IR 05000298/1987025

Ack Receipt of NRC 871210 Ltr Re Six Deficiencies Noted in Insp Rept 50-298/87-25.One Area Needs Clarification.Three Events Observed During Emergency Exercise.Requests Schedule for Correcting Deficiency 298/8725-02 within 30 Days

ML20148J972
Person / Time
Site:	Cooper
Issue date:	01/22/1988
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Trevors G NEBRASKA PUBLIC POWER DISTRICT
References
NUDOCS 8801270518
Download: ML20148J972 (2)

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Ap = JAN 2 2 KE8 In Reply Refer To:

Docket: 50-298/87-25-Nebraska Public Power District ATTN:. George A. Trevors Division Manager - Nuclear Support P. 0.-Box 499 Columbus, NE 68601'  ;

Gentlemen:

Thank you for your letter of December 10, 1987, in response to our lette l dated November 6, 1987. We have reviewed your reply to the six deficiencies identified in our report. The response in your letter was duscussed with Mr. R. Hayden of your staff on December 30, 1987. In your response, there is one area that needs additional clarificatio In your response to deficiency number 298/8725-02,- you quoted NUREG-0696 and the need for face-to-face communications between Technical Support Center (TSC) and Control Room (CR) personnel. The face-to-face method of communicating is beneficial, but not a substitute for the primary method of information exchange between Emergency Response Facilities (ERF), which should be by direct telephone from the TSC to the Control Roo The three events ob. served during the emergency exercise highlighted weaknesses in the exchange of vital information between CR and TSC staffs, We believe that a review of this area is in order. This review should identify kinds of information that need to be exchanged between ERFs, the~ organizational elements in charge of transmitting and receiving various types of information, and the means used to transmit and receive each type of information, Additionally, procedures should designate responsibilities and describe necessary actions and equipmen It is requested that within 30 days after the receipt of this letter you provide this office with a schedule for correcting deficiency number 298/8725-0 Your reply to the other five deficiencies identified was considered adequat We will review the implementation of your corrective actions during a future inspectio

Sincerely, M S e nt Bp

%[2{gy g$ e L J. CALLAN O

L. J. Callan, Director Division of Reactor Projects cc: (see next page) E RIV:NMEPB W ( C:NMEPB l

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Guy Horn, Division Manager-of Nuclear.0perations Cooper Nuclear Station P. 0. Box 98

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Brownville, Nebraska 68321 Program Manager FEMA Region 7 911 Walnut Street, Room 200 Kansas City, Missouri 64106 Director-Nebraska' Civil Defense Agenc '1300 Military Road Lincoln, Nebraska 68508 Kansas Radiation Control Program Director Nebraska Radiation Control Program Director bec w/ltr from licensee dtd 11/06/87:

DMB - IE35 DRP/C DRP RRI R. D. Martin, RA Section Chief (DRP/C) L. Shea, RM/ALF TSS MIS System RIV File Project Engineer, DRP/C RSTS Operator W. Long, NRR Project Manager R. E. Hall DRS Inspector (s) W. L. Fisher l R. L. Bangart D. B. Matthews, NRR NMEPB t

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GENERAL OFFICE Nebraska Public Power District " * ""u'EiE*n$$'s*2MP"" _

NLS8700649 December 10, 1987

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U.S. Nuclear Regulatory Commission j EC l 8 %I Attention: Document Control Desk l

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Gentlemen: -

Subject: NPPD Response to Inspection Report 50-298/87-25 This letter is written in response to your letter (undated), transmitting Inspection Report 50-298/87-25. Therein you identified six (6) deficiencies in our emergency preparedness program observed during the 1987 annual emergency exercise. The following is our response to the deficiencies noted:

Deficiency 1 (285/8725-01)

The NRC inspector noted that not all notifications originating from the Control Room (CR) to offsite authorities were made in a timely or consistent manne The Emergency Director (ED) declared the Alert at 8:34 a.m.i however:

The authorities of the State of Nebraska were notified of the Alert at 8:51 *

The authorities of the State of Missouri were notified of the Alert at 8:55 *

The ED did not declare a Site Area Emergency until about 26 minutes after plant conditions warranted the sam As a consequence, notifications to offsite authorities pertaining to this escalation in accident severity were delaye Response The Emergency Director was fully aware of simulated plant conditions during the time frame immediately preceding the declaration of a Site Area Emergenc Time was spent in confirming all indication Regulations do not dictate the amount of time to be used in classification and verification of an emergenc It is felt that an erroneous or premature declaration of a Site Area Emergency would not be pruden Notification procedures will be revised to make the exact time of an emergency declaration for an alert or higher classification a part of the plant public address emergency announcement. It will also be reflected in the notification form used by the Control Room Communicator. This will be completed by February 29, 198 ' . e 7t y S W '

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P:gs 2 6 O ,.Dienbar 10,11987 Deficiency 2 (285/8725-02)

