IR 05000416/1998016
| ML20198L788 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf |
| Issue date: | 12/24/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20198L769 | List: |
| References | |
| 50-416-98-16, NUDOCS 9901050117 | |
| Download: ML20198L788 (17) | |
Text
.
.
.
.
..
-
..
.. -..-
. _.
--
.-
-
.
.
ENCLOSURE 2
,
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.:
50-416 License No.:
'
Report No.:
50-416/98-16 Licensee:
Entergy Operations, Inc.
Facility:
Grand Gulf Nuclear Station Location:
Waterloo Road Port Gibson, Mississippi Dates:
December 7-11,1998 inspector (s):
Gail M. Good, Senior Emergency Preparedness Analyst Peter J. Alter, Resident inspector Approved By:
Blaine Murray, Chief, Plant Support Branch
Attachment:
SupplementalInformation 9901050117 981224
,
PDR ADOCK 05000416
\\
G PDR
-2-EXECUTIVE SUMMARY Grand Gulf Nuclear Station NRC Inspection Report 50-416/98-16 A routine, announced inspection of the operational status of the licensee's emergency preparedness program was conducted. The inspection included the following areas: events, emergency facilities and equipment, emergency plan and implementing procedures, training, organization and management control, audits, effectiveness of licensee controls, and followup on open items. Emphasis was placed on changes that had occurred since the last routine emergency preparedness inspection.
Plant Sucoort Overall, the emergency preparedness program was effectively implemented.
- Emergency response facilities were operationally maintained, and appropriate equipment and supplies were readily available. There was an increase in program visibility and management involvement, and processes for program maintenance were well defined. The emergency preparedness staff consisted of knowledgeable and conscientious individuals with the appropriate expertise. Comprehensive and indepth program audits were conducted (Sections P2, P6, and P7.1).
A concern was identified involving the time allowed for updating the emergency plan and
procedures in the emergency response facilities, including the control room (Section P2).
Extending the response times for two health physics technicians from 30 to 60 minutes
in the emergency plan was identified as a violation of 10 CFR 50.54(q). Since corrective actions were taken, no response is required (Section P3).
Crew performance during the walkthroughs was good. Emergency classifications were
correct and timely. The offsite agency notification process was not always effectively implemented. For example, timeliness requirements were challenged on several occasions and forms were not always completed properly. The site evacuation process was implemented in a timely fashion, but actions were not fuily consistent with the site evacuation procedure. Guidance concerning the destination of personnel evacuated from the site was not included in the site evacuation procedure. Dose assessment activities were satisfactorily performed, and protective action recommendations were correct and timely. The emergency preparedness staff performed a self-critical evaluation of crew perfmance during the walkthroughs (Section P4).
A comprehensive action plan was developed to resolve chronic emergency response
organization qualification maintenance and tracking problems. Lesson plan content was not always reviewed by emergency preparedness personnel; one minor discrepancy
,
was identified. Drill reports were thorough and auditable (Section PS).
. -...
..... --_--
-
-..
_...=-.....
-
...
. -.. -.....
.. -... -..
.
!
.
.
3-An indepth self assessment ' as performed. The emergency preparedness department
'
- -
w
- increased its use of the condition reporting system to trend drill / exercise issues. There
were no longstanding issues (Section P7.2).
.
(
Corrective actions for a previously identified weakness were not well documented
,
- (Section P8.2).
'
'
.s
&
I
1
'
l l
.-
t I
,
,
s
,
,
,;
-
l i
I
'
J
,
p
,
.
.., -
y
-. -,,,, - _, -,
,-
,,
-
. _.
.
.
.
-4-Report Details IV. Plant Support P1 Conduct of Emergency Preparedness Activities a.
Insoection Scoce (93702)
The inspectors reviewed event notifications made since September 1997 to determine if events were properly classified. Thera were no declared emergency events during that period.
b.
Observations and Findinas The inspectors determined that none of the events were misclassified (i.e., none should have been declared emergency events).
c.
Conclusions The event notifications made to the NRC Operations Center since the last inspection were prop 63y classified.
P2 Status of Emergency Preparedness Facilities, Equipment, and Resources a.
Inspection Scope (82701-02.02)
.
The inspectors reviewed the status of emergency response facilities, equipment, instrumentation, and supplies to ensure that they were maintained in a state of operational readiness. The inspectors toured the following facilities:
Technical support center (TSC)
Operations support center (OSC)
Emergency operations facility (EOF)
b.
