ML20211K105

Insp Rept 50-298/86-25 on 860922-26.No Violations or Deviations Noted.Major Areas Inspected:Performance & Capabilities During Exercise of Emergency Plan & Procedures. Three Deficiencies in Emergency Response Area Identified

ML20211K105
Person / Time
Site:	Cooper
Issue date:	11/07/1986
From:	Hackney C, Yandell L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20211K097	List: ML20211K093 ML20211K105
References
50-298-86-25, NUDOCS 8611170018
Download: ML20211K105 (10)

See also: IR 05000298/1986025

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l APPENDIX

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-298/86-25 License: DPR-46

Dockets: 50-298

Licensee: Nebraska Putlic Power District (NPPD)

P. O. Box 439

Columbus, Nebraska 68601

Facility Name: Cooper Nuclear Station (CNS)

Inspection At: Brownville, Nebraska

Inspection Conducted: September 22-26, 1986

Inspector: Godf

C. A. Hackney, Emerg

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Personnel: C. Wisner, NRC Region IV

J. B. Baird, NRC Region IV

W. M. McNeill, NRC Region IV

T. Lynch, Battelle

G. Bryan, Comex

Approved: (lu 11/ 7///o

L. A. Yandell, Chief, Emergency Preparedness Dat'e

and Safeguards Programs Section

Inspection Summary

Inspection Conducted September 22-26, 1986 (Report 50-298/86-25)

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

and capabilities during an exercise of the Emergency Plan and procedures.

Results: Within the emergency response areas inspected, no violations or

deviations were identified. Three deficiencies were identified. (Sections 6

and 9)

8611170018 861112

PDR ADOCK 05000298

o PDR

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DETAILS

1. Persons Contacted

Principal Licensee Personnel

D. Norvell, Maintenance Manager

• P. R. Windham, Emergency Planning Coordinator

C. Goings, Regulatory Compliance Specialist

• J. Sayer, Assistant Technical Staff Manager

• J. M. Meacham, Technical Manager

J. W. Boyd, Shift Supervisor

R. D. Black, Operations Supervisor

• R. Hayden, Emergency Preparedness Specialist

• L. Kuncl, Vice President, Nuclear

• K. Krumland, Acting Emergency Planning Coordinator, General Office

D. Schaufelberger, President, NPPD

• J. Flash, Public Information Coordinator, Nuclear

G. Trevors, Manager, Nuclear Licensing and Safety Department

R. Wilber, Manager, Nuclear Services Division

T. Knippenburg, Consultant (Nutech)

M. Krumland, Emergency Planning Specialist

R. Palazo, Consultant (Nutech)

• G. Horn, Division Manager, Nuclear Operations

• E. Mace, Engineering Supervisor

W. Keller, Technical Support Center (TSC) Controller (Nutech)

D. Reeves, TSC Controller

R. Gibson, TSC Quality Assurance

NRC

• D. L. DuBois, Senior Resident Inspector

• E. A. Plettner, Resident Inspector

Federal Emergency Management Agency (FEMA)

R. Leonard, Program Manager

D. Sumpter, Senior Technological Hazards Specialist

The NRC inspectors also held discussions with other station and corporate

personnel in the areas of health physics, operations, and emergency

response organization.

• Denotes those present at the exit interview.

2. Licensee Action on Previous Inspection Findings

Closed (0 pen Item 50-298/8528-01). The licensee demonstrated the ability

to establish initial and continuous accountability.

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3. Exercise Scenari,o

i The exercise scenario was reviewed for completeness, continuity, and i

j consistency in conjunction with the requirements of 10 CFR 50, Appendix E,  ;

Section IV.F, and the guidance in NUREG-0654,Section II.N. The areas l

reviewed included objectives, events sequence, scenario messages, plant

parameter data, meteorological data, and radiological data. The events

sequence appeared adequate to allow the licensee to meet the listed

objectives. Specific aspects of the review are noted below:

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o The scenario contained objectives on which an evaluation of the

exercise could be made.

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o A narrative summary included in the scenario described the events

sequence and supporting information.

o The scenario messages were adequate to allow the controllers to

maintain the scenario time line.

o The scenario data adequately supported the sequence of events.

4. Control Room (CR)

Initial conditions were given to the operations personnel prior to the

initiation of the exercise:

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o CNS is operating at 100 percent rated power. The unit has been

operating continuously for 86 days. The core is near the end of core

life and has been exposed for 349 effective full power days,

j o RWCU pump "B" is isolated for corrective maintenance.

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o SBGT "B" is inoperable due to a seized fan. All required

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surveillances are complete and satisfactory for today. SBGT "B" was

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declared inoperable this morning and repairs should be completed

within 2 days. '

o Feedwater heater levels have experienced some unexplained

fluctuations during the past week. Investigation continues.

