ML20198M857
| ML20198M857 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 01/15/1998 |
| From: | Ewing E ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-382-97-18, NUDOCS 9801200142 | |
| Download: ML20198M857 (17) | |
Text
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g A Ente y Operations,Inc.
Killona. LA 70066 Tel 504 739 6242
. C. Ewing, m en e, nsgaany new, W3F1-98-0011 A4.05 PR I
January 15,1998 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
Subject:
Waiarford 3 SES Docket No. 50-382 License No. NPF-38 NRC Inspection Report 97-18 Reply to Emergency Preparedness Exercise Weaknesses Gentlemen:
Erstergy Operations, Inc. hereby submits in Attachment 1 the re * .o the emergency preparedness weaknesset documented in the subject inspection report. The reply includes an analysis of each weakness, corrective measures, and a schedule for completing those actions as requested.
in addition, a summary of Waterford 3's Operational Support Center (OSC) Actim Plan is provided as Attachment 2. This plan documents actions taken or schedulea to be taken to addret.s weaknesses in the OSC.
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NRC inspection Report 97 _
Reply to Emergency Preparedness Exercise Weaknesses L W3F1-98-0011 Page 2 January 15,- 1998 :
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if you have any questions concerning this response, please contact Jack Lewis at '
(504) 739-6624 or me at (504) 739-6242.
, Very truly yours,
/
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E.C. Ewing Director, j -- Nuclear Safety & Regulatory Affairs .
,_ ECE/GCS/tmm _
. Attachments:
cc: E.W. Merschoff (NRC Region IV),
C.P. Patel (NRC-NRR), ,
J. Smith, . .
N.S. Reynolds, NRC Resident insr,ectors Office i .
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. Att: chm:nt 1 to l . W3F1-98-0011 Page 1 of 13 ATTACHMENT 1 ENTERGY OPERATIONS. INC. RESPONSE TO THE EMERGENCY EXERCISE ,
WEAKNESSEG DOCUMENTED IN INSPECTION REPORT 97-18 WEAKNESS NO. 50-382/9718-01 A) During the radiological release, personnel were dispatched from the OSC and returned from the -4 foot elevation access point without self-reading dosimeters or equivalent (they were not monitored in transit). Procedure EP-002-130, l " Emergency Team Assignments," Revision 17, Section 5.1.3.4 stated that the OSC health physics liaison will contact the radiation control coordinator and dir. uer. the need to issue dosimetry, protective clothing and/or respirators to team personnel prior to leaving the OSC. There was no record of this discussion.
B) During the release, an individual left the OSC and entered the service building.
The records did not show that the individual left the OSC, nor was the individual briefed on external radiological conditions. Procedure EP-002-190, " Personnel Accountability," Revision 14, Section 5.1.3.1, stated that all OSC personnel shall check out with the applicable maintenance lead or OSC supervisor prior to lenving the OSC. Center management was not charly informed of the individual's destination. Other personnel obsrved the individual leave and reported the information to OSC management; however, there was no record of follow-up actions.
C) Appropriate precautions were not taken for an individual who was added to an existing team. The individual was tasked to obtain parts from the service building and deliver the parts to Team 9 (already at the work location). The individual was instr ":ted to take a route that was different than that used by the team.
However, since the individual's name was just added to the briefing form used for Team 9, no at.ditional radiological requirements were established.
Procedure EP-002-130, "Eraergency Team Assignments," Revision 17, Section 5.1.3.3, stated that the OSC health physits liaison will contact the radiation control coordinator and discuss the routing assigned to the task. Section 5.1.3.4 further stated that the OSC health physics liaison will contact the radiation control coordinator and discuss the need to issue dosimetry, protective clothing and/or respirators to team personnel prior to leaving the OSC. There was no record of this discussion. As a result, the individual was not aware of the ongoing release, not provided a self-reading dosimeter or equivalent, and not briefed on expected dose rates or contamination levels associated with the specified route.
D) Contamination controls for personnel exiting the plant were ineffective due to improper use of portal monitors at the primary access point and the location of the nearest frisker. An individual did not respond properly to alarming portal monitors at the primary access point (the individual added to Team 9). When told that the monitors were alarming, the individual exited through the portal monitor and proceeded to a fnsker outside the protected area. Sirce this i
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Att chm:nt 1 to W3F1-98-0011 Pcg3 2 of 13 l
individual was considered contaminated, the area outside the portal monitors was contaminated. The individual contacted the OSC and was directed to report to the -4 foot elevation access point.
