IR 05000416/1993005
| ML20035H167 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 04/23/1993 |
| From: | Barr K, Salyers G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20035H163 | List: |
| References | |
| 50-416-93-05, 50-416-93-5, NUDOCS 9305030227 | |
| Download: ML20035H167 (11) | |
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,M [ % g UNITED STAT ES
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NUCLEAR REGULATORY COMMISslON
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REGION 11
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ATLANT A, GEORGI A 30323 l
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APR gg y Report No.: 50-416/93-05
I Licensee:
Entergy Operations, Inc.
Jackson, MS 39205
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Docket No.:
50-416 License No.: NPF-29 Facility Name:
Grand Gulf L
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Inspection Conduc,ed: Ma rch 22-26,{l/93 '
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Inspector: N D
M o, ~r )
C 2/97 G.
W.' Salyer
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Approved by:
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K. P. Barr,' thief Date' Signed Emergency Preparedness Section
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Radiological Protection and Emergency Preparedness Branch
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Division of Radiation Safety and Safeguards
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SUMMARY
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Scope:
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This routine, announced inspection was conducted in the area of emergency i
preparedness, and included review of the following programmatic elements:
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(1) Radiological Emergency Response Plan and its implementing procedures;
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(2) emergency facilities, equipment, instrumentation, and supplies;
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t (3) organization and management control; (4) independent reviews / audits; and (5) training.
Results:
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In the area inspected, no violations or deviations were identified. The
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emergency preparedness program received adequate management support. Overall
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emergency response capability was adequate to protect the health and safety of
the public in the event of an emergency.
Recordkeeping and documentation were r
adequate but improvements can be made in record filing systems and proceduralizing of forms.
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9305030227 930423 PDR ADOCK 0500
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j REPORT DETAILS
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1.
Persons Contacted l
Licensee Employees j
- D.
Ables, Senior Nuclear Instructor l
- J. Armstrong, Technician A III
- D. Coulter, Radiation Control Supervisor
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- L. Daughtery, Plant Licensing Support
- J. Dimmette, Manager, Performance and System Engineering
- D. Ellis, Emergency Planner II i
- C. Ellsaesser, Assistance Operations Manager
- C. Hayes, Director, Quality
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- R. Hutchinson, General Manager, Grand Gulf
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- F. Mangan, Director, Plant Projects and Support
- A. Morgan, Manager, Emergency Preparedness
- J. Roberts, Manager, Maintenance
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- R. Ruffi, Licensing Specialist i
- W. Russell, Operations Coordinator, Emergency Preparedness
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- D. Townsend, Emergency Planner III
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Other licensee employees contacted during this inspection included
members of the emergency response organization, training staff, and
office personnel.
Nuclear Regulatory Commission j
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- C. Hughey, Resident Inspector
- Attended exit interview
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Acronyms and Initialisms used throughout this report are listed in the
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last paragraph.
2.
Emergency Plan and Implementing Procedures (82701)
Pursuant to 10 CFR 50.47(b)(16), 10 CFR 50.54(q), and Appendix E to
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10 CFR Part 50, this area was reviewed to determine whether changes were made to the program since the last routine inspection (April 1991), and to assess the impact of these changes on the overall state of emergency
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preparedness at the facility.
The inspector reviewed the licensee's program for making changes to the.
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EP and the EPPs. The licensee procedure 01-S-10-3 " Administrative
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Procedure, Emergency Preparedness Department Responsibilities, Safety Related" identifies EP as a " Safety System." By being identified as a
" Safety System", any change to the EP requires a 10 CFR 50.59 evaluation
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or review.
In addition' to the 10 CFR 50.59 evaluation or review, Section 6.4, " Control of GGNS Emergency Plan," of the procedure
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contained requirements for completing either Attachment V, " Evaluation
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of Proposed Changes to Emergency Plan" or Attachment VI, " Evaluation
Form for Emergency Preparedness Procedure" when making changes to the EP j
or EPPs. Attachment V, " Evaluation of Proposed Changes to Emergency
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Plan" addresses the requirements of 10 CFR 50.54(q) by specifically asking questions pertaining to 10 CFR 50.54, 10 CFR 50.47(b), and
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NUREG-0654. Attachment VI, " Evaluation Form For Emergency Preparedness
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Procedure" insures the proposed EPP change agreed with and implemented
the EP.
l The inspector reviewed documentation of Revisions 22 and 23 to the EP and 15 EPP change forms submitted to the NRC since the last inspection e
(April 1991 through February 1993).
