ML20056B393
| ML20056B393 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 08/21/1990 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Carns N ENTERGY OPERATIONS, INC. |
| References | |
| NUDOCS 9008280228 | |
| Download: ML20056B393 (3) | |
See also: IR 05000313/1990008
Text
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In Reply. Refer:To:-
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' Dockets:' 50-313'90-08:
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250-366/90-08
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.Entergyl Operations, Inc.
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-ATTN:. Nei.1 S.=Carns,-Vice President
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-Operations,-Arkansas Nuclear One
-P.O. Box 551..
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i Little, Rock, Arkansas' 72203
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Gentlemen:
.
Thank you for your . letter of July 27, 1990, in' response to our letter
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' dated June 15,.1990. We found that the corrective measures taken and your
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proposed corrective measures effectively address the concerns identified:during'
the 1990' exercise and discussed in the July
'8, 1990, management meeting-held-
' in: Region IV. 'We will review the implementation of.your corrective actions
during a future-inspection to determine that full compliance has been achieved
.and will be maintained.
Sincerely,.
Oristnal S15 nod BY
Samuel J. Collins, Director ~
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Division' of Reactor . Projects
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cc:
Entergy Operations, Inc.
ATTN: Donald C. Hintz,. Executive Vice
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President & Chief Operating Cfficer
P.O. Box 31995
Jackson, Mississippi 39286
Entergy Operations,'Inc.
G.TTN: Gerald W.-Muench, Vice President
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Arkansas Nuclear 0no-'
- ATTN:'- Early Ewing, General Manager-
Technical; Support and Assessment
Route 3, Box _137G
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.Russellville,LArkansas .72801
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Arkansas' Nuclear.One-
ATTN: ~ Jerry Yelverton, Director
Nuclear Operations
Route'3, Box 137G-
Russellville, Arkansas. 72801
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Arkansas Nuclear One..
' ATTN:. Mr. Tom W. Nickt is
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Russellville,' Arkansas 72801
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Combustion 4 Engineering, sinc.
ATTN: Charles B. Brinkr.an,_ Manager
Washington Nuclear Operations
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12300 Twinbrook Parkvay, Suite 330-
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Rockville,' Maryland 20852
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.H'onorableLJoe W. Phillips
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County Judgefof Pope County-
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LRussellville, Arkansas 72801
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Bishop,. Cook, Purcell & Reynolds
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ATTN:
Nicholas S. Reynolds, Esq.
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-1400 f Street, N.W.
Washington, D.C.
20005-3502
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' ATTN:- Ms.7 Greta Dicus, Otrector
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4815 West-Markam Street
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Little Rock, Arkansas 72201-
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U.S. Nuclear Regulatory Commission
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ATTN: Senior Resident; Inspector
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U.S. Nuclear Regulatory. Commission'
! ATTN:H Regional: Administrator,-Region IV
611 Ryan Plaza Drive, Suite'1000
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Arlington, Texas 76011,
Chief, Technological' Hazards Branch
uFEMALRegion 6.
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Federal Center
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'OCAN079009
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U.S.' Nuclear Regulatory Commission
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Document Control-Desk
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Mail Station P1-137
Washingten, 0.10.
20555
Subject: Arkansas Nuclear One - Units 1 & 2
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Docket Nos.-50-313-and 50-368
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Follow-up Response to Items From the 1990
Radiological Emergency Preparedness Exercise
Inspection Report 50-313/90-08; 50-368/90-08
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Gentlemen:
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Entergy Operations: has reviewed your correspondence of June 15, 1990 (OCNA'
069009), regarding. the Arkansas Nuclear One 11990, radiological emergency
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preparedness exercise.
.As discussed withJ Mr. Samuel Collins, Director, Division c1 Reactor
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Projects, Mr. Bill Beach, Director. Division of Radiation Safety and
Safeguards ' and . staf f in- our meeting. of July 18, 1990, we believe that
Arkansas Nuclear One has a very strong Emergency Preparedness Program and
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1990 e. ercise are
the abnormal number of weaknesses identified in the
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primarily attributable to the impact of the recent reorganization at ANO.
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Nevertheless, we agree with the weaknesses identified by the inspection
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team as evidenced by the close agreement-between'the team's evaluation and-
our post exercise self assessment.
We are, therefore, committed to the
plan for corrective action which we described during our rccent' meeting and
have set forth in detail in the attached.
The 1990 exercise was a successful and challenging experience which
identified several areas requiring further attention in order to enhance
our capabilities and effectively adjust to the recent plant reorganization.
Our detailed review identified
several
areas of corrective
action,-
including 1) increasing the frequency of emergency response facility
drills, 2) allocation' of additional technical support for the emergency
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response = organization, 3) improved information flow, 4) upgrading the
notification method, and 5) enhanced training.
