IR 05000382/1990017

Insp Rept 50-382/90-17 on 900625-29.No Violations or Deviations Noted.Major Areas Inspected:Operational Status of Emergency Preparedness Program Including Changes to Emergency Plans & EPIPs & Changes to Emergency Facilities

ML20059D595
Person / Time
Site:	Waterford
Issue date:	08/27/1990
From:	Powers D, Terc N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20059D593	List: IR 05000382/1990017 ML20059D590
References
50-382-90-17, NUDOCS 9009070113
Download: ML20059D595 (9)

Text

. ,; . ; ..

{

APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

i

'

NRC Inspection Report: 50-382/90-17 -Operating License: NPF-38 f

Docket: 50-382 Licensee: Entergy Operations, Inc. (E01)-

P.O. Box B i Killona, Louisiana 70066 Facility Name: Waterford 3 (WAT-3)-

Inspection At: WAT-3, Taft. Louisiana j

Inspection Conducted: June 25-29, 1990 '

Inspector: ha A1 TO Nemen M. Terc, Em(rJ,enef/ Preparedness Analyst Det6 .

I Security and Emergency Preparedness Section Accompanying Personnel: Stephen L. McCrory, License xaminer, Operator Licensing Section Approved: ,

Lh f/27 !io Dr. Dale A. Powers [, fhie#, Security and Dafe j Emergency Preparrdness Section

)

Inspection Summary Inspection Conducted June 25-29, 1990 (Report 50-382/90-17)-

Areas Inspected: Routine, unannounced inspection of the operational status of the emergency preparedness program including changes to the emergency plan (EP)

and EP implementing procedures (EPIPs), and changes to emergency facilities, equipment, instrumentation, and supplies. The inspection also included organization and management control, independent audits of the emergency preparedness program, and training of emergency response personne Results: Within the areas inspected, no violations or deviations were identified. The licensee was found to have appropriately processed changes to the EP and EPIPs. A tour of the licensee's emergency response facilities and a review of the licensee's organization and procedures revealed that the licensee is continuing its efforts to maintain a good, quality program. Interviews conducted with a sample of key emergency responders indicated that personnel were knowledgeable of their emergency duties. However, a weakness was 9009070113 900828 PDR ADOCK 05000302 >

G PNU

- _ . ___ _ _ _ __ _ __ _ _ - _ -

!

.,

• • !

) ,

. !

identified during walkthroughs pertaining to the performance of emergency-responders (paragraph 6), A review of the licensee's audits of.the emergency preparedness program found that the licensee has a good aud t program that includes help from outside the Entergy organization. The inspectors concluded,

'

based on the results of the inspection, that the operational status of the emergency preparedness program at WAT-3 was well maintained,

i

>w ~

..

e , ..,

.

-3-I

,

DETAILS Persons Contacted EDI

• D. E. Baker, Director,: Operations Support and Assessments

• L..R. Simon, Lead Supervisor, Radwaste  !

• J. Houghtaling, Operations Technical Manager l

• R. S. Starkey, Operations Superintendent '

• J.-M. O'Hern, Operations Training Supervisor i

• D. F. . Packer, Operations and Maintenance Manager ' -

• F. J. Englebracht, Emergency Planning and Administration Manager

• J. G. Hoffpauir, Planning and Scheduling Manager

• T. H. Smith, Plant Engineering Superintendent

• L. W. Laughlin, Site Licensing Supervisor

• J. J. Zabritski, Assistant QA Manager  !

• S. Ramzy, Assistant Radiation Protection (RP) Superintendent, Technical l

• D. F. Boan, Health Physics Supervisor i

• D. A. Landeche, Health Physics Supervisor '

• K. P. Boudreaux, Assistant Technical Specification Coordinator ,

• M. J. Langan, Technical Training. Supervisor ' '

• M. Davis, Event Analysis Reporting and Response Manager

• D. Dinh, Shift Technical' Advisor (STA) Supervisor NRC

• S. D. Butler, Resident Inspector

• Denotes those present at the exit interview, i Followup on Previous Inspection Findings (92701) )

h (Closed) Deficiency (382/8824-01): Delayed Shutdown Cooling - During the 1988 exercise, control room (CR) operators' actions resulted -in delayed actions to start shutdown cooling. Some of these actions wer .