1 Feedwater heater levels are presently stable.

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o All other plant systems are operable and in normal 100 percent

j operating configuration.

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i The exercise was initiated at 7:15 a.m. with a severe storm watch and

l associated wind of 70 mph and increasing. The licensee declared a

Notification of Unusual Event (NOVE) in accordance with Emergency Plan

Implementing Procedure (EPIP) 5.7.1 and Emergency Action

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' Level (EAL) 12.1.4., due to winds exceeding 74 mph. At 8:00 a.m., 69 kv

lines supplying the emergency station service transformer were severed due

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to high winds. A maintenance technician was injured and determined to be

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contaminated. The technician was administered first-aid and dispatched to

the hospital. The injured and contaminated person was'an EAL for the NOUE

! emergency class. At 8:30 a.m., a fire was reported in the diesel

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generator room and the fire teams were dispatched to the fire. An Alert

classification was declared at 8:35 a.m. Following the declaration of the

Alert, the Technical Support Center (TSC) was activated. Transfer of

, command to the TSC was announced at 9:07 a.m. The NRC inspector observed

that control room personnel consulted and utilized their procedures for

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the fire and dnormal operating conditions. Plant drawings and Technical

l Specifications were referenced during the exercise. Operations personnel

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responded to plant conditions in a timely manner and exhibited initiative

toward solving abnormal problems. Communications from the control room to

onsite and offsite agencies appeared adequate.

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! The following observation was called to the licensee's attention by the

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NRC inspector. The observation is neither a violation nor an unresolved

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item. The item was recommended for licensee consideration for

improvement, but it has no specific regulatory requirement.

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o Identify all player personnel in the control room in addition to

other emergency response exercise personnel.

No violations or deviations were identified.

l- 5. Technical Support Center (TSC)

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The TSC was activated approximately 20 minutes after the " Alert"

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declaration. Although the TSC was overcrowded due to the presence of both

primary and alternates for each position, upon activation the excess

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personnel moved to an adjacent Instrumentation and Controls shop and

i relieved the congestion. Habitability was marginal due to poor air ,

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conditioning. The noise level remained low despite the crowding in the

i TSC. Offsite notifications to the states and NRC headquarters were done in

a timely manner, although some of the information relayed in the initial

message to'the NRC was incorrect. Staff briefings were timely and

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generally adequate, except when limited by the control room's failure to

! relay critical information. Site-wide accountability was achieved in

! 33 minutes. Although TSC accountability was maintained, the process

should be reviewed to make it more efficient.

l The following are observations the NRC inspectors called to the licensee's

attention. These observations are neither violations nor unresolved

items. These items were recommended for licensee consideration for

improvement, but they have no specific regulatory requirement.

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o EPIPs 5.7.2, " Notification," and 5.7.20, " Protective Action

l Recommendations," should be revised to require that the Emergency

Director review the appropriate forms and authorize them via

signature for transmission on behalf of the licensee.

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o Modify status boards to include an unlabeled linear graph to allow

trending of key parameters and to allow the display of both the )

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licensee protective action recommendation and the protective actions

implemented by the state (s).

o The TSC should provide backup dose assessment calculations and

protective action recommendation evaluation for the Emergency

Operations Facility (EOF).

o The TSC staffing for engineering assessment should be reviewed for

adequacy.

o The methodology for maintaining accountability should be

standardized.

o Access and egress from the TSC should be limited to one door

controlled by the Security / Administration / Logistic (SAL) coordinator.

No violations or deviations were identified. .

6. Emergency Operations Facility

Emergency Operations Facility personnel began arriving after the Alert

declaration and the EOF was placed in standby approximately 50 minutes

after the declaration. The E0F was declared operational 37 minutes after

the Site Area Emergency declaration. Activation checklists were used.

Offsite notifications were made within 15 minutes after the Site Area and

General Emergencies were declared. However, the Emergency Director's

approval was not documented. The E0F Director held periodic briefings

that kept key state and licensee personnel informed on the plant status

l and offsite conditions. The briefinas were held off to the side from

where the Emergency Director sits, which caused some congestion and noise

problems.

l Source term data were erroneously entered into the dose projection model as

! microcurie /sec instead of Ci/sec. This resulted in projected offsite doses

which differed significantly (4 to 6 orders of magnitude) from the doses

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indicated by real time data and field monitoring data. There was

inadequate review of the dose projection results. Also, radiological

status boards were not updated periodically as new dose projections were

made.

The NRC inspectors observed the following deficiency:

o 10 CFR 50.47(b)(9) states that adequate methods, systems, and

equipment for assessing and monitoring actual or potential offsite

consequences of a radiological emergency condition are in use. Due

to the errors in dose projections and the lack of continuous

management review to ensure accuracy of the data, the capability

necessary to meet Objective 6 was not demonstrated (50-298/8625-01).

