ML20236L317
| ML20236L317 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 07/07/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20236L300 | List: |
| References | |
| 50-461-98-09, 50-461-98-9, NUDOCS 9807100311 | |
| Download: ML20236L317 (20) | |
See also: IR 05000461/1998009
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U.S. NUCLEAR REGULATORY COMMISSION
REGIONlli
Docket No: 50-461
License No: NPF-62 t
Report No: 50-461/98009(DRS)
Licensee: Illinois Power Company
Facility: Clinton Power Station
Location: Route 54 West
Clinton,IL 61727
Dates: May 4-8,1998
Inspector: James Foster, Senior Emergency Preparedness Analyst
Accompanying
Personnel: Serge Roudier, ISDN, France
Approved by: James R. Creed, Chief, Plant Support Branch 1
Division of Reactor Safety
9807100311 980707 7
PDR ADOCK 05000461
G PDR _
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EXECUTIVE SUMMARY
Clinton Nuclear Power Station, Unit 1
NRC Inspection Report 50-461/98009 .
This inspection reviewed a portion of the Emergency Preparedness (EP) program, an aspect of
Plant Support. This inspection included a review of documentation related to an actual
Emergency Plan activation, an evaluation of the quality of EP program related audits and
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- reviews, reviewed the effectiveness of management controls, verified the adequacy of
l' emergency response facilities and equipment, and included follow-up on previous inspection
findings. This was an announced inspection conducted by a regional inspector.
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Overall, the EP program has been generally maintained in an adequate state of operational
.readiness. Emergency response facilities, equipment, and supplies have generally been
adequately maintained, with some exceptions. ,
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. The Shift Supervisor's decision to classify an Alert in response to a loss of shutdown
cooling event on February 13,1998 was conservative and defensible. (Section P1.1.b)
-. Initial notifications of the Alert were made in a timely manner but contained some
inaccurate meteorologicalinformation. (Section P1.1.b)
. Involvement of the Shift Technical Advisor in making initial notifications detracted from .
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his primary duties. This was a repeat of events that occurred during the September 5,
1996 recirculation pump seal failure event. (Section P1.1.b.1)
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.- The Emergency Response Data System was not initiated within the required timeframe
of one hour after the Alert was declared. This was a violation. (Section P1.1.b.2)
. In one case, on-shift staffing was inadequate, because only one of two mechanical
maintenance workers on site was appropriately trained. This was a violation. (Section
P1.1.b.3)
. Control of in-plant operators was not well-coordinated between the main control room
(MCR) and the Technical Support Center (TSC). (Section P1.1.b.4)
. A timely and comprehensive critique of the Emergency Response Organization (ERO)
performance was held following the loss of shutdown cooling event. (Section P1.1.b.4)
. The call-in system and lack of ERO badges delayed TSC activation beyond goal
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'timeframes. This was a violation. A good decision was made to control facility access,
l- but security had to call the MCR for access approval for some personnel-a potential
Distraction at a critical time. (Section P1.1.b.5)
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i . The material condition of the Technical Support Center was marginal, as was noted in
the sa:t inspection. The failure of the TSC backup dose assessment laptop computer to
function indicated that its test frequency was not adequate. (Section P2.1)
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An excellent decision was made to continue the Emergency Operations Facility (EOF)
= training drill during the actual power loss to the EOF Participants coped well with the
effects of the power outage. Some emergency ceiling lighting allowed participants to
gather and position other lighting equipment. Dose projection could not be performed in
the EOF due to backup failures. _ All emergency exit lighting failed almost immediately.
Emergency power supplies failed quickly, well before expected failure times. . (Section
P4.1)
.- The licensee's 1997 and 1998 Emergency Preparedness (EP) audits were adequate
l and satisfied the requirements of 10 CFR 50.54(t). The audits were of adequate scope
and depth, but were weak in the area of equipment maintenance, particularly
considering identified equipment operability problems. (Section P7)
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Reoort Details
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IV. Plant Suncort
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P1 Conduct of Emergency Preparedness (EP) Activities
P1.1 Actual Emergencv Plan Activations
a. Insoection Scoce f 82701)
The inspector reviewed documents and logs related to the February 13,1998
declaration of an Alert due to loss of shutdown cooling. A detailed recount of events
related to the Alert response were previously included in NRC Inspection Report 50-
461/98003. The inspector also developed a chronology of emergency preparedness
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actions related to the event, which is attached to this report as Attachment 1.
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b. Findings and Observations
b.1 Initial Notifications for Alert Declaration
On February 13,1998, at approximately 3:41 a.m., Division 2 of the nuclear system
protection system (NSPS) bus deenergized, as indicated by multiple annunciators in the
main control room. The reactor water cleanup system then isolated and tripped. At
approximately 3:50 a.m., a review of the event classification system in procedure EC-02
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indicated that an Alert did not directly apply, as the suppression pool was available and
could cool the reactor via the residual heat removal (RHR) system.
The classification of an Alert was made at approximately 4:11 a.m., based upon the
shift supervisor's judgement that additional resources were required to deal with the !
situation, which was a conservative, defendable classification. Initial notifications were
made in a timely manner but contained some inaccurate meteorological information.
