IR 05000382/1997018
| ML20198C531 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/05/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20198C505 | List: |
| References | |
| 50-382-97-18, NUDOCS 9801070317 | |
| Download: ML20198C531 (22) | |
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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION !
REGION IV [
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Docket No.: 50 382 i-License No.: NPF-38 :
Report No.: 50 382/07 18 l Licensee: Entergy Operations, In Facility: Waterford Steam Electric Station, Unit 3 Location: - Hwy.18 ;
Killona, Loulslana Dates: November 4 7,1997 !
Inspectors: Gail M. Good, Senior Emergency Preparedness Analyst, Team !
Leader Brad A. Smalldridge, Resident inspector, Wolf Creek Francis L. Brush, Resident inspector, Callaway Thomas H. Andrews, Emergency Preparedness Analyst i Observer: John C. Edgerly, Reactor Engineer Approved By: Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety Attachment: Supplemental inspection Information
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EXECUTIVE SUMMAB ,
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Waterford Steam Electric Station, Unit 3 - !
NRC Inspection Report 50 382/97 18 lr A routine, announced inspection of the licensee's performance and capabilities during the I full-scale, biennial exorcise of the emergency plan and implementing procedures was performed. The inspection team observed activities in the control room simulator, technical support center, operational support center, and emergency operations facilit ;
i Plant Sucoort ;
- Overall, performance was generally good. Emergency classifications were promptly I recognized and classified. Corresponding offsite agency notifications were correct !
and timely. The control room (CR) simulator s:aff and technical support center ,
(TSC) successfully implemented all assigned emergency plan functions. The ,
extensive use of three part communications in all emergency response f acilities was .
identified as a strengt * CR performance was geretally good. Operators rapidly detected and accurately '
classified emergency events. Corresponding offsite agency notifications were correct and timely. CR briefings were frequent, structured, and interactiv Three part communications were used consistently and contributed to the effectiveness of the CR team. The sequence of events and basis for decisions were i not sufficicntly documented in the station logs. At times, operators lacked ,
sufficient attention to detail to prevent unexpected system response, and CR supervision did not fully implement the personnel accountability procedure (Section P4.2).- * The TSC staff's performance was very good. The staff developed effective strategies to address equipment problems. The TSC personnel functioned well as a team.- Frequent and comprehensive site wide briefings were conducted, and 1 three part communications were stressed. TSC personnel accountability was initially unsteady, because the accountability coordinator was unf amiliar with the position and some personnel were late performing callbacks after leaving the TSC (Section P4.3). ;
- The operational support center (OSC) staff's performance was adequate. The center was activated in a timely manner, and briefings were frequent and comprehensive. Three part communications were strongly emphasize Habitability was confirmed and routinely assessed.- Status boards were adequately used and updated in a timely manner. An exercise weakness was identified for f ailure to implement' proper radiological exposure controls (dosimetry and contamination controls). An exercise weakness was identified for failure of the fire brigade to use required respiratory protection while combating a fire with toxic smoke in an enclosed space (Section P4.4).
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3- ir i * The emergency operations facility (EOF) staff's performance was generally goo l Facility members frequently used three part communications to ensure that !
instructions were understood. Briefings were initially detailed and comprehensive l but the frequency degraded during the last half of the exercise. Emergency i
- classifications were correct and timely, and, with one exception, offsite agency 3 notifications were made promptly following changing plant conditions. An exercise !
- weakness was identified because a protective action recommendation upgrade
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decision was unnecessarily delayed. Dose assessment and field team control ;
activities were well managed and executed to determine actual offsite impac interactions with offsite response members were open and informative l
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(Section P4.5).
- The exercise objectives were exceptionally detailed and measurable. An ;
- inconsistency in the dose related emergency action levels was identified during the l scenario review; appropriate corrective actions were identified. The scenario was sufficiently challenging to test onsite response capabilities. The use of mock ups to !
- Increase the realism for exercise participants was identified as a program strengt Although ambiguous Information given to the participants inhibited / delayed identifying the stuck open safety relief valve, participants did not exhibit a -
. questioning attitude. The lack of radiation protection controllers / monitors limited ;
- participant response in the OSC (Section P4.6). !
- The integrated critique process was very comprehensive and considered a program strength due to the quality of the post exercise critiques (OSC excepted), the use of .
a separate evaluation team and peer review group, and the continued practice of j conducting a followup participant critique. The critique process emphasized areas i in need of improvement, rather than areas of strength (Section P4.7),
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IV. Plant Suunort 84 Staff Knowledge and Performance in Emergency Preparedness P Exercise Conduct and scenario Descriotion 182301 and 82302) j l The licensee conducted a full scale, biennial emergency preparedness exercise on l November 5,1997. The exercise was conducted to test major portions of the !
