Manager. This informanon would have been valuable in planmng and preparanon for other possible entries suo this area. The heahh physics technician did later in the exercise document survey information, however, these surveys were not provided to the RPKhern Manager in the 13CMSC. The failure to perform debnefings, desenbad in the licensees procedure EPIP l 12. " Repair and Correcove Action Guidehnes Dunns Emergency Situanons." Section 6.6. *Debnefings." is considered an mspection follow up item.
IFI Monticello 97 16 Duplicate No l Date Entered 10/26/9 Safety No l 8 i
Field Moratonns team ;mblems. Teams had difficult finding their present locanon and their assigned destinations because their maps did u accurasely reflea the roads in the area.
, Weakness Comanche Peak 97 04 Duplicate Yes l
l Date Entered 10/27 S Safety No 8
97-04JJ2:The supector concluded that the emergency cor,rdmaior did not demonstrase confidence or full fannlianry with established pmcess or procedures for deter mmng protective accon recommendanons to the extent that it resuhed in an untunely nott6 canon and proteaive action recoinmendanon. Moreover, had this been a real emergency, the beensee's credibdity with the offsite agencies could have been durunished given the l display ofindecisiveness. The failure to make a amely non6mnon and prosecove acsion recommendation was idenafied as an exercise weakness due to the potennal unpact Weakness Turkey Poun 97-05 Duplicate No Date f.ntered 10/26/9 Safety No 8
Failure to perfonn a prompt damage assessment of safety-related eqimpment Page! 10/27/98 l
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Emergency Preparedness Findings ..
1997 - 1998 i
Accident Assessment
-Weakness Grand Gulf 97 09 Dupheate No Date Entered 10n7B Safety No 8
Failure to satisfactorily perfonn dose assessment acuvaies to support emergency clasifianons. Dose assessment acovines wet a not sansfacionly performed by the shift chemists dunng the walkbud=; some dose projections were untime'y incorrect, and incomplete, and results were not correctly communicated to the emergency director.
Weakness Wolf Creek 98-07 Duplicate No Date Entered 10C2S Safety ' yes 8
A perfont ance weakness was idenafied involving one crew that failed to properly aasess plant condinons whids required r pgrading to a general emergency. The second crew properly declared the emergency but reqmred 18 mmunes e a usess plant condinons, exceedmg the 15 mmune goat lnipections IFl Callaway 98 14 Duplicate No Date Entered 10n2s Safery yes 8
he fa lure of'the pnmary nonficanon system and the transinon to the backup system caused some minor delays in offs te agency nonfications dunng the first walkthmugh. The second crew did not classify one of three events in a tir acly manner because an emergency operanng procedure confheted with an emergency implemennng procelure. De procedure for emergency operanng procedure usage stated that emergency acnon level deten sinanon commences after exiting the reactor snp procedure. The classification procedure reqtured class'5 canon when abnonnal readings mdicate an emergency situanon has occurred. The first crew did not have the s sne problem because a entered the reactor tnp procedure later in the scenano. '!he delayed classificanon was ider afied as a performance weakness.
IF1 Crystal River 97 08 Duplicate No Date Entered 10G6S Safety No 8
Ur acceptable vanance in classifymg scenanos among a representative sample of Emergency coordinators.
In spectors noted ddferent classdicanons in 10 of he 13 scenanos presented to the intervmws.
Emergency Action Level Exercises IFI Monneello 97-16 Dupucate No Date Entered 10n6s Safety No 8
Clanticanon needed to EAL Gindeline 28. This delayed the GE declarmon by approx. 20 nunutes Weakness Robinson 97 13 Duplicate No Date Entered 10n6s Safety No 8
NOUE declaration was not amely made when EAL was exceeded Inspections Page 8 10/28/98
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1997 - 1998 I l Emergency Action Level l
- IFl Susquehanna 97-01 Duplicate No I Date Entered 10a6s Safety No l 8
During the rispecnon the inspector determined that the licenses connnued to make changes to the current (NUREG 0654) EALs to meet the NUREG 654 EAL guidance throughout the penod. The Licensee indicated to the mspector that it is uncenam about whether it will connnue to seek NRC approval for the NUMARC NESP007 EALs or update the current EALs. This maner is being tracked as an IF1.
IFI Quad Cities 97-26 Duplicate Yes Date Entered lon6s Safety
- No 8
IFl 97-02645 Dunns scenario the shift manager decimd an imusual event. However the dnll controllers prompted the shift manager to decim an alen. During the recent 1997 Dresden exercise, the corporate office of Come Ed determined the basis for the EAL MA6 needed clarification on whether the loss of one of three control room momtonng systems or loss of au three systems requued,in addinon to the loss of annunaasors,to declare an alert.
Real Events LERs Weakness Sequoyah 97-15 Duplicate No Date Entered lon6s Safety No 8
The delay in declanns a NOUE dunng the October 5.1996 transformer explosion was a weakness in the plant's emergency preparedness response. The NOUE was decimd 59 nunuien after the event was ininated and 33 mmutes after the control room was returned to nonnal.
Event Recognition Exercises IFl Oyster Creek 97 08 Duplicate No Date Entered 10n6B Safety No i
8 I Emergency Conuel Center crew's decision to shut the MSVs with an existmg ATWS was an NRC concem I Violanon TM1 97 02 Duplicate Yes Date Entered 10/26n Safety No 8
I Dunng the full-pamcipanon exercise on March 5.1997, the EPIP procedure TM] .01 was not followed in that the Emergency Director failed to classify a general emergency when sudi a dectanon was warranted due to the .
sunulated loss of the three fasion product barners. I as of March 5,1997, emergency response anuning was not adequate and procedures contained insufficient guidance for considenng protecove acnon recommendanons (PARS) beyond the 10wirule EP2. As a result, emergency response management did not commmucate recommendanons for PARS for residents beyond the 10 mile EPZ when plume dose projecuons appeared to indicate that protecave action gmdel:nes would be exceeded beyond that zone dunng the fuu pamcipanon exercise on March 5,1997.
These violanons m Sr. tion IV represent a Seventy Level III problem (Supplement 1). Cml Penalty - 555.000.
I j Weakness Cooper 98 12 Duplicate Yes Date Entered 10/22n Safety Yes 8
1he failure of one crew to effecovely unplement key elements of the emergency plan (e g., emergency director oversight, protecove scuon recommendanons, offsite agency nonficanons, and emergency classtficanon) dunng simulator walkthroughs was idenufied as an exercise weakness.
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Event Recognition l Palo Verde 97 10 Duplicate No
" Weakness Date Entered 10/26 S Safety No 8
Failure to recognize and classify the notificsion of unusual event Inspections IFl Quad Cities 97- 26 Lplicate Yes Date Entered 10/26S Safety No 8
IFl 97-026 05. Dunng scenario the shift manager declared an unusual event. However the drill controllers prompted the shift manager to declare an alert. Dunng the recent 1997 Dresden exercise, the corporate office of Come Ed determined the basis for the EAL MA6 needed clanficanon on whether the loss of one of three control room morutonng systems or loss of all three systems reqinred in addmon to the loss of annunciato s,to declare an alert.
RealEvents LERs Violanon River Bend 97-08 Duplicate No Date Entered 10/27 S Safety No 8
On May 6.1997, the licensee failed to follow Procedure EIP.2@l in that the licensee entered Techrucal Specification Luninns Condition for Operanon 3.4.5 apon detemunation that pressure boundary leakage existed, but did not declare a Nonficanon of Unusual Event unni prompted by the inspectors on May 7,1997.
Tius is a Seventy LeveIIV violanon Violanon Harns 97-01 Duplicate No Date Entered 10/27 S Safety No 8
Manitenance personnel fond a cut wire in the motor control cabmet for the turtnne buildmg vent stack radianon monitor at 1:25 p.m. The wire had been pulled out of a winng bimdle, cut, twisted together, and left m the front '
of the panel. Secunty declared a Secunty Alert at 2:00 p.m. based on the cut wire and that tampenng could not be ruled out.
De NRC was noufied of the physical secanty event under 10 CFR 73.71 at 2:25 p.m., A Secunty guani was posted at the motor control panel, personnel access entnes to the proteced area were reviewed, and a search of the protected area was conducted, he operanons shift supenntendent had worked duough the Emergency Aaion Level (EALI Flow Puh from PEP
- 110 with the Secunty Manager pnor to the 2:25 p.m. NRC nonficanon. The understanding of the shift supenntendent was that a Secunty Emergency had not been declared, and therefore the flow path (side 1) did not require an EAL flow path declaration. In discussing the secunty event classificsion at approxunnely 3:00 p.m.
with the inspector,the sluft supenntendent foimd out that a Secumy Alert had been declared. He immedinely confirmed this wah the Secunty Manager and a 3 f)5 p.m. declared a Nonce of Unusual Event (NOUE).
Nonfication Worksheet sent from Secunty to the Main Control Room did not idennfy thu the event had been clamfied as a Secunty Alert, the bcensee determined that the shift supenntendent has sufficient mfonnation communtcated to him to have declared an NOUE at the tune of the 10 CFR 73.71 declared and nonfication (2:25 p.m.k This twensee identified and corrected violanon is being tremed as a Non-Cited violanon.
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!. Emergency Preparedness Findings
- 1997 - 1998 II l Ecategoryst; secategory n > s l a$ub-Category 2 t l IFI l Um l Violation l Weakness ll Direct interface with Exercises i 2
. Offsite Ag,encies ,
l Direct interface with inspections i 1 Offsite Agencies ,,..._ , , ,
Direct Interface with !Real Events LERs ' 1 Offsite Agencies !
Adequate Communication l Exercises 1 1 2
. Channels , ,
Alert and Notification Exercises '1 .
3 System Alert and Notification iReal Events LERs 1 2 1
System !
Direct interface to Offsite ' Exercises 1{i 3
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Direct interface to Offsite Inspections ; i 1
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Direct interface to i OffsitE51eal Events LERs i~5~!
i l- Direct Interface with ! Exercises ~i 1
.Offsite Agencies }
!lR_ _ _ _LERs i 1 i ,
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i Direct Interface with Offsite Agencies Exercises Weakness Palo Verde 97 10 Duplicate No Date Entered 10/26n Safety No 8
Failure to make regiared offnte agency nonficanon l
Weakness Oyster Creek 97-08 Duplicate T.'o Date Entered 10/26S Safety No 8
l Faalure to nonfy state authonnes widun 15 nunutes of the Site Area Declaranon
, Inspections l
l Violanon Palo Verde 97-21 Duplicate No Date Entered 10/26 S Safety No 8
l Lase nonficanon of state and local of5cials dunns Feb 25,1996 nonficanon of unusual event l
l Real Events LERs Violanon Deo Canyon 97-19 Duplicate No Date Entered 10/26 s Safety No 8
Dunng the reactor tnp and safety injection event of October 24,1997, the hcensee declared a NOUE at 8:32 a.m.
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Emergency Preparedness Findings -
1997 - 1998 Although Procedure EP G3 required the hcensee to provide updmes to stme and county officials every 30 minutes when the cmergency plan was activsed, the licensee provided no other follow-up communications to state and local agencies unn! the event was terminated. As a result,these agencies were not provided with updates for approximately I bour.
County officials were notified at 9:52 tm. (14 minutes) and state officials at 9:54 a.m. (16 minutes). However Procedure EP G3 required that same and local authonties be nonfied within 15 minutes.
"The fauure to update state and local officials every 30 minutes, and to notify state officials of termination of the emergency plan widun 15 minutes,is a violation of Procedure EP G3 and 10 CFR 50.54 (q).This non-repennve, hcensee-idenafied and conected violanon is being treated as a non-cited violanon.
Adequate Communication Channels Exercises IF1 La Salle 98-08 Duplicate No Date Entered 10/22 S Safety No 8
The insial nonficanon to the State and local agencies was completed withan the regulatory time hmits. Hc:vever, the Emergency Nonficanon System (ENS) aanfication to the NRC concenung the Alen declaranon was not r:ade immediately following the nonfication of appropnate offsite officials as required.
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Adequate Communication Channels
- Violanon Comanche Peak 97-04 Duplicate Yes Date Entered 10/27 S Safety No 8
as of February 12.1997, the hcensee had not correaed a weakness involving implementanon of site evacuation procedures that was identified dunns an emergency preparedness inspecnon conducted durms the penod September 25 29,1995. Durms the September 1995 mspecnon. the emergency coordmator did not consider wmd duection when evacuatmg personnel from the site; personnel were mstructed to evaluate through the sunulized plume.
During this inspection, a site evacuanon was not ordered in a tunely manner. Both faalures were attnbuted to procedural adherence.
This is a Seventy Level IV violanon (Supplement VIII) (50-445S7G4-03: 50-446S704-03).
Weakness Wolf Creek 97 02 DupUcate No Date Entered 10/26 S Safety No 8
Five examples of meffective mternal and external technical support cenier commurucanons. Two instances where commurucations between the conuel room and techrucal support center resuited in the TSC not being aware of plant condinons. TSC management did not bnef center staff on probable fadure paths in the emergency acnon levels of condinons that woujd cause event escalanon. The commurucanon between the control room and the TSC concemmg the condensate storage tank damage was not clearly communicated. The tennaiology used to desenbe the mam steam hne break to techrucal support center personnel caused some confusion. The fadure to accurately communicate that the RHR system was to be sampled, rather than the post acadent samphng system, further delayed the reactor coolant system cooldown and release termmanon.
Weakness Arkansas 97 10 DupUcate Yes Date Entered 10/26S Safety No 8
97 10 02 The failure to sausfacionly implement site evacuanon procedures was identified as an exercise weakness due to the potennal unpact to plant personnel Alert and Notification System Exercises URI Fort Calhoun 97 04 Dupucate No Date Entered 10/27 S Safety No 8
Dunns the exercise, the inspectors observed that one of the nottficanon forms did not have an authonzanon signature, but the nonficanon to offsna agencies had been made. When the forms were reviewed aher the exercise, all of the forms had been signed The signature on the form that was onginally unsigned was significandy different from the rest. The Emergency duector stated that it was not his signature.
Weakness Callaway 97 13 Duplicate Yes Date Entered 10/27 S Safety No 8
9713-01 The mspectors deternuned that programmars factors caused a delay in mahng umely offsite agency notificanons (f.e widun the 15 nunute regulatory lunit). In response. the licensee considered the nonficanon timely based on the alert declaranon log entry (15 nunutes vs.17 minutes). The inspectors concluded that there were prograrnmauc reasons for the delays: 1) lack of clear understanduig about when the nonfication penod starts.
l 2) the use of commumators who were not stanoned in the control room, and 3) a lack of famihanty with the new electroruc nonficanon system. Due to the programmanc 7 actors,the inspectors idenufied the failure to make tunely offsite agency nouficanons as an exercise weakness Page 13 10/28/98
Emergency Preparedness Findings 1997 - 1998 II Alert and Notification System
-Weakness Brunswick 98-01 Dupbcate No
- Date Entered 10n2/9 Safety Yes 8
The EOF failed to fulfill a pnmary facihty resporailmhty by not providing off site agencies with off site Protecive Action Recr==-~iirions (PARS)in a umely manner. lius failure was idennfied as an Exercise Weakness.
Weakness Cooper 98 12 Duplicate Yes Date Entered 10a2/9 Safety Yes 8
The failure of one crew to effectively implement key elemenu of the emergency plan (e.g.. emergency director oversight, protecove action recommendanons.offnte agency notificanons, and emergency classtfication) dunng simulator walkthroughs was idennfied as an exercise weakness.
Real Events LERs IF1 Clinton 98-09 Duplicate No l Date Entered 1042S Safety Yes 8
The hcensee determined that the non-heensed operator (htO) asugned to make siitial offsite nonficanons was unsure of his dunes for mahng offste nonficanons and was communicanng wnh some dtfficuky.
UR] Chnton 98 03 Duplicate No Date Entered 1042/9 Safety Yes 8
Approximasely two hours elapsed between the nme the &screpancy (ND-6685 computer had stopped updanns the buffer computer) was identtfied and the trne current radiologral and meteomlogwal informanon was transmitted to the NRC. IDNS, and the EOF. The inabthty to transmit currect rachological and mescomlogical data widun one hour of dectanng an emergency classificanon is conndered an Unre sd item.
IfRI Chnson 98-03 DapUcate No Date Entered 10n2/9 Safety Yes 8
The licensee determined that the NLO assigned to make ininal nonficanons was unsure of his dunes for mahn offute nonficanons. De shift techrucal advisor (STA) was regtured to reheve the NLO and perform the inniai offste notificanons. The mappropnate use of the STA to perform off site nonficanons was previously
! documenied m NRC Inspecnon reports 9610 and 97-02.
DJplicate No W lanon Clinton 98-09 Date Entered 10/22/9 Safety Yes 8
The ERDS system was not nunated within one hour of the declaranon of an Alert. Specifically, ERDS was imnated one bour and seventeen nunutes after the event declaranon.
