ML20126H020
| ML20126H020 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 12/22/1992 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20126G962 | List: |
| References | |
| 50-313-92-27, 50-368-92-27, NUDOCS 9301050040 | |
| Download: ML20126H020 (12) | |
See also: IR 05000313/1992027
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APPENDIX
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Inspection Report: 50-313/92-27
-50-368/92-27
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Operating Licenses: DPR-51
NPF-6 -
Licensce: Entergy Operations, Inc.
Route 3, Box 137G
Russellville, Arkansas 72801
Facility Name: Arkansas Nuclear One
Inspection At: Russellville, Arkansas
Inspection Conducted: December 7-11, 1992
Inspectors: D. Blair Spitzberg, Ph.D., Emergency Preparedness Analyst
(Lead-Inspector) Facilities Inspection Programs Section-
John L. Pellet Chief, Operations Inspection Section
Approved: ///h 2//v /// F ,
B.'Murray, Chief, Faeflities Inspection Cate'
Programs Section
Insnection Summary
Areas'Insnected: Routine, announced inspection of the operational . status of-
the emergency preparedness program, including changes to the emergency plan-
and implementing procedures; emergency ' facilities, equipment, .and supplies;
organization and management control; training; and internal reviews and
audits. . A regional inspection initiative was performed in .the area of
knowledge and performance of duties of emergency response personnel.
Results:
e. The licensee had reviewed and properly submitted to NRC changes in the
emergency plan and implementing. procedures. The licensee had maintained-
a close and responsive relationship with offsite emergency planning
organizations (Section 1).
o Emergency facilities, equipment, and supplies had been maintained in a
proper state of ' operational readiness -(Section 2).
e The licensee had maintained excellent numbers of emergency response _
personnel who were prepared-to respond to emergencies in a short period
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of time. The emergency planning staff was fully staffed with qualified
personnel (Section 3).
e Timely and effective training had been provided to individuals assigned
to the emergency-response organization in accordance with the governing
procedure. The licensee had conducted an excellent pre : ram of training
drillsandexercises'(Section4).
e During walkthrough emergency scenarios conducted, operating crews
demonstrated the ability to classify emergency events pro.nely and in a
timely manner and made appropriate protective action rec eme idations to
offsite authorities. A Unit I crew experienced difficult;,- in
assessing plant conditions and in making adequate notifications, but the
inspectors did not consider the Unit 1 problems to be indicative of an
emergency preparedness training weakness. A weakness was identified for
failures by all three crews evaluated to perform accurate dose
assessments in a timely manner from the control room following an
unmonitored radiological release (Section 5).
- Annual internal audits of the emergency preparedness program hed been
conducted in an excellent manner in accordance with 10 CFR 50.54(t).
Emergency preparedness surveillances were well targeted and focused
(Section 6).
Summarv of Inspection Findinas:
Weakness 313/9227-01; 368/9227-01 was opened (Section 5.1).
Attachment,
Attachment 1 - Persons Contacted and Exit Meeting
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RETAILS
I EMERGENCY PLAN AND IMPLEMENTING PROCEDURES (82701-02.01)
The inspectors reviewed changes in the licensee's emergency plan and
implement %g procedures to verify that these changes had not decreased the
effectiveness of emergency planning and that the changes had been reviewed
properly and submitted to NRC.
1.1 Discussion ,
The inspectors determined that the last emergency plan change was implemented -
in December 1991. The internal review of the plan change required by
i 10 CFR 50.54(q) hart included detailed justification for each change and a
determination that the changes-had not decreased the effectiveness of the
plan. The changes received appropriate internal review prior to
implementation. The inspectors reviewed the process for revising emergency
plan implementing procedures and selective documentation associated with such
revisions. All implementing procedure changes had been submitted to NRC
within 30 days following implementation as required by 10 CFR Part 50,
Appendix E,lV. The inspectors reviewed the document control practices of the-
licensee's emergency plan and implementing procedure changes and found them to
be appropriate.