onsite (licensee) and offsite emergency response capabilities. The licensee activated its emergency response organization and all emergency response f acilities. -
The Federal Emergency Management Agency evaluated the offsite response capabilities of the state of Loulslana and St. Charles and St. John the Baptist parisSes. The Federal Emergency Management Agency willissue a separate repor The exercise scenario was run using the CR simulator in a dyncmic mode. The exercise scenario began at 8:05 a.m. with the plant operating at 100 percent power. Normal weekday personnel were available for duties. At the start of the exercise, dose equivalent iodine was 0.7 microcuries per gram due to earlier turbine :
valve testing. Both the A and B charging pumps were running to decrease the dose '
equivalent lodin At 8:07 a.m., the CR received alarms on the seismic monitoring panel that Indicated the occurrence of a 0.035G earthquake. The CR implemented the procedure for seismic events and directed plant personnel to check for earthquake damage. The shift superintendent declared an unusual event at 8:12 a.m. due to the earthquak ;
At 8:25 a.m., the CR received an Emergency Feed Water Pump A/B not available alarm. Attempts to reset the trip were unsuccessful, and a mechanicel maintenance team was dispatched to troubleshoot and repair the proble At 8:49 a.m., the CR received indication of a ground on Switchgear 383 Electrical maintenance was dispatched to investigate. The investigation revealed a ground in Motor Cnntrol Cabinet 317 At 9:10 a.m., the CR received alarms indicating a fire in the area of the Train B switchgear. The shift superintendent declared an alert at 9:17 a.m. based on a fire in the protected area potentially affecting safety systems. The alert declaration prompted the staffing and activation of the other emergency response f acilities, c At 9:50 a.m., a control element assembly drive mechanism control system timer
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failure alarm was received. The CR dispatched instrumentation and control maintenance to investigat At 10:25 a.m., the CR received a blowdown demineralizer flow low alarm and two
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blowdown valves indicated closed. The CR dispatched instrumentation and control maintenance to investigate,
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At 11:30 a.m., the CR noted a large mismatch between letdown flow and charging flow, immediately following the mismatch, the CR received a high radiation alarm and indication on Stearn Generator B. The CH identified a steam generator tube leak. At 11:34 a.m., Charging Pump A tripped and Charging Pump A/B failed to star At 11:40 a.m., the CR manually tripped the reactor, initiated safety injection, and initiated containment isolation based on the leak rate exceeding the charging capacity. The EOF director, who had assumed primary emergency duties at 10:30 a.m., immediately declared a site area emergency based on reactor coolant system leakage greater than available charging pump capacity. A plant cooldown was commenced, and a site evacuation of nonessential personnel was conducte At about 12 noon, a loss of condenser vacuum occurred, and Atmospheric Dump Volvo 1 f ailed to open. Since an evaluation revealed that it would take some time to repair the valve, the CR decided to use Atmospheric Dump Valve 2 to cooldown the core. This resulted in a controlled release of radioactivity to the atmospher At 1:35 p.m., the CR received a loose parts monitor alarm due to a dislodged tube plug on Steam Generator 2. The dislodged tube caused tube leakage to increase to 432 gpm and resulted in approximately 1 percent fuel damage to the cor At about 1:40 p.m., Main Steam Safety Valve MS1080 failed open due to a broken cpring. The CR received alarms indicating an increase in radiation in the vicinity of the main steam safety valves and noted that levels were decreasing in Steam Generator 2 and the pressurizer. This event was characterized cs a steam line break,instead of a stuck open main steam safety valve as planned by scenario developer At 1:51 p.m., the EOF director declared a general emergency based on high offsite dose rates. The CR staff responded to other events and annunciators as required throughout the remainder of the exercise. The exercise was terminated at about 3:55 p.m.