Each of the EPP change forms contained changes to multiple EPPs.
In this review the inspector
verified that the licensee was properly implementing procedure 01-S-10-3
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discussed in the above paragraph.
No deficiencies were identified in
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Implementing Procedure 01-S-10-3.
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The inspector selected two of the above procedure changes, 10-S-01-18, Revision 5 and 10-S-01-14, Revision 14 and reviewed the changes. The
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inspector used procedure 01-S-10-3, Attachment VI, " Evaluation Form For.
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Emergency Preparedness Procedure" and compared the changes in the EPP to j
the EP. No discrepancies were identified by the inspector.
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A review of licensee records confirmed that all changes to the EP and l
EPPs from April 1991 through February 1993 were approved by management I
and submitted to the NRC within 30 days of the effective date, as required.
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The inspector reviewed documents indicating the EALs were presented to
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and reviewed by the States of Louisiana and Mississippi and the local
counties and parishes in 1991 and 1992.
Neither the States nor local
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governments recommend any changes to the EALs at that time. The i
inspector reviewed the EALs. The EAls in the procedures were consistent with the EP and with those required by regulation. The EALs did not i
appear to contain impediments or errors which could lead to incorrect or untimely classification. The inspector noted that the EALs were based
on parameters obtainable from Control Room instrumentation.
The inspector audited selected controlled copies of the EP, EPPs, and
the Emergency Telephone Directory in the Control Room, TSC, and the EOF.
The controlled copies were audited for the most current revision of the
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procedures. No problems were identified.
One NOVE emergency declaration was made by the licensee since the last
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inspection, April 1991.
j June 10, 1992 Both divisions of the Standby Gas l
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t Treatment System inoperable
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The inspector reviewed the EAL Classification procedure and conditions
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prompting the classification. The review indicated that the i
classification was made correctly and offsite notifications were timely.
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Section 8, " Maintaining Emergency Preparedness" of the EP addressed the performance of a variety of required activities, including drills,
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i educational information to the public, testing of communication systems, l
training for licensee and offsite emergency response personnel, and l
other program maintenance activities.
Procedure 01-S-10-3, t
" Administrative Procedure, Emergency Preparedness Department l
Responsibilities, Safety Related" was more specific in the
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implementation of these activities. The inspector verified
documentation of these activities was being maintained by reviewing the t
following areas:
Inspections and Audits
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Emergency Communications Test Results
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Alert and Notification System Test Results
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Emergency Plan Augmentation Callout. An off hours unannounced
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augmentation drill was conducted on December 18, 1991. The drill l
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results were satisfactory.
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Emergency Plan Radiation Instruments and Emergency Kit Inspection
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and Checks
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i The inspector's review of these audits and test results indicated the
tests and audits were comprehensive and conducted in accordance with the l
EP. All of the required records were found satisfactory.
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By reviewing documentation and discussion with licensee personnel, the
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inspector determined that the following NRC ins applicable to emergency
planning were reviewed by the licensee and distributed to cognizant l
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personnel. The inspector noted that corrective actions, were taken when j
appropriate.
IN 91-33: Rx Safety Info for States During Exercises and l
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Emergencies i
IN 91-72: Revision of EPA PAG Manual
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IN 92-32: Problems Identified With Emergency Ventilation Systems
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for Hear-Site (Within 10 Miles) Emergency Operations facilities j
and Technical Support Centers-i IN 92-38: Implementation Date for the Revision to the EPA Manual
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of Protective Action Guides and Protective Actions for Nuclear i
Incidents IN 93-07: Classification of Transportation Emergency
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No violations or deviations were identified.
3.
Emergency Facilities, Equipment, Instrumentation, and Supplies (82701)
Pursuant to 10 CFR 50.47(b)(8) and (9), and 10 CFR 50.54(q), and l
Section IV.E of Appendix E to 10 CFR 50, this area was inspected to
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determine whether the licensee's ERFs and other essential emergency equipment, instrumentation, and supplies were maintained in a state of
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operational readiness, and to assess the impact of any changes in this
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area upon the emergency preparedness program.
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The inspector toured the licensee's ERFs.
In the E0F, the inspector
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observed several new changes since the April 1991 inspection:
New laser jet printers
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New FCC approved channel for the environmental monitoring teams
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VIP 2000 auto dialer
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Computer terminal from the simulator which functions as an SPDS
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during emergency preparedness drills Evaluating converting the dose assessment program from MES0 REM to
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CADAP New " Operational Hot Line" (auto ringdown phone system) to State
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and local agencies
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In the past, radio communication within the plant had caused
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interference with the environmental monitoring teams radio i
communication.