The licensee determined that the non-licensed operator (NLO) assigned to make initial
offsite notifications was unsure of his duties for making offsite notifications and was
- _ communicating with some difficulty. Emergency Plan Implementing Procedure (EPIP)
EC-07," Emergency Plan Notification," Section 4.1.3, specified that the responsibility for
completing notification to the State and NRC should not be assigned to the STA.
However, the shift technical advisor (STA) was directed to relieve the NLO and perform
the initial offsite notifications. This issue was previously documented in NRC Inspection
Reports 50-461/96010 and 97002 and indicates that the corrective actions for this
deficiency were ineffective. The inappropriate use of the STA to perform offsite
notifications was determined to be an inspection Followup Item (50-461/98009-01).
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b.2 . Activation of Emeraencv Resoonse Data System
A review of procedures and discussion with emergency response personnelindicated l
that activation of the ERDS system is accomplished through a two-step process. First, a
short series of entries must be made on a computer located in the TSC, in accordance
with EPIP EC-01, Form 16, "TSC Computer Operator." Then, a second short series of
entries must be made on a computer located in the plant simulator located in the
EOF / Training facility outside the protected area, in accordance with EPIP EC-01, Form
57," EOF Computer Operator." Procedurally, most EOF positions are not required to be
staffed at the Alert declaration.
A review of procedures and checklists and discussion with licensee personnel indicated I
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~ that procedures did not address assurance that activation of the ERDS system met the
requirements of 10 CFR 50.72, which indicates that the ERDS system will be initiated as 4
L soon as possible following an Alert or higher emergency declaration, but within one hour
in any case. Specifically, the Site Emergency Directors' procedure and checklist did not
prompt a verification that the ERDS system had been activated.
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A review of licensee and NRC logs and interviews of participating licensee personnel
indicated that the ERDS system had not been activated until 5:28 a.m., one hour and
seventeen minutes after the Alert declaration ca February 13,1998. This was
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determined to be a violation of 10 CFR 50.72 (60-461/98009-02).
b.3 Staffina of Emeroencv Resoonse Organization (ERO)
Through discussions with the licensee, the inspectors determined that the licensee had
not verified its ability to meet the minimum staffing requirements described in the
emergency plan. Upon further review, emergency planning personnel stated that .
Table 2-1 for shift staffing requirements were not met. Discussions with licensee
personnel indicated that on February 13,1998, the shift crew consisted of operations
personnel required for cold shutdown, three radiation protection technicians, seven
mechanical / maintenance personnel, two electrical maintenance personnel, and five
l' Control & Instrumentation personnel. One of the two electrical maintenance personnel,
a contractor, had not received emergency response organization training.
On the moming of February 13,1998, two electrical maintenance personnel were on
shift, but only one individual was trained and a member of the emergency response
organization (ERD). This was determined to be a violation of 10 CFR 50.72 (50-
461/98009-03).
10 CFR 50.47(b)(2) indicates, in part, that, in the licensee Emergency Plan, on-shift
facility licensee responsibilities for emergency response be unambiguously defined, and
adequate staffing to provide initial facility accident response in key functional areas be
maintained at all times.
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The CPS Emergency Plan, Section 2.1, " General," indicates that dedicated alternates in
i sufficient quantities have been assigned to fulfill primary emergency response positions
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and to perform their functions on a continuous (24-hour) basis. Section 2.2.7, "24-Haur l
Shift Complement," provides numbers and types of normal shift personnel during power I
operation, startup and hot shutdown and references Table 2-1. Table 2-1 indicates that
two mechanical maintenance personnel, able to respond to emergencies, would be on
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shift. Operating shift complement during periods of cold shutdown are not addressed in
l this listing. The plan specifies that in addition, one radiation protection technician and
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one chemistry technician are required to fulfill Table 2-1 requirements (NUREG-0654,
Table B-1). The CPS Emergency Plan also specifies that in accordance with CPS
, Technical Specifications and the Operational Requirements Manual (ORM), the number .
of personnel required to fill main control room positions may be reduced when the plant
is in Condition 4 (Cold Shutdown). Table 2-1 itself does not address plant operational
modes. Additionally, the NUREG-0654, Table B-1, also does not allow that individuals
l not part of the ERO can be placed into those positions.
Emergency planning personnel stated that it was their expectation that each affected
department was responsible for ensuring minimum staffing requirements were met. The
inspector interviewed operations, maintenance, and radiation protection managers and
determined that the affected departments could not explain how the minimum
emergency plan requirements were met for on-shift and 30-minute responders. In
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addition, the licensee could not identify how collateral assignments were performed. For !
example: (1) emergency planning believed operations personnel could perform l
radiological self-monitoring; however, radiation protection personnel stated that
operations personnel were not qualified to perform s J-monitoring; and (2) emergency
planning personnel believed that operations personnel could satisfy the requirement for
mechanical and electrical maintenance activities; however, the licensee was unable to
determine if operators possessed the requisite skills and abilities to perform
maintenance tasks. Discussion indicated that a procedure did not exist which would
assure that the commitments in Emergency Plan Table 2-1 were met.
b.4 : TSC Activation
The chronology of events indicates that the TSC activation was slow. The CPS
Emergency Plan indicates that it is the station's goal to achieve staffing additions within
the times specified (30 minutes and 60 minutes)in Table 2-1. During the Alert event on
February 13,1998, the resident inspectors noted that the OSC was staffed and
activated at 5:26 a.m.,1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 15 minutes after the Alert declaration. The inspectors
noted that a time requirement for activating the OSC was not specified in the
Emergency Plan nor Emergency Plan Implementing Procedure (EPIP). However,
Emergency Plan Table 2-1, "Clinton Power Station Minimum Staffing," specified
30-minute and 60-minute staffing addition goals for personnel.