P4.2 Control Room (CR) Lrnocction Scone (82301-03.02)
The inspectors observed and evaluated the CR simulator staff as they performed tasks in response to the exercise scenario conditions. These tasks inc uded event detection and classification, analysis of plant conditions, offsite agency notifications, intomal and external communications, and adherence to the emergency plan and procedures. The inspectors reviewed applicable emergency plan sections and procedures, operations procedures, logs, and notification form _ , - ._- _
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-6- Observations and Findinag During the exercise, the CR crew quickly recogn! zed and analyzed emergency events. The shift superintendent declared the unusual event and alert within minutes of the initiating conditions, using the correct emergency action level Corresponding offsite agency notifications were made within regulatory time limit The voice notification system (emergency response organization call out) was promptly activated following the alert declaratio However, CR supervision did not properly implement EP-002100, " Personnel Accountability," Revision 14, which delayed entry of CR personnel into the accountability system. Specifically, following the 9:17 a.m. alert declaration, the shif t superintendent did not direct CR personnel to card in on the accountability card reader as required by Step 5.1 of the procedure. A plant wide announcement that the accountability system had been activated was made at 9:23 a.m. CR operators began entering identification cards into the accountability system card reader at 10 a.m. Such a slow response could delay accountability during site evacuation CR communications were effective. Briefings were frequent, structured, and interactive. Three part communications were used consistently and contributed to the CR team effor At times, CR operators lacked sufficient attention to detail to prevent unexpected system response to operator actions. Inspectors observed the following examples:
- At 1:11 p.m., CR operators reenergized Bus 3B317 without first checking the status of breakers for loads on the bus. An earlier fire in Motor Control Cabinet 3178 resulted in a modification that permitted operation of only one containment air cooler. When Bus 3B317 was reenergized, both containment air coolers were energize * At 2:36 p.m., CR watch standers attempted to close safety injection tank isolation valves with a safety injection signallocked in. Safety injection tank isolation valves are maintained in the open position by a safety injection signa * At about 2:40 p.m., the CR receivert a loose parts / valve monitor alar While the operator acknowledged several alarms during this time frame, no reference was made to the alarm response procedure. The correct rosponse to this alarm could have provided the operators with information pertaining to the emergency in progres * CR operator 3 did not reset the seismic monitoring panel that could have prevented acquisition of information pertaining to the effect of aftershocks on the plant. The seismic monitoring panel was a mock-up that consisted of two full size pictures of the panel. One picture showed the panelin alarm
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stat.;., the other showed the panel af ter reset. CR operators did not attempt to reset the pane The CR station log lacked sufficient detail to communicate decision basis or recreate the sequence of shifts events. inspectors observed two examples. First, inquiries of outside organizations concerning the magnitude of the earthquake was not logged. Second, a break in the logs occurred from 11:30 a.m. to 1:20 During this time, the reactor was tripped, safety injection and containment isolation were initiated, a site area emergency was declared, site evacuation was accomplished, and heat was removed from the core using the atmospheric dump valve on a steam generator with a tube leak. None of these events were captured, nor was the occurrence or subject of the frequent CR briefings documented, Conclusions CR performance was generally good. Operators rapidly detected and accurately classified emergency events, Corresponding offsite agency notifications were correct and timely. CR briefings were frequent, structured, and Interactiv Three part communications were used consistently and contributed to the effectiveness of the CR team. The sequence of events and basis for decisions were not suf ficiently documented in the station logs. At times, operators lacked sufficient attention to detail to prevent unexpected system response, and CR supervision did not fully implement the personnel accountability procedur P4.3 Technical Supoprt Center (TSC) Inspection Scone (8230103.03)
The inspectors observed and evaluated the TSC staff as they performed tasks necessary to respond to the exercise scenario conditions. These tasks included staffing and activation, accident assessment, NRC notifications, personnel accountability, f acility management and control, onsite protective action decisions and implementation, internal and external communications, assistance and support to the CR, and prioritization of mitigating actions. The inspectors reviewed applicable emergency plan sections, procedures, and logs, Observations and Findinas The TSC was activated 38 minutes after the alert declaration. Activation was delayed briefly due to health physics coordinator communication equipment problems. The emergency coordinator made the appropriate announcements when the TSC was activated. The TSC was staffed with the appropriate number of personnel with the requisite expertise for the positions assigne Plant conditions were analyzed and evaluated in a timely and effective manner. The TSC staff held discussions and briefings, during which, appropriate responses to emerging issues were determined. The TSC staff also discussed the responses with the CR, OSC, and EOF, as appropriate.
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The TSC emergency coordinator demonstrated very good management practices ;
that included:
- Conducting frequent, comprehensive, and concise plant wide briefings, j
- Stressing three part communication ;
i e Conducting frequent, thorough staff briefings to assess changes in plant i conditions, (
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- Ensuring f acilities priorities and goals were effectively communicated throughout the emergency organizatio ,
Coupled with the staff's efforts and support, the TSC personnel functioned well as
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a tea Personnel accountability within the TSC was not wellimplemented in the initial -
portion of the exercise. The inspectors observed that the TSC accountability coordinator was unsure of the position requirements until briefed by another participant. Additionally, also early in the exercise, personne! were sate performing callbacks af ter leaving the TSC (requested at 15 minute intervals). The TSC contacted these personnel using the plant paging system in order to mainialn personnel accountabilit !
A cite evacuation was properly initiated following the site area emergency i declaration. The assembly / initial accountability was promptly completed in 22 minutes. The inspectors noted that a radiological control point was properly established at the entrance to the TSC. Health physics personnel routinely conducted thorough TSC habitability evaluation The inspectors observed that the status boards were kept un to date and effectively used by the TSC staff. The inspectors also observed that the TSC logs were thorough, Conclusions The TSC staff's performance was very good. The staff developed effective ,
strategies to address equipment problems. The TSC personnel functioned well as a team. Frequent and comprehensive site wide briefings were conducte6 and r three-part communications were stressed. TSC personnel accountability was .
initially not wellimplemented because the accountability coordinator was unfamiliar with the position and some personnel were late performing callbacks af ter leaving
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, 9 P4.4 Ooerational Sunnort Center (OSCI
- a, jnsoectior, Scone (8230103.05)
The inspectors observed and evaluated the OSC staff as they performed tasks in response to the scenario conditions. These tasks included functional staffing and emergency response team dispatch and coordination in support of CR and TSC requests. The inspectors reviewed applicable emergency plan sections, procedures, logs, checklists, and forms.
