ML20125C057

Insp Repts 50-445/92-46 & 50-446/92-46 on 921116-20.No Violations or Deviations Noted.Major Areas Inspected: Licensees Performance & Capabilities During an Annual Exercise of Emergency Plan & Implementing Procedures

ML20125C057
Person / Time
Site:	Comanche Peak
Issue date:	12/07/1992
From:	Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20125C056	List: ML20125C053 ML20125C057
References
50-445-92-46, 50-446-92-46, NUDOCS 9212110024
Download: ML20125C057 (14)

See also: IR 05000445/1992046

Text

-

,

,

.

,

.

.

APPENDIX

U.S. NUCLEAR REGULATORY COMMISSION

REGION-IV

Inspection Report: 50-445/92-46

50-446/92-46

Operating License: NPF-87

Constructiun Permit: CPPR-127

'

Licensee: TV Electric

Skyway Tower

400 North Olive Street, L.B. 81

Dallas, Texas 75201

Facility Name: Comanche Peak Steam Electric Station l

Inspection At: Glen Rose, Texas

Inspection Conducted: November 16 through 20, 1992

Inspectors: D. Blair Spitzberg, Ph.D., Emergency Preparedness Analyst,

-Team Leader

K. M. Kennedy, Project Engineer j

0. Barss, Emergency Preparedness Specialist, Office of Nuclear

Reactor Regulation (NRR)

Accompanying

Personnel: J. D. Jamison, Senior Staff Scientist, Battelle Laboratories

G. W. Bethke, Comex Corporation-

R. Emch, Section Chief, Emergency Preparedness Branch, NRR

M. L. Thomas, Radiation Specialist, Office of Nuclear Regulatory

Research

Approved: 8 /([i [d 8kg

B hine Murray, Cthef, Facil ties

/k

Dat( '

'M

Inspection Programs Soft on

Inspection Summary

'

Areas Inspected: Routine, announced inspection of the licensee's performance

and capabilities during an annual exercise of the emrgency plan and

implementing procedures. The team observed activities in the control room

(simulator), Technical Support Center, Operational Support Center, and the

Emergency Operations Facility.

9212:r v024 921207

PDR  !. DOCK 05000445

O PDR

,

, t, .

-

.

,

.

-2-

Results:

e The control room staff performance was strong during the exercise

(Section 2).

e The Technical Support Center was staffed and activated promptly

(Section 3),

e An exercise weakness was identified for delays in detecting and

classifying two emergency classes (Section 3.1).

• An exercise weakness was identified for failure to make prompt

notifications to offsite authorities of an emergency classification

(Section 3.1).

e The Operational Support Center was staffed and activated promptly.

Information flow within the Operational Support Center and between the

Operational Support Center and other facilities was good. Repair teams

followed proper safety controls and were well briefed (Section 4).

e The Emergency Operations Facility was staffed and activated promptly,

and personnel were proficient in carrying out their assigned duties.

The press conference'did not clearly convey essential information which

was available at the time to the media (Section 5).

e An exercise weakness was identified for several examples of weak

emergency command and control (Section 6.1).

e The sccaarlo and exercise preparation provided sufficient challenge to

demonstrate the exercise objectives (Section 7).

e The licensee's self-critique process was excellent in identifying areas

in need of corrective action (Section 8).

Summary of Inspection Findinas:

• Exercise Weakness 445/9246-01; 445/9246-01 was opened (Section 3.1).

'

• Exercise Weakness 445/9246-02; 446/9246-02 was opened (Section 3.1).

'

i

e Exercise Weakness 445/9246-03; 446/9246-03 was opened (Section 6.1).

Attachment:

Attachment 1 - Persons Contacted and Exit Meeting

4

.

. . s .- ,

-

'

l

.

_3_

,

DETAILS

1 PROGRAM AREAS INSPECTED (82301)

' The licensee's annual emergency preparedness exercise began at 2 a.m. on

November 18, 1992. The exercise start time had been withheld from exercise

participants. The exercise did not involve participation by offsite agencies.