The inspectors reviewed Letters of Agreement between outside support
organizations and the licensee and found them to be current. At the time of
the inspection, several of the agreements were in the process of undergoing a
review and update which is required every 2 years. The inspectors met.with
the Manager of the Arkansas Department of Health Nuclear Planning Program to
discuss state and licensee interfaces and cooperation. The state's
representative stated that the licensee has continued to work closely with'the
state regarding offsite emergency planning and has been responsive to -state
and local needs.
1.2 Conclusions
The licensee had reviewed and properly submitted to NRC changes in the
emergency plan and implementing procedures. The licensee had maintained a.
close and responsive relationship with offsite emergency planning
organizations.
2 EMERGENCY FACILITIES, EQUIPMENT, INSTRUMENTATION, AND SUPPLIES
(82701-02.02)
The inspectors toured onsite emergency facilities and reviewed the licensee's
emergency equipment inventories to determine whether facilities and equipment
had been maintained in a state of operational readiness.
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2.1 Discussion
The licensee's onsite emergency response facilities appeared to be in a state
of operational readiness. No significant changes had been made_ in the
facilities since the previous inspection, although in the Emergency Operations
Facility improvements had been made in the layout of the comand center.
Emergency equipment lockers in the response facilities were observed to be
secured. The inspectors performed a random check of emergency equipment-
inventories and found no discrepancies. Sampling and survey equipment
designated for emergency use were operational and in current calibration. The
inspectors observed licensee representatives demonstrate-the operability of
the dose assessment computers in the response facilities. Current, controlled
copies of the emergency plan and implementing procedures were observed in each -
response facility.
The inspectors reviewed documentation of routine inventories and tests of -
emergency response equipment. Inventories and emergency equipment checks had
been performed at the designat'ed frequencies. Tests of the comunications
systems showed that telephones and radio equipment had been maintained.
Documentation was reviewed of the Emergency Operations Facility emergency
ventilation system test performed in July 1992 in accordance with station
procedures and ANSI 1.52. The results of this tests showed that the emergency
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ventilation system could perform its intended function.
The inspectors reviewed the documentation of routine operability tests of the
i Emergency Operations Facility emergency diesel generator. These tests had not
! been proceduralized but instead had been performed according to a written
L instruction. The instruction specified testing once per month with loading,
and once per week without loading. The records of the tests showed that the
weekly tests had not met the specified frequencies. According to emergency
planning representatives, engineering had recomended that weekly _ test be
discontinued. The inspectors noted that if the licensee accepted their
, . internal recomendation to test the emergency diesel generator in accordance-
L with written procedures, this would be an improvement.
2.2 Conclusions
. Emergency facilities, equipment, and supplies had been maintained in a proper
! state of operational readiness.
l 3 ORGANIZATION AND MANAGEMENT CONTROL (82701-02.03)
The inspectors reviewed the emergency response organization and procedures for
y its activation to determine conformance with the emergency plan. The
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emergency planning organization was reviewed to-determine whether
any changes had impacted the ability of this organization to carry out its
responsibilities.
3.1 Discussion-
No changes had been made since the previous inspection in the Emergency-
Response Organization organizational structure or position responsibilities.
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The most recent duty list had been issued in June 1992 according to
Procedure 1903.004. This-list assigned weekly duty responsibilities to one of
the four primary emergency response teams. Ewergency response organization
supervisory staff positions were at least four deep in individuals
specifically trained for the assigned position. Licensee representatives
indicated that in the event an individual on active duty was to be
unavailable, it was that individual's responsibility to reassign their duty to
another qualified emergency responder. Emergency response organization
staffing reviews performed monthly were found to be in order. Documentation
of quarterly Emergency Response Organintion notification and staffing drills
conducted in accordance with Procedure 1903.061E indicated that the licensee
would have the capability to provide minimum Emergency Response Organization
staffing during all hours with an acceptably short response time.
The inspectors determined that the emergency planning organization was fully
staffed with qualified individuals. No changes in staffing levels had been
made since the previous inspection. Position descriptions were on file for
emergency planning staf f positions. The staff consisted of two senior
planners, three Level 111 and one Level 11 planners, and temporary part-time
clerical support all reporting to the Emergency Planning Supervisor.
