IR 05000382/1998003
| ML20248L523 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/10/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20248L519 | List: |
| References | |
| 50-382-98-03, 50-382-98-3, NUDOCS 9803230145 | |
| Download: ML20248L523 (22) | |
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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.: 50-382 License No.: NPF-38 Report No.: 50-382/98-03 Licensee: Entergy Operations, In Facility: Waterford Steam Electric Station, Unit 3 Location: Hwy.18 Killona, Louisiana l
Dates: February 16 to 20,1998 l Inspector (s): Thomas H. Andrews Jr Emergency Preparedness Analyst Approved By: Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety Attachment: Supplemental Information ,
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I-2- l EXECUTIVE SUMMARY Waterford Steam Electric Station, Unit 3 NRC inspection Report 50-382/98-03 l l l Plant SucogIt This routine, announced inspection focused on the operational status of the licensee's emergency preparedness program. Emphasis was placed on changes that had occurred since the last routine emergency preparedness inspectio S Plant Support
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The emergency preparedness program was properly implemented. Declared events were properly classified and notifications to offsite agencies were made in a timely manner. The emergency response facilities were well maintained. Changes to the j emergency preparedness program were incorporated into the emergency plan and implementing procedures. Emergency response organization personnel and emergency planning department staffing were trained appropriately. The process for identifying and incorporating corrective actions was very good. Emergency preparedness program audits were effectiv *
Declared events were properly classified and notifications to offsite agencies were timel Events were reviewed for lessons learned (Section P1).
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The backup emergency operations facility was very well equipped. Equipment and supplies for hurricane preparedness were in good condition and stored properly, Various l problems associated with respiratory protection equipment were identified including a l noncited violation for failure to maintain an adequate supply of small and large j air supplied respirators in the control room (Section P2). I
Personnel were properly trained regarding significant changes to the emergency plan and implementing procedures. Changes to the plan and procedures were reviewed, approved, and distributed in accordance with approved licensee procedures and NRC l requirements. The licensee maintained a good system to track procedure reviews and changes (Section P3).
- Performance was good during emergency preparedness walkthroughs using the plant simulator. Event recognition, classifications and notifications were timely and correc Protective actions for onsite personnel were initiated in a timely manner. Dose projections were performed correctly and protective action recommendations were prepared and communicated in a timely manner. Critiques were comprehensive and provided good findings to improve crew performance (Section P4.1).
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Operational support center staff performance during the remedial exercise was very
- good. Habitability controls were established and surveys were performed on a regular l basis. Dosimetry was issued to all personnel within the operational support center.
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-3-Supervisory oversight and repair team preparation were good. Briefings were identified as a strength because of the enhanced focus on personnel safety. The facility critique was comprehensive and identified areas for improvement (Section P4.2).
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Emergency response organizat;on personnel were trained as described in the ,
emergency plan. Tracking systems for checking respiratory protection qualification status contained inconsistent data (Section P5.1). i
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The emergency planning staff was well trained and maintained good awareness of industry issues (Section P5.2).
- The open act6on item trend showed a reduction in the number of open items. The process for identifying and incorporating corrective actions was very good (Section P6).
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Emergency preparedness program audits were effective in identifying problems and recommending areas for improvement. A noncited violation was identified for failure to i document the results of the assessment of offsite interfaces and make the results available to management and offsite agencies (Section P7).
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I-4-Reoort Details j Summary of Plant Status j
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The plant operated at full power throughout the inspection period. There were no operational occurrences that had impact upon the inspection result IV. Plant Support P1 Conduct of Emergency Preparedness Activities Inspachon Scoce (97302)
The inspector reviewed licensee events and assessed the appropriateness of the emergency action levels used to classify events, timeliness of notifications, and I effectiveness of action item identification and resolutio l Observations and Findinas The inspector reviewed the following event reports and associated licensee documentation: i January 18,1997 Alert Toxic chemical s%Il approximately 10 miles north of the plant on the Mississippi river (NRC Event 31619)
March 20,1997 Alert Toxic chemical release located less than 1 mile from the plant - barge struck a pipe resulting in release of ammonia (NRC Event 31979)
July 18,1997 Unusual Event Hurricane Danny (NRC Event 32645)
In all cases, the licensee made appropriate classifications and notified the parishes, State of Louisiana, and NRC within prescribed time requirements. The licensee was effective in identifying conditions and/or performance that warranted action items and closed action items in a timely manne Conclusions Declared events were properly classified and notifications to offsite agencies were timely.
