ML20137C700
| ML20137C700 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 11/05/1985 |
| From: | Hackney C, Yandell L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20137C682 | List: |
| References | |
| 50-382-85-23, NUDOCS 8511260582 | |
| Download: ML20137C700 (6) | |
See also: IR 05000382/1985023
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APPENDIX B
U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
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NRC Inspection Report:
50-382/85-23
License:
Docket:
50-382
Licensee:
Louisiana Power & Light Company
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142 Delaronde Street
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New Orleans, Louisiana
70174
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Facility Name:
Waterford 3 Steam Electric Station (SES)
Inspection At:
Waterford 3 SES site near Killona, Louisiana
Inspection Conducted:
August 5-9, 1985
Inspector:
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C. A. Hackney, Emergency Preparedness Analyst
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Accompanying Personnel:
D. Schultz, Comex Corporation
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Approved:
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L. A. Yandell, Chief, Emergency Preparedness
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and Safeguards Programs Section
Insjecticn Summary
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Inspection Conducted August 5-9, 1985 (Report 50-382/85-23)
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Areas Inspected:
Routine, unannounced inspection of the licensee's emergency
preparedness program in the areas of knowledge and performance of emergency
response duties.
The inspection involved 92 inspector-hours onsite by two
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NRC inspectors.
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Results: Within the emergency response areas insoected, one violation was
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identified (personnel assigned to emergency organization not adequately
trained
paragraph 3).
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DETAILS
1.
Persons Contacted
Principal Licensee Personnel'
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- R. P. Barkhurst, Plant Manager
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- S. A. Alleman, Assistant Plant Manager, Plant Technical Services
- R. G. Azzarello, Emergency Planning Coordinator
- J. O'Hern, Ganeral Training Superintendent
- J. Lewis, Onsite Emergency Planning-Coordinator
- P. Prasankumar, Technical Support Superintendent
- A. Roberts, Quality Assurance
C. Gaines, Training Department Instructor
- J. Messina, Quality Assurance
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- L. Meyers, Operations Superintendent
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- K. Brewster, Onsite Licensing
- D. Packer, Training Manager
T. Brown, Shift Supervisor
D. Miller, Nuclear Plant Operator
11. Pendergrass, Reactor Operator
M. Bourgeois, Shift Supervisor
A. Bowers, Control Room Supervisor
R. Brinkley, Control Room Supervisor
J. Hampton, Reactor Operator
K. Chester, Nuclear Auxiliary Operator
C. Fugate, Control Room Supervisor
D. Jory, Nuclear Auxiliary Operator
G. Davie, Shift Supervisor
M. Jones, Control Room Supervisor
G. Wemett, Nuclear Plant Operator
J. Hoffpauir, Shift Supervisor
D. Schultz, Control Room Supervisor
H. Miller, Nuclear Plant Operator
NRC
- T. A. Flippo, Resident Inspector
- W. Jones, Resident Inspector
The NRC inspectors also held discussions with other station and corporate
personnel in the areas of, reactor operations, emergency response
organization, and training.
- Denotes those present at the exit interview.
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2.
Licensee Action on Previous Inspection Findings
(Closed) Open Item (382/8402-03) - Training plans for offsite agencies had
been finalized and initiated.
This item is closed.
(Closed) Open Item (382/8402-04) - The training lesson plan had been
revised to include the use of the nomogram.
This item is closed.
(Closed) Open Item (382/8402-05) - Meteorological data selection hierarchy
for dose projections had been included in EP-2-050.
This item is closed.
(Closed) Open Item (382/8402-06) - EP-2-050 had been revised to include
meteorological tower heights in meters and feet.
This item is closed.
(Closed) Open Item (382/8402-07) - Control room walkthroughs were
completed February 27, 1985, using the specified procedures.
This item is
closed.
3.
Knowledge and Performance of Duties
The NRC inspector reviewed selected portions of the Emergency Plan,
Emergency Plan Implementing Procedures (EPIP's), station normal operating
procedures, station off-normal operating procedures, and portions of the
emergency preparedness training program. The NRC inspector also compared
selected station personnel training records with the required retraining
program and determined that the reviewed personnel had received their
required training.
Emergency response walkthroughs were conducted with selected operations
shift supervisors, control room supervisors, reactor operators, nuclear
plan operators and nuclear auxiliary operators.
Prior to the
walkthroughs a meeting was held with selected personnel from operations,
training, and emergency preparedness to review the scenario.
The
scenario was adjusted to reflect conditions that would be plant specific
for the operations personnel.
Walkthroughs were conducted with operations representatives from all five
shifts.
The individuals were given various simulated conditions to
determine their capability to detect and classify an incident.
In
addition they were to make offsite notifications and protective action
recommendations to offsite agencies under simulated incident conditions.
During the walkthroughs, the crews were requested to:
React and respond to specific, simulated indications carrying out
(simulate) actions of plant operating, annunciator response, abnormal,
and emergency procedures.
Classify the evolving plant conditions into one of the four emergency
classifications based on the emergency action levels (EAL).
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Perform all notification actions to site and offsite persons and
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agencies (some notifications were performed, some were simulated).
Perform dose assessment calculations and evaluations for a General
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Emergency classification with no radiological release occurring.
Formulate protective action recommendations based on the dose
assessment evaluations for transmittal to offsite authorities.
Crews were requested to use any procedure that would be referred
to in an actual emergency.
The performance of the crews in the areas mentioned above is detailed
below:
Operators were prompt and correct in their selection, application,
and utilization of Technical Specifications, annunciator response,
and normal /off-normal / emergency operating procedures.
