ML20056B393

Ack Receipt of Informing NRC of Corrective Measures Taken & Proposed to Address Concerns Identifed During 1990 Radiological Emergency Insp Repts 50-313/90-08 & 50-368/90-08

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

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In Reply. Refer:To:-

' Dockets:' 50-313'90-08: ,

250-366/90-08 .,

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.Entergyl Operations, Inc.

-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 l

' dated June 15,.1990. We found that the corrective measures taken and your d

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 ~

Division' of Reactor . Projects '

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cc:

Entergy Operations, Inc.

s ATTN: Donald C. Hintz,. Executive Vice

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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Operations Support ,

P.O. fm ~1995 -

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Jacku ,, i ssissippi 39286

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1 Arkansas Nuclear 0no-'

- ATTN:'- Early Ewing, General Manager-

Technical; Support and Assessment

Route 3, Box _137G .

.Russellville,LArkansas .72801 M

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Arkansas' Nuclear.One-

ATTN: ~ Jerry Yelverton, Director

Nuclear Operations

Route'3, Box 137G-

Russellville, Arkansas. 72801 .

Arkansas Nuclear One..

' ATTN:. Mr. Tom W. Nickt is -

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Route 3, Box:137G

Russellville,' Arkansas 72801

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Combustion 4 Engineering, sinc.

ATTN: Charles B. Brinkr.an,_ Manager

Washington Nuclear Operations  !

12300 Twinbrook Parkvay, Suite 330- 1

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, Rockville,' Maryland 20852

b .H'onorableLJoe W. Phillips

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County Judgefof Pope County- -r

Pope County Courthouse

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LRussellville, Arkansas 72801

Bishop,. Cook, Purcell & Reynolds r

ATTN: =

Nicholas S. Reynolds, Esq. '

-1400 f Street, N.W.

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Washington, D.C. 20005-3502

Arkansas Department of Health i

' ATTN:- Ms.7 Greta Dicus, Otrector

. Division of Environmental Health '

~ Protection

4815 West-Markam Street

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Little Rock, Arkansas 72201-

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U.S. Nuclear Regulatory Commission 4

ATTN: Senior Resident; Inspector

1 Nuclear Plant Road- ,

e . ,Russellville, Arkansas 72801 i

U.S. Nuclear Regulatory. Commission'

! ATTN:H Regional: Administrator,-Region IV

611 Ryan Plaza Drive, Suite'1000 >

Arlington, Texas 76011,

Chief, Technological' Hazards Branch

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'Denton, Texas 76201-3698

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July 27, 1990 #E - 21990 .L

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'OCAN079009 .

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U.S.' Nuclear Regulatory Commission ,

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Document Control-Desk

Mail Station P1-137

Washingten, 0.10. 20555

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Subject: Arkansas Nuclear One - Units 1 & 2

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Docket Nos.-50-313-and 50-368

L License Nos. DPR-51 and NPF-6

Follow-up Response to Items From the 1990

Radiological Emergency Preparedness Exercise

Inspection Report 50-313/90-08; 50-368/90-08

! Gentlemen:

L Entergy Operations: has reviewed your correspondence of June 15, 1990 (OCNA'

" 069009), regarding. the Arkansas Nuclear One 11990, radiological emergency

p preparedness exercise.

.As discussed withJ Mr. Samuel Collins, Director, Division c1 Reactor

i Projects, Mr. Bill Beach, Director. Division of Radiation Safety and

Safeguards ' and . staf f in- our meeting. of July 18, 1990, we believe that

t Arkansas Nuclear One has a very strong Emergency Preparedness Program and

the abnormal number of weaknesses identified in the 1990 e.x ercise are

, primarily attributable to the impact of the recent reorganization at ANO.

!- Nevertheless, we agree with the weaknesses identified by the inspection

L 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

L notification method, and 5) enhanced training.

Arkansac Nuclear One is committed to a quality emergency preparedness

program. The' effectiveness of our program is evidenced by a number of

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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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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cc: RegionalsAdministrator 1

Region IV -!