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The following are observations the NRC inspector called to the licensee's

attention. These observations are neither violations nor unresolved

items. These items were recommended for licensee consideration for

improvement, but they have no specific regulatory requirement.

o Radiological data in the EOF should be trended.

o The TRS-80 dose projection program should include the appropriate

dose rate units with the calculated values. Consideration should be

given to printing the cumulative dose values that the protective

action recommendations are based on.

o Attachment B to EPIP 5.7.18, " Dose Assessment," should be completely

filled out for each monitoring team. The NRC inspector noted that

the following information was left blank on Attachment B: instrument

type, serial number, team leader's name, and dosimeter readings.

o The offsite notification and protective action recommendation forms

should have a sign-off section for approval by the Emergency

Director.

o Offsite doses and dose rates should be periodically updated on the

radiological status board. The initial projected doses were left on

the status board for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 15 minutes, during which time several

new dose projection calculations were made.

o Radiological surveys should include the determination of habitability

by assuring that doors are closed and controlled during EOF

activation and operation.

o Seating and communications should be provided for the NRC and state

representatives near the Emergency Director.

o Briefings for key state and NRC personnel should be held in a

briefing room.

o The Emergency Director should spend more time directing the offsite

and onsite emergency response effort. Too much time was utilized on

the telephone trying to perform TSC and CR functions.

o The E0F critique was a summary of events and should have involved

participation by players and controllers.

No violations or deviations were identified.

7. Medical First Aid

The accident victim was to have been an individual that had a simulated

fall and was discovered by his co workers. The observer announced that a

person had been injured and needed assistance. Approximately ten persons

looked at the controller and one person responded to inquire about what

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had happened. The person responding notified the control room that an

injured person was lying down by a lathe in the shop. The victim was not

administered to or assisted until the medical team arrived. The medical

team arrived in approximately 12 minutes after the controller's

announcement. The patient was radiologically monitored for contamination

and prepared for transporting to the hospital via CNS ambulance.

No violations or deviations were identified.

8. Operational Support Centers (05Cs)

The OSCs were activated in a timely manner. Personnel accountability was

maintained and teams dispatched from the OSCs were logged in and out of

their respective OSCs. Response teams were briefed on the job tasks to be

performed prior to being dispatched from the TSC.

No violations or deviations were identified.

9. General Office Emergency Center

The NRC inspector reviewed the Emergency Plan, EPIPs, and corporate

nuclear emergency procedures (CNEPs) which described the functions of the

General Office Emergency Center (G0EC) during an emergency at CNS.

Several inconsistencies were noted as follows:

a. CNEP 1.0, " Notification of General Office Emergency Organization,"

had a former employee (A. C. Morgan) listed as an off-hours

monitor (OHM).

b. The G0EC organization chart depicted in Attachment F to CNEP 2.0,

"GOEC," did not agree with the organization shown in Figure 5.3-1 of

the Emergency Plan.

c. The CNEPs were previously referred to as " General Office

Guidelines" (G0Gs), and the Emergency Plan had not been revised to

replace the G0Gs with the new procedures.

d. EPIPs 5.7.6 and 5.7.28 made reference to the NPPD management position

"AGM-Nuclear." This management position title had been changed to

Vice President-Nuclear.

e. Except for notifications, the EPIPs did not specifically address the

interface between the CNS emergency response organization and the

GOEC functions described in the CNEPs.

The NRC inspector also observed the activation and operation of the G0EC

at the general offices in Columbus, Nebraska, on the day of the exercise.

The general office off-hours monitor was notified by CNS of the NOUE at

about 8:03 a.m., in accordance with EPIP 5.7.6. The OHM then contacted

and briefed licensee general office management. The OHM was subsequently

notified by CNS at about 8:53 a.m. that an Alert had been declared at the

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station and conditions were not stable. At approximately 8:58 a.m., the

OHM assumed the responsibilities of the G0EC Director and requested

staffing of the GOEC. At about 9:15 a.m., the GOEC Director announced

that the GOEC was declared operational without having the Emergency

Planning Coordinator (EPC) position filled. This position was specified

as one of the five minimum staffing requirements in Section II.C of

CNEP 2.0 and Section 5.3.1.A of the Emergency Plan. The position was not

staffed due to lack of depth in personnel qualified to perform the EPC

function. This deficiency was also identified by the licensee's

observers.

The NRC inspector observed that the G0EC Director demonstrated good

command and control of GOEC activities throughout the exercise, and except

for an approximate 1-hour period following his first briefing, provided

frequent and effective briefings to the GOEC staff. The NPPD President

and Board members were periodically briefed on events and response

activities. The first of these briefings was held in the president's

office between about 10:20 a.m. and 10:40 a.m. During this period, the

station conditions worsened and a General Emergency was declared at about

10:39 a.m. The NRC inspector noted that, since the briefing was outside

of the G0EC, the worsening conditions were not known to the briefer and

the briefing presented a station status inconsistent with events in

progress. Communications were maintained with the Media Release

Center (MRC) and EOF through a telephone conference line and by facsimile

transmissions. The NRC inspector noted that the public affairs and

information authentication functions were handled in an efficient and

effective manner, and support to the MRC in these areas appeared to be

very good. The NRC inspector also noted that the G0EC staff provided

timely and effective input to the GOEC Director throughout the exercise.

