IR 05000382/1997026

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/97-26

ML20199L292
Person / Time
Site:	Waterford
Issue date:	02/05/1998
From:	Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dugger C ENTERGY OPERATIONS, INC.
References
50-382-97-26, NUDOCS 9802090169
Download: ML20199L292 (4)

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• 9,*****e ARLINGTON, TE XAt 760118064 February 5,1998 Charles M. Dugger, Vice President Operations - Waterford 3 A

Entergy Operations, Inc.

P.O. Box B '

- Killona, Louisiana 70066 SUBJECT: NRC INSPECTION REPORT 50 382/9718

Dear Mr. Dugger:

Thank you for your letter of January 15,1998, in response to the exercise weaknesses identified in NRC Inspection Report 50-382/97-18, dated December 5,1997, We have reviewed

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4 your reply and find it responsive to the concems raised in our inspection report. We will review the implementation of your corrective actions during a future inspection.

Sincerely, Blaine Murray, Chief Plant Support Branch Division of Reactor Safety Docket No.: 50-382 License No.: NPF 38 cc:

Executive Vice President and Chief Operating Officer Entergy Operations, Inc.

P.O. Box 31995 Jackson, Mississippi 39286 1995 Vice President, Operations Support Entergy Operations, Inc.

P.O. Box 31995 Jackson, Mississippl 39286-1995

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Entergy Operations, Inc. 2-

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Wise, Carter, Child & Caraway P.O. Box 65 :

Jackson, Mississippi 3g205 General Manager, Plant Operations Waterford 3 SES Entergy Operations, Inc.

P.O. Box B Killona, Louisiana 70066

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Manager. Lloonsing Manager Waterford 3 SES Entergy Operations, Inc.

P.O. Box B

, Killona, Louisiana 70066 Chairman Louisiana Public Service Commission

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One American Place, Suite 1630 Baton Rouge, Loulslana 70825-1697

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Director, Nuclear Safety &

. Regulatory Affairs Waterford 3 SES Entergy Operations, Inc.

P.O. Box B Killona, Louisiana 70066 William H. Spell, Administrator Louisiana Radiation Protection Division P.O. Box 82135 Baton Rouge, Louisiana 70884 2135 Parish President St. Charles Parish P.O. Box 302 Hahnville, Louisiana 70057 Mr. William A. Cross Bethesda Licensing Office 3 Metro Center Suite 610 Bethesda, Maryland 20814 Winston & Strawn 1400 L Street, N.W.

Washington, D.C. 20005-3502

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l Entergy Operations, Inc. 4 I 1 i DISTRIBUTION w/ cony of licensee's letter dated January 15.1998: '

DCD (IE35)

Regional Administrator WAT 3 Resident inspector DRS Director ,

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DRS Deputy Director DRP Director DRS.PSB Branch Chief (DRP/D)

Project Engineer (DRP/D)

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Branch Chief (DRP/TSS)

MIS System RIV File

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DRS Action item File (98 G-0001)

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DOCUMENT NAME: G:\ REPORTS \WT718AK.GMG To recolve copy of document, indicate in bon:"C" = Copy without enclosures *E" = Copy with enclosures "Na e No co)y RIV:PSB E. C:DRS\PSD GMGood:nh G4% VBMurray Q 02/998 02Q98

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OFFICIAL RECORD COPY

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Entergy Operations, Inc. -4-DISTRIBUTION w/rev of ihnama's letter et=**d January 15.1998:

DCD (IE35)

Regional Administrator WAT 3 Resident inspedor DRS Diredor DRS Deputy Diredor DRP Diredor DRS-P8B Branch Chief (DRP/D)

Projed Engineer (DRP/D)

Branch ChW(DRP/TSS)

MIS System RIV File DRS Action item File (g6-G-0001)

DOCUMENT NAME: G;\ REPORTS \WT718AK.GMG To receive copy of document, indcato in box:"C" a Copy wthout enclosures *E" = Copy wth enclosures *N" = No co y RIV:PSB 1 C:DRS\PSD GMGood:nh (iMWBMurray D 02/3 98 02Ay98

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OFFICIAL RECORD COPY ngon43

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• Entergy nW

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(wW,c. Ihdas, a ggtsswMas W3F1980011 A4.05 PR Januar/ 15,1995 U.S. Nuclear Reguletory conmission ATTN: Document Control Desk Washington, D.C. 20555 Subject: Waterford 3 8E8 Docket No.80-382 _

L.loonee No. NPF-38 NRC inspection Report 9718 Reply to Emergency Preparedness Exercise Weaknesses Gentlemen: ,

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Entergy Operations, Inc. hereby submits in Attachment i the reply to the emergency preparedness weaknesses documented in the othjoot inspection report. The reply includes en analysis of each weakness, correctivie measures, and e schedule for completing those actions es requested, in addition, e summary of Waterford 3's Operational Suppod Center (080) Action .