In response, the licensee requested and received from
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the FCC an additional radio communication channel (frequency). This
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communication channel was assigned to the environmental monitoring teams, mobile vans, EOF, and Back-up EOF.
The licensee had installed a new auto dialer system. The VIP 2000 auto dialer, was used for contacting emergency response personnel and
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activating the ERO. The system contained the office, home, and pager t
telephone number of all ERO personnel. The system called the office number during working hours and the home number during non-working hours. The system had 12 telephone lines, initially,10 of the lines were outgoing lines and 2 were designated as incoming lines. The inspector observed the system in operation during a drill.
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inspector noted that the system was fully automated and could initiate
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I telephone calls, relay messages, state the emergency classification, state whether the call was a drill, test or an actual emergency, and s
acknowledge filled positions. The system was programmed to make three i
complete passes through the ERO list in an attempt to contact ERO
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personnel before securing itself. The inspector noted that the system
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functioned as designed but, two problems were identified and promptly
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corrected: 1) the system did not recognize the 930 telephone exchange as a local call, and 2) one wrong telephone number was identified.
The licensee had relocated the OSC to the second floor of the maintenance building. The inspector observed the OSC prior to and during a Quarterly drill. The OSC contained adequate communication equipment, faxes, and computer equipment necessary to effectively and efficiently operate the facility.
The licensee had fabricated a j
portable cart with two computers for automatically issuing electronic dosimeters and keeping track of personnel exposure. The system was identical to the dosimeter issuance equipment used in the licensee's radiological control area. The inspector noted that the physical layout of the OSC was well planned. The lay out contained wall mounted file holders which facilitated keeping track of up to six individual emergency teams.
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OSC was located adjacent to a fully equipped emergency supply locker (room), in the proximity of respirator gear, radiological laboratories, I
and access was controlled for contamination and accountability.
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The inspector requested an operational demonstration of the ERFIS
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terminals in the EOF and TSC. The system was successfully accessed and i
was immediately available for use.
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The inspector observed the E0F Emergency Ventilation System. The
ventilation room was clean and all ducting, dampers and motors appeared
to be maintained and in good working condition. The licensee demonstrated their capability to isolate the EOF from the rest of the
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building thus establishing an EOF envelope.
When the licensee i
representative shut, then reopened the large electro mechanically operated steel door, the inspector could feel and hear the rush of air ll leaving the envelope once the door was open, indicating a positive
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pressure had been established within the EOF envelope by the ventilation-system. The system appeared to be maintained and in a state of operational readiness.
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The inspector reviewed documentation dated September 30, 1991, which was a response to QDR 077-91, " Failure to perform required isolation / differential pressure test of E0F HVAC system" and QDR 078-91,
" Failure to perform required preventative maintenance of the EOF Diesel
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Generator / Motor." The EP orgar.ization implemented an emergency
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preparedness procedure 01-S-10-5 which establishes requirements for
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maintenance on the EOF emergency ventilation system and the EOF diesel
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generator. They also wrote procedure 01-S-7-40 to provide instructions i
for scheduling, completing and documenting maintenance performed on the
EOF systems.
The inspector reviewed maintenance tests performed on the EOF Emergency Ventilation System in August 1992 and the EOF diesel generator perfJrmed in March of 1992. The test indicated that the
system functioned properly. The inspector noted that the TSC and the control room were in the same emergency ventilation system envelope.
l The inspector reviewed inventory records from April 1991 to February
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1993, of the various emergency kits. The records indicate the emergency
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kits were being properly maintained.
Since the licensee used many of the emergency kit during the March 24, 1993 drill, the inspector did not
performed any inventory check of emergency kits during this inspection.
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The inspector reviewed the licensee's documentation of required communications tests for the period of April 1991 to February 1993 for.
the EOF and TSC: (1) monthly communications system functional tests; (2) monthly communications drills involving message transmission to the state Warning Point via the Automatic Ring-Down; and (3) tests of the
ENS and HPN. According to the records, prompt corrective actions were
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undertaken when equipment deficiencies were identified.
The ANS consisted of 43 fixed sirens (30 in Claiborne County and 13 ~in Tensas Parish). Testing was performed under the jurisdiction of the
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respective county and parish emergency management agencies, with test i
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results forwarded to the licensee. The test results were satisfactory and indicated that sirens met the annual 90 percent capability criteria.
The inspector noted in June 1992, that the licensee had used 42 as the total number of sirens instead of 43.
