ML20207R748
| ML20207R748 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 02/26/1987 |
| From: | Terc N, Yandell L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20207R737 | List: |
| References | |
| 50-313-87-04, 50-313-87-4, 50-368-87-04, 50-368-87-4, NUDOCS 8703180091 | |
| Download: ML20207R748 (9) | |
See also: IR 05000313/1987004
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APPENDIX
U.S. NUCLEAR REGULATORY COMMISSION
4
REGION IV
NRC Inspection Report:
50-313/87-04
Licenses:
50-368/87-04
-Dockets:
50-313
50-368
Licensee: Arkansas Power & Light Company (AP&L)
P. O. Box 551
Little Rock, Arkansas
72203
Facility Name:
Arkansas Nuclear 0ne (ANO), Units 1 and 2
Inspection At:
Russellville, Arkansas
Inspection Conducted:
January 11-16, 1987
Inspector:
%dN_l
M k M TQ;L
3!dd h 7
NTM.~Terc, Emergency Preparedness Analyst
Ddte
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Emergency Preparedny s and Safeguards
Programs Section
' Accompanying
Personnel:
David H. Schultz, Comex Corporation
Approved:
GAAk
8!BS 9 7
L. A. Yandell, Chief, Emergency Preparedness
Date
and Safeguards Programs Section
Inspection Summary
Inspection Conducted January 11-16, 1987 (Report 50-313/87-04; 50-368/87-04)
Areas Inspected:
Routine, unannounced inspection of emergency detection,
classification, and protective action decisionmaking.
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Results: Within the areas inspected, no violations or deviations were
identified.
One deficiency was identified (emergency detection,
classification, and protective action decisionmaking, paragraph 3).
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DETAILS
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1.
Persons Contacted
- J. Levine, Director, Site Nuclear Operations
- P. Campbell, Plant Licensing Engineer
- D..Lomax,. Plant Licensing Engineer
- E. Ewing, General Manager, Plant Support
- T. Baker, Technical Support Manager
- D. Howard, Special Projects Manager
- D. Snellings, Nuclear Projects Manager
- M. Tull, Corporate Emergency Preparedness Coordinator
- D. Boyd, Site Emergency Preparedness Coordinator
- F. Van Buskirk, Site Emergency Preparedness Coordinator
- B. Baker, Operations Manager
W. McKelvy, Assistant Radiochemistry Supervisor
R. Gillespie, Technical Analysis Superintendent
D. Binkley, Emergency Plan Trainer
E. Bickel, Health Physics Superintendent
D. Bullington, Computer Support Superintendent
M. Frala, Assistant Radiochemistry Supervisor
C. Reed, Shift Operating Supervisor
D. Millar, Shift Administrative Assistant
G. Randall, Shift Operations Supervisor
R. dallard, Shift Administrative Assistant
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T. Voss, Shift Operations Supervisor
S. Kaufman, Shift Administrative Assistant
M. Harris, Shift Operations Supervisor
E. Neal, Shift Administrative Assistant
S. Quennoz, General Manager, Plant Operations
Other Persons Interviewed
J. Meyer, Manager, Arkansas Department of Health, Nuclear Planning and
Response Program
NRC
- W. Johnson, Senior Resident Inspector
C. Harbuck, Resident Inspector
- Denotes those present during exit interview.
2.
Licensee Action on Items Identified in Previous Inspections
(0 pen) Deficiency (313/8612-03; 368/8612-03).
The NRC inspector
determined that the ability of the various Operations Support Centers to
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efficientlycoordinaterecoveryandreentryactivitieswoufdbebest
ascertained during the coming 1987 exercise.
(0 pen) Violation (313/8604-01; 368/8604-01).
The NRC inspector 'noted that
the licensee had committed to finalize corrective actions by March 1,
1987, and that progress was being made to that effect.
(0 pen) Violation (313/8604-02; 368/8504-02).
The NRC inspector noted that
the licensee had committed to finalize corrective actions by March 1,
1987, and that progress was being made to that effect.
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(0 pen) Deficiency (313/8511-05; 368/8511-05).
The NRC inspector
determined that a design package had been approved and was being installed
in order to maintain positive pressure on the habitable portion of the
Emergency Operations Facility (E0F).