3.2 Conclusions
The licensee had maintained excellent numbers of emergency response personnel
who were prepared to respond to emergencies in a short period of time. The-
emergency planning staff was fully staffed with qualified personnel.
4 TRAlhlNG (82701-02.04)
The inspectors met with emergency planning personnel responsible for
implementing the licensee's emergancy response training program. The training
program was reviewed to determine compliance with the requirements of 10
CFR 50.47(b)(15); 10 CFR Part 50, Appendix E.IV.F; and the emergency plan.
The program review included training requirements for selected emergency
response organization positions, training records for selected individuals
identified as emergency responders, and selected emergency response lesson
plans and workbooks.
4.1 Discussion
" Emergency Response Training Program" Procedure, 1063.021, described the
training required to fill each of the response organization positions through
the use of a matrix listing applicable lesson plans for each position.
Initial training and certification had required satisfactory completion of the
lesson plans applicable to the position along with satisfactory performance on
the emergency drills or exercises appropriate to the position. In order to
maintain emergency response certification, each member of the roster had been
required to satisfactorily complete refresher or continuing training annually
along with the requisite drills or exercises. This retraining had been
completed either through the applicable classroom lesson plans or by a
self-study workbook created for certain positions.
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The inspectors reviewed training records for selected members of the emergency
response organization and found them to be current. The governing procedure
had recuired retraining each calendar year, so even though at least one
indivicual reviewed had last completed a required retraining lesson plan in
April 1991 this individual was current until January 1,1993.
Interviews with emergency response planning and training personnel indicated
that training needs had been determined through workbook and examination
grading, student feedback, and drill and exercise performance evaluations for
both individuals and the emergency response organization as a whole.
Individual needs normally had been addressed immediately after the observed
performance. Standard training feedback forms had been used for emergency
response training. The inspectors determined that emergency response planners f_
had been certified as trainers using the training certification process common
to facility training.
The inspectors reviewed selected lesson plans and noted that they contained
clear and explicit terminal and enabling objectives. Some of the lesson plans
however, were in essence, restatements of those objectives and did not include
the material to be taught. As a result, the quality and consistency of
training depended on the instructor for these lessons. The other lesson plans
reviewed provided detailed information to be covered.
Lesson plan mastery had been determined by an examination generated from an
examination question bank. The examinations reviewed were comprehensive and
appeared to discriminate based on the lesson plan learning objectives. The
examination question banks reviewed appeared to contain a sufficient number of
questions to allow sampling without compromise. g
The inspectors reviewed selected workbooks and noted that they did not
describe their objectives or give any other directions for completing or
grading them. In addition, it was not clear whether workbooks should be
completed individually or the extent to which group effort was acceptable.
The workbooks reviewed contained a broad spectrum of questions regarding a
position's emergency response responsibilities. The workbooks appeared to
limit their coverage to knowledge of the material presented in the applicable
procedures and material developed in response to NRC findings in the most
recent exercise. In accordance with Procedure 1063.10, the application of
this knowledge for retraining had been satisfied with each individual's
participation in a drill or exercise, ,
The inspectors reviewed documentation from training drills and exercises
conducted. The licensee had conducted emergency response drills at least
quarterly. Each of these drills involved one of the emergency response
organization teams and included staffing and activation of all emergency
response facilities. Like. exercises, the scenario for these drills had been
run on the dynamic simulator. The inspectors determined that emergency
response drills had been conducted more frequently than specified in either
the emergency plan or NUREG 0654. The licensee had conducted one drill
quarterly, namely the emergency response organization staffing drill, which
was not described in the emergency plan.
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Drill and exercise documentation was found to include critique findings and
where applicable, corrective action, and followup on self-identified
weaknesses. Corrective actions appeared appropriate, well documented, and
tracked until corrective action was verified. Overall, the number, type, and
manner of conduct by the licensee of emergency response drills was determined
to be a program strength.
