ML20214P413
| ML20214P413 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 11/12/1986 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | James Keppler, Shafer W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| CON-NRC-86-111 VPNPD-86-468, NUDOCS 8612040189 | |
| Download: ML20214P413 (7) | |
Text
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Wisconsin Electnc m cower 231 W. MICHIGAN, P.O. BOX 2046, MILWAUKEE, WI 53201 (414)277-2345 VPNPD-86-468 NRC-86-111 November 12, 1986 Mr. J.
G. Keppler, Regional Administrator office of Inspection and Enforcement, Region III U.
S. NUCLEAR REGULATORY COMMISSION 799 Roosevelt Road Glen Ellyn, Illinois 60137 Attention:
Mr. W.
D. Shafer, Chief Emergency Preparedness and Radiological Protection Branch Gentlemen:
DOCKETS 50-266 AND 50-301 INSPECTION REPORT 50-266/86018(DRSS)
AND 50-301/86017(DRSS)
POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 Your letter of October 1, 1986 forwarded Inspection Report 50-266/86018 and 50-301/86017, which described the results of a routine, announced inspection of the Point Beach Nuclear Plant emergency preparedness exercise by members of your staff on September 8-11, 1986.
Your letter requested that we advise you, within 45 days of the letter date, of corrective actions we have taken, or plan to take, with regard to the weaknesses cited.
Although a written response regarding the exercise weaknesses is normally not required, we have prepared the attachment to this letter in response to your request.
Very truly yours, 9
Wu 'avI C. W.
Fay gC'3[
Vice President 8612040189 861112 Attachment gDR ADOCK 0500 6
fkOVy 719861 Copy to Resident Inspector
4
,, n APPENDIX.
4 P
1.
WEAKNESS:
"The. Site Manager's location, and change of location was not logged on an' status. board nor announced.
.Therefore, it was not clear to the observer who was.in control at all times."
O'EN ITEM NOS.:
266/86018-01 and 301/86017-01 P
DISCUSSION:
The NRC report indicates that "The Site Manager departed the TSC, arrived.at the EOF and returned to the TSC (due to the exercise scenario requiring evacuation of the EOF)."
During the September exercise, the site Manager's movement'from the.TSC to the EOF and then to the TSC was not due specifically tosthe scenario.
The PBNP Emergency Plan Implementing Erocedures (EPIPs 3.1, 4.1, and 5.1) direct the Site Manager to' report to the EOF, initiate its setup, and i
formally activate the facility.
While at the EOF, the Site Manager assumes the responsibilities of the Emergency Support Manager until relieved.
The Emergency Support Manager position is ultimately filled by corporate support personnel-from Milwaukee.
In practice, the Emergency-Support Manager typically arrives at the EOF-from Milwaukee in about 90 minutes
- from the time of notification.
When the Emergency Support Manager position'is formally assumed by corporate personnel, the Site Manager returns to the TSC.
The actions taken by the Site Manager during the September 9, 1986 exercise were consistent with those required by the EPIPs.
The weakness specifically alleges a failure to document and announce the Site Manager's change in emergency response facility location.
Therefore, the observer questioned i
whether TSC personnel were aware of who was 'in charge during i
the Site Manager's absence.
A search-through documentation generated during the drill by drill players revealed the following:
a.
The minutes from the 0830 TSC staff meeting (attended by the Site Manager, Health Physics Director, Technical Support Manager, Core Physics Coordinator, Training Supervisor, Chemistry Director, and Plant Operations Manager) contained the following note:
" EOF staffed, l
J. Zach [ Site Manager] going out after meeting."
l Therefore, persons holding major roles in the TSC were i
aware, by virtue of their attendance at the staff L
meeting, that the site Manager would soon be leaving j
b.
The TSC log, maintained by clerical staff, documented the Site Manager's departure at 0902 hours0.0104 days <br />0.251 hours <br />0.00149 weeks <br />3.43211e-4 months <br />.
I c.
The EOF log documented the arrival of the Site Manager l
at 0906 hours0.0105 days <br />0.252 hours <br />0.0015 weeks <br />3.44733e-4 months <br />.
C' I
Appendix Page 2 d.
Subsequent EOF log entries describe personnel (DTAs,
-Offsite Health. Physics Director, communicators, Rad con / Waste' Manager, and Emergency Support Manager) reporting to the Site Manager.for.information and instructions, indicating an awareness of who was in charge.
e.
The assumption of Emergency Support Manager. duties from the Site Manager by personnel from corporate headquarters (Milwaukee) was logged in the EOF as occurring at 1045 hours0.0121 days <br />0.29 hours <br />0.00173 weeks <br />3.976225e-4 months <br />.
i f.
