View source for RBG-25801, Responds to NRC Re Violations Noted in Insp Rept 50-458/87-06.Corrective Actions:Training for First Aid & Emergency Notification Process Increased & Procedures EIP-2-017 & EIP-2-102 Revised

{{Adams
| number = ML20209G285
| issue date = 04/22/1987
| title = Responds to NRC Re Violations Noted in Insp Rept 50-458/87-06.Corrective Actions:Training for First Aid & Emergency Notification Process Increased & Procedures EIP-2-017 & EIP-2-102 Revised
| author name = Deddens J
| author affiliation = GULF STATES UTILITIES CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF ADMINISTRATION &amp; RESOURCES MANAGEMENT (ARM)
| docket = 05000458
| license number = 
| contact person = 
| document report number = RBG-25801, NUDOCS 8704300512
| title reference date = 03-23-1987
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 7
}}

=Text=
{{#Wiki_filter:r M
GULF STATES                   UTILITIES COMPANY POSTOFFICEBOX22O e ST            FRANCiSVILLE. LOutsiANA70775 AREACOOE 504 635-3237             387-4257 April 22, 1987 RBG- 25801 File Nos. G9.5, G15.4.1 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Gentlemen:
River Bend Station - Unit 1 Refer to: Region IV Docket No. 50-458/ Report 87-06 This letter responds to the Notice of Violation contained in NRC Inspection Report No. 50-458/87-06. The inspection was performed by Mr.
N. M. Tere during .the period February '23-27,              1987 of activities authorized by NRC Operating License NPF-47 for River Bend Station.
Gulf States Utilities Company's (GSU) response to Notice of Violation 8706-01, " Failure to Perform Training", and to Deficiencies 8706-02, 8706-03, and 8706-04 are provided in the enclosed attachments pursuant to 10CFR2.201. This completes GSU's response to these items.
Sincerely, Senior Vice President River Bend Nuclear Group JCD/         / LA/je Attachments cc:   Mr. Robert D. Martin, Regional Administrator
             'U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 NRC Resident Inspector P.O. Box 1051 St. Francisville, LA 70775 B                                                        N b

(MITED SBES & ABERICA M]CIEMt parTirATCur a3egSSI(m sum!: OF IOUISIANA
* PARISH & WiST FELICIANA
* In the Matter of
* Docket Nos. 50-458 GHF SDGES UTILITIES CCB@ANY                             *
(River Bend Station, Unit 1)
AFFIDAVIT J. C. Deddens, being duly sworn, states that he is a Senior Vice President of Gulf States Utilities Canpany; that he is authorized on the part of said Ocznpany to sign and file with the Nuclear Regulatory Carmission the documents attached hereto; and that all such du-nts are true and correct to the best of his knowledge, information and belief.
                                                                                  /
J. 7.'Deddens Subscribed and sworn to before me, a Notary Public in and for the State and and Parish above named, this/ M day of                               )n f ,19h
                                                                       < / t-t s t          1,                                                                                                       . th    Y
                                                                       /Joan W. Middlebrooks
                                                                       *~ Notary Public in and for West Feliciana Parish, Louisiana My Camission is for Life.
_ _ _ _ - - _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ - - - - - - - - - - - - - - - - - - - - - - - - - - . _ _ _ _   __J

ATTACHMENT 1 RESPONSE TO NOTICE OF VIOLATION 50-458/8706-01 LEVEL IV REFERENCE Notice of Violation     -
J. E. Gagliardo letter to J. C. Deddens, dated March 23, 1987.
FAILURE TO PERFORM TRAINING 10CFR50.54(q) requires that licensees shall follow and maintain in effect emergency plans which meet the standards in 10CFR50.47(b) and the requirements in Appendix E to Part 50.
10CFR50.47(b)(15) requires that radiological emergency response training be provided to those who may be called on to assist in an emergency.
10CFR50, Appendix E, paragraph IV.F requires, in part, that specialized initial training and periodic retraining be provided to first aid teams.
River Bend Station Emergency Plan, Section      13.3.7.1.1.2,   " Specialized Training," states, in part, that first aid and rescue personnel will receive training, at least annually, in both Red Cross Multi-Media First Aid and in the Special Handling of Radioactively Contaminated Personnel.
Contrary to the above, on February 25, 1987, the NRC inspector determined that first aid and rescue personnel had not received specialized annual retraining in handling injured and contaminated persons.
This is a Severity Level IV violation.
REASON FOR THE VIOLATION Although training in the special handling of injured and radioactively contaminated personnel was conducted, this program was presented as a separate training course and was not incorporated into Emergency Response    Organization training requirements;      therefore,   scheduling personnel for this training was inconsistent with emergency plan requirements.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED A review of personnel assigned to the First Aid Team indicates a sufficient number have received the appropriate Multi-Media First Aid Training and Annual First Aid for Radiological Accident Victims Training to meet the on-shift requirements.         These individuals have       been identified to Operations so that only currently trained individuals will be assigned to the First Aid Team.