His is a Severny Level IV violanon (Supplement 8)
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Emergency Preparedness Findings i 1997 - 1998 H
Direct Interface to Offsite "IFl Zace 97-29 Duplicate No l Date Entered lon6s Safety No 8
IFI 97 29-01.De communicator initially did not follow available guidance and irutially contacted towa officials regarding the Unusual event declaration. The commurucator son corrected lus error and made use of the avaiiable gudance when mabng this and subsequer.t ininal nottficanons of Dlinois and Wisconsin officials wuhin the regulatory tune imut. Conect use of the nottficanon procedure and checklist was an IFl.
Weaknas Callaway 97 13 Duplicate Yes Date Entered 10n78 Safety . No 8
971341 The inspectors detemuned that programmatic factors caused a delay in making tunely offsite agency notificanons (i.e-, widun the 15 nunute regulatory hrrut). In response, the licenseo considered the nonficanon
, timely based on the alert declaranon log entry (15 minutes vs.17 minutes). He inspectors concluded that there were programmanc reasons for the delays: 1) lack of clear undentandmg about when the nonficanon penod starts.
l 2) the use of comrnunicators who were not stanoned a the control room, and 3) a lack of fanuhanty wuh the new electrome nonficanon system. Due to the programmanc factors,the mspecton idenuried the failure to make l timely <ifsue agency nonficanons as an exercise weakness t
Weakness Surry 97-08 Duplicate No Date Entered lon6s Safety No l 8 l An Exercise Weaknes's was idennfied regardmg news releases that chd not accurately portray release informanon I and were not coordinated with the Recovery Manager.
Weakness Comanche Puk 9744 Dupbcate Yes i Date Entered lon78 Safety No i 8 l l 97 04-02: he inspector concluded that the emergency coonhnator did not demonstrate confidence or full famihanty with estabbshed process of procedures for determuung protecove accon recommendanons to the extent that it resulted in an unnmely nonfication and protecove action recommendanon. Moreover, had this been a real emergency, the hcensee's credibihty wuh the offsite agencies could have been dimuushed given the display of indecisiveness. The failure to make a nmely nonficanon and protecove action reconnuendanon was idenafied as an exercise weakness due to the potential unpact.
Inspections l Violation Fort Calhoun 97-02 Duplicate No Dare Entered lon7S Safety No l 8 l Dunng review of hcensee documents related to the notificanon ofimusual event that was declared on December 31,19%, the inspectors discovered that the bcensee expenenced communicanon problems nonfymg the state and l
local authornies dunng the ininal nottlicanon. De control voorn comrnumcator anernpted to make the required nonficanons to the state and local govemment agencies approximately 14 mmutes aher the event declaranon.
However,the conference operanons network phone that wu used as a pnmary method of nonficanon was
- dead."
The commencator uunated the nottficanons usung the backup rnethod of contactmg each agency via the commercial phone system. Dunng the call to the first offsua agency, the communicator nonced that the phone i Ime was disconnected from the conference operations network phone. The communicator plugged the phone ime i into the phone and completed the nonficanons usmg the conference operanons network phone.
, 10 (TR Part 50. Appendix E. Secxion IV.D.3. states,in part " , a hcensee shall have the capabibry to nonfy responsible State and local govemmental agencies withm 15 nunutes after declartng an emergency." As a result of the phone problem. The nonficanon to the State of Iowa occuned 17 minutes after the evem declaranon.
The late nonfication was a violanon of 10 CFR Part 50, Appendix E. Accordmgly,the violanon is bems treated as a Non-Cited Violanoa, violanon .
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Emergency Preparedness Findings 1997 - 1998 11 DirectInterface to Offsite RealEvents LERs IFl Zion 97-08 Duplicate No Date Entered lon6s Safety No 8
EPIP 190 2 " Communicators." hem 10 of Attachment A.*NARS Fonn. Instructions for Use." indicated that the individual completag the form should. in the addinonal information section of the form, provide additional informanon that will be helpful to personnel evaluation the event . The bcensee had recognized that the conuntunicator's response was improper (Unit nurnber not included) and had wnnen a PIF. Conecuve actions in response to this PIF will be an IFl.
IF1 Zion 97-08 Duplicate No ,
Date Entered lon6S Safety No 8
The review of the 2n4S7 Unusual Event conducted by the Emergency Preparedness Coordmator noted that the Bulk Power operations officer did not answer the Ilhnois Nuclear Accident Reportmg System telephone DirectInterface with Offsite Agencies Exercises Weakness McGmre 97-12 Duplicate No Date Entered lon7s Safety No 8
Messages 3 through 6. which were follow-up nonficanons to the Alert classifu:ation, all indicated that the plant condinon was stable. In actuahty, the plant condinons connnued to degrade dunng this pened of nme. T1us failure to provide a conect prognosis to the plant condinons to the offsite governmental agencies was idennfied as an eacrcise weakness.
Real Events LERs IFl Clinton 98-03 Duplicate No Date Entered lon2n Safety No 8
The hcensee idennfied that a follow up message was not relayed to the IDNS for a change in command authonty from the sluft supemwr to the Techrucal Support Center Stanon Ernergency Director. The inspectors identdied that the uunal NARS Fonn was sent at 4:35 a m.: however, the first follow-up telephone call was not made unul 6:11a.m a period of I hour and 36 minutes.
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Emergency Preparedness Findings 1997 - 1998 III CategoryilB Sut> Category;1 ?SW l j Sut> Category 2 ? l IFI l URi l Violation l Weakness ll1
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Direct interface with ' Exercises 1 Offsite Agencies . . . . ,
IAccident Assessment Exercises 2 ]!
1 4
, . -.--,. ; 4 Accident Assessment inspections 1 2 1 l
, . _ . , . 1 Activation of Emergency Exercises i 1
, Response _ Organization ,. i j Aciquate Communication Exercises i 1-l Channels
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' Direct Interface with '5xercises I 2-O.! site Agencies Othte Exercises ! 1 I I 111 Other inspections 1 F
Protection of Emergency Exercises 8 Workers 1l ,
Protection of Emergency Inspections Workers 2l ,
I~ Protection of Emergency Real Events LERs 1 iWorkers DirectInterface with Offsite Agencies Exercises I Weakness Waterford 97-18 Duplicate No Date Entered 10/26/9 Safety No 8
An emcise weak ,ess was idenafied because a protective actwn recommendation upgrade decision was unnecessardy delayed. The decmon to follow the procedust and make the recommendauon in the three addinonal areas was not made unal 3:45 p.m. GO nunates after the information first became available.
Accident Assessment i
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1997 - 1998-IH Accident Assessment Exercises IFI Cook 97 13 Duplicate No Date Entered 10/27/9 Safety No 8
97013-02The licensee identified that a controller had to intervene dunns PAR development for the second Par when Containmmit radianon levels esceeded 25.000 R/hr in the containment builduig. Licensee review of the prvedure for possible clartficanon is an inspecnon follow-up item.
IFI Kewaunee 97 13 Duplicate No Date Entered 10/27 S Safety
- No 8
During tedinically competent discussions in the TSC, accident mitiganon items or tasks were desenbed as "pnonties." but these were neither hsted nor tracked, creaung the potennal thu an item or task could be overlooked. Likewise, pnoriues weit not utdized in associanon with the mplant repair teams.
Violanon TM1 97 02 Duplicate Yes Date Entered 10/26/9 Safety No 8
During the full-participanon exercise on March 5,1997,the EPIP procedure Th0 .01 was not followed in that the Emergency Director failed to classtfy a general emergency when such a declaranon was warranted due to the simulmed loss of the three fission product barners.
as of March 5,1997, emergency response trauung was not adequate and procedures contained insufficient gindance for considenng prosecuve accon recommendanons (PARS) beyond the 10 nule EPZ. As a result, emergency response management did not communicate r--Wons for PARS forresidents beyond the 10 nule EPZ when plume dose projections appeared to indicate that protecove accon studehnes would be exceeded oeyond that zone dunng the full pamcipanon exercise on March 5,1997.
Dese violanons in Secnon IV represent a Seventy Level ID problem (Supplement 1). Civil Penalty - 555.000.
Weakness Harns 97 11 Duplicate No Date Entered 10/27/9 Safety No 8
The inspectors in the TSC observed that the fadure of the TS staff to promptly detect and evaluate the waste gas decay tank leak delayed onsite protecnve acnons. Despite clearindicanons of an ongoing release in progress, there was no urnely ininanon of protective acnons forTSC personnel and no sicewide PA announcement to inform personnel of the release.
Weakness Arkansas 97 10 Duplicate No Date Entered 10/26/9 Safety No 8
9710-03.The failure to property asses the amount of fuel damage was identified as an exercise weakness due to the potential impact on the abibty to accurately make protecnve acnon recommendations.
Weakness Seabrook 98-03 Duplicate No Date Entered 10/22N Safety Yes 8
The licensee did not relay important informuion promptly and was not aggreurve in pursumg issues. There was a three hour delay in iruttaung actions to secure an open steam generator safety rehef valve (wtuch was the radiological release path): there were no discussions that correlated increased radianon morutor readings with fuel damage: and reactor coolant chemisay results, indicative of fuel damage, were not acuvely sought or dissemmated once available.
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-Wealmess WNP 2 98-14 DopUcate No Date Entered 10/22n Safety Yes 8 ,
A petformance weakness was identified for failure of one of two crews to recogruze that dose projecnons indicated 4 need for protective acnor recommendanons beyond 10 nules.
l Inspections IFl Clinton 97 02 Duplicate No Date Entered 10/27n Safety No 8
IF197-02-02. The E plan did not contasi specific ( .- -----ts for on-shift dose assessment. Procedures i
. provided methodology for the dose calculanon. The procedure currently does not include a requirement to utilize the saual meteorological stalnhty class, but utilizes default adverse weather conditions encant to be conservauve. ,
Licensee personnel had previously been advised that this was unacceptable, and a commaanent was made to revise i the procedure fouowmg the current refuel outage. Licensee personnel commmed to modifying the E-plan and l appropnate secnons of procedures addressing dose assessment capabihty following the current refuel oumge.11us i wdl be an inspecuan follow-up item. '
Violanon Chnson 97-02 Dupucate Yes Date Entered 10/27 s Safety No 8
a Condition Report (1 94 10 002) dated September 30,1994, and issued October 3.1994, indicated that the backup meteorological tower wmd speed and wind duecnon sensors were inoperable. This condinon had not been corrected. The wmd speed and wind direenon sensors have been unavailable since October 1994.
This is a Seventy Level IV violanon (Supplement VIIIK Violation Calvert Chffs 97.08 DupUcate No I Date Entered 10/26n Safety No 8
97-08-06. 'on January 15,1998, methods and techniques for assessing and monstonng umal or potennal offsite consequences of a radiological emergency condition were not adequately implemented, dunng tabletop walkthroughs,in that two technicians funchomng as mienm Radaological Assessment Direaors, assumed incorrect isotopic concentranons of the radioactive matenal release source tenn wluch resulted in non conservanve offsite dose projecuons.
This is a Seventy LevelIV violanon. (Supplement VIB . Emergency Preparedness)
Weakness Calvert Chffs 97 09 Duplicate No Date Entered lon6s Safety No 8
An exercise weakness was idenafied in the dose assessment area at the Emergency Operanons Facihty. The dose l assessment team produced unreasonable projecuons due to the operator's lack of understandag and knowledge of i how to marupulate and interpret bcensees automated dose assessment models. Because of this,the hcensee could j not adequately demonstrate that they were able to make a technically sound PAR based on radiological condmons, l
l Activation ofEmergency Response Organization Exercises weakness Arkansas 97 10 Duplicate i Date Entered 10/263 safety No 8
97 1042 The failure to sansfaciortly implement site evacuanon procedures was identified as an exercise weakness due to the potential unpact to plant personnel l
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Emergency Preparedness Findings 1997-1998 III Adequate Communication Channels Exercises Grand Gulf 97 09 Duplicate No Weakness -
Date Entered 10/27 S Safety No 8
Failure to sansfaaonly unplement sue evacuzion procedures. Both crews had core damage and an uncontrolledAmmorutored release for 23 minutes before soundmg the site evacuanon alann. Inspectors used 15 minutes as a reasonable ame. He emergency director failed to mfonn secunty of evacuanon routes, areas to be evacused, and the destinzion of evacuees.
DirectInterface with Offsite Agencies Exercises Weakness Grand Gulf 97 15 Duplicate .No Date Entered 10/27 s Safety No 8
Dunns the wind shift, prosecuve acnon recommendaions for diree affeaed sectors (IUK) were not communicaed to offsite authonnes as reqtared by the emergency plan and implemennng procedures.
Weakness Cooper 98-12 Duplicate Yes Date Entered 10/22 s Safety Yes 8
he failure of one crew to effecovely unplement key elements of the emergency plan (e.g., emergency direaor oversight.protecave accon recomrnendanons.offsite agency notificanon , and emergency classificanon) dunng simulator walkthroughs was identified as an exercise weakness.
Other Exercises Vioision Comanche Peak 97-04 Duplicate Yes Date Entered 10/27 s safety No 8
as of February 12.1997, the licensee had not correaed a weakness involvmg implementation of site evacuanon procedures the was identified dunng an emergency preparedness inspecnon conducted dunng the penod September 25 29.1995. Dunng the September 1995 inspecnon, the emergency coorduiator did not consider wind direcnon when evacuumg personnel from the site; personnel were instructed to evaluate through the sunulmed plume.
Dunng thn inspection, a site evacuanon was not ordered in a tunely manner. Both failures were attnbuted to procedur a! adherence.
His is a Sevenry Level IV violanon (Supplement VIlf)(50-445s704-03; 50 446S704-03).
Inspections IFl Davis-Besse 97 06 Duplicate No Date Entered 10/27 s Safety No 8
The inspecurs noted inas the projected Lake Ene warerlevel condinons could advenely affect the approved emergency plan evacuation routes dunng certain extreme storm conditions.
Protection ofEmergency Workers Exercises Page 20 10/28/98
Emergency Preparedness Findings 1997 - 1998 LII Protection ofEmergency Workers TF1 DavwBease 97-07 Duplicate No Date Entered 10a6s Safety No 8
OSC staff contmued to eat after the OSC Manager had announced that canng. dnnking, or chewing was not pemuned. One ERT member was observed chemng gurn across the radiologically restncted area boundary. He poor radiological control pracnces dunng the exercise will be tracked as an IF1.
Weakness Grand Gulf 97-15 Duplicate No Date Entered 10n7s Safety No 8
Failure to estabbsb protecove measures for secunty penannel. Failure to perfonn habitabihty surveys m the secunty island and detemune the need for addinonal protecnve measures was identtfied as an exercise Weakness.
Weakness Comanche Peak 97 16 Duplicate No Date Entered 10/27 s Safety No 8
97-16 An exercise weakness was identified for fadure to provide proptr radianon proteccon coverage for teams perfomung tasks outside the power blocks as reqtured by procedures Weakness Indian Point 2 98 07 Duplicate No Date Entered 10/22 S Safety No 8
A repair team dispatched without them knowmg of a sunulated radiological release m progress.
Wiakness Fort Calhoun 97 04 Duplicate No Date Entered 10a7s Safety No l 8
An exercise weakness wss identified related to protecove measures (potassium iodide) for onsite pers mnet. De mspectors determmed that there was a potennal forindividuals to leave the operanons support center without bemg bnefed reganhng the authonzation to use potasnum iodide.
Weakness Cooper 98 16 Duplicate No Date Entered 10/22 S Safety Yes
[ 8 l
An exercise weakness wu identified for the fadure to implement proper radiological contanunanon controls in the TSC and OSC. Additionally, sorne station workers. includmg radianon protecnon personnel, did not demonstrate proper radianon protecnon pracuces when respiratory eqtuprnent and prctecnve clothmg were used.
Weakness Waterford 97 18 Dupbcate No Date Entered 10/26 s Safety No 8
An exercise weakness was identified for failure of the fire bngade to use required respiratory protecuan while combating a fire with toxic amoke in an enclosed space. Personnel did not don the self contatned breadung i apparatus before enterms the area as reqtured by the fire emergency / fire report procedure. Not all fire brigade I personnel has self<ontamed breathmg apparatus, i
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Emergency Preparedness Findings 1997 - 1998 IH Protection ofEmergency Workers
" Weakness Waterford 97 18 Duplicate No Date Entered 10/26s Safety No 8
An enerose weakness was identined for failure to implement proper radiological esposure controls (dosimetry and "n controls). Mulapie examples. Contamination controls inconsistent between OSC and the =4 foot elevanon access posit Radiological controls were not property enforced within the OSC. Individuals did not us a fruker. Etc.
W..am s Callaway 97 13 Duplicate Yes Date Entered 10/27 S Safety . No 8
971342 ~!he inspector observed lunited coordmanon with seaarity personnel concemmg radiological precautions: however, the hcensee infonned the inspeaors that radiological precautions were taken for secunty personnel. Due to the irnpact on personnel safety.the failun to estabhsh effecove technical support center access controls was identined as an exercise weakness.
Inspections IFI Arkansas 97 10 Duplicate No Date Entered 10/269 Safety No 8
IFI 97-10 01 De inspector concluded that the current options of KI distribution to neld teams were insufficent -
because they would delay KI admimstranon and hinder personnel safety, in addition, recalling all field teams cculd inhibit the hcansees abdity to monnor/ con 6nn offsite consequences.
