ML20199G228

Responds to NOV Ltr Re Violation Noted in Insp Rept 50-416/97-15.Corrective Action:Ggns EPIP Will Be Enhanced to Ensure That Air Reserves & Supporting Equipment Are Tracked More Accurately

ML20199G228
Person / Time
Site:	Grand Gulf
Issue date:	11/18/1997
From:	Hughey W ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-416-97-15, GNRI-97-00162, GNRI-97-162, GNRO-97-00113, GNRO-97-113, NUDOCS 9711250128
Download: ML20199G228 (7)

Text

,-

" _-y{h{J[Of Entergy ooerations, Inc.

OV RO. Box 756 Port Gitrean, MS 39150 Tu eci 437-e 70 -

W Hughey e_

uxia s*v a % paw November 18, 1997 O.S. Nuclear Regulatory Commission Mail Station P137 Washington, D.C. 20555 Attention:

Document Control Desk

Subject:

Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 Response to Weaknesses Cited in Emergency Preparedness Report No. 50-416/97-15 (GNRI-97/00162)

Corrected Copy With Cornoletion Dates GNRO-97/00113 Gentlemen:

1 Entergy Operations, Inc. submits the response to inspection weaknesses 50-416/9715-01, 9715-02 and 9715-03 as cited in NRC inspection report 50-416/97-15. The attachments to this letter contain corrective actions and completion dates for the cited items.

This corrected copy supercedes GNRO-97/00111 dated November 14,1997.

Should you have any questions or concerns regarding the attached, please contact Mr. A.C.

Morgan at (601) 437-2721, Yours truly, i

h}l WKH/TMC attachments 1) Response to Exercise Weakness 50-416/9715-01

2) Response to Exercise Weakness 50-416/9715-02

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3) Response to Exercise Weakness 50-416/9715-03

. cc: (See Next Page) 9711.250128 971118 PDR ADOCK 05000416 G

PDR

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. November 18, 1997 GNRO-97/OO113 Pape 2 of 3 cc:

Ms. J. L. Dixon-Herrity, GGNS Senior Resident (w/a)

Mr. L. J.- Smith (Wise Carter) (w/a)

Mr. N.~ S. Reynolds (w/a)

Mr. H. L. Thomas (w/o)

Mr. J. W. Yelverton (w/a)

Mr. Ellis W. Merschoff (w/a)

Regional Administrator U.S. Nuclear Regulatory Commission -

Region IV.

611 Ryan Plaza Drive Suite 400 Arlington, TX 76011 Mr. J. N. Donohew, Project Manager (w/2)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.C. 20555 -

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Attachm:nt 1 to CNRO-97/00113 Page 1 of 2 Corrective Actions Pursusnt to Emergency Preparedness inspection Report 50416/97-15 50 416/9715-01; Exercise Weakness - Failure to monitor and replenish supplies of respiratory protection equipment.

Issue During th' 997 Exercise, inspectors from the Nuclear Regulatory Commission (NRC) determined that there was inadequate adherence to 10-S-01-29, Step 6.3.1.a(2) with regard to the monitoring of Self Contained Breathing Apparatus (SCBA) air supply reserves to affect an adequate supply of breathing air for response teams.

Also, inspectors determined that thers appeared to be insufficient control of SCBA facepiecv usage.

Analysis SCBA Air Reserves The SCBA equipment and supplies are inspected and maintained on a regular schedule to ensure adequate supplies are available when needed. There are approximately 100 one-hour bottles, located at various locations in the protected area and inside the power block, that are available for immediate use in an actual event.

In accordance with 10-S-01-29, the OSC Coordinator is tasked with ensuring that SCBA air supplies are monitored and replenished as necessary. Also, he must ensure that response teams know what supplies are available and where those supplies are located at any given time during the event to facilitate the exchange of air bottles when needed. However, there is no programmatic mechanism in place to provide the OSC Coordinator with the information regarding what air supplies are available.

Facepiece Reuse The SCBA facepieces were not left at the stepoff pad as would normally occur in an actual event. Personnel are trained in Radiological Respirator Training to place their respirator in the receptacles designated by HP or place them in the same receptacle tnut is available for used protective clothing. This action prevents their re-use and re-issue until such time that the respirator facepiece has been properly sanitized, inspected, and returned to service in accordsnce with GGNS procedures.

AttachmCnt 1 ta GNROo97/00113 Page 2 of 2 Whib fealism is important during exercises, GGNS must still maintain the ability to respond to an actual event. To ensure equipment availability would not be significandy impacted in case of

- an actual event, the respirators facepieces were not used. Therefore, during the exercise tearn player briefings, the responders were told that SCBA usage would be limited to donning the equipment, but not breathing though the mask. As a result, the facepieces were 91 removed from their bagsf (The facepiece is placed in a bag after inspections to indicate that it is available for use.) This is done so as not to decrease the ability of the OSC to respond to an actual event, should it occur at the same time that the exercise is in progress.