Observations and Findinas Inspectors found that the emergency response facilities were tidy and capable of operation. The OSC was the only facility that served a dual purpose (meetings were routinely held in the command room). As a result, the facility was less orderly than the other two. Appropriate equipment, instruments, procedures, and supplies were maintained in the facilities.
'
,
i Since the last inspection, the licensee identified different alternate locations for the TSC l
and OSC. The new locations were appropriately incorporated into the emergency plan, and drills were conducted to test the alternate locations and familiarize personnel with their use. The inspectors asked if procedural guidance / criteria existed to help emergency response organization members determine the need to relocate (habitability
1
!
,
_ _. _ _ _ _.. _.... _ _ _ _ _ _ _. _ _ _ _ _. _
_
_
_ _.
_.
-5-thresholds, materials to be relocated, etc.). The licensee stated that Condition Report 1998-1339 had already been issued to address this need. The licensee's response demonstrated awareness of issues identified during other regional emergency l'
preparedness inspections.
The inspectors verified that processes existed to maintain the facilit:es, test equipment, l
verify telephone numbers, and update facility copies of the emergency plan and l
procedures. Although the processes were established and implemented, the inspectors identified a concern involving the length of time allowed to update emergency response facility emergency plans and procedures (up to 14 days for all facilities, including the control room). Inspectors determined that 14 days was excessive for procedures that involved protection of the public (emergency classification, protective action
'
recommendations, etc.). The licensee issued Condition Report 1998-1452 to evaluate the inspectors' concerns.
c.
Conclusions Emergency response facihties were operationally maintained, and appropriate equipment and supplies were readily available. Procedural guidance for relocating emergency response facilities was being developed. A concern was identified involving the time allowed for updating the emergency plan and procedures in the emergency response facilities, including the control room.
P3 Emergency Preparedness Procedures and Documentation s.
Inspection Scope (82701-02.01)
The inspectors used Inspection Procedure 82701 in determine whether the emergency plan and procedures were maintained. The inspectors reviewed: (1) emergency plan and procedure submittals, (2) offsite agency wviews of emergency action levels, and (3) selected portions of the emergency plan and implementing procedures for continuity, b.
Observations and Findinas The Office of Nuclear Reactor Regulation (NRR) reviewed Revision 28.001-95 to the Grand Gulf Nuclear Station Emergency Plan submitted on June 30,1995, via Task Interface Agreement 95-15 from NRC, Region 11. As part of that plan change, the licensee extended the augmentation response time for two health physics technicians from 30 to 60 minutes. The licensee did not request prior NRC approval since it determined that the change did not decrease the effectiveness of the emergency plan.
The Emergency Preparedness and Radiation Protection Branch completed its review of Emergency Plan Revision 28.001-95 on November 21,1996. The resulting safety evaluation stated that the change in the response tirne for the two health physics technicians constituted a decrease in the effectiveness of the emergency plan. The safety evaluation was forwarded to the licensee by a letter dated April 24,1997.
.
-
-
-
.
-6-
,
The licensee appealed the decision, and an appeal board was convened on July 10,1997. A summary of the appeal board meeting was issued on July 17,1997.
After further review, NRR reaffirmed its initial position that the change decreased the effectiveness of the emergency plan (letter to Mr. William Eaton from Mr. Jack Donohew, dated November 16,1998). During the inspection, the licensee confirmed that it did not plan to appeal the final decision.
10 CFR 50.54(q) permits licensees to make emergency plan changes, without prior NRC
-
approval, only if the changes do not decrease the effectiveness of the plan. Accordingly, the failure to receive NRC approval prior to making an emergency plan change that decreased the effectiveness of the plan was identified as a violation (50-416/98016-01).
Af ter the receipt of the initial safety evaluation, the licensee issued Condition Report 1997-0397 to track resolution. Corrective actions already taken included adding licensing concurrence to emergency plan changes to help prevent implementation of other changes that may decrease emergency plan effectiveness. Following receipt of the November 16,1998, letter, the licensee reinstated two 30-minute health physics responders to the emergency response organization. The inspectors concluded that the licensee's' actions were prompt and thorough.
