ML20206K592
| ML20206K592 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 11/14/1988 |
| From: | Everett R, Terc N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20206K589 | List: |
| References | |
| 50-298-88-29, NUDOCS 8811290460 | |
| Download: ML20206K592 (9) | |
See also: IR 05000298/1988029
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APPENDIX
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report :
50-298/88-29
Operating License: DPR-46
Docket:
50-298
Licensee:
Nebraska Public Power District (NPPD)
Facility Name:
Cooper Nuclear Station (C'IS)
Inspection At:
Inspection Conducted:
October 17-20, 1988
Inspector:
C.x
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N. M. Terc, Emergency Preparedness Analy t
Date
(NRC Team Leader)
Accompanying
Personnel:
R. A. Caldwell, Security Specialist, NRC, Region IV
R. Wise, Radiation Specialist, NRC, Region IV
D. H. Schultz, Comex Corporation
G. R. Bryan, Comex Corporation
Approved:
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.h VI
Il[/Y[N
k. J. Everott, Chief, Security and Emergency
Date '
Preparedness Section
Inspection Summary
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Inspection Conducted October 17-20,1988 (Report 50-298/88-29)
Areas Inspe_cted: Routine, announced inspection of the licensee's performance
and capabiTities during an annual exercise of the emergency plan and
procedures.
Results: Within the areas inspected, no violations or deviations were
identified.
Eleven deficiencies were identified by the NRC inspector
(paragraphs 3-11).
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DETAILS
1.
Persons Contacted
- H. Parris, Vice President, Production
- L. Kuncl, Nuclear Power Group Manager
- G. Horn, Division Manager, Nuclear operations
"R. Hayden, Emergency Preparedness Coordinator
- M. Krumland, Emergency Preparedness Supervisor
- D. Whitman, Program Control Manager
- V. Wolste.tholm, Division Manager, Quality Assurance
- R. Wilbur, Division Manager, Nuclear Engineering and Construction
- T. Chard, Health Physics Supervisor
- E. Mace, Senior Manager Technical Support
- J. Flaherty, Manager, Engineering
- G. Smith, Manager, Quality Assurance
- G. Smith, Licensing Supervisor
- D. Norvell, Manager, Maintenance
- R. Brungardt, Manager, Operations
NRC
- W. Bennett, Senior Resident Inspector (CNS)
- G. Pick, Resident Inspectar (CNS)
- Denotes those present at the exit interview.
The NRC inspector also held discussions with other station and corporate
personnel in the areas of security, health physics, operations, traini.19,
and emergency response.
2.
Followup on Previous Inspection Findings (92702)
(Closed) Deficiency (208/8725-01):
Delay in Nocifications - The NRC
inspector noted that during the 1988 exercise, the Notification of Unusual
Event (NOVE) and Alert notifications were p',rformed from the Control
Room (CR) in a timely rnanner.
(Closed) Deficiency (298/8725-02):
Inadeqtati, Information Flow - This
deficiency was repeated during this exercist.
The NRC inspector opened a
new item (298/8829-05).
See paragraph 4 below.
(Closed) Deficiency (298/8725-03):
Inadequate Personnel Proficiency -
This deficiency was repeated during this exercise.
The NRC insrector
opened new items:
(298/8829-01),(298/8829-02),(298/8829-03),
(298/8829-04), (298/8829-06), (299 '8829-08), and (298/8829-09).
See
paragraphs 4, 5, and 6.
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(Closed) Daficiency (298/8725-04):
Inadequate Emergency Action
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Level (EAL) - The NRC inspector noted that EPIP 5.7.1, "Classification
Guide," had been revised.
EAL 2.6 is now consistent with the guidance of
NUREG 0654, Appendix 1.
(Closed) Deficiency (298/872;-05): Deficient Technical Support
Center (TSC) Status Boards - The NRC inspector noted that during the 1988
exercise, status boards were maintained up-to-date, and parameter trends
for critical systems were displayed.
3.
Program Areas Inspected
The NRC inspector observed licensee activities in the CR, TSC, Operations
Support Center (OSC), and Emergency Operations Facility (EOF) during the
exercise.
The NRC inspector also observed emergency response organization
staffing; facility activation; detection, classification, and operational
assessment; notifications of licensee personnel; notifications of offsite
agencies; formulation of protective action recommendations; off site dose
assessment; in plant corrective actions and resc'Je; s9curity/
accountability activities; and recovery operations.
4.