4.2 Conclusio2
Timely and effective training had been provided to individuals assigned to the
emergency response organization in accordance with the governing procedure.
The licensee had conducted an excellent program of training drills and
exercises.
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5 KNOWLEDGE AND PERFORMANCE OF DUTIES (82206)
The inspectors conducted a series of walkthroughs on the plant specific
contrcl reem simulators to eva:uate the current knowledge and ability of
personnel assigned emergency response duties in the control room. The
scenarios used in the evaluations were developed by the inspectors to
determine if control room teams were able to classify events accurately,
perform the required notifications in a timely manner, perform offsite dose
assessments, and make adequate protective action recommendations.
5.1 Discussion
One Unit 1 and two Unit 2 crews were observed in their respective simulators.
The scenarios for the two units were very similar, involving a plant shutdown
required by Technical Specifications, followed by partial fuel failure, a
feedwater line break inside containment, and then unisolable failure of a main
steam line and a steam generator tube on the faulted steam generator. This
scenario required initial declaration of a Notification of Unusual Event then
escalated in stages to a General Emergency with an offsite release.
Unit I simulator infidelity caused the unit radiation monitors to all indicate
high and alarmed when the scenario initiated a ramped fuel failure, rather
than just the failed fuel monitor as interded. This required the inspectors
to intervene in the scenario to update the crew on the intended status of the
radiation monitors. Despite this correction, the simulator infidelity
complicated the crew's diagnostic evaluation later in the scenario by
erroneously indicating major fuel damage and obscuring the indications of the
offsite release. During the scenario, a further potential infidelity was that
core exit temperatures remained elevated beyond the expected level with normal
high pressure injection cooling. This required the crew to transition to the
inadequate core cooling procedure which mitigated the core exit indications
when implemented.
The Unit 1 crew initial classification and notification in accordance with the
governing procedure was timely. The notification form was completed by the
Shift Engineer serving as communicator then approved by the Shift
Superintendent prior to transmittal. The initial notification was made within
5 minutes of the event doclaration with the NRC notified within 15 minutes of
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the initial offsite notification. The NRC notification did not indicate that-
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the turit had declared a Notification of Unusual Event but instead indicated
the equivalent of a 50.72 non-emergency notification based on a Technical
Specification required shutdown.
During each scenario, two event reclassifications and subsequent notifications -
were required because of evolving conditions. The first, to upgrade from
Notification of Unusual Event to Site Area Emergency, because of a failure of
automatic and manual reactor trips, was made in a proper and timely fashion.
With respect to the Unit I crew however, the notification erroneously
indicated that a control rod ejection had occurred. .
The second upgrade, to General Emergency, was forced by the failure of the
third fission product barrier. For the Unit 1 crew, the notification of the
General Emergency took longer than 15 minutes, but less than 20 minutes after-
the declaration. - More importantly, the notification form was partially
completed by the communicator and the dose assessor to indicate im)roperly
that no radioactive release was in progress. This error was made 1ecause the
normal release monitors did not indicate a release. In fact, a release was in
progress at the time, and it was bypassing.these monitors. Further, the Shift
Superintendent stated that this declaration was the result of a failure of all
three fission product barriers as well as his correlation of containment
radiation readings to core damage. The notification form transmitted,
however, indicated classification only as a result of containment failure or-
challenge and did not provide any information that significant fuel damage was
indicated. The Shift Superintendent approved the notification message despite
repeated declarations on his part prior to this that ar. unmonitored release-
appeared to be in progress by way of a leak at the main steam line penthouse.
The protective action recommendations developed for the General Emergency
declaration were conservative for the level of' fuel damage indicated by the.
containment high range radiation monitors ar.d consistent with the governing-
procedure.
During the Unit-I crew's scenario, several communications breakdowns were
observed. These included:
e The Shift Superintendent was unaware that the main steam line radiation
monitor for one steam generator inoicated a substantial increase in
secondary activity and that this was for the steam generator that was
depressurized. The majority of the crew did not appear to_ understand
that the depressurized steam generator indicated an increase ir.
radioactivity.
