ML20203L883
| ML20203L883 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 03/04/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20203L882 | List: |
| References | |
| 50-458-98-01, 50-458-98-1, NUDOCS 9803060284 | |
| Download: ML20203L883 (20) | |
See also: IR 05000458/1998001
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ENCLOSURE
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.: 50-458
1
License No.: NPF-47 '
Report No.: 50-458/98-01
Licensee: Entergy Operations, Inc.
Facility: River Bend Station
Location: 5485 U.S. Highway 61
St. Francisville, Louisiana
Dates: February 10 to 13,1998
Inspector (s): Gail M. Good, Senior Emergency Preparedness Analyst, Team Leader
Michael E. Murphy, Reactor Engineer
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Thomas H. Andrews, Emergency Preparedness Analyst
Michael C. Hay, Radiation Specialist
Observer: John C. Edgerly, Reactor Engineer
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Approved By: Blaine Murray, Chief, Plant Support Branch
Division of Reactor Safety
Attachment: Supplemental Information
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9803060284 980304
PDR ADOCK 05000458
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EXECUTIVE SUMMARY
River Bend Station
NRC Inspection Report 50-458/98-01
A routine, announced inspection of the licensee's performance and capabilities during the full.
scale, biennial exercise of the emergency plan and implementing procedures was performed.
The inspection team observed activities in the control room simulator, technical support center,
operations support center, and emergency operations facility.
Plant Sucoort
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Overall, performance was generally very good. The control room (CR), technical support
center (TSC), and emergency operations facility (EOF) successfully implemented all
assigned emergency plan functions. Performance in these facilities was very good.
.
The CR crew's performance was very good. Operators promptly responded to plant
events and applied proper mitigating actions. The initiating emergency event was
properly classified. Corresponding offsite agency notifications were correct, and timely.
CR briefings were frequent, structured, and interactive. Normal CR communications,
both intemal and extemal, were very good. Confusion about who was coordinating and
directing operations response teams or individuals could have affected personnel
accountability (Section P4.2).
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The TSC staffs performance was very good. The facility was promptly activated in an
orderly fashion. Event classifications were made in a timely manner using the proper
emergency action levels. Notifications to NRC were accurate and timely. Protective
actions for onsite perso, nel were very good. Tasks and priorities were not clearly
tracked. Habitability surveys were frequently performed but did not include all areas
(Section P4.3).
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The Operations Support Center (OSC) staffs performance was satisfactory. Due to the
potentialimpact on mitigation efforts, the failure to promptly and properly dispatch inplant
response teams was identified as an exercise weakness. It took up to an hour to
dispatch several teams, and some teams, including a high priority team, were canceled
before the teams could be dispatched. Work team order documentation was incomplete
and would have hampered event response reconstruction. Habitability controls were
properly implemented. Team tracking status boards were not always maintained and
could have affected personnel accountability. Good ALARA practices were
demonstrated by radiation protection personnel assigned to assist work teams, although
one team did not use proper contamination controls (Section P4.4).
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The EOF staffs performance was very good. Facility activation was timely and
controlled, although there were no precautions taken for personnel who traveled from the
s
site to the EOF during simulated sevce weather conditions. Management oversight was
very good. Facility briefings were comprehensive and made a positive contribution to
iacility performance. With one relatively minor exception, offsite agency notifications
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were correct and timely. Dose assessment and field team control activities were well
managed and performed to support protective action recommendations. Protective
action recommendations to offsite authorities were correct and timely. Interactions with
offsite response team members were open and informative (Section P4.5).
.
The exercise objectives were appropriate to meet emergency plan requirements. ~ The
initially submitted scenario was not acceptable because it was too similar to the 1996
exercise scenario (two of four events were the same). Appropriate actions were taken
once the concems were raised. The final exercise scenario was sufficiently challenging
to test onsite emergency response capabilities (Section P4.6),
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The critique process was identified as a program strength and was significantly improved
when compared to the 1996 biennial exercise self critique. The evaluation team
identified several important areas in need of correction / improvement (Section P4.7).
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IV. Plant Sunnort !
P4 Staff Knowledge and Performance in Emergency Preparedness
P4.1 ' Exercise Conduct and Scenario Descriotion (82301 and 82302)
The licensee conducted a full-scale, biennial emergency preparedness exercise on
February 11 and 12,1998. The exercise was conducted to test major portions of the
onsite (licensee) and offsite emergency response capabilities. Day 1 consisted of plur a
pathway elements, and Day 2 consisted of ingestion pathway elements. During Day 1,
the licensee activated its emergency response organization and all emergency response
~ facilities. The Federal Emergency Management Agency evaluated the offsite response
capabilities of the state of Louisiana and West Feliciana, East Feliciana, Pointe Coupee,
West Baton Rouge, and East Baton Rouge Parishes. The Federal Emergency
Man 0gement Agency willissue a separate report.
