ML20211K105
| ML20211K105 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 11/07/1986 |
| From: | Hackney C, Yandell L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20211K097 | List: |
| References | |
| 50-298-86-25, NUDOCS 8611170018 | |
| Download: ML20211K105 (10) | |
See also: IR 05000298/1986025
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APPENDIX
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-298/86-25
License:
Dockets:
50-298
Licensee:
Nebraska Putlic Power District (NPPD)
P. O. Box 439
Columbus, Nebraska
68601
Facility Name:
Cooper Nuclear Station (CNS)
Inspection At:
Brownville, Nebraska
Inspection Conducted:
September 22-26, 1986
Inspector:
Godf
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bA
II
k[#
C. A. Hackney, Emerg
cy Preparedne
nalyst
Date e
Personnel:
C. Wisner, NRC Region IV
J. B. Baird, NRC Region IV
W. M. McNeill, NRC Region IV
T. Lynch, Battelle
G. Bryan, Comex
Approved:
(lu
11/ 7///o
L. A. Yandell, Chief, Emergency Preparedness
Dat'e
and Safeguards Programs Section
Inspection Summary
Inspection Conducted September 22-26, 1986 (Report 50-298/86-25)
Areas Inspected:
Routine, announced inspection of the licensee's performance
and capabilities during an exercise of the Emergency Plan and procedures.
Results: Within the emergency response areas inspected, no violations or
deviations were identified.
Three deficiencies were identified.
(Sections 6
and 9)
8611170018 861112
ADOCK 05000298
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DETAILS
1.
Persons Contacted
Principal Licensee Personnel
D. Norvell, Maintenance Manager
- P. R. Windham, Emergency Planning Coordinator
C. Goings, Regulatory Compliance Specialist
- J. Sayer, Assistant Technical Staff Manager
- J. M. Meacham, Technical Manager
J. W. Boyd, Shift Supervisor
R. D. Black, Operations Supervisor
- R. Hayden, Emergency Preparedness Specialist
- L. Kuncl, Vice President, Nuclear
- K. Krumland, Acting Emergency Planning Coordinator, General Office
D. Schaufelberger, President, NPPD
- J. Flash, Public Information Coordinator, Nuclear
G. Trevors, Manager, Nuclear Licensing and Safety Department
R. Wilber, Manager, Nuclear Services Division
T. Knippenburg, Consultant (Nutech)
M. Krumland, Emergency Planning Specialist
R. Palazo, Consultant (Nutech)
- G. Horn, Division Manager, Nuclear Operations
- E. Mace, Engineering Supervisor
W. Keller, Technical Support Center (TSC) Controller (Nutech)
D. Reeves, TSC Controller
R. Gibson, TSC Quality Assurance
NRC
- D. L. DuBois, Senior Resident Inspector
- E. A. Plettner, Resident Inspector
Federal Emergency Management Agency (FEMA)
R. Leonard, Program Manager
D. Sumpter, Senior Technological Hazards Specialist
The NRC inspectors also held discussions with other station and corporate
personnel in the areas of health physics, operations, and emergency
response organization.
- Denotes those present at the exit interview.
2.
Licensee Action on Previous Inspection Findings
Closed (0 pen Item 50-298/8528-01).
The licensee demonstrated the ability
to establish initial and continuous accountability.
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3.
Exercise Scenari,o
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The exercise scenario was reviewed for completeness, continuity, and
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consistency in conjunction with the requirements of 10 CFR 50, Appendix E,
Section IV.F, and the guidance in NUREG-0654,Section II.N.
The areas
reviewed included objectives, events sequence, scenario messages, plant
parameter data, meteorological data, and radiological data.
The events
sequence appeared adequate to allow the licensee to meet the listed
objectives.
Specific aspects of the review are noted below:
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The scenario contained objectives on which an evaluation of the
exercise could be made.
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A narrative summary included in the scenario described the events
sequence and supporting information.
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The scenario messages were adequate to allow the controllers to
maintain the scenario time line.
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The scenario data adequately supported the sequence of events.
4.
Control Room (CR)
Initial conditions were given to the operations personnel prior to the
initiation of the exercise:
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CNS is operating at 100 percent rated power.
The unit has been
operating continuously for 86 days.
The core is near the end of core
life and has been exposed for 349 effective full power days,
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RWCU pump "B" is isolated for corrective maintenance.
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SBGT "B" is inoperable due to a seized fan.
All required
surveillances are complete and satisfactory for today.
SBGT "B" was
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declared inoperable this morning and repairs should be completed
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within 2 days.
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Feedwater heater levels have experienced some unexplained
fluctuations during the past week.
Investigation continues.
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Feedwater heater levels are presently stable.
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All other plant systems are operable and in normal 100 percent
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operating configuration.