Initial conditions for the exercise included full power operations in Unit I

with Diesel Generator 2 removed from service. Unit 2 was undergoing

pre-operational testing, and its equipment and systems were unavailable for

use during the exercise. The exercise began with a small steam generator tube

r Mture meeting the conditions for a Notification of Unusual Event. A short

tir..a later, a fire alarm was received in the control room (simulator)

indicating a fire in the Emergency Diesel Generator 1-01 Day Tank Room. This

would lead to conditions corresponding to an Alert classification. Following

several subsequent minor events, the scenario presented a significant increase

in the size of the steam generator tube rupture concurrent with an unisolable

steam break uutside of containment on the affected steam generator. These

events led to conditions corresponding to a Site Area Emergency, with activity

in the primary coolant being released to the environment. About 40 minutes

later, the final significant event occurred with the rupture of a waste gas

decay tank drain line. The scenario called for the emergency to be terminated

while in the Site Area Emergency classification with two offsite release

pathways. The releases were not of a magnitude to cause offsite dose

projections to exceed Environmental Protection Agency protective action

guidelines.

The inspection team identified various concerns during the course of the

exercise; however, none were of the significance of a deficiency as defined in

10 CFR 50.54(s)(2)(ii). Each observed concern is characterized as an exercise

weakness or as an area recommended for improvement. An exercise weakness is a

finding that a licensee's demonstrated level of preparedness could have

precluded effective implementation of the emergency plan in the event of an

actual emergency. An exercise weakness is a finding that needs licensee

corrective action. Other observations are documented which did not have a

significant negative impact on overall performance during the exercise but

still should be evaluated and corrected as appropriate by the licensee.

l 2 CONTr10L ROOM (82301-03.02.b.1)

l

,- The inspection team observed and evaluated the control room staff as they

l

performed tasks in response to the exercise. These tasks included detection

l

and classification of events, analysis of plant conditions, implementation of

'

corrective measures, notifications of offsite authorities, and adherence to

the emergency plan and implementing procedures.

2.1 Discussion

The control room simulator was used to initiate the exercise. Dynamic

simulation of the exercise was accomplished throughout the exercise.

l

._

.

. s a -

.

-4-

Overall, the control room staff performance was observed to be strong during

the exercise. The crew successfully detected abnormal events, analyzed plant

conditions, and aggressively pursued corrective actions and alternate success

paths. Augmentation of the control room staff by offsite personnel assigned

to Emergency Organization positions occurred within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> following the Alert

declaration. The Notice of Unusual Event and the Alert classifications were

both made from the control room during the exercise. The inspectors observed

that the classification of the Alert was delayed by the control room crew

after confirming that a fire in the protected area which lasted more than 10

minutes was potentially affecting a safety system. This observation is

discussed in detail in Section 3.1 as part of an exercise weakness in

detection and classification. Notifications to offsite authorities from the

control room were timely and accurate. The inspection team noted that the

control room crew performed prompt and appropriate offsite dose projections

based on the small steam generator tube leak.

The following observations made in the control room did not significantly

detract from the overall effectiveness of the licensee's response and are

identified as potential areas for improvement:

e following the declaration of a Notification of Unusual Event and the

subsequent activation of the pager system, the control room received

numerous phone calls requesting information from offsite personnel with

pagers. These phone calls were handled by the two control room

communicators and the Emergency Coordinator which caused a distraction

to the performance of their duties.

e Control room logs were not maintained during the late stages of the

exercise between 5:09 a.m. and the termination of the exercise at 6:09

a.m. During this time period, events which were not logged by the

control room included the rupture of a waste gas decay tank and the loss

of an offsite power distribution line.

2.2 Conclusions

The performance of the control room staff was observed to be strong during the

exercise. A delay in the classification of the Alert contributed to an

exercise weakness in detection and classification (Section 3.1).