Control Room (82301[1]]
The CR staff did not maintain adequate records according to
Procedure 2.0.2, "Operations Logs and Reports." As a consequence, the CR
staff did not list information that would allow for the future
reconstruction of accident events.
This is a deficiency (298/8829-01).
The Shif t Technical Advisor (STA) and the Reactor Operator (RO) were
assigned (or assumed) duties that prevented them from carrying out their
primary responsibilities as follows:
At 8:15 a.m. the STA started to perform a detailed analysis of Piping
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and Instrumentation Diagrams to determine the source of the primary
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leak.
Not until after 8:30 a.m. did he return to assume his
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responsibilities as specified by Procedure CNS 0.21, "Shift Technical
Advisor," such as independently sssessing plant conditions and
making objective evaluations concerning plant safety.
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From 8:00 a.m. to 8:45 a.m.,
instead of carrying out his primary
responsibilities, the RO was assigned to a back panel in the
CR to monitor the sump pump integrator in order to n.ake leak rate
determinations.
This assignment had to be terminated by the exercita
controller anticipating the numerous operational data status messages
that were due at 9:00 a.m.
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The above is a deficiency (293/8829-02).
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The TSC staff initiated major hazardous repair activities without the
knowledge and cc.icurrence of the CR staff and without initiating proper
tag-out of equipment.
This was in violation of Conduct of Operations
Procedure 0.9, "Equipment Clearance and Release." This procedure
establishes the requirements for, and methods of, maintaining personnel
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and plant safety. The following two violations of procedure were
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observed:
A repair team worked from 9:15 a.m. to 11:55 a.m. to restore the
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4160 volt bus IF.
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Another repair team worked to install power leads from the 480 volt
bus.
This occurred from 9:15 a.m. to 11:25 a.m.
In the above instances, the CR staff was not advised that the teams had
been dispatched, and clearance for either effort was not initiated. As a
result, the emergency workers were at risk of being electrocuted.
The above is a deficiency (298/8829-0's).
Temporary modifications to plant electrical wiring ',tre performed or
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attempted without adherence to Conduct of Operations Procedure 2.0.7,
"Plant Temporary Modifications Control." For example, at 10:23 a.m.,
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engineers arrived in the CR seeking permission to install wiring jumpers
that would defeat the interlocks associated with the traveling in-core
probes. At the time of this attempt, there was no indication that
any authorization had been given, nor that any preparation had taken place
in accordance to the aforementioned procedure.
In this case, the
controller intervened and prevented them carrying out the activities
until procedures were followed.
This is a deficiency (298/8829-04).
Numerous instances of inadequate information flow was noted between the CR
and other emergency response facilities. As a consequence, the efficiency
of the licensee in responding to the emergency events was significantly
reduced.
E/amples are as follow:
Repair activities at 9:15 a.m. to replace the 4120 volt bus bar, and
the discussions of the conditions that required its replarament were
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not discussed between the TSC and the CR.
The TSC staff did not inform the CR staff about the repair activities
to install the power leads between the 4800 1G and 1F buses.
After 9:00 a.m., the TSC staff made several requests to the CR staff to
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determine the leak rate from the primary system apparently not aware
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that at 9:00 a.m. a Primary Containment Isolation Signal (PCIS) had
taken place,
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The EOF staff directed CR operators to inject water into the reactor
vessel unaware that the CR staff was maintaining a 'ow reactor water
level to minimize reactor power and the amount of heat injected to
the torus. This directive from the E0F was contrary to Emergency
Operating Procedure (EOP) E0P-1, "Level Power Control ." This request
by the EOF is symptomatic of poor information exchange between the
emergency managers and the CR operators.
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At 12:29 p.m. the EOF diracted the CR staff to start a Control Rod
Drive (CRD) pump to drive the control rods in place.
This was not
possible at that time due to the valve line-up.
This showed lack of
information exchange between the cecision-makers and the operators.
At 12:32 p.m. the CR staff was directed by the TSC or E0F staff not
to increase the water level above the feed-water spargers (i.e. ,
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-37 inches). At that time, however, the water level was already at
the level specified by the E0Ps (+15 to +55 inches).
Apparently,
decision-makers were not well informed of the status of the plant.
From 9:00 a.m. to 9:05 a.m., the TSC staff had no awareness that an
Anticipated Transient Without Scram (ATWS) was in progress.
In
addition, there was an eight minute delay in the CR staff informing
TSC managament o/ results of scram discharge volume repair-team
efforts, These were significant changes in plant status, and
corrective actions should have been immediately communicated to the
TSC staff.