IFl Calvert Chffs 97 08 Duplicate No Date Entered 10/26/9 Safety No 8
he Inspectors considered BGE's failure to screen TSC responders for K1 sensinvity to be an oversight wonhy of correcove action. The inspectors are trackms this item as an inspector follow-up item to assess BGEs correcuve i accons to ensure protecnon of TSC responders while the control room vennlanon is sull degraded.
Real Events LERs IFl Chnson 98-03 Duplicate No Date Entered 10/22n Safety No 8
The licensee determined that field team members sutially brought Seid samples to the secondary door of the EOF.
however, since nn one was present to answer the door,the Seid team members brought the field sanples into the EOF through the normal EOF entrance. The secondary door is provided to prevent contaminatag the EOF.
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Emergency Preparedness Findings 1997 - 1998 IV 15 Category @@Mr:J:={Mm l f SthCategosy 2E l IFI l URi l Violation l Weakness IV Activation of Emergency
, Response Organization Exercises 5l1 i
1 4 Activation of Emergency . Inspections 2' 8 Response Organization .. ___, , ,
, Activation of Emergency jReal Events LERs 3 2 Response _ Orga_nization I Adequacy of Facilities Exercises 2l1 L
1
+
Adequacy of Facilities Inspections 4l3 11 i
Adequacy of Facilities jReal Events LEhs 1 i
Other Exercises 6 1 1 2 Other inspections Sl 2 18 i
Other iReal Events LERs 4' 1 i
Activation of Emergency Response Organization Exercises IFl Davis-Besse 97-07 Dupucate No Date Entered 10n6/9 Safety No 8
None of the welders available to weld the component coo ling water hne that was cracked providmg a release path to the environment, were qualified to wear SCBA respiratory prosecuon. He evaluanon of and any subsequent corrective acions for maintaining sufficient staffing of respirator and SCBA quahfied welders and other personnel for emergency response will be tracked as an IFl.
IFl Oyster Creek 97 @ Duplicate No Date Entered 10/26/9 Safety No 8
Off tmurs staffing excretse failed to meet objecoves IFI Kewaunee 97-13 DupUcate No Date Entered 1047/9 Safety No 8
Use of the "Available Resources" status board was confuses. This status board was intended to provide a rapid overview of available resources forinplant teams. Individuals posted on the board were moved to other locanons l ce the board, bin not removed from the board.
IFl Kewaunee 97 13 Dupucate No Date Entetad 1047/9 Safety No 8
he espectors noted that the Auxihary Operator (AO) sent to close the stuck open Sicarn Generator Power Operated Rehet Valve was delayed by the Health Physm:s Process mhile entenng the Auxiliary buildmg. he AO did not get into the plant for approximasely 30 minutes. Procedures dui not address expedited dispatch of tugh pnonty repair personnel.
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Emergency Preparedness Findings 1997 - 1998 Braidwood 04-07 Duplicate No IFl Date Entered 10/22B Safety No 8
OCS staffing was slow due to the plant announcement to activate lhe'onsite facitrues not being heard during the 1998 EP Exercise URI Vogde 97-05 Duplicate No Date Entered 10/26 s Safety No 8
At least six indviduals recaued to the site, who responded to the T3C and OSC. failed to sign in on the appropnate ,
ernergency response facihty roster data sheet.
Violanon Bnmswick 98-01 Duplicate No Date Entered 10/22s Safety No 8
Contrary to the above. Revision 46 to the hcensee's emergency plan decreased the effectweness of the plan in that it adopted the regulasory provision for biennial exercues but did not address the requirement in Appendix E to conduct a dnll between beensual exercises that would sivolve a combinauon of some of the pnncipal funcnonal areas of the hcensee's onsite ernergency response capatnhnes.
This is a Seventy LevelIV violation L
Page 24 10/28/98
! e 6 Emergency Preparedness Findings 1997 - 1998 IV Activation of Emergency Response Organization Weakness Rrver Bend 98-01 Duplicate No Date Entered 10n19 Safety Yu 8
Due to the potannal impact on mitigation efforts, the failure to promptly and property dispatch inplant response teams was idenufied as an exercise weaknas. It took up to an hour to dupatch several teams, and some teams, I includeg a high pnonty team, were canaled before the teams could be dispatched.
I Weakness Fort Calhoun 97 04 Duplicate No Date Entered 10n7s Safety No 8
An exercise weakness was identified related to ths failum to demonstrate the abihty to staff emergency response facihnes on a prolonged basis. Mulople personrael were e ed to staff positions in the operanons support center.
Personnel designated to fill rehef shift positions were e .wed to remain m the facility to support ongoing acovities. Some personnel selected to fill posinons had not completed the necessary training or were disqualified for medical reasons. Based upon trauung amendance rosters, some p>sinons on the work schedule had people idenafied to work the backshift,but were present dunng the exercise with no day shift pamcipauon. As a result no personnel were present to relieve the indrviduals so they could be released. Sirmiar observanons were made in the emergency operanons facthly.
Weakness La Saue 98-08 Duplicate No Date Entered 10nL9 Safey No 8
RP personnel conduenng team dispatch bnefingt did not venty the stanis of SCBA quahficanons of two personnel assigned to the " Urgent 4* tearn pnor to dispatch. Addinonally, no readdy available method to venfy SCBA or respirator quahficanons was maintamed in the OSC Weakness La Salle 98 08 Duplicate No Date Entered lon2n Safety No 8
j The dispatch nmes of Urgent teams ranged from an appropnate low of five mmutes to an unacceptable high of 43 I minutes. 'Ihe inabihry to consistently dispatch " Urgent
- pnonry teams m a timely manner was an Exerrue Weakness.
I.rtspcCliOf15 r.
I In Peny 97 17 Duplicate No Date Entered 10n6s Safety No 8
l IF197-17-02 An inspector fouow-up item was opened to track the potential impact on program performance of the loss of five expenenced EP Una staff members and the EP instructor.
IFI Duane Amold 97 03 Duplicate No l Date Entered 10n6s Safety No 8
! Ten ERO persons wah expued qualificanons hsted in the emergency telephone book one person was o sick leave, there were to be deleted from the ERO and not available to respond to an emergency call and five were wainns to paracipant in the next dnll. Acnous Outef-qualificanon ERO personnel identified in the notificanon and call hst secnon of the Emergency Telephone book wiu be tracked as an inspecnon fouow up item.
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4 Emergency Preparedness Findings ..
1997 - 1998 IV Activation ofEmergency Response Organization
[ Yiolanon Comanche Peak 97 19 Duplicate No Date Entered 10/27 S Safety No 8
on October 29,1996, the hcensee made changes to its emergency plan, without Comnuuion approval, that decreased the effectiveness of the plan and did not connnue to meet Planning Standard 50.47(b)(2). Specifically, on-shift and augmentanon capabiinies were reduced as follows:
. Adequate staffing for uunal response in key functional areas wr4 not maintained when the emergency response organizanon no longer included a dedicated commisticsor to perform offsite agency nottficanons.
. Tunely augmentanon of response capabilmes was not available when two 40-nunate responders, to help the shift technical advisor perform dose assessment and engmeenng tasks, were deleted.
.Tunely augmentation of response capabshnes was not available when one 40 minute responder, to perform offsite monitoring. was deleted As a result,offsne morutonag capabihnes would be delayed unal the 70 minute responders arnved, since on-shift resources wee not sufficient to perfonn the momtorms (accordmg to the licensee).
. Tunely augmentation of response capabihties was not available when 6ve 44 minute responders to help pe fonn stanon surveys, tearn coverage, onsite surveys, access control, personnel monnonng, and dossnetry were deleted.
This is a Seventy Level IV violation (Supplement VIU).
Violation Nies %)e Point 97-06 Dylicate No Date Entered 10/27/9 Safety No 8
From June 6.1997 through July 16,1997, rune of the quahfied individuals for dose assessment had eaceeded the 15 month lutut for receiving refresher trammg, yet continued to be listed as qualified members of the Ernergency Response Orgarnzanon.
From November 8,1994, through July 18.1997, there were no acavat.ons of ERO members tha involved actual personnel response from offsue to the emergency facilnies.
In the aggregate, this is a Seventy Level IV Violaton Violanon Wilstone 98 80 Duplicate No Date Entered 10/22/9 Safety No 8
Because NRC regulanons require hcensees to follow and rnamtain in effect emergency plans thm meet cenaan standards, and because the licensee did not follow the Plan by ensunna the ortly respuntor quahfied individuals were assigned to those positions requinng such qualificauon. the inspecton concluded that a violanon of NRC regulanons occuned. This violanon was due to the licensee's failure to adequately track respirator quahfications and ensure that only quahfied personnel were assigned to the SERO. However, this issue was self-idenufied by the hcensee, not a recurrence of a previously idenufied issue, not a willful violation on the part of the licensee, and correcove acnons have been imamed and commined to. Therefore. the violsion sausfies the entena of Secnon VII of the NRr's Enforcement Policy and is non-ened l
1 Page 26 10/28/98
.. l Emergency Preparedness Findings 1997 - 1998 IV Activation ofEmergency Response Organization
" Violation Comanche Peak 97 19 Duplicate Yes Date Entered 10/27 s Safety No 8
on Ocsober 29.1996, the licensee made the following changes to its emergency plan without Commission approval that did not continue to meet Planning Standard 5047(bX2), or the reqmromenu of Appendix E.
- 1. Changes involving the descripnon of emergency response organizanon mesters did not connnue to meet Planning Standard 50.47(b)(2) and Appendix E.IV.A requiremenu. Specifically, the descripnon and responnbilities of the followmg four emergency response organ,zanon posinons were deleted from Revision 25 but remamed on the organization diart and emergency response organizanon call-out roster: (a) emergency operanons facihty radianon assessment coordmator, (b) technical support center operanons coordmator,(c) ,
operations advisor, and (d) supporung staff for the logistical support coordmator. j
- 2. Changes involving the desenption of the emergency response organization traming program did not conunue to meet Appendtx E.IVF.I requirements. Specifically,the desenpnon of the fire bngade and secunty traming ;
programs were deleted from Revision 25.
- 3. Changes involung the desenpnon of offsite decision makers iid not continue to meet Appendix E.IV.A.8 reqmrernents. Specifically, the identificanon of the offnte prosecove acnon decision makers for the mgesnon l l
pashway zone was deleted from Rension 25 to the plan. l This is a Seventy Level 1V violanon (Supplement VIII).
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1 Vioimion Callaway 98 06 Duplicate No l
! Date Entered 10/22s Safety No 8
i On May 29,1997, the hcensee made changes to its emergency plan, without Commission app # oval that decreased
- the effecoveness of the plan and did rot contmoe to meet Plannmg Standard 50.47(b)(2). Fourteen changes to response goals noted.
l Violanon San Onofre 97 26 Duplicate No Date Entered 10/26s Safety No 8
NCV 97 26 01. The hcensee idennfied the recover /re-entry pomon of the emergercy plan had not been I
exercised since 1989. Therefore, the failure to exercise the recovery /re-entry pornons of the emergency plan every 5 years was a violation of the emergency plan and 10 CFR 50.54(q). The violanon was hcensee idennfied.
l nonsepetauvr., corrected within a reasonable ame and non-willful. Accordagly the violation is being tremed as a
( Non Cited violation.
l Violanca Turkey Point 97 12 Duplicate No Date Entered 10/26/9 Safety No 8
NOV-971248 Revision 32 to the beensee's emergency plan decreased the effectiveness of the plan in that it did l not address the requirement in Appendix E to conduct a dnli between bientual exercises that would involve a combmation of some of the pnncipal funcnonal areas of the hcensee's onnte emergency response capabihties.
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This is a Seventy Level IV violanon (Supplement VIII).
l i Violanon Limenck 97 10 Duplicate No I
Date Entered 10/26 s Safety No 8
NCV 9710 09: Following an Alert emergency notificsion or above,the Licensee ER procedures simes tha six HP technicians must be onnte within a half hour and six more within 60 mmutes. Following the October 9.1997 i
alert incident the HP team leader idennfied the he had difficulty in locanns 12 quahfied HP techmcians and
- umehness of their response was not acceptable.
Real Events LERs 4
i Page 27 10/28/98 f
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Emergency Preparedness Findings .-
1997 - 1998 IV Activation ofEmergency Response Organization Chnson 9843 Duplicate No
"!Fl Date Entered 10a m Safety Yes 8
He inspectors noted that the OSC was staHed and acavsed one hour and 15 minutes aher the alert declaration.
The 30 minute posaions for inplant surveys, radiation protection personnel, and supenisor technical or alternate were fined after more thar. 37 minutes. The 60 minute posinon for radtarion protecnon personnel was filled aher more than 75 minutes. The mechanical engmeer ponnon was not 611ed with a designated individual, however, personnel were present who could have filled the position. The 60 minute electncal maintenance position was filled by a quahfied electncian who was not ERO quahfied. Approxunately 10-12 mmutes elapsed between emergency classification and nonficanons by the auto 6aler.
IFl Clinton 98-03 Duplicate No Date Entered loam Safety No
! 8 The autodialer operanon staned a succession of events which ultimately resulted in unnmely filhng of the TAS posinon, a posinon required to acavare the ISC.
I IF1 Chnton 98-03 Duplicate No Date Entered 10c m Safety No 8
The hcensee determmed that several personnel did not have or were unaware of the need to have an ERO badge.
Not having an ERO badge creased delays in giving access to the protected area in that secunty personnel were required to venfy ERO members against an non-alphabencal h t of ERO personnel.
Violanon Chnton 9849 Duplicate No Date Entered loa m Safety No 8
On the mommg of February 13.1998, there was only one electncal maintenance personnel on sluft, who was trained and assigned as a member of the emergency response organizanon. Specifically, one of the two electncal maintenance personnel on shift was not tramed This is a Sevenry LevelIV vioision i
Violanon Clinton 98 09 Duplicate No Date Entered 10c m Safety No 8
The issued emergency access badges did not allow entry in the event of an ernergency because on the mommg of t
February 13,1998, followmg the declaration of an Alen, several repomng emergency response organization I members failed to have the badges an their possesnon. he regtured other means of access idennficanon to be unlized, delaymg emergency facility access au! acuvaton. Specifically,Techrucal Support Center acavanon was delayed.
This is a Seventy LevelIV violanon Adequacy ofFacilities Exercises IFl Chnson 98-09 Duplicate No Date Entered loa m Safety No 8
The mspectors observed that the eait signs throughout the EOF /sunulatorArminmg facihty failed to illumaiate on loss of power.
Page 28 10/28/98 i
I Emergency Preparedness Findings 1997 - 1998 IV
. Adequacy ofFacilities '
"IFl Clinton 98 09 Duplicate No Date Entered 10a2n Safety Yes 8
%res umatorruptible power soun:es (UPS)locased in the EOF failed. Failure of the Seid team's radio UPS had the impaa of making commumcanon with the field teams from the EOF ddficult if not impossible.
URI Pilgrun 97 10 Duplicate No Date Entered lon6s , Salety No. .
8 Lack of adminiuranve control over SCBA fit taas resuhing in shonage of quahfied SCBA wearers i
( Weakness Grand Gulf 97 15 Duplicate No Date Entered 1047s Safety No 8
Failure to monitor and mentan supphes of self-contained beathing tpparatus for long term center operation. l The licensee did not demonatase adequase control over the use of respiratory proiecsion eqtapment by momionns ,
the quantines of face puces and use of nar bottles, and _" dy replenishing these supphes as needed.
InspcClions IFl Chnson 97-15 Duplicate No Date Entered 10a7s Safety No 8
IFl 97-15-07 The inspectors noted that the man access to the EOF was through a set of urlock doors.
However, an shamate access to the facihty for field teams had not been controlled with airlock doors. E-plan l personnel inistased a work request to install door seals on field team access doors. Procedures specified that the l EOF area HVAC subsystern provides a pontrve pressure in relation to the rest of the bialding and the outside. The l inspectors determined that without door seals on the field access team doors, the HVAC system may not have the l- abdity to develop the pressure needed to sausfy the procedure. His maner will be tracked as an Inspecnon l follow-up item.
!. IFl Perry 97-17 Duplicate No Date Entered 10n6s Safety No 8
IF19717-01 An inspector follow-up item was opened to track the operabihty of the Emergency Operanons Facihty's Emergency vennlanon system which was found to be lealung dunna the inspecnon ]
IFI La Salle 98-03 Duplicate No l
Date Entered 1042n Safety No 8 j Seavice bialdmg pubbc address symaan capabilaies. PA not audible in the service buikhng.
IFI ' Callaway 98 14 Duplicate No !
Date Entered 10a2n Safety No 8
The need to perfonn additional NRC revww of backup emergency operasions facihty capabihtie was idenafied because a radio base station to coaummicate with offsite field monitonns teams was not avalable at the backup facihty.
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Emergency Preparedness Findings 1997 - 1998 IV i Adequacy ofFacilities Pdgrim 97 02 Duplicate No ITRI Date Entered lon7S Safety No 8
The existing configuration of radiation monitors on the refuel floor does not satisfy the requirements of 10 CFR 70.24,"Cnticality accident reqintements." In addition BEco has not conducted evacuanon dnits as requimd by this part.Tius problem has mmimal safety consequences.