l Events were reviewed for lessons learne l i
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P2 ' Status of Emergency Preparedness Facilities, Equipment, and Resources Insoection Scone (82701-02.02)
The inspector toured emergency response facilities to determine whether facilities and equipment were adequately maintained and to determine whether changes made since the last inspection were technically adequate, met NRC requirements and licensee commitments, and were appropriately incorporated into the emergency plan and implementing procedures. Licensee offsite communication circuits were tested as part of _ j this determinatio Observations and Rndings The inspector observed that emergency response facilities were tidy and contained appropriate communications equipment, emergency plan implementing procedures,
- portable suivey instruments, dosimeters, and emergency supplies. Emergency planning personnel conducted required inventories of emergency recponse facilities, equipment and of emergency lockers. Communications tests were conducted according to emergency plan requirements. The emergency response facilities were well maintaine The operational support center and portions of the emergency operations facility were used for other purposes but were readily usable as response facilities. The inspector concluded that emergency response facilities and equipment were maintained in a state of operational readines The inspector toured the backup emergency operations facility at 142 Delaronde Street in New Orleans, Louisiana. The facility was a dedicated response facility that was maintained ready for use. The facility contained support documents, communications equipment, computers, and a safety parameter display system terminal. The inspector determined that the backup emergency operations facility was very well equipped and maintaine The inspector reviewed the licensee's equipment associated with hbrricane respons As part of this program, the licensee established a dedicated storage area that contained cots, bedding, water, food, etc. The inspector toured this area and found that it was neatly organized and arranged. Cots and bedding were stored in individually sealed plastic bags and kept in large, sealed shelves to prevent them from being used for other purposes. The licensee also demonstrated the process for setup of the satellite telephone maintained onsite as a backup means of communication following a hurrican The inspector determined that equipment and supplies maintained for hurricane
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preparedness were in good condition and well maintained.
l The inspector reviewed the contents of selected emergency supply kits. Used i silver-zeolite cartridges were found in two sampler heads. The inspector found that the cartridge was too small to fit tightly within the sampler head. The licensee's subsequent inspection resulted in the following determinations:
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Charcoal cartridges were thicker and fit in sampler heads properly. Charcoal l cartridges were typically used during drills because of the cost of silver zeolite l cartridges compared to charcoal cartridges Therefore, the issue assoaaled with the silver-zeolite cartridge would not have normally been identified during routine drill According to the manufacturer of the sampler heads, removing the o-ring on the threads used to close the sample cartridge in the sample head would not adversely affect sample results and would permit a proper fit by silver-zeolite cartridges within sampler heads. The vendor provided a written confirmation that this field modification was permitted.
! in response to the inspe:: tion findmgs, the licensee began removing the identdied o-nng on all sampler heads. Removing this o-ring increased the need to emphasize that irttemal o-rings be present and in good condition. The licensee stated that technicians would be trained to permit use of sampler heads without the identified o-nng and to strongly emphasize the importance of intemal o-rings. The inspector determined that the licensee's actions were appropriat Self-contained breathing apparatuses were stored in carrying cases in the hallway outside the main control room but within the control room ventilation envelope. This hallway was considered part of the technical support center. The face-pece was stored inside the carrying case in a plastic bag for sanitary purposes The hose assembly was connected to the face-piece and coiled inside the bag. The inspector observed signs of distortion on the face-pece sealing surface resulting from the method used to store the face-piece Therefore, the face-pece was not useable. The licensee initiated a condition report to check the other face-pieces and to investigate altemative storage methods to correct the problem.
