Text

IR 05000458-02-005, Inspection on 01/28 - 03/20/2002, River Bend Station, Emergency Action Level & Emergency Plan Changes. Violations Noted & Being Considered for Escalated Enforcement Action
	ML022810670
Person / Time
Site:	River Bend
Issue date:	04/18/2002
From:	Howell A; Division of Reactor Safety IV
To:	Hinnenkamp P; Entergy Operations
References
	EA-02-036 IR-02-005
	Download: ML022810670 (22)
	v • d • e

April 18, 2002

EA-02-036

Mr. Paul D. Hinnenkamp, Vice President - Operations

River Bend Station

Entergy Operations, Inc.

P.O. Box 220

St. Francisville, Louisiana 70775

SUBJECT: NRC INSPECTION NO. 50-458/02-05; PRELIMINARY YELLOW FINDING

Dear Mr. Hinnenkamp:

On March 20, 2002, the NRC completed an inspection at your River Bend Station. The

enclosed report presents the results of that inspection which were discussed with Mr. D. Mims,

General Manager - Plant Operations, during a telephonic conference on March 20, 2002.

The inspection examined activities conducted under your license as they relate to safety and

compliance with the Commissions rules and regulations and with the conditions of your license.

The inspector reviewed implementation of the onsite emergency preparedness program,

selected documents and procedures, observed facilities, and interviewed personnel.

This report discusses a finding that was preliminarily determined to have substantial safety

significance. As described in Section 1EP4.1 of this report, the finding involves the failure to

meet the requirements of 10 CFR 50.54(q), the failure to meet emergency planning standards

10 CFR 50.47(b)(10) and 10 CFR 50.47(b)(7), and the failure to meet the requirements of 10 CFR Part 50, Appendix E, section IV(G), in that: (1) a range of protective actions were not

developed and maintained for members of the public who routinely used facilities located in the

River Bend Station owner controlled area, (2) emergency response information was not

periodically made available to members of the public who routinely used facilities located in the

River Bend Station owner controlled area, and (3) the River Bend Station emergency plan was

not reviewed and updated as members of the public were given access to facilities located in

the owner controlled area. This finding was assessed using the Emergency Preparedness

Significance Determination Process (SDP) and was preliminarily determined to have a

significance of Yellow. Yellow findings have a substantial importance to safety and may require

additional NRC inspection.

The finding also appears to involve three apparent violations of 10 CFR 50.54(q) involving

10 CFR 50.47(b)(10), 10 CFR 50.47(b)(7), and 10 CFR Part 50, Appendix E, section IV(G), and

is being considered for escalated enforcement action in accordance with the General

Statement of Policy and Procedure for NRC Enforcement Actions (Enforcement Policy),

Entergy Operations, Inc. -2-

NUREG-1600. The current Enforcement Policy is available on the NRCs website at

www.nrc.gov/what-we-do/regulatory/enforcement.html.

Before the NRC makes a final decision on this matter, we are providing you an opportunity to

request a Regulatory Conference where you would be able to provide your perspectives on the

significance of the finding, the basis for your position, and whether you agree with the apparent

violations. If you choose to request a Regulatory Conference, we encourage you to submit your

evaluation and any differences with the NRC evaluation at least one week prior to the

conference in an effort to make the conference more efficient and effective. If a Regulatory

Conference is held, it will be open for public observation. The NRC will also issue a press

release to announce the Regulatory Conference.

Please contact Ms. Gail M. Good, Chief, Plant Support Branch, at (817) 860-8215 within 7 days

of the date of this letter to notify the NRC of your intentions. If we have not heard from you

within 10 days, we will continue with our significance determination and enforcement decision

and you will be advised by separate correspondence of the results of our deliberations on this

matter.

Since the NRC has not made a final determination in this matter, no Notice of Violation is being

issued for this inspection finding at this time. In addition, please be advised that the number

and characterization of apparent violations described in the enclosed inspection report may

change as a result of further NRC review.