Beaver Valley 97-01 DupUcate No 1TPJ Date Entered 10n7s Safety No 8
URI 97-0104: Loss of power to the emergency response facdity, the event indicated potential weaknesses in operating procedures for the ERF building, deleganon of responsibility among site orgaruzations for the ERF, and follow-up of correcove accons for previous sinular events. De6ciencies associated wah the loss of power to the ERF are unresolved item pendmg compienon of DLC evaluacion and subsequent NRC review.
URI Millstone 98-80 Duplicate No Date Entered lon2n Safety No 8
Numerous longstanding problems were found to exist in the post accident sampims system. Due to the nanue of the problems, these 6ndmgs are being made an unresolved item and wn!! be documented in a subsequent inspection report.
Violanon Praine Island 97.!! Duplicate No Date Entered 10n7N Safety No 8
On June 24,1997. 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> emergency lighting was not provided for access and egress routes to the safeguards but No.15 room, which contamed equipment needed for operation of safe shutdown eqinpment.
This is a Seventy LevelIV violanon Violanon Braidwood 97-04 Duplicate No Date Entered 10/27N Safety No 8
Site Quahty Venficanon Audit Repon QAAJ20L96-05," Emergency Plan and Irnplemennns Procedures." dated March 22,19%, the 12 month review of the emergency preparedness program did not include an evaluanon of the adequacy ofinterface with the State of thinois. (50 457S70%01)
This is a Seventy Level IV violaion (Supplement VIID.
Violanon Waterford 97 15 Duplicate No Date Entered 10nes Safety No 8
Emergency hghting tuuts wit at least an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> banery power supply were not provided for the reactor auxiliary buildmg staarwell leadmg to the 46 foot chiller water system room, an access and egress route for an area needed for operatum of safe shutdown eqtupment.
Violanon Waterford 9g-03 Duplicate No Date Entered 1042S Safety No 8
The inspector reviewed infonnation for the two crews where the number of small or large face-pieces was inad.quate. In one crew,the stuft supervisor and a reactor operator were affected. In the other crew, a contml room supervisor and a reactor operator were affected. There were no controls estabhshed to address t!w shortage of properly sized air-supphed respirators.
The inspector determmed that the supply of air-supphed respirator face-pieces was inadequate and prevented the licensee from bems able to unplement procedun OP-901-520. The violanon is bems treated as a non-cited violanon.
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Emergency Preparedness Findings i 1997 - 1998 IV 1 1
Adequacy ofFacilities "Violanon VennonYankee 97 11 Duplicate No Date Entered 10a7s Safety No 8
This issue involved Ibe failuse to have un place either a enncabty momtonng system for storage and handling of new (non-irradiated) fuel or an NRC approved exempnen to this requirement contained in 10 CFR 70.24.
The NRC has also detennined that numerous other bcensees have smular cuctanstances that were caused by confumon regardng the continuanon of an exempnon to 10 CFR 70.24 orismally issued prior to issuance of the Pan 50 hcense. After considenng all the factors that resuhad in these violanons, the NRC has conchaded that while a violation did exist. it is appropnate to exercise ' enforcement discienon for Violanons Involving Special Circumstances in accordance with Section VII.B.6 of the " General Statement of Pohcy and Procedures for NRC Enforcement Actions"(Enforcement Policy). NUREG-1600. Pending the amendrnent to 10 CFR 70.24. further J
i enforcement action will not be taken for falute to meet 10 CFR 70.24 provided an enforcement saion will not 1 be taken for falure to meet 10 CFR 70.24. provided an exempnen to this regulanon is obtained before the next receipt of fresh fuel or before the next planned movement of fresh fuel. NCV 971104 and unresolved item URI 9743-07 are clowd. NCV included in EP section of report-l
- Violanon ' Millstone 97-81 Duplicate No f i
! Date Entered lon7n Safety No I 8
As of August 29.1997, adequais facilines and eqmpment were not being mamtaned. in that the TSC/OSC reference hbrary contaned uncontrolled drawmss and other documents relased to the response effon were in the l facihty but were not marked as controlled documents.
This is a Seventy LevelIV violanon Violation Cimson 97-02 Duplicate Yes Date Entered 10/27n Safety No 8
a Condinon Repon (l-94 10 002) dated September 30.1994, and issued October 3.1994, indicated that the backup meteoroletical tower wed speed and wed direction sensors were moperable. This condaion had not been conected. The wed speed and wmd direenon sensors have been unavalable since October 1994.
This is a Seventy Level IV violation (Supplement VIID.
Violation Beaver Valley 97-(9 Duplicate No Date Entered 1046n Safety No
! 8 VIO 97-09-03 the bcensee had not tested Iwenty of twenty-seven duect lines at its Ahemate EOF in Cornopohs.
PA. 'Ihese lanes would be used to perform the funences desenbod in Secuon IV.E.94-d of Appendix E in the ,
l event of an activanon of that facihty. l l This is a Seventy level IV violanon (Supplement VED apphcable to Umt I and Umt 2.
Violanon Calven Chffs 97 08 Duplicate No Date Entaced 10a6s Safety No 8
l 97-08 from September,1996 to September 1997:
( a. BGE tested the duect ime confication commumcanon hnk with the conaguous State / local governments quanerty instead of monthly,
- b. BGE tested the Heahh Physics Network communication hnk with NRC Headquaners and the Region i Operations Center quaneriy instead of monthly.
This is a Seventy Level IV violanon (Supplement VIII-Emergency Prepare &iess (EP).
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Emergency Preparedness Findings .-
1997 - 1998 IV Adequacy ofFacilities WNP2 97 18 Duplicate No Yiolation Date Entered 10/26S Safety No 8
NCV 9718-09 The fauure to perfonn a monthly check of the conuel room facsimile machine is a violation of TS 6.8.1, which rapares the hcensee to follow pmcedures that implement the emergency plan. This non-non-repensive, bcensee-idenafied and corrected violation is being treated as a Non-Cited violanon.
Violation Palo Verde 97-21 Duplicate No Date Entered 10/26S Safety No 8
Failun to perform emergency kit inventones Real Events LERs IFI Clinton 98-03 Duplicate No Date Entered 10/22 S Safety Yes 8
Extended periods of nme may have existed when the licensee did not poness the capabdity to transtmt radiological and meteorological data to the NRC. IDNS, or EOF, The hcensee's correcuve a tions to unprove the reliabibty of the ND-6685 computer will be reviewed dunns a future inspecnon.
Other Exercises IFl River Bend 98-01 Duplicate No Date Entered 10/22S Safety No 8
Plant access trauung dxi not siclude a discussion of regulatory hmits. mstruenons for fnsking, protection of the embryo / fetus per the declared pregnant female program, etc. Since these topics were only discussed m radiance worker trauung, inspectors questioned whether emergency response organizanon members received trauung consistent with 10 CFR Part 19.12.
IFl Braidwood 98 07 Duplicate No Date Entered 10/22S Safety No 8
An RFT was observed posung a high radianon area dunng the 1998 EP exercise which does not support ALARA pracoces.
IFl Indian Point 2 98-07 Duplicate No Date Entered 10/22S Safety No 8
Dunng the course of this inspection, the inspectors found several areas where EP programmanc controis were lacking. E.g.. No documentanon of complenon of shared offsite responnbdmes with Indian Point 3 EP personnel.
IFl Davis Besse 97 07 Duplicate No
(
Date Entered 10/26S Safety No 8
The poor simulanon of radiological data by controllers affected the abdity of the inspectors to evaluate radiological control practices by the participants and will be tracked as an IFl.
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Emergency Preparedness Findings 1997 - 1998 IV Other "IFl Cook 97-13 Duplicate No Date Entered 10/27 S Safety No l 8 IFl . 97 13 A potennal perfonnance anomaly was idennfied in relanon to repair team response Emergency i
Response searn I was given a highest pnonty designuson. Plant performance usessment (PA) suppon was requested for this team. PA was contacted and provided an individual. However smce this team wu designmed highest priorny there was discussion the the team would have to be sent out without wamng for PA support.
Inclusion of a rep from the PA group in an emergency response team had the potennal to delay the teams dispatch. Plant personnel were requested to clarify the desired degree of PA involvement in emergency inplant team actmties. The degree of PA involvement m emergency response teams will be an mspecion follow-up item.
IFl Zion 97 29 Duplicate No Date Entered 10/26 S Safety No 8
IF197 2902 -The inspector noted several problems with the control of the scenano and the over-sunulanon of acavities: On one occasion, a control a. lowed a response team to enter and stay in a stearn environment without providini ny simulanon for approximsely 3 minutes. On several occasions a the reques. of PET: controuers prowdeo vose rate infonnanon wahout venfymg that the RITs were conectly utthring the instruments to sunulate obtaming the requested informanon or that the instruments were property setup. An exarnple of such over.sunulanon wu idenafied whde accompanying the team. On one occasion a controDer allowed a non-hcensed operator to sunulate donning high vehage protective gear for breaker racking cperanons. On numerous occasions contioDers allowed personnel to sunulate donrung reseirators and protecove clothing.
Licensee acnons to detemune and specify the correct level of exerciso simulanon was an IFl.
URI River Bend 98-01 Duplicate No Date Entered 10/22S Safety No 8
An Unresolved item was idenufied concermns whether Regulatory Guide 8.13 trauung (protecuon of the embryo / fetus) was conducted m accordance with the Updated Safety Analysis Report Violanon Peny 98-03 Duplicate No Date Entered 10/22 S Safety Yes 8
Dunng this penod.neither the control room simulsor crew nor the TSC caff were able to determine a procedural method to emergency depressurize the reactor vessel to reduce the ra.hanon :elease to the environment.
The preadure inadequacy of PEl-D17 is a violanon of 10 CFR 50 Appendix B Cntenon V. Instructions -
Procedures and Drawmss,in that a safety related procedure was inadequate. T1us non-repennve, hansee-idennfied and conected violanon is being treated as a Non-Oted violanon.
Weakness Limerick 97-05 Duplicate No Date Entered 10/27 S Safety No 8
' An exercise weakness was idenufied in the TSC. The Emergency Director (ED) and As.60rnergency Director's ( AED) strong command and control tended to promote a"reacave" response inus ; i..an a "proacave" response from the engmeenng staff for perfonning "what if" straegies and providtog attemmive suggestions to the ED. This resulted in the bcensee not fuuy demonstranns an integreed response m the TSC. Also, the duties of the Mamtenace Team Coordinator (MTC) were not effecovely demonstrated.
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l IV Other Cooper 93 12 Duplicate Yes
" Weakness Date Entered loc 2n Safety Yes 8
ne failure of one cre v to effemvely irnplement key elements of the emergency plan (e.g., emergency director ovenight, protective accon reca=~aA~< offsne agency nonficanons. and emergency classdicanon) durmg simulator walkthroughs was idenafied as an exerase weakness.
InSpcCtions Cook 97 13 Duplicate No IFI Date Entered lon7s Safety ' No 8
!FI 9713 h was subsequently detennined that the hcensee's exercise controllers sunulated response teams. To fix needed equipment to keep the exerose tunelme on track. Controllers injeced clus infonnation without informing paracipants in TSC. He omission of exerose controllers to comrnunicate informanon regardmg the sunulated response teams to the TSC controllers will be tracked as an Inspecnon follow-up item.
Cooper 98 12 Duplicate No I IFl Date Entered lon2s Safety No 8
Based on a review of selected pornons of the emergency plan and unplementing procedures, the utspector idennfied the follomng areas that needed additioual review:(1) mconsistencies with WREG-0654. Table B I mmunum staffing levels (2) adequacy of radianon protecnon traimng provided to operaton who perfonn health physics dunes specified m NUREG-0654 (3) determine whether the emergeon plan sufficiently desenbed the responsibihties of certain on-shift personnel.
Callaway 98-10 Dupbcate No IFl Date Entered 10n2n Safety No 8
In addition to the actual dnll/exerose participants, the licensee also allowed dnWesercise parncipanon credit for trauung for the controllers sad evaluators.
Byron 98-02 Duplicate No IF1 Date Entered loa 2/9 Safety No 8
Traimns module S 25,'ODrs Specialist," was found to have a revision date of December 21.1994. He trauung module was also out of date in that it did not provide trauung on MESOREM% whidi is the dose calculation program currently used.
Millstone 98-80 Duplicate No IF1 Date Entered 10a2s Safety No 8
Based upon the assessment made by audit MP 97 Al2 02. the inspectors concloded that addmonal concenve acnons were regeired on the part of the EPSD in order to cemfy the EP function as ready for plant restart. He inspectors noted that the EPSD had outhne a correcove acnon plan m response to the audit and that some conecove scuons had already been completei ne NRC will evaluate the hcensee's compienon of these acnons and the need for enforument, dunns a futuri, inspecnon.
Comanche Peak 97 16 Duplicate No URI Date Entered 10/27 S Safety No 8
URi 97 16 Unresolved itern vivolving the deanption of the ERO m the E-Plan is being idenafied as an 10/28/98 Page 34
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IV Other URI Cook 97 15 DupUcate No Date Entered loc 7S Safety b 8
URI 971542. Not all members of the ERO maintained current respirator qualificanons. Some members of the operaung crews had not been respirator fit tested in over a year. 81 of 235 members of the ERO had current respirator quahficanons.
Violation Dresden 97 23 Duplicate No Date Entered 10c6s safety No 8
in May 1997, the SQV staffs idenafied that management asennon was needed in the area of EP, speedically in the ana of mantairung emergency procedures. Four findmss were idenafied in SQV's auda re'ated to EP[Ps not being mairitained cunent with the changes made to the GSEP Manual (speedically the EPIPs contauung the PAR procedures had not been revised to reflect ee more conservanve PARS developed frorn the revised GSEP manual whidi were currently agreed upon by the Late of 11hnois). the GSEP Augmentanon and Notdicanon Phone List not bemg adequately maintained, specific training rewrds were not readdy retnevable, and a lack of asennon to detail of GSEP Eqtapment Surveillances.
The fadure to update the PAR EPIPs within four months of a GSEP Manual revision as stated in the GSEP Manual. Revision 71.Secnon 8.5 is a violation of 10 CFR 50.54(q)."Condinons of Licenses." Tlus non-repeonve. heensee idenafied and corrected violanon is bemg treated as a Non-Gled Violanon.
Violanon Fon Calhoun 97-02 Duplicate No Date Entered 10c7s Safriy No 8
On May 6.1997, the NRC inspectors discovered that there were no instructions or procedures to ensure that al hcensed operators, who were required to wear correcove lenses as a condition of their uidividual licenses, had mrrecove lenses of the appropnate type available should these indivuluals be required to wear self-contained breathmg apparatus wlule perfomung bcensed dunes.
This is a Seventy Level IV Violanon Violanon Palo Verde 97 21 Duplicate No Date Entered 10a6B Safety No 8
Failure to submit emergency plan procedures to the NRC within 30 days of change Vio! anon Millstone 97 81 Duplicate No Date Entered 10/27S Safety No 8
the Audit Report No. A25 tl3.enntled " Connecticut Yankee /Milhtone Emergency Plan Audit and 10CFR56.54(t) Review for 1996" dated January 24,1997, did not include all elements of 10CFR50.54(t) such as adequacy of imerfaces with state and local govemments, ernergency preparedness program capabihoes. and procedures.
This is a Seventy LevelIV violanon This is a Seventy LevelIV violation "Dus is a Seventy Level IV violation Violanon Comanche Peak 97-04 Duplicate No Date Entered lon7s safety No 8
97-04-01: Emergency plan provisions for penodic reviews of off site agreement lesers were unclear and inconsistent with procedural requirements. A Non-Cited violanon was identified for failure to conduct an annual review of the emergency action levels with offsite authonties. The failure to review the emergency accon levels with the state and local authonties was idenafied as a violanon. The violanon was bcensee idenafied, nonrepetanve, corrected wuhin a reasonable tune and non willful.
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l - Emergency Preparedness Findings i
1997 - 1998 IV Other
- Violanon La Salle 98-03 Dupbcate No Date Entered 10/22n Safety No 8
Licensee records idenufied that approximately 110 mantenance personnel had not received annual requahficanon traming in 1997 and were not quahtied for emergency response in 1998. The failure to train mamtenance personnel as stated in the GSEP Manualis a Violanon. His non-repettave, heensee idennfted and conected violation is being treated as a Non-Cited Violanon.
Violanon Calvert Chffs 97 08 Duplicate No Date Entered 10/26 s Safety. No ,
8 NCV-97-08 he UFS AR desenbed the emergency radios onsite u having digital voice protecnon, but BGE had removed this feamre to unprove recepnon quahty. BGE revised its ERPIP for mahng changes to the EP program to include a review of proposed changes against the UFSAR but inled to conect the Identified deviation
- Odennfied as an URI in 19%). He inspectors concluded that BGE had fuled to update the UFSAR m a tunely i
fashion for a clunge affecnng the UFSAR.