3 TECHNICAL SUPPORT CENTER (82301-03.02.b.2)

The inspectors observed the operatiu of the Technical Support Center from

activation through termination of the exercise. The inspectors evaluated

staffing, command and control, technical assessment and support of operations,

classifications and notifications, dose assessment, formulation of protective

action recommendations, and adherence to the emergency plan and implementing

procedures.

3.1 Discussion

The Technical Support Center was staffed and activated promptly within I hour

of the Alert declaration. The transition of emergency command from th:

_

-

,

, u ,

.

-5-

control room to the Emergency Coordinator in the Technical Support Center was

noted to be inefficient and confusing. Inspector observations related.to the-

transfer of Emergency Coordinator duties to the Technical Support Center are

discussed in further detail in Section 6.1 as part of an exercise weakness in

emergency comand and control .

Technical Support Center briefings were held approximately every half hour.

These briefings included a presentation by each major technical area

coordinator and served to keep all Technical Support Center personnel apprised

of plant conditions and priorities. The classification and declaration of the

Site Area Emergency was made from the Technical Support Center approximately

18 minutes following this facility's activation. The inspectors noted

unnecessary delays associated with the detection and classification of the

initiating conditions for two of the three emergency classifications made

during the exercise as follows:

e In the control room, the Emergency Coordinhtor failed to *.mplement

correctly Procedure EPP-201, " Assessment of Emergency Action Levels,

Emergency Classification and Plan Activation," Chart 11, " Fire." This

chart indicated that a fire inside the protected area lasting-greater

than 10 minutes for which safety systems were potentially affected by

the fire would result in an Alert classification. The Emergency

Coordinator failed to declare an Alert 10 cinutes after the Diesel

Generator 1-01 Day Tank Room fire alarm was received in the control

room. Instead, the declaration was made 10 minutes after the existence

of the fire was confirmed by an auxiliary operator dispatched to the

scene. This resulted in a 6-minute delay in the Alert classification.

Through player interviews, the inspectors determined that the Emergency

Coordinator began the 10-minute countdown at the time when the fire was

confirmed by the auxiliary cperator. The operator confirmation took

6 minutes from the receipt of the alarm. During this 6 minutes, the

fire potentially affected safety systems. Under the conditions of this

scenario, following the operator's confirmation of the fire, the Alert

classification conditions were met 10 minutes after the receipt of the

fire alarm.

e in the Technical Support Center, declaration of the Site Area Emergency

following the major steam generator tube rupture and main steam line

break was not made promptly following reports of ihese conditions. At

4:28 a.m., the Technical Support Center staff becam aware that the

steam generator tube rupture had significantly increcsed concurrent with

reports of an unisolable steam line break outside of tor,tainment on the

affected steam line. According to the licensee's classification scheme

contained in Procedura EPP-201, " Assessment of Emergency Action Levels,

Emergency Classification and Plan Activation," Chart 4, these conditions

correspond to a Site Area Emergency. The declaration of the Site Area

Emergency was not made by the Technical Support Center until 4:49 a.m.,

or 21 minutes following Technical Support Center staff awareness of

these conditions. The inspectors noted that a briefing was being

started at 4:30 a.m. in the Technical Support. Center as information of

the main steam line break was received. Rather than take action on this

1

, 9 .

.

-6-

event, the managers took another 5 to 10 minutes to complete the

briefing. The control-room finally prompted the Technical Support

Center concerning the need to upgrade to Site Area Emergency at about

4:47 a.m.

Delays in detecting and classifying emergency conditions ware identified as an

exercise weakness (445/9246-01; 446/9246-01).

Following the declaration of the Site Area Emergency at 4:49 a.m., the

notifications to offsite authorities of this classification were not completed

until 25 minutes later at 5:14 a.m. According to 10 CFR 50, Appendix E.IV.D.3

and EPP-203, " Notifications," Section 4.1.2.2, notifications are to be made

within 15 minutes after declaring the emergency. The licensee's failure to

make prompt offsite notifications of the Site Area Emergency was identified as

an exercise weakness (445/9246-02; 446/9246-02).