In accordance with 10 CFR 2.790 of the NRCs Rules of Practice, a copy of this letter and its

enclosures will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of NRCs document

system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-

rm/ADAMS.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Arthur T. Howell lll, Director

Division of Reactor Safety

Docket: 50-458

License: NPF-47

Enclosure: Inspection Report 50-458/02-05

cc w/enclosure:

Executive Vice President and

Chief Operating Officer

Entergy Operations, Inc.

P.O. Box 31995

Jackson, Mississippi 39286-1995

Entergy Operations, Inc. -3-

Vice President

Operations Support

Entergy Operations, Inc.

P.O. Box 31995

Jackson, Mississippi 39286-1995

General Manager

Plant Operations

River Bend Station

Entergy Operations, Inc.

P.O. Box 220

St. Francisville, Louisiana 70775

Director - Nuclear Safety

River Bend Station

Entergy Operations, Inc.

P.O. Box 220

St. Francisville, Louisiana 70775

Wise, Carter, Child & Caraway

P.O. Box 651

Jackson, Mississippi 39205

Mark J. Wetterhahn, Esq.

Winston & Strawn

1401 L Street, N.W.

Washington, DC 20005-3502

Manager - Licensing

River Bend Station

Entergy Operations, Inc.

P.O. Box 220

St. Francisville, Louisiana 70775

The Honorable Richard P. Ieyoub

Attorney General

Department of Justice

State of Louisiana

P.O. Box 94005

Baton Rouge, Louisiana 70804-9005

H. Anne Plettinger

3456 Villa Rose Drive

Baton Rouge, Louisiana 70806

Entergy Operations, Inc. -4-

President

West Feliciana Parish Police Jury

P.O. Box 1921

St. Francisville, Louisiana 70775

Michael E. Henry, State Liaison Officer

Department of Environmental Quality

P.O. Box 82135

Baton Rouge, Louisiana 70884-2135

Brian Almon

Public Utility Commission

William B. Travis Building

P.O. Box 13326

1701 North Congress Avenue

Austin, Texas 78701-3326

Training, Exercises, & Evaluation Branch Chief

FEMA Region VI

800 North Loop 288

Federal Regional Center

Denton, Texas 76201-3698

-5-

Electronic distribution by RIV:

Regional Administrator (EWM) D:ACES (GFS)

Deputy Regional Administrator (TPG) ACES (RXW)

DRP Director (KEB) Regional Counsel (KDS1)

DRS Director (ATH) Public Information Officer (BWH)

Deputy DRP Director (EEC) D. Powers (DAP)

Branch Chief, DRP/B (DNG) Project Manager, NRR (DJW1)

Branch Chief, DRS/PSB (GMG) Jennifer Dixon-Herrity, OE (JLD)

Staff Chief, DRP/TSS (PHH) Scott Morris, OEDO (SAM1)

Senior Resident Inspector (PJA) Regional State Liaison Officer (WAM)

Senior Project Engineer, DRP/B (RAK1) RITS Coordinator (NBH)

RBS Site Secretary (LGD) NRR Event Tracking System (IPAS)

Section Chief, NRR IRSB, EP/HP (KHG) IRSB, EP/HP (REM2)

Electronic distribution from ADAMS by RIV:

ADAMS (PARS)

RIDSSECYMAILCENTER

RIDSOCAMAILCENTER

RIDSEDOMAILCENTER

RIDSOEMAILCENTER

RIDSOGCMAILCENTER

RIDSNRROD

RIDSNRRADIP

RIDSOPAMAIL

RIDSOIMAILCENTER

RIDSOIGMAILCENTER

RIDSOCFOMAILCENTER

RIDSRGN1MAILCENTER

RIDSRGN2MAILCENTER

RIDSRGN3MAILCENTER

OEWEB

DOCUMENT NAME: R:\_RB\2002\RB2002-05RP-PJE.wpd

RIV:DRS/PSB PSB C:PSB C:DRP\B ORA/ACES

PJElkmann:nh * RELantz * GMGood * DNGraves * GFSanborn *

/RA/ /RA/ /RA/ /RA/ /RA/

4 / 9 /02 4 / 9 /02 4 / 9 /02 4 / 10 /02 4 / 11 /02

D:DRS

ATHowell lll

/RA/

4 / 18 /02

OFFICIAL RECORD COPY ( * previously concurred) T=Telephone E=E-mail F=Fax

ENCLOSURE

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-458

License No.: NPF-47

Report No.: 50-458/02-05

Licensee: Entergy Operations, Inc.