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No large or small face-pieces for self-contained breathing apparatuses were stored in the technical support center or operational support center. The self-contained breathing apparatus carrying cases only contained medium-sized face-pieces. Limited supplies of these were available at the -4 foot elevation access control point to the radiological control area. However, because these had fixed contamination, the licensee did not want to store them outside the radiological control area. The licensee initiated a condition report to determine the number of large and small face-pieces needed and to ensure that these were placed where they could be used, if needed. The condition report included a review of inventories in fire brigade lockers in addition to emergency response facilities. An expedited purchase of large and small face-pieces was initiated with expected delivery on March 7,1998. Because a limited supply of small and large face-peces was available for use from the -4' elevation access control point until additional face-pieces could be procured, the inspector determined that the licensee's actions were appropriat While touring the control room, the inspector observed storage of air-supplied respirator face-pieces. The face-pieces were maintained in a cabinet within the main control room for use by operators during a toxic gas emergency. There were 10 face-pieces and hose
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assemblies stored in the cabinet: 8 medium,1 small and i large. The licensee had identified the need to store multiple sized air-supplied respirator face-pieces in the control room and had based the number of face-peces for each size on statistical results According to the licensee, approximately 80% of respirator users were fitted with medium-sized face-pece According to the shift supervisor, all personnel on shift at that time were qualified to wear medium-sized face-peces, in response to the inspector's questions, the shift supervisor questioned the oncoming shift regarding face-pece sizes. The shift supervisor determined that there were two people on the oncoming shift who required a large face-pece. The shift supervisor refused to tum over the shift until an additional face-pece was brought to the control room and stored in the cabinet with other i face-piece In pursuing this matter, the licensee reviewed shift staffing and determined there were two shift crews (including the one mentioned above) where more than one person wore either a small or large face-piece. As a result, the licensee stored six medium, three small and three large face-pieces in the cabinet in the control room as their immediate -
corrective action. The inspector determined that these actions were appropriat The licensee stated that, during a toxic gas emergency, five positions were staffed in the l control room using air-supplied respirators. The five positions included shift supervisor, control room supervisor, shift technical advisor and two reactor operators. According to OP-901-520, " Toxic Chemical Release," Revision 5, operators would be required to don air-suppled respirators if toxic gas was detected in the control room. Based upon information provided by the licensee, the inspector determined that the quantities of small and large face-pieces were not adequate to ensure that all the operating crews would have properly fitted face-piece The inspector reviewed information for the two crews where the number of small or large face-pieces was inadequate. In one crew, the shift supervisor and a reactor operator were affected. In the other crew, a control room supervisor and a reactor operator were affected. It was permissible for either the control room supervisor or the shift supervisor to leave the control room thereby permitting the remaining four personnel to use air-supplied respirators. However, since there were no controls established to address the shortage of properly sized air-supplied respirators, the following vulnerabilities existed:
- The licensee could readily substitute staffing on an as-needed basis. No controls were in place to ensure that there would be an adequate number of properly sized face-pieces available for the on-shift crew during a toxic gas emergency.
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- No contingency plans were established to address a potential shortage of face-pieces. As a result, valuable time could be lost in determining who would use the face-pieces. If the wrong person used the face-piece before the shortage was identified, there would not be time available to sanitize the face-piece before giving it to the proper individua l
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If an individual elected to use a medium-sized face-piece instead of the properly sized face-piece, the increased leakage would reduce the air supply duratxm This could adversely affect the ability of the control room to function as designed during a toxic gas emergenc *
If an individual who was required to use a large or small face-piece did not have a properly sized air-supplied face-piece available and elected to use a self-contained breathing apparatus from the technical support center supplies, they would have discovered that there were no small or large face-pieces available for these device The inspedor determined that the supply of air-supplied respirator face-piscos was inadequale and prevented the 16conese from being able to implement procedure OP-901-520. Because this procedure was described by Regulatory Guide 1.33, and required by technical specification 6.8.1, this condition was determined to be a violation of technical specification 6.8.1. The violation was licensee identified, nonrepetitive, corrected within a reasonable time, and nonwillful. Accordingly, the violation is being treated as a noncited violation consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-382/9803-01).
In the technical support center and operational support center, the inspector observed that air bottles were stored in shelves that permitted the bottles to roll from side-to-sid These bottles were pressurized to approximately 2600 pounds. The inspector expressed concem since these bottles were not stored in the shelves to prevent them from becoming a missile hazard. The licensee placed spacers between the bottles to limit movement without limiting access to the bottles. The inspector determined that the licensee's corrective actions were appropriat During the tour of the emergency operations facility equipment room, the inspector discovered three self-contained breathing apparatus bottles laying on the floor. The bottles were outside the room where the batteries and diesel generator controls for the center were located. The bottles were fully charged with approximately 2600 pounds of pressure. The bottles were very dirty and information on the bottles was difficult to rea Upon examining the bottles, it appeared that the last hydrostatic test on the bottles was performed in 1988. The licensee emptied the bottles, removed them from the area then had them destroyed. Further investigation revealed that the bottles had been considered lost since 1993 and removed from inventory records. The inspector determined that the licensee's actions were appropriat c. Conclusions The emergency response facilities were well maintained. The backup emergency operations facility was very well equipped. The equipment and supplies for hurricane preparedness were in good condition and stored properly. An air sampler head modification was implemented to ensure that silver-zeolite cartridges fitted properly in the sample head. Various problems associated with respiratory protection equipment were identified. The method used to store self-contained breathing apparatus face-pieces in
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. storage cases was not consistent with the manufacturer recommendations. Small and large face-pieces for self-contained breathing apparatuses were not stored in the technical support center or operational support center. Failure to maintain an adequate supply of small and large air-supplied respirators in the control room was identifMMj as a noncited violatio P3 Emergency Preparedness Procedures and Documentation a. Insoection Scooe (82701-02.01) {
l The inspector reviewed changes made to the emergency preparedness program to !