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The exercise was initiated at 7:15 a.m. with a severe storm watch and
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associated wind of 70 mph and increasing.
The licensee declared a
Notification of Unusual Event (NOVE) in accordance with Emergency Plan
Implementing Procedure (EPIP) 5.7.1 and Emergency Action
Level (EAL) 12.1.4., due to winds exceeding 74 mph.
At 8:00 a.m., 69 kv
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lines supplying the emergency station service transformer were severed due
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to high winds.
A maintenance technician was injured and determined to be
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contaminated.
The technician was administered first-aid and dispatched to
the hospital.
The injured and contaminated person was'an EAL for the NOUE
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emergency class.
At 8:30 a.m., a fire was reported in the diesel
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generator room and the fire teams were dispatched to the fire. An Alert
classification was declared at 8:35 a.m.
Following the declaration of the
Alert, the Technical Support Center (TSC) was activated.
Transfer of
command to the TSC was announced at 9:07 a.m.
The NRC inspector observed
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that control room personnel consulted and utilized their procedures for
the fire and dnormal operating conditions.
Plant drawings and Technical
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Specifications were referenced during the exercise.
Operations personnel
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responded to plant conditions in a timely manner and exhibited initiative
toward solving abnormal problems.
Communications from the control room to
onsite and offsite agencies appeared adequate.
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The following observation was called to the licensee's attention by the
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NRC inspector.
The observation is neither a violation nor an unresolved
item.
The item was recommended for licensee consideration for
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improvement, but it has no specific regulatory requirement.
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Identify all player personnel in the control room in addition to
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other emergency response exercise personnel.
No violations or deviations were identified.
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5.
Technical Support Center (TSC)
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The TSC was activated approximately 20 minutes after the " Alert"
declaration.
Although the TSC was overcrowded due to the presence of both
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primary and alternates for each position, upon activation the excess
personnel moved to an adjacent Instrumentation and Controls shop and
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relieved the congestion.
Habitability was marginal due to poor air
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conditioning.
The noise level remained low despite the crowding in the
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TSC. Offsite notifications to the states and NRC headquarters were done in
a timely manner, although some of the information relayed in the initial
message to'the NRC was incorrect.
Staff briefings were timely and
generally adequate, except when limited by the control room's failure to
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relay critical information.
Site-wide accountability was achieved in
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33 minutes.
Although TSC accountability was maintained, the process
should be reviewed to make it more efficient.
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The following are observations the NRC inspectors called to the licensee's
attention.
These observations are neither violations nor unresolved
items.
These items were recommended for licensee consideration for
improvement, but they have no specific regulatory requirement.
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EPIPs 5.7.2, " Notification," and 5.7.20, " Protective Action
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Recommendations," should be revised to require that the Emergency
Director review the appropriate forms and authorize them via
signature for transmission on behalf of the licensee.
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Modify status boards to include an unlabeled linear graph to allow
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trending of key parameters and to allow the display of both the
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licensee protective action recommendation and the protective actions
implemented by the state (s).
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The TSC should provide backup dose assessment calculations and
protective action recommendation evaluation for the Emergency
Operations Facility (EOF).
o
The TSC staffing for engineering assessment should be reviewed for
adequacy.
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The methodology for maintaining accountability should be
standardized.
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Access and egress from the TSC should be limited to one door
controlled by the Security / Administration / Logistic (SAL) coordinator.
No violations or deviations were identified.
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6.
Emergency Operations Facility personnel began arriving after the Alert
declaration and the EOF was placed in standby approximately 50 minutes
after the declaration.
The E0F was declared operational 37 minutes after
the Site Area Emergency declaration.
Activation checklists were used.
Offsite notifications were made within 15 minutes after the Site Area and
General Emergencies were declared.
However, the Emergency Director's
approval was not documented.
The E0F Director held periodic briefings
that kept key state and licensee personnel informed on the plant status
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and offsite conditions.
The briefinas were held off to the side from
where the Emergency Director sits, which caused some congestion and noise
problems.
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Source term data were erroneously entered into the dose projection model as
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microcurie /sec instead of Ci/sec.
This resulted in projected offsite doses
which differed significantly (4 to 6 orders of magnitude) from the doses
indicated by real time data and field monitoring data.
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inadequate review of the dose projection results. Also, radiological
status boards were not updated periodically as new dose projections were
made.
The NRC inspectors observed the following deficiency:
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10 CFR 50.47(b)(9) states that adequate methods, systems, and
equipment for assessing and monitoring actual or potential offsite
consequences of a radiological emergency condition are in use.
Due
to the errors in dose projections and the lack of continuous
management review to ensure accuracy of the data, the capability
necessary to meet Objective 6 was not demonstrated (50-298/8625-01).
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The following are observations the NRC inspector called to the licensee's
attention.
These observations are neither violations nor unresolved
items.
