ML20101G296

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Forwards Response to NRC Violations Noted in Insp Rept 50-382/92-07.Corrective Actions:Lesson Plans for Emergency Response Personnel Will Be Revised & Special Training Seminars Will Be Conducted for Each Operations Shift
ML20101G296
Person / Time
Site: Waterford Entergy icon.png
Issue date: 06/22/1992
From: Burski R
ENTERGY OPERATIONS, INC.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
W3F192-0174, W3F192-174, NUDOCS 9206250397
Download: ML20101G296 (4)


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W3F192-0174 Al.05 j

QA June 22, 1992 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.

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Subject:

Waterford 3 SES Dncket No. 50-382 Ideense No. NPF-38 NRC Inspection Report 92-07 Gentlemen:

Entergy Operations, Inc. hereby submits the response to toe emergency pr:paredness waakness identified during walkthroughs of simulated accident j

t.cenarios with control room operating crev.s and documented in the subject Inspection Report. This response is attached and includaa an analysis of the weakness, a descriptian of corrective measures and a schedule for completing these actions as requested.

If you have any questions concerning this response, please cor. tact F.J. Englebracht, Emergency Phinning & Administration Manager, at l

(504) 739-0607, Very truly yours,z

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v 4tFB/CJT/dc Attachment ec:

R.D. Martin, NRC Region IV D.B. Spitzberg, NRC Region IV R.B. McGehee N S. Reynolds 4

NRC Resident Inspectors Office l

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Attachment to W3F192-0174

' Page 1 of 3 ATTACHMENT

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L ENTERGY OPERATIONS, INC. RESPONSE TO THE EMERGENCY EURCISE WEAKNESS DOCUMENTED IN INSPECTION REPORT 92-07 I.

WEAKNESS NO. 9207-01:

The inspectors conducted a series of evaluations on the plant-specific control l

room simulator to evaluate the current knowleQe and ability of personnel assigned emergency respont.e duties in the control room. The scenario used in 8

the evaluation was developed by the inspectors to determine if contr. I room teams were able to classify events accurately, to perform the required notifications in a l

timely manner, to perform offsite dose assessment, and to make adequate protective action recommendations. During the walkthroughs, several problems in the crews abilities to formulate protective actions and to assess the offsito consequences of the emergency were noted as follows:

One crew sheltered onsite personnel during a toxic ga*: release instead of evacuating these personnel as specified in Emergency Plan' Implementing i

Procedure EP-004-010 for the specific conditions posed by the scenario.

i One crew mt.de an error in estimating the release rate and subsequently communicated the erroneous estimate to nftsite authorities. The arroneous estimate was 1000 curies per second (C1/s) or oe?r 3 times the actual release rate of about 300 C1/s. Errors such es this could lead to confusion j'

by offsite decisio'< makers in attempting to correlate the'offsite dose i

projections to the release rate estimate and in independently assessing the release using licensee provided release rate estimates, i

One crew made an error in transcribing the correct meteorological data onto the Alert notification form and, ao a result, communicated the incorrect i

data and erroneous affected gc. > Tphical sectors to offsite agencies.

One crew made a protective action recommenoation to the state of evacuation of all sectors out to 5 miles. Such a protective action recommendation could not be arrived at using EP-2-052, " Protective Action i

Guidelines." This protective action recommendation, if implemented, would

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have caused the evacuation of poptdations located in the upwind direction -

r between 2-5 miles.

i One crew made a baseline protective action recomnmndation at the general.

i emergency of shelter the 2-m11e radius and the downwind sectors out to 5 miles.. Although the protective action recommendation was valid for tho -

classification, the crew did not consider dose projections calculated before the protective action recommendation was made which showed offsite doses exceeding protective action guidelines and, thereby, t.ogy.Wue, evacuation of these sectors.

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Attaciunent to W3F192-0174 t c Page 2 of 3 i

_ RESPONSE j:

(1)'

Analysis af the Weakness I

Entergy Operations, Inc. performed an analysis of this weakness by separating it into five single problems. Fach problem was analyzed 7

separately to facilitate the identification of-probable root causes md 4

1 effective corrective measures. The analysis revealed the following:

l l-The first problem involves the failure of one crew to make the proper j

protective action recommendations for site personnel during a toxic gas j

release. This failure is attributed to human error. Emergency Plan i

ImplemenCng Procedure (EPIPT EP-004-010 clearly recommends personnel l

evacuation during this type' of emergency. In fact, later during the i

scenario the shift supervisor recognized the error and made a conscious

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decision tc, stand by the recommendation. This decision appears to have been appropriate because the plume was about to arrive onsite.

The second problem involves an error by one crew in estimating the release rate. This error is attributed to human error r nd the failure of the Control i

Room Dose Assessment Computer to provide assistance in this area, i

l The third problem involves an error by one crew in t>anscriolag the j

correct meteorological data onto the Alert notification form. This error is attributed to the failure to utilize the information provided in the EPIPs and on the Control Room Dose Assessment Computer program.

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Finally, the last two problems involve the offsite protective action recommendation decision making process. There problems are attributed to two things. First, EPIP EP-002-052 is somewhat cumbersome and difficult i

to use. Second, the Control Room Dose Assessment Computer program does i

not provide offsite protective action decision methodologies, j

(2)

Corrective Measures t

I Four specific actions are planned to prevent recurrence. These actions are as follows:

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Lesson plans for Control Room emergency response personnel will be revised to include a discussion of this weakness as a lessons learned.

l This discussion will emphasize the importance of using available resources (i.e., procedural aids, computer program)-to ensure that j'-

. initial protectis e action recommendations are made (given time l

restraints) with the best information available.

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2.

Special training seminars will be conducted by Emergency Planning.

E for each Operations shift. A portion of these serine.rs will be devoted to a discussion of this weakness as a les-~ -

c.wnad.

l During the seminars, emphasis will be placed on the itaportance of using available resources (i.e., procedural aids, computer program)

to ensure that initial protective action recommendations are made (given time restraints) with the best information available. In i

addition, the seminars will include exercises that require protective I

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Attachment to W3F192-0174 Page 3 of 3 action recommendations to be generated during toxic chemical and radiological scenarios.

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The computerized Control Room Dose Assessment program will-be revised to provide a calculation and display of the release source tarm (Ci/sec release rate) and offsite protective action recommendations when a dose calcult. tion is run, i

4.

An evaluation of the offsite protective e:tions procedure, _EP-002-052, will be conducted. This evaluation willinclude consultations >

with control room personnel and other users to identify ways in which the procedure could be enhanced and made more user friendly.

-(3)

Schedules for Completion Corrective measures 1 through 4 will be completed by October 1,1992.

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