determine if these changes adversely affected the licensee's overall state of emergency preparedness and to determine if they were appropriately incorporated into the licensee's )
emergency plan and implementing procedures. The inspector reviewed the changes to determine if they were reviewed, approved, and distributed in accordance with approved licensee procedures and NRC requirement b. Observations and Findinas The licensee made significant changes to procedures associated with the operational support center. These changes were related to corrective actions taken as a result of the performance during the 1997 biennial exercise. Discussions with personnelindicated that training had been performed and that people were knowledgeable of the change As demonstrated in the operational support center drill discussed in Section F4.2, the changes were property implemente The emergency planning department maintained a tracking board for all procedure reviews, changes, and transmittals. The process ensured that procedure reviews were timely and that once approved, the procedure would be transmitted to the NRC within 30 days. A review of document transmittal logs showed that all transmittals were timel Conclusions Changes made to the emergency preparedness program were appropriately incorporated into the licensee's emergency plan and implementing procedure Personnel were properly trained regarding significant changes. The changes were reviewed, approved, and distributed in accordance with approved licensee procedures and NRC requirements. The licensee maintained a good system to track procedure reviews and changes.
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-10-P4 Staff Knowledge and Performance in Emergency Preparedness P4.1 Simulator Walkthroughs Insoection Scnce (82701-0?d4)
The inspector conducted walkthroughs with two operating crews using a scenario developed by the licensee and run on the plant specific control room simulator. The inspector assessed the ability of control room teams to recognize accident conditions, declare emergencies using the appropriate emergency ac. tion levels, perform offsite notifications, initiate protective ar.tlons for onsite personnel, and to make protective action recommendations to offsite agencie Otgrvations and Findings The inspector reviewed the scenario prior to the on-site inspection and determined that it was adequate to assess on-shift emergency response capability. The crew was briefed on initial conditions and were told to assume that the scenario was a weekend such that staffing of the technical support center and operational support center would be delaye The simulator scenario lasted approximately 90 minutes for each shift cre The scenario began with a 50 gallon leak that resulted in the declaration of an alert. The leak rate increased to greater than charging pump capacity prompted the declaration of a site area emergency. The reactor coolant system leak rate continued to increase causing core uncovery. The operable low pressure safety injection pump tripped followed by increased temperatures on the core exit thermocouple. A general emergency was declared due to a loss of coolant accident with a safety system failure such that a core melt sequence was in progress or imminen Supervisory oversight for both crews was good. While the crews delegated responsibilities differently, both functioned in a manner to make timely notifications to offsite agencies and to initiate onsite protective actions as required by licensee procedure Communications within the control room were good in that three-part communications were consistently used. Three-part communications involves the first individual making a statement or giving a direction, the second individual restating the statement or direction, and the first individual confirming that the information was communicated properl Events were recognized quickly and were properly classified using the appropriate emergency action levels. Dose projection calculations were performed properly and in a timely manner to support offsite notifications. Protective actions were properly identified
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and communicated offsite.