Plan is provided es Attechment 2. This plan documents actions taken or scheduled to be taken to address weaknesses in the OSC.

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i NRC Inspection Report 9718 Reply to Emergency Properedness Exercise Weeknesses W3F1-96-0011 Peps 2 January is,1998 If you have any questions conoeming this response, please contact Jack Lewis at (504) 7394624 or me et (504) 7394242.

Very truly yours,

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E.C. Ewing Director, Nuclear safety & Regulatory Affairs

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ECEIGCS/tmm Attachments:

oc: E.W. Marschoff (NRC Region IV),

C.P. Patel (NRC-NRR),

J. Smlui, N.B. Reynolds, NRC Residentinspectors Omco

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Page 1 of 13 ATTACitMENT.1 ENTERGY OPERATIONS. INC. RESPONSE TO THE EMERGENCY EXERCISE WRatititSA18.RQGMhEblTfa.iti.jnRPgGIID.N REPORT.97-15

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WEAKNES8 NO. 50302/9715-01 A) During the radiological release, poisont el were dispatched from the 080 and ..

returned from the -4 foot elevation access point without self feeding dosirrators or equivalent (they were not monitored in tratisit). Procedure EP.002130,

Emergency Team Assignments," Revision 17, 86ction 5.1.3.4 stated that the OSC hesith physics liaison wlil contact the redletion control coordinator and ,

dieouse the need to issue dosimetry, protective clothing and/or respimtors to team persorinet prior to leaving the 08C, There was no record of this discussion.

B) During the release, an Individual left the OSC and entered the twvice building.

The records did not show that the individual left the 080, nor was the individual briefed on extemal radiologloal conditions. Procedure EP C02190, "Pensonnel Accountebflity," Revision 14, section 5.1.3.1, stated that all osc personnel she'l check out with the appilcabke maintenance lead or OSC supervisor prior to leaving the 08C. Center management was not cleariy informed of the individual's destinction. Other personnel observed the individual leave stid reported the information to OSC management; however, there was no record of follow up actions. .

C) Appi,riste proosutions were not taken for an individual who was added to an existing team. The individual was tasked to obtain ports 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 differont than that used by the team.

However, since the individuars name was just added to the briefing form used for Team 9, no additional radiological requirements were established, Procedure EP 002-130, " Emergency Team Assignments," Revision 17, Section 5.1,3.0, stated that the 080 health physics liaison will contact the radiation control coordinator and discuss the routing assigned to the task. Section 5.1.3.4 further stated that the OSC health physics liaison will contact the radiation contml coordinator and discuss the need to lasue dosimetry, protective clothing end/or respirators to team personnel prior to leaving the OSC. There was no record of this discussion. As a result, the indivkksal was not aware of the ongoing mioase, not provided a self4eeding dosimeter or equivalent, and not briered on expected dose rates or contamination levels associated with the speelfled route.

D) Contamination controls for persotmel exiting the plant were ineffective due to improper use of portal monitors at the primary nocess point and the location of the nearest frisker. 'An individual did not respond property to alarming portal monkts at the primary access point (the individual added to Team 9). When told tnat the monitors were staiming, the Individual exited through the portal monitor and pic-:::f+1 to a frisker outside the protected area. Since this til-80r ll/t0'd H l-1 06996t1HS SW011YW3dC AD831W1:80 4 (9160 864t0-tid

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W3F1-g84011 Page 2 of 13 individual was considere1 contaminated, the area outskie the portal monitors was i contamina6ed The indl.idual contacted the OSC and was directed to report to

[ the 4 foot elevation socess point.

l L . - Health physics personnel wete not Weiiiied that a c,ontaminated Individual had i

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alarmed the portal ruonitors or had usea the friskor. Therefore, a survey of the primary mooems point was not performed.