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The exercise scenario was run using the CR simulator in a dynamic mode. The exercise
scenario began at 7:51 a.m., with the plant operating at 100 percent power. Normal
weekday personnel were available for duties. At the start of the exercise, the area was
under a severe thunderstorm and tomado watch with grid perturbations reported due to
the weather. The crew was in Abnormal Operating Procedure 0029, " Severe Weather
Operation," Revision 12. The low pressure core spray pump was tagged out of cervice
for motor inspection, and Condensate Transfer Pump CNS-P1B was tagged out for
replacement of the motor end bearing.
At 8:02 a.m., the CR received telephone notification from a security guard that a tornado
had touched down just south of the turbine building and that there was apparent damage
to the fire pump house.
At 8:06 a.m., a ground on Condensate Transfer Pump CNS-P1 A occurred, but its
breaker failed to trip. ACB300, load center feeder breaker, tripped causing a loss of
480VAC NJS-LDCIL. At 8:07 a.m., the shift superintendent declared an alert based on
Emergency Action Level 14.3 (tomado touchdown onsite). Plant power reduction, at
10 percent per hour, was in progress due to the deteriorating weather conditions.
At 9:01 a.m., an electrical transient caused a fault on Bus 1NNS-SWG1C which resulted
in a trip and lockout of all feeder breakers to the bus. Significant electricalloads affected
were Chiller HVN CHLR1C and 1E22*S004, Division til 4160 volt bus, causing the high
pressure core spray diesel generator to start and tie on to the E22 switchgear.
At 10:01 a.m., a condensate line common header pipe weld cracked causing a leak in
the turbine building. Reactor feed pumps tripped off, a ma..ual reactor scram was
inserted but all rods did not insert, the turbine inadvertently tripped, and alternate rod
insertion and standby liquid control both failed. At 10:05 a.m., the TSC declared a site
area emergency based on Emergency Action Level 7 (anticipated transient without
scram).
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. Shortly thereafter, the CR operators responded to the first turbine building radiation
alarm. As a result, the TSC declared a genomi emergency at 10:17 a.m. based on a
loss of two of three fission product baniers with a potential loss of the third.
At 10:20 a.m., a reactor core isolation cooling steam line break occurred in the steam -
tunnel at the upstream weld on E51*MOVF064, resulting in a reactor _ core isolation
cooling isolation signal on high main steam tunnel temperatures. - The inboard isolation
valve failed to isolate which caused a loss of all high pressure feed and a loss of coolant
accident pathway from the reactor pressure vessel to the steam tunnel. Radioactivny -
was released through the turbine building ventilation system with no charcoal or high
efficiency particulate air filtration.
At 11:11 a.m., all rods were reported in, and the CR personnel continued to work on the
established priorities: recover injection and isolate the leak. At 12:41 p.m., injection was >
reestablished, and the reactor core isolation cooling system was isolated at 1:10 p.m. to
stop the leak. At 1:13 p.m., the CR received confirmation that the release had stopoed
The exercise was terminated at 1:41 p.m.
P4.2 Control Room (CR)
a. Inanection Scone (82301-03.02) ;
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The inspectors observed and evaluated the CR simulator staff as they performed tasks in
response to the exercise scenario conditions. These tasks included event detection and
classification, analysis of plant conditions, offsite agency notifications, intomal and
extemal communications, and adherence to the emergency plan and procedures. The
inspectors reviewed applicable emergency plan sections and procedures, operations
procedures, logs, and notification forms.
b. Observations and Findinas
During the exercise, the CR crew quickly recognized, analyzed, and responded to
emergency events. The shift superintendent declared an alert within minutes of being
informed of the initiating conditions, using the correct emergency action level.
Corresponding offsite agency notifications were made within regulatory time limits. The
pager system activation (emergency response organization call-out) was promptly
activated following the alert declaration. H owever, the wrong code was used and the
resulting activation was for an actual emergency, rather than a drill. When the error we.s
recognized, the shift superintendent immediately ordered another pager system
activation with the proper code. The pagers reactivated with the proper drill
announcement. A plant wide announcement was also made to advise all personnel of
the error.
