ML20137C700

Insp Rept 50-382/85-23 on 850805-09.Violation Noted: Personnel Assigned to Emergency Organization Not Adequately Trained

ML20137C700
Person / Time
Site:	Waterford
Issue date:	11/05/1985
From:	Hackney C, Yandell L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20137C682	List: ML20137C675 ML20137C693 ML20137C700
References
50-382-85-23, NUDOCS 8511260582
Download: ML20137C700 (6)

See also: IR 05000382/1985023

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APPENDIX B

U. S. NUCLEAR REGULATORY COMMISSION

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REGION IV

NRC Inspection Report: 50-382/85-23 License: NPF-38

Docket: 50-382

Licensee: Louisiana Power & Light Company

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142 Delaronde Street

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New Orleans, Louisiana 70174

Facility Name: Waterford 3 Steam Electric Station (SES)

Inspection At: Waterford 3 SES site near Killona, Louisiana

Inspection Conducted: August 5-9, 1985

Inspector: M -a li Llcbds e ll T-is

C. A. Hackney, Emergency Preparedness Analyst Date

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Accompanying Personnel: D. Schultz, Comex Corporation

Approved: b nu II-s~ - f s'

L. A. Yandell, Chief, Emergency Preparedness Date

and Safeguards Programs Section

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Insjecticn Summary

Inspection Conducted August 5-9, 1985 (Report 50-382/85-23)

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Areas Inspected: Routine, unannounced inspection of the licensee's emergency

preparedness program in the areas of knowledge and performance of emergency

response duties. The inspection involved 92 inspector-hours onsite by two l

NRC inspectors. '

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Results: Within the emergency response areas insoected, one violation was

l identified (personnel assigned to emergency organization not adequately

trained paragraph 3).

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DR 851114

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DETAILS

1. Persons Contacted

Principal Licensee Personnel'

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, *R. P. Barkhurst, Plant Manager

• S. A. Alleman, Assistant Plant Manager, Plant Technical Services

• R. G. Azzarello, Emergency Planning Coordinator

• J. O'Hern, Ganeral Training Superintendent

• J. Lewis, Onsite Emergency Planning-Coordinator

• P. Prasankumar, Technical Support Superintendent

• A. Roberts, Quality Assurance

C. Gaines, Training Department Instructor

• J. Messina, Quality Assurance

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• L. Meyers, Operations Superintendent

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• K. Brewster, Onsite Licensing

• D. Packer, Training Manager

T. Brown, Shift Supervisor

D. Miller, Nuclear Plant Operator

11. Pendergrass, Reactor Operator

M. Bourgeois, Shift Supervisor

A. Bowers, Control Room Supervisor

R. Brinkley, Control Room Supervisor

J. Hampton, Reactor Operator

K. Chester, Nuclear Auxiliary Operator

C. Fugate, Control Room Supervisor

D. Jory, Nuclear Auxiliary Operator

G. Davie, Shift Supervisor

M. Jones, Control Room Supervisor

G. Wemett, Nuclear Plant Operator

J. Hoffpauir, Shift Supervisor

D. Schultz, Control Room Supervisor

H. Miller, Nuclear Plant Operator

NRC

• T. A. Flippo, Resident Inspector

• W. Jones, Resident Inspector

The NRC inspectors also held discussions with other station and corporate

personnel in the areas of, reactor operations, emergency response

organization, and training.

• Denotes those present at the exit interview.

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2. Licensee Action on Previous Inspection Findings

(Closed) Open Item (382/8402-03) - Training plans for offsite agencies had

been finalized and initiated. This item is closed.

(Closed) Open Item (382/8402-04) - The training lesson plan had been

revised to include the use of the nomogram. This item is closed.

(Closed) Open Item (382/8402-05) - Meteorological data selection hierarchy

for dose projections had been included in EP-2-050. This item is closed.

(Closed) Open Item (382/8402-06) - EP-2-050 had been revised to include

meteorological tower heights in meters and feet. This item is closed.

(Closed) Open Item (382/8402-07) - Control room walkthroughs were

completed February 27, 1985, using the specified procedures. This item is

closed.

3. Knowledge and Performance of Duties

The NRC inspector reviewed selected portions of the Emergency Plan,

Emergency Plan Implementing Procedures (EPIP's), station normal operating

procedures, station off-normal operating procedures, and portions of the

emergency preparedness training program. The NRC inspector also compared

selected station personnel training records with the required retraining

program and determined that the reviewed personnel had received their

required training.

Emergency response walkthroughs were conducted with selected operations

shift supervisors, control room supervisors, reactor operators, nuclear

plan operators and nuclear auxiliary operators. Prior to the

walkthroughs a meeting was held with selected personnel from operations,

training, and emergency preparedness to review the scenario. The

scenario was adjusted to reflect conditions that would be plant specific

for the operations personnel.

Walkthroughs were conducted with operations representatives from all five

shifts. The individuals were given various simulated conditions to

determine their capability to detect and classify an incident. In

addition they were to make offsite notifications and protective action

recommendations to offsite agencies under simulated incident conditions.

During the walkthroughs, the crews were requested to:

• React and respond to specific, simulated indications carrying out

(simulate) actions of plant operating, annunciator response, abnormal,

and emergency procedures.

• Classify the evolving plant conditions into one of the four emergency

classifications based on the emergency action levels (EAL).

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• Perform all notification actions to site and offsite persons and

agencies (some notifications were performed, some were simulated).

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Perform dose assessment calculations and evaluations for a General

Emergency classification with no radiological release occurring.

• Formulate protective action recommendations based on the dose

assessment evaluations for transmittal to offsite authorities.