[ E) Personnel contarninetions were not investigsted to detoimine where the I contaminations originated and what areas had boon contaminated by the

[ indMduals. This investigation wcxrid have highli pited the need to establish

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better controls for personnel who traveled betwes') the OSC and -4 foot elevetion -

eccess control point. Moreover, this investigation ccold have idontified the need l to assess the dose for the contaminateu irdvidual who was added to Team 9.

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l F) Contamination ceinivis wwro inconsistently applied between the OSC and the 4 foot elevation eccess pdnt. Personnel who left the OGC to go to the -4 toot elevation access point wwe required to weer protective clothing, but personnel who left the 4 foot elevation to retum to the OSC were not.

G) Radiologloal corvols v. ore 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 u roieese in progress at the time, and esting, drinidng, smoking, and chewing had 'osen suspended. The sign on the door staitett that exit was not permitted without en 080 supervisor briefing. There were no documents to Indioste thet this briefirsi occurred.

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In addition, thoso Individuals entered the OSC through a rear door and retumed to work without frisking. There were no contamination surveys documented for the eres outside the OSC roar door. As a result, the OSC could have been contaminated, o

que to the potential impact on personnet safety, the feliure to adequately monitor or control radiologloal exposures and property establish onsite contamination controls was klontified as an exercise weakness (50 382/971841).

RESP _ONSE T0_WMKNESS NOu"4482l011Hai 1. Analysis of the Weakness There are several causes for the failure to adequately monitor or control radiological exposures and properly establish onsite contamination ceidmis.

The causes have been attributed to lack of enforcement of management expectations under sknulated and actual emergency conditions, personrol error, and inadequate procedures and t sining. An analysis of each example oited in the weakness Is provided below.

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Attachment i to p W3F196@11 Page 3 of 13 I During the radiological release, personnel were dispatched from the OSC and I returned from the -4 foot elevation access point without self-reading

dosimeters or equivalent (they were not monitored in transit). Procedure EP.  ;

j 002-130, " Emergency Team Assignments," Revision 17, Section 5.1.3.4 l l

stated that the OSC health physics liaison will contact the radiation ceiawl j

l coordinator and discuss the need to issue dosimetry, protective clothing '

j and/or respirators to team personnel prior to leaving the 080. There was no

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record of this discussion.

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Examnia.AAnalvgit l An invowtigation of this occurrence has confirmed there was no record of a

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discussion of the need for dosimetry, protective clothing, and/or respirators for personnel departing the OSC. However, there was a discussion between the l OSC health physics llelson and the radiological controle coordinator (RCC) on l

these lasues. The result of their discussion was a decision not to issue i

dosimetry, protective clothing and/or respirators to team personnel prior to ,

I leaving the OSC because that equipment would be procured at the -4 Control l

! Point and their intention was to route OSC personnel away from any potential  :

! or actual release. The RCC and OSC Health Physics technician monitored l r wind direction and routed (for the most part, see Examples B and C below)

personnel around the plant away from a potential release thinking this would l eliminate the need for self-reading dosimeters for personnel in transit from the '

l OSC to the -4 Control Point. The failure to record the discussion wcs an error l by the drill partleipants. The dooision not to issue dosimetry was

! nonconservative because of the release in progress and the fact that meteorological and redlologlost conditions could change.

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Example B '

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i l During the reisese, an Individual left the OSC and entered the service l building. The records did not show that the individual left the 080, nor was l the individual briefed on extemal radiological conditions. Procedure EP402-l 190, " Personnel Accountability," Revision 14, Section 5.1.3.1, stated that all l

OSC personnel shall check out with the applicable maintonence lead or 000 supervisor prior to leaving the 080. OSC management was not oloarly informed of the individual's destination. Other personnel observed the .

g individual lasve and reported the information to OSC management; however,

, there was no record of follow up actions.