Violsion Millstone 97 81 Duplicate No Date Entered 10/27N Safety No
- 8 j As of August 29,1997, adequate dose assessment methods were not in use,in that all personnel responsible for dose usessment could not adequately perform radiological dose usessment for potennat offsite consequences of radiological conditions in a manner necessary to support timely emergency management decision mahng for protecove acnon recommendanons.
l his is a Seventy LevelIV violanon i
Violanor Callaway 93-06 Duplicate No Date Entered 10/22n Safety No l 8 On May 29,1997, the hcensee made changes to its emergency plan, without Commission approval, thm decreased the effecnveness of the plan. Specifically,the requirement to collect and analyze offsite sample rnedia (solid, hquid, gu) was deleted from the desenpion of the radiological morutonng dnl!. His resulted in a reduction in t
field monsonng team trauung regmrements.
l his is a Seventy LevelIV violanon Violanon Millstone 97 81 Duplicate No l
Date Entered 10/27 s Safety No t 8 the NRC determined, by direct inspection, that during June 1997, the hcensee implemented Revision 22 to the l
emergency plan. *he bcensee decrewed the eNecoveness of the emergency plan in Revision 22 and implemented it without pnor NRC approval. Decreases in eNecnvenen included changms accountabihty tune from 30 to 45 minuses, a psovision decreasing the coverage for 4 health physics posinons from 30 to 60 minutes, and staffing time seducnons for other emergency response staff members.
His is a Seventy Level IV violation his u a Seventy LevelIV violanon l-1 i
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Emergency Preparedness Findings 1997 - 1998 IV Other South Texas 97,13 Duplicate No
- Violanon Date Entered 10/26 S Safety No 8
On September 3,1997, the inspectors idenuSed two cases in which individuals in the emergency response organization had not received the proper inical or annual trarung for their assigned position.
One individualidenn6ed by the inspectors u as assigned as an assistant radision manager on the emergency response orgaruzanon call out roster. De posmon was not part of the nunimum response organizanon identified in the hcensee's emergency plan.
l The other individual idenufied by inspectors was assigned to the on-stuft response orgaruzanon a one of three of I
four plant operators capable of performing the state / county communicuor responder function.
Violation Vogtle 97-04 DupUcate No l
Date Entered 10/27 9 Safety No 8
On And 15,1997,eight Emergency Plan implemennns Procedures in the OSC were idenufied for which revisions dated between November 21,19% and April 7,1997 had not been distributed shortly af'.cr approval to all required locanons.
Tins is a Seventy LevelIV Violation Violanon Wuerford 98-03 Duplicate No Date Entered 10/22 s Safety No 8
%1ule reviewing the 1997 emergency preparedness program audit, the inspector observed that there was no mention of the assessment of the mterfaces with state and local govemments. De bcensee provided a copy of the audit checklist shomng that the auditors had interviewed representauves from state and local agencies and had received very good response. From the informanon provided, the inspector detemuned that the offsne interfaces were well mantamed.
Herefore,the assessment was performed, but not documented. This was idenufied as a violanon of the reqmrements m 10 CFR 50.54(t).
His future consatutes a vie! anon of minor sigruficance and is being treated as a non-cited violanon .
Violsion WNP 2 98 14 Duplicate No Date Entered 10/22B Safety No 8
Contrary to the above,on July 13,1998, the licensee made changes to iu emergency plan. without Commission approval, that decreased the effecnveness of the emergency plan. Specifically,inmal trauung requirements wore reduced from formal classmom instruction, wnnen examinanon, and hands-on traming where appropriate to I
formal classroom instruccon, wnnen examination, or hands-on training.
l And, on July 23,1998. it was determined that the licensee's emergency plan did not desenbe the irutial and retrauung programs. De emergency plan stsed that course assignmenu for members of the emergency organizanon may be found in emergency plan implementmg procedures. The course assignments were not found !
in implementing procedures, and retrainmg courses were only idennSed in a computer dmhm ]
This is a Seventy Level!V violanon. l Violsion WNP2 98-09 Duplicate No Date Entered 10/22 s safety No 8
On April 3,1997,the bcensee made a change to its emergency plan, without pnor NRC approval,the decreased the effecoveness of the plan. Specifically, the change reduced the level of health physics expemse on-stuft and I
overburdeaed the on-shtft chemistry technician with health physics responsibihnes.
This is a Seventy LevelIV violanon l
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Emergency Preparedness Findings 1997 - 1998 1
IV Other
" Violation Comanche Peak 97-19 Dupbcate Yes e
Date Entered 10/27 s Safety No 8
on Ocuhr 29.19%, the licensee made the foUowing changes to its emergency plan without Commission approval that did nc4 cononus to meet Planrung Standard 5047(b)(2), or the reqmrements of Appendix E.
!. Ganges involving the desenpnon of emergency response orgaruzanon memben &d not conunue to rneet j Planrung Standard 50.47(bH2)and Appendia E.IV.A requirements. Spec 6cany,the desenpnon and responnbihnes of the following four emergency response organizanon posinons wem deleted from Revision 25 but remamed on the organizanon chart and emergency response organizanon callet roster. (a) emergency operations facilay radianon assessment coonhnator,(b) techrucal support center opecanons coordmator, (c) operanons advisor, and (d) supponmg staff for the logistical support coordmaior.
] 2. Changes invoinns the desenpuon of the emergency response organizanon trairung program did not conunae I to meet Appendix E.IVF.I reqmaments. Specifically,the desenpoor.of the fire bngade and security trurung programs were deleted from Revision 25.
- 3. Changes invoinns the desciipnon of offnte decision makers &d not continue to meet Appendix E.IV.A.8 regarements. Specifically,the idenaficanon of the offsite protecove aanon decision makers for the ingesnon '
i pathway zone was deleted from Revision 25 to the plan.
his is a Seventy Level IV violanon (Supplement VIID.
Violation llarns 97-06 Duplicate No Date Entered 10/27/9 Safety No 8
The .nspectors reviewed the licensee's masitenance of the Emergency Plan (Plan) and selected comnutments therent and reviewed recent revisions to the Plan to determine whether changes were made b accordance with 10 CFR 50.54(q).
Dunng review of documentanon associated with Revisn 28 (which crimpnsed e& tonal " cleanup" only), the inspeaors noted that the Plan revision was processed by the bcensee's Docurnent Services group and assigned an effecove date of July 31,19%. However, the reqmnd final approval of Revisen 28 by the Plant Nuclear Safety Comnuttee (PN!C) did not transpire unal August 1,19%.
his failure to folaw an admuustranve procedure consatutes a violanon of maior sign 6cance and is being treated as Non-Cited %olanon.
Violation Zion 97 08 Dupucate No Date Entered 10/26/9 Safety No 8
Annual reviews of the Emergency Prepare &iess programs. contained in Site Quabt) Venficauon Au&t QAA 22 95-04,"Generanng Stanon Emergency Plan," dated July 28,1995, and Site Quabry Verlicanon QAA 22-96 08," Audits of Generanng Stanon Emergency Plant (GSEP)." dated July 25,19%. &d not address the adequacy of the offsite interface with the State of 11hnois.
His is a Seventy LevellV violanon Real Events LERs IF1 Clinton 98-03 DupUcate No Date Entered 10/22/9 Safety No 8
he TSC SED assumed the lead role but did not wect of coordinate the response acavities of the facshty.
Essentzauy, the sift supervisor did not relinquish command authonty over the ERO and conunued to estabbsh the pnonties for the stanon throughout the duranon of the Alert.
IFl Chnton 98 03 Dupucate No Date Entered 10/22/9 Safety No 8
he hcensee noted that one wide si-- -: =re were infrequendy made and did not include informanon regardtng Page 39 10/28/98
Emergency Preparedness Findings .-
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'IFl Cimton 98-03 Duplicate No Date Entered 10n2/9 Safety Yes 8
The hcensee noted that three-pan communications were not used by all ERO penonnel and that reminden made dunas the Alert unproved commurscanons for shot duranons. The hcensee noted that commurucanons between the maan control room and the TSC were ddficuh in that a dedicased communicator was not estabbshed in the control room. Pnonnes were not cleady communicated beween the TSC and the main control room.
IFl Chnton 98-09 Duplicate No Date Entered 10/22/9 Safety , No 8
The licensee detemuned that the SED was not always aware of operations teams formed and dupatched by the shift supervisor. The lack of ovenight by the SED resuhed m communicanon problems regardmg restormoon of plant equipment.
11Rt Cimson 98 03 Duplicate No Date Entered lon2n Safety No 8
The hcensee deternuned that the SED was not always aware of operanons teams formed and dispatched by the shiA s.apervisor. The lack of oversight by the SED resuhed m --+n problems regardms restoranon of plant eqmpment.
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1997 - 1998 V
bcategorysli . Subcategory 1Msl: Subcategory 2 t l lFI l URI l Violation l Weakness]
V Other jRoal Events LERs 1j Other RealEvents LERs IF1 Turkey Poua 9847 Duplicate No Date Entered 10a2s Safety No 8
Follow-up on the root cause of a motor generator se: fire. (no EP impbcations noted) l l
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LER I -
Accident Assessment Real Events LERs l Event Minstone 97 o60 Duplicate Yes l
Date Entered 10/22B Safety No l
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Title:
Ineffective implementation of the Post Accident Sampimg Symem Program On November 25,1997, with the unit in Mode 5, a Nuclear Oversight audit findtng identdied several Post Accident hmphng System (PASS) program weaknesses wluch quesconed the functionahty of the system and the I
capabihty of sampimg personnel to obtain and analyze reactor coolant, contamment atmosphere, and containment recirculanon sump samples, following a design basis accident he audu idenafied specific PASS programmanc weakneases in the areas of tedmician traines, maintenance of equipment and supphes, instnamentanon cahbration and twevenove maintenance acnvines, and PASS emergency plan dnll performance.
On Apnl 15,1998, results of a February 23-26,1998. Nuclear Regulatory Comnussion (NRC) assessment inspecnon of the PASS idenufied several addnional emergency response reised program deficiencies the had not j been previously addressed in the onginal report subnuttal (ref. LER 97 06(M)0). These deficiencies called into quesnon the effecoveness of the PASS program and the abthey to " ensure the capabshty* to obtam and ar.alyze post accident samples "under accident condinans." llus is a failure to comply wnh 13 6.8.4.d and is betr1 reponed pursuant to 10 CFR 50.73(aK2)(i)(In. as a condition or operation prohibited by the unit's Technical Specificanons. He cause of this condition is aanbuted to a failure of management to unplement an effecave PASS program that ensured comphance with Technical Specificanon requirements. Although the abiimy cf the PASS system to function in compliance with the TS requirements could not tw assured, attemate sources could be unhzed to make appropnate post accident nunganon and protecove action recommendations. Here were no safety consequences as a result of clus event. he correenve acnons associated mth these idenufied deficiencies have been completed with the exception of a correcnve acnon to conduct survetllances that will venfy that PASS samples can be analyzed to satisfy acceptance entena.
Event Recognition Real Events LERs Event Callaway 97 006 Duplicate Yes Date Entered 10/22N Safety No 8
Title:
Loss of Annunciators and Unusual event Declaranon Due to Lightrung Senkes On 7/19S7, a approximately 1600 CDT, two lightning stnkes occuned in the Callaway Plant weer treatment facihty resultog in degraded field power supply voltages and a toss of seversi Main Control Board (MCB) annuncisors. At approxunately 1625, unhty instrument and Control (l&C) techrucians discovered smoking connector cards in computer muluplexer cabuiet RK045DI, rack M-7 and de-energized the rack, thus recunung most MCB annuncisors to a funcmonal status. At approximsely 2230 CDT, utihty engineers detemuned that shhough the power sapphes had not failed during the subject 25. minute period,it could not posinvely be detemuned that the majonty of MCB annunciators had been funcnonal from 1600 to 1625. Notification was made that condinons had existed between 1600 and 1625 which placed Callaway Plant in an Unusual event. %:s report is being mm voluntanly to address the root cause and correenve acnons for a declared Unusual event. The cause of the post event emergency declaration was inadequate procedure sindance. The unhty Nuclear Erigineenns department will perform a comprehensive system design review to identify probable failure modes and potential design enhancernents. Appbcable procedures have been revised to more clearly define entena for a " failed" power supply. Integrated training will be conducted on this event with unbry personnel l
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Other Real Events LERs Event WNP 2 97 003 Duplicate No Date Entered 10/22M Safety No 8
Title:
Nonficanon of Noocomphance with Techrucal Spectficanons At 1645 on March 20,1997, with the plant operutng at 100% power, NRC staff nonfied the Supply System ths
%HP 2 Techn cal Specificanons 03) Surveillanca Reqmremenu (SRs) for Response Time Tesung (RTT) were not bems met for specified instrumentation in the Reactor Protecnon System. Pnmary Contanment isolanon System, and Emergency Core Coohng System. %KP-2 declared the specified eqmpment inoperable and entered the apphcable Technical Specificanon Acnon Statements (TS AS). his accon requred subsequent entry into LCO.
3.0.3 necessitanng ininacon of a plant shutdown widun I bout and placing the reactor mode switch in the startup postoon withm 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. At 1740 %NP 2 declared an unusual event based on entry into LCO 3.0.3 and uunned a j power reduchon required by the TS. %NP 2 then requested enforcement discreuon for a one-etme exempoon from the ambcable Techsucal Specificsion SRs unul Apnl 18,1997 or unn! the issuance of a license amendment changing the Technical Spectficatwns. At 2136 %KP-2 received verbal nonficanon of enforcement discrenon.
De TSAS and LCO 3.0.3 were es ted at this time. He unusual event was temunated a 2200 based on eut froru LCO 3.0.3 ne elapsed tune the sqmpment was declared inoperable was 4 hrs. 50 mm. ne March 20 letter mdicued the fadure to meet the SRs was caused by an inconsistency between %NP 2's method of irnplemenung i Licensing Topical Repon NEDO-32291
- System Analyses for Ehminanon of Response Tune Tesung Requiremenu" and %NP-2 Techrucal Specificanon SRs and RTT defuutiona. he Supply System's failure to clartfy the staffs expectanons before proceedmg with implementanon u as also a cause.
Event Pdgnm 97 007 Duplicate No Date Entered 10/22n Safety No 8
Title:
Safeguards Buses De Energtred and Losses of Off Sne Power Dunns Severe Storm Whde Shut Down On Apnl 1,1997, both 120 volt safeguards buses de energued on two occasions, and subsequently, a loss of prefernd off-nte power (345 kV) followed Imer by a loss of secnndary off-ute power (23 kV) occurred wlule the emergency diesel generators were n operanon durmg a severe storm (bhzzardt An Unusual event was declared at 0349 Inurs and was termmated at 2347 hours0.0272 days <br />0.652 hours <br />0.00388 weeks <br />8.930335e-4 months <br /> by wiuch ame the secondary and prefened off-site power sources were re energized. The cause of the de-energtzmg of the safeguards buses was bnef, severs 345 kV transmission system undervoltage transients tha resulted m automanc shut downs of the voltage regulanng transformers (480/120 volt) ths power the safeguards buses. He transformers' purchase spectftcanon did not address and the manufacturer and suppher documentanon did not idennfy an automanc shut down feature if mput voltage was less than 384 volts (greger than zero volu). De separse losses of the offsite power sources were cause by the effects of the stonn. Conectrve acnon taken included the replacement of the nucroprocessor control uruts installed in the voitage regulanns transfonners. he events occurred while in cold shut down. The reactor mode selector switch was in the REFUEL posinon. De evenu posed no three to pubbc health and safety.
Event Calven Chffs 9t005 Duplicate No Date Entered 10/22s safety No 8
Tide: Reactor Coolant Syr'em Leak Due *o Failed Compression Fimns On May 29,1997 at 1620, Calvert Chffs Unit I experienced a Reactor Coolant System leak of approximately 810 gallons per minute while operating at ;00 percent power. Operators implemented Abnormal Operatmg Prowdure 2A, declared an Unusual event, and comrnenced a rapid unit downpower. The leakage source was a failed 3/4 inch compression fitung in an lastrument ime from the pressuruer vapor space. He leak was isolmed at 1930. By 1935 the plant was in Hot Standby. De cause of the compression fitting fadure was improper assembly. It's ferrule was insufficiently compressed due to insufficient nut advancement. Inspecnons of cnocal compression fitungs in both Calvert Chffs uruts was expedmously completed. Other compression finings will be evaluned and addressed during scheduled systern mamtenance. Addinonal correenve accons will be implemented based on the resolu of an ongom; root cause analysis.
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l'- Emergency Preparedness Findings i
1997 - 1998 l
l H
l Other
' Event Arkansu 96 009 Duplicate No
- Date Entered 10/22 S Safety No 8
Title:
Cracked Weld in an Oil Line on a Reactor Coolant Pump A fire was discovered in insulanon around the Main Feedwater noule nas on *B" Once lhrough Steam Generator l
(OTSG) dunng heuup of the Reactor Coolant System (RCS). A weld located in the discharge line of a Reactor Coolant Purnp (RCP) motor ou hft pump had cracked due to a fabrication defect. The failure, believed to have occuned at the start of the outage, resulted in od being introduced onto the insulanon. Oil on the insulanon
! allowed a wicking effect that reduced the auto-igrution point of the oil to a value lower than the documented value.
The fire originated when the RCS temperatum was aproximately 439 degrees. Apphcanon of a bght waterfog l
from a fire hose extmguished the fire approumately 16 minutes afterit was discovered. A Notification of Unusual .