The inspectors reviewed other emergency plan and procedure submittals to determine if they were submitted to the NRC in accordance with 10 CFR 50.54(q),50.4, and Appendix E.V to Part 50. All reviewed submittals were properly submitted.
The inspectors verified that emergency action levels were reviewed with offsite agencies on an annual basis in accordance with 10 CFR 50, Appendix E.IV.B. The licensee issued Condition Report 1998-1160 to address a discrepancy in this area. The licensee's actions were thorough and complete.
In reviewing the emergency plan and procedures, the inspectors identified a discrepancy in Emergency Preparedness Procedure 10-S-01-1, " Activation of the Emergency Plan,"
Revision 103, concerning the guidance for classifying a security threat event.
Attachments I and IV, " Emergency Classifications and Emergency Classification Flowchart," did not clearly define an event where intruders take control of vital areas of the plant, other than the control room or the remote shutdown panel. The inspectors interviewed two shift superintendent / emergency directors. Neither could make a definitive classification for a postulated event where armed intruders had entered the protected area and had taken control of the standby service water complex. The standby sen/ ice water complex was defined elsewhere in the attachments as a vital l
area. The licensee agreed that the procedural guidance was unclear.
)
In response, the licensee immediately alerted those members of the staff who could be responsible for event classification that the proper classification for this situation would be a site area emergency, rather than an aled The licensee also issued Condition Report 1998-1466 to track the resolution of the problem and subsequent procedure change. The licensee's actions were prompt and appropriate.
{
. - _ _ _ - _ _.
.
.
c.
Conclusions Extending the response times for two health physics technicians from 30 to 60 minutes in the emergency plan was identified as a violation of 10 CFR 50.54(q). Since corrective
'
actions were taken, no response is required. The licensee properly responded to e discrepancy in the emergency classification procedure involving security events.
P4 Staff Knowledge and Performance in Emergency Preparedness a.
Inspection Scoce (82701-02.01)
The inspectors conducted walkthroughs with two operating crews using a dynamic j
simulation on the plant-specific control room simulator. During the walkthroughs, the i
licensee was evaluated on the ability to:
Evaluate plant conditions,
=
Classify the emergency using the latest procedures, a
Recommend appropriate protective actions (onsite and offsite),
Make timely notifications to offsite agencies, and
,
Perform and evaluate dose calculations.
- The scenario consisted of a sequence of events requiring escalation of emergency classifications, culminating in a general emergency. The initiating event was a notification of unusual event resulting from an increase in off-gas pretreatment radiation levels, indicating a failure of reactor fuel cladding. Subsequent reactor coolant sample analysis required a plant shutdown and declaration of an alert. During tha plant i
shutdown, a main steam line high radiation alarm caused the operators to scram tne reactor and shut the main steam isolation valves. Due to subsequent system failures, all high pressure injection systems were lost and reactor water level dropped below the top of active fuel. This condition led to a declaration of a site area emergency.
Following a manual depressurization, the reactor was refilled with low pressure inject;on systems. During the depressurization, the steam supply piping to the reactor core isolation cooling systerc hiled and the system did not isolate. The auxiliary building blowout panels ruptured. uutting in an uncontrolled release to the environment and the declaration of a general emergency. The release was terminated when one of the failed reactor core isolation cooling system isolation valves was re-energized and closed by the operators. Each walkthrough lasted approximately 90 minutes.
b.
Observations and Findinas Both crews responded well to the transients, and both shift superintendents / emergency directors correctly classified the emergency events in a timely manner. Both shift superintendents anticipated that reactor water level would reach top of active fuel before it could be procedurally recovered and declared the site area emergency earlier than expected by the scenario developers, using the discretionary emergency action level.
,
~
.
._ -
.-
. -.
.
-
.
-
-
.
<.
-8-The second operating crew did not perform to expected levels of operational performance on one occasion. The reactor operators did not recognize the failure of the reactor core isolation system to isolate for several minutes. The licensee identified this performance issue and took prompt remedial actions. The reactor operators involved were counseled during the operations critique of the walkthrough and the emergency preparedness implications were emphasized to the entire crew.
l
!
The offsite agency notification process was not always effectively implemented during
'
the walkthroughs. Inspectors identified the following examples:
During the first walkthrough. timeliness requirements were challenged on several
occasions due to implementation methods (waiting for briefings to end, meteorological data input, etc.).