Esample B Analysis

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The cause of this ocourrence is inadequate communication in that the j individual who left the OSC did not clearly inform OSC management thac he r was going to the service building. The individual informed his supervision

that he was leaving bk immediate area, but it was not understood that he was

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leaving the OSC. Accordingly, a briefing of radiological conditions outside the l 080 was not required and no record of the individual leaving the OSC was documented. This would be the appropriate response given the OSC i Supervisot's understanding that the individust was not leaving the 08C. l I ,

l A contributing cause of this example is inadequate work instructions because l of the failure of the OSC exit / entry watch to challenge Individuals leaving the 1 OSC. Entergy Operations' investigation revealed that OSC exit / entry watches 3 are not reoolving adequate instructions when posted as to their responsibility l l to challenge personnel leaving the OSC to ensure job briefings have i oocurred.

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When informed of the actual situation and destination, OSC management should have taken more aggressive follow-up action to return the Individual to the facility and determine his potential radiological exposure and reason for ;

his actions. At this point, 080 management should also have reinforood the  :

protocol for personnel departing the OSC with this individual and all OSC t r::;-:-M=s to prevent recurrence during the response to the emergency exercise events.

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Epcample C )

Appropriate precautions were not taken for an Individual who was added to an i existing team. The individual was tasked to obtain parts from the servios 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, sinos the individual's name was just odded to the briefing form used for Team 9, no additional radiological requirements were established. -

Procedure EP 002130, " Emergency Team Assignrr,ents," Revision 17, Section 5.1.3.3, stated that the OSC health physics llelson will contact the radiation control coordinator and discuss the routing assigned to the task.

Section 5.1.3.4 further stated that the OSC health physics liaison will contact the radiation evievi coordinator and discuss the need to issue dosimetry, protective clothing and/or respirators to team personnel prior to leaving the 08C. There was no record of this discussion. As a result, the individual was not aware of the ongoing release, not provided a self-reading dosimeter or equivalent, and not briefed on expected dose rates or contamination levels assoolated with the spoolfied route.

Example C Analysis E

The cause of this example is inadequate communication in that personnel wens not mode swure of existing persontal routing requirements. The individual assigned to obtain a part frum the service building was told by an

- OSC instrumentation and Control (l&C) Lead to go directly to the service building from the OSC to get the required part. The l&C Lead was not aware

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i j that a deelslon had been made to require Individuals to go around the turbine

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l building on the east side to the 4 Control Point prior to going to any other i j loostion. This deciolon was made prior to a release occurring and was based i

on existing wind dirootion. The route specified by the l&C Lead was contrey l to those requirements.

l Prior to the individual leaving the 080, his name was added to a briefing

shoot which did include instructions on the correct route to take when i

! traveling outside the 080. The 08C supervisor assumed that the Individual 1 l

would follow the routing as stipulated in the briofing fann. The 08C l 1- Supervisor was not aware that the l&C Lead had told the Individual to go to

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the servloe building. Shortly after beginning his trip to the oorvios building, e i release started and the individual was contaminated.

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Examnia D

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Contamination i;,wevis for personnel exiting the plant were ineffective due to

improper use of portal moniters at the primary access point and the location of i the nearest friskor. An Individual did not respond properiy to clarming portal l monitors at the primary necess point (the Individual added to Taatn 9). When i told that the monitors were alarming, the Individual exited through the portal

! monitor and proceeded to a friskor outside the protected area. Sinos this l individual was considered comaminated, the area outside the portal monitos l was contaminated. The individual contacted the OSC and was directed to j report to the -4 foot elevation soooos point. i

Health physics personael were not informed that a contaminated individual i had alarmed the portal monitors or had used the frisker, Therefore, a survey ,

l of the primary access point was not performed. j Examole D Analvals i l The causes of this element are the need for improved work instructions (and  :

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training) for all Waterford 3 personnel on the proper actions to take when they '

j cause a portal monitor alarm at the PAP and an inappropriate friskor location.

A contributing cause is inodoquete drill c,ontrol. Although the individual was given a cue that he had alarmed the portal monitor, other (Security) esercise i' partleipants in the area were not given the cue of an alarming monitor,

! therefore it is not known what Security's response would have been ( stain j the individual at the PAP for Health Physics surveys) If they had boon

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provided with this cue. In addition, the drill monitor for this event was

! replaced when the contaminated exercise participard left the PAP to go to the

. 4 Control Point, losing continuity of drill control for this event and leaving no

! one at the PAP to provMe contamination Information for Health Physics

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personnel if follow-up surveys were performed. Health Physics personnel rn =-d+d to the PAP subseouent to the departure of the contamina:ed

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individual and the drill control monitor. When the responding Health Physics i_!M!i!!!!!T.fi _!H!!E!! _ _.._ _ * @38339 N! "'!'!'~!!-!!! _ i

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Attachment i to W3Fi-g8 0011 Page 6 of 13 Technk,lan questioned Security about the individual exiting the portal monitor, Security informed him there was no alarm assoolated with the individual's exit.