' Observations and Findinas Following the 9:17 a.m. alert declaration, the OSC was staffed and activated at 9:53 a.m. The OSC supervisor announced the activation to center personnel. The
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activation was considered timel Center briefings were conducted on a regular basis. The briefings addressed plant parameters, emergency classification, and the status and priorities of tasks. Early in the exercise, the volume on the speakers in the OSC assembly area was very low. Soon af ter the problem was identified, the volume was adjusted to make the-announcements easy to hea Generally, communications from the OSC management to center personnel was very good. The OSC supervisor made frequent rounds through the center to check on the status of tasks and to maintain awareness of actions within the cente Habitability surveys were performed on a regular basis. Continuous airborne monitors were used to monitor for airborne radiation. The instruments used for surveys and contamination monitoring were properly response checked prior to us However, radiological exposures were not adequately monitored or controlled, and onsite coniamination controls were not properly established. For example:
- During the radiological release, personnel were dispatched from the OSC and returncd from the -4 foot elevation access point without self reading dosimeters or equivalent (they were not monitored in transit).
Procedure EP-002130, " Emergency Team Assignments," Revision 17, Section 5.1.3.4 stated that the OSC health physics liaison will contact the radiation control coordinstor and discuss the need to issue dosimetry, protective clothing and/c r respirators to team personnel prior to leaving the OSC. There was no record of this discussio * During the release, an individual lef t the OSC and entered the service building. The records did not show that the individual left the OSC, nor was the individual briefed on external radiological condition Procedure EP-002190, " Personnel Accountability," Revision 14, Section 5.1.3.1, stated that all OSC personnel shall check out with the
' applicable maintenance lead or OSC supervisor prior to leaving the OS . .
Center management was not clearly informed of the individual's destinatio Other personnel observed the individual leave and reported the information to OSC management: however, there was no record of followup action * Appropriate precautions were not taken for an individual who was added to an existing team. The individual was tasked to obtain parts from the service building and deliver the parts to Team 9 (already at the work location). The individual was instructed to take a route that was different than that used by the team. However, since the individual's name was just added to the .
briefing form used tor Team 9, no additional radiological requirements were establishe Procedure EP-002130, "Ernergency Team Assignments," Revision 17, Section 5.1.3.3, stated that the OSC health physics liaison will contact the radiation control coordinator and discuss the routing assigned to the tas Section 5.1.3.4 further stated that the OSC health physics liaison will contact the radiation control coordinator and discuss the need to issue dosimetry, protective clothing and/or respirators to team personnel prior to leavira the OSC. There was no record of this discussion. As a result, the individual was not aware of the ongoing release, not provided a self reading
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dosimeter or equivalent, and not briefed on expected dose rates or contamination levels associated with the specified rout * Contamination controls for personnel exiting the plant were ineffective due to improper use of portal monitors at the primary access point and the location of the nearest friskor. An individual did not respond properly to alarming portal monitors at the primary access point (the individual added to Team 9). When told that the monitors were alarming, the individtal exited through the portal monitor and proceeded to a frisker outside the protected area. Since this individual was considered contaminated, the area outside the portal monitors was contaminated. The individual contacted the OSC and was directed to report to the -4 foot elevation access poin Health physics personnel were not informed that a contaminated individual had alarmed the portal monitors or had used the frisker. Therefore, a survey of the primary access point was not performe * Personnel contaminations were not investigated to determine where the contaminations originated and what areas hart been contaminated by the individuals. This investigition would have highlighted the need to establish better controls for personnel who traveled between the OSC and 4 foot elevation access control point. Moreover, this investigation could have identified the need to assess the dose for the contaminated individual who was added to Team * Contamination controls were inconsistently applied between the OSC and the 4 foot elevation access point. Personnel who lef t the OSC to go to the
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4 foot elevation access point were required to wear protective clothing, but personnel who left the 4 foot elevation to return to the OSC were no * Radiological comrols were not properly enforced within the OSC. At 3:10 p.m., there were participants outside the OSC north door who were smoking, even though there was a release in progress at the time, and eating, drinking, smoking, and chewing had been suspended. The sign on the door stated that exit was not permitted without an OSC supervisor briefing. There were no documents to indicate that this briefing occurre in addition, these individuals entered the OSC through a rear door and returned to work without frisking. There were no contamination surveys documented for the area outside the OSC rear door. As a resu;t, thc OSC could have been contaminate Due to the potential impact on personnel safety, the f ailure to adequately monitor or control radiological exposures and properly establish onsite contamination controls was identified as an exercise weakness (50 382/9718 01).