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-11-During the walkthroughs, the inspector made the following observations:
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One crew evacuated the site to the downwmd evacuahon area. There was no release in progress at the time of the evacuabon. However, after the release started, personnel at this evacuation area would have been required to relocat The inspector determined that the decision was appropriate at the time, but could have taken the wind direction into consideration when recommending the evacuston assembly area to be use * The communicators were not trained on developing protective action recommendations, but were called upon to assist the shift supervisors in this process. This could have resulted in delays in notifying offsste agence Examples include One shift supervisor told the communicator to prepare the offsite notification form for the general emergency and to recommend evacuating the " keyhole" and shelter the remainder of the 10-mile radius. The communicator understood that " keyhole" meant evacuate a 2-mile radius and 5 miles downwind. However, the communicator was not familiar with the process used to identify the emergency planning zones to be evacuated. When asked, the shift supervisor showed the communicator where the information was found in a procedure tabl One shift supervisor filled out the offsite notification form for the general emergency, including the protective action recommendation. The shift supervisor asked the communicator to peer check the protective action recommendation Following the simulator walkthroughs, the shift crews performed a critique of their performance. The critiques were thorough and contained a mix of positive and negative comments. The critiques identified areas where improvement was neede Conclusions Performance of both crews was good. Event recognition, classifications and notifications were timely and correct. Protective actions for onsite personnel were initiated in a timely manner. Dose projections were performed correctly and protective action recommendations were prepared and communicated in a timely manner. The critiques were comprehensive and provided good findings to improve crew performanc P4.2 Bemedial Operational Suooort Center Exercise Insoection Scooe (82701-02.04)
The inspector observed the remedial operational support center exercise conducted on February 18,1998. The remedial exercise was conducted to ensure that the facility had incorporated changes to correct problems identified during the 1997 biennial exercis _ - _ - - - - - - - - - - --
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-12-b. Observations and Findinas The licensee conducted a special exercise for the operational support center using the simulator and a control cell to support the exercise. The control cell was challenged to ensure that timing and information to and from the operational support center would be similar to that found during full facility exercises. During the exercise, the inspector observed some of the activities in the control cell and found them well organized and coordinated. Observing activities in the operational support center and in the plant, the inspector found that the process worked very wel i l
The scenario began with a seized reactor coolant pump shaft. The reactor failed to trip automatically, so the operators manually tripped the reactor. At 9:00 a.m., an alert was declared based on the failure of the reactor to automatically trip when required. An announcement was made and the operational support center emergency organization was mobilized. At approximately 9:30 a.m., the "A" charging pump failed. Prior to the start of the exercise, the "A/B" charging pump was out of service for maintenance. At 10 a.m., an instrument air leak occurred in the "B" switchgear room. At 10:30 a.m., a steam generator tube rupture occurred giving a 150 gpm primary to secondary leak. A site area emergency was declared due to the leak rate exceeding charging pump capacity. A site evacuation was simulated as part of the scenario. At 10:45 a.m., a gas '
leak was detected on the 3A515-S transformer. At 11:30 a.m., welds on a blowdown line failed between the containment wall and isolation valve. The line was associated with the steam generator that had the tube rupture. A release path existed due to the steam i generator tube rupture. The wind blew the plume across the administration building l requiring routing of teams around the plant. A general emergency was declared based on loss of two of three fission product barriers with a potentialloss of the third barrie ;
The scenario continued until approximately 1:30 )
i The operational support center was staffed and activated in a timely and organized manner. Habitability controls were quickly established. Communication equipment was set up and tested to support facility operations. An entry / exit watch position was staffed to ensure personnel were challenged upon entering or leaving the cente All personnelin the operational support center were issued dosimetry. Personnel were prompted to check their dosimeters on a frequent basis. The facility briefings contained reminders for personnel to obtain dosimetry if they had not already been issued dosimetr Supervisory oversight within the operational support center was very good. Priorities were maintained and well focused. Briefings for the facility and teams were frequent and informative. The briefings were identified as a strength because extra attention was given to protecting personnel. Personnel were reminded to maintain awareness
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regarding wind direction and routing. People were reminded about using safety l equipment such as hard hats, safety glasses, and safety hamesses, when appropriat The briefings also used and emphasized good three-part communications. All of these factors enhanced the focus on personnel safet ___________-_____________ ____ . _ _ _ _ _ _ _
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i -13-Onsite protective actions were very good. The radiological release affected the administration building where the primary access point was located. Discussions regarding relocating personnel from this location were conducted. A radiation protection technician was dispatched to conduct regular surveys of the primary access point and to determine if an evacuation was needed. A site map located in the assembly area was used to identify the wind direction. Personnel were reminded to refer to this map on a regular basis and to use it to maintain awareness of the wind direction. As a precaution, personnel were routed through the turbine building to the -4 access point to avoid a potential release plum Preparation and dispatch of repair teams were good. Each team was properly briefed on radiological conditions and the equipment needed. One team member who was to wear a self-contained breathing apparatus stated that he could wear a medium face-piec The radiation protection technician in the operational support center noted that the individual was fit tested with a small face-piece and corrected the individual. The technician arranged for a small face-piece to be brought to the west-side radiological )
control area access for use by the individua l l
Following the exercise, the critique was very good. The critique was led by a I representative of the emergency planning department. A discussion of the scenario along with input from controllers and evaluators was provided. Comments were provided l by participants. The critique included a very good mix of positive and negative observations. The inspector determined the critique provided a good mechanism for program improvemen During the exercise, the inspector identified the following scenario control issues that detracted from realism and training value of the exercisa:
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There was confusion regarding relocation of the primary access point. This was considered the result of the artificiality caused by security not participating in the exercis During the exercise, an observer was observed talking with a participant and providing coaching regarding response activitie During the exercise, a monitor became a participant and provided very good assistance to a repair team. Actions included:
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Calling security for the team while the team donned protective clothin Prompting participants on the actions to be taken while inspecting and donning self-contained breathing apparatuses while telling them what actions were to be simulated.