Because of the lack of information provided to Security by drill personnel and the -L 2 --it incorrect Information that there was no alarm from the portal monitor provided to Health Physics personnel, a survey of the primary sooses point was not performed, in any case, the contaminated individual should not have left the PAP to go to the -4 control Point until en investigation of the portal monitor alarm was conducted.

Further investigation of this example noted that the friskor was located on the exit side of the portal monitor as established by scourity bounderles.

Exampia.E personnel contaminations were hot Investigated to determine where the contaminations originated and what areas had been contaminated by the individuals. This investigation would have highlighted the need to estabiloh better controls for personnel who traveled between the 08C 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 9.

Example E Analysis The oeuse of this example is inadequate training. Entergy Operations drill evaluators concluded that training previous to this exercise did not sufficiently challenge Health Physics personnel to consider the ramifications and follow-up actions they should take for en offsite release traveling over the servios building or contamination occurring between the OSC and 4 Control Point.

Example F

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Contamination controls were inconsistently applied between the OSC and the 4 foot elevation soonas point. Personnel who left the OSC to go to the -4 foot elevation access point were required to wear protective clothing, but personnet who left the 4 foot elevation to retum to the OSC were not.

Example F Analysis An investigation has identified one individual who was required to wear protective clothing prior to leaving the OSC boomuse OSC management suspected that he was contaminated prior to arrival at the 080. Therefore, the doolsion to use protootive clothing was made to contain the contamination on the individual and prevent its spread to other areas while in route to the -4 Control Point for decontamination. This example does not represent en inconsistency in contamination controls, but indloates that controls were 1 appropriate for the situation that existed at the time. This item does constitute en example of lack of investigation of personnel cent.iriinations as identified-til-9er ti/60'd H s-_1 _ _ _ _ _ _ _

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W3F196.co11 Page 7 of 13 in E above because en adequate Investigation of where this individual might have gotten contaminated and the impact on other personnel er d areas was not conducted.

EmaalLE Radiologloal controls were not properly enforced within the 080. At 3:10 p.m., there were participants outside the OSC north door who were smoking, even though there was a rolesse in progress et the time, and eating, drinking, smoking, and chewing had been suspended. The sign on the door stated that exit was not permitted without an 080 supervisor briefing. There were no documents to indicate that this briefing occurred.

F.xample GAnalvas The cause of this example was unclear and ambiguous enforcement of management expectations regarding employee complianon with amargency response postings, barriers and habitability restrictions and the importance of

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compliance with any and all restrictions that may be placed in effect during an emergency. These expectations apply equally for drills and actual events.

Entergy Operations notes that the actions described in this example were never deemed neceptable at Waterford 3 and that the analysis provided here refers to the reinfe oement and publication of management expectations, not the estabilshment of restrictions on behaviors that were previously pommed.

2. Corrective Measures ,

Wateiford 3 has implemented an Operational Support Center (080) Action Plan to address the above weakness identified in the 08C. The resultant corrective actions are as follows:

1) A letter from the General Manager Plant Opwelions to all Waterford 3 employees reiterating W expectations for emergency response activities was issued on December 18,1997. Thisletter addressed both actual event and drill response expectations. This Corredive Measure was completed on December 18,19g7.

2) Special training seminars for OSC responders, Health Physics and Redweste personnel will be conducted by the Emergency Planning department to address the lessons lemmed from this exercise. All elements of this exercise weakness will be addressed. Programmatic actions taken to prevent reoummoe and the expected actions of trainees to prevent recurrence will be discussed in these seminars.

This action will be completed by February 2,1998, til-818f II/Ol'd til-1 16116tD06 $1cl1Y13de AD13Diled 16:60 16-t0-93d

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W3F1960011 Pa9e 8 of 13 3) The Training Lesson Plan modressing general Operstkmal Support Center and emergency team Information will be revised to include lessone 10amed from this exercise. All OSC responders including Health Physics and Redweste personnel recolve this course es part of their required training. This action will be completed by February 2, 1996.

