ML20197F748
| ML20197F748 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 12/24/1997 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Hagan J ENTERGY OPERATIONS, INC. |
| References | |
| 50-416-97-15, NUDOCS 9712300286 | |
| Download: ML20197F748 (5) | |
See also: IR 05000416/1997015
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REoloN IV
611 RYAN PLAZA DRIVE, EUITE 400
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AR UNGToN, T ExAS 79011-a064
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Decernber 24, 1997
Joseph J. Hagan, Vice President
Operations - Grand Gulf Nuclear Station
Entergy Operations, Inc.
P.O. Box 756
Port Gibson, Mississippi 39150
SUBJECT: NRC INSPECTION REPORT 50-416/97-15
Dear Mr. Hagan:
Thank you for your letter of November 14,1997, in response to the exercise
weaknesses identifiert in NRC Inspection Report 50-416/97-15, dated October 9,1997.
We have reviewed your reply and find it responsive to the concerns raised in our inspection
report. We will review the implementation of your corrective actions during a future
inspection.
Sincerely,
Blaine Murray, Chiet
Plant Support Branch
Division of Reactor Safety
Docket No.: 50-416
License No.: NPF 29
cc:
' Executive Vice President
and Chief Operating Officer
' Entergy Operations, Inc.
P.O. Box 31995
Jackson, Mississippi 39286-1995
Wise, Carter, Child & Caraway
P.O. Box 651
Jackson, Mississippi 39205
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9712300286 971224
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. Sam Mabry, Director
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Division of Solid Waste Management
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- Port Gibson, Mississippi 39150
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- Manager of Operations
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Bechtel Power Corporation =
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P.O. Box 2166
Houston, Texas.77252 2166
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General Manager
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- Grand Gulf Nuclear Station
Entergy Operations, Inc.
P.O. Box 756
Port Gibson, Mississippi 39150
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The Honorable Richard leyoub
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' Department of Justice.
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. State of Louisiana
P.0; Box 94005 -
. Baton Rouge, Louisiana 70804-9005
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Office of the Govemor
LState'of Mississippi-
1 Jackson, Mississippi 39201
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Mike Moore, Attomey General-
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Frank Spencer, Asst. Attomey General .
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Dr. F. E. Thompson, Jr.
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VK:e President -
- Operations Support
Entergy. Operations, Inc.-
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F.O. Box 31995
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Jackson, Mississippi 39286 1995-
Director, Nuclear Safety
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Entergy Operations, Inc.
P.0; Box 756
Port Gibson, Mississippi 39150
Vice President, Operations
Grand Gulf Nuclear Station
Entergy Operations, Inc.
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P.O. Box 756
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DISTRIBUTION w/ cooy of licensee's letter dated November 14.1997:
DCD (IE35)
Regional Administrator
Senior Resident inspector (River Bend)
DRS Director
DRS Deputy Director
DRP Director
DRS PSB
Branch Chief (DRP/G)
Project Engineer (DRP/G)
Branch Chief (DRP/TSS)
Senior Resident inspector (Grand Gulf)
MIS System
RIV File
DRS Action item File (97-G-169)
DOCUMENT NAME: G:\\ REPORTS \\GG715AK.GMG
Al 97-G-169
To receive copy of document, indicate in box:"C" = Copy without enclosures "*." = Copy with enclosures "N" = No copy
RIV:PSB
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GMGood:nh ( h6 BMurray })
12/2)97
124@7
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OFFICIAL RECORD COPY
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Entergy Operations, Inc.