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Arkansac Nuclear One is committed to a quality emergency preparedness
The' effectiveness of our program is evidenced by a number of
program.
program strengths-such as our cooperative and productive relationship with
state.and local government, effective self-assessment, committed management
support and an experienced emergency planniig staff.
ANO continues to have
.a' strong program'to assure the protection af the public health and safety.
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Tk'90-436
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JJuly 27; 1990'
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OCANB790091 Page'2'
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If you haveLany further questions, piease feel free to call me.'
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- Very truly yo'urs,
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1 General Manager,.
Assessment
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RegionalsAdministrator
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Region IV
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- U. S. Nuclear. Regulatory Commission
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'j 611 Ryan Plaza Drive, Suite 1000
' Arlington. Texss. 76011
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5
ARKANSAS NUCLEAR ONE
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1990 RADIOLOGICAL EXERCISE
RESPONSES TO EXERCISE WEAKNESSES
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ATTACHMENT TO OCAN079009
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Weakness'(313/9008-01: 368/9008-011
The' licensee's failure to promptly detect and classify Site Area. Emergency
(SAE) and General Emergency (GE) conditions is considered to be an exercise
weakness..
Response.
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Additional technical. resources have been allocated to support the Emergency-
Direction and- Control (ED&C) function in the Control Room (CR), Technical
.
Center (TSC), and Emergency Operations Facility (EOF).
This
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Support
support includes a procedural task entitica " Emergency Action Level (EAL)
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Review", with the task being staffed by Senior Reactor Operators (SRO) in
support of the Shift Operations Supervisor-(505); TSC Director, and the EOF
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Director.
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The purpose of this assignment is to formulato recommendations for the
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individual with ED&C regarding emergency classification.
Action is completa and becomes effective on July 30, 1990.
Arkansar Nuclear One will also implement a schedule of quarterly Emergency
Response Facility (ERF) drills, which will increase the number of drills
for activation and operation of the TSC, OSC, and EOF from 1 per year to 4
per year (in addition to the annual exercise). Objectives will include:
1.
Emergency Action Level detection and classification.
2.
Development of teamwork skills both within and between Emergency
Response Facility staffs.
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3.
Increase
the
effectiveness,
efficiency
and- accuracy
of
information flow within the ER0i
.
Implementation of the ERF drills begin during the fourth ouarter of 1990.
Weakness (313/9008-02: 368/9008-021
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Examples of inadequate information flow within ~ and from the CR during the-
exercise constitutes an exercise weakness.
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Resnonse
The Emergency Plan will be revised to more explicitly -define formal
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_ information flow paths.
The Implementing Procedures will also be revised
to establish more precise guidelines for Emergency Response Facility (ERF)
information input and output points.
These changes, along with requisite
-training, will achieve the following objectives:
1.
F. educe parallel and uncoordinated information flow channeln
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between Emergency Response Facilities.
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ATTACHMENT TO OCAN079009
PAGE 1
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=2.
Improve the fidelity of information exchanged between Emergency
Response Facflities.
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3.
-Reduction of overall-communications load within tie ERO through
. improved efficiency of information transfer.
This revision is scheduled for November 30, 1990.
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The previously described Quarterly Dr m Program will be the vehicle for-
developing skills in this area.
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Weakness (313/9008-03: 368/9008-03)
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Inadequate technical analysis of all potential consequences when resp'iding
to the exercise accident events constitutes an exercise weakness.
Resnonse
The -position of Accident Assessment Mr. nager has been added to the EOF
staff. The primary duties for this position are to:
,
1.
Develop projections of potential accident pathways and their
consequences and propose mitigation -strategies to .the. EOF
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Director.
]
2.
Review ongoing response activities to ensure work priorities'are
adequ te, correct and consistent with long-term recovery goals.
3.
Explore alternative solutions.
4.
Recommend job-priority changes to the EOF Director, as necessary.
Action is' complete and becomes effective on July 30, 1990.
The Quarterly' Drill Program will be the vehicle used to develop proficiency
in this area.
In addition to the above, the staff of ERO Technical Assistants, which was
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predominantly staffed by- SR0s, has been _ expanded to include approximately
25 Engineering personnel.
This approximately doubles the number of
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Technical Assistants allocated to emergency response.
Selected Technical
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Assistant functions will
be formally assigned upon ERO activation.
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Additional Technical Assistants are available to any ERO member upon
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request through the Support Manager or his staff.
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Action is complete and becomes effective on July 30, 1990,
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ATTACHMENT TO OCAN079009
PAGE 2
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~ Weakness (313/9008-04: 368/9008-04)
.The failure to assign priorities and. assure timely information flow within
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the TSC constitutes an exercise ;<akness.
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Resnonse
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The Engineering Manager has been assigned the responsibility to assist the
.TSC Director
in
eve'uat W
of established priorities
for
response
activities on a' continuous basu throughout, the emergency.