The communicator on the fi st crew did not use consistent terminology during
=
notifications. The individuai mixed the use of the phonetic alphabet when j
affected sectors for protective action recommendations were communicated.
I This could have caused confusion.
Notification forms were not always completed properly (both crews).
- The communicator on the second crew did not complete the initial or final roll call
when making the notification of unusual event notification and did not properly l
'
document the notifications on the back of the form (a different form was initially used then the information was copied onto the record form). This practice was not consistent with procedures or training.
In addition to the examples identified by the inspectors, the licensee identified several other examples of improper implementation of the notification process. The licensee characterized the issue as a weakness during the critique process and issued Condition Report 1998-1462 to track corrective actions and resolution.
l l
Both shift superintendents satisfactorily demonstrated the ability to implement a site i
evacuation in a timely manner; however, inspectors observed the following i
inconsistancies:
The first shift superintendent / emergency director appeared less certain of the
procedural guidance required for the site evacuation and did not consult the procedure until after the evacuation was started. Although security personnel were contacted prior to the evacuation (simulated), the evacuation route was not provided. Evacuation announcements to plant personnel did specify an evacuation route.
l Prescripted announcements included in the site evacuation procedure
(10-S-01-11," Evacuation of Onsite Personnel," Revision 5) were not consistently (
used to ensure that announcements contained all necessary information and were consistent. Announcements were composed at the time of the
!
_..
....
--
_
.
~-,-
-
--
-
.
-9-announcement and not written down to ensure that the content remained the same when announcements were repeated.
Neither shift superintendent identified or communicated an evacues destination
=
as required by Step 6.1.2.a of Procedure 10-S-01-11. Inspectors also noted that the procedure did not provide guidance concerning destination options (e.g., home or offsite reception centers). Provisions for monitoring personnel evacuated from the site are specified in Evaluation Criteria J-3 and * af NUREG-0654 (FEMA-REP-1)," Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1. This matter was identified as an inspection followup item (50-416/98016-02).
Dose assessment and protective action recommendations were satisfactorily performed during the walkthroughs. Both crews made the default protective action recommendations for the general emergency and calculated projected doses to determine if additional protective actions were necessary. Both shift chemists effectively communicated with their respective shift superintendent to ensure that offsite doses were understood and that protective action recommendations were correctly formulated.
However, the shif t chemist and superintendent on the first crew used an incorrect isotopic mixture to perform dose calculations. The licensee identified this error as a weakness during the critique process and issued Condition Report 1998-1461 to track corrective actions and resolution.
c.
Conclusions Crew performance during the walkthroughs was good. Emergency classifications were correct and timely. The offsite agency notification process was not always effectively implemented. For example, timeliness requirements were challenged on several occasions and forms were not always completed properly. The site evacuation process was implemented in a timely fashion, but actions were not fully consistent with the site evacuation procedure. Guidance concerning the destination of personnel evacuated from the site was not included in the site evacuation procedure. Dose assessment activities were satisfactorily performed, and protective action recommendations were correct and timely. The emergency preparedness staff performed a self-critical evaluation of crew performance during the walkthroughs.
P5 Staff Training and Qualification in Emergency Preparedness a.
Inspection Scope (82701-02.04)
The inspectors reviewed the training program, training records for selected individuals, and documents associated with emergency drills / exercises.
-
.
.
-10-b.
Observations and Findinas Over the past several years, the licensee documented several problems involving emergency response organization qualification maintenance. Both the 1997 and 1998 program audits (10 CFR 50.54(t)] identified instances where training qualifications were not maintained. Numerous condition reports were written and a root cause analysis was conducted, but corrective actions were ineffective. Problems with the training tracking system were also documented.
When questioned about the chronic problem, the !icensee stated that an action plan was developed and in the final approval process. The action plan focused on communicating expectations to emergency response organization members, providing feedback to drill / exercise participants who make recommendations, and resolving the training database problems. The action plan was considered comprehensive.
The inspectors reviewed training records for selected key emergency response personnel to determine if qualifications were current. The inspectors focused on new emergency response organization members and those who were transferred to new positions. All training qualifications were complete and current.