Information . ' pertaining to. plant status was not conveyed from the CR to the TSC in a timely manner, as follows:

Information about the discharge-volume drain valve being inoperative at 9:15 a.m. was not received in the TSC until 9:27 *

At 10:03 a.m., the CR mandated through -the public address system the evacuation of the Reactor Building due to high radiation level At 10:09 a.m., the ED called the CR to find out why this evacuation took place, ',

indicating lack of continuous flow of information from the CR to the TS *

An alarm pertaining to the inoperable scram discharge valve was received by CR operators at 9:30 This required visual inspection by procedur The CR operators failed to inform the TSC staff about this situation,

and as a consequence the valve inspection team was not dispatched until 9:53 *

Several face-to-face meetings between the CR and TSC staffs were necessary to compensate for the shortcomings of other means of communication throughout the exercise, indicating a possible need for additional communication hardware between these two emergency response facilitie Response Section 2.2 (page 9) of NUREC 0696, Functional Criteria for Emergency Response Facilities, supports actions taken by CNS Control Room and TSC staff by stating the need for face-to-face communcitions between TSC and Control Room personne The next cycle of CNS operator requal training will include a thorough review of this inspection ite In addition, section A of EPIP 5.7.7, Activation of TSC, will be revised to prompt the Emergency Director to review plant status with control Room and TSC personnel on a periodic basi This will be completed by April 15, 198 Deficiency 3 (285/8725-03)

The . NRC inspector noted that the Shift Supervisor (SS) acting as the ED, in the CR, and the Control Room Supervisor (CRS), became involved with

, administrative details, or failed to delegate functions to the TS This detracted from their ability to direct and coordinate emergency response activities in an efficient manne Response The District has embarked on an ef fort to develop and implement an improved emergency response organization training progra This new program will be position task oriented and will address issues such as those described l in the stated deficienc Improved training should help to increase efficiency

in the coordination of the operational and administrative direction of emergency situation The revised emergency response training programs will be implemented during calendar 198 m _

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b(,.mi .Decubar 10 -1987 Deficiency 4 (285/8725-04)

-The NRC inspector noted that Procedure EPIP 5.7.1, "Emergency Classification",

listed Emergency Action Level (EAL) 2.6 as the loss of two fission product barriers as a Ceneral Emergenc The EAL in some situ ~ations would produce minimal offsite consequence that would not justify taking mandatory pretective actions as is the case in a Ceneral Emergency clas Additionally, the guidance in NUREG 0654, Appendix A, states-that a General Emergency requires the loss of 2 out of 3 fission product barriers with a potential loss of the third barrie Response

.A proposal. to change the NPPD Emergency Plan for CNS and the corresponding EPIPs to reflect the guidance in NUREG . 0654 concerning loss of 2 out of 3 fission product barriers will be presented to the appropriate state agencies for their review and comment. Upon receipt of their comments, the appropriate '

changes will be incorporated into the Emergency Plan, EPIPs, and CNS training cycle. This will be completed before April 15, 198 Deficiency 5 (285/8725-05)

The NRC Inspectors noted that the TSC engineering staff used uncontrolled copies of plant system diagrams, that could be out of date, for troubleshooting during the unfolding of the accident scenari The status boards in the TSC vere deficient in that:

The status boards were not maintained up-to-date ( equipment status was not updated from 10:00 to 3:00 p.m.).

Parameter trends were not indicate '

Parameters such as valve position for critical systems, like Standby Cas Treatment and Switch Liquid Control, were not indicate Response Parameters, trends and current system lineups are available on PMIS/SPDS in the TSC for access by the TSC organization in the event of an actual emergenc Uncontrolled copies of plant system disgrams have been removed from the TSC and controlled copies made available. The District will be developing enlarged TSC status corads having improved capabilities for status and trending displays -

for installation in the new TSC currently under constructio 'the se revised disploys will be available by the end of June 198 !

Deficiency 6 (285/8725-06)

l The NRC inspector determined that the medical team failed to take appropriate first-aid actions to save the life of the injured-contaminated individual, and was unable to establish priorities between medical and radiological concern f

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... * * ,P:33 4-Dec=bar 10, 1987 Response The CNS medical training program will be upgraded to provide for Red Cross Multimedia First-Aid, training for station personnel and the establishment of EMT qualified squads to improve the station's capability to combat medical emergencie A procedure is under development for medical response to injured, non-contaminated individuals with renewed emphasis on first aid capabilitie In addition, the revised emergency response training program will address the coordinating of medical emergency actions during plant casualty condition These actions will be completed before the end of June, 198 Should you have any questions concerning this matter, please contact my offic

Sincerely, G. A. Trevors Division Manager Nuclear Support CAT /rkrijw cci U.S. Nuclear Regulatory Commission Regional Office, Region IV NRC Resident Inspector Cooper Nuclear Station

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