ML17292B437

Forwards Response to Violations Noted in Insp Rept 50-397/98-14.Corrective Actions:Individuals Involved in Emergency Plan Rev Process Counseled Re Need to Ensure Emergency Plan Meets Requirements of 10CFR50 App E

ML17292B437
Person / Time
Site:	Columbia
Issue date:	08/27/1998
From:	Webring R WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-397-98-14, GO2-98-154, NUDOCS 9809020246
Download: ML17292B437 (6)

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'I ACCESSION NBR:9809020246 DOC.DATE: 98/08/27 NOTARIZED: NO DOCKET ¹ FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME, AUTHOR AFFILIATION BRING,R.L. Washington Public Power Supply System RECIP.'NAME 'ECIPIENT AFFILIATION Records Management Branch (Document Control Desk)

SUBJECT:

Forwards response to violations noted in insp rept 50-397/98-14.Corrective actions:individuals involved in emergency plan rev process counseled re need to ensure emergency plan meets recpxirements of 10CFR50 App E.

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ( ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation R sponse

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NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL

'D4-2 PD 1 1 POSLUSNY,C 1' INTERNAL: ACRS 2 2 AEOD/SPD/RAB 1 '1 AEOD/~ 1 1 DEDRO 1 1 E 1 1 NRR/DRCH/HOHB 1 3.

RR DRPM PECB 1 1 NRR/DRPM/PERB 1 1 NUDOCS-ABSTRACT 1 1 OE DXR 1 1 OGC/HDS3 1 '

RGN4 FILE 01 1 1 RNAL: LITCO BRYCE,J H NRC PDR 1

1 1

1 NOAC NUDOCS FULLTEXT 1,

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NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROZ DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL 19

4 WASHINGTON PUBLIC POWER SUPPLY SYSTEM PO. Box 968 ~ Richlattri, Washington 99352-0968 August 27, 1998 G02-98-154 Docket No. 50-397 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

Subject:

WNP-2 OPERATING LICENSE NPF-21 NRC INSPECTION REPORT 98-14, RESPONSE TO NOTICE OF VIOLATION

Reference:

Letter, dated July 31, 1998, B Murray (NRC) to JV Parrish (SS), "NRC Inspection Report 50-397/98-14 and Notice of Violation" The Supply. System's response to the Notice of Violation, pursuant to the provisions of Section 2.201, Title 10, Code of Federal Regulations, is enclosed as Attachment A.

Additionally, as requested in the cover letter our response to the performance weakness identified during walk-throughs in the simulator is enclosed as Attachment B.

Should you have any'questions or desire additional information regarding this matter, please call Mr. PJ Inserra at (509) 377-4147.

Respectfully, RL Webring Vice President, Operations Support/PIO Mail Drop PE08 Attachments cc: EW Merschoff - NRC RIV NRC Sr. Resident Inspector - 927N DF Kirsch - NRC RIV, WCFO DL Williams - BPA/1399 C Poslusny, Jr. - NRR PD Robinson - Winston & Strawn 9809020246 980827 PDR ADQCK OS000397 8 PDR

INSPECTION REPORT 50-397/98-14 RESPONSE TO NOTICE OF VIOLATION Appendix A Page 1 of 2 RESTATEMENT OF VIOLATION 10 CFR 50.54(q) requires licensees to follow and maintain in effect emergency plans which meet the standards in 50.47(b) and the requirements in Part 50, Appendix E. 10 CFR 50.54 also permits licensees to make changes to emergency plans without prior Commission approval only if the changes do not decrease the effectiveness of the plan.

Appendix E, Paragraph IV.F.1, requires that emergency plans include a description of specialized initial training and periodic retraining programs provided to certain categories of emergency personnel including directors; personnel who perform accident assessment, radiological monitoring te'ams, etc.

Contrary to the above, on July 13, 1998, the licensee made changes to its emergency plan, without Commission approval, that decreased the effectiveness of the emergency plan.

Specifically, initial training requirements were reduced from formal classroom instruction, written examination, and hands-on training where appropriate to formal classroom instruction, written examination, or hands-on training.

And, on July 1998, it was determined that the licensee's emergency plan did not describe the initial and retraining programs. The emergency plan stated that course assignments for members of the emergency organization may be found in emergency plan implementing procedures. The course, assignments were not found in implementing procedures, and retraining courses were only identified in a computer database.

This is a Severity Level IV violation (Supplement VIII) (50-397/98-14-01)

R P N ET VI LATION The Supply System accepts the violation.

REAS NS FOR VIOLATION The'upply System agrees with the staff's characterization of the reason for this event given in

'he Report Details section of Inspection Report 50-397/98-14.