The inspectors reviewed Lesson Plan GG-1-LP-RO-EPTS6," Emergency Assessment (Operations)," Revision 1, and found that it contained statemente that were not supported by the emergency plan or procedures. The lesson plan stated that written summaries of declared events were provided to offsite agencies. These summaries are described in Appendix l to NUREG-0654. Although this discrepancy had no effect on emergency response capabilities, inspectors noted the public relation value of the written summaries. However, the discrepancy in the lesson plan highlighted a shortcoming in the lesson plan review process: emergency preparedness personnel were not included in the review process to verify that content was necessary and correct. The licensee acknowledged the inspectors' comments.
Several drill reports were reviewed to ensure that required specialty drills were being conducted (e.g., radiological monitoring, post-accident sampling system, offhours/ unannounced, and backup emergency response facilities). The drills were well documented (thorough and auditable). Reports included a list of action tracking items and a list of the specialty drills if they were conducted during an integrated drill.
The inspectors did question the scope of the offhours/ unannounced drill, since
,
'
controllers ran the drill from the simulator, rather than using a control room crew. As a result, the drill did not test the ability of an onshift crew to contend with the emergency situation until the augmented staff arrived. In response, the licensee indicated that the adequacy of onshift staffing, effectiveness of training, and opportunity to practice emergency director responsibility turnover were covered in other training / drill situations.
The inspectors agreed with the licensee's comments but planned to discuss the matter with NRC Headquarters to promote consistency between the NRC regions.
_ _ _ _ _ _ _
s
..
.
.
-
.
.--
..
.
-
.
.
-11-c.
Conclusions
.
A comprehensive action plan was developed to resolve chronic emergency response organization qualification maintenance and tracking problems. Lesson plan content was not always reviewed by emergency preparedness personnel; one minor discrepancy
- was identified. Drill reports were thorough and auditable.
P6 Emergency Preparedness Organization and Administration a.
Inspection Scope (82701-02.03)
The inspectors reviewed emergency preparedness department management and staffing, emergency response organization staffing, and offsite support organization agreements.
b.
Observations and Findinas in March 1998, the emergency preparedness department was transferred from plant projects and support to training. Inspection results indicated that this change has had a positive effect. Program visibility and management involvement were increased by utablishing a site management lead team (facility process owners) with increased responsibilities and by instituting an " emergency preparedness day of the week." These actions have improved attendance at exercise / drill critiques and heightened emergency response organization awareness of the program and performance expectations.
Processes for program maintenance were well defined.
The inspectors reviewed emergency preparedness program staffing and found that there were no changes in staffing numbers or expertise. Although some personnel rotations had occurred, the staff still consisted of highly trained individuals with emergency preparedness, chemistry, radiation protection, and operations expertise.
The emergency response organization was fully staffed. The number of teams was reduced from four to three, but a reserve in some positions existed. The reduction in the number of teams did not affect the licensee's emergency response capabilities.
c.
Conclusions There was an increase in program visibility and management involvement, and
. pri nses for program maintenance were well defined. The emergency preparedness stax cnsisted of knowledgeable and conscientious individuals with the appropriate expe h e.
,
i l
l-lc
-
-12-P7 Quality Assurance in Emergency Preparedness Activities P7.1 Indeoendent and Internal Reviews and Audits (82701-02.05)
a.
Insoection Scope The inspectors examined the latest emergency preparedness program audit reports (Quality Program Audit Reports OPA 06.01-97, dated August 22,1997; and OPA 06.01-98, dated November 9,1998) to determine compliance with NRC requirements and licensee commitments.
b.
Observations and Findinos The emergency preparedness program audits were conducted in accordance with 10 CFR 50.54(t). Technical specialists from other sites (including non-Entergy sites)
were included on both audit teams. As previously discussed, both audits identified problems with emergency preparedness training qualifications. The 1998 audit also identified issues involving poor emergency response organization performance, the lack of critical self assessment, and omissions in emergency preparedness training content.
Although both audits were very good, the 1998 audit was particularly probing; 2 positive findings,8 negative findings (1 significant),39 observations, and 32 recommendations for improvement were identified. Results of both audits were appropriately made available to offsite authorities.
c.
Conclusions Comprehensive and indepth program audits were conducted. Audit results contributed to emergency preparedness training program improvements.