The inspectors made the following observations from the Technical Support

Center which were determined not to have significantly detracted from the

overall effectiveness of the licensee's response and are identified as areas

for improvement:

• Status boards in the Technical Support Center were often late in being

updated or were never annotated in sections pertinent to the exercise

scenario data. Specific examples include:

-

At 3:55 a.m., the Sequence of Events status board attributed the

ALERT to " Primary to Secondary Leakage" versus the actual cause

which was the Train "A" diesel day tank fire.

-

At 4:17 a.m., the Sequence of Events status board did not

indicate that the Operational Support Center and Technical

Support Center were activated.

-

The Radiological status board was never updated to reflect

offsite monitoring team data or the results of dose projections

made,

e The inspectors noted difficulties in the Technical Support Center

associated with use of the "Offsite Release. Consequence. Assessment

System" (0RCAS). Fifteen minutes following activation of the Technical

Support Center, there was still no operator available for the ORCAS

computer system. Because of this, the Technical Support Center Onsite

Radiological Assessment Coordinator decided that he would have to

operate the ORCAS instead of occupying his position at the management

table. At about 4:30 a.m., a newly arrived individual was assigned to-

the ORCAS but this individual stated that he had only operated ORCAS

once before.

Throughout the exercise, the Technical Support Center ORCAS was operated

under only one accident scenario assumption, " Steam Generator Tube

Rupture." All dose projections performed used data from the main steam

line radiation monitors. These monitors are installed on the steam

- .

- _ _ _ _ _ _ _ _ _ _ _ _ _ _ -

-

, , .

.

-7-

lines between the relief valves and the ma'n steam isolation valves.

For the exercise scenario, the inspectors found that these monitors

could have been unrepresentative of release concentration because of

such conditions as being positioned downstream of the break, because of

damage by high temperature and humidity, or because of being subjected

to physical damage caused by pipe whip, etc.

Scenario selections are not available on the ORCAS computer program for

releases via the condenser offgas stack or for ground level releases

created by main steam line breaks with a steam generator tube rupture.

• Several personnel in the Technical Support Center stated that the

Gaitronics/All Page system was unreliable or would not work from the

Technical Support Center. This was explained by the licensee as being a

drill artificiality caused by the additional load on the system of the

remote simulator facility. The inspectors noted that the loading

problem did not appear to affect transmission from the simulator to the

plant speaker systems; therefore, the problem may not be one of system

over-loading.

3.2 Conclusions

The Technical Support Center was staffed and activated promptly. An exercise

weakness was identified for delays in detecting and classifying two emergency

classes. Another exercise weakness was identified for failure to make prompt

notifications to offsite authorities of an emergency classification.

The transition of emergency command from the control room to the Emergency

Coordinator in the Technical Support Center contributed to an exercise

weakness discussed in Section 6.1 in the area of emergency command and

control.

"

4 OPERATIONAL SUPPORT CENTER (82301-03.02.b.4)

The inspectors evaluated the performance of the Operational Support Center

staff as they performed tasks in response to the exercise to determine whether

the Operational Support Center would be effective in providing emergency

support to operations.

4.1 Discussion

The inspectors observed the activation and operation of the Operational

Support Center and repair teams dispatched to in-plant locations. The

Operational Support Center was initially staffed by personnel who were on site

at the time the Alert was declared, and the facility was operational with

minimum staffing 12 minutes after the declaration of the alert. The

Operational Support Center was officially declared operational 33 minutes

after the Alert declaration.

Personnel appeared generally to be acquainted with their responsibilities and

duties. Procedural guidance was available and used by individuals in the

Operational Support Center. The inspectors noted that on one occasion an

auxiliary operator who was dispatched to investigate the fire alarn needed to

l

. _ - _ _ _ _ ____ _ _ _ - . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ __________- _ ___ _ _ - _

. . .

l .