inappropriate instructions to' auxiliary operators, lack of preplanning and 1 coordination with the chemistry staff, and lack of health physics support functions. After the exercise, the licensee identified the failure of'

decisionmakers in the CR to provide their staff with clear instructions as the root cause for this deficiency. During 1990, the licensee has conducted five remedial drills on (April 11, July 19, and August 30, 1989, and March 28 and June 13,1090). Players were presented a scenario requiring good information flow within the CR staff, and prioritization of-major tasks. The players demonstrated by their performance, the adequacy of the corrective action (Closed) Deficiency (382/8924-01): Timeliness of Initial Notification -

During the 1989 exercise, the CR staff failed to notify NRC within the time requirement of 10 CFR 50.72(a)(3). Since the August 1989 exercise,

.-

3- - , . .,-

.

-4-the licensee conducted refresher training in September 1989 emphasizing

-

the importance of notifying NRC. In addition, lesson plans were revised to incorporate the importance of notifying NRC as soon as possible after a declaration of an emergency even (Closed) Exercise Weakness (382/8924-03): Lack of Proper Coordination -

During the 1989 exercise, there were various unnecessary delays'in accomplishing tasks in support to operations. These tasks involved coordination and direction of ini. ant' repair teams. In response to this i weakness, on February 26, 1990, the licensee approved modified lesson-plans for retraining.' The licensee subsequently provided six different sessions of additional training during' April and May 1990 to the decisionmakers responsible for these delays (e.g.,' operational support center (OSC) supervisor,. communicator, technical support center (TSC)

supervisor, communicators, operations coordinator, emergency coordina b w and shift supervisors).

' Emergency Plan and Implementing Procedures (82701-02.01)

The inspectors reviewed the licensee's EP_and EPIPs and noted that-one j revision, Revision 13, to the EP was implemented on November 15,:1989. No

-

'

other revisions were made to the EP since then. The revision to the EP ;

was made in accordance with Procedure NSP-102,' Revision 2.1, " Review and Approval of Revisions to Licensing Documents." This procedure specifies that changes to the EP will be reviewed against the criteria of ,

10 CFR 50.54(q):and that the emergency planning department will make a '

determination as to whether the change' decreases the level of affectiveness of the EP, Later, the changes are submitted to the plant operating review committee (PORC) and the plant manage The inspectors noted that 14 procedure changes were-made since the.last inspection in December 1989. These changes were submitted in accordance with the requirements of 10 CFR 50, Appendix E. Procedure changes were prepared, revised, and checked for consistency against other.relate procedures, and the need for additional training, and they were '

distributed to users on-a timely basis using mechanisms for document control contained in Procedure UNT-004-009, " Control, Distribution, Handling, and Use of Plant Procedures."

No violations or deviations were identified in this program are , Emergency Facilities, Equipment, Instrumentation, and Supplies (82701-02.02)

The inspectors toured key emergency facilities and equipment to verify that they were adequately maintaine The inspectors noted that emergency facilities, equipment, and supplies were in place and adequately maintained, and that no adverse changes were made to the same since the last inspectio .-

(..

.

-5-The inspectors noted that the licensee incorporated means to perform radiation instrument response checks, but that no specific range to ensure that instruments were not under or over responding had been establishe Additionally, the inspectors noted that the licensee was in the process of- '

evaluating habitability criteria for emergency response facilities (ERFs)' .