This work is scheduled to be complete
by March 1, 1987.
(Closed) Deviation (313/8520-01; 368/8521-01).
The NRC inspector verified
that Letters of Agreement were updated and that a computer method of
tracking commitments has been implemented since July 1985.
(Closed) Deficiency (313/8612-01; 368/8612-01).
The NRC inspector noted
that paragraph 7.1 in Emergency Preparedness Implementing
Procedde(EPIP) 1905.001, " Emergency Radiological Control," was changed
to establish control points.
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(Closed) Deficiency (313/8612-04; 368/8612-04).
The NRC inspector noted
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that new method to maintain personnel accountability in the Emergency
Response Facilities was documented in EPIP-1903.30, " Evacuation,"
Para 0raph 8.0.
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(Closed) Open Item (313/8502-05; 368/8502-05).
The NRC inspector
determined that paragraph 6.4 of TAP-1063.21, " Emergency Response Training
Program," was changed to be compatible with the emergency plan.
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(Closed) Open Item (313/8510-01; 368/8510-01).
The NRC inspector noted
that EPIP-1903.50, " Emergency Response Organization," was revised to
relieve the operator from other duties during emergencies.
(Closed) Open Item (313/8510-07; 368/8510-07).
The NRC inspector verified
that EPIP 1903.50, " Emergency Response Organization, Task L-2," assigned
communicators to the E0F to communicate with the NRC during emergencies.
(Closed) Deficiency (313/8511-01; 368/8511-01).
The NRC inspector noted
that the Gaseous Effluent Radiological Monitoring System (GERMS) terminal
was removed from the Technical Support Center (TSC) and installed in the
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EOF, where it has backup power.
The Radio Base Station was moved to the
Operational Support Center (OSC), and at this time is not connected to
backup power.
The licensee uses hand held radios supported by a coaxial
cable antenna system installed strategically throughout the site as a
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backup system for communicating with onsite and inplant emergency teams.
The licensee plans to perform dose assessments from the EOF and to direct
monitoring teams from the OSC.
In addition, the NRC inspector noted that
the library aperture card reader was connected to back-up power.
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(Closed) Violation (313/8502-01; 368/8502-01).
The NRC inspector noted
that procedure QAA-3/1, " Quality Assurance Procedure Review Form," was
revised to include a sign off for the Quality Assurance Manager.
(Closed) Deficiency (313/8502-03; 368/8502-03).
The NRC inspector
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determined that according to NRC Inspection Report 50-313/85-02;
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50-368/85-02 an unannounced drill was conducted in which the licensee
demonstrated their capability to staff the Emergency Response Facilities
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during the regular shift hours within the time specified in NUREG-0737,
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Supplement 1.
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(Closed) Deficiency (313/8511-02; 368/8511-02).
The NRC inspector held
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discussions with the licensee's computer support superintendent and noted
that additional error detection / correction capability in the licensee's-
Safety Parameter Display System (SPDS) was not necessary, because the
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errors of using the present system were improbable and small. The NRC
inspector noted that the SPDS contained dual Central Processing Units (CPUs)
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and redundant consoles and used separate fiber optics for communication.
The SPOS was found to be 99.1 percent reliable.
The data for a typical
display on a CRT contains some 2000 bytes, of which 100 may be critical.
The screen is updated once per second.
From these considerations, the
expected errors would be approximately 9 bytes out of 200,000 of a duration
of 1 second.
In the present system, graphic signals emanate from a display
generator local to the CPU, so that any errors would appear as ' snow' which
would be corrected in 60 seconds.
(Closed) Deficiency (313/8511-03; 368/8511-03).
The NRC inspector noted
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that point-by point SPOS database verification was completed and fully
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operational in August 1985.
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(Closed) Deficiency (313/8525-02; 368/8526-02).
The NRC inspector
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verified that procedure EPIP 1903.10 " Emergency Action Level!.
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Response / Notifications," paragraph 8.1.1 was changed to include measured
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dose rates.
(Closed) Deficiency (313/8525-01; 368/8526-02).
The NRC inspector
determined that ANO emergency procedures contained measurable and
observable emergency action levels (EAls) based on in plant conditions and
onsite and offsite radiological monitoring results.