Facility: River Bend Station

Location: 5485 U.S. Highway 61, St. Francisville, Louisiana

Dates: January 28 through March 20, 2002

Inspector: Paul J. Elkmann, Emergency Preparedness Inspector

Approved: Gail M. Good, Chief, Plant Support Branch

Division of Reactor Safety

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SUMMARY OF FINDINGS

River Bend Station

NRC Inspection Report 50-458/02-05

IR05000458-02-05, on 1/28-2/01/2002 (onsite) and 2/4 through 3/20/2002 (in-office), Entergy

Operations, River Bend Station. Emergency Action Level and Emergency Plan changes.

The inspection was conducted by a regional emergency preparedness inspector. This

inspection identified one preliminary finding, and three apparent violations associated with this

finding. The significance of the finding is still being determined but has preliminarily been

assessed as Yellow. The significance of issues is indicated by its color (Green, White, Yellow,

Red) using IMC0609, Significance Determination Process (SDP). Findings for which the SDP

does not apply are indicated by No Color or by the severity level of the applicable violation.

The NRCs program for overseeing the safe operation of commercial nuclear power reactors is

described at its Reactor Oversight Process website at

http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/index.html.

Inspector Identified Findings

Cornerstone: Emergency Preparedness

C TBD. The inspector identified one preliminary finding involving the failure to develop a

range of protective actions, disseminate emergency response information, and maintain

the emergency plan in accordance with the requirements of 10 CFR 50.54(q), planning

standards §50.47(b)(10) and (7), and 10 CFR Part 50, Appendix E, section IV(G)

pertaining to members of the public located in the owner controlled area. Three

apparent violations are associated with the finding. The issues involved: (1) a failure to

establish effective means or provisions for warning, advising, evacuating, and

monitoring members of the public during an owner controlled area evacuation, (2) a

failure to disseminate emergency response information to the public using facilities in

the River Bend Station owner controlled area, and (3) a failure to update the emergency

plan and procedures after the public was permitted access to facilities in the owner

controlled area. The licensee has entered these issues into its corrective action

program in CR-RBS-2001-1713 and CR-RBS-2002-0183.

This issue was preliminarily determined to have substantial safety significance (Yellow)

because it represented a failure to meet a risk-significant emergency preparedness

planning standard (Section 1EP4.1).

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Report Details

1. REACTOR SAFETY

Cornerstone: Emergency Preparedness (EP)

1EP4 Emergency Action Level and Emergency Plan Changes (71114.04)

.1 Owner Controlled Area Evacuation

a. Inspection Scope

The inspector reviewed the licensees emergency plan, selected documents, and

procedures related to the evacuation of the owner controlled area against the

requirements of 10 CFR 50.54(q), 10 CFR 50.47(b), and 10 CFR Part 50, Appendix E,

and the planning standard evaluation criteria contained in NUREG-0654, Criteria for

Preparation and Evaluation of Radiological Emergency Response Plans and

Preparedness in Support of Nuclear Power Plants, Revision 1, to verify that the

licensee continued to meet planning standards 50.47(b)(10) and 50.47(b)(7) and

requirements in Appendix E.

The inspector also toured the following areas of the licensees owner controlled area to

which the public had been given access: the West Feliciana Community Development

Foundation; the security firing range; the activity center; the outage recreational vehicle

(RV) campground; the Sportsmans Association base camp; the primary, back-up, and

alternate assembly areas; and the river access road which provided the primary hunting

and fishing access in the owner controlled area.

The inspector interviewed licensee personnel, including members of the emergency

preparedness staff, key emergency response organization members, security

management and officers, and the administrative staff responsible for scheduling at the

activity center and RV campground, to determine if there was an effective means to

warn and evacuate members of the public in the owner controlled area. The inspector

also interviewed three members of the public located within the owner controlled area to

determine their level of knowledge concerning the methods for notification, evacuation,

and monitoring that would be used in an emergency.