! event was declared when the fin was not exunguubed within 10 nunutes. The plant returned to cold shutdown condmons to evaluase damage. Other than some nunor damage to insulation the fire did not damage any systems or v a &+=~-u were made to the ou coucanon systems of all RCP moton, and damaged insulanon was repaired or replaced pnor to the subsequent heatup.
Event Diablo Canyon 97-005 Duplicate No Date Entered 10/22 S Safety No 8 i l
j
Title:
Reactor Trip and Safety injection Caused by inadvertent Main Stearn isolation valve Closure Due to l Penonnel Enor On October 24.1997, at 0815 PDT with Urut 2 in Mode I (Power Operanon) at 100 percent reactor power, a !
l
! reactor inp (RD and safety injecnon (SI) occurred due to inadvenent closure of a mam steam isolation valve. l One power operated relief valve lifted to reheve reactor coolant system (RCS) pressure seven ames dunns l
l recovery from the RT and St. 51 actuation signal was reset at 0829 PDT. An unusual event (UE) was declared for .
l this event at 0832 PDT. The San Luis Obispo county Shenffs Office Watch Commander was nonfied at 0837
! PDT. A 1. hour emergency report was made to the NRC,in accordance with 10 CFR 50.72(a)(110) at 0900 PDT.
! On October 24.1997, at 0938 PDT followmg stabdizanon of Unit 2 in Mode 3 0Iot Standby). ilu UE was ternunated. This was the twelfth Urut 2 emergency core coohng system actuanon cycle that resuhed in a d scharge of water mto the RCS. The cause of the event wu inadvenent actuanon of the closed posinon switch ;
for FC%44 by a contract laborer removmg scaffoldmg adjacent to the valve. Correcove acnons to prevent recurrence include: (1) revision of the scaffoldmg program procedure and risk assenment procedure and (2) issuance of a maintenance pobey to require a nsk assessment and management approval for non rouune work near cnucal componenu. i l
l i
I
, 1 l l l
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Page 45 10/28/98
Emergency Preparedness Findings 1997 - 1998 e
II Other Mdistone 97 060 Duplicate Yes
- Event Date Entered 10/22/9 Safety No 8
Title:
Ineffeaive 'mplementauon of the Post Acadent Samphng System Program On November 25,1997, with the umt in Mode 5, a Noclear Oversight auet fin &ng identified several Post Acc dent Samphng System (PASS) program weaknesses which quesnoned the functionalny of the system and the capabihty of samphng personnel to obtan and analyn reactor coolant, containment atrnosphere, and contsnment rectrculanon sump samples, follomng a design basis accident. De audit identified specific PASS programmanc weaknesses in the areas of technician trainmg.mmatenance of equipment and supphes, instrumentation cahbranon and prevenove mantenance aamnes, and PASS emergency plan dnli pcrformance.
On April 15,1998, results of a February 23-26,1998, Nuclear Regulatory Comnussion (NRC)assessmem inspection of the PASS idenafied several ad&tional emergency response relsed program deficiencies that had not been previously addressed in the onginal report subnunal (ref. LER 97 060-00). %ese de6ciencies called into quesnon the effecoveness of the PASS program and the abthey to " ensure the capabibty" to obtam and analyn post-accident samples "under accident conditions." His is a fadure to comply wnh TS 6.8.4.d and is being reported pursuant to 10 CFR 50.73(a)(2)(i)(B), as a condition or operanon prolutnted by the urut's Technical Specificanons. De cause of tius condition is aanbuted to a falure of management toimplement an effecove PASS program that ensured comphance wnh Technical Spect6 canon requirements. Although the abdity of the PASS system to funcnon in compliance with the TS requirements could not be assured, attemate sources could be untiud to make appropnse post. accident nutiga: ion and protecove acnon recommendauons. Here were no safety consequences as a result of this event he correcove actions associated mth these idenn6ed deficiencies have been completed with the eacepuon of a correcove accon to conduct survedlances that will venfy usat PASS samples can be analynd to satisfy acceptance entent Event Davis-Besse 48-006 Duplicate No Date Entered 10/22/9 Safety No 8
Title:
Tomado Damage to Switchyard Causing Loss of Offsite Power On June 24,1998, a approximately 2040 hours0.0236 days <br />0.567 hours <br />0.00337 weeks <br />7.7622e-4 months <br />, with the unit in Mode I a 99 percent power, a storm cell moved l
through the site area, and, at approximate y 2044 hours0.0237 days <br />0.568 hours <br />0.00338 weeks <br />7.77742e-4 months <br />, a tomado touched down onsite. The Emergency Diesel Generators were both manually started when the Control Room received a report of a tomado on sue. ne damage from the tomado, accompanyuig straight-line winds, rain and hghtning, resuited in a complete loss of offsite power (LOOP). He LOOP caused the turbine control valves to close m response to a load rejecnon by the man generator. De Reactor Proteaion System (RPS) initised a reaaor tnp on lugh Reactor Coolant System (RCS) pressure. At 2118 hours0.0245 days <br />0.588 hours <br />0.0035 weeks <br />8.05899e-4 months <br />,an Alert was declaredin accordance with procedure RA-EP-01500 Emergency Cl.assification Emergency Action Level (EAL) 8.B.2, Any tomado stnking facihty. Following restoration of an offsite power source,the Alert wu downgraded to an Unusual Event at 0200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> on June 26,1998, and at (405 hours0.00469 days <br />0.113 hours <br />6.696429e-4 weeks <br />1.541025e-4 months <br />, the Unusual Event was terminsed.1he tomado resuhed in signdicant darnage to the offsne electncal estnbunon system, telecommunications, power to the sirens and other unfornned structures. lmmed me correcave actions involved it.e testing and repanng of the affeaad electncal and mecharucal equipment necessary to restore two offsuo power sources and assessing damage to other plant componenu and structures and iruaanns repairs. Plant telecommunicanons we.e restored and the stren system was returned to 90 percent availabthey pnor to plant startup. Here were no adverse effecu to the pubhc heahh or safety. Davis.Besse Nuclear Power Stanon Umt I stautup was irutiated, with reaaor enticahty reached on July 1,1998, at 2257 hours0.0261 days <br />0.627 hours <br />0.00373 weeks <br />8.587885e-4 months <br />, but was shutdown due to elevsed sulfse levels in the steam generator wuer chemistry on July 2,1998. Follomng steam generator fiti, soak and & ains, starcup was uunatet on July 5,1998, and at 0400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> on July 7,1998, the Man Generator was synchronized to the gnd.
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s Emergency Preparedness Findings 1997 - 1998 II Other Tvent La Salle 97-009 Duplicate No Date Entered 10/22 s Safety No 8
Title:
Inadequare Understanding of Lake Design Basis Results in Lake Level Higher Than Penniaed by UFSAR LaSalle County Simion entered an Unusual event at 19:45 on 3/11M7 when it was detemuned that the 701.8 foot elevanon of tho lake level at that time was above the 701 foot maximum level desenbed in the LTSAR and usalin plant flooding potential analyses. The high take level resulted principally from a lack of knowledge and consideracon of the design basis for the maxunum lake level. This led to operanng and surveillance procedures which provided upper knuu for take level higher than the UFSAR spetfied value of 701 ft. Contnbutmg faaors were high rates of preciptanon, poor matenal condicon of the lake make.up and blowdown hnes and the l unavailability of the lake blowdown valve. Cnucal plant equipment were confirmed to be operable for the higher than analyaed lake level. However, as prudent measures, plant personnel monitored lower elevanons of the plant, and the flood wall on the north side of the condenser pt was effecovely raised by placement of sand bags to o elevanon of 701 ft.10 m. Operanns procedures were revtsed and additional revisions are in progress. The lake blowdown valve wu returned to full service on 3/13/97 to begin reducing take level to its normal range. The l
Unusual event was temunated at 17:00 on 3/26S7 with the lake level at 700.68 ft. The lake level was witlun normal operanns range on 4/3/97.
I l
Event Cook 97-005 Duplicate No l Date Entered 10/22n Safety No 8
Title:
Condinon Outside Design Basis Resulu in Technical Specificanon Regtnred Shu'down On September 8.1997, at 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br />, with Unit 2 at 96 percent Rated Thermal Power,it was discovered that under certam scenarios the volume of water resident in the acuve sump volume of the containment may not be adequate to support long term Emergency Core Cooling Systems (ECCS) or Containment Spray (CTS) pump opersue, during the rectreulation phase of a LOCA event. This was detennined to be reponable under 10 CFR 50.72(b)(1)(ii)(B), as a condition outside the design basis. A Technical Specification required shutdown was undertaken, which wa.; reportable imder 10 CFR 50.72(b)(1)(i)( A). This intenm LER is being sutunned tn acconiance with 10 CFR 50.73(a)(2)(ii) and 10 CFR 50.73(a)(2)(i)(A). The containment drainage system is designed to ensure that water from an RCS break. ECCS injecnon, and ice melt flows back to the recirculanon ,
sump in sufficient quannties to provide adequate protecnon asainst vortexmg in the sump dunng recirculation l followmg a design basis accident. Existing analyses were unable to readily confinn that the nununurn sump level u ould be acaieved under all potennal scenanos, paracularly a very small break LOCA. Without sufficient sump l lev el, long ter.n integnty of the ECCS and CTS pumps could not be ensured due to potennal air entraintnent from vortexing in the sump. A shutdown was conservatively commenced at 1728 hours0.02 days <br />0.48 hours <br />0.00286 weeks <br />6.57504e-4 months <br /> for the urut, and uten it became apparent that analysts was not able to confirm sufficient communicanon, an Unusual event was declared at 2000 houn. On September 10,1997 at 0015 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> Unit 2 entered Mode 5. cold shutdown. The Unusual event was ternuna.ed at 0303 on September 10,1997 when Urut 1, which was also engaged in a Technical Specificazion required shutdown, entered Mode 5 as well. Analysis is being perfonned to confirm adequate water volume, and the physical configuranon of the acuve surnp volume boundary is being validated.
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Emergency Preparedness Findings 1997 - 1998 11 Other Event Cook 97 017 Duplicate No Date Entered 10a2s Safety No 8
Title:
Condmon Outside Design Basis Resuhs in Technical Specificsion Required Shutdown On September 8.1997, at 2000 huurs, wuh Unit I s 74 percent Rated Thermal Power,it wu discovered thm under certam scenanos the volume of wazer resident in the acuve sump volume of the containment niay not be adequae to suppon long term Emergency Core Coohng System (ECCS) or Containment Spray (CTS) pump operation dunng the recirculanon phase of a LOCA event. This was determined to be reportable under 10 CTR 50.72(bX1XiiXB).as a condition outside the design basis. A Techrucal Specificanon required shutdown was undertaken, which is reponable under 10 CFR 50.72(b)(1)(iXA). This intenm LER is being subnutted in accordance wnh 10 CFR 50.73(aX2Xii) and to CFR 50.73(a)(2)(i)( A). The contamment drainage system is designed to ensure that water from an RCS br-ak ECCS injecnon, and ice melt flows back to the recirculation sump in sufficient quanones to provide adquate protecnon agamst vortexing in the sump dunng recirculanon following a design basis accident. Eaistmg analyses were unable to readily confirm that the muumum sump level would be achieved under au potential scenarios, parucularly a very small break LOCA. Without sufficient sianp level,long term integnty of the ECCS and C13 pumps could not be ensured due to potennal air entramment frorn vorteams in the sump. A shutdown was consert.wely commenced at 1655 hours0.0192 days <br />0.46 hours <br />0.00274 weeks <br />6.297275e-4 months <br /> for the urut, and when it became apparent that analysts was not able to confirm sufficient communicanon, an Unusual event was declared at 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br />. On September 10,1997 at 0303 hours0.00351 days <br />0.0842 hours <br />5.009921e-4 weeks <br />1.152915e-4 months <br /> Urut i entered Mode 5, cold shutdown, and the Unusual event was temunated. Analysis is betng performed to confirm adequate wser volume, and the physical configuranon of the acuve sump volume boundary 61 being validated Event Sony 98-009 Duplicate No Date Entered 10a2s Safety No 8
Title:
Non isolable Leak of Reactor Coolant Pump Seal Injecnon Lins Weld On May 9.1998, with Unit I at 100% power, an increase was noted in Reactor Coolant System (RCS) leakage.
Operanons personnel entered the contamment to invesagate and discovered a leak in the area of the i 1/2" seal injection line to the "C" Reactor Coolant Pump (RCP) at the pump thermal barner. A subsequent contamment entry confirmed that a weld or pipe through-wau non-isolable leak existed at the seal mjecnon Itne of the RCP.
The urut was placed at cold shutdown as required by TS 3.1.C.4. On May 9.1998, a Nonce of Unusual event was declared and, at 2316 the NRC was notified in accordance with 10CFR50.72(a)(1)(i) and 10CFR50.72(bX1)(i)(A).
The sealinjecnon ime was repaired and the urut was prepared for start-up and the urut was retumed to service on May 25,1998. A Root Cause Evaluanon (RCE) was initiated to venfy the cause of the leakmg "C" RCP seal injecnon weld. The cause has prelmunanly been detemuned to be from a pre-existmg uxhcanon at the toe of the weld. The most probable cause for the weld fadure was a lack of fusion orthermal fangue coupled with vibration stress due to a loose rod hanger. This event is reportable pursuant to 10CFR50.73 (a)(2Xi)(B).
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Emergency Preparedness Findings 1997 - 1998 H
Other
" Event Callaway 97 006 Duplicate Ya Date Entered 10/22n Safety No 8
Title:
Loss of Annuncisors and Unusual event Declarmion Due to Lightning $tnkes On 7/19M7, as appmaunately 1600 CDT, two lightning stnkes occurred in the Callaway Plant weer treatment facthty resultag in degraded field power supply voltages and a loss of several Man Control Board (MCB) annuncators. At approximately 1625, utility Instnunent and Control (l&C) technicians discovered smoking connector cards in computer muluplexer cabmet RK045DI, rack M-7 and de-energized the rack, thus returning most MCB annunaators to a funcnonal status. At approximately 2230 CDT, unhty engineers determined that akhough the power supplies had not failed dunng the subject 25munate pened,it could not posiavely be determined that the majonry of MCB annunciators had been functional imm 1600 to 1625. Notification was made that condmons had existed between 1600 and 1625 which placed Callaway Plant in an Unusual event. His
, repon is beung made voluntanly to address the root cause and correcave acnons for a declared Unusual event. The cause of the post event emergency declaration was inadequase prt.cedure guidance. The unhty Nuclear Engineenns depanment will perform a comprehensive systern design review to identtfy probable failure modes and potennal design enhancements. Appbcable pecedures have been revised to more clearty denne enteria for a
- failed" power supply. Integrated trauung will be conducted on dus event with utthey personnel.
Event WNP2 98 011 Duplicate No Date Entered 10/22n Safety No At -13:43 on June 17,1998, with the plant shutdown in Mode 4 and RHR A in shutdown cooling mode, a signdicant water harnmer event a the plant fire protecnon system piping resuhed in the catastroph:c failure of fire protecnon valve FP.V 29D located m the reactor builduig northeast stairwell. Water from the ruptured fire protecnon val e flooded the stairwell and the Residual Heat Removal C (RHR C) and Low Pressure Core Spray (LPCS) rooms locased on elevanon 422. Due to water covenng the system keep fill pumps, control room personnel started RHR B m suppresnon pool coolms mode to mamtain system operabthty. After venfying no fire or threas of fire,operanons personnel shut off the operaMg fire protection pianps and temunated the source of flooding. An Unusual Event was declared, and supplemental fire protecnon personnel and equipment were called to standby on-site until the fire protection system operability could be reestabhshe<L The cause of event was deteanned to be inadequate design of the fire protection system. Several contnbunns factors exacerbated the event. Just prior to the event the plant was shutdown and during the event two systems (one from each electncal division) were maintamed available for shutdown coohng at a!! nmes. Therefore, the safety consequences of this event was detemune to be low.
1 Page 49 10/28/98
Emergency Preparedness Findings 1997 - 1998 II Other Davis Besse 98-004 Duplicate No Event Date Entered 10/22,9 Safety No 8
LER 98-004:Tomado Damage to Switchyard causing Loss of Offsite Power On June 24,1998, at approxunsely 2040 hours0.0236 days <br />0.567 hours <br />0.00337 weeks <br />7.7622e-4 months <br />, with the unit in Mode I at 99 percent power, a storm cell rnoved through the site area, and, at approxunately 2044 houn, a tomado touched down onsite. De Emergency Diesel Generators were both manually staned when the Control Room received a report of a tomado oc site. The damage frorn the tomado, accompanytog straight bne winds, rain and hghtrung, resulted in a complete loss of offsite power (LOOP). The LOO? caused the turbine control valves to close in response to a load rejecion by the main genernor.De Reactor Protection System (RPS) initiated a reactor inp on high Reactor Coolant System (RCS) pressure. At 2118 hours0.0245 days <br />0.588 hours <br />0.0035 weeks <br />8.05899e-4 months <br />, an Alert was declared in accordance with proceaure RA EP 01500. Emergency classification. Emergency Acnon Level (EAL) 8.B.2, Any tornado sinking facihty. Following restorsion of an offsite power source,the Alert was downgraded to an Unusual event at 0200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> on June 26,1998, and at i405 houn, the Unusual event was tertunned, ne tomado resuhed in sigruficant damage to the offsite electncal distnbunon system, telecommurucanons, power to the sir % and other unfortified strucmres. Immedise correcove acnons involved the testing and repairing of tha affeaed clearical and mechanical eqmpment necessary to restore two offsite power sourc+s and assessmg damage to other plant componenu and strucsures and iruuanng repain. Plant telecommurucanons were restored and the stren nystem was retumed to 90 percent avslabihty pnor to plant startup. Here were no adverse effects to the public health or safety. Davis-Besse Nuclear Power Stanon Urut I startup was ironmed with reactor enncahey reached on July 1,1998, at 2257 hours0.0261 days <br />0.627 hours <br />0.00373 weeks <br />8.587885e-4 months <br />, but was shutdown due to elevued sulfate levels in the steam generator wuer chemistry on July 2,1998. Following steam genernor fili, soak and druns, startup wu uunated on July 5,1998, and at 0400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> on July 7,1998, the Man Genersor was syndtroruzed to the gnd.