Specifically, the .30-minute positions for inplant surveys, radiation protection personnel,
. and supervisor-technical or alternate were filled after more than 37 minutes. The
' 60-minute position for radiation protection personnel was filled after more than
75 minutes. The mechanical engineer position was not filled with a designated
individual; however, personnel were present who could have filled the position. The
60-minute electrical maintenance position was filled by an individual who was not ERO
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l qualified. As filling the 30-minute responder positions was specified as a goal, a
violation did not specifically occur.
As an interim measure, the licensee designated seven additional personnel to the on-
shift minimum staffing requirements from the maintenance and radiation protection
departments. Discussion with licensee personnel indicated that, following the
February 13,1998 event, individuals listed as thirty-minote responders had been placed
on-shift as immediate corrective action. In addition, personnel with 30-minute and 60-
minute response requirements were selected based on the proximity to the site and
were briefed on the expediency of their response. Licensee personnelindicated that,
based on their experience during the Alert and analysis of the responders needed to
properly respond to any event, it was their intent to revise table 2-1 to delete 30-minute
responders, while increasing those on shift, and submit this for NRC review and
approval.
Emergency planning personnel stated that previous off-hour notification drills did not
account for the delay in activation of the autodialer. Approximately 10-12 minutes
elapsed between emergency classification and notifications by the autodialer. Addition
of the 10-12 minute autodialer delay to ERO member response times resulted in the
failure to verify that 30-minute and 60-minute stsffing goals could be met.
The CPS Emergency Plan, Section 2.3.1.4, indicates that upon declaration of an
emergency, reactor operators, non-ficenset. operators, and other operations shift
personnel shall report to the MCR and shall perform station operations under the
direction of the Assistant Shift Supervisor in accordance with established normal and
emergency procedures. However, EPIP EC-12. " Emergency Teams," required that the
Site Emergency Director (SED) authorize the formation and dispatch of emergency
teams.
During the Alert declaration of February 13,1998, the licensee determined that the SED
was not always aware of operations teams formed and dispatched by the Assistant Shift
Supervisor. The lack of oversight by the SED resulted in communication problems
regarding restoration of plant equipment. For example, personnel in the TSC believed
that three fill-and-vent processes of the RHR system occurred, but actually there were
only two occurrences. The MCR had completed a check list for an NSPS outage while
the TSC/OSC was developing a team to perform the same checks. The oversight of
field teams by the TSC/OSC is a repeat deficiency from the October 1997 exercise. The
method by which the SED will coordinate inplant operator activities and authorize and
control the formation and dispatch of field teams should be clearly procedurally defined.
This item Unresolved Item (50-461/98003-17) is closed, converted to an Inspection
Followup Item (50-461/98009-04), pending appropriate demonstration of capability to
appropriately track field teams during an evaluated exercise.
b.5 ERO Badc_ e Use
EPIP EC-09, " Security During Emergencies," Section 4.5, "ERO Personnel
Identification," specified that members of the ERO were issued emergency access
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badges to allow entry into the protected area and emergency facilities in the event of an
emergency. The individuals issued such badges would need them in their possession to
allow for planned entries during emergency conditions. Section 4.6.2 indicates that at
an Alert or higher emergency declaration, Secu'ity Force Members should control
access to the Operations Support Center (OSC) and TSC. Section 4.6.3 states that
Security Force Personnel or EOF Access Control Coordinator shall grant access to the
Protected Area and emergency response facilities to the following individuals:
l Emergency Response Organization personnel. . Interviews of security personnel on shift
during the morning of February 13,1998 indicated that 70-80% of those responding to
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the Alert did not have their ERO badge with them. Discussion with EP personnel,
indicated that procedures and plant policy adequately addressed the issue.
The licensee determined that personnel did not have or were unaware of the need to
have an ERO badge. Not having an ERO badge in their possession created delays in
gaining access to the protected area in that security personnel were required to verify
ERO members against a non-alphabeticallisting of ERO personnel sorted by assigned
position. ~An alphabetical list was available; however, security personnel were unable to
locate the list during the event. Some individuals could not be immediately identified as
on the listing. This delayed responders from processing through security and reporting
to the TSC. In at least two cases, the security log indicated that the SED was contacted
to request site access authorization for individuals. Contacting the SED under suh
circumstances is extremely undesirable, potentially distracting him from his nuclear
safety emergency responsibilities at a critical time. Not possessing an ERO badge
could additionally delay the response to the facility if state and local authorities
established road blocks to minimize access to the plant. This was determined to be a
violation (50-461/98009-05).
b.6 ERO Performance Critiaue
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. The inspector reviewed Critique Report OPS-98-007, dated February 23,1998, _
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documenting the critique held between 7:30 a.m. and 4:00 p.m. on February 14,1998. l
The critique was timely and relatively comprehensive, covering the time period
preceding and following the Alert and identifying weaknesses and opportunities for
improvement in numerous areas. The critique did not identify that the ERDS system
was not initiated in the required timeframe. A relatively detailed chronology of pre- and
. post-incident activities was developed as a part of the critique process. While noting
that the Emergency Planning group was preparing a more comprehensive critique of the
emergency plan activation and response, the critique report identified the following
emergency planning weaknesses:
1. The NLO had difficulty in preparing the initial notification message. The STA
had to provide assistance.- The initial message referenced the incorrect
downwind sector.