These items were recommended for licensee consideration for
improvement, but they have no specific regulatory requirement.
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Radiological data in the EOF should be trended.
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The TRS-80 dose projection program should include the appropriate
dose rate units with the calculated values.
Consideration should be
given to printing the cumulative dose values that the protective
action recommendations are based on.
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Attachment B to EPIP 5.7.18, " Dose Assessment," should be completely
filled out for each monitoring team.
The NRC inspector noted that
the following information was left blank on Attachment B:
instrument
type, serial number, team leader's name, and dosimeter readings.
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The offsite notification and protective action recommendation forms
should have a sign-off section for approval by the Emergency
Director.
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Offsite doses and dose rates should be periodically updated on the
radiological status board.
The initial projected doses were left on
the status board for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 15 minutes, during which time several
new dose projection calculations were made.
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Radiological surveys should include the determination of habitability
by assuring that doors are closed and controlled during EOF
activation and operation.
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Seating and communications should be provided for the NRC and state
representatives near the Emergency Director.
o
Briefings for key state and NRC personnel should be held in a
briefing room.
o
The Emergency Director should spend more time directing the offsite
and onsite emergency response effort.
Too much time was utilized on
the telephone trying to perform TSC and CR functions.
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The E0F critique was a summary of events and should have involved
participation by players and controllers.
No violations or deviations were identified.
7.
Medical First Aid
The accident victim was to have been an individual that had a simulated
fall and was discovered by his co workers.
The observer announced that a
person had been injured and needed assistance.
Approximately ten persons
looked at the controller and one person responded to inquire about what
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had happened.
The person responding notified the control room that an
injured person was lying down by a lathe in the shop.
The victim was not
administered to or assisted until the medical team arrived.
The medical
team arrived in approximately 12 minutes after the controller's
announcement.
The patient was radiologically monitored for contamination
and prepared for transporting to the hospital via CNS ambulance.
No violations or deviations were identified.
8.
Operational Support Centers (05Cs)
The OSCs were activated in a timely manner.
Personnel accountability was
maintained and teams dispatched from the OSCs were logged in and out of
their respective OSCs.
Response teams were briefed on the job tasks to be
performed prior to being dispatched from the TSC.
No violations or deviations were identified.
9.
General Office Emergency Center
The NRC inspector reviewed the Emergency Plan, EPIPs, and corporate
nuclear emergency procedures (CNEPs) which described the functions of the
General Office Emergency Center (G0EC) during an emergency at CNS.
Several inconsistencies were noted as follows:
a.
CNEP 1.0, " Notification of General Office Emergency Organization,"
had a former employee (A. C. Morgan) listed as an off-hours
monitor (OHM).
b.
The G0EC organization chart depicted in Attachment F to CNEP 2.0,
"GOEC," did not agree with the organization shown in Figure 5.3-1 of
the Emergency Plan.
c.
The CNEPs were previously referred to as " General Office
Guidelines" (G0Gs), and the Emergency Plan had not been revised to
replace the G0Gs with the new procedures.
d.
EPIPs 5.7.6 and 5.7.28 made reference to the NPPD management position
"AGM-Nuclear." This management position title had been changed to
Vice President-Nuclear.
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Except for notifications, the EPIPs did not specifically address the
interface between the CNS emergency response organization and the
GOEC functions described in the CNEPs.
The NRC inspector also observed the activation and operation of the G0EC
at the general offices in Columbus, Nebraska, on the day of the exercise.
The general office off-hours monitor was notified by CNS of the NOUE at
about 8:03 a.m., in accordance with EPIP 5.7.6.
The OHM then contacted
and briefed licensee general office management.
The OHM was subsequently
notified by CNS at about 8:53 a.m. that an Alert had been declared at the
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station and conditions were not stable.
At approximately 8:58 a.m., the
OHM assumed the responsibilities of the G0EC Director and requested
staffing of the GOEC.
At about 9:15 a.m., the GOEC Director announced
that the GOEC was declared operational without having the Emergency
Planning Coordinator (EPC) position filled.
This position was specified
as one of the five minimum staffing requirements in Section II.C of
CNEP 2.0 and Section 5.3.1.A of the Emergency Plan.
The position was not
staffed due to lack of depth in personnel qualified to perform the EPC
function.
This deficiency was also identified by the licensee's
observers.
The NRC inspector observed that the G0EC Director demonstrated good
command and control of GOEC activities throughout the exercise, and except
for an approximate 1-hour period following his first briefing, provided
frequent and effective briefings to the GOEC staff.
The NPPD President
and Board members were periodically briefed on events and response
activities.
The first of these briefings was held in the president's
office between about 10:20 a.m. and 10:40 a.m.
During this period, the
station conditions worsened and a General Emergency was declared at about
10:39 a.m.