For background, between 1985 and January 2002, members of the public were given

access to the following areas in the licensee owner controlled area: the West Feliciana

Community Development Foundation; the security firing range; the activity center; the

outage RV campground; the Sportsmans Association base camp; and the river access

road which provided the primary access for hunting and fishing in the owner controlled

area. This access continued through January 2002. Based on information provided by

the licensee, the daily capacities of the individual locations routinely used by the public

varied between 12 and 200 persons, and the total number of members of the public who

could have been present on any given day, had all of these locations been in

simultaneous use, was between 300 and 400 persons. Actual usage of the facilities

varied greatly during the year based on the change of seasons, special events, and

conduct of meetings outside normally scheduled times. All of the above facilities were

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actively used by members of the public during the time frame above. Offsite audible

sirens activated at a general emergency classification to warn the emergency planning

zone may be heard in portions of the owner controlled area but are not described in the

licensees emergency plan and implementing procedures as a method for warning

occupants of an owner controlled area evacuation.

b. Findings

One finding was identified with potentially substantial safety significance (Yellow)

involving: (1) a failure to establish effective means or provisions for warning, advising,

evacuating, and monitoring members of the public during an owner controlled area

evacuation, (2) a failure to disseminate emergency response information to the public

using facilities in the River Bend Station owner controlled area, and (3) a failure to

update the emergency plan and procedures after the public was permitted access to

facilities in the owner controlled area. This finding also constitutes apparent violations of

10 CFR 50.54(q), 10 CFR 50.47(b)(10), 10 CFR 50.47(b)(7), and 10 CFR Part 50

Appendix E, IV(G).

The inspector determined that between 1985 and January 2002 the licensee failed to

develop a range of protective actions for members of the public: (1) working at the

West Feliciana Community Development Foundation; (2) using the security firing range,

the activity center, the outage RV campground, and the Sportsmans Association base

camp; and (3) hunting and fishing in the owner controlled area as required by 10 CFR

50.54(q) and 50.47(b)(10). Also, the licensee did not provide, on a periodic basis,

information to members of the public routinely using facilities in the River Bend Station

owner controlled area which described the process used to warn occupants of an owner

controlled area evacuation, the designated evacuation assembly areas, the evacuation

route(s) used to travel to the evacuation assembly areas, the radiological monitoring and

decontamination process, and other protective measures such as sheltering, respiratory

protection, and radioprotective drugs as required by 10 CFR 50.54(q) and 50.47(b)(7).

Additionally, the licensee did not effectively implement provisions that ensured the

emergency plan and its implementing procedures were maintained up to date as

changes were made to the station and its owner controlled area as required by 10 CFR

50.54(q) and 10 CFR Part 50, Appendix E IV(G).

The Statements of Consideration for 10 CFR 50.47, 50.54, and Part 50, Appendix E

(45 FR 55402, August 19, 1980, Emergency Planning) state, in part, that: ...two

guidance documents were published for public comment and interim use. These are

NUREG-0610... and NUREG-0654/FEMA-REP-1... It is expected that versions of these

documents, revised on the basis of public comments received, will be issued to assist in

defining acceptable levels of preparedness to meet this final regulation. NUREG-0654,

Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and

Preparedness in Support of Nuclear Power Plants, Revision 1, provides planning bases

for licensees and offsite authorities, and contains guidance for implementing planning

standards.Section I.H, Nuclear Facility Licensee Response Organization, states, in

part, ...licensees of nuclear facilities have a primary responsibility for planning and

implementing emergency measures within their site boundaries. These emergency

measures include...protective measures and aid for persons onsite.

-5-

A. Criteria for implementing §47(b)(10) are found in NUREG-0654 Planning

Standard J, Protective Response. The following four evaluation criteria from

Planning Standard J did not appear to be developed and incorporated into the

licensees emergency plan:

1. Evaluation Criterion 1 states, in part, Each licensee shall establish the

means and time required to warn or advise onsite individuals who may be

in areas controlled by the operator, including . . . (b) visitors . . . (d) other

persons who may be in the public access areas on or passing through

the site or within the owner controlled area. The NRC determined that

this evaluation criterion was not met because:

a. The licensees emergency plan and procedures relied on security

personnel to warn and advise personnel in the owner controlled

area. These security sweeps would not have been completely

effective for members of the public because:

i. Licensee procedures and bulletins contained partial

listings of outlying plant buildings and did not include all

the locations routinely occupied by the public. Security

management interviewed in January 2002 stated that

security officers would sweep along the river access road

but would not sweep off-road fishing locations.