P7.2 Effectiveness of Licensee Controls (82701-02.06)
a.
inspection Scope The inspectors reviewed a draft self assessment, conditions reports, and emergency preparedness action tracking system items.
t Observations and Findinas An assessment of the emergency preparedness progra n was conducted November 16-19,1998. The assessment team included a number of Entergy representatives (corporate and site representatives), an omergency preparedness manager from another site (non-Entergy), and an emergency preparedness coordinator from another site (also non-Entergy). The team assessed the following areas:
(1) program adequacy, (2) emergency response organization knowledge and skills, (3) interfaces, (4) problem identification and resolution, and (5) severe accident management. The assessment was thorough and detailed. Many good issues were i
_ _ _ _ _ _ _ _ _ _
..
-_.
- -
-
--
..
i-13-identified, some of which were incorporated into the licensee's emergency preparedness training action plan (see Section P5 above).
The licensee used the emergency preparedness action tracking system to track lower level improvement items and the condition report system for tracking more significant items. To improve trending capabilities for drill / exercise issues, emergency
,
preparedness personnel were using a lower threshold for initiating condition repds.
There were no longstanding issues on either tracking system and it was clear that there was an increased use of the condition reporting system.
c.
Conclusions An indepth self assessment was performed. Many good issues were identified; some were factored into the emergency preparedness training action plan. The emergency preparedness department increased its use of the condition reporting system to trend drill / exercise issues. There were no longstanding issues.
P8 Miscellaneous Emergency Preparedness issues
'
P8,1 (Closed) IFl 50-416/97009-01: exercise weakness for failure to satisfactorily perform dose assessment activities. During the simulator walkthroughs conducted during the last emergency preparedness operational status inspection, the shift chemists poorly performed dose assessment activities. Some dose projections were untimely, incorrect, and incomplete, and some results were not correctly communicated to the emergency director. Corrective actions taken to resolve the weakness, as described in the i
licensee's August 22,1997, response, included periodic training with the operations shift in the control room or simulator, providing a work station for the chemist near the shift superintendent (to facilitate communications), upgrading training, and upgrading procedures. As discussed in Section P4 above, dose assessment activities were satisfactorily performed during this inspection. One of the shift chemists used the wrong
'
isotopic mixture in calculations. The licensee issued Condition Report 1998-1461 to track resolution of that error.
P8.2 (Closed) IFl 50-416/97009-02: exercise weakness for failure to satisfactorily implement site evacuation procedures. During the simulator walkthrout,Ss conducted during the last emergency preparedness operational status inspection, both shift superintendents poorly implemented site evacuation procedures. The site evacuations were not timely, security personnel were not informed of the evacuation routes, and the site evacuation procedure was not used. To correct the matter, the licensee provided training to the emergency response organization to reinforce strict emergency procedure adherence.
The inspectors reviewed the corrective actions taken and found that an electronic mail message had been sent to the emergency response organization. However, the list did not include shif t personnel (including operations). The inspectors were informed that emergency preparedness personnel conducted separate training with operations personnel covering the site evacuation process and procedure usage. There was no documentation to support this training. In addition, the licensee revised the " Emergency Director Checklist"(an attachment to procedure 10-S-01-1," Activation of the Emergency l
,
.
-14-Plan," Revision 103) to include more guidance to alert security and determine an appropriate evacuation route for all partial and complete site evacuations. As discussed in Section P4 above, both shift superintendent / emergency directors satisfactorily implemented site evacuation procedures during this inspection. Timely affected area and site evacuations were conducted (simulated). In each case, security was informed and specific site evacuation routes were announced; however, procedure usage was inconsistent.
P8.3 (Closed) IFl 50-416/97015-04: dose assessment methodology (release duration time).
During the 1997 biennial exercise, inspectors identified the potential for performing non-conservative dose calculations due to the licensee's practice of using a 2-hour release duration time even when the release continued for more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. As a result, the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of a release would not be factored into dose projections. This i
could affect protective action recommendations. The licensee based its practice on terminology used in Section 2.1 of Environmental Protection Agency EPA-400-R-92-001," Manual of Protective Action Guides and Protective Actions for Nuclear Incidents." To resolve this issue, prior to the inspection, the lead inspector discussed the matter with an Environmental Protection Agency representative, NRC Headquarters personnel, and regional inspectors. The consensus was that the licensee had misapplied the guidance. After discussing the matter during this inspection, the licensee agreed that there was a need to clarify its procedures to ensure that dose assessments were as accurate as possible and would provide the greatest level of public protection. The licensee issued Condition Report 1998-1451 to track corrective actions. The inspector planned to discuss the matter further with NRC Headquarters to promote consistency between the NRC regions.