The NRC inspector noted that, since the briefing was outside
of the G0EC, the worsening conditions were not known to the briefer and
the briefing presented a station status inconsistent with events in
progress.
Communications were maintained with the Media Release
Center (MRC) and EOF through a telephone conference line and by facsimile
transmissions.
The NRC inspector noted that the public affairs and
information authentication functions were handled in an efficient and
effective manner, and support to the MRC in these areas appeared to be
very good.
The NRC inspector also noted that the G0EC staff provided
timely and effective input to the GOEC Director throughout the exercise.
The GOEC Technical Advisor maintained communications with station
counterparts and provided technical information to the G0EC Director,
Public Affairs Director, and MRC staff.
The resources and administrative support functions were active in planning
and arranging for personnel and logistics support for CNS.
In addition,
the Environmental Support Manager was observed to communicate with the E0F
on radiological matters, perform independent analyses on environmental
impacts, and provide interpretations and assessments of environmental and
public health impacts.
The NRC inspector noted that key staff referred to
the CNEPs frequently and appeared to be following procedures and
checklists.
Information flow appeared to be good and status boards were
generally maintained throughout the exercise.
However, the event
chronology displayed was very terse and appeared to be too limited in
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scope and time span due to the small space allocated for this information
on one of the status boards.
At about 1:45 p.m. , the scenario clock was advanced 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and recovery
planning was demonstrated.
The GOEC participated in the planning at CNS
by telephone conference call.
Additional health physics technicians,
General Electric core assessment services, and engineering support were
discussed in addition to the environmental assessment plans.
The G0EC
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participation in recovery planning appeared to be appropriate; however,
the NRC inspector noted that there were no written, approved procedures
specifying the GOEC role and responsibilities in implementing recovery
plans developed pursuant to the planning standard of 10 CFR 50.47(b)(13).
This is considered to be an emergency preparedness deficiency.
Licensee
observers also identified this deficiency during the exercise.
GOEC
participation was terminated with the end of the. exercise at about
4:00 p.m.
The NRC inspector observed the following deficiencies:
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The G0EC was activated and declared operational without the minimum
staffing (no Emergency Planning Coordinator) specified in
Section II.C. of CNEP 2.0 and Section 5.3.1.A of the Emergency Plan
(50-298/8625-02).
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No written, approved procedures were provided to control G0EC
recovery planning and support activities pursuant to the planning
standard specified in 10 CFR 50.47(b)(13) (50-298/8625-03).
The following are observations the NRC inspector called to the licensee's
attention. These observations are neither violations nor unresolved
items.
These items were recommended for licensee consideration for
improvement, but have no specific regulatory requirement.
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The CNS EPIPs should be reviewed and revised as necessary to provide
specific interfaces with the GOEC CNEPs.
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G0EC organizational charts in the Plan (figure 5.3-1) and in
Attachment F to CNEP 2.0 should be brought into agreement.
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The CNS EPIPs and Emergency Plan should be reviewed and revised to
incorporate corporate organization title changes and the change in
corporate implementing procedures nomenclature,
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More space should be provided for significant event information
display in the GOEC than currently provided on the status board.
No violations or deviations were identified.
10.
Media Release Center
The HRC was activated in a timely manner.
The MRC staff, including all
agencies represented, were preplaced, except Kansas, due to the compressed
time schedule provided in the scenario.
The briefings were conducted in a
professional manner.
A sufficient number of prebriefings were conducted
and in a professional manner.
Prebriefings were conducted before each
news briefing.
The addition of a sound system permitted everyone to hear
the briefings.
The sound system was suitable for the small briefing room
used.
The NPPD visual aids were suitable for a small room; however, the
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visual aids may be too small for a larger briefing room.
The sector map
used by the State of Nebraska was not large enough in size and did not
contain sufficient detail.
11.
Exercise Critique
The NRC inspectors attended the post-exercise critique by the licensee
staff on September 25, 1986, to evaluate the licensee's identification of
deficiencies and weaknesses as required by 10 CFR 50.47(b)(14) and
Appendix E of Part 50, paragraph IV.F.5.
The licensee staff identified
the deficiencies listed below.
Corrective action for identified
deficiencies and weaknesses will be examined during a future inspection.
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Communications from the CR to the TSC were degraded on several
occasions; e.g.:
TSC was not aware of the Anticipated Transient Without
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Incorrectly informed that the Safety Relief Valves lifted
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The Emergency Director's command of the emergency organization needs
improvement.
12.
Exit Meeting
The NRC inspectors met with licensee representatives (denoted in section 1)
at the conclusion of the inspection on September 26, 1986.
The NRC
inspector summarized the purpose and the scope of the inspection and the
findings.
Additionally, the licensee representatives were informed that
additional findings may result following a briefing of Region IV management.
The licensee's actions during the exercise were found to be adequate to
protect the health and safety of the public.