The CR crew consistently responded to system annunciators using the proper
annunewtor response procedure. The crew exhibited excellent team work. Normal CR
communications, both intemal and external, were very good. However, when the tempo
of events increased, there were instances when expected three-part communications-
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- were not used, and the target individual was not identified. For example, immediately
after the attempt to manually scram and identification of a failure of the plant to scram,
several communications had to be repeated or personnel had to request a repeat of the
communication. Also, at one point the CR supervisor had to forcefally direct all
personnel to ' slow down" in order to refocus proper communicatiens techniques.
Briefings were frequent, structured, and interactive. However, following the activation of
the TSC and OSC, several briefings were conducted to identify field team activities and
locations. There was apparent confusion about who was coordinating and directing the
operations response teams or individuals (i.e., the CR, TSC, or OSC). As a result,
personnel accountability was questionable.
c. Conclusion 6
The CR crew's performance was very good. Operators promptly responded to plant
events and applied proper mitigating actions. The initiating emergency event was
properly classified. Corresponding offsite agency notifications were correct and timely.
CR briefings were frequent, structured, and interactive. Normal CR communications,
both internal and extemal, were very good. When the tempo increased,- there were
instances when expected three-part communications were not used, and the target
individual was not identified. The initial activation of the pager system was incorrect but
did not affect the emergency response. Confusion about who was coordinating and
directing operations response teams or individuals could have aWeted personnel
accountability.
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'4.3 Technical Sucoort Center (TSC)
a. Insoection Scooe (82301-03.03)
The inspectors observed and evaluated the TSC staff as they performed tasks
necessary to respond to the exercise scenario conditions. These tasks included staffing
and activation, accident assessment, NRC notifications, personnel accountability, facility
management and control, onsite protective action decisions and implementation, intemal
and external communications, assistance and support to the CR, and prioritization of
mitigating actions. The inspectors reviewed applicable emergency plan sections,
procedures, and logs.
b. Observations and Findinos
The TSC was staffed and activated in a timely manner. The first responder arrived
immediately after the 8:10 a.m. plant announcement for the alert declaration. Upon
arrival, responders signed in on the position staffing board. The last " minimum staffing"
position was filled at 8:26 a.m., and ihe last person signed in at 8:31 a.m. The TSC was
activated at 8:54 a.m. when emergency director / recovery manager duties were
transferred from the CR.
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The emergency director requested current meteorological cla from dose assessment
personnel, because the alert was based on severe weather, Upon learning that the
current indications showed 45 mph sustained winds, the emergency director asked
security to consider suspending any outside walking patrols and use attemative
methods. The emergency director then cautioned against dispatching any personnel
outside of the buildir'g until the weather abated. The emergency director's actions
demonstrated good awareness of conditions and concern for plant personnel protection.
Upon notification from the CR that the reactor scram was not successful (automatic and
manual), the emergency director promptly declared a site area emergency using the
correct emergency action level. Shortly after the anticipated transient without scram,
plant conditions begati to degrade: reactor water level was dropping, tb core was not
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subcntical, and there was indi(Ation of a :eak within the steam tunnel. Ine emergency
director determined that general emergency conditions existed due to a loss of two
fission product barriers with a potential' ,s of the third. The decision was challenged by
one of the TSC staff to confirm lost /potentially lost barriers. Based on the emergency
director's explanation and th9 available information, the inspectors determined that the
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general emergency declaration was performed properly. The questioning attitude ci the
TSC Waff demoratrated good cross checking.
Following the emergency classification upgrade, a communicator simulated the NRC
notifications. The information provided wap tecurate and timely.
Personnel accountability within the TSC was quickly established and maintained
throughout the exercise. There were three doors into the TSC envelope: one door led
into the computer room ares and was not used, another door led into the main TSC work
area and was quickly disabled to prevent entry into the center, and the other door had a
key card reader for accountability purposes. Participants used the card readei when
enterirg and exiting the center.
Following the site area emergency declaration, a plant evacuation was simulated.
Security perscnnel performed the prccedural actions to determine personnel
accountability. Using simulated information, accountability was properly established
within 30 minutes of the site area emergency declaration.
The emergency director conducted frecuent and comprehensive briefings. The briefings
were announced in advance and contained a F .cussion of priorities. Occasionally, the
briefings contained a summary of previous ever;ts. Functional area coordinators
participated in the briefings.
The emergency director made good onsite protective action decisions and implemented
them approp iately. Examples included:
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The decision to make potassium iodide available to workers was made in
accordance with procedures. Personnel in the TSC and OSC were told to
consider taking potassium iodide before leaving the centers.
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Frequent announcements were made in the TSC and OSC regarding the release
in progress, general direction of the plume, and need to avoid affected areas.
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During the planning discussions for the steam tunnel Ontry, the T3C considered
the increased consumption of ak from self contained breathing apparatuses in
tb high temperature environment. The plans included staging extra air bottles at
the location, prior to actually entering the steam tunnel.