2. The call-out process did not ensure the timely activation of the TSC, which
was activated 37 minutes after the activation goal.
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3. Incorrect meteorological data was transmitted.
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4. On-site announcements were infrequent.
5. Coordination and direction of on-shift operator resources once the TSC/OSC
activated was a problem.
Some of the more significant licensee corrective actions included creating four
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during July 1998, and significantly enhancing the tests of the pager and callout system.
Corrective actions were in process or planned in a number of areas.
Conclusions
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The Shift Supervisor's decision to classify an Alert was conservative and defensible.
L Involvement of the STA to make initial notifications was improper and a repeat of events
from the September 5,1996 seal failure event. Notifications were made in a timely
manner but contained some inaccurate meteorological information. On-shift emergency
response staffing was inadequate. The call-in system, and lack of ERO badges delayed
TSC activation beyond goal timeframes. A good decision was made to control facility
access, but security had to call the MCR for access approval for some personnel which
was a potential distraction at a critical time. Control of in-plant operators was not well-
coordinated between the MCR and the TSC. A timely and comprehensive critique was
held following the incident. Violations were identified regarding use of the STA to make
initial notifications, initiation of the ERDS system, on-shift staffing, and use of ERO
badges.
- 2 Status of EP Facilities, Equipment, and Resources
P2.1 Material Condition of Emergency Response Facilities (ERFs)
a. Insoection Scone (82701)
The inspector evaluated the material condition of the control room, TSC, OSC, and -
Emergency Operations Facility (EOF). The licensee demonstrated the operability of
. several pieces of emergency response equipment, including radiological survey
instruments, dose assessment computers, and communications equipment.
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. b. Observations and Findings
b.1 - Emeroency Resoonse Facilities' Material Condition
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The control room was well-maintained and had current EP procedures available. The ,
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maintained, with sufficient supplies available, and instrumentation was operable and
within calibration periods.
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The EOF was well-maintained with adequate supplies, current plans and procedures,
and operable survey instrumentation within calibration periods. As noted later in this
report, a drill conducted during a power outage indicated some problems with facility
equipment.
The TSC was in marginal material condition, as identified in the last inspection, with a
conduit modification adding a considerable tripping hazard. A laptop computer (labeled
PC 173), intended as the backup computer for performance of offsite dose assessment,
. was inoperable, apparently because of insufficient battery power. Two hand calculators
were noted to be of older vintage, using unique input methods which might not be
familiar to some individuals. .
Telephones, computer terminals, and other equipment were tested and found operable.
Current procedures were available in the facilities.
b.2 Paoer Tests
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The inspector reviewed the results of recent pager tests, and discussed plans for future !
pager tests with licensee personnel. Response to the pager and autodialer system was l
an identified problem during the Alert declaration. Previously, pager tests were i
conducted the first Tuesday of the month to test the system function. Responses to the
autodialer system were not included in these tests. Therefore, testing had not provided
- assurance that individuals would respond properly.
Recent pager test results were as follow:
3/24 10:00 a.m. 27 A team members not responding.
3/25 9:30 a.m. A team on call; 11 members not responding.
3/25 2:00 p.m. Pager problems ; test a failure, vendor troubleshoots.
3/27 9:00 a.m. A team on call; 100% response.
4/02 9:00 a.m. B team on cail; 14 members not responding.
4/03 10:30 a.m. B team on call; 5 positions not filled, one a key position. !
4/07 10:00 a.m. B team on call; 4 members not responding. !
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4/14 7:00 p.m. B team on call; 8 members not responding.
4/20 9:00 p.m. B team on call; 1 member not responding. i
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in response to early pager test results and identified problems during the Alert event, on
April 8,1998, the Senior Vice President provided a memorandum to all nuclear program
employees which indicated the importance of emergency response organization. This
memorandum clearly conveyed the expectation that on-call ERO personnel will be
. prepared at all times to support activation of the emergency facilities within the
established timeframes. In general, review of the pager tests results indicated an
- improving trend.
Dismssion with licensee personnel indicated that an alphanumeric pager system had
been selected to replace the system currently provided to key ERO personnel, allowing
short event classification messages in addition to the response telephone number to be
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' displayed on the pager. In addition, a comprehensive system of pager tests and drills l
were planned, consisting of four types of, tests / drills: I
' 1. Daytimo pager function tests, conducted for each team, to verify that the
team menicers which will be on call possess a functional pager.
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2. Off-hours " call back" pager tests, with responders calling back to verify
system operation, to be conducted once per month.
l 3. Off-hours notification drills, utilizing the autodialer syst'em to fill key positions
j and perform an estimate of response time, to be conducted twice per year.
l. 4. An off-hours response drill, where the pagers would be activated, the
- autodialer system would fill positions, and responders would actually report to
the site, to be conducted a minimum of once per year.