4) A special OSC training drill will be conducted without the participation of other emergency response foollities to allow the drill contivi team to focus solely on the response of the OSC participants, identify areas for improvement and determine the effectiveness of program changes and training implemented following the exercise. This motion will be completed by February 2,1998, 5) An OSC Operations Review Group will be established that will include representation from the other Entergy sites as well as a multidiscipline site memberehlp to review OSC operations and meke recommendations for improvements to Waterford 3 management.

This action will be completed by April 1,199e.

6) Procedures EP403-040, Emergency Equipment inventory, and EP-002-101, Operational Support Center (080) Activation, Operation and Desotivation, were revised to increase the number of self reading dosimeters (BRDs) in the OSC and require issue of SRDs to OSC personnel upon response to the facility. These procedures were revised on December 23,1997, with an effective date of January 5, 1998. This Corrective Measure was completed on January 6,1995.

Y) PAP Portal Monitor exit expootations were reviewed by Health Physics immediately following the exercise. A clarifloation of the exit expectations for personnel alarming a portal monitor to exit the back of the monitor, ensure Health Physics is contacted and weit for Health Physics to respond to supervise frisking activities was communloated to site personnel through the use of fliers provided for pick-up at the PAP upon entry to the plant on November 12,1997. This same flier was also mailed to all Waterford employees on November 13,1997.

The clartfloation on exit expectations conteined in the flier was published in the inside Entergy site newsletter on November 14,1997.

Supplemental training material on the proper exit procedure was developed and provided for use in the General Employee Trainin9 program on November 19,1997. The barrier at the PAP that donarantes the friskor and portal monitor locations was reconfigured on November 12,1997, to clearty place the frisker behind the portal monitors. This Corrective Measure was completed on November 19, 1997.

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Attachtnent i b W3F1-98 0011 PeGe 9 of 13 3. Schedule for Completion of Corrective AcUons  !

The Corrective Measures will be completed as stated above. All adlone will be completed by April 1,1998

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W3F1960011 Page 10 of 13 Weakness 50_382/g71842 The inspectors observed the fire brigade's respotese to the simulated fire. Procedure FP,001420, " Fire Emergency / Fire Report," Revision 10, Section 0.7.1.2, stated that the fire brigade shall don fire fighting apparel and self contained breathing apparatus and proceed to the fire soone. The f'.re brigade failed to use respiratory protection for a fire with toxic smoke in en onclosed space; therefore, personnel could have been impelred or injured. Moreover, the failure to use respiratory protection could have jeopardized the firo 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 procedure.

Not all fire brigade personnel had self contained breathing apparatus. The fire brigede member who discovered and reported the fire remained in the area while another fire brigade member went to dress out and bring en extra set of equipment.

The Individual only brought one self<xmtelned broething apparatus.

Due to the potential impact on personnel safety, the failure of the fire brigade to property use respiratory preisctieri was identified as an exercise weakness (60-382/9718 42).

RESPONSE 1. Analvalg of the Weaknesq The cause of this exercise weakness is conr.icting procedural raquirements.

The Fire Brigade Equipment proceduto, FP401-01g, allows the Fire Brigade Leader to determine the need for resps atory protection equipment. The Fire Brigade response procedure, FP-001020, requires the donning of all equipment by the team, including SCBAs, befom pmoeeding to the fire scene.

Because of the guidance of procedure FP-001019, Fire Brigade members received training contrary to FP 001420. This training silowed response without 8CBAs donned and ready for use at the discretion of the Fire Brigade Leader, in this exercise, the Fire Brigade Leader expected the Fire Brigade members to respond with their SCBAs donned and ready for use. The Fire Brigade Leader did not make a decision to relax respiratory prctection requirements nor did he notify the Fire Brigade members that they wem to respond without SCBAs. A cvntiiinsting cause to the failure of the team to don respiratory equipment was inadequate drill contiol. Fire scenario drill control personnel were overly sensitive to the issue of prompting of participarte and therefore reliert solely on an enlarged photograph to cue response personnel of conditions. The phete,.ph adequately depicted smoks, but did not give cues such as sounds, smells or heat that would be present in an actual event.