.

i ,

8-

be instructed in immediate entry procedures at the access control point.

Radios, telephones, and plant page systems were effectively used to maintain

communication between emergency response facilities and teams dispatched to

in-plant and onsite locations.

Key emergency responders kept logs of ongoing activitier. A status board for

plant events was maintained. The inspectors noted that reports of in-plant

radiation monitors were posted on a dry erase board while another status board

specifically provided for this information was not utilized. Also, results of

radiological surveys were not posted on plant maps provided in the Operational

Support Center.

The comand and control of the Operational Support Center was fragmented and

somewhat uncoordinated. Early in the exercise, it appeared that no single

individual was clearly in control of assigning 2nd dispatching teams. The

licensee did manage to dispatch teams needed to respond to emergency events in

For example,

a timely manner; however, it was not done in an orderly fashion.

the licensee failed to maintain adequate administrative controls over teams

dispatched in response to emergency conditions as specified in

Procedure EPP-16. " Emergency Repair & Damage Control and Imediate Entries."

This finding is discussed in Section 6.1 as part of the exercise weakness in

emergency command and control.

Repair team priorities were frequently discussed by tbs Operational Support

Center Manager with Technical Support Center management. These priorities

were clearly posted on a status board in the Operational Support Center.

Briefings of emergency respo se damage control teams were good. Team members

were adequately informed of existing or expected radiological conditions.

Appropriate radiological controls were prescribed and gcad radiological

practices were followed by team members. Team tasks were clearly explained.

4.2 Conclusions

The Operational Support Center was staffed and activated promptly.

Information flow within the Operational Support Center and betwaen the

Operational Support Center and other facilities was good. Repair teams

followed proper safety controls and were well briefea. Failure of the

Operational Support Center to exercise specified administrative controls over

repair teams is discussed in Section 6.1 as part of a weakness identified in

the area of emergency command and control.

5 EMERGENCY OPERATIONS FACILITY (82301-03.02.b.3)

The inspection team observed the Emergency Operations facility staff as they

performed tasks in response to the exercise. These tasks included activation

of the Emergency Operations Facility, accident assessment and classification,

of fsite dose assessment, protective action decisionmaking, notifications, and

interactions with offsite field monitoring teams.

I

- --_--___ _ _ _ _ _ _

-

,

.

• 7

.

-9-

5.1 Discussion

The Emergency Operations facility staff arrived promptly and the Emergency

Operations-Facility was declared activated 72 minutes following the Alert

declaration. Some minor security access delays were observed in the Emergency

Operations Facility. It was noted that the authorized access list for the

Emergency Operations Facility was dated September 10, 1992. The first two

responders to the Emergency Operations Facility were not on the list and the

guard responsible for Emergency Operations Facility access control had to

obtain authorization by telephone before admitting them. Later, for the same

reason, the driver assigned to field monitoring team No. I was prevented from

accessing the area where survey team equipment was stored, causing a short

delay in the deployment of the team.

The inspection team noted that Emergency Operations Facility staff appeared to -

be trained and proficient in carrying out their response duties. The

operational status and event sequence status board was kept current and

complete throughout the exercise, it provided a very useful and accurate

summary of plant :onditions for ready reference by all the Emergency

Operations Facility staff. Written logs, however, were not as well

maintained. For example, logs kept by key Emergency Operations Facility

players were in loose-leaf format instead of bound log books. Many

interpersonal and inter-station communications were recorded using scraps of

paper or informal notes. These practices would make event reconstruction from

the records very difficult and legally tenuous.

Control of the offsite monitoring teams and dissemination of the measurement

results they collected were weak. These observation are discussed in further

detail in Section 6.1 as part of the exercise weakness in emergency command

and control. In addition, offsite monitoring team measurement results of the

plume traverse reported as background by the team at 5:39 a.m. were not logged

in the field team communicator log, nor were these, or the later

above-background readings reported about C a.m. recorded on the offsite

monitoring status board.