. Health physics personnel were not informed that a contaminated individual had alarmed the portal monitors or had used the frisker. Therefore, a survey of the primary access point was not performed.
E) Personnel contaminations were not investigated to determine where the contaminations originated and what areas had been contaminated by the individuals. This investigation would have highlighted the need to establish better controls for personnel who traveled between the OSC and -4 foot elevation access control point. Moreover, this investigation could have identified the need to assess the dose for the contaminated individual who was added to Team 9.
F) Contamination controls were inconsistently applied between the OSC and the -4 foot elevation access point. Personnel who left the OSC to go to the -4 foot elevation access point were required to wear protective clothing, but personnel who left the -4 foot elevation to return to the OSC were not.
G) Radiological controls were not properly enforced within the OSC At 3:10 p.m.,
there were participants outside the OSC north door who were smoking, even though there was a release in progress at the time, and eating, drinking, smoking, and chewing had been suspended. The sign on the door stated that exit wn not permitted without an OSC supervisor briefing. There were no documents to indicate that this briefina oc;urred.
In addition, these individusts entered the OSC through a rear door and returned to work without frisking. There were no contamination surveys documented for the area outside the OSC rear door. As a result, the OSC could have been contaminated.
Due to the potential impact on personnel safety, the failure to adequately monitor or control radiological exposures and properly establish onsite contamination controls was identified as an exercise weakness (50-362/9718-01).
RESPONSE TO WEAKNESS NO. 50-382/9718-01
- 1. Analysis of the Weakness There are several causes for the failure to adequately monitor or control radiological exposures and properly establish onsite contamination controls.
The causes have been attributed to lack of enforcement of management expectations under simulated and actual emergency conditions, personnel error, and inadequate procedures and training. An analysis of each example cited in the weakness is provided below.
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Attachne ,t 1 to W3F1-98-0011 Page 3 of 13 Examole A During the radiological release, personnel were dispatched from the OSC and returned from the -4 foot elevation access point without self-reading dosimeters or equivalent (they were not monitored in transit). Procedure EP-002-130, " Emergency Team Assignments," Revision 17, Section 5.1.3.4 stated that the OSC health physics liaison will contact the radiation control coordinator and discuss the need to issue dosimetry, protective clothing and/or respirators to team personnel prior to leaving the OSC. There was no recyJ of this discussion.
Example A Analysis An investigation of this occurrence has confirmed there was no record of a discussion of the need for docimetry, protective clothing, and/or respirators for personnel departing the OSC. However, there was a discussion between tie OSC health physics liaison and the radiological controls coordinator (RCC) on these issues. The result of their discussion was a decision not to issue dosimetry, protective clothing and/or respirators to team personnel prior to leaving the OSC because that equipment wouM as procured at the -4 Control Point and their irtention was to route OSC personnel away from any potential or actual release. The RCC and OSC Health Physics technician monitored wind diraction and routed (for the most part, see Examples B and C below) personnel around the plant away from a potential release thinking this would eliminato the need for self-reading dosimeters for personnel in transit from the OSC to the -4 Control Point. The failure to record the discussion was an error N the drill panicipants. The decision not to issue dosimetry was nonconservat.ve because of the release in progress and the fact that meteorological and radiological conditions could change.
Example B During the release, an individual left the OSC and entered the service building. The records did not show that the individual left the OSC, nor was the individual briefed on extemal radiological conditions. Procedure EP-002-190, " Personnel Accountability," Revision 14, Section 5.1.3.1, stated that all OSC personnel shall check out with the applicable maintenance lead or OSC supervisor prior to leaving the OSC. OSC management was .iot clearly informed of the individual's destination. Other personnel observed the individual leave and reported the information to OSC management; however, there was no record of follow-up actions.