ii. Five security officers, responsible for performing owner

controlled area evacuation sweeps, who were interviewed

in December 2001, described processes for warning

station employees but did not discuss any actions to warn

members of the public of an evacuation.

iii. Station procedures did not specify how an evacuation

message was to be delivered by security officers. The

expectation that security officers stop at outdoor areas and

remain stationary while delivering an evacuation message

was not written in procedures, security bulletins, or training

lesson plans.

iv. The skills required of the security coordinator and security

shift supervisor included coordination of the evacuation of

personnel from the owner controlled area but did not

include warning or evacuating the public. Lesson plans for

security officers specifically discussed the evacuation of

River Bend Station employees during an owner controlled

area evacuation but did not discuss evacuation of the

public. As described during interviews with emergency

response organization members and used in lesson plans,

personnel was understood to mean licensee staff and

contractors.

-6-

v. The skills required of key emergency response

organization members described in Emergency Plan

Appendix A, did not include performing an owner

controlled area evacuation, and these responders were not

trained on methods for the evacuation of the owner

controlled area.

vi. There were no emergency response functions listed in

Emergency Plan Appendix A for security officers. Lesson

plan Advanced Security Skills, Section D,

Responsibilities During Emergencies, did not include an

owner controlled area evacuation among seven listed

security responsibilities.

vii. The security shift supervisor and security officers did not

demonstrate essential skills related to an owner controlled

area evacuation through the annual protected area

evacuation, because the protected area evacuation did not

demonstrate elements such as: (1) obtaining sufficient

security officers to accomplish simultaneous security

emergency tasks, (2) developing and communicating

routing instructions for the security officer assigned to

security sweeps, (3) developing and briefing the

evacuation message for evacuees, (4) providing

appropriate radiological protection and briefings for the

security officer assigned to the security sweep, and (5)

simultaneously managing multiple security priorities and

officers.

viii. River Bend Station did not test or validate the process for

performing an owner controlled area evacuation prior to

January 2002.

b. Licensee procedures and training lesson plans did not contain a

specific time requirement for completing the warning or

notification of an owner controlled area evacuation. Based on the

text of Section 13.3.5.4.1.1.4 of the Emergency Plan (Evacuation

Times) states, in part: The estimated elapsed times, measured

from the time of initial warning to persons required to evacuate

identified areas of the site are as follows...(3) owner controlled

area evacuation (30 to 60 minutes). This section discusses the

time for evacuation without reference to the time permitted for the

warning to occur.

c. Prior to January 2002, loudspeaker equipment used by security

personnel during owner controlled area evacuations was not part

of a defined maintenance program. The inspector was unable to

determine the functionality of the loudspeakers prior to January

2002 due to the lack of maintenance and testing records.

-7-

2. Evaluation Criterion 2 states, in part, Each licensee shall make

provisions for evacuation routes and transportation for onsite individuals

to some suitable offsite location. The NRC determined that this

evaluation criterion was not met because:

a. Procedures did not establish the emergency response

organization position responsible for developing evacuation

instructions pertaining to evacuation routing and transportation for

evacuees outside the protected area. During inspection

interviews, personnel assigned to the technical support center did

not describe having this responsibility when asked to describe

their duties in carrying out an owner controlled area evacuation.

b. Procedural direction did not ensure that evacuation instructions

and evacuation routing messages were developed for each area

of the owner controlled area where members of the public could

be located.

3. Evaluation Criterion 3 states, Each licensee shall provide for radiological

monitoring of people evacuated from the site. Criterion 4 states, Each

licensee shall provide for the evacuation of onsite nonessential personnel

in the event of a Site or General Emergency and shall provide a

decontamination capability at or near the monitoring point specified in

J.3. The NRC determined that these evaluation criteria were not met

because:

a. Members of the public using the security firing range, the activity

center, the outage RV campground, and the Sportsmans

Association base camp, were not informed that they would be

monitored as part of an evacuation under adverse radiological

conditions. Public information brochures were not made available

at these locations. Brochures sent to the West Feliciana

Community Development Foundation did not address radiological

monitoring for persons in the owner controlled area.

b. Members of the public using facilities in the owner controlled area

were neither provided advance information about radiological

monitoring locations nor were they provided directions or maps.