Siren MBB had been removed.from the pole for repair prior to the test.
The inspector noted when calculating the operability factor for the ANS, (number of sirens that function properly divided by the total number of' sirens) the licensee subtracted from the denominator, the siren known to be out of-service.
This in effect increased the apparent operability factor.
The accepted method of calculating siren operability was discussed with the licensee.
The licensee stated that the method of calculation had been brought to their attention. The licensee stated that they will continue to use the total number of installed sirens when calculating ANS system operability.
The inspector concluded that the ERO facilities and emergency equipment I
was appropriately maintained.
No violations or deviations were identified.
4.
Organization and Management Control (82701)
i Pursuant to 10 CFR 50.47(b)(1) and (16) and Section IV.A of Appendix E to 10 CFR Part 50, this area was inspected to determine the effects of.
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any changes in the licensee's emergency response organization and/or l
management control systems in the emergency preparedness program and to i
verify that such changes were properly factored into the EP and EPPs.
i The inspector discussed the site's working relationship, in Emergency Preparedness, with offsite agencies. The relationships were described
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as open and responsive. The inspector noted there was a change in the
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Claiborne County Civil Defense Director in 1992. The licensee noted
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there had been improvements in the Claiborne County emergency program
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which improved the overall effectiveness of the licensee's emergency
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preparedness program since the new director assumed' office. The i
licensee stated that they have monthly meetings with the local governments. Documentation of licensee response to local communities
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request indicated that the licensee provided both personnel and
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financial support to the local communities.
Review of organizational charts and discussions with the licensee indicated there were no management or organizational changes and that i
the ERO was basically unchanged since the last inspection.
Based on the
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stability of the licensee's organization, the number of facility improvements, and the emergency preparedness procedural process, the
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inspector concluded that management was involved in and supportive of
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the Emergency Preparedness Program.
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No violations or deviations were identified.
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Independent Review / Audits (82701)
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Pursuant to 10 CFR 50.47(b)(14) and (16) and 10 CFR 50.54(t), this area
was inspected to determine whether the licensee has a corrective action
system for deficiencies and weaknesses identified during exercises and-i drills.
l The inspector reviewed two audit reports, QSA-91/0014 conducted April 4 j
through April 24, 1991,- and QSA-92/0010 conducted March 2 through l
March 24, 1992.
Both audits focused on the following areas of the l
Emergency Preparedness program:
l interface with state and local officials
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effective implementation of Emergency Preparedness procedures t
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I training of the ERO
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readiness of the ERF
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programmatic adequacy of the EP and implementing procedures l
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Both audits were adequate in depth and coverage of the program and met
the requirements identified in 10 CFR 50.54(t). The inspector verified j
j that the audit findings were being tracked (QDR) and adequately
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responded to by the Emergency Preparedness organization. The inspector
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reviewed the qualifications of the auditors and concluded that the auditors qualifications were satisfactory.
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i The licensee's programs for follow-up on findings from audits, drills,
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and exercises. The inspector reviewed the following EP tracking lists:
Emergency Preparedness QDR Activities Summary
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Licensing Commitment Tracking System (EP)
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Emergency Preparedness Action Tracking System j
i The inspector reviewed the tracking list and concluded that the licensee l
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was responsive in addressing the identified items. The licensee and j
Emergency Preparedness organization had developed an " Emergency l
Preparedness Performance Indicators" chart for evaluating and monitoring i
their monthly performance. The chart monitored:
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NRC open items
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EP Administrative Procedure Requirements Past Due
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Siren Operability
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VIP 2000 Test
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QDR Closeout
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By the licensee's criteria, the Emergency Preparedness organization had l
performed in the best of four categories. The inspector only reviewed
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Emergency Preparedness Performance Indicator charts from October 1992 until present.
Procedure 01-S-10-4, " Emergency Plan Trsining and Drills," Attachment V,
" Required Drills and Exercises" along with other required testing were
placed in a matrix type ledger called the "1992 Emergency Preparedness j
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Activities." When the inspector reviewed the ledger, it was noted that i
several of the required activities identified on the ledger were not
indicated as having been completed. Atter considerable time and effort, j
the licensee was able to produce documentation that indicated the l
required activities had been completed. Also, the inspector noted that
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the licensee was performing some required activities, but were not i
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documenting them properly (as an example monthly check of the VIP 2000).
