ML20116B077
| ML20116B077 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 07/25/1996 |
| From: | James Fisicaro ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20116B080 | List: |
| References | |
| W3F1-96-0125, W3F1-96-125, NUDOCS 9607290094 | |
| Download: ML20116B077 (9) | |
Text
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d Ent: gy per:ti:ns, Inc.
Killona, LA 70066 Tel 504 739 6242 am s J. Fisicaro lla$L5Y' W3F1-96-0125 A4.05 PR l
July 25,1996 U.S. Nuclear Regulatory Commission
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ATTN: Document Control Desk Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Inspection Report 96-06 Gentlemen:
Entergy Operations, Inc. hereby submits the response to the emergency preparedness weakness documented in the subject inspection Report. This response is attached (attachment 1) and includes analysis of the weakness, description of corrective measures and schedules for completing these actions as requested.
In addition to the response to the identified exercise weakrsess, Entergy Operations, Inc. would like to take the opportunity to offer information relating to the Inspection Follow-up Item and other observations noted in the inspection Report. This information is provided in attachment 2.
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NRC inspection Report 96-06 W3F1-96-0125 Page 2 July 25,1996 If you have any questions concerning these responses, please contact me at (504) 739-6242 or Tim Gaudet at (504) 739-6666.
Very truly yours,
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.J. Fisicaro Director Nuclear Safety JJF/GCS/ssf Attachments Enclosures (w/ Attachments & w/ Enclosures) cc:
L.J. Callan (NRC Region IV) - 2 copies (w/ Attachments & w/o Enclosures)
C.P. Patel (NRC-NRR)
R.B. McGehee N.S. Reynolds NRC Resident Inspectors Office
Attcchmtnt 1 to W3F1-96-0125 Page 1 of 3 ATTACHMENT 1 ENTERGY OPERATIONS. INC. RESPONSE To THE EMERGENCY EXERCISE WEAKNESS DOCUMENTED IN INSPECTION REPORT 96-06 WEAKNESS NO. 9606-02 Scenario conditions and en 1.sacy plan implementing procedures required both crews to initiate actions to augment onshift emergency response personnel at the site area emergency classification level. The first crew performed this action promptly and efficiently. However, the shift supervisor on the second crew did not direct activation of the voice notification system (automatic pager/ dialer) until 43 minutes after the declaration of the site area emergency. Had this been a real emergency, activation of the technical support center to relieve the control room of emergency plan requirements would have been delayed. Once directed to activate the call-out, the communicator experienced a computer problem which further delayed system activation. The failure to activate the voice notification system in accordance with Step 5.3.1 of Emergency Plan implementing Instruction EP-001-030, Revision 21, " Site Area Emergency," was identified as an exercise weakness (382/9606-02).
RESPONSE
(1)
Analysis of the Weakness The root cause of the failure to activate the Voice Notification System (VNS) in a timely manner by one of the two Operations crews participating in the inspection activity is personnel error in that the crew in question failed to consult the emergency plan implementing procedure section which delineates the requirements for activating the VNS. When the Shift Supervisor failed to activate the VNS he was concerned with changing conditions in the plant requiring possible escalation in emergency classification. These changes in condition did require dose assessment calculation to be performed. The Shift Supervisor did not remember to direct VNS activation or consult the appropriate emergency plan procedure section until after implementing procedure EP-001-040, General Emergency, for general emergency classification.
Contributing to this event is that emergency plan implementing procedures EP-001-020, Alert, EP-001-030, Site Area Emergency, and EP-001-040, General Emergency are not very specific as to when the VNS activation should be conducted during emergency events. Another contributing factor is
. that the software design of the VNS is such that use of the number keypad on the terminal may cause keyboard operator commands to fail to be recognized
Attechment 1 to i
Page 2 of 3 1
by the system. VNS activation was delayed further when the communicator attempted to transmit commands using the number keypad as opposed to the alphanumeric keys on the keyboard.