This will.
ensure that prior 9ies establisheid by the TSC staff ate appropriate and
responsive to changes in tne nature and/or severity of the emergency.
Furthermore, the new ERO position of Accident Assessment Manager has been
given the responsibility for oversight- of job prioritization with an
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emphasis on long-term aspects of accident assessment and recovery (the
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Engineering Manager's responsibilities . are to concentrate' more on . the -
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immediate recovery efforts).
The position 'of Radiation- Protection and Radwaste Manager. has been
relocated from the 0,nrations Support Center (OSC) to the TSC. This action
provides more readily available Health Physics expertise to the TSC- staff
and . facilitates the - flow of radiological information to the TSC.
First
line' supervision of the 'Onsite Monitoring Teams remains with. the health
' Physics Supervisor in the OSC.
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- Action is complete for the aMve changes to become effective on July 30,
1990.
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Improvenent in the flo1 of information will be accomplished as discussed in
the response to 9008-02.
The Quarterly ERF Drills will be the vehicle for developing proficiency in
this
area.
Refer to
the
response to weakness
9008-01
for
the
implementation schedule.
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Weakness (313/9008-05: 368/9008-05)
Inadequate and delayed technical analysis in the TSC constitutes an
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exercise weakness.
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Resnonse
To address this weakness, action has been completed to add the position of
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Radiation Protection and Radwaste Manager to the TSC staff (see response to
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weakness 9008-04), anct this change will become effective July 30, 1990.
This will enhance the technical expertise available in the TSC to address
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radiological concerns.
In addition,. a means of determining release rate
information will be available in the TSC with the install: tion of a
terminal for the Radiological Dose Assessment Computer System (RDACS).
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ATTACHMENT TO OCAN079009
PAGE 3
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This addition will provide the.TSC staff with direct access to radiological.
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release rate and offsite dose' projection information.
Technical personnel
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will be trained and located in the TSC to interrogate RDACS and interpret
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this information.
. Implementation for RDACS is scheduled for November 30, 1990..
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The' TSC
staff will
also
have available additional
Operations
and
Engineering expertise provided by the ERO Technical Assistants- (see
response to weakness 9008-03) to aid the staff in assessing plant
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conditions (e.g., determination of primary leak rate and its correlation.to
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, release rate).
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Proficiency in the response measures taken to address this weakness will be
enhanced and continuously evaluated through the Quarterly Drill Program._
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Weakness (313/9008-06; 368/9008-06)
Examples .of incorrect and delayed information on status boards in the EOF
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conttitutes an exercise weakness.
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Resnonse
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A more specialized grw. of communicators will be trained and used for the.
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maintenance of ERF plant
status boards and,
additionally,
explicit
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procedural instructions will be developed for status -board maintenance.
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Furthermore,- steps will be added to the Emergency Plan - and implementing
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- procedures to provide more precisely. defined' information flow paths (see
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response to weakness-9008-02).
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Implementation for these changes is scheduled for November 30, 1990.
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The Quarterly ERF. Drills will be the vehicle for developing proficiency in
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this area (refer to response to weakness 9008-01).
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Replacement of the Gaseous Effluent Radiation Monitoring System (GERMS)
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with RDACS phase II- will result in a reduction of time required to process-
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release rate data =for dose pror t'9ns from 20-30 minutes to approximately
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10 minutes.
As a result, mon.
. rent- information will be provided for
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display on the - offsite ' radiological status board.
This replacement is
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scheduled to occur by November 30, 1990.
Weakness (313/9008-07: 368/9008-07)
. The inspectors noted that-the Dose Assessment (DA) supervisor was not aware
that neither of the two trains of the emergency ventilation systems had
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been activated.
Iodine removal efficiency in one train was less than 80%,
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but the system had not been shifted to the other train to improve filtering
efficiency and minimize offsite release.
The lack of DA personnel
proficiency in; the EOF for the evaluation of the radiological release and
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the consequential dose constitutes an exercise weakness.
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ATTACHMENT TO OCAN079009
PAGE 4
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Resoonse
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Radiological / Environmental Assessment Managers (REAM) and Dose Assessment
Supervisors (DAS) ~will be required to receive Emergency Systems Overview
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Training.
This course will include . information on Emergency Ventilation
-Systems. and is provided to selected ERO. positions and conducted by
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Operations Training . Instructors.
This additional
requirement,
when
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combined with the added capabilities provided by the Accident Assessment
Manager in the EOF, will improve our ability to identify and employ
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measures for. minimizing the consequences of a release to the off-site
environment.
Implementation is scheduled. for November 30, 1990.