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Page 11 of 13 j 2. Corrective Measures

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! 1) Fire Brl0ede response expectations were reiterated in a management

! position paper distributed to all Fire Brl9ede members and the lead

! Fire Brigade trainer from the General Manager Plant Operations on

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i November 28,1997.

The FP401-020 requirement to don all protective equipment, including l respirators, bofore proceeding to the fire soone was established in this position paper as the goveming requirement and to have xsoodence

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over the conflicting information in FP401419 until such t me as the FP401-019 information could be removed. This position paper also

established strict ecoeptance criteria for the use of protective

equipment in fire drills. This Corrective Measure was completed on l November 28,1997.

I 2) The fire rssponse end equipment procedures will be revised as

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necessary to include the Fire Brigade response requirements rettensted In the Ncvember 26,1997, management position paper. This will

include at a minimum the removal of fire respc,nse protocols from the

equipment procedure. This action will be completed by February 2, 4 L 1998.

i 3) Periodic independent observation of routine fire response drills by

, Emer9ency Planning and Waterford 3 manecement have been l Implemented. independent observations by Emergency Planning of

routine fire drills were conducted on Dooember 10 and December 17, i 1997. The donning of respliatory protective equipment by Fire Brigade

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members was observed in both drills. This Corrective Measure was completed on December 10.1997, with the first drill observation.

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4) Spoolol training seminars on the fire response lessons leamed from

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this exercise will be conducted for Fire Brigade members by

Emergency Planning and Fire Brigade training personnel. This motion will be completed by February 2,1998.

5) The drill control lessons loamed from this exercise with regard to control of the fire scenario were addressed in the full control team debriefs on November 6,1997, and have been added to training

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meterials for drill control team personnel for future drills. This Corrective Measure was completed on January 5,1998.

3. Schedule for Completion of Corrective Actions  ;

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Corrective Measures will be completed as stated above. All motions will be  ;

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completed by February 2,1998.

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Page 12 of 13 l Weakness 50-382/9Z15-03 The protective action recommendation that accompanied the general emergency notification (eveountion of a 2-mile radius and downwind to 5 miles) was property l formulated and quickly communloated; however, the decision to upgrade the i protootive action recommendations to include three additional protective response l areas within 510 miles in the downwind direction was unnecessarily delayed and

) not communloated to offsite agencies in a timely manner. At 3:25 p.m., dose

! projedions indicated a need to upgrade the protective action recommendations to i include an evaeustion of Protective Response Areas M, C3, and C4. Doses

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exceeded i rom total effective dose equivalent and 5 rom thyroid ceweitted dose

! equivalent beyond 5 miles.

i The EOF director was out of the room when the dose projections first beoeme available. The radiological assessment ooordinator and field team coordinator i discussed the dose projection results with the state. The EOF directorjoined the discussions in progress. The dose projections wara characterized as accurate,  !

since they were based on field team results at known distances (pre-determined l Sampling points).

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l During the discussions with the state representatives, the option of issuing a .

! protodive action recommendation that included fewer protective response areas l l than required by Procedure EP 002-052, "Protodive Action Guidelines," Revision l

16, was discussed. The decision to follow the procedure and make the  !

! recommendation in the three additional areas was not made until 3:45 p.m. (20 l minutes after the information first became available). Offsite agencies were notified l st 3:60 p.m., 25 minutes after the information was available. The failure to make a i l

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timely protective action recommendation to offsite agencies was identified as an l exaroise weekness (50-382/g718 03). j

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RESPONSE

) 1. Analvals of the Weakness

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! The cause of this weakness is inadequate training, consisting of two i elements. The rationale and logic for the guidance in the protective setion

!- twoommendations procedure (EP 002-052) was developed in the early 1980s.

t Clear direction was given at that time by the 8t. Charles and St. John the  :

Baptist parish emergency preparedness directors that protodive action

' recommendations were to be provided using protective response areas and that the protective response arou geopolitical boundaries were not to be

subdivided when a recommendation was given. Although this direction is still

valid today and reflected in the procedure's final produd, the means of i arriving at this product is not addressed in training for either Waterford or i" State emergency responders._ Therefore, the responders in the exercise spent time discussing an issue (subdivision of protective response areas) that l would have been rejected by the parishes and was contrary to the i proceJure's guidanoe. More comprehensive training on this procedure is

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Page 13 of 13 required for both groups'of responders that includes the basis and historiosi perspective for the protective action recommendaticos contained in the procedure end not just the mechanical methodology for arriving at these

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protective nations.