Results

1. Based on the above information on SCBA air reserves, GGNS agrees that there was inadequate adherence to 10-S-01-29, Step 6.3.1.a(2) with regard to the monitoring of Self Contained Breathing Apparatus (SCBA) air supply reserves to affect an adequate supply of f

breathing air for respoilse teams.

The lack of a programmatic method for tracking the air reserves is the apparent cause for the inadequate procedural compliance.

2. Based on the above information on the perceived inadequate facepiece tracking, GGNS does not agree that there was inadequate control of facepiece use. During an actual event, the facepieces would have been left at the stepoff pad and been no longer available for use.

Also, it is prudent to not remove the protective covering for the facepiece during drills because it reduces the ability of the OSC to respond to an actual event, should it occur during the exercise.

Corrective Measures to be Applied to Resolve issue and Prevent Recurrence The following actions will be taken by 3/30/98.

1. GGNS Emergency Plan implementing procedures will be enhanced to ensure that the air reserves and supporting equipment are tracked more accurately.

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2. Information will be maintained, in the OSC, that provides the current status of those air reserves designated for emergency use.

3. GGNS will ensure that future exercises simulate, in the manner consistent with GGNS procedures, the depletion of SCBA facepieces for response team personnel due to their disposal at the point of removal of the equipment.

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Attachraent 2 t3 CNRO-97/00113 Page 1 of 2 Corrective Actions Pursuant to Emergency Preparedness inspection Report 50 416/9715 50 416/9715 02; Exercise Weakness - Failure to provide protective measures for personnel located in the security island.

Issue During the 1997 Exercise, inspectors from the Nuclear Regulatory Commission determined that there was a failure to provide protective measures for personnel located in the Security Island.

Analysis A review of GGNS procedures found that the Security Plan implementing procedures indicate that safeguards may be suspended in a radiological emergency and that security personnel

- outside the Protected Area, including Security Island, will be evacuated with the rest of the plant population. The expanded security barrier will be maintained at whatever distance is deemed safe by the Emergency Director, if possible, Security personnelinside the Protected Area, including CAS and personnelinside the power block, will relocate to the Control Room envelope. Otherwise, they will evacuate to a location determined by the Emergency Director.

Also, the Security Plan implementing procedures do not provide for the actions of the guard force or suspension of safeguards during simulated radiological emergencies such as drills and exercises.

l Results l

GGNS agrees that there was inadequate discussion between the Security Coordinator and the Emergency Director, and there may be a lack of general procedural guidance on what habitability surveys must be conducted.

l However, GGNS does not agree that there were inadequate protective measures taken for Security Island personnel because under a real evacuation, they would have been moved to a l

safe location as directed by the Emergency Director; thus, not requiring habitability surveys to be completed.

Corrective Measures to be Applied to Resolve issue and Prevent Recurrence The following actions will be taken by 3/30/98.

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1. GGNS Emergency Plan implementing procedures will be enhanced to ensure that there is better communication between the Security Coordinator and the Emergency Director.

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. to CNRO-97/00113 Page 2 of 2 -

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2. GG'NS procedures win be enhanced so that during a site evacuation, any required duty station, such as Security Point of Entry, radiological monitoring will be performed. Should the location require evacuation they will be moved to a new location and periodic monitoring will be resumed, if required.

3. Any proceduraldiscrepancies between GGNS Emergency Plan implementing procedures and those procedures used to implement the Security Plan will be reconciled to ensure that they are consistent with each other.

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to CNRO497/00115 Page 1 of 1 Corrective Actions Pursuant to Emergency Preparedness l

Inspection Report 50-416/9715

_ -416/9715-03; Exercise Weakness - Failure to properly formulate protective action 50 recommendations.

Issue During the 1997 Exercise, inspectors from the Nuclear Regulatory Commission (NRC) determined that there was a failure to properly formulate Protective Action Recommendation (PARS) when several sectors that were downwind of the simulated radiological release were omitted from an Emergency Notification issued to offsite agencies.

Analysis The scenario specified rapidly shifting wind directions that resulted in the rapid change of affected downwind sectors. State briefings were occurring during the wind shift that caused the radiological assessment personnel to become distracted and by the time the personnel were abie to fillin the portion of the Emergency Notification Form, the affected sectors had again changed.

Since the GGNS Emergency Plan requires that PARS be made only on projected dose that can be avoided, the radiological assessment personnel did not feel that they should put the previously affected sectors on the current Emergency Notification Form. Radiological Assessment personnel should have recognized the wind direction changes immediately when they occurred and made the appropriate notifications for those affected sectors.

Results Based on the above information. GGNS agrees that there was a failure to make PARS for several sectors which were subject to short term releases during the rapid wind shift.

Corrective Measures to be Applied to be Resolve issue and Prevent Recurrence The following actions will be taken by 3/30/98.

1. Training will be enhanced for personnel responsible for the formulation of protective action recommendations to ensure that there will be proper management of meteoro!ogical changes during a radiological release.

2. GGNS Emergency Plan procedures will be enhanced to include more specific guidance on the formulation of Protective Action Recommendations and the proper management of meteorological changes during a radiological release.

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