Information Notice 2012-18, Failure to Properly Augment Emergency Response Organizations

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Failure to Properly Augment Emergency Response Organizations
ML12178A010
Person / Time
Issue date: 10/26/2012
From: Camper L, Laura Dudes, Mcginty T
NRC/FSME/DWMEP/DURLD, Division of Construction Inspection and Operational Programs, Division of Policy and Rulemaking
To:
Garmon-Candelaria, David 301-415-3512
References
IN-12-018
Download: ML12178A010 (5)


ML12178A010

UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

OFFICE OF NEW REACTORS

OFFICE OF FEDERAL AND STATE MATERIALS AND

ENVIRONMENTAL MANAGEMENT PROGRAMS

WASHINGTON, DC 20555-0001

October 26, 2012

NRC INFORMATION NOTICE 2012-18:

FAILURE TO PROPERLY AUGMENT

EMERGENCY RESPONSE ORGANIZATIONS

ADDRESSEES

All holders of an operating license or construction permit for a nuclear power reactor, including

decommissioning power reactors, under Title 10 of the Code of Federal Regulations (10 CFR)

Part 50, Domestic Licensing of Production and Utilization Facilities, except those who have

permanently ceased operations and have certified that fuel has been permanently removed

from the reactor vessel.

All holders of and applicants for a power reactor early site permit or combined license under

10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants.

PURPOSE

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to notify

addresses of instances of licensees not properly staffing emergency response organizations

(EROs). The NRC expects recipients to review the information for applicability to their facilities

and consider actions, as appropriate, to avoid similar problems. However, suggestions

contained in this IN are not NRC requirements; therefore, no specific action or written response

is required.

DESCRIPTION OF CIRCUMSTANCES

From 2009 through 2011, a number of events occurred in which licensee EROs were not

adequately staffed when required. On two occasions - at different sites - the ERO was

augmented in a time that exceeded the licensee emergency plan requirements. On a third

occasion, at a third site, the ERO was not activated because the licensee failed to declare an

emergency action level (EAL) as required.

Brunswick Steam Electric Plant (Brunswick) - Delay in Augmentation of On-Shift Emergency

Response Staff during Alert

On June 6, 2010, Brunswick declared an Alert, in accordance with EAL guidelines, in response

to a discharge of Halon gas into the basement of the emergency diesel generator building. After

the Alert declaration, the control room site emergency coordinator directed the secondary alarm

station operator to activate the Brunswick emergency notification system. However, the

secondary alarm station operator was unable to activate the emergency notification system

because of administrative and computer access problems and an interruption by an incoming phone call. After the control room site emergency coordinator was notified of the failure to

activate the emergency notification system, the individual initiated a manual ERO group page.

This second attempt to activate the ERO was not initiated correctly because of operator error.

The ERO notification issue finally was remedied by the emergency preparedness supervisor.

As a result of these communications issues, the Brunswick ERO received confusing

notifications of ERO activation (i.e., three inaccurate manual pages, one accurate text message, and several notices from the emergency notification system advising of the Alert declaration).

Delays in proper ERO notification cascaded into delays in the actual staffing of the Brunswick

ERO facilities to the extent that the Technical Support Center (TSC), the Operations Support

Center (OSC), and the Emergency Operations Facility were not staffed in the time required by

the site emergency plan.

The licensee determined that the root cause of this event was inadequate augmentation drill

frequency, coupled with an inadequate strategy for staffing emergency facilities. Corrective

actions included an increase in the frequency of ERO augmentation drills, shifting to an

All-Call/All-Come ERO response philosophy, and implementing an improved automated

notification system. This event is described in NRC Inspection Report 05000325/2010007 and

05000324/2010007, (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML102930092) and Final Significance Determination of White Finding and Notice

of Violation, EA-10-192 (ADAMS Accession No. ML103560553).

Indian Point Nuclear Generating Unit 2 - Failure to Staff the TSC and OSC within the Required

Time Limit

On November 7, 2010, the licensee at Indian Point Unit 2 declared an Alert, in accordance with

EAL guidelines, in response to two explosions in the Unit 2 transformer yard. After the Alert

declaration, the operations crew activated the automatic notification system directing the ERO

to staff the site emergency response facilities. The Indian Point Emergency Plan requires the

TSC and OSC to be staffed and operational within 60 minutes of an Alert declaration. However, the licensee exceeded the 60-minute requirement when they declared the TSC and OSC

operational 79 minutes and 86 minutes, respectively, after the Alert declaration.

The licensee identified two factors that contributed to the delay: (1) members of the ERO

questioned the validity of the ERO beeper indications, or they believed that other ERO members

would respond to the call-in, and (2) problems occurred with the beeper and phone systems

where some ERO responders indicated that the system recording stated there was no

emergency, while other personnel received a beep but were unable to call in.