From 12:00 p.m. to 12:13 p.m.,
the CR staff did not report the
termination of the release of radioactivity to the environment to the
TSC staff.
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The TSC staff was not informed about the whereabouts of Station
Operators (50s) causing a delay of repair / corrective actions (see
paragraph 5.b below).
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At 12:07 p.m., the TSC status board showed that a release of radio-
activity to the environment was still in progress indicating that the
TSC staff was lagging behind in awareness of important changing
emergency conditions since the release had terminated at 12:00 p.m.
The above is a repeat deficiency (298/8829-05).
On several occasions, the NRC inspector noted that the CR staff did not
implement Emergency Procedures (EPs) or Emergency Operating
Procedures (EOPs) in .4 timely manner and did not adhere closely to them.
As a consequence, degradation of equipment occurred which increased the
severity of the accident.
For example, at 9:15 a.m., the 4160 volt bus IF
was supposed to be partially destroyed. As a reaction to this event, at
9:28 a.m.,
the CR supervisor briefly referred to EP 5.2.5, "Loss of AC
Power-Use of $tandby Power," but did not implement any operator actions
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demanded by the procedure.
In addition, the CR staff did not implement
procedures necessar.y to respond to the loss of AC power such as Abnormal
Procedures 2.4.6.5, "4160 Volt Switch-Gear Failure," anJ 2.4.6.14, "Loss of
AC Power to Security System."
Implementation of these procedures would
have allowed emergency feeders to restore power.
Another example of the CR staff failing to implement procedures occurred
at 9:00 a.m. in response to the scram.
On this occasion, the CR staff
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began implementing Procedure E0P-1, "Reactor Pressure Vessel Control," at
9:02 a.m.
The required concurrent activities instructed the user to
inject boron using Procedure EP-5.2.14 when the O'.andby Liquid Control
System was unavailable for boron injection. Ti.;s action was not
considered by the CR operators until 10:11 a.m.
Furthermore, the CR
staff did not implement any of the steps for inserting controirods.
The above is a deficiency (298/8829-06).
No violations or deviations were identified.
5.
Technical Support Center (8230l[2])
The NRC inspector noted that the EAL 7.2.2 of Procedure EDIP 5.7.1,
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"Emergency Classification," is deficient and inconsistet.t with E0Ps.
This
EAL does not properly classify an ATWS with partial controired insertion,
a power decrease, and continued heat generation.
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This is a deficiency (298/8829-07).
The TSC staff was not aware of the location of 50s during emergency
conditions.
Furthermore, the NRC inspector noted that relevant
implementing procedures did not specify 50s location during emergencies.
This delayed the formation of the repair team whose objective v:ns to
determine the scram discharge volume.
This is a deficiency (298/8829 08).
Notifiers and notification procedures were deficient as follows:
In The Control Room
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At least twice during the period 7:25 a.m. to 7:39 a.m.,
and
prior to the NOVE, the Plant Manager directed the Shift
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Supervisor (SS) to "Notify the Commission." Since the report
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format and the reason for the notification were neither clearly
specified, nor apparent to the SS, he appeared puzzled and
distracted from his other emergency duties.
Apparently the SS
was not aware of the need to perform this notification.
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In The Technical Support Center
The communicator did not record notifications on Attachments C
and E of EPIP 5.7.6, "Notification."
The Emergency Director (ED) did not record the date, time, and
initial classification on the initial report form (Attachment A)
of the above procedure, for both, NOVE and Site Area
Emergency (SAE).
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The TSC communicator erroneously decided to notify the States
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and local authorities about the ALERT classification when at
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that time notifications were made from the CR (this i' another
example of poor information flow between the CR ani cae TSC
staffs).
See paragraph 4.
The TSC notification forms for ALERT and SAE were not reviewed
and approved (signed) by the ED before notifications were made.
The TSC comsunicator made entries on data sections of the
notification forms after the communications had been made (e.g.,
during the SAE notification, the type of release was not
recorded until after the States and local notifications had been
completed).
Apparently, the licensee has agreed to provide direct
notification to Atchison County in Missouri.
This requirement
is not documented in the notification procedure.
The above is a deficiency (298/8829-09).
No violations or deviations were identified.
6.
Emergency Operations Facility (82301[3])
The information flow within the EOF was deficient in that the ED did not
inform the EOF communicator about protective actions recommended to the
State and local governments.