The inspectors observed the fire brigade's res;ponse to the simulated fir Procedure FP-001020, " Fire Emergency / Fire Report," Revision 10, Section 0.7.1.2, stated that the fire bigade shall don fire fighting apparel and self contained breathing apparatus and proceed to the fire scene. The fire brigade f ailed to use respiratory protection for a fire with toxic smoke in an onclosed space; therefore, personnel could have been impaired or injured. Moreover, the f ailure to use respiratory protection could have jeopardized the fire fighting response. Specific observations included:
- Personnel did not don the self contained breathing apparatus before entering the area as required by the fire emergency / fire report procedur * Not all fire brigade personnel had self contained breathing apparatus. The fire brigade member who discovered and reported the fire remained in the area while another fire brigade member went to dress out and bring an extra set of equipment. The individual only brought ene self-contained breathing apparatu Due to the potentialimpact on personnel safety, the failure of the fire brigade to properly use respiratory protection was identified as an exercise weakness (50 382/9718 02).
During the exercise, plant announcements wera not always offective:
- A 10:06 a.m. announcement for visitors to leave the protected area was confusing because it stated that the direction was based on the unusual event declaration. An alert was in progress at the tim .
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- Some announcements within the plant were inaudible or not clear. Examples included: (1) the ramp outside Door 49 (the speaker is above the overhead and aimed such that the sound was muffled), (i, the area between Door 49 and the northeast corner of the fuel handling building (the echo distorted the sound), and (3) near the middle of the north side of the fuel handling buildin Conclusions The OSC staff's performance was adequate. The center was activated in a timely manner, and briefings were frequent and comprehensive. Three part communications were strongly emphasized. Habitability was cor. firmed and routinely assessed. Status boards were adequately used and updated in a timely manner. An exercise weakness was identified for failure to implement proper radiological exposure controls (dosimetry and contamination controls). An exercise weakness was identified for failure of the fire brigade to use required respiratory protection while combating a fire with toxic rnoke in an enclosed spac P4.5 Ememenev Ooorations Facility (EOF) Insoection Scone (8230103.04)
The inspectors observed the EOF's staff as they performed tasks in response to the exercise. These tasks included f acility activation, event classification, notification of state and local response agencies, development and issuance of protective action recommendations, dose projections, field team control, and direct interactions with offsite agency response personnel. The inspectors reviewed applicable emergency plan sections and procedures, forms, dose projections, and participant logs, Observations and Findinna The EOF was promotly staffed after the 9:17 a.m. alert declaration. Upon arrival, personnel obtained position specific supplies and procedures and readied the facility for operation. Minimum f acility staffing was achieved at 9:43 a.m. At 10:38 a.m.,
following a comprehensive briefing with key facility personnel and a formal turnover with the TSC, the EOF director activated the facility. EOF activation was not required by the emergency plan until 1 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after a site area emergency declaration; however, during recent training, the organization has been encouraged to relieve the TSC of emergency coordinator duties as soon as possible to allow the TSC to focus on CR support. Upon activation, the EOF director assumed the responsibilities for event classificatior', offsite agency notifications, and protective action recommendations. Facility activation and the transfer of essential emergency responsibilities were conducted in a systematic manne Scenario events were quickly recognized and classified using the correct emergency action levels. The EOF director declared the site area emergency at 11:40 a.m.,
based on reactor coolant leakage greater than charging pump capacity, and a general emergency s 7:51 p.m., based on offsite duses exceeding procedural
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i 13- l limite. Corresponding offsite agency notifications were made well within the
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15 minute requirement. Followup notifications, in between emergency classification changes, were made at 30 minute intervals in accordance with !
procedure j The protective action recommendation that accompanied the general emergency .
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nutification (evacuation of a 2 mile radius and downwind to 5 miles) was properly formulated and quickly communicated; however, the decision to upgrade the
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protuctive action recommendations to include three a Mitional protective response areas within 510 miles in the downwind direction was unnecessarily delayed and not communicated to offsite agencies in a timely manner. At 3:25 p.m., dose projections indicated a need to upgrade the protective action recommendations to include an evacuation of Protective Re:.ponse Areas A4, C3, and C4. Doses exceeded 1 rem total effective dose equivalent and 5 rem thyroid committed dose
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equivalent beyond 5 mile The EOF director was out of the room when the dose projections first became >
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available. The radiological assessment coordinator and fieH team coordinator l discussed the dose projection results with the state. The EOF director joined the !
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discussions in progress. The dose projections were characterized as accurate, since they were based on field team results at known distances (pre-determined sampling points).
During the discussions with the state representatives, the option of issuing a !
protective action recommendation that included fewer protective response areas than required by Procedure EP 002 052, " Protective Action Guidelines,"
Revision 16, was discuesed. The decision to follow the procedure and make the recommendation in the three additional areas was not made until 3:45 (20 minutes after the information first became available). Offsite agencies were notified at 3:50 p.m., 25 minutes after the information was available. The fallure to make a timely protective action recommendation to offsite agencies was identified as an exercise weakness (50 382/9718 03).