The inspector noted that the terms " monthly," Quarterly," and " Weekly" l
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were not defined in the Emergency Preparedness program. Although no
violation or deficiency had occurred in their testing, the. inspector
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discussed with the licensee their meaning of " frequency" and their method of recordkeeping and documentation. The licensee acknowledged
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that these were areas that could be improved upon.
No violations or deviations were identified.
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Training (82701)
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Pursuant to 10 CFR 50.47(b)(2) and (15), and Section IV. F of Appendix E to 10 CFR Part 50, this area was inspected to determine whether the licensee's key emergency response personnel were properly trained and understood their emergency responsibilities.
The inspector selected members of the ERO and reviewed their training i
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records. The training records were computerized and data could be accessed in a number of ways making tracking of ERO member training
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easy. The inspector reviewed the monthly Emergency Response Organization Training Verification Report. The report listed each
individuals training: their name, ERO position, the course titles code, the date they completed the course, and indicated if they failed, passed
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on retest or exempt from test, certified by exam, incomplete, or expired. The inspector also reviewed a computer list that identified individuals with expired training. The expired individuals were removed
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from the ERO roster until they were trained. All of the records reviewed were current and up to date.
The inspector interviewed the EP Training Instructor and inquired about the instructors qualifications, the training program, and management support.
The inspector concluded that the instructor was well qualified and dedicated.
It was also noted that the lone instructor performed numerous other teaching responsibilities.
The inspector reviewed procedure 01-S-04-21, " Administrative Procedure, Emergency Preparedness Training Program." The procedure defined
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management responsibilities in the ERO, Scope of ERO training,
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Summary /0utline of EPTS Classes, and a matrix of ERO Training
Qualification requirements. The inspector concluded the EP training program was organized and disciplined.
The inspector reviewed EPTS-3, Radiological Emergency Assessment j
Handout, the question bank for EP03, and an exam that was given for
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EP03. The inspector concluded that the lesson handout satisfied the J
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i requirements identified in 01-S-04-21, " Administrative Procedure, i
Emergency Preparedness Training Program," Attachment 1.
The test bank
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was sufficient to ensure a diversity in the exams, but the inspector I
noted that in actuality there were only one half of the apparent exam.
bank questions.
All of the exam bank questions were asked basically
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twice but, in different formats. The duplication of questions was noted i
by the inspector and discussed with the instructor.
The instructor
indicated she was aware of the condition and was working to upgrade the
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question bank but that it was not a high priority. The inspector reviewed an exam, and concluded that the exam was adequate to test the
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skills required of the position in the ERO.
The inspector reviewed documentation that indicated training, as i
specified in the Plan, was provided to Parkview, Vicksburg, and Claiborne Counties, and Riverland Hospital, in the 2nd, 3rd and 4th quarter of 1992, State and local trairing was provided in June 1992, and
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the annual fire brigade drill with the local fire department was held in
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December 1992.
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The inspectors observed a quarterly training drill on March 24, 1993.
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The scope of the drill involved the emergency response organization
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fully participating in the Simulator / Control Room, TSC, OSC, and E0F.
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State and local agencies participated in communications and i
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notifications only. Damage repair teams were dispatched from the OSC and the OSC tested their new cart and procedure for the issuing electronic alarm dosimeters to emergency team members. Other activities
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such as dispatch of offsite monitoring teams and personnel site accountability / evacuation were simulated.
The intent of this exercise was to provide additional training to the ERO. The licensee's critique was very thorough and solicited group participation.
The inspector concluded that the exercise achieved its training objectives.
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No violations or deviations were identified.
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Exit Interview j
The inspection scope and results were summarized on March 26, 1993, with l
those persons indicated in Paragraph 1.
There were no dissenting
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remarks by the licensee. No proprietary information was reviewed during this inspection.
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Acronyms and Initialisms
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ANS Alert and Notification System l
CFR Code of Federal Regulations l
EAL Emergency Action Level i
EDG Emergency Diesel Generator
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ENS Emergency Notification System j
E0C Emergency Operations Center i
EOF Emergency Operating Facility
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EP Emergency Plan EPP Emergency Plan Procedures EPZ Emergency Planning Zone
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ERF Emergency Response Facility (TSC, EOF, OSC)
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ERFIS Emergency Response Facility Information System ERO Emergency Response Organization
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EW Exercise Weakness IFI Inspector follow-Up Item i
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IN Information Notice INP0 Institute of Nuclear Power Operations IR
Inspection Report
Notice Of Unusual Event
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Nuclear Regulation
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Operational Support Center
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Protective Action Recommendation
Quality Deficiency Report
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Safety Parameter Display System
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Technical Specification
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