The inspection team observed the licensee's exercise press conference

conducted in the auditorium adjacent to the Emergency Operations Facilf ty.

The press conference did not clearly convey basic information that was

l

available at the time and that both the media and public would need to

! understand. For example, the press briefing apprised'the media of a

I radiological release in progress but failed to convey any clear information as

to the offsite hazards associated with the release. In fact, before the press

conference was held, the licensee's response staff had conducted onsite

,

monitoring surveys of the release and had performed detailed dose projections,

l both of which indicated that the offsite hazards associated with the release

! were minor. In the absence of such information being conveyed, the media was

l left to report only that licensee personnel had been evacuated from the site

but as for the general population, county authorities were working to

formulate offsite protective actions. Further, the press conference did

t

little to describe the licensee's response efforts in progress at the time.

'

No definition was given for the Site Area Emergency which had been declared,

nor was it differentiated from the other emergency classes. No perspective

!

_

.

c .

-

-

.

.

-10-

was conveyed relative to whether the emergency was stabilizing or whether

conditions were still degrading.

5.2 Conclusions

The Emergency Operations Facility was staffed and activated promptly and

personnel were proficient in carrying out their assigned duties. Control of

offsite monitoring teams and the information they returned to the Emergency

Operations Facility was part of an exercise weakness discussed in Section 6.1

in the area of emergency comand and control. The press conference did not

clearly convey essential information to the media which was available at the

time.

6 EMERGENCY COMMAND AND CONTROL (82301)

The inspection team evaluated the emergency comand and control exercised in

each emergency response facility to determine whetner clear chains of comand

were in place for effective emergency management, and whether tha emergency

response organization was issued appropriate directives by key decisionmakers.

6.1 Discussion

The Emergency Coordinator position (a.k.a. Emergency Dit ctor) was transferred

twice during the exercise. Between the Alert declaration and the Site Area

Emergency, the Emergency Coordinator position shifted from the control room to-

the Technical Support Center. About 30 minutes after the Site Area Emergency

declaration, the Emergency Coordinator responsibilities were transferred to

the Emergency Operations Facility. The inspection team made the following

observations which, in the aggregate, indicated that overall comand and

control during the exercise was weak:

e The transfer of Emergency Coordinator duties from the control room shift

supervisor to the manager in the Technical Support Center was-

l

inefficient and confusing and appeared to leave a vacuum of comand

authority for a period of time.

The Alert was declared at 3:19 a.m. By 3:36 a.m., there were about four

people in the Tech :al Support Center but with no particular individual

in charge. At about 3:42, the Emergency Coordinator's checklist logs

indicated that the individual who would eventually become the Emergency

Coordinator in the Technical Support Center had relieved the control

room shift supervisor of the Emergency Coordinator's duties (while in

l the simulator). By about 4 a.m., one individual in the Technical

l Support Center had taken charge of personnel there but did not claim the

'

title of Emergency Coordinator. The Emergency Coordinator arrived .in

the' Technical Support Center from the simulator at about 4:28 a.m. but

did not announce that he was the Emergency Coordinator. Status boards

in the Technical Support Center continued to show that the control room

had comand and control. The Technical Support Center Emergency

Coordinator log showed that the same individual who had-assumed

Emergency Coordinator duties in the simulator again assumed these duties

in the Technical Support Center at 4:50 a.m.

!

l

\

l

.. .

.