(2)
Corrective Measures a) The Emergency Planning Manager, Operations Manager and affected Shift Supervisor critiqued the inspection activities associated with Operations crew response on June 12,1996. The delay in VNS activation and ways to ensure timely activation occurs were discussed as lessons learned from the inspection. This Corrective Measure was comploisd on June 12,1996.
b) The procedures referencing VNS activation (EP-001-020, Alert; EP-001-030, Site Area Emergency; EP-001-040, General Emergency) will be revised to relocate the step on system activation to the front of the procedure. These procedures will also be revised to include specific guidance as to when VNS activation activities should be conducted during emergency response.
c) Training will be provided for all Operations shift personnel in the form of '
E Operator seminars conducted by the Emergecy Planning Department in which the failure to activate the VNS in a timely manner during the inspection simulator walkthrough will be discussed as a lesson learned.
The seminars will include actual hands' on training on VNS keyboard operations and system activation where attendees will be expected to activate simulated call-out scenarios.
d) Emergency Response Organization training lesson plans for Operations personnel will be revised to incorporate discussion on the VNS weakness as a lesson learned from the 1996 emergency preparedness inspection.
e) A physical barrier was placed on the VNS terminals in the Control Room and Control Room Simulator to prevent a user from inadvertently attempting scenario activation commands using the number keypad. This Corrective Measure was immediately implemented after the problem was identified. This Corrective Measure was completed on May 23,1996.
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_. to W3F1-96-0125 l
Page 3 of 3 (3)
Date When Full Comoliance Will be Achieved Waterford 3 is currently in full compliance. Additional corrective steps to I
address the weakness are scheduled to be completed as identified below.
Corrective Measures b and c will be completed by October 1,1996.
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Corrective Measure d will be completed by December 1,1996.
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Attachm:nt 2 to W3F1-96-0125 Page 1 of 4 ATTACHMENT 2 ENTERGY OPERATIONS. INC. RESPONSES TO FOLLOW-UP ITEM AND OBSERVATIONS DOCUMENTED IN INSPECTION REPORT 96-06 INSPECTION FOLLOW-UP ITEM 9606-01 On May 29,1996, the emergency planning manager informed the inspector that i
carbon dioxide testing had been performed to further define habitability considerations 4
and that preliminary plans included establishing a time limit to evaluate the situation j
and take necessary actions. The licensee stated that once the time limit was j
established, applicable emergency plan implementing procedures would be revised to i
provide procedural guidance to emergency responders. The results of the control room habitability assessment and the provisions for transfer of technical support center functions will be reviewed in a subsequent inspection as an inspection followup item (382/9606-01).
RESPONSE
Preliminary testing of carbon dioxide buildup in the Control Room Envelope with the Control Room ventilation system in the isolation mode has been completed.
Additional testing will be performed before procedure revisions are finalized to include the time limit for evaluation of necessary actions before TSC responders would be required to leave the Control Room Envelope in a toxic chemical contingency that occurs after the facility has been staffed for a radiological emergency. These procedure revisions will identify the EOF and Backup EOF (if EOF is affected) as relocation sites for the TSC, with the requirement to call out -
additional TSC responders to report to the selected facility to effect as smooth a transition of functions as possible. All testing and procedure revisions are currently anticipated to be completed by September 1,1996.
OBSERVATION 1 The inspectors reviewed portions of the emergency plan and recently revised
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implernenting procedures. Minor discrepancies involving locations of NRC facilities were observed and discusred with emergency planning personnel. None of the I
changes decreased the effectiveness of the emergency plan. Program changes (facilities, emergency response organization, etc.) were properly incorporated into l
the emergency plan and procedures.
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Attachm:nt 2 to W3F1-96-0125 Page 2 of 4 RESPONSE 1 The minor discrepancies in the Emergency Plan involving NRC facility locations have been identified and marked with the correct information and will be corrected with the next annual Emergency Plan revision in the fourth quarter of 1996.
OBSERVATION 2 The inspectors concluded that since the emergency preparedness training program was maintained separately from other emergency plan implementing procedures, changes to the program could be made without receiving the same level of review. For example, changes to the emergency plan and implementing procedures require a review under 10 CFR 50.54(q) to determine if the changes decrease the effectiveness of the emergency plan. Changes that decrease the effectiveness of the plan must receive prior NRC approval. Currently, the licensee could make changes to its emergency preparedness training program without: (1) performing a 10 CFR 50.54(q) determination, (2) receiving prior NRC approval, and (3) submitting the changes to NRC in accordance with 10 CFR Part 50, Appendix E.V. The licensee acknowledged the inspectors' comments and indicated that the matter would be reviewed for correction.