The root cause was determined to be'a work practice issue. Specifically, changes to the Emergency Plan were made that changed an "and" statement to an "or" statement concerning the description of the initial emergency training program requirements for essential personnel.

Although the actual training was not changed, this could lead to a misunderstanding of the requirements by future users of the Emergency Plan.

e INSPECTION REPORT 50-397/98-14 RESPONSE TO NOTICE OF VIOLATION Appendix A Page 2 of 2 The change was made in an attempt to clarify the wording in the Emergency Plan. The "or" statement implies that Emergency Preparedness (EP) initial training could consist of only hands-on training with performance evaluation. The change inadvertently created an alternative to formal classroom training with written examinations. The intent was to change the "and" to a stand alone statement and indicate that hands on training with performance evaluation sign off by an instructor could be used, where appropriate, in addition to required formal classroom training. It was also intended to mean that a performance evaluation could be used rather than a written examination to determine mastery of a task.

The lack of a detailed training program description in the Emergency Plan and corresponding procedures was identified in the, inspection and resulted as a carryover of previous Emergency Plan revisions, Traditionally, the EP Training Course Catalog, and more recently, the Personnel Qualification Directory have been used to identify and track training qualification requirements for emergency response personnel. The brief description of the training program for emergency responders in the Emergency Plan had previously been deemed satisfactory as a program description. However, more detail is necessary to satisfy the requirements of 10 CFR 50

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Appendix E, A Problem Evaluation Request was initiated to address these issues.

ORRECTIVE ACTI NS TAKEN AND RESULTS ACHIEVED Upon identification of the issue, the EP personnel involved in preparing and reviewing revision 20 of the Emergency Plan were counseled on the importance of providing thorough reviews and properly identifying changes that could reduce the effectiveness of the Emergency Plan.

In addition, individuals involved in the Emergency Plan revision process were counseled regarding the need to ensure the Emergency Plan meets the requirements of 10 CFR 50 Appendix E for content and level of detail.

ORRECTIVE TEPS T BE TAKEN T AV ID F RE VIOLATIONS The appropriate section of the Emergency Plan will be'revised to remove the "or" statement and replace it with an "and" as originally written in revision 19.

In addition, the Emergency Plan revision will also include a more detailed training program description as required by 10 CFR 50 Appendix E.

DATE F FULL C MPLIANCE The revision to the Emergency Plan will be submitted for Plant Operations Committee and Plant.

General Manager approval by September 30, 1998.

RESPONSE TO INSPECTION FOLLOW-UP ITEM 50-397/98-14-02 Appendix B Page 1 of 1 RESTATEMENT OF F LLOW-UP ITEM Crew performance during the walkthroughs [in the simulator] was mixed. The second crew observed was less rigorous in its use of Emergency Plan implementing procedures and did not perform correct dose calculations. A performance weakness was identified for failure of one of two crews to recognize that dose projections indicated a need for'protective action recommendations beyond 10 miles.

RESPONSE TO FOLLOW- P ITEM The, Supply System agrees with the characterization of the follow-up item and the need for corrective actions.

Immediate corrective actions were taken to counsel the Shift Manager and Shift Technical Advisor (STA) on the need to consider Protective Action Recommendations (PARs) beyond the 10 miles if Protective Action Guides (PAGs) could be exceeded. On July 23, 1998 additional dose projection training and evaluation was provided to the STA that had incorrectly performed dose calculations, In addition, a Problem Ev aluation Request was initiated to address the issue.

CORRE TIVE ACTI N T BE TAKEN Plant Procedure 13.2.2, Determining Protective Action Recommendations, will be revised to ensure evaluations are initiated to determine the need to notify offsite agencies of PARs beyond 10 miles if dose projections indicate PAGs at 10 miles may be exceeded.

In addition, during Operator Requalification Training, a review will be conducted of the PAGs and the need to consider PARs beyond 10 miles if the PAGs would be exceeded.

DATE OF FULL IMPLEMENTATI N Corrective actions will be completed by September 30, 1998.

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Washington Public Power Supply System ISTRIBUTION w/co of licensee's letter dated Au ust 27 1998:

bCD"(IE35)

Administrator

'egional WNP-2 Resident Inspector DRS Director DRS Deputy Director DRP Director DRP Deputy Director DRS-PSB Branch Chief (DRP/E, WCFO)

Senior Project Inspector (DRP/E, WCFO)

Branch Chief (DRP/TSS)

WCFO File MIS System RIV File DRS Action Item File (98-G-0116)(Goines)

DOCUMENT NAME: R:CWN2iWN814AK.GMG To receive co of document, indicato In box: C" ~ Co without enclosures "E" = Co with enclosures "N" ~ No co RIV:SEPAttPSB E C:DRS'tPSB 6MGood:nh BMurra 09&'98 09 98 OFFICIAL RECORD COPY