-11-

Because of the distance between the Technical Support Center and the .

simulator, this exercise included an artificially long period of time

(about 10 minutes) to transit between the two facilities. Even giving

consideration to this artificiality, it was unclear who was the

Emergency Coordinator during the 4:30 to.4:50 a.m. timeframe.

e In the Operational' Support Center, the licensee failed to maintain

adequate controls over teams dispatched in response to emergency

conditions. Between 4 and 6:07 a.m., 16 teams were dispatened from the

Operational Support Center. No Emergency Work Permits were completed

for 10 of these teams as required by Procedure EPP-116. "Emernancy

. Repair & Damage Control and immediate Entries," step 4.2.2. ' ema o f

,

these teams were recorded on the Operational Support Centw Team Status

board and in various logs but no consistent central record was

maintained of these teams. In addition, as noted in Section 4.1, early

in the exercise it appeared that no individual in the Operational

Support Center was clearly responsible for the control of assigning and

dispatching repair teams.

e In the Emergency Operations Facility, control of the offsite monitoring

teams and utilization of the information developed from them was

inadequate. Neither the results of the 5:39 a.m. plume traverse nor the

later measurements reported to the Emergency Operations Facility about-

6 a.m. that produced above-background readings were recorded on the

offsite monitoring status board or reported to the Emergency Operations

Facility decisionmakers. At the termination of the exercise, the

Radiation Protection Coordinator and the Emergency Coordinator were

unaware of the results of the monitoring team traverse of the plume

3 miles downwind from the plant some 25 minutes before. For an

undetermined period of time around 5:53 a.m., the monitoring team

communicator's station was abandoned leaving no apparent radio

cmmunication or centralized control over the deployed teams during this

t .ne period,

e Staffing of the Emergency Response Facilities was at times disorganized,

as sometimes several qualified individuals shared (or attempted to fill)

the same position. The facility managers were not forceful in directing

the excess staff to be released for other duties. There appeared to be

no standard practice or procedure for staffing the initial response

organization and recording, reassigning or releasing the other personnel

who responded. While three different qualified individuals were signed

in for, and took part in carrying out the duties of the Emergency

Operations Facility Radiation Protection Coordinator position, the

Technical Support Center dose projection capability was suffering for a

lack of experienced personnel.

Emergency command and control was identified as an exercise weakness

(445/9246-03; 446/9246-03).

. ._

_ _ _ _ _ _ _ _ _ _ _ _ ._. _ _. ..

,

o ,,

-

,

.

.

-12-

6.2 Conclusions

Several examples eT weak emergency command and control were identified in

emergency response facilities.

7 SCENARIO AND EXERCISE CONDUCT (82301)

The inspection team made observations during the exercise to assess the

challengo and realism of the scenario ar.d to evaluate the conduct of the

exercise.

7.1 QIscussio.n

The iwpection team determined that the scenario provided sufficient challenge

to wercise response activities in each of the exercise objectives. P.ealism

was enhanced by utilizirig the contro! room simulator in the dynamic mode to

model the accident segaence.

The following observatt mc it Pted to the scenario and to the conduct of the

exercise did not significantly detract from the exercise and are discusse, es

potential areas for improvement:

e The exercise data for the RM-Il was inaccurate for the Steam Gu.erator

Sample (SGS 164) and the Steam Generator Blowdown Process

Monitors (SGB 173). The exercise data for the steam generator blowdown

monitor indicated that the channel would be at the alert level at

2.164E-4 pCi/cc and the alarm level at 4.272E-4 pC1/cc, and the steam

generator sample monitor would be in: alert at-2.524E-4 pCi/cc and in

alarm at 3.779E-4 pCi/ce. The actual alant setpoints for these monitors

are different inan those provided in t1e scenario. In addition, the.

exercise data did not reflect the isolation of the steam generator

blowdown or sample lines when these respective monitors reached the

alarm setpoint.

e Scenario data for the ligad primary coolant sample and the No. 3 steam

generator was inconsistent. At times (e.g., 2:30 to 2:45 a.m.) the

steam generator noble gas and iodine levsls were a factor of 3 to 5

times greater than the coolant activity values, a condition which is a

physical impossibility.

e In-plant survey teams :;imulated the posting of radiological controlled

areas. This was contrary to information presented in the pre-exercise

discussions with the inspection team which indicated that posting would

not be simulated,

e The scenario and exercise control did not provide for realistic feedback

to the Emergency Operations Facility regarding the status of

implementation of the offsite protective actions. County officials

would be expected to. report (or be responsive to queries) on what they

were doing in response to the licensee's recommendations, and licensee

personnel would be expec ed to take that feedback into account when

,

'

l making further recommendat ans.