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DISTRIBUTION w/ coov of licensee's letter dated November 14.1997:
DCD (IE35)-
Regional Administrator
Senior Resident inspector (River Bend)
DRS Director
DRS Deputy 0; rector
DRP Director
DRS PSB
Branch Chief (DRP/G)
Projed Engineer (DRP/G)
Branch Chief (DRP/TSS)
Senior Resident inspector (Grand Gulf)
MIS System
RIV File
DRS Action item File (97-G 169)
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DOCUMENT NAME: G:\\ REPORTS \\GG715AK.GMG
Al 97-G-169
To receive copy of document, Indicate in box:"C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy
RIV:PSB
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Port Geson. MS 39150
Tel 001437 6470
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W.K.Hughey
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_ Attachment 1 to CNRO-97/00111-
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Page 1 of 2'
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l Corrective Actions Pursuant to Emergency Preparidness
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Inspection Report 50-418/9715
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L50-416/9715 41; Exercise Weakness ~ Failure to monitor and replenish supplies of respiratory -
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. During the 1997 Exercise l inspectors from the Nuclear Reguistory Commission (NRC)-
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= determined that there was inadequate adherence to 10-S 01-29, Step 6.3.1.a(2) with regard to
the monitoring of Self Contained Breathing Apparatus (SCBA) air supply reserves to affect an -
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adequate supply of breathing air for response teams.
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? Also, inspectors determined that there appeared to be insufficient control of SCBA facopiece
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usage.
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- Analysis
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SCBA Air Reserves
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The SCBA equipment and supplies are inspected and maintained on a regular schedule to
- ensure adequate supplies are available when needed. There are approximately 100 one-hour
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bottles, located at various locations in the protected area and hside the power block, that are
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available for immediate use in an actual event.
In accordance with 10-S-01-29, the OSC Coordinator is tasked with ensuring that SCBA air
supplies are monitored and replenished as necessary, Also, he must ensure that response
teams know what supplies are available and where those supplies are located at any given time
during the event to facilitate the exchange of air bottles when needed. However, there is no
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programmatic mechanism in place to provide the OSC Coordinator with the information
regarding what air supplies are available.
Facepiece Rouse -
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The SCBA facepeeces were not 'left at the stepoff pad as would normally occur in an actual
event. Personnel are trained in Radiological Respirator Training to place their respirator in' the ;
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receptacles designated by HP or place them in the same receptacle that is available for used -
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- protective clothing. This action prevents their re-use and re-issue until such time that the
respirator facepiece has been properly sanitized, inspected, arid returned to service in
--accordance with GGNS procedures,
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Attachment 1 to CNRO 97/00111
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Page 2 of 2
While realism is important during exercises, GGNS must still maintain the abinty to respond to
an actual event. To ensure equipment svailability would not be significantly impacted in case of
an actual event, the respirators facepieces were not used. Therefore, during the exercise team
player briefings, the responders were told that SCBA usage would be limited to donning the
equipment, but not bresthing though the mask.- As a result, the facepieces were not removed
from their bags. (The facepiece is placed in a bag after inspections to indicate that it is available
for use.) This is done so as not to decrease the ability of the OSC to respond to an actual event,
should it occur at the same time that the exercice is in progrctss.
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Results
1. Based on the above information on SCBA air reserves, GGNS agrees that there was
inadequate adherence to 10-S-0129, Step 6.3.1.a(2) with regard to the monitoring of Self
Contained Breathing Apparatus (SCBA) air supply reserves to affect an adequate supply of
breathing air for response teams.
The lack of a programmatic method for tracking the air reserves is the apparent cause for
the inadequate procedural compliance.
2. Based on the above information on thefperceived inadequate.facep'iece tracking GGNS
does not agree that there was inadequate controliif facepiece usa D0rir5 actual event,
the facepieces would have been left at the stepoff pad and been no longe
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Also, it is prudent to not remove the protective covering for the facepiece during drills
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because it reduces the ability of the OSC to respond to an actual event, should it occur Jk
during the exercise,
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Corrective Measures to be Applied to Resolve issue and Prevent Recurrence
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The following actions wiil be taken to remedy this issue:
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1. GGNS Emergency Plan implementing procedures will be enhanced to ensure that the air
reserves and supporting equipment are tracked more accurately.
2. Information will be maintained, in the OSC, that provides the cunent status of those air
reserves designated for emergency use.
3. GGNS will ensure that future exercises simulate, in the manner consistent witil GGNS
procedures, the depletion of SCBA facepieces for response team personnel due to their
disposal at the point of removal of the equipment.