The TSC status board was updated at 1117 hours0.0129 days <br />0.31 hours <br />0.00185 weeks <br />4.250185e-4 months <br /> to reflect the official assumption of Emergency Support Manager responsibility by Milwaukee personnel.
In view of scenario activity at this time (a loss of TSC-EOF telecommunication, evacuation of both the plant and EOF in progress, personnel accountability in progress, and assumption of EOF responsibilities by the TSC); the 37 minute time frame for posting the changeover was surprisingly prompt.
In summary, an examination of the-TSC and EOF logs generated during the exercise indicates a strong awareness of the Site Manager's location and an awareness on the part of exercise players of who was in charge at the TSC and EOF.
RESPONSE
Notwithstanding_the above observations, this open item will be addressed as follows:.
a.
An evaluation will be performed to determine the best method of assuring an improved awareness by both exercise players and observers of the Site Manager's location and an improved awareness of who is in control at all times in each facility.
Options may include:
additional training, revi-sion of appropriate EPIPs, revision of status boards, or revision of-the TSC staff meeting agenda. JCombinations of these methods may be appropriate.
The evaluation will be completed by January 1, 1987.
b.
Upon completion of the evaluation, implementation of the method chosen will be initiated.
Training and/or appropriate revision will be completed by July 31, 1987.
(-
2.
WEAKNESS:
"The responsibility to maintain the events log and the entry team status board... was not assigned to one individual, and the entry team status was significantly out of date in the latter stages of the exercise, and contained l
Appendix Page 3 entries which were. incorrect.
.It was also noted that EPIP 6.5,
" Technical Support and Operational Support Center Activation", does not deal with the OSC elsewhere than in the
' document's title.
Licensee attention is needed in this area, to proceduralize,-to the-extent possible, OSC-
-actions,' including activation, tracking of teams, and dose tracking / projection for team members."
OPEN ITEM NOS.:
266/86018-02 and 301/86017-02 DISCUSSION:
It has been the practice to log reentry team activities on a chalk board in the TSC.
The organization, dispatch, and exposure control of emergency reentry teams are controlled by EPIPs 12.1 and 12.2.
As discussed in the report, the activation and operation of the OSC are not specifically proceduralized.
RESPONSE
This open item will be addressed as follows:
a.
EPIPs 12.1'and 12.2 will be evaluated to assess their.
adequacy for enabling tracking and performance of personnel dose / projection tracking of emergency reentry teams.
Procedure revision and required training will be completed by-July 31, 1987, b.
Consideration will be given to the installation and use of a reentry team status board in the TSC/OSC as opposed to use of the free form chalk board method.
Alternately,
.use of the chalk board could be formalized by a revision to the EPIPs.
Evaluation and implementation will be completed by July 31,-1987.
c.
A procedure will be developed which specifically addresses setup, organization, and. operation of the OSC.. This procedure will be developed and implemented by July 31, 1987.
3.
WEAKNESS:
" Plant procedures require that the thermolumin-escent dosimeter (TLD) be worn beneath the outer layer of protective clothing (to prevent contamination of the device).
Since the TLD is almost universally attached to the-identification / access card, the access control card was not accessible by the entry team for use in card readers.
This prevented the turbine building team from gaining quick access to the cable room."
OPEN ITEM NOS.:
266/86018-03 and 301/86017-03
39
.g'..
Appendix Page 4 DISCUSSION:.It has been=PBNP plant practice'to wear TLDs beneath.the outer layer of ~ protective clothing.
This
- practice has proven to be most effective in preventing loss and/or contamination of the device.
That -practice is a practice only'and, contrary to the inspection. report, is'not required by plant procedure.
We believe that the practice is justifiable..'However,.since the TLD and cardkey are typically fastened together, entry team movement throughout the plant has, in some cases, been impeded.
RESPONSE
A change to the Emergency Plan Implementing Procedures will be made to provide that TLDs of emergency c
reentry teams be removed'from the cardkey and be placed beneath the outer layer of protective clothing with other dosimetry.
The cardkey alone will be worn on the outer layer of clothing, thus assuring ready access to the cardkey.
Procedure changes will be made'by March 1, 1987.
.4.
WEAKNESS:
"The health physics team sent to the turbine room was not sufficiently protected from the environment predicted by the exercise scenario...
Canvas hoods and canvas shoe covers were provided.
Also, good health physics practice 4
indicates that more than one... survey instrument should be F
taken by an entry team, especially when entering a hostile environment."
~
OPEN ITEM NOS.:
266/86018-04 and 301/86017-04 DISCUSSION:
At the time the health physics team was being sent out for turbine hall surveys, it had been reported that water was flowing from the turbine hall-through the truck access door.