.. __. . ._. - _ _ . _ , _ . _ _ _ _

-

,

- . . ,

.

2

-

13-

7.2 Conclusions

The scenario and exercise preparation provided sufficient cnallenge to

demonstrate the exercise objectives.

O LICENSEE SELF-CRITIQUE (82301-03.02.b.12)

The in;pectors observed and evaluated the licensee's formal self-critique on

November 20, 1992, to determine whether the process would identify and

characterize weak or deficient areas in need of corrective action.

1

8.1 Discussion

The licenFee gave a presentation of its Critique findings as Well as a

documented summary. The licensee used terminolngy identical to that used by

the NRC to characte-ize its findings. The licensee identificd the following 2

weaknesses:

e notification was not timely.

.

• Command and control was unsatisfactory in some areas.

In addition to the two weaknesses identified, the licensee characterized five

improvement items and a list of proficiencies. Among the improvement items

were the identification of delays in assessing and classifying conditions of

the Alert and Site Area Emergency as well as other observations nated by the

NRC inspection team. The licensee's self-critique process involved

appropriate levels of management review and was determined to be a strength,

8.2 Conclusions

The licensee's self-critique process was excellent in identifying areas in -

need of corrective action.

I

i

-- , --,,c . . , . . . . , . . . - --,.y., , ,,m. _ ,. -..-,~,.--e--.m--

- -

., ,,.

- - _ . . -- . _ .

,

.

,

-

- . ;. ,

.

O

ATTACHNEKT 1

1 PERSONS CONTACTED

1.1 Licensee Personnel

• J. Ardizzoni, Supervisor, Administrative Security

• D. Barham, Emergency Planner

• R. Beleckis, Senior Emergency Planner

• G. Bell, Supervisor, Emergency Planning

• H. R. Blevins, Director, Nuclear Overview

• T. A. Carder, Emergency Planner

• D. Davis, Manager, Plant Analysis

• J. Ellard, Senior Emergency Planner

• J. R. Gallman, Manager, Trend Analysis

• W. G. Guldemono, Manager, Independent Safety Engineering Group

• N. Harris, Licensing Engineer

• N. Hood, Manager, Emergency Preparedness

+T. Hope, Manager, Site Licensing

• B. T. Lancaster, Manager, Plant Support

• P. E. Mills, Senior Quality Assurance Specialist

• D. Moore, Manager, Unit 2 Nuclear Operations Transition Organization

• S. Palme, Stipulation Manager

• A. Saunders, Atsessment Manager

• A. J. Scogin, Jr., Manager,-Security

• E. A. Sirois, Senior Engineer

• W. Stengar, Senior Emergency Planner

1.2 NRC Perve9gl

• V. G. Gaddy, Reactor Inspector (Intern)

• D. N. Graves, Senior Resident inspector

• T. P. Gwynn, Deputy Director, Division of Reactor Projects

• B. E. Holian, Project Manager,-NRR

• L. A. Yandell, Chief, Project Section B

1.3 Other Personnel

• 0. L. Thero, Consultant, Citizens for Sound Energy

• T. Mayberry, Senior Staff Consultant, Houston Lighting and Power

• Denotes thost present at the exit interview

2 EXIT MEETING

The inspection team met with the licensee representatives and other personnel

indicated in Section 1 of this-attachment on November 20, 1992, and summarized

the scope and findings of the inspection as presented in this report. The

licensee did not idcti:fy as proprietary any o' the materials provided to, or

reviewed by, the in+.iection team dm'ing the inspection.

-. - - -

- . .-