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l c. Conclusions
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i Facilities had been generally maintained in a good state of operational readiness, with I
, some exceptions.- The material condition of the TSC was marginal, as in the last
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inspection. The failure of the TSC backup dose assessment laptop computer indicated j
! that its test frequency was not adequate. Review of pager tests indicated an improving '
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trend. A comprehensive pager and callout testing program had been outlined by the
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P4 Staff Knowledge and Performance in Emergency Preparedness
P4.1 Emeraencv Ooerations Drill Observation
- a. Insoection Scooe (82701)
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On May 6,1998, the inspectors observed a drill conducted in the Emergency Operations
Facility,
b. Observations and Findings
On the morning of the drill, the 12-kilovolt power line supplying the building housing the
. EOF / Simulator / training facilities was lost at approximately 7:30 a.m. The licensee
decided to proceed with the drill as realistic training exercise in coping with a power loss
in an emergency facility. The drill began at approximately 9:20 a.m. The inspectors -
L . focused their evaluation on the impact of the loss of power on the facility and the
participants, rather than on drill participant performance. However, it was observed that
participants displayed a good attitude, and excellent "drillsmanship" was demonstrated.
' Where necessary, participants improvised methods of coping with the power loss.
The inspectors observed that the exit signs throughout the EOF / simulator / training facility
failed to illuminate on loss of power. These exit lights had internal batteries, a light-
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l emitting diode indicator, and a test button on the exterior, and were intended to
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illuminate both the exit sign and the area immediately beneath the exit sign. Discussion
with electrical maintenance personnel indicated that the units had not been maintained
or tested for an extended period.
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Subsequent discussion indicated that exit lights are covered by OSHA regulations in
i 10 CFR 1910, but their illumination is not addressed. The National Fire Protection Act
(NFPA) Life Safety Code, incorporated into law in the State of Illinois, indicated in
Section 101-49,5-10.3 that such signs shall be suitably illuminated by a reliable light
source. Extemally and intemally lighted signs shall be legible in both the normal and
emergency lighting mode. Licensee personnel indicated that the internal batteries of the
exit lights in the facility would be replaced. This was an Inspection Followup Item (IFI)
l 50-461/98009-06.
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The eight installed emergency lighting ceiling units illuminated well, and remained
illuminated for a period which was more than adequate for drill participants to obtain
provided florescent lights and flashlights. By 9:40 a.m., three of the ceiling units had
dimmed and fai!ed. At 10:08 a.m. two of eight ceiling units remained in operation.
Administrative personnel rapidly positioned florescent lights in predetermined positions
above status boards, utilizing plastic chains. Emergency lighting in the facility was
adequate for facility operation for an extended period of time. A portable public address
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system was available for EOF staff briefings. Exercise participants coped well with the
power outage. The portal monitor located at the front entrance to the EOF was
observed to be operating acceptably on internal battery power.
Three uninterruptible power sources (UPS) were located in the EOF. One unit,
powering a large digital clock, failed quickly as the clock was not illuminated at
approximately 7:30 a.m. when the inspectors arrived at the facility. Failure of this unit )
had little impact. A second unit, powering a facsimile machine, failed shortly after the 1
drill began and prior to any documents being sent or received. A third unit (located in l
the dose assessment room), intended to power the radios for the field monitoring teams, i
failed within seconds of the start of the drill at the start of the initial radio check with field
monitoring teams. Hand-held radios were available for communicating with field teams,
but these units had an optimum range of approximately two miles. Discussion indicated
that field teams had coins for telephones or could relay messages, but this would make
communications with the field teams very difficult. Failure of the field team's radio UPS
had the impact of making communication with the field teams from the EOF difficult if
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. not impossible. Evaluation of the adequacy of the EOF UPS systems was an Inspection
Followup item (IFI) 50-461/98009-07.
The primary dose assessment computer was unavailable due to the power outage, and ;
the failure of the field team radio UPS (adjacent to the dose assessment computer) i
L eliminated any option for powering the computer. An immediate attempt was made to j
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utilize the backup dose assessment laptop computer, but it failed to function due to lack
of battery. charge. An alternate laptop computer was obtained from elser;here in the
building, but it was not loaded with the dose assessment software (Mesorem 96). After
locating copies of the dose assessment software (Mesorem and an evaluation copy of
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Mesorem 98), attempts were made to load and run the program, but the loaded program
repeatedly retumed error messages and would not function.
The manual (paper) dose assessment method was attempted. This method utilizes
several sheets of calculations, and would be expected to produce somewhat different
results from the computerized method. One of the Hewlett-Packard calculators would
not function, and attempts were made to locate a replacement battery. The individual
tasked with dose assessment appeared unfamiliar with the manual method and
expressed lack of familiarity with the supplied Hewlett-Packard calculator. Discussion
indicated that the dose assessment individual was appropriately trained but was
unfamiliar with the supplied calculator and was slow as a result. The drill participants
chifted responsibility for dose assessment back to the TSC for drill purposes. Licensee
personnel indicated that the laptop computers intended for backup dose assessment
calculations in the TSC and EOF would be reviewed for replacement, and the older
model calculators would be replaced. Dose Assessment capability in the EOF was an
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inspection Followup Item (IFI) 50-461/98009-08.
During the drill critique, licensee personnel identified that a portable printer battery also
did not fu"ction. The laboratory and decontamination area were properly set up to
receive field team samples as needed.
Conclusions
The licensee made an excellent decision to conduct the d niven that power to the EOF
had been lost. Participants demonstrated both a good attituoe and "drillsmanship"in
coping with the effects of the power outage. The emergency ceiling lighting system
worked well, allowing participants to gather and position other lighting equipment. All
emergency exit lighting failed almost immediately. Emergency power supplies failed
quickly, well before expected failure times. Dose projection could not be performed in
the EOF due to backup failures. Three followup items were identified.