Information flow was challenged by the lack of EOF briefings during the latter stages of the exercise and EOF public address system limitations. Although briefings were initially very systematin and cornpret isive, there were no EOF briefings, except for the site area and general emergency announcements, after 11:17 a.m. The exercise was terminated at about 3:55 p.m. As a result, some facility personnel may not have bt.en aware of f acifity priorities, offsite protective action decisions and implementation, results of EOF habitability surveys, etc. In >
addition, the EOF public address system ovenode TSC public address announcements. As a result, some information provided by the TSC could have been lost or delaye '
- Consistent with EP-001-030, " Site Area Emergency," Revision 22, the EOF director ordered a site evacuation following the site aroa emergency declaration. However, the site evacuation was not propstly coordinatad with security before trie '
announcement was made. As a result, security may not have been prepared to
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handle the site evacuation (the large, number of individuals exiting the site at once).
Specifically, Step 5.2.2 of the site area emergency procedure raquired that the security shif t supervisor be notified before sounding the station alarm. The TSC sounded the alarm (the EOF does not have this capability) before the EOF director requested security notification. The coordination difficulties appeared to be related to the TSC and EOF sharing k plementation responsibilitie Radiological assessmant activities (EOF habitability, field team control, and dose projections) were well controlled and implemented, EOF habitability was frequently confirmed, and field teams were effectively positioned to determine the offsite impact of the radiological release. The dose assessment staff performed numerous dose projections. Initial dose projections were based on plant conditions (for the first minor release). Following the major release, dose projectionc were based on field team open/ closed ion chamber window readings and air sample results. When dose projections indicated a need to consider protective actions beyond the 10-mile emergency planning zone, the results were discussed with state representative The exercise was terminated immediately af ter these discussion Three part cort ;nications were frequently used in the EOF, particularly among the radiological assessment team, to ensure that directions and communications were correctly communicated. When individuals forgot to complete the second part, the provider often reminded the receiver to repeat back the instructions /informatio Status boards were generally useful and maintained during the exercise. Two exceptions were observed. First, the plant pararneters status board was difficult to read from the EOF direuor's table. The inability to read the board could have
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presented a problem il plant parameters were discussed during telephone discussions with outside entities (NRC and state / parishes). Second, the major events status board did not capture some significant events (OSC activation).
Interactions with state response team members who were stationed in the EOF were frequent, open, and constructive. Upon arrival, state representatives were briefed on plant conditions and prognosis. The stato provided good feedback to the EOF director regarding the status of offsite protective action implementation, Conclusions The EOF staff's performance was generally good. Facility members frequently used three part communications to ensure that instructions were understood. Briefings were initially detailed and comprehensive, but the frequency degraded during the last half of the exercise. Emergency classifications were correct and ti ely, and, with one exception, offsite agency notifications were made promptly following changino plant conditions. An exercise weakness was identified because a protective action recommendation upgrade decision was unnecessarily delaye Dose assessment and field team control activities were well managed and executed to determino actual offaite impact. Interactions with offsite response members
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i 15 f P4.6 Scenario and Exercise Control insoection Scone (82301 and 82302) i
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The inspectors evaluated the exercise to assess the challenge and realism of the scenario and exercise contro i Observations and Findinas !
The licensee submitted the exercise objectives and scenario for review on July 23 !
and September 8,1997, respectively. The exercise objectives were considered appropriate to demonstrate emergency response capabilities and commitment Moreover, the objectives were exceptionally detailed and measurable, During the scenario review, the NRC identified an inconsistency in the licensee's l emergency action levels. The inconsistency involved the use of dose rates instead i of integrated doses in offsite dose related emergency action levels. The licensee ;
stated that the inconsistency would be corrected by early in the second half of ;
1998. The emergency planning manager created an emergency planning action f item to track the procedure and dose code corrections. This response was acceptabl The scenario was sufficiently challen0 ing to test onsite emergency response capabilities. The licensee developed 13 mock ups to use during the exercis Mock ups included:
- Full size photograph of the seismic panel
- A simulated Cil ventilation panel
- Training aid with the poppet stem for the terry turbine f ailure
- Photograph of Panel 59 ovmvolt relay (simulated smoke from fire)
- Photograph of control element _ drive mechanism control system panel
- Charging pimip
- Atmospheric dump valve
- Photograph of loose parts monitor panel
- Safety valve (plus a recording of steam leak over plant page)
- Photograph of a DC voltmeter
- Initial conditions in plan of the day format
- Radio controlled radiation survey meters
- Simulated radiation monitors
- Although some of the mock ups, particularly the steam leak sound effect over the plant page (discussed further below), may not have produced the expected response from exercise participants, as a whole, the licensee's efforts to increase the realism for exercise participants and reduce controller provided messages /information were identified as a program strength. The number and types of mock ups were significantly more than seen at other site .. .
. 16-In contrast, the following aspects of exercise conduct and control detracted from the realism and training value of the exercise and _were considered areas for _
improvement:.