The process for tracking tasks, assignments, and pr%rities was confusing. The TSC staff
used several methods to display tasks, assignments, and prior; ties within the center. A
video link was used to transmit a list of tasks and priorities to the OSC. Tasks and l
priorities were updated and revised as plant conditions changed. A status board was
used to track TSC priorities. A large paper tablet was used to track TSC engineering
tasks. Engineering tasks were listed in sequential order as they wero assigned. On
several occasions, the priorities for the OSC and TSC were not consistent for extended
periods. In addition, the lack of a mechanism to link the engineering tasks to the TSC
priorities could have led to conflicting priorities.
The TSC staff correctly performed dose assessments and projections. TSC personnel
used a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> default release duration time for dose projections. When it appeared that
the release duration woWd exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, doss assessment personnel performed
several calculations to determine the release duration that would cause the
Environmental Protection Agency protective action guidelines to be exceeded at
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10 miles. The result was effectively used to establish / focus equipment repair priorities to
! terminate the release. The inspectors determined that this was a good use of dose
projection capability within the TSC.
TSC habitability surveys, including area radiation surveys, contamination surveys, and
air sample measurements, wer? conducteo frequently but wee not alway;. ; .operly
completed Forexample:
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Area radiation and contamination surveys were only performed in occupied
areas. Rooms that were not routinely occupied were not surveyed. As a result,
contamination could have gone unnoticed.
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The air sampler was placed in the TSC access hallway inside the TSC ventilation
envelope but outside the door used for accountability control. Sir.ce the location
was different ti,an the main TSC work area, the air sample may not have been
representative of the TSC environment.
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The ak sampler was operated through the exercise with the flow rate showing
about 85 titers per minute. The applicable procedure stated that the flow through
the charcoal cartridge was to be about 2 cubic feet per minute. Using the
licensee's procedure, the indicated flow rate was actually about 3 cubic feet per
minute. Since there was no mechanism to adjust the air sampler flow rate, it
appeared that the flow indication was simply an indicator that there was air flow
inrough the sampler at the calibrated flow rate. Following the exercise, the
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licensee detonnined that the actual flow rate was about 2 cubic feet per minute
and that the indicator was in error. Had the flow rate been as indicated, the air
sampling results could have been nonconservative.
c. Conclusion _s
The TSC stdrs performance was very good. The facility was promptly activated in an
orderly fashion. Event classifications were made in a timely manner using the proper
emergency action levels. Notifications to NRC were accurate and timely. Protective
actions for onsite personnel were very good. Precautions were taken for the simulated,
severe weather, arrangements were made for additional air bottles for the steam tunnel
entry, potassium iodide was authorized, and pt'ar.t personnel were cautioned to avoid
areas affected by the plume. Tasks and priorities wem not clearly tracked. Habitability
surveys were frequently performed but did not include all areas.
P4A Qoerations Suooort Center (QSC)
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a. Insoection Scope (82301-03.05)
The inspectors observed and evaluated the OSC staff as they performed tasks in
response to the scenario conditions. These tasks included functional staffing and
emergency response team dispatch and coordination in support of CR and TSC
requests. The inspectors reviewed applicable emergency plan sections, procedures,
logs, checklists, and forms.
b. Observation 1 add Findinas
The OSC was promptly staffed and activated. Activation began shortly after the
8:07 a.m. alert declaration and was completed at 8:54 a.m. The OSC director properly
announced the activation to center personne!.
Center briefings were provided on a regular basis by the TSC (via loudspeakers). The
briefings appropriately addressed plant parameters, current emergency classification,
task priorities, and response team work status. The detail and frequency of the briefings
precluded the need for the OSC director to personally conduct regular OSC briefings.
The process used to form and dispatch teams, coupled with the level of activity and the
distribution of responsibilities, inhibited the OSC's ability to promptly and properly
dispatch response teams. This determination was based on the following observations:
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The OSC director sometimes logged when the TSC notified the OSC to dispatch
a repair team. Using the OSC director'c log and the corresponding team work
order dispatch time, inspectors quantified dispatch times for 6 teams (a total of
16 teams were dispatched). There was insufficient documentation to quantify
dispatch times for the other 10 teams. Of the 6 teams that could be quantified,
4 took opproximately 53-60 minutes to be dispatched following OSC notification
(one may have been 25 57 minutes).
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+ Of the 21 " Team Work Orders" initiated by the OSC director,5 were cancelled
prior to the team being dispatched, because the teams were no longer needed.