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Checking out the self-contained breathing apparatus for a team member.
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Assisting a member with the donning of the self-contained breathing apparatu The inspector noted that the licensee had identified all of these issues as part of their critique process.
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c. Conclusions The performance of the operational support center staff during the remedial exercise was very good The center was staffed in a timely and organized manner. Habitability controls were established, and surveys were performed on a regular basis. Dosimetry was issued to all personnel within the operational support center. Supervisory oversight and properation of repair teams were good. Bnefings were identified as a strength because of the enhanced focus on personnel safety. The facility critique was very good and identified areas for improvement. Exercise control was very good with some instances of prompting by monitor / observer P5 Staff Training and Qualification in Emergency Preparedness P Emeroency Resoonse Oroaniration Training Insoection Scoom (82701-02.04)
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The inspector reviewed training requirements for emergency response organization ;
personnel as described in the emergency pla Observations and Findinos Based upon information provided by the licensee, the inspector determined that training for emergency response organization personnel was provided consistent with the emergency plan. The emergency plan discussed both general employee training and specific training for emergency response organization personnel. The inspector observed that general employee training consisted of two courses: plant access training and radiation worker trainin The inspector found that the licensee was responsive to audit findings. As an example, in the 1997 audit of the emergency preparedness program, the licensee had identified that some personnel in the emergency response organization were not required to receive radiation worker training. The radiation worker training portion of general employee training was the section of the course that discussed regulatory exposure limits, frisking techniques, dosimetry usage, and the licensee's declared pregnant worker policy. A lesson plan was drafted by the radiation protection and emergency planning departments l and provided to training. This lesson plan would ensure that all personnel in the ,
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licensee was in the process of incorporating these changes to the emergency response !
organization training.
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The inspector reviewed the method of tracking respiratory protection qualifications for on-shift personnel. Air-supplied respiratory protection equipment located in the control room is considered to be 'self issue * at the time of an emergency. To be qualified to wear respiratory protection, an individual was required to have a current physical, a current fit test, and current training. If any one of these elements were expired, then the individual was not considered qualified to wear respiratory protection. Because on-shift personnel do not have the time or mechanism to confirm that respiratory protection qualifications were current at the time of an emergency, the inspector asked if there was a mechanism to ensure that all personnel on-shift had current qualification The inspector determined there were at least three separate tracking systems used by the licensee: one by radiation protection, one for fire brigade personnel, and one by operations. Prior to conducting respiratory protection training, the training department confirmed that the individual had a current physical on record. However, there were no controls in place to ensure that the physical coincided with the training date. Therefore, an individual could have a current physical, take the training and fit test, have the physical expire, and still be considered as qualified to wear respiratory protectio The tracking system used by the operations department only considered the fit test and training information for respirator qualification when considering personnel qualified for shift work. This was inconsistent with the qualification requirements and information used in the other tracking systems. The inspector reviewed a listing of all personnelin the operations department whose respirator qualifications (physical, training, or fit test)
had expired. There were no on-shift personnel on the lis j
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The inspector expressed concem regarding use of multiple tracking systems to ensure i I
that personnel maintained current respiratory protection qualifications. The licensee presented a condition request where problems had been identified associated with these multiple tracking systems. The plan was to consolidate the information into a common database that was accessible by those needing the information. The development of the program and installation of new equipment had not been implemented. The inspector determined that the licensee's planned actions were appropriat Conclusion _s Emergency response organization personnel were trained as described in the emergency plan. Tracking systems for checking respiratory protection qualification status contained inconsistent dat PS.2 Emeraency Preparedness Staff Trainina Insoection Scooe (82701-02.03)
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. emergency planning staff to ensure that personnel were properly qualifie ..