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Attachment 2 to GNROc97/00111
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Page 1 of 2
Corrective Actions Pursuant to Emergency Preparedness
inspection Report 50416/9715
50416/9715 02; Exercise Weakness Failure to provide protective mes:,ures for personnel
located in the security island.
Issue
During the 1997 Exercise, inspectors from the Nuclear Regulatory Commission determined that
there was a failure to provide protective measures for perst anellocated in the Security Island.
Analysis
A review of GGNS procedures found that the Security Plan implementing procedures indicate
that safeguards may be suspended in a radiological emergency and that security personnel
outside the Protected Area, including Security Island, will be evacuated with the rest of the plant
population. The expanded security barrier will be maintained at whatever distance is deemed
safe by the Emergency Director, if possible, Security personnelinside the Protected Area,
including CAS and personnel inside the power block, will relocate to the Control Room
envelope. Otherwise, they will evacuate to a location determined by the Emergency Director.
Also, the Security Plan implementing procedures do not provide for the actions of the guard
force or suspension of safeguards during simulated radiological emergencies such as drills and
exercises.
Results
GGNS agrees that there was inadequate discussion between the Security Coordinator and the
Emergency Director, and there may be a lack of general procedural guidance on what
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, habitability surveys must be conducted.
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However, GGNS does not agree that there were inadequate protective measures taken for
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Security Island personnel because under a real evacuation, they would have been moved to a
safe location as directed by the Emergency Director; thus, not requiring habitually st.rveys to b
completed.
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Corrective Measures to be Applied to Resolve issue and Prevent Recurrence
The following actions will be taken to resolve this issue:
1. GGNS Emergency Plan implementing procedures will be enhanced to ensure that there is
better communication between the Security Coordinator and the Emergency Director.
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Attachment 2 to CNRO 97/00111
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Page 2 of 2 -
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2. GGNS procedures will be onhanced so that during a site evacuation, any required duty
station, such as Security Point of Entry, radiological monitoring will be performed. Should
the location require evacuation they will be moved to a new location and e iodic monitonng
will be resumed, if required.
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3. Any procedural discrepancies between GGNS Emergency Plan implementing procedures
and those procedures used to implement the Security Plan will be reconciled to ensure that
they are consistent with each other.
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Attachment 3 to CNRi>97/00111
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Page 1 of 1
Corrective Actions Pursuant to Emergency Preparedness
inspection Roport 50416/9715
50416/9715-03: Exercise Weakness - Failure to properly formulate protective action
recommendations.
Issue
During the 1997 Exercise, inspectors from the Nuclear Regulatory Commission (NRC)
determined that there was a failure to properly formulate Protective Action Recommendation
(PARS) when several sectors that were downwind of the simulated radiological release were
omitted from an Emergency Notification issued to offsite agencies.
Analysis
The scenario specified rapidly shifting whd di;ections that resulted in the rapid change of
affected downwind sectors. State briefings were occurring during the wind shift that caused the
radiological assessment personnel to become distracted and by the time the personnel were
able to fill in the portion of the Emergency Notification Form, the affected sectors had again
changed.
Since the GGNS Emergency Plan requires that PARS be made only on projected dose that can
be avoided, the radiological assessment personnel did not feel that they should pt! the }
previously affected sectors on the current Emergency Notification Form. Radiological -
Assessment personnel should have recognized the wind direction changes immediately when
they occurred and made the appropriate notifications for those affected sectors.
Results
Based on the above information, GGNS agrees that there was a failure to make PARS for
several sectors which were subject to short term releases during the rapid wind shift.
Corrective Measures to be Applied to be Resolve issue and Prevent Recurrence
The following actions will be taken.
1. Training will be enhanced for personnel responsibie for the formulation of protective action
recommendations to ensure that there will be proper management of meteorological
changes during a radiological release.
2. GGNS Emergency Plan procedures will be enhanced to include more specific guidance on
the formulation of Protective Action Recommendations and the proper management of
meteorological changes during a radiological release.