- ~ An unanticipated operator action resulted in an unexpected change in plant parameters. Simulator control booth operators programmed a plant parameter change (radiation levelincrease) to occur when a specific alarm panellight was energized. When CR operators took the entire alarm panel to test, the light was energized, resulting in an early/ unexpected chang Simulator controllers properly Intervened to correct the scenari * Observer interference distracted an exercise participant. An observer approached a CR operator during the exercise and held a nonexercise related conversation at the CR supervisor's des * Ambiguous information given to the participants inhibited / delayed identifying the stuck open safety relief valve. The valve stuck open at approximately 1:40 p.m., but a team was not dispatched to determine the source of the steam leak until '3:45 p.m. As a result,-TSC resources were tied up attempting to mitigate a stsam line break that did not exist. Although the controller information and the steam leak sound effect did not produce the planned conclusion, responders also demonstrated a lack of a questioning attitude concerning the location of the releas * There were not enough controllers / monitors available to accompany personnel who exited the OSC. Two examples were observed. First, a monitor escorted the contaminated individual from the primary access polht to Door 49 then lef t the area. The individual waited for a radiation protection technician from the -4 foot elevation access control point. Upon arrival, there was no one there to provide the contamination levels for the individual and for the area in which they were waiting. _Second, there was no monitor at the primary access point when radiation protection personnel responded to the alarming portal monitor Conclusio01 The exercise objectives were exceptionally detailed and measurable. An inconsistency in the dose related emergency action levels was identified during the scenario review; appropriate corrective actions were identified. The scenario was sufficiently challenging to test onsite response capabilities. The use of mock ups to increase the realism for exercise participants was identified as a program strengt Although' ambiguous information given to the participants inhibited / delayed identifying the stuck open safety relief valve, participants did not exhibit a-questioning attitude. The lack of radiation protection controllers / monitors limited participant response in the OS ,
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P4.7 Licensee Self Critious Insoection Scope (8230103.13)
The inspectors observed and evaluated the licensee's post exercise facility critiques and the formal management critique on November 7,1997, to determine whether -
the process would identify and characterize weak or deficient areas in need of corrective actio Observations and Findinas With the exceptioI, of the OGC, post exercise facility critiquen were thorough, open, and self critical with input from participants, evaluators, and controllers. Facility specific observations and exceptions included:
- In the CR simulator, participants appeared genuinely concerned with improving performanc * All TSC personnel directly participated in the critiqu * With respect to OSC performance, the lead controller gave a general outline of the scenario with comments on some of the main cbservations made during the exercise. Comments were provided by controllers, monitors, and evaluators; however, comments were pref aced with a statement that there would be further review and discussion before final comments would be
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provided at a later date. This approach appeared to limit the discussion'to well understooo issues only. There was very little feedbeck provided by exercise participant * Tho lack of participation by state representatives in the EOF detracted from the overall completeness. The licensee stated that the state representatives normally attended the critiques but were unable to stay on this occasion because of previous commitments. Most participants tended to focus on positive performance. Controllers, evaluators, and the EOF director were more critica Durin0 the November 7,1997, management critique, the emergency planning manager described the exercise critique process and presented the preliminary findings. The process, which was considered very comprehensive, incorporated post exercise f acility critiques, controller / monitor debriefs, controller / emergency
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planning debriefs, evaluator comments, quality assurance comments, peer review Droup comments, and a management review board. The use of a separate evaluator team and the use of a peer review group to independently assess performance were new additions to the licensee's critique process. The peer review group consisted of three emergency planning managers from the other Entergy sites and a representative from the Entergy Corporate Office. A followup participant critique to convey all exercise findings (licensee, Federal Emergency
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Management Agency, and NRC) was planneo for Novembet 10,1997. Key participants were required to attend; all others were invite j l
.The licensee's critique process / evaluation team identified two exercise weaknesses: l one for exercise control and one for inadequate radiation protection practices in the i OSC. In addition,6 significant improvement areas and 80 observations were ;
identified. The failure of the fire brigade to don self contained breathing apparatus I was identified as a significant improvement area. The emergency planning manager j
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stated that strengths were identified but that they would not be discussed during ;'
the meeting because identifying areas for improvement was the primary purpose.