The second training element applies to the need for a sense of urgency when arriving at protective action recommendations and timellness in providing

, those recommendations to the parishes. Waterford and State responders are well trained in develo; vnent and communloation of initial protective action recommendations and provide them in a timely manner as evidenced in this exercise. Additional training will be gwW to apply this same sense of urgency for protective action recommendations that result in changes to the initiel General Emergency recommendations.

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2. Corrective Measures 1) Emergency Planning will provide supplemental training in the form of seminars on the basis and historical perspective for the actions called for in the pecedure EP-002 052, Protodive Action Guidelines. Emphasis on the timing and sense of urgency for changes to initia.1 recommendations will also be provided in this training. The supplemental training will be provided for Waterford and Loulslana Radiation Protection Division (LRPD) personnel responsible for developing and approving protective action recommendations. This action will be completed by March 2,1999.

2) Lesson plans for Waterford positions responsible for de,veloping and approving protective action recommendations and the lesson plan for LRPD annual training will be revised to incorporate discussion of this exercise weakness as a lesson lommed and to include the information provided in the seminars addressed in Corrective Measure number i above. This action will be completed by March 2,1998.

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3. Schedule for ComDlption of Corrective Adlona Corrective Measures will be completed as stated above, til-8tof II/It'd rll-1 16896titOS $N011Ydid0 AD831W):8cli 20 01 Il-t H 3d

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W3F1-98@ii Page 1 of 2 ATTACHMENT 2 080 ACTION PLAN JgDmisia 1. Review portal monitor issue, communicate any changes to all site personnel and modify GET as necessary This will be completed by November 14,1997. STATUS: ALL ACTIONS COMPLETED BhartTerm 2. Training on Lessons Leamed for all OSC responders, Health Physics and Redweste - Special training in the form of seminars will be conducted by the Emergency Planning Department for all OSC responders including Health Physics and Redweste personnel by February 2,1998. Leesons learned from this exercise will be addressed. STATUS: ON SCHEDULE ShortTerm 3. Management expectations will be reiterated for all ERO personnel The General Manager Plant Operations will reiterate management expectations for Emergency Response Organization i-i.er,rr.1 by December 15,1997. STATU5: ALL ACTION 8 COMPLETED Short Term 4. Revise procedures to require dosimetry to be issued to all 08C personnel upon response to OSC - Procedures to be revised and inventories increased by January 1,1998. STATUS: All ACTIONS COhPLETED Short Term 5. Fire brigade response expectations, procedures and brigede member training Fire brigade responw expectations will be reiterated by December 1,1997. Fire response procedures will be revised and liipcM es required by February 2,1998. Emergency Planning and management observations of routine fir 9 brigade drillt, will be implemented by December 1,1997. Special training on the leesons loomed from this exercise for fire brigade members will be conducted by Emergency Planning and Fire 9rigede training personnel by February 2, 1998. STATUS: ALL ACTIONS DUE BY DECEMBER 1 COMPLETEL OTHER ACTIONS ON SCHEDULE ShortTerm- 6. Perform an OSC drill including actual repair team response compiloeled by an offsite release. Drill to be conducted by February 2,1998.

STATUS: SCHEDULED FOR JANUARY 29,1998 Short Term 7. Revise applicable training lesson plans to include the lessons lemmed from this exercise in future training. Lesson plan revisions to be completed by February 2,1998. STATUS: ON SCHEDULE til-90r ll/11'd H M Ilt96t1HI tiiOl1YW3dO ADW311i3Nd (0:01 26-t0-93d

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W3F1-96-0011 Page 2 of 2 Lona Term 8. OSC Operations review group with representation from other Entergy  :

sites - Team will assist in the improvement of OSC operational processes. I The review group will consider the move of Health Physics emergency 1 operations to the 000. This review group will be chartered by Waterford I management and provide final recommendations by April 1,1998.

STATUS: ON SCHEDULE

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Demonstration 9. Demonstrate OSC operations to the NRC . Date to be determined.

STATUS: SCHEDULED FOR FEBRUARY 18,1998

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