Byron 98 017 Duplicate No Esent Date Entered 10/22/9 Safety No 8
LER 98 017: At C247, on August 4,1998,345 kV Line 0621 between Byron Station and Cherry Valley sensed a fault causing feeder breakers at Cherry Valley Transrnission Sub<tanon and Byron Stanon Oil Circint Breakers (OCB) 4-5 and 5 6 to inp open [FKl. Electric Operanons identified the most probable cause of this fault as a hghtnmg stnks to Line 0621. Electric Operanons had the feeder breaker at Cherry Valley re closed and Line 0621 was re-energized.De Byron Staion switchyard and relay house were walked down, associated trip targets reset, and OCB 4 5 and 5-6 visually inspected for damage. At 0347, a reclosure of OCB 5-6 was attempted.OCB 5-6 immedimely tnpped open and gave a local Breaker Backup (LBB) causing Air Circuit Breaker ( ACB) 6 7 to enp open resultmg in a loss of offsite power to the Urut i Stanon Auxihary Transformers (S AT).ne apparent cause of the loss of offsue power for Umt I at Byron Stanon was due to the failure of the 94X relay to reset after the fault cleared. Furthermore, due to the procedusi inadequacy of BAR Ow35 Dl, the opersor anempted reclosure of 345 kV OCB 5-6 with the false inp signal on 345 kV OCB 5-6, caused by the failed 94X relay on Line 0621 System 2 relays. T1us,in conjuncnon with the irnproper pole synchronizanon time on OCB 5-6, led to loss of offsite power to Urut 1 System Auxihary Transformers. Correcove acnons are to:Invesagare the failure of the 94X relay to reset, review the annuncisor sesponse, ravise procedure BAR 0 35131, and review IEN 9712 for switchyard spare part reviews. An Unusual event was declar d and an Emergency Nottficanon wu made. His event is reponable per 10rFR50.73 (a)(2)(iv).
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l *- Emergency Preparedness Findings 1997 - 1998 H
Other "Odwr Oconee 97 001 Duplicate No l Date Entered 10/22/9 Safety No l 8 Tide: Unisolable Ranctor Coolant 1.eak Due to inadequate Surveillance Program I
l On April 21,1997. Unit 2 was at 100% Full Power (FP). At 2245 hours0.026 days <br />0.624 hours <br />0.00371 weeks <br />8.542225e-4 months <br /> Opersors noted indicanons of a 2.5
! spm Reacsor Coolant System (RCS) leak. The source could not be decennined, so at 0352 hours0.00407 days <br />0.0978 hours <br />5.820106e-4 weeks <br />1.33936e-4 months <br /> on Apnl 22, J power reducson began. At 20% FP Operators could not idennfy the leak as isolable, so the decuion was made to i go to cold shutdown. At 1443 hours0.0167 days <br />0.401 hours <br />0.00239 weeks <br />5.490615e-4 months <br />,the reactor was inpped by a planned tests. At 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br />, a NOUE (Notice !
of Unusual event) was decla ed when the leak exceeded 10 spm. The NOUE was terminated at 2032 hours0.0235 days <br />0.564 hours <br />0.00336 weeks <br />7.73176e-4 months <br /> after j the leak reduced below 10 gym. The leak was found to be a crack at the safe end to pipe weld on the High Pressure j Injection to RCS cold les nozzle near Reactor Coolant Pump 2A1. Le safe end and pipe were found to be cracked intsmally and the thermal sleeve was foimd to be loose and damaged. The failures were caused by thermal cychng fangue. The ruot causes were desemuned to be failure to implement an effecove HPI nozzle inspection program based on available indusny recommendations and failure to effecovely evaluate known problems and i
implement appropriate conocove actions. Conecove actions include repair of tin nozzle co6.iponents and estabhshing an effecove program to inspect and support nozzles. Evaluanon shows that the HP! line sull had a factor of safety greater than 2 tmder design basis event loads. Prompt shutdown prevented the development of an l tasafe condmon.
l l Other Browns Feny 97-001 Duplicate No Date Entered 10/22/9 Safety No l 8
Title:
Loss of Offsite power on Un 3 Dunng Refueling Outage Resulting From a Shorted Component On March 5.1997, a 1040 hours0.012 days <br />0.289 hours <br />0.00172 weeks <br />3.9572e-4 months <br /> Central Standani Tune,(CST) Unit 3 received engineered salery fesure system
! actuations due to a loss a'offsite power. The loss of power was the result of the loss of both the Athens and Tnmty 161 kV power hres. Emergency Diesel Genersors 3A 3C, and 3D automancally started and tied to their l respective shutdown bocnis. At 1122 hours0.013 days <br />0.312 hours <br />0.00186 weeks <br />4.26921e-4 months <br /> CST, BFN declared a Nonficanon of Unusual event (NUE) for Unit 3
- due to a loss of offsne power greater than 15 minutes and notified NRC in accordance with 10 CFR 50.72(a)(3).
l At 1136 hours0.0131 days <br />0.316 hours <br />0.00188 weeks <br />4.32248e-4 months <br /> CST, following the restoranon of the offsite power to Unit 3 BFN tenninated the NUE, and in acco, dance with 10 CFR 50.72(c)(1)(iii) notified NRC. The root cause of this event was the sensinvity of the l auxihary inpping relays. IVA has replaced the relays involved in the event with less sensinve relays. TVA is aarrently replacing other Wesonghouse AR rype relays in sondar apphcanons with less sensinve relays. T1us event is being reported accordance with 10 CFR 50.73(a)(2)(iv), as any event or condition that resulted in manual or automanc acsuanon of any engineered safety feanire ecluding the reactor protecnon system.
Other Conn. Yankee 97 013 Duplicate No i Date Entered 10/22/9 Safety No 3
l
Title:
Inadvenent Halon thscharge in Control Room Due to Camera Flash Results in Precaunonary Control Room
! Evacuation i
On Augur 7,1997, at approximately 0947 hours0.011 days <br />0.263 hours <br />0.00157 weeks <br />3.603335e-4 months <br />, with the plant in a permanently defueled condaion, the atrol l.
l room Halon system was inadvenently discharged wlule a training instructor was taking flash camera pwnues of the inside of a Halon control panel located in the control room. Because prolonged exposure to Halon, a cheutical used to exnnguish fires, can result in ria-a and dizziness, the control room and the adjacent secunty central alarm station were evacuated as a precautionary measure. Upon exiang the control room, operators continuously monitored the control board through windows in the viewing area located immediately outside the conuel room.
Opersors were not prevented from reentenng to perfonn amely actions if they had been regsared. The control l
room venalanon system was used to remove the Halon, the air was umpled and the control room reoccupied in
, approximately 45 trunutes. No personnel injunes were sustained. Subsequent testnig confirmed that the hght from j the camera flash affected a hght sensitive cucuit (EPROM) locased inside the Halon control panel which initised the acsuntion of the system without any tune delay. Conective acnon consuted of instalhng a protective cover
- over the EPROM wmdow and evaluating other systems that use EPROM cuants. His event was reponed as an Unusual event and is beuig documented as a voluntary LER.
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Emergency Preparedness input to the Commission Paper on NRC Performance Assessment.
1.0 Emergency Preparedness Corner Stone erei threshold oflicensee safetyperformance above which the NRC can allow licensees to
, aj:fres eaknesses with decreasedNRC action.
NRC Overall Safety Mission Ensure Public SIe a resun of civilian nuclear reactor operation h
Strategic Perfonnance. Area Reactor Safety w
Cornerstone- Emergency Pre ness Emergency Preparedness (EP) is the mal barrier in the defense in depth NRC regulations provide in ensuring the public health and safety while allowing operation of civilian nuclear reactors. In this way it is related to the Reactor Safetykrategic Performance Area.10 CFR Part 50.47 defines the requirements of an EP program.
i Measures taken to protect the public from the effects-one radiological emergency must necessarily involve action by governmental authorities in the vicinity of the reactor. Generally, the program, procedures and systems maintained to implement suchnovemmental actions are referred to as ofsite EP. The facets of the EP program that involve Feco@ ion of the accident, mitigation ofits affects, assessment of the offsite impact and communibation ofinformation to govemmental authorities, including protective action recommendationJdre generally referred to as onsite EP. The licensee is responsible for ensuring the development of both aspects of the program. but generally will turn over the offsite program to govemmental authorities for implementation and maintenance. Similarly, NRC is responsible for ensuring the adequacy of the total program, but has tumed over assessment of the offsite program to the Federal Emergency Management Agency (FEMA).
l l While both aspects are vitally important to ensuring the EP program can serve its intended function, the offsite portions of the program are maintained by govemmental authorities and the
! collection of data to support performance indicators (PI's) may not be appropriate. However, l regular assessments by FEMA of the efficacy of the offsite program do take place. The use of l these assessments can form the basis for reasonable assurance that the offsite aspects of the program are capable of taking adequate protective measures should they be necessary.
1
Compliance of EP programs with regulation is largely assessed thrcagh observation of response to simulated emergencies. Although routine inspection of onsite programs are currently conducted to ensure administrative aspects are functioning and FEMA requires an annual certification letter from governmental authorities for generally a similar purpose. However, demonstration exercises form the key observational tool currently used to support, on a continuing basis, the reasonable assurance that adequate protective measures can and will be njrt the event ofa radiological emergency. This is true for the most risk significant facets of th EP Iogram. This being the case, the PI's contemplated for onsite EP draw significantly ormance during simulated emergencies but are supplemented by licensee self
- ment and NRC inspection. Assessment of the adequacy of offsite EP will rely (as it does currently) on FEMA assessment of the biennial exercise and certifications from governmental authorities.
,h The dominatmg 3r Ys sigmficant aspects of the onsite EP program have been identified as:
A1
. Timelv and accurate classification of events; including the recognition of events as
- potentially exceeding emergency action levels (EALs), maintenance of the EAL scheme in an approved and appro . te configuration and any assessment actions necessary to support the classificatio
. Timely and accurate noti on of offsite governmental authorities; including the Vert 7
and Notification System ade5cy of communication channels and the direct intern 2 with offsite authorities;
- Timelv and accurate develooment and communication of protective action recommendations to offsite authorities; includ 'y accident assessment necessary to support the protective action recommendation lopment, the protection of emergency workers and direct interface with offsite auth ' s; and
. Emergency Resnonse Organization readiness; including adequacy of facilities, timely activation of the Emergency Response Organization (ERO), ade uate training of the ERO to ensure proficiency, efficacy of the corrective action progt t i entify and correct deficiencies in ERO proficiency and supporting equipment / faci'.i' ties.
Statement of Objective Ensure that the licensee capability is maintained to take adequate protective measures in the event of a radiological emergency Scope Onsite EP program is addressed by the proposed PI's and inspection elements.
Offsite EP program is addressed by FEMA related elements Desired Result / Performance Expectation 2
(
l
l=.
l.,'
Demonstration that a reasonable assurance exists that the licensee can effectively implement emergency plans to adequately protect the public health and safety in the event of a radiological l emergency.
2.0 Data Requirements I 21 nsite EP Program l i Tb ej required comes from the following sources:
l
- Licensee self assessment of drills and exercises l
. Lice assessment of the response to actual EP activation events l
- Lice 1- sessment of shift operating crew response to simulated emergency events j l Licenseehassessment of plant management recognition of events as contained in LERs .L.
=
Statistics on drill participation by emergency response organization (ERO) members Statistics on ERO duty rosters Statistics on ERO activati tests l Statistics on the conduct related critiques of actual events and training activities l '. Licensee self assessme o remainder of the EP program.
2.2 Offsite EP Program Results of assessments by FEMA of the biennial exch e annual state EP certification and the absence of FEMA withdrawal of program reasonal assurance.
.L.
l 3.0 Onsite EP Program 3.1 Clanification of Fmergencies F I d l Basis: Recognition and subsequent classification of events is artLsk significant activity of an EP program. It is assumed that classification will lead to activation of the ERO as appropriate to the emergency class and notification of governmental authorities. If an EP program consistently recognizes and classities simulated and L actual events in a timely and accurate manner, it indicates that the program is operating at or above the threshold oflicensee safetyperformance above which the NRC can allow licensees to address weaknesses with decreasedNRC action.
3.1.1 Numerical performance indicators:
A.
- Percent of timely and accurate classifications of simulated emergency events
=
) Number and type of opportunities for classification 1
1 3
i I _ _ _ . . _
(OR fraction, numerator and denominator, of timely and accurate classifications of simulated emergency events over number of opportunities)
Requirements: All activities that are formally critiqued for the timely and accurate classification of emergency class shall be included in this statistic. All simulated emergency events that are identified as opportunities for this PI shall be included in the statistics, i.e., a candidate opportunity can not be
] removed from the data set after actual performance, for instance due to j poor performance. This would include the biennial exercise, any other drills of appropriate scope and operating shift simulator evaluations conducted by the licensee training organization. The later element would
, only be appropriate when the evolution being evaluated is of such a k character as to require classification ifit were a real event. No mir:imum L is set for these observational opportunities, but a statistical analyses A rformed on the data will likely recognize that the more opportunities provided the more accurately the PI numerical value represents licensee performance. All critiques shall be conducted by an individual (s) that is
, qualified to dge the timeliness and accuracy of the classification perfonn e tatistical opportunities may include multiple events during a singlef , olution, etc., if supported by the scenario.
l B. . Percent of(operationally oriented?) LERs that should have been declared as emergency events, but were not. ,3 (Or fraction as discussed above) m Requirements: Recognition of actual plant events as warranting classification as an emergency or not, is a measure of the quality of EP training and its implementation. While the number of missed'dicIaFations is expected to be small, this indicator would reflect program q0lity. Review of these -
events by an individual (s) that is qualified to judge,the timeliness and accuracy of the classification performance is required to determine the
. statistics.
C, . Percentage of declared emergencies that were timely and accurate.
- Percentage of declared emergencies that were later found to be inappropriate (or retracted)
(Or fraction as given above) l.
Requirements: All declared emergency events must be formally critiqued for compliance with approved procedures, at least in the areas identified as risk '
significant. All statistics from these events must be reported. Review of 4
l l
- - .- - . - _ - _ - , .-. -.\
4 ,, -
i.
,~ these events by an individual (s) that is qualified to judge the timeliness and accuracy of the classification performance is required to determine the statistics.
1 3.1.2 ' Inspection Interface
- P d inspection areas that would be necessary to support these PI's include
l
- a erify that the collection of data is in compliance with the guidelines above.
. a.
Review the**efficacy of the self assessment program to gather valid statistics thought the accurat ue of successes and failures during classification opportunities.
H Review t begicacy of the corrective action program to correct identified deficiencies in the riskapuT4 ant areas.
Review control of the EAL set in an approved and validated configuration.
i.
1 Review self assessment events during the inspection period.
Review the scenarios used to evelop PI statistics to verify adequacy of challenge.
Review the licensee's self assessment progran
% relates to classification activities.
L -H Review of biennial exercise scenario for adeqt a.cy, a.-
i 3.2. Notification r j 1 Basis: Timely and accurate notification of offsite authorities is a risk significant activity of an EP program. It is assumed that notification will IM to activation of the 1
ERO as appropriate to the emergency class and mobilization of govemmental authorities. If an EP program consistently performs notifications during simulated
, and actual events in a timely and accurate manner, it indicates that the program is operating at or above the threshold oflicensee safetyperformance above which
, the NRC can allow licensees to address weaknesses with decreasedNRC action.
. 3.2.1 Numerical performance indicators:
A.
- Percent of timely and accurate notifications during simulated emergency events
- Number and type of opportunities for notification i
4 (OR fraction, numerator and denominator, of timely and accurate notifications during 1
5 i
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.- , .,,a - - r -., - - - - - -,
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simulated emergency events over number of opportunities)
Requirements: All activities that are formally critiqued for the timely and accurate performance of notifications to offsite authorities shall be included in this l statistic. All simulated emergency events that are identified as j opportunities for this PI shall be included in the statistics, i.e., a candidate
': opportunity can not be removed from the data set after actual performance,
- for instance due to poor performance. This would include the biennial
}
i exercise and any other drills of appropriate scope. Operating shift simulator evaluations conducted by the licensee training organization shall l be included in the statistic if notification is simulated as a part of the
, evaluation. Use of operating shift simulator evaluations would only be y appropriate when the evolution being evaluated is of such a character as to require classification of the event and subsequent performance of a L. tifications. No minimum is set for these observational opportunities, but a statistical analyses performed on the data will likely recognize that the more opportunities provided, the more accurately the PI numerical
, value repre " ts licensee performance. All critiques shall be conducted by an indivi 1 ) that is qualified tojudge the timeliness and accuracy of notificat' ns. tatistical opportunities may include multiple events during l a single 'll,i supported by the scenario. The opportunities for
! notification would include: initial emergency classification notification, upgrade of emergency class, nos Asation of PARS, notification of change in PARS and formal periodic u; of offsite authorities if required by procedures.