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-16- Observabons and Findings 1 Since the last inspechon, one emergency planning planner poeden was filled with an -
individual from secunty, and one vacancy resulted from an individual transfemng from ,
the emergency planning department The new planner had been properly trained and was very knowledgeable regarding assigned dutie With regard to other individuals in the organization, the qualification requirements stated that personnel will attend seminars, industry meetmgs, trainng courses, etc. The licensee presented records showing active industry participation to maintain a good I awareness of ongoing industry issue Conclusions The emergency planning staff was well trained and maintained good awareness of industry issue P6 Emergency Preparedness Organization and Administration i Insoection Scone (82701-02.06)
The inspector reviewed the licensee's controls in identifying, resolving and preventing problems by reviewing such areas as corrective action systems and routine task trackin Observatens and Findings The licensee tracked corrective actions through the use of the condition request syste The process ensured that consistent tracking and documentation of problems and their resolution received the appropriate level of management review. Based upon trend data provided by the licensee, the number of open action items was going down, indicating a good trend to reduce long term issues. The inspector did not identify any issues associated with the licensee's corrective action proces The licensee used a detailed tracking system to ensure routine tasks were performed on a regular basis. Routine tasks included performing telephone tests, drills, inventories of supplies, etc. The inspector reviewed several tasks, including annual procedure review, emergency action level review, and the training of offsite agencies regarding emergency action levels. The inspector determined that all were performed in a timely manne The inspector reviewed the documentation associated with the hurricane tabletop drill conducted in June 1997. This review was made to assess the licensee's process for identifying issues and incorporating lessons leamed. The level of detail for this drill was very good. Topics included staging of equipment, providing facilities for personnel, ;
including toilet and sleeping facilities; determining the number of people who would be onsite during the response; making arrangements for evacuation of families; etc. The licensee identified several issues that were implemented in time for response to i
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-17-Hurricane Danny in July 1997. The inspector determined that the licensee's process for
- identifying and incorporating program enhancements was very goo Conclusions The open action item trend showed that the number of open items was being reduce Routine tasks were completed consistent with procedural and regulatory requirement l The process for identifying and incorporating corrective actions was very goo '
i P7 Quality Assurance in Emergency Preparedness Activities Irmandan hana (82701-02.05)
The inspector reviewed audit reports for the licensee's emergency preparedness program since the last inspection to determine compliance with NRC requirements and licensee commitment Observations and Findinas The inspector reviewed the 1997 audit of the emergency preparedness program.- The inspector found that the audit was comprehensive and provided good insight into program performance. Issues identified where tracked using the licensee's corrective action program. The 1998 audit was in progress at the time of the inspectio According to 10 CFR 50.54(t), licensees are required to provide for the review of its emergency preparedness program at least every 12 months. The review is required to include, among other things, an evaluation for adequacy of interfaces with state and local govemments.10 CFR 50.54(t) further states that the results of the review, along with i recommendations for improvements, shall be documented, reported to the licensee's l corporate and plant management, and retained for a period of five years. The part of the i review involving the evaluation for adequacy of interface with state and local governments shall be available to the appropriate state and local govemment While reviewing the 1997 emergency preparedness program audit, the inspector observed that there was no mention of the assessment of the interfaces with state and local governments. The licensee provided a copy of the audit checklist showing that the auditors had interviewed representatives from state and local agencies and had received
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very good response. From the information provided, the inspector determined that the offsite interfaces were well maintained. Because there were no issues identified, the licensee did not document the results of the review in the audit report that was provided to corporate and plant management and made available to the offsite agencie ,
Therefore, the assessment was performed, but not documented. This was identified as a '
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violation of the requirements in 10 CFR 50.54(t). The information contained within the i audit checklist indicated that the offsite interface was functioning properly. The failure to document the findings in the audit report appeared to be an isolated example. This failure constitutes a violation of minor significance and is being treated as a noncited i violation consistent with Section IV of the NRC Enforcement Policy (50-382/9803-02). t
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-18- Conclusions The audits of the emergency preparedness program were effective in identifying problems and recommending areas for improvement. A noncited violation was identified related to failure to document the results of the assessment of offsite interfaces and to make the results available to management and offsite agencie P8 Miscellaneous Emergency Preparedness issues P (Closed) IFl 50-382/9606-01. Insoection Followuo item - Backuo Technical Suocort Center Concem about control room habitability arose from the need to limit the number of personnelin the control room when the control room ventilation was isolated. The licensee mads provisions for a backup technical support center to be established in the emergency operations facility. The activation procedure for the technical support center contained a note informing pecple that they were to report to the backup technical support center when access to the control room envelope was limited. Documentation was provided showing that personnel had been trained on this change. The inspector confirmed that procedures were located in the emergency operations facility to support activation of the backup technical support center. The licensee's actions were appropriate to address the concer P8.2 (Closed) IFl 50-382/97018-01. Exercise weakness - Failure to adeauatelv monitor and control radiological exoosures and establish contamination controls Due to the potential impact on personnel safety, the failure to adequately monitor or control radiological exposures and properly establish onsite contamination controls were identified as an exercise weakness during the 1997 biennial exercise. Several examples were provided. On February 18,1998, the licensee conducted a remedial operational support center exercise. The results of this exercise are documented in Section P4.2 of this report. The results indicated that the problems identified in the 1997 biennial exercise had been correcte P8.3 (Closed) IFI 50-382/97018-02. Exercise weakness - Failure of the fire brigade to use reauired respiratory orotectioD Due to the potential impact on personnel safety, the failure of the fire brigade to properly use respiratory protection was identified as an exercise weakness during the 1997 biennial exercise. The licensee initiated changes to the fire brigade procedures, fire brigade training, and reinstructed personnel regarding the expectation to don self-contained breathing apparatuses prior to leaving the fire brigade lockers. The l inspector reviewed the changes as well as the results of fire drills and determined that I
the licensee's corrective actions were appropriate.