Most crews (3 out of 5) did not utilize " Protective Response Areas"
when formulating protective action recommendations, but used
"Affected Sectors" (22.5 degree sectors, A, B, C, etc.) in messages
transnitted to offsite agencies.
Specifically,'they were unable to
implement paragraph 5.1.2.3 and the succeeding " Note" of tab A.,
" Uncontrolled Release of Radioactivity," of EP-2-052, " Protective
Action Guidelines." Further, one crew did not :Jnderstand that the
"Affected Sectors" are identified as the plume centerline sector and
the two adjacent sectors.
It was also noted that the initial and
followup notification message forms (attachments 7.5 and 7.7 to
EP-2-010) addressed only affected sectors and did not make provisions
for considering " Protective Response Areas."
Two of five crews were unable to make correct protective action
recommendations (PAR) for the conditions of a General Emergency
classification with no release occurring. . Most operators were not
familiar w~ith attachment 7.5 to EP-2-052, " Protective Action
Guidelines." One of five crews formulated the proper PAR, but none
would have completed General Emergency notifications with the PAR in
a prompt manner.
The failure to demonstrate adequate familiarity
with the Emergency Plan and procedures is considered a violation of
the training requirements of 10 CFR 50.47 (b)(15) (382/8523-01).
A similar emergency action level (EAL) is listed for Alert. In trying
to use Attachment 7.1, Tab C, EP-1-001 " Recognition and Classifi-
cation of Emergency Conditions," the Shift Supervisor and chemistry
personnel had no correlation devices available to permit them to
readily determine percentage of failed fuel from observed plant
conditions or instrument readings.
One Shift Supervisor experienced
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difficulty in classifying the EAL dealing with failed fuel when
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'provided with reactor coolant sample isotopic analysis results.
Confusion resulted from being unable to evaluate the " Percentage
Failed Fuel" words of the EAL.
This situation would have resulted in
a non-timely classification of Alert if the shift supervisor had not
been prompted by the NRC inspector.
Operators did not follow or understand all steps of EP-2-050,
" Nomogram Procedure" (Manual Dose Assessment), specifically
step 2.8;" The Nomogram will only produce values for the Exclusion
Area Boundary (EAB), go to attachment 7.3 and use appropriate
worksheet. . . If other values are needed out to 2, 5, and 10 miles."
This resulted in operators recommending unnecessary evacuation of
populations out to 10 miles radius (routinely), when dose rates and
integrated doses were Iris than PAG for evacuation at distances much
less than 10 miles. Ope.ators did not consider evacuation time
estimates and plume travel times when formulating PAR's.
Based on the reviews and observations above, the following items were
discussed with licensee representatives as items which should be
considered for improvement of the emergency preparedness program:
Operating Procedure, OP-500-007, "Annuciator Response for Control
Room Cabinet G," did not refer the operator to OP-901-021, "High
Activity in Reactor Coolant System," for further action steps.
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Attachments 7.1 to 7.8 of EP-2-050, "Offsite Dose Assessment," as
titled on the book separators were not the same as the title of the
procedure.
Plant Operating Manual Index, Volume 4, System Operating Procedure
Section 10, Annunicator Response Procedures A.- Control Room, list
Annunicator responses for control room cabinets A, B, C, etc.
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(procedures numbered similarly) when in fact control room panels are
designated and visibly marked as CP-1, CP-4, and etc.
'As read meteorological conditions include wind speed in meters per
second in the control room, however, manual computational methods
employed by the~ control room operators utilize miles per hour wind
speed.
Having to make the conversion manually caused an error in
computation of dose rate at the exclusion area boundary by one of the
Crews.
Attachment 7.7 to EP-2-010, the followup notification form for
Parish, State, and secondary agencies does not contain all the
information content of message format guidelines of
NUREG-0654, II.E.4.1, specifically projected dose rates and
integrated dose at the projected peak.
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' Attachment 7.1, Tab C, EP-1-001,_" Recognition and Classification of
Emergency Conditions," under Notification of Unusual Event, Item 4
states, " Fuel damage as indicated by Letdown Activity Hi Alarm, D-1
on CP-4, and verified by isotopic analysis indicating an increase of
failed fuel greater than 0.1% in 30 minutes, or failed fuel greater
than 1.0%."
A similar emergency action level (EAL) was listed for
Alert.
No correlation devices were available to the shift
supervisors or chemistry personnel to readily make a determination if
EAL had been exceeded based on plant conditions or instrument
readings relating to percentages of failed fuel.
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" Essential Personnel Emergency Plan Training," attachment 1, to
GE-EP-01, " Emergency Plan Training" does not require course
instructions in protective action guidelines for the positions of
Emergency Coordinator or Senior Reactor Operator (Shift Supervisor is
not listed as an essential persor.nel position).
Only the health
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physics coordinator and assistant require course instruction in this
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topic.
4.
Exit Interview
The exit interview was held August 9, 1985, at the Waterford 3 SES
Administration Building.
The exit interview was conducted by
Mr. C. A. Hackney, Emergency Preparedness Analyst, with Mr. T. A. Flippo,
Mr. W. Jones, the NRC resident inspectors, and Mr. D. Schultz in
attendance.
The licensee was represented by Mr. R. Barkhurst, Plant
Manager, and his staff.
The licensee representatives were given a verbal
summary of the inspectors findings, observations, and comments.
The
licensee representative acknowledged the findings.
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