While reviewing this event, NRC inspectors identified a cross-cutting aspect in the area of

human performance associated with the work practices attribute of defining and effectively

communicating expectations regarding procedural compliance. This event is described in NRC

Inspection Report 05000247/2010-005 (ADAMS Accession No. ML110420231).

Davis-Besse Nuclear Power Station (Davis-Besse) - Failure to Declare Alert and to Implement

the Emergency Classification and Action Level

On June 25, 2009, an explosion and fire occurred in voltage monitoring equipment on a

345 kilovolt electrical bus. Shift management personnel did not recognize the event as having

satisfied any emergency criteria. The next day, the oncoming control room Shift Manager, in

consultation with the Emergency Preparedness Manager, determined the event met the conditions for an Alert, in accordance with EAL guidelines. At this point, the NRC, State, and

local officials were notified of the missed EAL declaration and the proper classification status.

The licensee attributed the failure to declare an Alert to personnel not adequately describing the

event as an explosion. A recent change to the site procedure added catastrophic failure of

energized equipment to the definition of an explosion. However, this procedure change was

not properly managed, resulting in site personnel not receiving adequate training to identify

catastrophic electrical faults as explosions. Therefore, site personnel made reports of an

electrical fault and did not report the explosion to the control room. This event is described in

NRC Inspection Report 05000346/2009503 (ADAMS Accession No. ML093620814); Final

Significance Determination for a White Finding Notification of Follow-Up Assessment, and

Notice of Violation, EA-09-283 (ADAMS Accession No. ML100560592); and the Response to

the Notice of Violation (ADAMS Accession No. ML100910164).

BACKGROUND

Part 50.54(q) of 10 CFR, Conditions of licenses, requires licensees to follow and maintain the

effectiveness of prescribed emergency plans. The requirements for emergency plans are

codified in 10 CFR Part 50.47, Emergency Plans, and Appendix E to 10 CFR Part 50,

Emergency Planning and Preparedness for Production and Utilization Facilities. Additionally, NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response

Plans and Preparedness in Support of Nuclear Power Plants, amplifies the requirements set

forth in the regulations. Regulatory Guide 1.101, Emergency Planning and Preparedness for

Nuclear Power Reactors, endorses NUREG-0654 as an acceptable method for applicants and

licensees to comply with the planning standards of 10 CFR 50.47(b).

DISCUSSION

Part 50.47(b)(2) of 10 CFR, requires that timely augmentation of on-shift emergency response

capabilities be available. An in-depth review of the events described in this IN revealed

inadequate training as a contributing cause to the untimely augmentation of emergency

response capabilities. In general, training for emergency responders should be sufficient to

ensure designated individuals are competent in executing their assigned emergency response

duties. The events described in this IN illustrate potential deficiencies that licensees should

take measures to avoid. Although there is no explicit NRC requirement to do so, licensees may

consider reviewing the circumstances of these events within their emergency response training

programs and preemptively implementing applicable corrective actions described in the

documents referenced above.

CONTACT

S

This IN requires no specific action or written response. Please direct any questions about this

matter to the technical contacts listed below or the appropriate Office of Nuclear Security and

Incident Response (NSIR) manager.

/RA/

/RA/

Timothy J. McGinty, Director

Larry W. Camper, Director

Division of Policy and Rulemaking

Division of Waste Management

Office of Nuclear Reactor Regulation

and Environmental Protection

Office of Federal and State Materials and

Environmental Management Programs

/RA by JLuehman for/

Laura A. Dudes, Director

Division of Construction Inspection

and Operational Programs

Office of New Reactors

Technical Contacts: Eric Schrader, NSIR

(301) 415-5627 E-mail: eric.schrader@nrc.gov

David Garmon, NRR

(301) 415-3512

E-mail: david.garmon@nrc.gov

Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under NRC Library.

ML12178A010 *via e-mail

TAC ME8295 OFFICE

NRR/DIRS/I

OEB*

Tech Editor*

NSIR/DPR/

DDEP/IRIB*

NRR/DIRS/IOE

B:BC

NSIR/DPR/DD

EP/IRIB:BC*

FSME/DWM

EP/RDB:BC*

NRR/DORL:D*

NAME

DGarmon

JDougherty

ESchrader

HChernoff

RKahler

BWatson

MEvans (SCoffin

for)

DATE

08/28/12

06/29/12

09/19/12

08/28/12

09/18/12

07/31/12

09/18/12 OFFICE NRR/DIRS:D NSIR/DPR/DD

EP:DD*

NRR/DPR/

PGCB:PM*

NRR/DPR/

PGCB:LA

NRR/DPR/PGC

B:BC

NRO/DCIP:D

FSME/

DWMEP:D

NRR/DPR:D

NAME

HNieh

MThaggard

ARussell

CHawes

DPelton

LDudes

(JLuehman

for)

LCamper

TMcGinty

DATE

09/10/12

09/19/12

09/19/12

09/19/12

09/27/12

10/11/12

10/25/12

10/26/12