- The dose assessor and the Shift Engineer discussed what dose estimates
could be made but neither discussed with the Shift Superintendent
whether a calculation for an unmonitored release was needed. (See
weakness 313/9227-01; 368/9227-01 below).
e Several members of the crew stated during the scenario that a control
rod ejection had occurred, but the crew never discussed whether the unit
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parameters supported this diagnosis. This misdiagnosis appeared to be
derived from one control rod stuck fully withdrawn.
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e The Shift Superintendent and the Shift Engineer discussed'the two
containment high range radiation monitors' indications as an '.ndication
of core damage but did not discuss with the rest of the crew whether
other plant parameters supported the diagnosis from the single parameter
or whether confirmatory information was available.
Many of the communications breakdowns above are also indicative of a. failure
to establish effective command and control of crew activities. While the
staffing was adequC.e to implement the emergency plan, the communications,
command, and control breakdowns such as those listed above degraded the crew's
ability to effectively diagnose the symptoms and implement the emergency plan
effectively. As a result, the Unit I crew consistently failed to provide
complete and correct information to offsite organizations.
The inspectors discussed the observed performance of the Unit I crew with
emergency planning and Unit 1 operations managers who also observed the
walkthrough evaluation. The facility. managers indicated that the observed
performance by the Unit I crew was not at the level expected and that
retraining would be provided to the crew during the remainder of the
inspection week. The inspectors noted later in the week that the crew was
being provided additional retraining.
The Unit I crew problems noted above were not observed during the other crew -
scenarios with the exception of problems with dose assessment. With the
exception of initial dose assessment from the control room, the other two
crews implemented the emergency plan from the control room effectively.
Command and control and assessment of plant conditions were observed to be
strong with the Unit 2 crews evaluated. At the same time, effective
communications resulted in an enhanced ability to develop a practical
mitigation strategy. Therefore, the inspectors concluded that the performance
problems observed on the part of one of the three crews observed were not
indicative of generic training or emergency response capability weakness-with
the exception of initial dose assessment from the control room. -During the
walkthroughs, problems were observed with all three crews as described below,
relating to their ability to obtain accurate and timely dose assessments
following an unmonitored radiological release,
e A Unit I crew did not provide any dose assessments on an unmonitored
release from a main steam line outside of containment. For 30 minutes
following the declaration of a General Emergency, there were multiple
indications of an unmonitored release out of a steam line. In addition,
members of the crew were aware that one steam line monitor was reading
ten times normal level and that there were radiation levels in
containment of 1.0E7 Roentgen / hour. Despite these indications, the crew
did not discuss whether any dose assessment was available or
appropriate, and dose assessments were neither generated nor pursued.
' * Two Unit 2 crews did not produce a dose assessment for at least
40 minutes following the declaration of a General Emergency and the
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report of a contaminated steam line leak outside of containment. For
each of these crews, there was information available for this length of
time to use in performing the dose assessments such 'as field
measurements quantifying the activity measured downwind at the site
boundary, and primary to secondary leak rate estimates.
e A Unit 2 crew input noble gas release rate data into the incorrect model
parameter which resulted in erroneous dose projections and protective
action recomendations. This dose assessor, who later corrected the
input error, still recomended to the Shift Superintendent erroneous
Protective Action Recomendations based upon the faultad data entry.
The erroneous Protective Action Recommendations indicated evacuation of
downwind sectors not appropriate for the magnitude of the release.
o A Unit 2 crew received a computer error message upon attempting to print
out the initial dose assessment which locked up the dose assessment
terminal. He was unable to overcome this problem by rebooting the
terminal.
The licensee's failure to demonstrate the capability to perform accurate dose
assessments in a timely manner from the control room following an unmonitored
radiological release was identified as a weakness (313/9227-01;368/9227-01).