As previously mentioned,16 teams were dispatched. One of the cancelled teams
- the number one priority - y " ready to leue the OSC 40 minutes after the
initial TSC request. The team e ince: led because the CR accomplished an
alternate success path.
. The OSC director was actively involved in arranging work team composition.
EIP 2-016, " Operations Support Ceni;r,' Revision 15, Section 4.4, stated that
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work team composition v'as the responsibility of the woA team facilitator and the
OSC manager Similarly, the OSC director handled communications from inplant
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work teams, another OSC manager and/or work team fach!tator duty. The
involvement in team formation and communications inhibited the OSC director's
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ability to provide direction and control.
. Procedurally required documentation was incomplete and would have hampered
event response econstruction. Section 4.2 of EIP 2-016 stated that the OSC
manager wa: t.. ensure that OSC team work orders were completed for all
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dispatched teams. Attachment 1 to EIP 2-016 stated that tne OSC director was
to ensure that work orders were fully completed for teams that had completed
assigned tasks, inspectors identified the following incomplete work orders:
(1) Radiation protection br efing/ debriefing sections were not completed for
3 of 4 teams that were redirected to perform other tasks while in the field.
(2) Of the 16 dispatched work teams,7 work team orders did not include
dicpatch/ return times.
(3) Of the 16 dispatched teams,12 work team orders did not indicate that the
"OSC Director / Manager Task Briefing" was completed.
The failure to promptiv and properly dispatch inpiant field teams was identified as an
exercise weakness because of the potential impact on mitigation effeds
(50-458/9801 01).
Habitability surveys were performed on a regular basis using calibrated instruments.
Radiological survey data sheets were reviewed and found to be detailed and
comprehensive. Habitability controls implemented in the OSC were very good.
The OSC team tracking status board, maintained by the status communicator, was not
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always properly rnaintained and could have adversely affec;ed personnel accountability.
information that was known by the OSC director and/or manager concerning work tear 1
status was not always provided to the status communicator. On one occasion, the OSC
had to contact the CR to find out the location of an individual. In general, work teams
were satisfactorily tracked.
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Teams observed la the field used proper protective clot: Mg, minimizing the potential for
personnel contamination. In contrast, contamination controls were not always properly
performed. !nspectors observed that 3 out of 4 members of r work team, including a
radiation protection technician, passed through a radiological step-off pad without
frisking. Failing to frisk could spread contamination to an uncontrolled area.
Radiation protection personnel assigned to provide work team coverage exhibited good
as low as is reasor, ably achievable (ALARA) job practices. Radiation protection
personnel properly located and informed teams of low dose areas for idle teams / team
members,
c. Conclusions
The OSC staff's performance was satisfactory. */he center was activated in a timely
manner, and briefings were frequent and comp ebensivo. Due to the potentialimpact on
mitigation efforts, the failure to promptly and properly dispatch inplant response teams
was identified as an exercise weakness. It took up to an hour to dispatch several teams,
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and some teams, including a high priority team, were cancelled before the teams could
be dispatched. Work team order documentation was incomplete and would have
hampered event response reconstruction. Habitability controls were property
implemented. Team tracking status boards were not always maintained and could have
affected personnel accountability, Good Al. ARA practices wero demonstrated by
radiation protection personnel assigned to assist work teams, although one team did not
use proper contamination controls.
P4.5 Emergency Ooerations Facility (EOF)
a. Insoection Scooe (8230103.04)
The inspectors observed the EOF's staff as they performed tasks in response to the
exercise. These tasks included facility activation, notification of state and local response
agencies, development and issuance of protective action recommendations, dose
projections, field team control, and direct interactions with offsite agency response
personnel. The inspectors reviewed applicable emergency plan sections and
procedures, forms, dose projections, and logs.
b. Observations and Findings
The EOF was promptly staffed following the 8:07 a.m. alert declaration. Upon arrival,
personnel simulated locking exterior doors, prepared registration forms to log emergency
responders, initiated position checklists, established communications with counterparts,
and determined facility habitability. Activation steps were completed at 8:57 a.m., and
the recovery manager responsibilities (offsite agency notifications, dose
assessment / protective action recommendations) were assumed by the EOF at 9:05 a.rn.
- The transfer of responsibilities was conducted in a controlled manner to ensure that key
response actions were not overlooked or misunderstood.
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Although the EOF was staffed promptly, the safety of facility personnel was not
considered after the ?.lert was declared due to a tomado touctdown onsito. No special
precautions were taken or considered for those personnel who traveled from the site to
the EOF, although precautions were taken for onsite and offsite monitoring teams.