P6 EP Organization and Administration
The emergency planning organization consisted of a Supervisor / Emergency Exercises
and a Supervisor / Emergency Planning, each directly supervising one individual. An
Emergency Planner had recently been added to the organization. The two supervisors
reported to the Director, Security and Emergency Planning, who reported to the
Manager, Nuclear Training and Support. The Manager, Nuclear Training and Support
reported directly to the Senior Vice President and Chief Nuclear Officer.
P7 Quality Assurance in EP Activities
a. Insoection Scooe (82701)
The Inspector reviewed Nuclear Assessment Audit Report " Emergency Response /
Emergency Operating Procedures," Audit Number Q38-97-03, and Quality Assurance
Audit Report " Emergency Response / Emergency Operating Procedures," Audit Number
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l Q38-98-07. A Technical Review" performed by a seven-person team of industry
emergency preparedness experts was also reviewed.
b. Qhgervations and Findinas '
Audit Q38-97-03 was performed by a six-person team March 17- April 11,1997, and
included an evaluation of the adequacy of Emergency Operating Procedures (EOPs),
and EOP training. The audit report, issued April 29,1997, stated that the emergency '
response and EOP programs were effectively implemented. The audit resulted in one
audit finding and five condition reports. The audit section dealing with EOPs was not
extensive, but EOPs are emergency procedures not directly related to emergency
preparedness and could dilute the EP audit effort.
Audit Q38-98-07 was performed by a six-person team March 9-27,1998, and also
included an evaluation of Emergency Operating Procedures (EOPs) and EOP training.
The audit did not resuit in any audit findings or recommendations but noted that the use
of pagers and autodialer for calling in personnel had been self-identified prior to the
audit as an area requiring further evaluation. The audit noted the declining operability of
the Post Accident Sampling System and the review and assessment of the emergency
preparedness program by a team of utility experts in Emergency Planning. The audit
concluded that no problems which required CPS to take corrective action or initiate any 1
corrective action documents were noted during the review. The inspector's review of l
the document indicated that the review had generated a number of recommendations
which should be recorded and tracked within the corrective action tracking system.
Both above audits encompassed interviews with offsite authorities to verify that the
interface with the state and local governments had been effective in satisfying the
requirements of 10 CFR 50.54(t), which requires this review. Audit Q38-97-03 '
contained an excellent, standardized list of questions to be addressed during such
interviews. The audits were of adequate scope and depth but, considering identified
maintenance problems, should focus more on equipment operability and maintenance.
Including a review of EOPs and related training in an emergency planning audit may
dilute the primarily emergency planning aspects of an audit.
A "TF.hnical Review" was conducted by a seven-member team of industry emergency
pt6wedness experts during the period of March 23-27,1998. Eight specific program
arne.1 were selected for the group's review, as follows:
1. Table 2-1 of the CPS Emergency Plan.
' 2. Emergency Response Organization structure and concept.
3. Technical Support Center & EOF staffing goals.
4. Emergency Response Organization notification process.
5. Offsite official notification process.
6. Emergency Preparedness Training Program.
7. Emergency Preparedness drills.
8. Management support for the Emergency Preparedness program.
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! The Technical Review groups report, dated April 3,1998, provided numerous
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observations, conclusions, and recommendations. It was not clear that these
recommendations had been comprehensively reviewed to determine whether they fell
within already identified and tracked corrective actions, or whether they represented
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new issues which should be tracked for resolution.
c. Conclusions
The licensee's 1997 and 1998 EP audits were adequate and satisfied the requirements
of 10 CFR 50.54(t). The audits were of adequate scope and depth but, considering
identified maintenance problems, should focus more on equipment operability and
maintenance. Including a review of EOPs and related training in an emergency planning
audit may dilute the (marily emergency planning aspects of an audit. The " Technical
Review" self-assessn. J identified issues which needed further reviews and to be
appropriately tracked for resolution.
P8 Miscellaneous EP lssues
USAR Review
Emergency Preparedness was addressed in Updated Safety Analysis Review (USAR)
Section 13.3," Emergency Planning." In the March 1997, Revision 7 edition of the
USAR, this section was completely revised to appropriately provide a general overview
of Clinton Power Station Emergency Plan. No problems were identified.
P8.1 (Closed) Violation (VIO) No. 50-461/97002-01: Failure to maintain the backup
meteorological tower. Discussion with licensee personnel indicated that the backup l
meteorological tower had been restored to service. This item is closed.
P8.2 (Closed) Insoection Followuo item (IFI) No. 50-461/97002-02: Changes needed to the l
Emergency Plan to clearly indicate commitments to do dose assessment. This item is l
closed.
P8.3 (Ocen) Insoection Followuo item (IFI) No. 50-461/97022-02: Training needed regarding
requesting additional operator resources. This item will remain open pending
completion of the proposed training.
P8.4 (Ocen) Insoection Followuo item (IFI) No. 50-461/97022-04: Correction to training on
Emergency Operating procedure number 6. This item will remain open pending
completion of the proposed training.