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-19-V. Management Meetings X1 Exit bleeting Summary l
The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on February 20,1998. The licensee acknowledged the findings i presented. No proprietary information was identifie I
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i ATTACHMENT SUPPLEMENTAL INFORMATI PARTIAL LIST OF PERSONS CONTACTED Licensee G. Bourgeois, Quality Assurance Specialist i A. Cilluffa, Technical Training Supervisor F. Drummond, Director, Site Support T. Gaudet, Licensing Manager J. Hoffpauir, Operations Manager D. Landsche, Radiation Protection Superintendent T. Leonard, General Manager, Plant Operations J. Lewis, Emergency Planning Manager R. Perry, Emergency Preparedness Coordinator G. Scott, Licensing Engineer NRC J. Keaton, Resident inspector LIST OF INSPECTION PROCEDURES USED IP 82701 Operational Status of the Emergency Preparedness Program IP 92904 Followup - Plant Support IP 93702 Prompt Onsite Response to Events at Operating Power Reactors LIST OF ITEMS OPENED AND CLOSED Ooened 50-382/9803-01 NCV Failure to have an adequate supply of small and large size air-supplied respirators in the control room (Section P2).
50-382/9803-02 NCV Failure to document the results of the assessment of the offsite interface and make the results available to corporate and plant management and to state and local agencies (Section P7).
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Closed 50-382/9606-01 IFl Backup Technical Support Center (Section P8.1)
50-382/9718-01 IFl Exercise weakness - Failure to adequately monitor and control radiological exposures and establish contamination controls (Section P8.2) l 50-382/9718-02 IFl Exercise weakness - Failure of fire brigade to use required respiratory protection (Section P8.3)
50-382/9603-01 NCV Failure to have an adequate supply of small and large size air-supplied respirators in the control room (Section P2).
50-382/9803-02 NCV Failure to document results of the assessment of the offsite interface and make the results available to corporate and plant management and to state and local agencies (Section P7).
LIST OF DOCUMENTS REVIEWED Audits W3D1-97-0028 Waterford 3 Quality Assurance Audit SA-97-026.1,' Radiological Emergency Plan," March 21,1997 ProceduftA EP-001-001 Recognition and Classification of Emergency Conditions Revision 18 EP-002-010 Notifications and Communications Revision 26 EP-002-015 Emergency Responder Notification Revision 6 EP-002-031 In-plant Radiological Controls and Surveys During Emergencies Revision 6 EP-002-034 Onsite Surveys During Emergencies Revision 4 EP-002-052 Protective Action Guidelines Revision 16 EP-002-071 Site Protective Actions Revision 13 EP-002-101 Operational Support Center (OSC) Activation, Operation, and Deactivation Revision 23 EP-002-130 Emergency Team Assignments Revision 17 EP-003-020 Emergency Preparedness Drills and Exercises Revision 9 EP-004-010 Toxic Chemical Contingency Procedure Revision 6 EP-004-020 Backup EOF Activation, Operation, and Deactivation During a Toxic Chemical Emergency Revision 5 FP-001-020 Fire Emergency / Fire Report Revision 11 FP-001-019 Fire Brigade Equipment Revision 9 HP-001-102 Respiratory Protection Revision 7 l
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l i -3-HP 002-607 Portacount Operation, Maintenance and Fit Testing of Personnel Revision 8 OP-901-520 Toxic Chemical Release Revision 5 OP-901-521 Severe Weather and Flooding Revision 2 SSl457 Duty Emergency Planner Revision 5 WB.102 Hurricane Policy Revision 1 W6.103 Hurricane Preparation / Response Guidelines Revision 3 ;
I Other Documents Waterford 3 Steam Electric Station Emergency Plan Revision 22
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