Example B Ana:vsis The cause of this occurrence is inadequate communication in that the individual who left the OSC did not clearly inform OSC management that he was going to the service building. Tne individual informed his supervision
- that he was leaving his immediate area, but it was not understood that he was {
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, Att chment 1 to l ,
Page 4 of 13 leaving the OSC. Accordingly, a briefing of radiological conditions outside the OSC was not required and no record of the individual leaving the OSC was documented. This would be the appropriate response given the OSC Supervisor's understanding that the individual was not leaving the OSC.
A contribu'eng cause of this example is inadequate work instructions because of the failure of the OSC exit / entry watch to challenge individue.ls leaving the OSC. Entergy Operations' investigation revealed that OSC exit / entry watches are not receiving adequate instructions when posted as to their responsibility to challenge personnel leaving the OSC to ensure job briefings havo occurred.
When informed of the actual situation and destination, OSC management should have taken more aggressive follow-up action to return the individual to the fecility and determine his potential radiological exposure and reason for his actior.s. At this point, OSC management should also have reinforced the protocol for personnel departing the OSC with this individual and all OSC responders to prevent recurrence during tne response to the emergency exercise events.
Example C Appropriate precautions were not taken for an individual who was added to an existing team. The individual was tasked to obtain parts from the service building and deliver the parts to Team 9 (already at the work location). The individual was instructed to take a route that was different than that used by the team. However, since the individual's name was just added to the briefing form used for Team 9, no additional radiological requirements were established.
Procedure EP-002-130, " Emergency Team Assignments," Revision 17, Section 5.1.3.3, stated that the OSC health physics liaison will contact the radiation control coordinator and discuss the routing assigned to the hsk.
- Section 5.1.3.4 further stated that the OSC health physics liaison will contact the radiation control coordinator and discuss the need to issue dosimetry, protective clothing and/or respirators to team personnel prior to leaving the OSC. There was no record of this discussion. As a result, the individual was not aware of the ongoing release, not provided a self-reading dosimeter or equivalent, and not briefed on expected dose rates or contamination levels associated with the specified route.
Example C Analysis The cause of this example is inadequate communication in that personnel were not made aware of existing personnel routing requirements. The individual assigned to obtain a part from the service building was told by an OSC Instrumentation and Control (l&C) Lead to go directly to the service i building from the OSC to get the required part. The l&C Lead was not aware l
Attuchment 1 to l
W3F1-98-0011 P ga 5 of 13 that a decision had been made to require individuals to go arour'd the turbine building on the east side to the -4 Control Point prior to going to any other location. This decision was made prior to a release occurring and was based on existing wind direction. The route specified by the I&C Lead was contrary to those requirements.
Prior to the !ndividual leaving the OSC, his name was added to a briefing sheet which did include instructions on the correct route to take when traveling outside the OSC. The OSC supervisor assumed that the individual would follow the routing as stipulated in the briefing form. The OSC Supervisor was not aware that the I&C Lead had told the individual to go to the service building. Shortly after beginning his trip to the service building, a release started and the individual was contrninated.
Example D Contamination controls for personnel exiting the plant were ineffective due to improper use of portal monitors at the primary access point and the location of the nearest frisker. An individual did not respond properly to alarming portal monitors at the primary access point (the individual added to Team 9). When told that the monitors were alarming, the individual exited through the portal monitor and proceeded to a frisker outside the protected area. Since this individual was considered contaminated, the area outside the portal monitors was contaminated. The individua! contacted the OSC and was directed to report to the -4 foot elevation access point.
Health physics personnel wero not informed that a contaminated individual had alarmed the portal monitors or had used the frisker. Therefore, a survey of the primary access point was not performed.
Example D Analysis
'ihe causes of this element are the need for improved work instructions (and training) for all Waterford 3 personnel on the proper actions to take v,+1en they cause a portal monitor alarm at the PAP and an inappropriate frisker location.
A contributing cause is inadequate drill control. Although the individual was given a cue that he had alarmed the portal monitor, other (Security) exercise participants in the area were not given the cue of an alarming monitor, therefore it is not known what Security's response would have been (retain the individusi at the PAP for Health Physics surveys) if they had been provided with this cue. In addit lon, the dri!I monitor for this event was replaced when the contaminated exercise participant left the PAP to go to the
-4 Control Point, losing continuity of drill control for this event and leaving no one at the PAP to provice contamination information for Health Physics perconnel if follow-up surveys were performed. Health Physics personnel 3 responded to the PAP subssauent to the departure of the contaminated I individual and the drill centrol monitor. When the responding Health Physics
AttochmQnt 1 to l . W3F1-98-0011 Page 6 of 13
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Technician questioned Security about the individual exiting the portal monitor, Security informed him there was no alarm associated with the individual's exit.