B.
- Percentage of timely and accurate notifications during declared emergencies.
(Or fraction as given above) r T l
Requirements: All declared emergency events must be formallygitiqued for compliance with approved procedures, at least in the areas identified as risk
, significant. All statistics from these events must be reported. Review of these events by an individual (s) that is qualified to judge the timeliness and accuracy of the notifications is required to determine the statistics.
C.
- Percent availability of Alert and Notification System Requirements: Statistical information gathered in support of system availability reports given to FEMA would form basis of this Pl. However, the reporting of availability is not standardized currently. It is proposed that the following rules be applied to gathering of this data:
= Failure of a siren is indicated by failure of any portion of the 6
0 -
l .
l system that would have prevented it fre 7 performing its safety j function, i.e., creating its design sound level and pattern.
l The period assumed for the failure would be half the time since the last successful test.
, Periodic testing is in accordance with FEMA guidance and actually i tests the ability of the siren to perfonn its intended safety function.
7
- A failure will be assumed to last at least one day (hour?).
l l
- HD l
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3 Inspection Interface
! Proposed ins areas that would be necessary to support these PI's include:
H
- Verify the collection of data is in compliance with the guidelines above.
.h.
Review the efficacy of the self assessment program to gather valid statistics thought the accurate critique of successes and failures during notification opportunities.
y .
- Review the efficacy of tive action program to correct identified deficiencies in l' the risk significant are l
Review the critique of actual events during the inspection period.
Review conduct of Alert and Notification siren T7 s l
guidance.
qtem for compliance with FEMA y
A Review licensee self assessment program as it relates to adequacy of communication i channel testing, communication system availability and timel correction of deficiencies.
l Review of the licensee self assessment program as it relates to u.equacy of direct O
l l interface with offsite authorities during exercises and drills tha.t_ igyolve offsite authority participation.
3.3 Protective Action Recommendation l Basis: The timely and accurate development of protective action recommendations l (PARS) is a risk significant activity of an EP program. It requires that several I supporting activities be performed including: accident assessment, quantification of radiological release magnitude, projection of the potential dose to the public t and communication to government authorities. It is assumed that communication j of PARS will lead to actions by governmental authorities to protect the public l
~
health and safety. If an EP program consistently develops and communicates PARS in a timely and accurate manner, it indicates that the program is operating at )
7
e or above the threshold oflicensee safetyperformance above which the NRC can allow licensees to address weaknesses with decreased NRC action.
3.3.1 Numerical performance indicators:
A = Percent of timely and accurate PARS during simulated emergency events q Number and type of opportunities for PAR development i
k
""g,OR l fraction, numerator and denominator, of timely and accurate notifications during simulated emergency events over number of opportunities)
Requirements:,, All activities that are formally critiqued for the timely and accurate 1
- development of PARS and communication to offsite authorities shall be included in this statistic. All simulated emergency events that are sa entified as opportunities for this PI shall be included in the statistics, i.e.,
a candidate opportunity can not be removed from the data set after actual performance, for instance due to poor performance. This would include l . the bienniagercise and any other drills of appropriate scope. Operating shift simulathgevaluations conducted by the licensee training organization l
shall be
- c u 4d in the statistic if PAR development is simulated as a part of the ev uats$. Use of operating shift simulator evaluations would only be appropriate when the evolution being evaluated is of such a character as to require classification of the d subsequent development of PARS. No minimum is set for observational opportunities, but a statistical analyses performed o data willlikely recognize that the more opportunities provided, ore accurately the PI numerical value represents licensee performance. All critiques shall be conducted by an individual (s) that is qualified to judge the timeliness and accuracy.of PAR development. Statistical opportunities may idcEIe'ihultiple events during a single drill, if supported in the scenario by circumstances that would require modification of the initial PAR. A 3.3.2 Inspection interface Proposed inspection areas that would be necessary to support these PI's include:
= Verify that the collection of data is in compliance with the guidelines above.
= Review the efficacy of the self assessment program to gather valid statistics thought the accurate critique of successes and failures during PAR development opportunities.
- Review the efficacy of the corrective action program to correct identified deficiencies in the risk significant areas.
8
l., -
Review of the licensee self assessment program as it relates to adequacy of direct interface with offsite authorities during exercises and drills that involve offsite authority participation, in the area of PAR communication..
Review of the licensee self assessment program as it relates to adequacy of worker protection during exercises and drills.
7
- . view of exercise scenarios to ensure they provide and appropriate challenge.
i D Emercency Resoonse Organintion Readiness Basis: grams ensure the readiness oflicensee personnel, facilities and equipment to s rt response to emergency situations and protect the public health and sW The previous PI's indicate the performance of segments of the ERO in risk. cant activities during simulated and actual emergency situations.
However, this PI is meant to indicate the readiness of the total ERO to perform as an integrated organization. Here are several supporting activities important to
, ERO readiness in ing: ERO activation tests, ERO training and drills, facility and equipment r ss checks, communications channels tests, the licensee corrective actio pro , licensee self assessment program, management support, effect E unplementation by licensed operators, severe accident management guide implementation and ERO ability to diagnose plant accident conditions, formulate mitigating actions % implement them under accident conditions.
If an EP program consistently ensurev hat the ERO is in a high state of readiness it indicates that the program is operating at or above the threshold officensee safetyperformance above which the NRC can allow licensees to address weaknesses with decreasedNRC action. (B1 3.4.1 Numerical perfo mance indicators: i A
- Percent of ERO that bu participated in a drill or exercise in the past 24 months.
Requirements: The ERO participation indicated is that of the essential positions committed to in the Emergency Plan. Plant workers, security personnel, operations shift staff and others that are on shift or may be called in to support the emergency but do not fill positions on EP duty rosters are not intended to be captured in this Pl. Positions that are formally on the EP duty roster, but not committed to in the Emergency Plan may be included, j but only if this is done completely and consistently. Participation could be l
either as a drill / exercise participant or as an evaluator (but not as an l observer). Signature on a drill / exercise attendance fonn would be 9
i
L a
i adequate documentation, but the hdent is that the participation be a meaningful and thorough opportmdty to gain proficiency in the assigned j
position.
j Pa<cipation in the biennial exercise and any other drills of appropriate scope may be used in statistics, but table top drills that do not provide i
' meaningful interaction with interfacing ERFs would not be appropriate.
l ;] Multiple assignees to a given ERO poshion could take credit for the same
{ j drill / exercise if their participation is a meaningful and thorough j -
" Q' opportunity to gain proficiency in the assigned position.
t of operating shift crew that have participated in a drill, exercise or B.
- E ehlu d simulator evolution in the past 12 months.
L <
I Requirements:s - valuated simulator evolutions contribute to statistics for several PI's.
This PI only indicates the training opportunities provided to operating shift crews and not their success during those opportunities. It assumes that the training wi ontribute to proficiency and overall ERO readiness. It may be expected t any evaluated evolution would be given to all shifts. That being th['cas e statistic could be in excess of 100%, e.g., if all shifts had taken 2 ev uated evolutiens in the past year the PI would be 200%.
Evaluated evolutions are those simulator based evaluations that provide a scenario that includes emergeng nt classification and notification of offsite authorities, are formally lc ' ued by a qualified individual and are included in the PI's for classificati of emergencies and notifications.
.L.
C.
- Percentage of essential ERO positions that successfully responded in each of the last 4 pager tests.
r , 1 Requirements: Pager tests indicate the readiness of the ERO to till duty roster positions during emergencies that take place during off-n_onnal hours. Only statistics from tests during off-normal hours may be included. The results of all such tests shall be included, i.e., a test may not be removed from the data set due to poor performance. The frequency tests may be set or changed at licensee discretion, but results from the last four must be included in the Pl. Successful response means that it could reasonably be expected that the position would have been filled within the time goal expected in the Emergency Plan. A position is filled by one qualified individual. Multiple individuals filling a single position can not be used to improve the statistics.
3.4.2 Inspection interface
. 10
= - _ _ _ _ . -. .__ - . ____ _ ______ __
t*
l .
Proposed inspection areas that would be necessary to support these PI's include:
Verify that the collection of data is in compliance with the guidelines above.
l
- Review the efficacy of the self assessment program to gather valid statistics thought the accurate critique ofpager test successes and failures.
view the etTicacy of the corrective action program to correct identified deficiencies in l Q5hO, facility and equipment readiness.
Review of the licensee celf assessment program as it relates to adequacy of facility and equipm eadiness checks, communications channels tests, the licensee corrective action progt management support, effective EOP implementation by licensed i
operator Iver,eg accident management guide implementation and ERO ability to diagnow lilanbcident conditions, formulate mitigating actions and implement them under accident conditions.
I
! 4.0 Offsite EP Program TBP, but "'11 be based on: ,
1 FEMA evaluation of the biennial exercise hav o more than 3 deficiencies ;
l FEMA acceptance of the annual state certificeien of preparedness The absence of FEMA withdrawal of reasonable assurance r - 1 l '
t and w hue e
I 5
11
e
.e, . . .
Lynnette Hendricks RAT m OfVis m October 23,1998 Rules Docket Clerk Office of General Counsel Federal Emergency Management Agency Room 840 500 C Street SW Washington, DC 20472
SUBJECT:
" Publication of Radiological Emergency Preparedness (REP)
Program Strategic Review Draft Final Recommendations" (63 End. Beg. 48222, September 9,1998)
The Nuclear Energy Institute (NEI),* on behalf of the nuclear energy industry, has reviewed the " Publication of Radiological Emergency Preparedness (REP)
Program Strategic Review Draft Final Recommendations,"(63 End. Reg.48222, September 9,1998). The industry strongly supports the FEMA reform initiative to improve efficiency and cost effectiveness. Specific comments regarding the Strategic Review are enclosed.
In addition to the specific comments provided on FEMA's Strategic Review, industry believes initiatives underway at NRC, as presented at the NRC Performance Assessment Workshop September 28-October 1,1998, provide more insight for FEMA's regulatory reform initiative. Representatives from FEMA were in attendance at the workshop. The NRC periormance assessment workshop focused on a new paradigm of risk informed performanced based regulatory
- NEI is the organizstion responsible for establishing unified nuclear industry policy on matters alTecting the nuclear energy industry, including the regulatory aspects ofgeneric operational and j_ technient issues. NErs members include all utilities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect / engineering firms, fuel fabrication facilities, materials licensees, and other organizations and individuals involved in the nuclear energy f/>lustry.
l<
Rnles and Docket Clerk October 23,1998 Page 2 oversight. The benefit of a risk-informed oversight approach is the ability to focus resources on areas important to safety. The NEI White Paper describing this process "A New Regulatory Oversight Process," is enclosed.
The workshop included a breakout session on Emergency Preparedness. The goal of this breakout session was to focus on the safety significant onsite performance indicators that address the objective of insuring that licensee capability is maintained to take adequate protective measures in the event of a radiological emergency. Information was identified at the breakout session which can be used to adequately assess licensee onsite performance.
The ensite Emergency Preparedness Performance Indicators are based on the following inputs from actual events and exercises: Emergency Classi6 cation (event recognition, emergency action levels, and accident assessment), Notification (alert and notification, adequate communication channels, and direct iaterface to offsite organizations), Protective Action Recommendations (accident assessment, protection of emergency workers, and direct interface with offsite agencies), and Emergency Response Organization Readiness, (adequacy of facilities, and activation of the Emergency Response Organization). The industry and the NRC are working to develop threshold reporting levels. Once this has been accomplished j NRC inspection procedures will be revised to reflect these changes.
The scope of the NRC workshop was limited to onsite emergency plans; offsite emergency plans were not addressed but are believed to be bound by FEMA's Finding of Reasonable Assurance. The industry encourages FEMA to review this approach as a basis for assessing performance for offsite emergency planning.
The industry's gous is to help achieve comprehensive change in the regulatory process so that the industry can most effectively carry out our mutual responsibilities for public protection.
NEI appreciates the opportunity to comment on this notice and stands ready to meet with you to discuss any of the recommendations presented. Please contact Alan Nelson at (202) 739-8110 or by e-mail (apn@nei.org) with any questions on this response.
Sincerely, Lynnette Hendricks Enclosure
Enclosure Specific Comments Radiological Emergency Preparedness (REP) Strategic Review Draft Final Recommendations (63 Fed. R_eg. 48222, September 9,1998)
Recommendation 1: Streamline the REP Program
- a. This set of recommendations is commendable because it de-emphasizes FEMA's reliance on biennial exercises to confirm reasonable assurance finding and places equal reliance on self-reporting and FEMA technical assistance.
- b. Industry recommends consolidation of the current FEMA-REP-14 and 15 exercise objectives into the six programmatic areas identified in the draft final recommendation 1.1. The industry also supports elimination of Objectives 23,31,32, and 33.
- c. Comments:
- 1. Recommendation 1.1, consolidation of exercise objectives, does not say what guidance will replace the prescriptive and detailed FEMA-REP-14 and 15 exercise evaluation criteria. The recommendation should address the desired outcomes versus compliance with evaluation criteria.
- 2. The "no notice", FEMA initiated, once in six years demonstration af the prompt alert notification system for a fast breaking scenario would impose a new REP requirement. It is a novel proposalin that no other exercise activity has ever involved a FEMA initiated event without notice to any of the parties. There is no NUREG 0654 or other '
program criteria or requirement driving this activity. The industry opposes this initiative and recommends its removal from the fmal strategic review recommendations. Industry questions the practicality of such a demonstration, i.e., simulated activation of the public alert system and simulated broadcast of an EAS message with protective action recommendations within 15 minutes of FEMA contacting a primary warning point. This recommendation is wholly inconsistent with Recommendation 1.7, i.e., scenario realism.
l 3. Recommendation 1.7, should also allow flexibility in the severity of i conditions to include scenarios that stop short of offsite radiological consequences.
4
,e i
, . >=
l l
- 4. Recommendation 1.9 states annual letters of certification should be submitted to support program changes. This recommendation requires l clarification. Does this recommendation mean that states will be ,
asked to assess the impact of any program changes on the effectiveness !
of their plans?
i
- 5. Recommendation 1.13, consolidation of REP guidance, is very l important. Appendix 1 catalogues a myriad of REP series documents, guidance memoranda, policy statements, etc. The recommendation proposes to consolidate these materials into a single REP Program Handbook. The recommendation should state that a primary purpose of this initiative will be to focus REP guidance on expected results and to make it less prescriptive.
Recommendation 2: Increase Federal Participation in Exercises No comments.
Recommendation 3: Use State, Tribal and Local Exercise Evaluators
- a. The industry strongly supports this recommendation. This recommendation should have two specific goals: 1) decreased reliance on contractor personnel to evaluate exercises, and 2) increased opportunities for state and local emergency management personnel to perform structured self-assessments of their programs.
The latter gcal is not entirely consistent with the proposed caveat that state, tribal and local evaluators cannot evaluate exercise performance within their own jurisdictions.
Ti~
- b. FEMA should consider expanding the availability of exercise evaluatien j training for state, tribal and local personnel through the regional offices to support Recommendation 5 - Enhance the REP Training Program.
Recommendation 4: Include Native American Tribal Nations in the REP Preparedness Process No comments Recommendation 5: Enhance the REP Training Program No comments
^
Nuclear Energy Institute Project No. 689 cc: Mr. Ralph Beedle Ms. Lynnette Hendricks, Director Senior Vice President Plant Support and Chief Nuclear Officer Nuclear Energy Institute Nuclear Energy Institute Suite 400 Suite 400 1776 i Street, NW 1776 i Street, NW Washington, DC 20006-3708 Washington, DC 20006-3708 Mr. Alex Marion, Director Mr. Charles B. Brinkman, Director Programs Washington Operations Nuclear Energy institute ABB-Combustion Engineering. Inc.
Suite 400 12300 Twinbrook Parkway, Suite 330 8 - 1776 i Street, NW Rockville, Maryland 20852 i Washington, DC 20008-3708 Mr. David Modeen, Director !
Engineering >
Nuclear Energy Institute -
1 Suite 400 1776 i Street, NW Washington, DC 20006-3708 Mr. Anthony Pietrangelo, Director Licensing Nuclear Energy Institute Suite 400 1776 i Street, NW Washington, DC 20006-3708 Mr. Nich7las J. Liparuto, Manager Nuclear Safety and Regulatory Activities Nuclear and Advanced Technology Division Westinghouse Electric Corporation P.O. Box 355 Pittsburgh, Pennsylvania 15230 Mr. Jim Davis, Director ;
Operations Nuclear Energy Institute Suite 400 1776 i Street, NW
' Washington, DC 20006-3708 e
j i
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