P8.5 (Closed) Unresolved item (URI) No. 50-461/98003-10: Use of Shift Technical Adviser to
perform initial emergency notifications. This item, identified by the Senior Resident
inspector, was unresolved pending regional specialist review. This item was reviewed
during this inspection and is addressed as a Inspection Followup Item in section P1.1 of
this report. This item is closed.
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! P8.6 (Closed) Unresolved item (URI) No. 50-461/98003-11: ERDS system. This item,
identified by the Senior Resident inspector, was unresolved pending regional specialist
review. This item was reviewed during this inspection and is addressed as a violation in
section P1.1 of this report. This item is closed.
P8.7 (Ocen) Insoection Followuo item (IFI) No. 50-461/98003-12: Reliability of the ND-6685
computer. The licensee discussed future upgrades to the plant computer systems
, which would improve the reliability of the information currently handled by the ND-6685
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system. These changes were not intended to be implemented for some time. This item
will remain open.
- P8.8 '(Ooen) Insoection Followic, item (IFI) No. 50-461/98003-13
- Ability to complete follow-
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up state notifications. TW, item will remain open pending appropriate demonstration in
an evaluated exercise. I
P8.9 (Ocen) Insoection Foi.awuo item (IFI) No. 50-461/98003-14: Ability to activate the
Technical Support Center in an hour. The CPS Emergency Plan, section 3.1.2.2,
! " Staffing," indicates that the TSC will be activated upon declaration of an Alert or higher. ,
"Upon activation of the TSC, designated personnel shall report to the TSC so as to be l
fully operational within about one (1) hour." This item will remain open pending
appropriate demonstration in an evaluated exercise.
P8.10 (Closed) Unresolved item (URI) No. 50-461/98003-15: Inability to ensure Emergency
Plan Table 2-1 minimum staffing requirements were met. This item, identified by the
Senior Resident inspector, was unresolved pending regional specialist review. This item
was reviewed during this inspection and is addressed as a violation in section P1.1 of
this report. This item is closed.
, P8.11 - (Ocen) Insoection Followuo item (IFI) No. 50-461/98003-16: Activation and response of
!~ the autodialer system. The licensee indicated the current system would be revised to
provide the telephone number for responders to call, and the autodialer program would
p be upgraded with an improved logic system which would provide flexibility in assigning
. higher level positions. A newer autodialer with enhanced speed and capacity was in the
process of being purchased. It was planned that this unit would undergo a test period
and then be the primary autodialer, with the present unit serving as a backup. The
,
backup unit would receive upgraded with newer software. Additional pager and
l autodialer testing was planned, as noted in section P2.1 of this report. Training would
l . be provided to station personnel after the upgrades to software and equipment were
installed. This item will remain open pending implementation and NRC review.
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. P8.12 (Closed) Unresolved item (URI) No. 50-461/98003-17: Site Emergency Director control
of inplant teams. This item, identified by the Senior Resident inspector, was unresolved
pending regional specialist review. This item was reviewed during this inspection and is
addressed as an inspection Followup Item in section P1.1 of this report. This item is
closed.
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E.
P8.13 (Ocen) Insoection Followuo Item (IFI) No. 50-461/98003-18: Transfer of Command and
Control from the Main Control Room to the Technical Support Center. Licensee
personnel indicated that Shift Supervisors were advises that priorities for response
efforts should be well communicated during response efforts. This item will remain open
pending appropriate demonstration in an evaluated exercise.
P8.14 (Closed) Unresolved item (URI) No. 50-461/98003-19: Emergency Response Badge
problems. This item, identified by the Senior Resident inspector, was unresolved
pending regional specialist review. This item was reviewed during this inspection and is
addressed as a violation in section P1.1 of this report. This item is closed.
P8.15 (Ocen) Insoection Followuo item (IFI) No. 50-461/98003-20: Sample control in the
Emergency Operations Facility. This item will remain open pending appropriate
demonstration in an evaluated exercise.
P8.16 (Ocen) Insoection Followuo item (IFI) No. 50-461/98003-21: Control Room to Technical
Support Center communication. This item will remain open pending appropriate
demonstration in an evaluated exercise.
P8.17 (Ocen) Insoection FolMMin item (IFI) No. 50-461/98003-22: Ability to disseminate
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information to plant personnel. During the February 13,1998 event, few inplant
announcements were made. This item will remain open pending appropriate
demonstration in an evaluated exercise.
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V. Management Meeting
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l X1 Exit Meeting Summary
The inspector presented the inspection results to licensee management at the conclusion of the
onsite inspection on May 8,1998. The licensee acknowledged the findings presented.
The inspectors asked the licensee whether any materials examined during the inspection
should be considered proprietary. No proprietary information was identified.
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PARTIAL LIST OF PERSONS CONTACTED
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H. Anagnostopoulous, Radiation Protection
K. Evans, Emergency Planning
J. Gearhart, Quality Assurance
S. Goldman, Consultant, Crisis Media
M. Hiter, Quality Assurance
G. Hunger, Plant Manager
W. MacFarland IV - Senior Vice President
W. Maguire, Director - Operations ,
J. Palchak, Manager, NT&S
R. Phares, Manager, NSPI ;
J. Pruit, Quality Assurance '
T. Roe, Maintenance
J. Sipek, Director, Licensing
D. Smith, Director, Security and Emergency Planning
M. Stickney, Licensing 4
J. Taylor, Director, Administration l
W. Yaroz, Emergency Planning
NBC
T. Pruett, Resident inspector
INSPECTION PROCEDURES USED
IP 82701 Operational Status of the Emergency Preparedness Program
ITEMS OPENED, CLOSED, AND DISCUSSED
Ooened
50-461/98009-01 IFl Use of Shift Technical Advisor to perform initial notifications.