Because of the leck of information provided to Security by drill personnel and the subsequent incorrect information that there was no alarm from the pertal monitor provided to Hoalth Physics personnel, a survey of the pr! mary access point was not performed in any case, the contaminated individual should not have left the PAP to go to the -4 control Point until an investigation of the portal monitor alarm was conducted.
Further investigation of this example noted that the frisker was located on the exit side of the portel monitor as established by security boundaries.
Examole E Personnel contaminations were not investigated to determine where the contaminations originated and what areas had been contantnated by the individuals. This investi0ation wouid have highlighted the neeo to establish better controls for personnel who traveled between the OSC and -4 foot elevation access control point. Moreover, this investigation could have identified the need to assess the dose for the contaminated individual who was added to Team 9.
Example E Analysis The cause of this example is inadequate training. Entergy Operations drill evaluators concluded that training previous to this exercise did not sufficiently challenge Health Physics personnel to censider the ramifications and follow-up actions they should take for an offsite release traveling over the service building or contamination occurring between the OSC and -4 Control Po!at.
Example F Contamination controls were inconsistently applied between the OSC and the
-4 toot elevation access point. Personnel who left the OSC to go to the -4 foot elevation access point were required to wear protective clothing, but personnel who left the -4 fot; elevation to retum to the OSC were not.
Example F Analysis An investigation has identified one individual who was required to wear protective clothing prior to leaving the OSC because OSC management auspected that he was contaminated prior to arrival at the OSC. Therefore, the decision to use protective clothing was made to contain the contamination on the individual and prevent its spread to other areas while in route to the -4 Control Point for decontamination. This example does not represent an inconsistency in contamination controls, but indicates that controls were appropriate for the situation that existed at the time. This item does constitute an example of lack of investigation of personnel contaminations as identified
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Attachment'1 to -
W3F1-98-0011. l
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- in, E above because an adequate investigation of where this individual might
i have gotten contaminated and the impact on other personnel and areas was--
not conducted.' ,
' framole G Radiological controls were not properly enforced within the OSC. ' At 3:10 . f
- p.m., there were' participants outside the OLC north door who' were smoking, even though there was a release in progress at the time, and eating, drinking,-
[ smoking, and chewing had been suspended. The sign on the' door stated that-exit was not permitted without an OSC supervisor briefing. There were no documents to indicate that this briefing occurred. i Examole G Analysis a
The cause of this example was unclear and ambiguous enforcement of -
- - management expectations regarding employee compliance with emergency -
L: response postings, barriers and habitability restrictions and the importance of compliance with any and all restrictions that may be placed in effect during an l'
omergency. These expectations apply equally for drills and actual events. _
- Entergy Oper.1tions notes that the actions described in this example were ,
never deemed acceptable at Waterford 3 and that the analysis provided here refers to the reinforcement and publication of manageinent expectations, not the establishment of restrictions on behaviors that were previously permitted. '
i 2. Corrective Measures .
Waterford 3 has implemented an Operational Support Center (OSC) Action Plan to aodress the above weakness identified in the OSC. The resultant F corrective actions are as follows:
- 1) A letter from the General Manager Plant Operations to all Waterford 3
. employees reiterating management expectations for emergency i
response activities was issued on December 18,1997. This letter s addressed both actual event and drR cssponse expectations. This
' Corrective Measure was completed on December 18,1997. '
- 2) Special training semincrs for OSC responders, Health Physics and Rertwaste personnel will be conducted by the Emergency Planning department to address the lessons learned from this exercise. ' All-
- elements of this exerciso weakness will be addressed. ' Programmatic l ' ctions taken to_ prevent recurrence and the expected actions of a
trainees to' prevent recurrence will be discussed in these seminars.
~ This action will be completed by February 2,1998.
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- 3) The Training Lesson Plan addressing general Operational Support
' Center and emergency team information v ill be revised to include lessons learned from this exercise. All OSC responders including Health Physics and Radwaste personnel receive this course as part of their required training. This action will be completed by February 2, 1998.