Under some circumstances (e.g., security events and severe weather conditions),
judgement may be needed regarding the decision to activate emergency response
facilities.
Management oversight in the EOF was very good. Briefings were frequent and
comprehensive. Facility members were given prior notice to prepare, and all facility
personnel participated in the briefings. The briefings included input from operations,
radiation protection, engineering, administrative, and state personnel. Special emphasis
was placed on facility priorttles and what effect changing plant conditions would have on
EOF activities. As the exercise progressed, briefings included a summary of previous
significant events. During periods of relatively low activity, facility personnel were
encouraged to review and update individual logs. The recovery manager was also
sensitive to noise levels and distractions. On several occasions, the recovery manager
limited observer access to the EOF.
Offsite agency notifications for the site area and general emergency were made within
the required 15-minute time limit. Short notification m'assage forms were uppropriately
used for classification and protective action recommendation changes. Long notification
- message forms were usually issued, as necessary, to convey changes in release status
l and dose projection data. Inspectors identified two issues conceming the content of the
l long notification message forms.
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There was a discrepancy between the affected sectors used by the utility and the
state which wculd have been confusing to outside organizations (NRC, media,
etc.). The long notification message form for the general emergency (Message 6)
indicated that the affected sectors were D, E, and F. The state included Sector G
because Scenario 4 included some areas within Sector G. This would be
confusing to organizations who would talk to both the state and the utility.
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On one occasion, valuable information was not properly communicated to offsite
autnorities. Although projected doses based on the actual release duration time
(2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />) were appropriately calculated, the information was not included on a
long notification message form. Forms issued after the release stopped
incorrectly stated that there were no projected offsite doses gall zeros).
Protectivo action recommendations, identified as scenario numbers (127 based on
different distances and downwind sectors), were correctly formulated and promptly
communicated to offsite authorities. Following the general emergency declaration, a
default 2 mile radius /5-mile downwind evacuation wa1 correctly recommended
(Scenario 4). When the release rate increa,ed, the r9 commendation was appropriately
upgraded to a 5-mile radius /10-mile downwind evacuation (Scenario 16). As required by
procedures, EOF personnel verified that the offsite agencies received the protective
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action recomrnendations and obtained the approved scenario (protective action
decision).
Dose assessment and field team control activities were wil managed and controlled to
support protective action recommendations. Numerous dose projections were calculated
based on plant conditions and field team data. There was good coordination between
the utility and state offsite monitoring tearns, and utility offsite monitoring team doses
were closely monitored to determine the need to issue potassium iodide.
However, the radiation protection advisor was not fully aware of procedural provisions for
a certain area of responsibility. Specifically, the radiation protection advisor was initially
not aware that EIP 2-024, 'Offsite Dose Calculations," Revision 17, allowed the use of
release duration times greater than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (Step 6.1.8). As previously discussed, dose
projections using the actual release duration time were eventually calculated. The failure
to use the actual release duration time could result in incorrect protective action
recommendations.
Facility habitability was appropriahly monitored during the exerc;ae. When the lock
failed on the EOF door and repairs were initiated, the effect on EOF habitability was
properly determined. Thormoluminescent dosiraeters and pocket ion chambers were
distributed to facility personnel during the activation process. Personnel were reminded
to read pocket ion chambers during periodic briefings.
interactions with state response team members who were stationed in the EOF were
frequent, open, and constructive. Upon arrival, state representatives were briefed on
plant conditions and prognosis. The state's input was solicited during briefings, and
changing plant conditions were quickly relayed so that offsite impact could be evaluated.
c. Conclusions
The EOF staff's performance was very good. Facility activation was timely and
controlled, although there were no precautiors taken for personnel who traveled from the
site to the EOF during simulated severe weather conditions. Management oversight was
very good. Facility briefings were comprehensive and made a positive contribution to
facility performance. With ane relatively minor exception, offsite agency notifications
were correct and timely. A notification made after the release stopped did not include
projected offsite doces. Dose assessment and field team control activities were well
managed and performed to support protective action recommendations. However, the
radiation protection advisar was not initially aware that the release duration time could
exceed the 2-hour default time. Protective action recommendations to offsite authorities
were correct and timely. Intera .;vns with offsite response team members were open
and informative.