ATTACHMENT 1 (CONT'D)
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN TO AVOID FURTHER VIOLATIONS i
GSU will schedule additional NE0/NCO personnel to attend Red Cross       !
Multi-Media      First Aid or equivalent training and First Aid for      l Radiological Accident Victims training to ensure adequate long term coverage of this function.
The First Aid and Handling Injured and Contaminated Individual's training will be incorporated into Module 7 of the Emergency Response Organization training program.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Trained and qualified individuals were identified to Operations on March 4, 1987.
Additional personnel will be trained in First Aid and Handling Injured and Radiologically Contaminated Persons by September 1, 1987.
First Aid and Handling Injured and Contaminated Persons training will be incorporated into Module 7 of the Emergency Response Organization training program by September 1, 1987. Annual training on this module is an existing requirement in procedure EIP-2-102, Training, Drills and Exercises.
i l

ATTACHMENT 2 RESPONSE TO DEFICIENCY 50-458/8706-02 REFERENCE Letter - J. E. Gagliardo letter to J. C. Deddens, dated March 23, 1987.
DESCRIPTION No sampling for radioactive contamination was performed in the Control Room during the emergency exercise.      No radiological controls were observed in the Control Room as prescribed in Procedure EIP-2-013, "Onsite Radiological Monitoring".
GULF STATES UTILITIES COMPANY'S RESPONSE EIP-2-013 "Onsite Radiological Monitoring", Rev. 3, Section 4.1.4 states    that   the   Emergency   Director shall " Periodically Direct Radiological Surveys of the Control Room, Operations Support Center (OSC), and Technical Support Center (TSC) to ensure habitability during re? eases of radioactive materials within the plant." However, the scope of the procedure has been limited by stating in section 1.0 that the
    " procedure provides instructions for performing radiological surveys in the plant and onsite out-of-plant during a radiological emergency", and in Sections 3.1 and 3.2 that "onsite radiological surveys are performed for two basic purposen.       One is to support Emergency Response Team efforts inside the plant building. The second is to verify release assumptions by monitoring the area outside but adjacent to the plant building", and "to minimize radiation exposures to Radiation Protection personnel, general area surveys inside the plant shall not usually be conducted during an emergency." With these limitations on the scope of the procedure, no mechanism exists directing the Emergency Director to refer to this procedure for habitability requirements.
The need to perform habitability surveys in the Control Room was discussed with the affected Emergency Director. The Nuclear Training Department has been directed to emphasize the need            to   perform radiological surveys in the Control Room to OSC Coordinators and Radiological Protection Technicians during the 1987 training cycle.
Section 4.1.4 of EIP-2-013 will be deleted from the procedures. It is not within the scope of the procedure and is redundant with sections that are or will be in other procedures.
A step will be added to EIP-2-017 " Operations Support Center - Support Functions", Section 4.1.1 directing the OSC Coordinator to periodically dispatch a habitability technician to        monitor    the   radiological conditions in the Control Room. EIP-2-013 and EIP-2-017 will be revised during the annual review and update by August 31, 1987.

ATTACHMENT 3 RESPONSE TO DEFICIENCY 50-458/8706-03 REFERENCE Letter - J. E. Cagliardo to J. C. Deddens, dated March 23, 1987.
DESCRIPTION The conduct of operations in the OSC was not conducive to efficient coordination and direction of in-plant teams. When the OSC Coordinator was required to attend meetings at the TSC, in-plant teams were unable to obtain proper direction and coordination from the person relieving the OSC Coordinator. This caused considerable delays in the performance of certain in-depth tast:s and caused the potential for unnecessary radiation exposure of team members.
GULF STATES UTILITIES COMPANY'S RESPONSE In an effort to improve the OSC's response capabilities, the OSC Coordinator was recently directed to attend the TSC staff briefings.
This had not previously been done. When this practice was instituted, it was found that no position was designated to assume direction of the OSC.
The Radiation Protection Foreman position has been designated to assume direction of the OSC when the OSC Coordinacor is not available.
EIP-2-017, " Operations Support Center -        Support   Functions",   and EIP-2-102, " Training, Drills, and Exercises," will be revised to reflect the designation of the Radiation Protection Foreman as the              OSC Coordinator in his absence.         This item will be emphasized during the 1987 Emergency Plan training cycle and drill program. EIP-2-017 and 102 will be revised during the annual review and update by July 31, 1987.
Training will be completed by November 30, 1987.

ATTACHMENT 4 RESPONSE TO DEFICIENCY 50-458/8706-04 REFERENCE Letter - J. E. Gagliardo to J. C. Deddens, dated March 23, 1987.
DESCRIPTION Notifications to parish representatives pertaining to the General Emergency Declaration were delayed.       Total notification time was 21 minutes after declaration. The initial protective action recommendation took 32 minutes to make. These times exceeded the capabilities required by 10CFR50, Appendix E, paragraph IV.D.3.
GULF STATES UTILITIES COMPANY'S RESPONSE The River Bend Nuclear Station must transmit the Notification Message Forms to 8 state and local agencies. Each of these agencies can and frequently does ask questions about the message content.      This results in excessive delay in message transmission (11 minutes in one case and over 20 minutes in the other).
It should be noted that the times it took to complete notifications were correctly identified by the NRC. However, the 32 minutes notification time did not occur during the initial Protective Action Recommendations (PAR) notification but rather during the first follow-up notification message. The delay occurred when one parish (East Feliciana) failed to respond to the initial all call and had to be contacted after the message was transmitted to the other state and local agencies.
Emergency Preparedness and the Nuclear Training          Department    have conducted additional training on the Notification process. This has reduced the time needed for notifications from that previously required.
However, it is not anticipated that additional training or practice will appreciably reduce the time to make notifications.
GSU is currently pursuing an alternate method for making              these notifications so that a hardcopy of the approved notification message form with PARS would be transmitted to all points in a sorter timeframe.
The alternate method will be implemented prior to the next scheduled NRC evaluated emergency preparedness exercise.}}