ML20044F090

Responds to Emergency Preparedness Weaknesses Documented in Insp Rept 50-382/93-08.Corrective Actions:Training Seminars on Classification Process Will Be Conducted & Training Lesson Plans for CR Emergency Response Personnel Revised

ML20044F090
Person / Time
Site:	Waterford
Issue date:	05/21/1993
From:	Burski R ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
W3F1-93-0148, W3F1-93-148, NUDOCS 9305260442
Download: ML20044F090 (5)

Text

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ie 94739??74 1 R. F. Burski

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Yi. ' 4 W3FI-93-0148 A4.05  :

PR May 21, 1993 t i

U.S. Nuclear Regulatory Commission  ;

ATTN: Document Control Desk Washington, D.C. 20555 ,

Subject:

Waterford 3 SES f Docket No. 50-382 License No. NPF-38 NRC Inspection Report 93-08 i Gentlemen:

Entergy Operations. Inc. hereby submits the responses to the emergency preparedness weaknesses documented in the subject Inspection Report. These l i

responses are attached and include analyses of the weaknesses, description of corrective measures and schedules for completing these actions as requested.

If you have any questions concerning these responses, please contact F.J. Englebracht, Emergency Planning & Administration Manager, at  ;

(504) 739-6607.

Very truly yours,  ;

j gud/1 R.F. B rski  ;

Director p500 b I Nuclear Safety RFB/GCS/ssf '

Attachment cc: J.L. Milhoan (NRC Region IV), D.L. Wigginton (NRC-NRR),

D.B. Spitzberg (NRC Region IV), R.B. McGehee, N.S. Reynolds, h j NRC Resident Inspectors Office (/  :

9305260442 930521 l, PDR ADOCK 050003B2 O PDR

Attachment to W3F1-93-0148

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ATTACHMENT I ENTERGY OPERATIONS. INC. RESPONSES TO THE EMERGENCY EXERCISE WEAKNESSES DOCUMENTED IN INSPECTION REPORT 93-0S WEAKNESS NO. 9308-01:

During the walkthroughs, the shift supervisors were effective in arriving at accurate and timely classifications with one exception. Approximately 6 minutes into a scenario, one shift supervisor declared an Alert based on a valid high radiation alarm on the containment purge monitor. The shift supervisor referenced Emergency Action Level (EAL) A/A/II in making the classification. This EAL states "A fuel handling incident resulting in a release of radioactivity to the containment or fuel handling building 2 high alarm limits". At the time the classification was made, the reactor was at full power with no fuel operations in progress. Consequently, the classification of an Alert was made using an EAL which was not applicable at the time, and without the plant having reached initiating conditions for this classification. Improper emergency classification was identified as a weakness.

RESPONSE

(1) paalvsis of the Weakness Entergy Operations, Inc. believes that the root cause of this weakness is personnel error by the shift supervisor in relating the particular indicator to its initiating condition. This weakness is not indicative of a programmatic deficiency requiring procedure i and/or Plan revisions. This assessment is supported by the fact that l the other two Shift Supervisors made the appropriate classifications l in their walkthroughs and the fact that this Shift Supervisor made other correct classifications as required. Also, when the shift  ;

supervisor who made the incorrect emergency classification was  !

informed of this error he immediately realized he had made a mistake l and that he should not have declared an alert based on Initiating Condition (IC) A/A/II.

An analysis of this weakness indicates that the shift supervisor ,

based his classification decision on procedural radiological .

monitoring indicator #3 (containment area radiation monitor high l alarm) for IC A/A/II located in procedure EP-001-001, " Recognition ,

and Classification of Emergency Conditions". The monitor reading in the procedure was in fact exceeded. Steps 5.1.2 and 5.1.3 of the -

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Attachment to W3F1-93-0146 procedura define ICs and Indicators. These steps clearly require classifications to be based on ICs and not Indicators. Indicators are "... merely assistance tools. They are not provided as the sum total of all conditions whereby a particular IC is met or exceeded".

It should be noted that the Shift Supervisor exhibited a high level of knowledge of the procedural Indicators, in that when given the radiological monitoring value, he was aware where that particular value was addressed, and immediately went to that point in the procedure.

(2) Corrective Measures Two specific corrective actions are planned:

I. Training seminars, conducted by Emergency Planning,  ;

will review this weakness with each operation shift. The seminars will emphasize the classification process, in particular the relationship between ICs and Indicators.

2. Training lesson plans for Control Room emergency response personnel will be revised to include discussion of this weakness as a lesson learned. The discussion will emphasize the relationship between ICs and Indicators in the classification process.

(3) Schedule for Completion The above corrective measures will be completed by October I, 1993 1

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Attachment to W3F1-93-0148 j WEAKNESS NO. 9308-02: ,

following the walkthroughs, the inspectors determined that the dose assessment training received by the communicators was less than that given to control room personnel. For example, the auxiliary operators -

(communicators) were not on the required reading list for EP-02-050, " Dose Assessment Computer and Nomogram". Further, EP-2-050, Rev. 11, Attachment .

7.1, specifies that the procedure should only be used initially by control i t

room personnel. The inspectors concluded that the communicators were neither fully trained on dose assessment methodology, nor were they authorized to perform dose assessments. The shift supervisors (emergency ,

coordinators) were observed to rely on the dose assessments performed by the communicators for important emergency assessments and decisions. The use of communicators who had not received all dose assessment training was identified as a weakness.

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RESPONSE

i (1) Analysis of the Weakness Entergy Operations, Inc. believes that the root cause of this ,

weakness is that the Emergency Plan and the Emergency Plan Implementing Procedures did not specify that dose assessments could be performed by Nuclear Auxiliary Operators (NA0s). Consequently; l the NA0s did not receive full training on dose assessment requirements.

In an effort to improve the ability of the Control Room communicators to generate accurate and timely meteorological data for transmission l to offsite agencies, Entergy Operations, Inc. began to emphasize the  !

use of the Control Room Personal Computer (PC) in 1992 to process raw data. By using certain features of the dose assessment program, communicators were able to rapidly and accurately ascertain stability-class, affected compass sectors and wind speed in miles per hour. Use i of the dose assessment program for this purpose was encouraged, but communicators were never trained on the full capabilities and ,

precautions relating to use of the program for performing offsite '

dose assessment calculations. Because communicators are now familiar 1 with the program and have demonstrated their ability to use its j capabilities, Shift Supervisors have exhibited a natural tendency to l have communicators assist with dose assessment functions. i l

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Attachment to W3F1-93-0148 i

(2) [grrective Measures Three specific corrective actions are planned:

1. The Emergency Plan and Emergency Plan Implementing' Procedures will be revised to indicate that NAQs may be used to perform dose assessment functions.

2. Training lesson plans and supplemental reading lists for NA0s will be revised to incorporate the appropriate training on dose assessment methodology.

3. Dose assessment training, including training on the full capabilities of the Control Room PC and use of the manual nomogram, will be provided for the NAQs.

(3) Schedule for Completion The above measures will be completed by October 1,1993.

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