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P4.6 Scenario and Exerciss Control
a. Insoection Scope (82301 and 82302)
The inspectors evaluated the exercise to assess the cha!!enge and realism of the
scenario and exercise control.
b. Observations and Findinas
The licensee submitted the exercise objectives and scenario for NRC review on
November 13 and 26,1997, respectively. The exercise objectives were appropriate to
meet emergency plan requirements (reference NRC letter dated December 3,1997). By
letter dated January 22,1998, the licensee was informed that the exercise scenario was
not acceptable. The scenario was rejected, because it was too similar to the 1996
biennial exercise scenario (two of four events were the same), if exercise participants
participated in the 1996 exercise, reviewed the correspondinj NRC report
(60-458/96-07), or were made aware of the outcome during tralning, response actions
could have been affected, it would not be accepabie for exercise participants to have
prior knowledge of exercise scenario events. Appropriate actions were taken once the
concerns were raised. The final exercise scenario was su'ficiently challenging to test
onsite emergency response capabilities.
Due to the initial scenario concern, the inspectors reviewed scenarios used in practice
drills to ensure they did not include exercise scenario events. Emergency planning
I
personnel provided scenario summaries for two integrated drills and three mini-drills.
l Although the scenarios were all different and did not include exercise scenario events,
the inspehrs expressed concerns about the level of pre-exercise training. The
preconditioning was greater than normal and initially caused concerns about whether the
other teams were as pwrared as the exercise team. In response, the licensee explained
that the '. raining was necessary because of a recent erihancement invoMng the CR
simulator. The simulator can now be used to display olant data via computer (in lieu of
using paper data). Moreover, additional training for the other teams was planned
(beginning the week tollowing the exercise). The planne.1 training would include
lessons-leamed by the responding team and mini-drills driven by the simulator. The
licensee's planned actions alleviated the inspectors' concerns.
Inspectors identified one isolated instance r f inappropriate controller / participant
interaction. A controller showed scenario survey data to a radiation protection technician
before the technician earned the data. The technician was not even in the area of
concern.
c. Conclusions
The exercise objectives were appropriate to meet emergency plan requirements. The
initially sut mitted scenario was not acceptable, because it was too similar to the 1996
exercise scenario (two of four events were the same). Appropriate actions were taken ,
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once the concerns were raised. The final exercise scenario was sufficiently challenging
to test onsite emergency insponse capabilities.
P4.7 Licaname Self Craique
a. Inanadion Scope (82301-03.13)
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The inspectors observed and evaluated the licensee's post exercise facility ortiques and
the formal management critique on February 13,1998, to determine whether the process ,
would identify and characterire week or deficient areas in need of corrective action. >
b. Claantations andfindings
Post exercise critiques in the CR simulator, TSC, OSC, and EOF were thorough, open, ,
and seti critical. The post exercise critiques included input from controllers, evaluatorc,
and participants. The lack of participation by state representatives in the EOF detracted .
from the overall completenus. Participants in all facilities made a sincere effort to '
identify areas where performance could be improved.
During the February 13,1998, management critique, the emergency planr5g manager
and lead River Bend Station evaluators presented the preliminary exercise findings. The -t
breakdown of findings was as follows: one area for improvement in the CR/ simulator,
one potential weakness and four areas for improvement in the TSC, one weakness and ,
four areas for improvement in the OSC, and five areas for improvement in the EOF.' The '
potential weakness in the TSC involved TSC habitability, and the weskness in the OSC
involved command and control.
In addition to the River Bend Station evaluators, exercise evaluation was performed by
_ quality assurance personnel, licensee management, representatives from other
Region IV sites, and the Entergy peer review groupc- The peer review group consisted of _
the three emergency planning menagers from the other Entergy sites and
representatives from the Entergy Corporate Office. The integrated critique process was ,
considered a program strength.. There was a significant improvement when compared to
the 1996 biennial exercise self critique. Severalimportant areas in need of correction
vrra identified.
c. Conclualons ;
The critique process was identified as a program strength and was signincantly improved
when compared to the 1996 biennial exercise self critique. The process includod site
evaluators, corporate evaluators, Entergy peer review group, other site evaluators, and
management evaluators. The evaluation team identified several important areas _in need
. of correction / improvement.
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P5 Staff Training and Qualification in Emergency Preparedness
a. Insoection Scope (82701)
The inspectors reviewed the Updated Safety Analysis Report (USAR), plant access
training material, emergency plan, and radiolegical controls procedures to determine if
training requirements and commitments werts being met.
b. Observations and Findings
inspectors noted that Procedure EIP-2 012, * Radiation Exposure Controls," Revision 13, I
stated that 10 CFR Part 20 occupational exposure limits applied to all members of the I
emergency response organization, even if they had not received radiation worker
training. Although the licensee required all personnel to attend plant access trainireg,
which included a brief discuscion of radiation, the training did not include a discussion of
regelatory 1,mits, instructions for frisking, protection of the embryo / fetus per the declared
pregnant female program, etc. Since these topics were only discussed in radiation
worker training, inspectors questioned whether emergency response organization
members received training consistent with 10 CFR Part 19.12. The NRC intends to
pursue this matter as an inspection followup item to determine if Part 19.12 training
applies to emergency response personnel who do not normally receive radiation worker
training (50-458/9801-02).