- 4) A special OSC training drill.will be conducted without the participation of other emergency response facilities to allow the drill control team to fccus solely on the response of the OSC participants, identify areas for improvement and determine the effectiveness of program changes and ;
training implemented following the exercise. This action will be completed by February 2,1998.
- 5) An OSC Operations Review Group will be established that will include representation from the other Entergy sites as well as a multidiscipline site membership to review OSC operations and make recommendations for improvements to Waterford 3 management.
This action will be completed by April 1,1998.
- 6) Procedures EP 003440, Emergency Equipment Inventory, and EP-002-101, Operational Support Center (OSC) Activation, Operation and Deactivation, were revised to increase the number of self reading dosimeters (SRDs)in the OSC and require issue of SRDs to OSC personnel upon response to the facility. These precedures were
. revised on December 23,1997, with an effective date of January 5, 1998. This Corrective Measure was completed on January 5,1998.
- 7) PAP Portal Monitor exit expectations were reviewed by Health Physics immediately foliowing the exercise. A clarification of the exit expectations for personnel al arming a portal monitor to exit the back of the monitor, ensure Healtn Physics is contacted a- 'or Health Physics to respond to supervise frisking activities was communicated to site personnel through the use of filers provided for pick-up at the PAP upon entry to the plant on November 12,1997. This same flier )
was also mailed to all Waterford employees on November 13,1997.
The clarification on exit expectations contained in the flier was published in the Inside Entergy ste newsletter on November 14,1997.
Supplementas training material on the proper exit procedure was developed and provided for use in the General Employee Training program on Movember 19,1997. The barrier at the PAP that demarcates the friske and portal monitor locations was reconfigured on November 12,1997, to clearly place the frisker behind the portal monitors. This Corrective Measure was completed on November 19, 1997.
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Attrchm:nt 1 to W3F1-98-0011 Pcgs 9 of 13
- 3. Schedule for Cor~-letion of Corrective Actions The Corrective Measures will be completed as stated above. All actions will be completed by April 1,1998.
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Attachment 1 to
.- W3F1-984011 Page 10 of 13 Weakness 50-382/9718-02 The inspectors observed the fire brigade's response to the simulated fire. Procedure i FP-00_1-020, " Fire Emergency / Fire Report," Revision 10, Section 6.7.1.2, stated that the fire brigade shall don fire fighting apparel and self-contained breathing apparatus and proceed to the fire scene. The fire brigade failed to use respiratory
- protection for a fire with toxic smoke in an enclosed space; therefore, personnel cou_id have been impaired or injured. Moreover, the failure to use respiratory protection could have jeop';dized the fire fighting response. Specific observations included:
Personnel did not don the self-contained breathing apparatus before entering the area as required by the fire emergency / fire report procedure.
Not all fire brigade personnel had seif-contained breathing apparatus. The fire brigade member who discovered and reported the fire remained in the area while another fire brigade member went to dress out and bring an extra set of equipment.
The individual only brought one self-contained breathing apparatus.
Due to the potential impact on personnel safety, the failure of the fire brigade to properly use respiratory protection was identified an an exercise weakness (50-382/9718-02).
RESPONSE
- 1. Analysis of the Weakness The cause of this exercise weakness is conflicting procedural requirements.
The Fire Brigade Equipment procedure, FP-001-019, allows the Fire Brigade -
Leader to determins the need for respiratory protection equipment, The Fire Brigade response procedure, FP-001-020, requires the donning cf all equipment by the team, including SCBAs, before proceeding to the ' ire scene.
Because of the guidance of procedure FP-001-019, Fire Brigade members received training contrary to FP-001-020. This training allowed response without SCBAs donned and ready for use at the discretion of the Fire Brigade Leader. In this exercise, the Fire Brigade Leader expected the Fire Brigade
- members to respond with their SCBAs donned and ready for use. The F:re Brigada Leader did not make a decision to relax respiratory protection requirements nor did he notify the Fire Brigade members that they were to respond without SCBAs. A contributing cause to the failure of the team to don respiratory equipment was inadequate drill control. Fire scenario drill control personnel were overly sensitive to the issue of prompting of participants and therefore relied solely on an enlarged photograph to cue response personnel
-of conditions. The photograph adequately depicted smoke, but did not give
- cues such as sounds; smells.or hest that would be present in an actual event.