Brochures sent to the West Feliciana Community Development

Foundation did not address radiological monitoring locations for

persons in the owner controlled area.

c. The primary and back-up evacuation assembly areas were each

provided with one decontamination shower and limited

decontamination supplies. A pre-positioned decontamination

capability was not available at the alternate assembly area, and

licensee procedures did not require that radiological monitoring

and decontamination equipment or supplies be dispatched to the

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alternate assembly area when it was used. This limited

decontamination capability, especially at the alternate assembly

area, would have caused significant delays in performing

decontamination and monitoring for events which resulted in more

than minor amounts of contamination.

10 CFR 50.54(q) requires, in part, A licensee authorized to possess and

operate a nuclear power reactor shall follow and maintain in effect emergency

plans which meet the standards in §50.47(b) and the requirements of Appendix

E of this part. 10 CFR 50.47(b)(10) requires, in part, A range of protective

actions have been developed for the plume exposure pathway EPZ for

emergency workers and the public. The failure to develop a range of protective

actions for members of the public using facilities located in the River Bend

Station owner controlled area is an apparent violation of 10 CFR 50.54(q) and

50.47(b)(10).

The apparent violation has a credible impact on safety because of the potential

to expose members of the public to radiation and/or radioactive material in the

event of an emergency if they are not provided with the appropriate protective

actions. The apparent violation was assessed through the Failure to Meet

Regulatory Requirement branch of the Emergency Preparedness Significance

Determination Process because it was an apparent violation of the regulatory

requirements of 10 CFR 50.54(q). The finding was preliminarily determined to

have substantial safety significance (Yellow) because it represented a failure to

meet a risk-significant emergency preparedness planning standard as defined by

NRC Inspection Manual Chapter (MC) 0609, Appendix B §2.a. The licensee has

entered this issue into its corrective action program as part of CR-RBS-2001-

1713 (AV 458/0205-01).

B. The criteria for implementing 10 CFR 50.47(b)(7) are found in NUREG-0654

Planning Standard G, Public Education and Information. The following

evaluation criteria from this planning standard were not developed and

incorporated into the licensees emergency plan:

1. Criterion 1 states, in part, Each organization shall provide a coordinated

(at least annually) dissemination of information to the public regarding

how they will be notified and what their actions should be in an

emergency. This information shall include, but not necessarily be limited

to...(c) protective measures; e.g., evacuation routes and relocation

centers, sheltering, respiratory protection, radioprotective drugs... The

NRC determined that this evaluation criterion was not met because:

a. Public information signs regarding an owner controlled area

evacuation were not posted at any of the locations in the owner

controlled area to which the public had routine access prior to

December 2001.

b. Between 1985 and 2001, written rules and material provided to

users of the activity center and outage RV campground did not

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contain: (1) basic radiological information, (2) information about

the notification process for owner controlled area evacuation, (3)

information about protective measures, such as onsite evacuation

routes and relocation centers, sheltering, and respiratory

protection, or (4) information about radioprotective drugs. Also,

information was not provided about the radiological monitoring

and decontamination process.

c. Basic radiological information, information about the notification

process for an owner controlled area evacuation, and information

about protective measures, such as onsite evacuation routes and

relocation centers, sheltering, respiratory protection, or

radioprotective drugs, were neither provided to members of the

Parish Sheriffs Department training at the security firing range

between 1992 and 2001 nor to members of the Sportsmans

Association hunting and fishing in the owner controlled area

between 1990 and 2001.

d. The public information brochure sent to the West Feliciana

Community Development Foundation between October 1999 and

December 2001 did not describe the notification process for an

owner controlled area evacuation and did not include information

about onsite protective measures, such as onsite evacuation

routes, relocation centers, and sheltering.