The GOEC Technical Advisor maintained communications with station

counterparts and provided technical information to the G0EC Director,

Public Affairs Director, and MRC staff.

The resources and administrative support functions were active in planning

and arranging for personnel and logistics support for CNS. In addition,

the Environmental Support Manager was observed to communicate with the E0F

on radiological matters, perform independent analyses on environmental

impacts, and provide interpretations and assessments of environmental and

public health impacts. The NRC inspector noted that key staff referred to

the CNEPs frequently and appeared to be following procedures and

checklists. Information flow appeared to be good and status boards were

generally maintained throughout the exercise. However, the event

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chronology displayed was very terse and appeared to be too limited in

scope and time span due to the small space allocated for this information

on one of the status boards.

At about 1:45 p.m. , the scenario clock was advanced 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and recovery

planning was demonstrated. The GOEC participated in the planning at CNS

by telephone conference call. Additional health physics technicians,

General Electric core assessment services, and engineering support were

discussed in addition to the environmental assessment plans. The G0EC

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participation in recovery planning appeared to be appropriate; however,

the NRC inspector noted that there were no written, approved procedures

specifying the GOEC role and responsibilities in implementing recovery

plans developed pursuant to the planning standard of 10 CFR 50.47(b)(13).

This is considered to be an emergency preparedness deficiency. Licensee

observers also identified this deficiency during the exercise. GOEC

participation was terminated with the end of the. exercise at about

4:00 p.m.

The NRC inspector observed the following deficiencies:

o The G0EC was activated and declared operational without the minimum

staffing (no Emergency Planning Coordinator) specified in

Section II.C. of CNEP 2.0 and Section 5.3.1.A of the Emergency Plan

(50-298/8625-02).

o No written, approved procedures were provided to control G0EC

recovery planning and support activities pursuant to the planning

standard specified in 10 CFR 50.47(b)(13) (50-298/8625-03).

The following are observations the NRC inspector called to the licensee's

attention. These observations are neither violations nor unresolved

items. These items were recommended for licensee consideration for

improvement, but have no specific regulatory requirement.

o The CNS EPIPs should be reviewed and revised as necessary to provide

specific interfaces with the GOEC CNEPs.

o G0EC organizational charts in the Plan (figure 5.3-1) and in

Attachment F to CNEP 2.0 should be brought into agreement.

o The CNS EPIPs and Emergency Plan should be reviewed and revised to

incorporate corporate organization title changes and the change in

corporate implementing procedures nomenclature,

o More space should be provided for significant event information

display in the GOEC than currently provided on the status board.

No violations or deviations were identified.

10. Media Release Center

The HRC was activated in a timely manner. The MRC staff, including all

agencies represented, were preplaced, except Kansas, due to the compressed

time schedule provided in the scenario. The briefings were conducted in a

professional manner. A sufficient number of prebriefings were conducted

and in a professional manner. Prebriefings were conducted before each

news briefing. The addition of a sound system permitted everyone to hear

the briefings. The sound system was suitable for the small briefing room

used. The NPPD visual aids were suitable for a small room; however, the

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visual aids may be too small for a larger briefing room. The sector map

used by the State of Nebraska was not large enough in size and did not

contain sufficient detail.

11. Exercise Critique

The NRC inspectors attended the post-exercise critique by the licensee

staff on September 25, 1986, to evaluate the licensee's identification of

deficiencies and weaknesses as required by 10 CFR 50.47(b)(14) and

Appendix E of Part 50, paragraph IV.F.5. The licensee staff identified

the deficiencies listed below. Corrective action for identified

deficiencies and weaknesses will be examined during a future inspection.

o Communications from the CR to the TSC were degraded on several

occasions; e.g.:

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TSC was not aware of the Anticipated Transient Without

Scram (ATWS)

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TSC was incorrectly informed of condenser tube failures

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Incorrectly informed that the Safety Relief Valves lifted

o The Emergency Director's command of the emergency organization needs

improvement.

12. Exit Meeting

The NRC inspectors met with licensee representatives (denoted in section 1)

at the conclusion of the inspection on September 26, 1986. The NRC

inspector summarized the purpose and the scope of the inspection and the

findings. Additionally, the licensee representatives were informed that

additional findings may result following a briefing of Region IV management.

The licensee's actions during the exercise were found to be adequate to

protect the health and safety of the public.