Attachm:nt 1 to W3F1-98-0011 Page 11 of 13
'2; Corrective Measures
- 1) Fire Brigade response expectations were reiterated in a management position paper distributed to all Fire Brigade members and the lead Fire Brigade trainer from the Gcneral Manager Plant Operations on Novembar 28,1997, s
The FP-001-020 requirement to don all prctective equipment, including respirators, before proceeding to the fire scene was established in this position paper as tha govemirig requirement and to have precedence over the conflicting informatiun in FP-001-019 until such time as the FP-001-019 information could be removed. This position paper also I estab!ished strict acceptance criteria for the use of protective equipment in fire drills. This Corrective Measure was completed on November 28,1997.
- 2) The fire response and equipment procedures will be revised as necessary to include the Fire Brigade response requirements reitt rated in the November 28,1997, management position paper. This will
- include at a minimum the removal of firu response protocols from the equipment procedure. This action will be completed by February 2, 1998.
- 3) Periodic independent observation of routine fire response drills by Emergency Planning and Waterford 3 management have been implemented. Independent observations by Emergency Fianning of routine fire drills were conducted on December 10 and December 17, 1997. The donning of respiratory protective equipment by Fire Brigade members was observed in both drills. This Corrective Measure was completed on December 10,1997, with the first drill observation.
- 4) _Special training seminars on the fire response, lessons leamed from this exercise will be conducted for Fire Brigade members by Emergency Planning and Fire Brigade training personnel. This action will be completed by February 2,1998.
- 5) The drill control lessons learned from this exercise with regard to control of the fire scenario were addressed in the full control team debriefs on November 6,1997, and have been added to training materials for drill control team personnel for future drills. This Corrective Measure was completed on January 5,1998.
- 3. Schedule for Comoletion of Corrective Actions Corrective Measures will be completed as stated above. All ections will be completed by February 2,1998.
l , Attichment 1 to
, W3F1-98-0011 Page 12 of 13 Weakness 50-382/9718-03 1
The protective action recommendation that accompanied the general emergency notification (evacuation of a 2-mile radius and downwind to 5 miles) was properly formulated and quickly communicated; however, the decision to upgrade the protective action recommendations to include three additional protective response areas within 5-10 miles .in the downwind direction was unnecessarily delayed and not communicated to cffsite agencies in a timely manner. At 3:25 p.m., dose projections indicated a need to upgrade the protective action recommendations to include an evacuation of Protective Response Areas A4, C3, and C4. Doses exceeded 1 rem total effective dose equivalent and 5 rem thyroid committed dose equivalent beyond 5 miles.
The EOF director was out of the room when the dose projections first became available. The radiological assessment coordiriator and field team coordinator discussed the dose projection results with the state. The EOF director joined the discussions in progress. The dose projections were characterized as accurate, since they were based on field team results at known distances (pro-determined sampling points).
During the discussions with the state represcntatives, the option of issuing a protective action recommendation that included fewer protective response areas than required by Procedure EP-002-052, " Protective Action Guidelines," Revaion 16, was discussed. The decision to follow the procedure and make the recommendation in the three additional areas was not made until 3:45 p.m. (20 minutes after the information first became available). Offsite agencies were notified at 3:50 p.m.,25 minutes after the information was available. The failure to make a timely protective action recommendction to offsite agencies was identified as an exercisa weakness (50-382/9718-03).
RESPONSE
- 1. Analysis of the Weakness The cause of this weakness is inadequate training, consisting of two elements. The rationale and logic for the guidance in the protectiva action recommendations procedure (EP-002-052) was developed in the early 1980s.
Clear direction was given at that time by the St. Charles and St. John the Baptist parish emergency preparedness directors that protective action recommendations were to be prov;ded using protective response areas and that the protective response area geopolitical boundaries were not to be subdivided when a recommendation was given. Although this direction is still valid today and reflected in the procedure's final product, the means of arriving at this product is not addressed in training for either Waterford or State emergency responders. Therefore, the responders in the exercise spent time discussing an issue (subdivision of protective response areas) that would have been rejected by the parishes and was contrary to the procedure's guidance. More comprehensive training on this procedure is
. Attrchment 1 to
. W3F1-98-0011 l P go 13 of 13 required for both groups of responders that includes the basis and historical perspective for the protective action recommendations contained in the procedare and not just the mechanical methodology for arriving at these protective actions.