10 CFR 50.54(q) requires, in part, A licensee authorized to possess and

operate a nuclear power reactor shall follow and maintain in effect emergency

plans which meet the standards in §50.47(b) and the requirements of Appendix

E of this part. 10 CFR 50.47(b)(7) requires, in part, Information is made

available to the public on a periodic basis on how they will be notified and what

their initial actions should be in an emergency. The failure to periodically make

information available to the public about how they will be notified during an

emergency and what their initial actions should be, is an apparent violation of 10 CFR 50.54(q) and 50.47(b)(7).

The apparent violation has a credible impact on safety because of the potential

to expose members of the public to radiation and/or radioactive material in the

event of an emergency if they are not provided with appropriate information

about how they will be warned and advised during an emergency and what their

actions should be. The apparent violation was assessed through the Failure to

Meet Regulatory Requirement branch of the Emergency Preparedness

Significance Determination Process because it was an apparent violation of the

regulatory requirements of 10 CFR 50.54(q). The finding was preliminarily

determined to represent a failure to meet an emergency preparedness planning

standard as defined by MC 0609, Appendix B §2.a. The licensee has entered

this issue into its corrective action program as part of CR-RBS-2001-1713

(AV 458/0205-01).

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C. The NRC concluded that the licensee did not effectively implement provisions

that ensured the emergency plan and its implementing procedures were

maintained up to date as changes were made to the station and its owner

controlled area. Specifically, the public use of the West Feliciana Community

Development Foundation, the security firing range, the activity center, the outage

RV campground, and the Sportsman Association, and, more generally, public

bow hunting and fishing within the owner controlled area, were not evaluated for

their effect on station emergency preparedness as each use was established or

permitted.

10 CFR 50.54(q) requires, in part, A licensee authorized to possess and

operate a nuclear power reactor shall follow and maintain in effect emergency

plans which meet the standards in §50.47(b) and the requirements of Appendix

E of this part. 10 CFR Part 50, Appendix E, section IV(G), requires, Provisions

to be employed to ensure that the emergency plan, its implementing procedures,

and emergency equipment and supplies are maintained up to date shall be

described. The failure to maintain the River Bend Station Emergency Plan and

implementing procedures up to date following the establishment of facilities in

the owner controlled area which were routinely used by members of the public is

an apparent violation of 10 CFR 50.54(q).

This apparent violation has a credible impact on safety because of the potential

for risk significant and other important emergency preparedness program

elements, such as emergency classification, notification of emergencies to offsite

authorities and the public, and protective action decision-making, to degrade if

changes to the plant and its environs are not adequately reviewed for their

impact on emergency preparedness. The finding was assessed through the

Failure to Meet Regulatory Requirement branch of the Emergency

Preparedness Significance Determination Process because it was an apparent

violation of the regulatory requirements of 10 CFR 50.54(q). The finding was

preliminarily determined to not represent a failure to meet an emergency

preparedness planning standard as defined by MC 0609, Appendix B §2.a. The

licensee has entered this issue into its corrective action program in CR-RBS-

2002-0183 (AV 458/0205-01).

Because the NRC has preliminarily determined that 3 apparent violations occurred, as

previously discussed, Unresolved Item 50-485/0104-02 is closed.

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.2 Review of Emergency Plan Changes

a. Inspection Scope

The inspector reviewed Revision 24 to the River Bend Station Emergency Plan,

submitted November 1, 2001, against the previous revision of the emergency plan and

against the requirements of 10 CFR 50.54(q) to determine if the revision decreased the

effectiveness of the plan.

b. Findings

No findings of significance were identified.

4. OTHER ACTIVITIES (OA)

4OA1 Performance Indicator Verification (71151)

.1 Drill and Exercise Performance

a. Inspection Scope

The inspector reviewed the following information and documents related to the drill and

exercise performance (DEP) indicator against the requirements of NEI 99-02,

Regulatory Assessment Performance Indicator Guidelines, Revisions 0 and 1, in order

to verify the accuracy of the licensees reported data for the second through fourth

quarters of calendar year 2001. The inspector reviewed data for 100 percent of the

drills included in the DEP statistics during this period.