• Crews were requested to use any procedure that would be referred

to in an actual emergency.

The performance of the crews in the areas mentioned above is detailed

below:

• Operators were prompt and correct in their selection, application,

and utilization of Technical Specifications, annunciator response,

and normal /off-normal / emergency operating procedures.

• Most crews (3 out of 5) did not utilize " Protective Response Areas"

when formulating protective action recommendations, but used

"Affected Sectors" (22.5 degree sectors, A, B, C, etc.) in messages

transnitted to offsite agencies. Specifically,'they were unable to

implement paragraph 5.1.2.3 and the succeeding " Note" of tab A.,

" Uncontrolled Release of Radioactivity," of EP-2-052, " Protective

Action Guidelines." Further, one crew did not :Jnderstand that the

"Affected Sectors" are identified as the plume centerline sector and

the two adjacent sectors. It was also noted that the initial and

followup notification message forms (attachments 7.5 and 7.7 to

EP-2-010) addressed only affected sectors and did not make provisions

for considering " Protective Response Areas."

• Two of five crews were unable to make correct protective action

recommendations (PAR) for the conditions of a General Emergency

classification with no release occurring. . Most operators were not

familiar w~ith attachment 7.5 to EP-2-052, " Protective Action

Guidelines." One of five crews formulated the proper PAR, but none

would have completed General Emergency notifications with the PAR in

a prompt manner. The failure to demonstrate adequate familiarity

with the Emergency Plan and procedures is considered a violation of

the training requirements of 10 CFR 50.47 (b)(15) (382/8523-01).

• A similar emergency action level (EAL) is listed for Alert. In trying

to use Attachment 7.1, Tab C, EP-1-001 " Recognition and Classifi-

cation of Emergency Conditions," the Shift Supervisor and chemistry

personnel had no correlation devices available to permit them to

readily determine percentage of failed fuel from observed plant

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conditions or instrument readings. One Shift Supervisor experienced

difficulty in classifying the EAL dealing with failed fuel when

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'provided with reactor coolant sample isotopic analysis results.

Confusion resulted from being unable to evaluate the " Percentage

Failed Fuel" words of the EAL. This situation would have resulted in

a non-timely classification of Alert if the shift supervisor had not

been prompted by the NRC inspector.

• Operators did not follow or understand all steps of EP-2-050,

" Nomogram Procedure" (Manual Dose Assessment), specifically

step 2.8;" The Nomogram will only produce values for the Exclusion

Area Boundary (EAB), go to attachment 7.3 and use appropriate

worksheet. . . If other values are needed out to 2, 5, and 10 miles."

This resulted in operators recommending unnecessary evacuation of

populations out to 10 miles radius (routinely), when dose rates and

integrated doses were Iris than PAG for evacuation at distances much

less than 10 miles. Ope.ators did not consider evacuation time

estimates and plume travel times when formulating PAR's.

Based on the reviews and observations above, the following items were

discussed with licensee representatives as items which should be

considered for improvement of the emergency preparedness program:

• Operating Procedure, OP-500-007, "Annuciator Response for Control

Room Cabinet G," did not refer the operator to OP-901-021, "High

Activity in Reactor Coolant System," for further action steps.

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• Attachments 7.1 to 7.8 of EP-2-050, "Offsite Dose Assessment," as

titled on the book separators were not the same as the title of the

procedure.

• Plant Operating Manual Index, Volume 4, System Operating Procedure

Section 10, Annunicator Response Procedures A.- Control Room, list

Annunicator responses for control room cabinets A, B, C, etc. I

(procedures numbered similarly) when in fact control room panels are

designated and visibly marked as CP-1, CP-4, and etc.

• 'As read meteorological conditions include wind speed in meters per

second in the control room, however, manual computational methods

employed by the~ control room operators utilize miles per hour wind

speed. Having to make the conversion manually caused an error in

computation of dose rate at the exclusion area boundary by one of the

Crews.

• Attachment 7.7 to EP-2-010, the followup notification form for

Parish, State, and secondary agencies does not contain all the

information content of message format guidelines of

NUREG-0654, II.E.4.1, specifically projected dose rates and

integrated dose at the projected peak.

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• ' Attachment 7.1, Tab C, EP-1-001,_" Recognition and Classification of

Emergency Conditions," under Notification of Unusual Event, Item 4

states, " Fuel damage as indicated by Letdown Activity Hi Alarm, D-1

on CP-4, and verified by isotopic analysis indicating an increase of

failed fuel greater than 0.1% in 30 minutes, or failed fuel greater

than 1.0%." A similar emergency action level (EAL) was listed for

Alert. No correlation devices were available to the shift

supervisors or chemistry personnel to readily make a determination if

EAL had been exceeded based on plant conditions or instrument

readings relating to percentages of failed fuel. ,

• " Essential Personnel Emergency Plan Training," attachment 1, to

GE-EP-01, " Emergency Plan Training" does not require course

instructions in protective action guidelines for the positions of

Emergency Coordinator or Senior Reactor Operator (Shift Supervisor is

not listed as an essential persor.nel position). Only the health

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physics coordinator and assistant require course instruction in this

topic.

4. Exit Interview

The exit interview was held August 9, 1985, at the Waterford 3 SES

Administration Building. The exit interview was conducted by

Mr. C. A. Hackney, Emergency Preparedness Analyst, with Mr. T. A. Flippo,

Mr. W. Jones, the NRC resident inspectors, and Mr. D. Schultz in

attendance. The licensee was represented by Mr. R. Barkhurst, Plant

Manager, and his staff. The licensee representatives were given a verbal

summary of the inspectors findings, observations, and comments. The

licensee representative acknowledged the findings.

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