50-461/98009-02 VIO Failure to initiate ERDS as soon as possible or within one hour of
an Alert or higher emergency declaration.
50-461/98009-03 VIO Failure to have sufficient trained response personnel on-shift.
50-461/98009-04 IFl Procedural definition of how the SED will control inplant teams.
50-461/98009-05 VIO Failure to have Emergency Response Organization badge to
facilitate entry to the Protected Area and response facilities.
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50-461/98009-06 IFl Exit signs did not illuminate in the Emergency Operations Facility.
50-461/98009-07 IFl Uninterruptible power supplies in the Emergency Operations
Facility did not function for an acceptable length of time.
50-461/98009-08 IFl Inability to perform dose projection in the Emergency Operations
Facility using any of the backup methodologies.
Closed
50-461/97002-01 VIO Failure to maintain the backup meteorological tower.
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50-461/97002-02 IFl Changes needed to the Emergency Plan to clearly indicate
commitments to do dose assessment
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50-461/98003 10 URI Use of Shift Technical Adviser to perform initial emergency i
notifications.
50-461/98003-11 URI ERDS system initiation.
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50-461/98003-15 URI Inability to ensure Emergency Plan Table 2-1 minimum staffing
l requirements were met.
50-461/98003-17 URI Site ' Emergency Director control of inplant teams.
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50-461/98003-19 - URI Emergency Response Badge problems.
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LIST OF ACRONYMS USED )
CFR Code of Federal Regulations
CPS Clinton Power Station <
i CR Condition Report
DRP Division of Reactor Projects 4
l DRS Division of Reactor Safety
EAL Emergency Action Level
EOF Emergency Operations Facility
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EOP Emergency Operating Procedures i
l EPIP Emergency implementing Procedures
{
ERF Emergency Response Facilities
ERO Emergency Response Organization
EPIP Emergency Plan implementing Procedure ;
ERDS Emergency Response Data System )
ERO Emergency Response Organization
IDNS lilinois Department of Nuclear Safety
IFl Inspection Followup Item
MCR Main Control Room i
NARS Nuclear Accident Reporting System l
NLO Non-licensed Operator
NPF Nuclear Power Facility l
NRC Nuclear Regulatory Commission
NRR Nuclear Reactor Regulation
NSPS Nuclear System Protection System
ORM Operations Requirements Manual
OSC Operations Support Center
, PDR Public Document Room
RO Reactor Operator
l RPT Radiation Protection Technician
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SED Station Emergency Director )
SRI Senior Resident inspector
STA Shift Technical Advisor
TAS Technical Assessment Supervisor
USAR Updated Safety Analysis Report :
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ATTACHMENT 1 1
EP CHRONOLOGY. FEBRUARY 13.1998
0341 Division 2 of NSPS bus deenergizes as indicated by multiple annunciators in the l
control room. Reactor Water Cleanup isolates and trips. I
L '0350 Review of EC-02,6.1 Alert does not apply as suppression poolis available and can
cool via RH "a" in suppression pool cooling.
0411 EC-02, Emergency Classifications, Emergency Action Level 13.6 declared; Alert in
order to activate TSC/OSC for additional help.
0414' Emergency Response Organization Notification System (ERONS) activated for Alert.
04'.9 Nuclear Accident Reporting System (NARS) form approved.
0421' State of Illinois notified over NARS system telephone.
m 0435 NARS form transmitted, error in affected sector.
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0443 NRC notification form, notification time 0545 (EDT.)
0526 OSC activated.
0527 . Joint Public Information Center (JPIC) activated. !
0528 NRC started receiving Emergency Response Data System (ERDS) data.
0537 NRC briefed on plant status.
0545 TSC activated. Bedford has command & control.
0606 NRC reports ERDS is off.
0611 ERDS again operational.
0615 State followup message.
0708 Decision made to allow non-essential personnelinto the protected area.
0715 State followup message.
0708 Access to protected area restored for non-essential personnel.
0745 Area Radiation Monitor / Process Radiation Monitor (AR/PR) operator notes apparent
discrepancy between IDNS meteorological data and AR/PR data. National Weather
Service (NWS) contacted.
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0809 NRC briefed on estimated time to Reactor Coolant System (RCS) boiling, estimated
to be approximately 41 hours4.74537e-4 days <br />0.0114 hours <br />6.779101e-5 weeks <br />1.56005e-5 months <br />.
0810 State followup message.
0820 Notified Illinois Department of Nuclear Safety (IDNS) of problem with data on AR/PR
system, plant process data current and correct.
0855 Rescinded orwr to evacuate containment building.
0940 NRC updated on plant status.
0945 Reactor Heat Removal system (RHR) a restored. NRC notified.
0958 Total Reactor Coolant System (RCS) heatup 4 degrees F.
1002 State followup message.
1004 Alert terminated.
1009 Termination NARS form transmitted. NRC informed and provided status of plant.
1009 Completed notification of state.
1030 tilinois Power conducts a news conference at the Joint Public Information Center.
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February 14,1998
0730-1600 Critique conducted.
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