V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on December 11,1998. The licensee acknowledged the findings presented. No proprietary information was identifie..
.
.... --.= - _ -
.
--.- - -
_..-
.
.
--...
l l
.
AlTACHMENT l
SUPPLEMENTAL INFORMATION
,
l
>
PARTIAL LIST OF PERSONS CONTACTED Licensee W. Eaton, Vice President, Operations F. Guynn, Emergency Planner D. Janecek, Director, Training and Emergency Preparedness K. Mcdonald, Emergency Planner C. Morgan, Manager, Ernergency Preparedness J. Owens, Senior Licensing Specialist B. Raines, Emergency Planner J. Roberts, Director, Quality C. Stafford, Manager, Operations D. Townsend, Senior Emergency Planner LIST OF INSPECTION PROCEDURES USED 82701 Operational Status of the Emergency Preparedness Program 92904 Followup - Plant Support 93702 Prompt Onsite Response to Events at Operating Reactors LIST OF ITEMS OPENED AND CLOSED Opened 98016-01 VIO Extended response times for two health physics personnel (Section P3)
98016-02 IFl Lack of procedural guidance for evacuee destination (Section P4)
Closed 97009-01 IFl Weakness - Failure to satisfactorily perform dose assessment activities (Section P8.1)
97009-02 IFl Weakness - Failure to satisfactorily implement site evacuation procedures (Section P8.2)
97015-04 IFl Dose assessment methodology - release duration time (Section P8.3)
98016-01 VIO Extended response times for two hea!th physics personnel (Section P3)
.
l
-2-LIST OF DOCUMENTS REVIEWED Emeraency Preparedness Procedures
.
10 S-01-1, Activation of the Emergency Plan, Revision 103 10-S-01-6, Notification of Offsite Agencies and Plant On-call Emergency Personnel, Revisien 30 10-S-01-11, Evacuation of Onsite Personnel, Revision 11 10-S-01-12, Radiological Assessment and Protection Action Recommendations, Revision 22 10-S-02-1, ERF inspection, Inventories, Operability Checks, and Maintenance, Revision 4 Administrative Procedures 01-S-04-21, Emergency Preparedness Training Program, Revision 103 01-S-10-3, Emergency. Preparedness Department Responsibilities, Revision 5 01-S-10-4, Emergency Preparedness Drills and Exercises, Revision 7 01-S-10-5, Control of Emergency Response Equipment and Faci!! ties, Revision 4 01-S 10-6, Emergency Response Organization, Revision 10 Other Documents Grand Gulf Nuclear Station Emergency Plan, various revisions through Revision 36 Event Reports: 33012,33082,33139,33265,33302,33432,33622,33807,34128,34184, 34605,34919, and 34957 Safety Evaluation for Grand Gulf Nuclear Station Emergency Plan, Revision 28.001-95, dated November 21,1996 Safety Evaluation transmittalletter to Grand Gulf Nuclear Station from NRC concerning Revision 28.001-95, dated April 24,1997 Appeal board summary, m: 3d July 17,1997 Letter documenting appeal mee';ng for Orand Gulf Nuclear Station Emergency Plan Change 28.001-95, dated November 16,1998 Condition Reports: 1997-0397,1997-1153,1997-1154,1998-1027,1998-1160,1998-1339, 1998-1451,1998-1452,1998 1461,1998-1462,1998-1466
..
..... _.. _ _ _.._ _ _ _._.
_.
.
_
.. _..
-
l
.
-3-Top 100 oldest condition reports list, dated December 10,1998 Training Lesson Plan GG-1-LP-RO-EPTS6, Emergency Assessment (Operations), Revision 1
'
Emergency Response Organization Roster, dated October 12,1998 Training records for selected emergency response organization personnel Selected 1997 and 1998 drill reports Letters confirming offsite agency agreements f
Quality Program Audit Report OPA 06.01-97, dated August 22,1997 Quality Program Audit Report OPA 06.01-98, dated November 9,1998 Emergency Precaredness Action Tracking System open items list, dated December 7,1998 Draft Emergency Planning Program Assessment, dated December 11,1998 Response to Exercisa Weaknesses, NRC Inspection Report 97-09, GNRO-97/00080, dated August 22,1997 Scenario for December 8 and 9,1998 walkthroughs
,
,
L j
L l