Briefings to the EOF staff were not adequate in that the ED did not inform
the staff about Protective Action Recommendations (PARS) taken, and
whetner these had been implemented.
In addition, staff briefings were not
sufficiently timely to keep up with the changing status of significant
em:'rgency events (e.g., protective action recommendations and their
implementation by state and local agencies).
The NRC inspector noted that
Procedure EPIP 5.7.9, "Activation of the EOF," does not provide guidance
for the ED to pe iodically update his staff on current emergency events.
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The briefings given to the state officials pertaining to the choice and
scope of the PARS were unclear.
The wind direction was not clearly
specified, and the areas affected were not graphically displayed.
See Deficiency 298/8829-05.
No violations or deviations were identified.
7.
Scenario
The NRC inspector noted significant technical inaccuracies and
incongruities in the exercise scenario. These detracted from tne realism
and free play of the exercise and resulted in confusion to the CR
operators.
Technical flaws in the scenario, not being representative of
actual plant response, minimized the training cenefits that normally are
derived from an emergency exercise.
In addition, the NRC inspectcr noted
that previous exercises were similar to the present 1988 exercise in that
they involved a ATWS.
Some examples of scenario inadequacies follow:
At 8 a.m., CR operators corrr etly decided to initiate a rapic; plant
shutdown due to the detection of a large leak in the primary system.
However, the scenario required them to maintain a high power level
until 9:00 a.m.
At 7:15 a.m., the scenario presented a 10 degree Fahrenheit increase
of temperature in the torus during a short High Pressure Coolant
Injection system test run. On the other hand, an hour long
heat reject to the torus resulting from a 25 percent power ATWS
(according to the scenario) only increased the temperature 25 degrees
Fahrenheit.
The NRC inspector made rough calculations and concluded
that instead the temperature of the torus would have increased to
212 degrees Fahrenheit.
The scenario included a loss of AC power at 9:15 a m. that prevented
the CR operators from establishing any containment vent path by
preventing activation of the valves in the desired patt.
The CR
operators recognized the los; of power at 11:1) a.il. and confronted
the exercise cor. troller in the CR.
The controller instructed them to
disregard the unavailability of AC pcwer, and to assume that the
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desired vent path had been established.
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The above is a deficiency (298/8829-10).
No violations of deviations were identified.
8.
Licensee's Self-Critique
The NRC inspector attended the post-exercise formal critique by the
licensee staff on October 19, 1988, to evaluate the licensee's
identification of deficiencies and weaknesses as required by
10 CFR 50.54(q),10 CFR 50.47(b)(14), and Appendix E, paragraph IV.F.5.
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The licensee briefly described 17 findings by their contro,lers and
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observers which they characterized as "comr* nts."
Dis.ussions with the
licensee regarding their "comments" characterization indicated that the
licensee had an incomplete understanding of the term "deficiency" as used
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in 10 CFR 50.47(b)(14), and Appendix E. Part TV.F.5 of the same. The
licensee eventually oaracterized some of their "comments" as weaknesses
which corresponded to the intent of 10 CFR 50.
Items characterized by the licensee as weaknesses were:
"The TSC initiated (simulated) plant work and evolutions without
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informing the CR or obtaining necessary documentation (no clearance
orders were obtained, the jumper log or temporary modifications log
were not used, permission was not obtained from the SS to perform
work.)"
"The procedure for the Adam model needs to be finalized."
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"The TRS 80 procedure needs to be updated."
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"Communications equipm6nt used to transmit hard-copy offsite is old
and inadequate.
The equipment needs to be upgraded. A computerized
system should be evaluated."
The Following Areas Were Not Observed By NRC Inspectors
"FAX equipment at the General Office Emergency Center (GOEC) in
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Columbus, Necraska, did not always function properly."
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"The paging system does not work in the inner recesses of the General
Office Building in Columbus, Nebraska."
"FAX equipment did not always function properly at the Media Response
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Center (MRC).'
Based on the above, the licensee identified fou* weaknesses 09-site.
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one item identified by the licensee adequately descrnri
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a significant weakness in-plant, and corresponded tr
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identified deficiency. When compared with the numbs *
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deficiencies identified by the NRC team, the NRC insova
....cluded that
the licensee's critique was inadequate.
The above is a deficiency (298/8829-11),
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No violations or deviations were identified.
9.
Exit laterview
The NRC inspector met with the NRC resident inspector and licensee
representatives indicated in paragraph 1 on October 20, 1988, and
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su'marized the scope and findings o' the inspection as presented in this
report.
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