The evaluation was accounting for integrated doses by performing risks versus' benefit analysis for each. individual ERF. The_ numbers, types, and'

ranges of personnel dosimeters kept in ERFs was being evaluated based on ;

the extent of protection derived from.the TSC and emergency operations .i facility (EOF) structures and on the e,tpected numbers of personnel l expected in these emergency centers during an accident.: The licensee stated that they would change their present dosimetry provisions depending-on the results of this evaluation, i

No' violations or deviations were identified in this program are . Organization and Management Control (82701-02.03) j The inspectors reviewed the emergency' planning and the emergency response l organizations to determine if changes to these-have been properly-incorporated-into the EP and EPIPs and have not adversely affected the licensee's emergency response readiness, i

The inspectors noted that since the last inspection, some changes had been made to the emergency planning organization. The nuclear emergency _

planning and records manager title was changed to emergency planning and administration manager. Instead of reporting-to the nuclear services manager, who, in turn, reported to the senior vice president, nuclear operations, the incumbent now report to the director of site support, who, in turn, reports to the vice president, operations. -Since the senior vice president, nuclear operations was transferred to Jackson, Mississippi, the vice president, operations is now the highest licensee representativ onsite. These changes preserved the organizational structure, and did-not adversely affect the emergency planning organizatio The inspectors determined that the functions of the emergency response organization had remained unchanged since the last inspection except for the addition of an emergency notification system (ENS) communicator in the TSC. This position was added as a result of observations made during a- <

previous inspection. It was noted that there was a need to relieve th licensing coordinator from some of his duties (i.e., providing information to NRC officials through the ENS phone from the TSC). Previously, the licensing coordinator had too many other functions and responsibilitie In addition, the new ENS communicator position at the TSC is filled by individuals with an operations backgroun No violations or deviations were identified in this program are l

+ .

.

-6- Training- (82701-02.04)

The inspectors reviewed the emergency preparedness training program at i WAT-3 and interviewed emergency responders to verify that the training !

program was established and maintained in accordance with q 10 CFR 50.47(b)(15), to determine whether the a' mount of .and type of training and retraining received by emergency responders was adequate, and whether key decision makers were proficient in the performance of their duties and responsibilities during a simulated accident scenario. In ;

addition, the inspectors verified that changes to the program since the i last inspection were incorporated into the. training program and that key '

emergency responders were aware of such changes, understood them, and had been properly trained to implement'the Furthermore, the inspectors verified whether authorities and responsibilities were clearly delineated for assessing accident conditions, and making protective action recommendations, and determined if key decisionmakers were capable of implementing timely onsite and offsite protective actions. The inspectors i verified the licensee's understanding of the relationships between plant '

(including core) conditions and possible onsite and offsite consequence The inspectors interviewed instructors and other' members of the emergency planning staff, and reviewed a sample of training records; primarily training records for those persons interviewed. In addition, the inspectors selected at random training records of 15 persons from the emergency response organization. The inspectors reviewed the records to

-

determine the status of EP training with respect to the function of the individuals and found that they were current with respect to initial or requalification training. The inspectors determined that specialized emergency preparedness training had been conducted for emergency responders, that lesson plans were in place and tests were g ven  !

commensurate with the materials presented. In addition, the in gectors i noted that part of the training consisted of practical, hands-on -i applications. The inspectors, however, determined that presently, for most lesson-plans, the licensee only had one test and that a training ;

questions / problems database containing selected materials to compose other

'

equivalent alternate tests was lacking. The inspectors _used the guidelines in NUREG/BR-0122, " Examiners' Handbook for Developing Operator Licensing Examinations," and Section 602 of NUREG 1021, " Operator Licensing Examiner Standards," to evaluate the examination question The inspectors noted that examination questions showed various weaknesses i which contributed to low validity or poor discrimination of emergency responders' abilities. Additionally, many of the training courses provided only one examination which was used repeatedly to evaluate personnel who had received scheduled trainin In discussions with the licensee staff, licensee representatives acknowledged the need for a database of questions / problems with attached weights depending on their level of difficulty, designed to develop

.