The licensee's emergency plan stated that all personnel would receive emergency
, plan / procedure training in plant access and radiation worker training as described in the
!
USAR. The inspectors reviewed the USAR description of the general employee training
and compared it to the plant access training content. The USAR stated that the training
would include a discussion of Regulatory Guide 8.13 which discusses the effects of
radiation on the embryo / fetus. This subject was included as part of the licensee's
declared pre 0nant female program but was not discussed in the plant access training.
The inspectors did not have sufficient time to determine if the Regulatory Guide 8.13
subject matter was provided as part of other required training. it.e NRC intends to
pursue this matter as an unresolved item to determine if Regulatory Guide 8.13 training
is conducted in accordance with the USAR (50-458/9801-03).
c. Conclusions
One inspection followup item and one unresolved item were identified involving
personnel training.
V. Management Meetings
X1 Exit Meeting Summary
The inspectors presented the inspection results to members of licensee managernent at the
conclusion of the inspection on February 13,1998. The licensee a : knowledged the facts
presented. No proprietary information was identified.
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! The Federal Emergency Management Agency conducted a public meeting in St. Francisville,
Louisiana, on February 13,1998. Representatives from the Federal Emergency Management
Agency and NRC provided a br'ef discussion of preliminary exercise resuNs,
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ATTACHMENT
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
Licensee
J. McGaha, Vice President, Operations
(A. Bellamy, Directoi, Site Support
M. Dietrich, Director, Quality Programs
J. Hurst, Senior Emergency Planner
J. Fowler, Manager, Quality Assurance
K. Huffstatler, Senior Emergency Planner
R. Jobe, Senior Emergency Planner
M. Jones, Senior Operations Instructor / Emergency Planner
R. King, Director, Nuclear Safety & Regulatory Aftairs
D. Lorfing, Supervisor, Licensing
W. O'Malley, Manager, Operations
P. O'Neil, Specialist, Licensinc
B. Ricketts, Supervisor, He .... Physics Shift
W. Spell, Supervisor, Health Physics Shift
i J. Waid, Director, Training
T. Wyrnore, Control Room Supervisor
Other Personnel
A. Morgan, Manager, Emergency Preparedness, Grand Gulf Nuclear Station
NHC
G. Replogie, Senior Resident inspector
LIST OF INSPECTION PROCEDURES USED
IP 82301 Evaluation of Exercises at Power Reacters
IP 82302 Review of Exercise Objectives and Scenarios for Power Reactors
IP 82701 Operational Status of the Emergency Preparedness Program
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_ _ _ _ _ _ _ _ _ _ . _ _ - _ ___ ___
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LIST OF ITEMS OPENED
Goened
50-458/98001-01 IFl Exercise weakness - Failure to promptly and properly dispatch
aplant response teams (Section P4.4)
l 50 4 8/98001 02 IFl Part 19.12 training for emergency response organization members
(Soction PS)
50 4 58/98001-03 URI Regulatory Guide 8.13 training per USAR (Section PS)
LIST OF ACRGNYMS USED
- Al. ARA As low as is reasonably achievable
l CR Control room
EOF Emergency operations facility
OSC Operations support center
USAR Updated Safety Analysis Report
LIST OF DOCUMENTS REVIEWED
!
Emeroency lmolementina Procedures
EIP 2 001 Classification of Emergencies Revision 9
ElP 2-002 Classification Actions Revision 17
ElP 2-006 Notifications Revision 23
EIP 2-007 Protective Action Recommendation Guidelines Revision 16
EIP-2-012 Radiation F.xposure Controls Revision 13
EIP 2-014 Offsite F diological Monitoring Revision 16
EIP 2-018 Operations Support Center Revision 15
EIP 2-020 Emerg.: f Operations Facility Revision 19
EIP 2 024 Offsite Dose Calculations Revision 17
Other Procedures
AOP-0029 Severe Weather Operation Revision 12
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QJher Documents
River Bend Station Emergency Plan, Revision 16
River Bend Station Updated Safety Analysis Report, Section 13.2.2,' General Employee
Training,' Revision 7, January 1995
EO S LP-GET-PA~ . . 03, 'EOl Plant Access Training,' October 27,1997
EOl S-LP-GET RWT01.05, 'EOl Rad Worker Training," November 5,1997
Prenatal Information Guide for Radiation Workers (undated)
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