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The integrated critique process was very comprehensive and considered a program i strength due to the quality of the post exercise critiques (OSC excepted), the use of a separate avaluation team and peer review group, and the continued practice of conducting a followup participant critique. The critique process emphasized areas in need of improvement, rather than areas of strennt P8 Miscellaneous Emergency Preparedness issues (92904)
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P [ Closed) Insoection Followuo item 50 382/9514 01: Exercise weakness for the f ailure of the TSC to clearly communicate ir;structions and to positively j followup / verify that the primary access point hau been relocated. The licensee's corrective actions included:
- Revising emergency planning procedas to implement three part communication * Training all emergency response personnel on the new communication requirement ,
- Incorporating the lessons learned from the 1995 exercise in the tabletop program and operations department seminar The inspectors observed very good three part communications in the TSC. The emergency coordinator and operations coordinator were proactive in ensuring i members of the TSC staff adhered to the communicstion expectation. The licensee '
also ensured, during the exercise, that security personnel were aware of site areas t that were restricted due to radiological condition ' P8.2 iClosed) Insoection Followun item 50 392/9606 02: Larcise weakness for failure to properly augment emergency response personnel. During s!mulator
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walkthroughs, one crew failed to activate the voice notification system per Step 5.3.1 of Procedure EP-001-030, " Site Area Emergency," Revision 21. Corrective actions included revising applicable emergency plan implementing procedures to relocate the voice notification system activation to an earlier step in the procedure
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f During this exercise, CR personnel promptly actuated the voice notification system i following the alert declaration (within 1 minute).- '
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V. Manaaement Meetlans i
X1 Exit Meeting Summary
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The inspectors presented the inspection results to members of licensee management at the conclusion'of the inspee 'n on November 7,1997. The licensee acknowledged the facts presented. No proprietary information was identified, j
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The Federal Emergency Management Agency scheduled a pub!!c meeting on November 6, [
1997, to discuss the preliminary exercise results. Since there was no media or public . '
attendance at the meeting, the meeting was convened and immediately adjourne }
Subsequent to the inspection, on November 10,1997, the licensee informed the l
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inspection team leader that a remedial drill would be conducted for the OSC On November 12,1997, the emergency planning manager informed the inspection team >
leader of the immedit.te, short term, and long term actions that would be taken to address the issues identified in the report. The licensee planned to itemize the e actior,s in its response to the weaknesses. -The actions discussed during the calls a, peared comprehensive and timel !
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SUPPLEMENTAL INFORMATION i PARTIAL LIST OF PERSONS CONTACTED i i
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T. Leonard, General Manager, Plant Operations M. Brandon, Supervisor, Licensing F. Drummond, Director, Site Support
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s E. Ewing, Director, Nuclear Safety and Regulatory Affairs T. Gaudet, Manager, Licensing l A. Harris, Superintendent. 9eactor Engineering J. Hoffpauir, Manager, Operations M. Langan, Workweek Manager, Planning and Scheduling J. Lewis, Manager, Emergency Planning T. Lett, Lead Supervisor, Radiation Protection A. Lubinski, Ernergency Planner D. Madere, Superintendent, Chemistry
- D. Marpe, Superintendent, Maintenance J. O'Hern, Director, Training D. Vinci, Manager, Plant Engineering
. A. Wrape lil, Director, Design Engineering Oiher Personnel P
W. Gresham, Manager, Emergency Planning, Arkansas Nuclear One A. Morgan, Manager, Em:rgenew Preparedness, Grand Gulf Nuclear Station NEG J. Keeton, Acting Senior resident inspector-LIST OF INSPECTION PROCEDURES USED IP 82301 Evaluation of Exercises at Power Reactors IP 82302 Review of Exercise Objectives ana Scenarios for Power Reactors IP 92904 Followup Plant Support
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LIST OF ITEMS OPENED AND CLOSED e Ooened 50 382/97018 01 IFl Exercise weakness Failure to adequetely monitor and control [
radiological exposures and establish contamination controls (Section P4.4) - !
50 382/97018 02 IFl E reise weakness . Failure of the fire brigade to use required !
respiratory protection (Section P4.4) [
50 382/97018 03 IFl Exercise weakness Failure to issue a timely protective action [
iecommendation upgrade (Section P4.5) [
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t 50 382/95014I)1 IFl Exercise weakness - Failure to clearly communicate and followup on instructions (Section P8.1)
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50 382/96006-02 IFl Exercise weakness Failure to properly augment emergency response personnel (Section P8.2)
LIST OF DOCUMENTS REVIEWED Emeroonev Plan imolementina Procedures EP 001001 Recognition and Classification of Emergency ,
Conditions Revision 18 EP-00101r Unus,ual Event Revision 20
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EP 001-020 Alert Revision 23 EP-001 030 Site Area Emergency Revision 22 EP 001-040 General Emergency Revision 23 EP 002 010 Notifications and Communications Revision 25 .
EP-002-015 Emergency Responder Notification Revision 06 EP-002 030 Emergency Radiation Exposure Guidelines and Controls Revision 7 EP.002-031 In plant Radiological Controls and Surveys During Emergencies Revision 6 EP-002-032 Monitoring and Decontamination Revision 11 EP-002 033 Administration of lodine Blocking Agents Revision 8 EP-002 034 - Onsite Surveys During Emergencies Revision 4 EP-002 052 Protective Action Guidelines Revision 16
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EP-002-071 Site Protective Actions' Revision 13 ,
EP-002100 Technical Support Center Activation, Operation '
and Desctivation Revision 26 EP-002101 Operational Support Center Activation, Operation, and Deactivation Revision 22 EP 002102 . Emergency Operations Facility Activation, t
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- Operation and Deactivation - Revision 25 - i
- EP 002130 - Emergency Team Assignments : Revision 17- -
EP 002190 ' Personnel Accountability Revision 14 EP 003-014 Contro! Room Heating and Ventilation Revision 06 Other Procedures I
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FP 001020 Fire Emergency / Fire Report Ravision 10 j
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