-

y , . ,-

-

- alternate tests'for emergency responders, _The licensee representatives stated that they intended to develop alternative tests and examinations for each lesson plan, and to expand and confirm the validity of their testing and qualifications progra In addition, in order to estaulish the adequacy of the training program, the inspectors interviewed three operations teams who would constitute the first phase of the emergency response._ Each team consisted of an emergency coordinator-(EC), a CR supe: visor, a shift technical advisor 1 (STA), nuclear plant operators (NP0s), and a CR communicator (CRC). Each interview lasted approximately 2h hours and consisted of;two parts. The first part presented various conceptual problems and questions designed to i inquire into the knowledge key decisionmakers had of fundamental emergency i response issues (e.g., emergency duties and responsibilities, core damage evaluation, prioritization of actions to be taken at site area and general emergencies, interactions with NRC during accident conditions, dose assessment, and habitability criteria). The second part of the interview i consisted of the team response to an accident scenario using the simulator '

in an interactive mode-for two of the three teams, and a tabletop type of walkthrough for one tea The walkthroughs showed the proficiency of the operators in responding to l a rapidly moving scenario, which forced them to handle onsite casualties, '

site evacuation, declare a general emergency, and make protective action recommendations offsite The licensee instructors formally conducted a routine requalification test simultaneously with the walkthrough. based on the same scenari In addition, a new set of emergency action levels were teste )

i Results from the interviews were as follows: I

'

The two groups tested with the simulator operating on an interactive mode performed their emergency response duties almost flawlessly. 'In general, j crew prioritization of response and mitigation actions and resource ~

allocation were good. Teams properly classified, notified, protected the health and safety of injured plant personnel, conducted site evacuation announcements, and made adequate protective action recommendation Several areas for improvement were identified, as follows: One of the three teams failed to properly perform dose calculation . One team underestimated the magnitude of the release because they failed to interpret the exponent in the monitor readou , In addition, the inspectors found that in some areas, key decisionmakers had not received sufficient guidelines to effectively make decisions (e.g., habitability criteria,_ reasons to contact NRC, difference between delegating work and delegating responsibilities, etc.).

"

a

--

y , .,

-8-

&

! Finally,-the information flow between the CR operators and the SS functioning as the EC, was less than optimal. and sometimes lagged the actual change in plant status by 5 to 10 minutes. In part, this may have been the result of the architectural design pertaining to the i location of the SS space within the CR. The-EC tended to remain in' i the SS booth, which restricted _his ability to hear the-information exchanged between CR operator Additionally, the activities of th STA were not uniform from crew to crew with respect to the method of i supporting the EC concerning plant statu The above four issues constitute a weakness (382/9017-01).

7. Independent Audits (82701-02.05)

The inspectors examined independent and internal audit reports for the licensee's emergency preparedness program since the last inspection to determine compliance with the requirements of 10 CFR 50.54(t), and to determine whether the licensee commitments ar.1 corrective actions-were implemented in a timely manner. The inspectors also examined the licensee's audit program to determine if it had a corrective action system for deficiencies and weaknesses identified during drills.and exercises, and to ascertain whether appropriate corrective actions were implemented in a timely manner. The inspectors held discussions with the quality assurance staff and examined audit reports for the licensee's emergency preparedness program since the last inspection. The inspectors also examined the licensee's audit program to determine whether appropriate means existed to record and follow up each item until_ corrective actions were complete The inspectors reviewed the annual quality assurance audit of the  ;

emergency preparedness program te see if it met the requirements of-10 CFR 50.54(t). The annual audit was performed during the period January 29 to March 16, 1990, by a certified lead auditor, two certified '

auditors, and a contractor. The audit included the status of emergency planning action tracking, EPIPs, ERFs, training of emergency responders, interviews with selected emergency planning personnel and members of the

,

a emergency response organization, and interfaces with the state and local governments. A total of 256 man-hours were used in this effort. In addition, the licensee performed surveillances of three drills and the 1 1989 exercis The inspectors noted that the scope and depth of the audit appeared to meet the requirements of 10 CFR 50.54(t), and that the use of additional emergency preparedness expertise outside of the licensee's organization enhanced the quality of the audi No violations or deviations were identified in this program are (' , s , .-..'

. ! Exit Interview

The inspectors met with the resident inspector and licensee representatives denoted in paragraph 1 above on' June 29, 1990, and .

'

summarized the scope and findings of the inspection as presented in this report. The licensee acknowledged the inspection findings. The. licensee did not identify as proprietary any of. the materials provided to, or reviewed by, the inspectors during the inspection, i

<

l