RESPONSE 2 The following training procedures will receive a 10CRF50.54(q) review by the Emergency Planning Department prior to approval by Training Department management for future revisions: NTP-203, Emergency Plan Training; NTC-216, Emergency Plan Training Initial; NTC-217, Emergency Plan Continuing Training.
Future revisions of these procedures will be submitted to the NRC in the same manner as Emergency Plan Implementing Procedures. Copies of these procedures are enclosed with this inspection weakness response in order to establish a baseline.
OBSERVATION 3 Both crews had difficulty diagnosing indications tnat fuel integrity was challenged or degraded which delayed the general emergency declarations. Offsite agency notifications and protective action recommendations were satisfactorily performed, f
however, potentially confusing information would have been transmitted if the scenario had continued.
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Att: chm:nt 2 to W3F1-96-0125 i
Page 3 of 4 RESPONSE 3 in addition to the corrective measures described in the attached submittal for the exercise weakness (attachment 1), Entergy Operations, Inc. will conduct a training session with each Operations crew with a dynamic simulator using the scenario from the inspection to address the classification and other improvement items identified during the two crew walkthroughs. These special training sessions will be conducted in the next scheduled requalification cycle (beginning July 29,1996). Emergency planners will be present at each session to eva!uate emergency plan implementation.
The protocol for this training will allow for stopping the scenario at selected intervals, such as when containment radiation monitor readings increase indicating potential cladding failure, to discuss the effect of the given conditions on emergency preparedness response activities. These improvement items will also be addressed in the Operator seminars, that are scheduled to be conducted as part of the exercise weakness corrective actions, in a classroom discussion format as iessons learned.
In addition, Entergy Operations, Inc. will complete an evaluation of the classification procedure in 1996 to determine if additional enhancements can be made in identification of fuel cladding failure criteria.
QRSERVATION 4 The inspectors were generally satisfied with the licensee's control of examination material, however, they encouraged the licensee to reassess the validity of remediation examinations that were administered within a very short period of time and that contained similar numbers of repeat questions to those in the 1995 examinations.
RESPONSE 4 The Waterford 3 Training Department is in the process of revising their remediation examination policy to require at least a 70% difference in test questions when a remediation examination is required.
OBSERVATION 5 Informal practices were used to track drill participation.
RESPONSE 5 The drill participation requirements presently maintained in an informal manner will be incorporated as part of procedure EP-003-020, Emergency Preparedness Drills and Exercises by December 31,1996.
Att chment 2 to W3F1-96-0125 Page 4 of 4 OBSERVATION 6 The emergency planning organization maintained five separate databases containing home/ work /pager telephone numbers for the emergency response organization. The inspectors reviewed several outputs and identified an incorrect telephone number for the newly appointed emergency operations facility director. In response, the licensee conducted a complete review of the lists and identified several other errcrs. The licensee promptly corrected the errors and initiated long-term actions to consolidate and computerize the databases. The inspectors concluded that the licensee's response to the identified errors was thorough.
RESPONSE 6 An Emergency Planning Department Natural Work Team was established to address the consolidation of the five separate databases presently maintained. The Natural Work Team activities are progressing on schedule with revisions to the process used to update the Emergency Management Resources Book (EMRB) anticipated by November,1996. An additional level of review and sign-off on EMRB revisions has been added specifically for evaluation of telephone number changes that are rnade as part of the monthly update of the document.
OBSERVATION 7 i
i The inspectors noted that Section 8.1.2.4 of the emergency plan specifically j
mentioned water, grass, soil, and air samples as examples of sample media but that Section 5.1.4 of the corresponding implementing procedure, EP-003-020, Revision 8, Emergency Preparedness Drills and Exercises, did not mention environmental sample collection. The inspectors acknowledged that sample collection was 1
performed as a matter of practice but concluded that procedural guidance was not sufficient to ensure that emergency plan requirements were consistently met. In response, the licensee stated that the additional guidance would be added to the i
implementing procedure.
RESPONSE 7 EP-003-020, Emergency Preparedness Drills and Exercises, was revised on May 31, 1996, to incorporate additional guidance on the collection of water, grass and soil samples to meet the applicable Emergency Plan requirements.