Drill schedules for calendar year 2001

Evaluation reports for drills included in DEP statistics

Drill scenarios for drills included in DEP statistics

Drill-related offsite notification forms, participant logs, checklists, and documents

Drill evaluation worksheets

Drill evaluation records

Performance indicator summary sheets

Performance indicator reports

b. Findings

No findings of significance were identified.

.2 Emergency Response Organization Drill Participation

a. Inspection Scope

The inspector reviewed the following records related to emergency response

organization participation against the requirements of NEI 99-02, Regulatory

Assessment Performance Indicator Guidelines, Revisions 0 and 1, in order to verify the

accuracy of the licensees reported data for the second through fourth quarters of

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calendar year 2001. The inspector verified drill participation data for a sample of six

emergency responders to verify the accuracy of the licensees tracking database.

Emergency response organization rosters for the second through fourth quarters

of Calendar Year 2001

Quarterly summaries of emergency responder drill participation dates over the

previous eight quarters, including a review of the participation dates in each

quarter for 100 percent of the key emergency response organization positions

List of key emergency response organization positions

Performance indicator summary sheets

Performance indicator reports

b. Findings

No findings of significance were identified.

.3 Alert and Notification System

a. Inspection Scope

The inspector reviewed siren testing records against the requirements of NEI 99-02,

Regulatory Assessment Performance Indicator Guidelines, Revisions 0 and 1, in order

to verify the accuracy of the licensees reported data for the second through fourth

quarters of calendar year 2001. The inspector also reviewed a sample of 12 siren

trouble tickets to verify the licensees characterization of siren problems and failures

against the requirements of EPP-2-701, Prompt Notification System Maintenance and

Testing, Revision 14.

b. Findings

No findings of significance were identified.

4OA6 Management Meetings

Exit Meeting Summary

The inspector presented the inspection results to Mr. D. Mims, General Manager - Plant

Operations, and other members of licensee management during a telephone

conference call on March 20, 2002. The licensee acknowledged the findings presented.

The inspector asked the licensee whether any materials examined during the inspection

should be considered proprietary. No proprietary information was identified.

KEY POINTS OF CONTACT

Licensee

B. Allen, Manager, Emergency Planning

M. Bakarich, Superintendent, Security

P. Hinnenkamp, Vice President, Operations

A. James, Supervisor, Security Operations

R. King, Director, Nuclear Safety Assurance

M. Krupa, Director, Licensing, Echelon

J. Leavines, Manager, Nuclear Safety and Regulatory Affairs

J. McGaha, President, EOI

D. Mims, General Manager - Plant Operations

J. Thayer, Vice President, Operations, Echelon

Other

P. Campbell, Winston & Strawn

NRC

A. Howell, Director, Division of Reactor Safety (DRS)

G. Good, Chief, Plant Support Branch, DRS

D. Powers, Senior Technical Analyst, DRS

R. Lantz, Senior Emergency Preparedness Inspector, DRS

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

50-458/0205-01 AV Preliminary finding based on apparent violations of

50.54(q), emergency planning standards 50.47(b)(10) and

(7), and Appendix E, section IV(G)

Closed

50-458/0104-02 URI Adequacy of procedures to notify members of the general

public who routinely occupy facilities within the OCA of an

OCA evacuation

DOCUMENTS REVIEWED

The following documents were selected and reviewed by the inspector to accomplish the

objectives and scope of the inspection and to support the findings:

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Plant Procedures:

AD-101, Nuclear Management Manual Process, Revision 7

EIP-2-001, Classification of Emergencies, Revision 11

EIP-2-002, Classification Actions, Revision 21

EIP-2-007, Protective Action Recommendation Guidelines, Revision 18

EIP-2-018, Technical Support Center, Revision 23

EIP-2-020, Emergency Operations Facility, Revision 23

EIP-2-024, Offsite Dose Calculations, Revision 18

EIP-2-102, Training, Drills, and Exercises, Revisions 21 & 22

EPP-2-703, Performance Indicators, Revision 1

SPI-30, Security Motor Patrol, Revision 18

SPI-32, Gate 5 (Industrial Area), Revision 5

TQ-110, Emergency Preparedness Training Program, Revision 0

ML022810670

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