The survey = team members were dressed in plastic suits, canvas hoods and boots, and respiratory
+
equipment.
During the predispatch' briefing, the survey team was instructed to view the area to determine the source of the water.
They were specifically instructed not to enter a j
wet or steam environment.
The donning of canvas boots and hoods as opposed to plastic was a conscious decision by the 3
Health Physics Director based on the fact that when one is entering a potential high heat / steam environment, the ability to detect the heat and steam is significantly reduced if fully suited in plastic.
Because the team was i
instructed not to enter a steam environment, the survey instrument was not " protected" in plastic.
RESPONSE
Notwithstanding these mitigating factors, this open item will be addressed as follows:
I 1
L
Appendix Page 5-a.
A supply of disposable plastic boots will be maintained in the OSC health physics storage area for use by
- emergency. reentry teams.
Appropriate changes will-be made to; inventory checklists and Emergency Plan-Mainte-nance Procedures (EPMPs).
These-changen will be'accom-plished by March 1, 1987.
b..
An evaluation will be performed regarding the need for an inventory of plastic hoods being maintained in the
-OSC.
Inventories, checklists and procedures will.be revised as required following the evaluation.- The
- evaluation will be completed by March 1, 1987 with implementation to be completed by July'31, 1987.
c.
An evaluation of EPIP 12.1, " Emergency Procedures for Emergency Operations," EPIP 12.2, " Personnel Exposure &
Search and Rescue Teams," and EPIP-32, " Search & Rescue and Emergency Operations Checklist," will be performed to determine the most effective method of assuring that reentry teams entering high risk areas are equipped with backup survey instrumentation.
The evaluation i
- will also include an assessment of how best to " flag" the need to " bag"l steam environment. survey instruments when entering a steam or potentia The evaluation will be completed by March 1, 1987, with appropriate changes complete by July 31, 1987.
1 5.
WEAKNESS:
"A single radiation control point was established at the door to the turbine' building (Door 116) and the TSC/OSC area.
It is unlikely that-positive radiation control could have been maintained at this point due to conditions experienced during'the exercise.
There was a strong inflow of air present.when the-door was open.
- Also, if an individual were to have been found to be contaminated, he would have to pass the checkpoint to reach the nearest shower (for decontamination).- Loss of radiation control at a checkpoint so located would have compromised nearby sample analysis and counting rooms and the TSC/OSC."
OPEN ITEM NOS.:
266/86018-05 and 301/86017-05 l-DISCUSSION:
EPIP 7.2.2,
" Activation of Chemistry & Health Physics at Technical Support Center / Operations Support
' Center," requires establishment of a stepoff pad and health physics control point at the TSC/OSC entrance to the Unit 1 turbine hall (Door 116).
During the exercise, other entrances to the TSC building (El. 26') were posted and roped off to prevent use.
Neither frisking instruments nor i
health physics personnel were stationed at the El. 26' i
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-Appendix Page 6 entrances; this is in accordance with practice and procedure.
We believe that.a combination of wind' conditions and turbine
-hall fan lineup may have caused an, observed phenomena of air flow from the turbine building to the TSC/OSC.
The design of-the TSC building ventilation system is such.that when-in the " emergency mode," the TSC_ building is pressurized relative to the outside environment.
Tests of the
" emergency mode" ventilation system were conducted on October 23 and 24, 1986.
In both cases, air flow was observed to be from the TSC/OSC to the turbine building at Door 116.
In the event that the ventilation system were
-inoperable and/or accident conditions caused TSC air flow to be inward, additional contamination control can be gained by closing the hallway-doors between Door 116 and the TSC/OSC.
Restrooms and showers in the TSC/OSC.are located on the
" clean side" of the TSC/OSC stepoff pad and control point.
This design allows use of the facilities by personnel manning the TSC and OSC.
If a person at the stepoff pad was dis-covered to be. contaminated, clothing would be removed, and the person.would be dressed in paper coveralls and disposable booties.
Normal health physics and decontamination practices I
would be utilized to control the. spread of contamination from the stepoff ' pad to the shower; A stepoff pad and frisking station can also be established in each restroom at the locker room exit.
RESPONSE
This open item will be addressed as follows:
l l
a.
In view of the observed flow-of air into the TSC, we l-will continue to evaluate the TSC ventilation system design and performance.
This evaluation will be completed by February 1, 1987.
If corrective actions are required, maintenance and/or modification requests will be initiated as soon as possible following the evaluation.
b.
Appropriate revisions to the EPIPs will be made to clarify methods of TSC/OSC contamination control.
Procedure changes and subsequent retraining will be l
completed by July 31, 1987.
-