Weakness (313/9008-08i 368/9008-08)
-The inspectors observed that the EOF staff was in a reactive mode,.
monitoring data, and carrying out routine activities instead of adopting a-
dynamic and aggressive accident management. posture.. The DA staff did not
clearly demonstrate
their -ability to perform analysis
and
explore
alternative solutions . to take corrective and preventive actions.
The
inadequate technical analysis in the EOF constitutes an exercise weakness.-
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Resoonse
,
As' discussed in the response to weakness 9008-03, the position of Accident-
Assessment Manager has been added to the EOF staff.
This addition will
serve to- give the EOF a focal point for the development of accident
management strategies and will place. the EOF staff in a more proactive
mode.
As nientioned in.the response to weakness 9008-07, the REAM and DAS will be
requiredEto receive Emergency Systems Overview training; however, the-
primary responsibility for this type of analysis will rest with the
Accident Assessment Manager.
<
The quarterly ERF drills will be utilized to measure effectiveness and
enhance-proficiency in this area.
Implementation schedule for these items are discussed above.
Weakness (313/9008-09: 368/9008-091
,
The NRC inspectors found that the EOF emergoney ventilation system had been
turned off during activation of the EOF, and that the EOF HP supervisor was
not aware that it had been shut off until questioned by an inspector,
Also, EOF personnel were not issued personal dosimetry as required by
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ATTACHMENT TO OCAN019009
PAGE 5
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Resnonse
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The EOF : Activation' Checklist- has been revised to establish a requirement
for the EOF Maintenance Coordinator to apprise the EOF HP Supervisor of any
change in the status of the EOF Ventilation: System.
The effectiveness of
this corrective action will be evaluated through the quarterly ERF drills.
Evaluation of EOF dosimetry needs is currently being' addressed in response.
to Inspector Follow-up Item 313/9018-01;368/9018-01.
Weakness (313/9008-10: 368/9008-10)
The licensee's. failure to provide an accurate briefing to the NRC response
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team upon arrival and.the lack of work space for the NRC response team is
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ccasidered to be an' exercise weakness.
Resnonse
- Preparation for NRC briefings will be an objective of the Quarterly. ERF
.
Drills scheduled to begin in the fourth quarter of 1990 (refer _ to response
to weakness 9008-01). ' Proficiency in this area will be enhanced ' and
continuously evaluated through this drill program.
ANO has recently instituted- the concept of colocation which encourages
~ 1icensee and responding agency officials. (NRC and Arkansas. Department of
Health) to work side-by-side during emergencies.
Emergency Planning will
perform an evaluation of the current application of~this concept in the EOF
and make modifications accordingly.
Implementation of the evaluation
results will take place by March 1, 1991.
Weak' ness (313/9008-11: 368/9008-111
The licensee'.s
failure to provide
for prompt,
offsite radiological
measurements is considered to be an exercise weakness.
kesconse
The delay.in deployment of offsite_ monitoring teams was directly related to
problems _ associated .with
the off-hours
call-out of Health
Physics
personnel.
'ANO will
utilize an automated-computer based emergency
notification system. The new system will achieve an increase in the speed,
efficiency, effectiveness and reliability of our capability to activate the
'
ERO, particularly .during non-routine working hours.
Implementation for
'
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this new call-out system is scheduled for completion by January 1,1991.
Additionally, as a result of a review of the current ERO staffing levels
and since the 1990 exercise, the staff of the Emergency Radiation Team has
been increased by approximately 25%.
Training was completed on June 8,
1990..
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ATTACHMENT TO OCAN079009
PAGE 6
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. Weakness (313/9008-12 368/9008-12)
,
The licensee's apparent failure to adequately train fire brigade personnel
on.SCBAs is considered to be an exercise weakness.
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Response
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Following the exercise, an evaluation of the Fire Brigade Training -Program'
t
was. conducted.- The . evaluation revealed that the. program did not- contain
instructions in the use of respiratory equipment nor protective clothing. .
!
The Fire Brigade training program has since been revised to include:
1.
The addition of objectives which address the proper use of SCBAs
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and protective. clothing.
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2.
The demonstration of this knowledge through practical factors
sessions.
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. Training was completed on May 10, 1990.
General Coments
,
In response to NRC concerns that many weaknesses appear to be related to
'
inadequate
training of
emergency
responders,
Emergency . Planning
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conducting a comprehensive review and evaluation of the Emergency Planning
Training program currently in use.
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At this ' point, we recognize the need to' provide increased emphasis in
!
practical
application of topics now _ covered
in ~ classroom training,
,
_particularly for new personnel who staff the Emergency Response Facilities.
One such change is the Quarterly ERF Drills discussed above. -Additionally,
1
prospective ERO members in all positions wil1 ~ participate in a practical
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session,. such as a facility walk-through or tabletop drill, prior to formal-
D
assignment.
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This evaluation, along with an implementation schedule based on. the
results, will be completed by December 31, 1990.
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ATTACHMENT TO OCAN079009
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