In addition, the NRC
inspector determined that ANO EALs contained FSAR accident scenarios.
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These EALs are used as the basis for making the four event classifications
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as required by 10 CFR 50.
See paragraph 3 for further discussion of the
EALs and emergency classification.
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(Closed) Deficiency (313/8122-51; 368/8121-51).
The NRC inspector
determined that a new meteorological tower and instrumentation appeared to
be operational and noted that a contract with a vendor was in place to
provide validation and calibration services.
(0 pen) Deficiency (313/8511-04; 368/8511-04).
The NRC inspector met with
the licensee's staff, discussed each of the four concerns, and concluded
as follows:
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The GERMS methodology uses a model which accounts for stack height as
a.
well as momentum of the effluent to calculate an effective release
height.
This model appears to be more sophisticated and realistic
than assuming a straight gaussian model ground release.
In cases
where an unmonitored release path is involved, the GERMS program
assumes a ground level release,
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b.
Default X/Q values (i.e., based on the annual average) for
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determining dose rates were evaluated by NRC Headquarters and
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approved in a letter dated September 16, 1980.
c.
A new meteorological tower and instrumentation were made operational
(see closeout to deficiency 313/8122-51; 368/8121-51 above),
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The GERMS system program applies a finite plume correction and a
height correction to the initial calculations, thus the results are
modeled significantly beyond the semi-infinite cloud assumption.
In
addition, the GERMS dose assessment model appears to meet the
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criteria in Appendix II of NUREG-0654.
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This item remains open pending further evaluu. ion.
3.
Emergency Detection, Classification, and Protective Action Decisionmaking
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The NRC inspector reviewed the appropriate sections of the Emergency Plan,
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hereafter called the Plan, and the Emergency Preparedness Implementing
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Procedures (EPIPs) as they related to the EALs and emergency
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classification.
Additionally, the NRC inspector compared selected EALs
from NUREG 0654 to EALs in the Plan.
The NRC inspector conducted interviews with selected representatives of
four different shifts at the two reactor units in the ANO site.
Each of
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the four interviews included the simultaneous presence of:
a Shift
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Operations Supervisor (505) and a Shift Administrative Assistant (SAA).
The SOS is responsible for emergency detection, classification, and making
initial protective action recommendations (PARS) to offsite authorities;
the SAA is responsible for performing initial dose assessment, and
formulating PARS for consideration of the 505.
An observer from ANO, who
was not part of the discussions, was present during each interview.
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The agenda for the interview consisted of providing each team with written
guidelines concerning the interview and overview questions concerning
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emergency preparedness, and conducting a table-top exercise or walkthrough '
based on a plant-specific accident scenario.
The interview lasted
approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> on the average.
Guidelines for the interview
included items such as:
Interview was open book.
Emphasis was on emergency preparedness versus operational / technical
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issues.
Interviewee could seek clarification at any time during the
interview.
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Realism of events in the scenario was not a concern.
The accident scenario consisted of:
Fuel failure due to faulty reactor coolant pump that necessitated an
Alert declaration.
Loss of coolant accident (LOCA) through the pressurizer relief valves
and containment cooling systems necessitating a General Emergency
declaration,
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Containment failure through the purge system.
The NRC inspector indicated that they expected the interviewees to:
Describe duties and responsibilities for their respective emergency
response organization position.
React orally to simulated plant conditions and carry out simulated
actions according to proceduras.
Utilize appropriate references.
Classify the evolving conditions by evaluating EALs according to the
four emergency classes of 10 CFR 50.
Evaluate plant radiological conditions and implement protective
actions for plant personnel accordingly.
Perform dose assessment calculations.
Formulate PARS for the General Emergency class before a release of
radioactivity to the environment has taken place and when a release
is occurring.
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The following findings resulted from the NRC inspector's review of Abnormal
Operating Procedures (A0Ps) and EPIPs:
EALs required by regulation (e.g., results of field monitoring
measurements) have been included in the Plan.
EALs in the Plan were found to be consistent in range and units with
actual control room instrumentation.
EPIPs clearly define responsibilities, authorities, and timeliness
requirements in accident assessment and protective action
recommendations formulation.