The second training element applies to the need for a sense of urgency when arriving at protective action recommendations and timeliness in providing those recommendations to the parishes. Waterford and State responders sre well trained in development and communication of initial protective action recommendations and provide them in a timely manner as evidenced in this exercise. Additional training will be provided to apply this same sense of urgency for protective action recommendations that result in changes to the initial General Emergency recommendations.
- 2. Corrective Measures
- 1) Emergency Planning will provide supplemental training in the form of seminars on the basis and historical perspe@a for the actions called for in the procedure EP-002-052, Protective Action Guidelines. Emphasis on the timing and sense of urgency for changes to initial recommendations will also be provided in this training. The supplemental training will be provided for Waterford and Louisiana Radiation Protection Division (LRPD) personnel responsible for developing and approving protective action recommendations. This action will be completed by March 2,1998.
- 2) Lesson pians for Waterford positions responsible for developing and approving protective action recommendations and the lesson plan for LRPD annual training will be revised to incorporate discussion of this exercise weakness as a lesson learned and to include the information provided in the seminars addressed in Corrective Measure number 1 above. This action will be completed by March 2,1998.
- 3. Schedule for Completion of Corrective Actions Corrective Measures will be completed as staied above.
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. Att: chm:nt 2 to W3F1-98-0011 l ,
P:ge 1 of 2 ATTACHMENT 2 OSC ACTION PLAN immediate 1. Review portal monitor issue, communicate any changes to all site personnel and modify GET as necessary - This will be completed by November 14,1997. STATUS: ALL ACTIONS COMPLETED Short Term 2. Training on Lessons Learned for all OSC responders, Haalth Physics and Radwaste - Special training in the form of seminars will be conducted by the Emergency Planning Department for all OSC responders including Health Phycies and Radwaste personnel by February 2,1998. Lessons learned from this exercise will be addressed. STATUS: ON SCHEDULE Short Term 3. Management expectations will be reiterated for all ERO personnel - The General Manager Plant Operations will reiterate management expectations for Emergency Response Organization personnel by December 15,1997. STATUS: ALL ACTIONS COMPLETED Short Term 4. Revise procedures to require dosimetry to be issued to all OSC personnel upon response to OSC - Procedures to be revised and inventories increased by January 1,1998. STATUS: ALL ACTIONS JOMPLETED Short Term S. Fire brigade response expectations, procedures and brigade member training - Fire briga* response expectations will be reiterated by DeceC sr 1,1997. . ;re response procedures will be revised and improved as required by February 2,1998. Emergency Planning anci managem?at observations of routine fire brigade drills will be implemented by December 1,1997. Special training on the lessons learned from this exercise for fire brigade members will be canducted by Emergency Planning and Fire Brigade training personnel by February 2, 1998. STATUS: ALL ACTIONS DUE BY DECEMBER 1 COMPLETED.
OTHER ACTIONS ON SCHEDULE Short Term 6. Perform an OSC drill including actualiepair team response complicated by an offsite release. Drill to be conducted by February 2,1998.
STATUS: SCHEDULED FOR JANUARY 29,1998 Short Term 7. Revies applicable +. raining lesson plans to includo the lessant leamed from this exercise in future training. Lesson plan revisions to be completed by February 2,1998. STATUS: ON SCHEDULE
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.. Attachment 2 to L -,- W3F1-98-0011
- - . Pege 2 0f 2 Lona Term 8. OS, Operations review group _with representation from other Entergy.
sites Team will assist in the improvement of OSC operational processes.
The review group will consider the move of Health Physics emergency nperations to the OSC. This review group will be chartered by Waterford management and provide final recommendations by April 1,1998.
STA.TUS: ON SCHEDULE Demonstration 9. Demonstrate OSC operations to the NRC . Date to be determined.
STATUS: SCHEDULED FOR FEBRUARY 18,1998 o
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