5.2 Conclusions
Operating crews demonstrated the ability to classify emergency events properly
and in a timely manner and made appropriate protective action recommendations
to offsite authorities. A Unit I crew experienced difficulties in assessing
plant conditions and in making adequate notifications, but the inspectors did
not consider the Unit 1 problems to be indicative of an emergency preparedness
training weakness. A weakness was identified for failures by all three crews
evaluated to perform accurate dose assessments in a timely manner from the
control room following an unmonitored radiological release..
6 INDEPENDENT AND INTERNAL REVIEWS AND AUDITS (82701-02.05)
The inspectors met with quality assurance personnel and reviewed independent
and internal audits of the emergency preparedness program performed since the
last inspection to determine compliance with the requirements of
6.1 Discussion
The last annual audit of emergency preparedness performed in accordance with.
10 CFR 50.54(t) was QAP-13-92 dated July 30, 1992. The inspectors discussed
this audit with the audit team leader and determined that the auditing
organization was independent of the emergency planning management reporting
chain. Audit personnel utilized for the audit included seven individuals
trained and qualified as auditors in accordance with internal quality
assurance procedures. The audit team leader was certified as an audit leader
to ANSI 45.2. Among the audit team was an emergency preparedness technical
specialist from another licensed facility. Documentation of the training and
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_ qualifications of the audit personnel were complete. The-inspectors-
determined that an excellent amount of resources had been directed toward the
audit.
The 50.54(t) audit plan had been developed by the team leader and approved by
quality assurance management prior to conducting the audit. The audit plar,
included areas specified by 10 CFR 50.54(t) as well areas of non-recurring-
scope such as NRC notices and inspection findings. The inspectors determined
that the audit scope and depth were excellent.
Audit findings had been characterized in accordance with QA Operating
Procedure QAO-6, " Interna! Audits." The inspectors reviewed the findings of
the annual audit and found that they appeared to have been properly-
characterized according to their significance. Followup packages on the-
significant findings showed that prompt and proper attention had been directed
toward correcting problem areas. Audit reports had been distributed to-
appropriate functionally responsible organizations and senior-facility
management.
In addition to the required audit, emergency preparedness surveillances had
been conducted by the_ quality assurance organization. Such surveillances had
not typtcally been performed by the licensee; however, the-emergency
preparedness surveillances were prompted by an identified need to assess the
adequacy of corrective actions to NRC exercise weaknesses identified during
the 1991 exercise. The surveillances were conducted in conjunction with
emergency drills and appeared to be well targeted and focused. Surveillance
findings were documented in a similar manner to audit-findings. 1
6.2 Conclusion
Annual internal audits of the emergency preparedness program had been i
conductedinanexcellentmannerinaccordancewith10CFR50.54(t).
Emergency preparedness surveillances were well targeted and. focused.
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ATTACHMENT 1
1 PERSONS CONTACTED
1.1 Licensee Personnel
- C, Anderson, Operations Manager, Unit 2
- H. Cooper, Licensing Specialist
- D. R. Denton, Director, Support
- R. K. Edington, Plant Manager, Unit 2
- C, R. Gaines, Manager, Industry Events Analysis
- B. Jackson, Technical Training Supervisor
- D. James, l.icensing Supervisor
- G. T. King, Superintendent Operations Training i
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J. Orlichek, f,9ntor Lead Quality Assurance Engineer
O. Provencher, Supervisor, Quality Assurance
- J. Taylor-Brown, Acting Director, Quality
- F. Van Buskirk, Emergency Planning Supervisor
- J. D. Vandergriff, Plant Manager, Unit 1
- J. W. Yelverton, Vice President, Operations
- C. Zimmerman, Operations Manager, Unit 1
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1.2 NRC Personnel
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S. Campbell, Resident inspector
1.3 Arkansas Department of Health
J. C. Meyer, Manager, Nuclear Planning and Response Program
- Denotes those present at the. exit interview
2 EXIT MEETING
An exit meeting was conducted on December 11, 1992. During this meeting, the_ j
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inspectors reviewed the scope and findings of the inspection as presented in
this report. The licensee did not identify as proprietary _any of the
materials provided to, or reviewed by, the inspection team during the H
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inspection.
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