• ' ;U. S. Nuclear. Regulatory Commission

'j 611 Ryan Plaza Drive, Suite 1000 J

' Arlington. Texss. 76011 l

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ARKANSAS NUCLEAR ONE j

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1990 RADIOLOGICAL EXERCISE  :

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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..

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Response. ,

Additional technical. resources have been allocated to support the Emergency-

Direction and- Control (ED&C) function in the Control Room (CR), Technical .

Support Center (TSC), and Emergency Operations Facility (EOF). This 1

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

7 Director.

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

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Response Facility staffs.

3. Increase the effectiveness, efficiency and- accuracy of

information flow within the ER0i

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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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The Emergency Plan will be revised to more explicitly -define formal

l _ 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 '

between Emergency Response Facilities. I

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=2. Improve the fidelity of information exchanged between Emergency

Response Facflities. '

3. -Reduction of overall-communications load within tie ERO through

. improved efficiency of information transfer.

This revision is scheduled for November 30, 1990. 1

The previously described Quarterly Dr m Program will be the vehicle for-

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developing skills in this area.

Weakness (313/9008-03: 368/9008-03) r

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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 3

Director.

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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.

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In addition to the above, the staff of ERO Technical Assistants, which was

predominantly staffed by- SR0s, has been _ expanded to include approximately

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25 Engineering personnel. This approximately doubles the number of

Technical Assistants allocated to emergency response. Selected Technical .

Assistant functions will be formally assigned upon ERO activation.

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Additional Technical Assistants are available to any ERO member upon

request through the Support Manager or his staff. 1

L Action is complete and becomes effective on July 30, 1990,

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~ Weakness (313/9008-04: 368/9008-04)

.The failure to assign priorities and. assure timely information flow within .I'

the TSC constitutes an exercise ;<akness.

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Resnonse .c

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

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given the responsibility for oversight- of job prioritization with an

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 -

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. s

- 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.  !

Weakness (313/9008-05: 368/9008-05)

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Inadequate and delayed technical analysis in the TSC constitutes an

l exercise weakness. ,

Resnonse

To address this weakness, action has been completed to add the position of

Radiation Protection and Radwaste Manager to the TSC staff (see response to

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i weakness 9008-04), anct this change will become effective July 30, 1990.

~ This will enhance the technical expertise available in the TSC to address

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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This addition will provide the.TSC staff with direct access to radiological. i

t 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

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

conditions (e.g., determination of primary leak rate and its correlation.to t

, release rate). ,

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)

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Examples .of incorrect and delayed information on status boards in the EOF

conttitutes an exercise weakness. .

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-- Resnonse

A more specialized grw. of communicators will be trained and used for the. H

maintenance of ERF plant status boards and, additionally,

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explicit  ;

procedural instructions will be developed for status -board maintenance. l

L 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 i

L response to weakness-9008-02). H

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 .l

L this area (refer to response to weakness 9008-01). _

Replacement of the Gaseous Effluent Radiation Monitoring System (GERMS)

L with RDACS phase II- will result in a reduction of time required to process-

l release rate data =for dose pror t'9ns from 20-30 minutes to approximately

l- 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

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

L . been activated. Iodine removal efficiency in one train was less than 80%,

h 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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Resoonse ,

Radiological / Environmental Assessment Managers (REAM) and Dose Assessment

Supervisors (DAS) ~will be required to receive Emergency Systems Overview

j. 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  !

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.-

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.

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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 i

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, l

Also, EOF personnel were not issued personal dosimetry as required by

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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 >l

team upon arrival and.the lack of work space for the NRC response team is l

ccasidered to be an' exercise weakness. I

Resnonse

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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 '

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ERO, particularly .during non-routine working hours. Implementation for

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

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 i

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  ;

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inadequate training of emergency responders, Emergency . Planning n

conducting a comprehensive review and evaluation of the Emergency Planning

Training program currently in use. .,

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E At this ' point, we recognize the need to' provide increased emphasis in  !

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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 ,

L 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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