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The following findings resulted from the NRC inspector's review of A0Ps and
EPIPs and together are considered to be an emergency preparedness deficiency
(313/8704-01; 368/8704-01):
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The Unit 1 Abnormal Operating Procedure A0P-1203.19, "High Activity
in the Reactor Coolant," does not include a follow-up action
requirement for sampling the primary coolant.
This is necessary to
evaluate actions according to Technical Specification requirements.
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The EPIPs do not contain a flow diagram equivalent to that of IE
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Information Notice No. 83-28 dated May 4, 1983.
As a consequence, the
teams interviewed did not consider evacuation before a release had
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occurred during General Emergency conditions with extensive fuel
damage and large amounts of radioactivity in the containment.
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There is no direct correlation between the example initiating
conditions of NUREG 0654, Appendix I, and the EAls found in the Plan.
In a few cases, it was shown that the departure from NUREG 0654 is in
a nonconservative direction.
For example, no EAls based upon
installed instrumentation are listed in the Plan that correspond to a
severe loss of fuel cladding.
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EALs in the Plan are not always equivalent to those in NUREG 0654 in
promptness of notification or in establishing the severity of the
emergency class.
Form 1904.02A, " Emergency Class /Of fsite Dose Projection Worksheet,"
does not provide for computing an integrated dose based upon expected
release duration and projected dose rate.
The following observations resulted from the NRC inspector's interviews
with Ilcensee personnel:
SOSs and SAAs were familiar with their duties and responsibilities,
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and understood the scope and Ilmits of their authorities.
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Three of four teams were familiar with Abnormal Operating Procedures
(e.g., 1203.19 and 2203.19) dealing with high activity in the reactor
coolant and promptly implemented their use in responding to the
scenario.
One of four teams was unable to refer to the procedure until
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prompted.
Out of eight opportunities to classify events provided to all teams,
one " Alert" classification was considerably delayed awaiting
unnecessary confirmation of coolant sampling results, while other
EALs were overlooked.
Protective actions for plant personnel under adverse radiological
conditions were not implemented satisfactorily.
Prompt evacuations
of high radiation areas due to the effects of the scenario were
neglected.
EPIPs do not contain explicit provisions for evacuation of local
inplant areas.
Each team interviewed was able to promptly and correctly make the
proper decisions needed to formulate the PARS for a General Emergency
when no release of radioactivity to the environment had taken place.
Two of the teams questioned were unable to effectively formulate a
PARS when a release had occurred.
This was because the two teams
failed to convert dose rates to doses by multiplying by the time
factor (e.g., expected duration of the release).
This method was
found in EPIP 1904.02,"OffsiteDoseProjections-PocketComputer
Method."
Several errors related to dose assessment calculations were noted as
follows:
one of four SAAs improperly evaluated a Delta Temperature
stability class; one of four SAAs failed to evaluate his data
correctly in reporting the information requested; one SAA of four was
unable to access the GERMS dose assessment program for release rate
information and was not familiar with default values; and one of
four SAAs erroneously computed reciprocal compass rose bearings, and
as a consequence improperly defined downwind map sectors.
The SOS
did not detect these errors.
The SOSs exercised discretionary authority in a conservative direction
with respect to event classification wren the Plan did not address a
particular situation.
Three of four teams demonstrated an overall understanding of
emergency procedures.
The licensee's overall performance in this area was considered
adequate.
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The NRC inspector interviewed representatives of the licensee and the
state of Arkansas to determine if the EALs were formally reviewed on an
annual basis.
The NRC inspector determined that the licensee was unable
to furnish written evidence that a formal meeting to review EALs had taken
place.
However, the State representative assured the NRC inspectors that
monthly meetings were held between State representatives and the licensee
to review EALs,
The NRC inspector recommended that this review process be
documented.
No violations or deviations were identified in this area.
4.
Exit Interview
The NRC inspectors met with licensee representatives (denoted in
paragraph 1 above) at the conclusion of the inspection on January 16,.
1987.
The NRC inspectors summarized the purpose and the scope of the
inspection and the findings.
The licensee stated that they would initiate
immediate corrective actions (e.g., interviews and retraining) as needed
to improve the performance of the 50Ss and SAAs.
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