IR 05000382/1986004

Insp Rept 50-382/86-04 on 860210-14.Violation Noted: Personnel Assigned to Emergency Organization Inadequately Trained

ML20210K981
Person / Time
Site:	Waterford
Issue date:	04/08/1986
From:	Baird J, Terc N, Yandell L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20210K956	List: IR 05000382/1986004 ML20210K949 ML20210K970
References
50-382-86-04, 50-382-86-4, NUDOCS 8604290134
Download: ML20210K981 (10)

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APPENDIX B U.S. NUCLEAR REGULATORY COMISSION

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REGION IV

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NRC Inspection Report: 50-382/86-04 License: NPF-38 l

Docket: 50-382 Licensee: Louisiana Power & Light Company 317 Baronne Street P. O. Box 60340 New Orleans, Louisiana 70160 o

Facility Name: Waterford 3 Steam Electric Station (SES)

, Inspection At: Waterford 3 SES site near Killona, Louisiana Inspection Conducted: February 10-14, 1986 Inspectors: n ,,)d h '5/2c/PZ J.7. Baird, Emergency reparedness Analyst 06te '

TM.'W a n 't Terc, Emergency r paredness Analyst ght

[ fate Approved: e 023 4/9 fl, l L. A. Yandell, Chief. Emergency Preparedness Difte'

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and Safeguards Programs Section Inspection Summary

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Inspection Conducted February 10-14 1986 (Report 50-382/86-04)

Areas Inspected: Routine, unannounced emergency preparedness inspection in the l areas of emergency detection and classification, protective action decision-( making, dose calculation and assessment, and audits.

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2-Results: Within the emergency response areas inspected, one violation was identified (personnel assigned to the emergency organization not adequately trained paragraph 3).

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DETAILS

- Persons Contacted Louisiana Power & Light

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

"R. Azzarello, Emergency Planning Manager

• P. Backes, Operations Quality Assurance Manager R. Bennett, Operations Support Quality Assurance Supervisor K.'Brewster, Onsite Licensing Thomas Brown, Shift Supervisor Terry Brown, Shift Supervisor

• N. Carns, Assistant Plant Manager, Operations and Maintenance

• F. Englebracht, Manager, Plant Administrative Services J. Hoffpauir, Shift Supervisor H. Herring, Senior Health Physics Technician M. Jones, Shif t Supervisor P. Kelly, Senior Health Physics Technician

• R. Kenning, Radiation Protection Superintendent

• M. Langan, General Training Supervisor H. Leason, Engineer Technical, Nuclear

• J. Lewis, Onsite Emergency Planning Coordinator W. Linares, Senior Health Physics Technician A. Lockhart, Site Quality Manager

• J. Messina, Operations Quality Assurance Representative G. Morrison, Licensing Engineer

• J. O'Hearn, Technical Support Training Superintendent

• D. Packer, Training Manager J. Ray, Senior Health Physics Technician A. Wemett, Control Room Supervisor J. Woods, Quality Control Manager State of Louicis **D. Zaloudek, Louisiana Nuclear Energy Division NRC

• J. Leuhman, Senior Resident Inspector

• Denotes those present at the exit intervie **Telephnne. contac .

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-4-2. Emergency Detection and Classification The NRC inspectors reviewed a sample of the Emergency Action Levels (EALs)

found in the Emergency Plan and in Emergency Implementing Procedure (EIP) EP-01-001, " Recognition and Classification of Emergency Conditions,"

and verified that they were consistent with the initiating events of NUREG 0654, Appendix In addition, the NRC inspectors noted that although the format used in the Emergency Plan differed from that used in the implementing procedure, EALs found in the plan were basically consistent with those in the implementing procedures. Moreover, the NRC inspectors determined through discussions and interviews with various members of the licensee's emergency organization that only EALs found in the implementing procedure (EP-01-001) would be used during emergency conditions at Waterford The NRC inspectors not?d that EALs appeared to be in agreement with NRC guidance and requirements. In addition, the NRC inspectors noted that Final Safety Analysis Report (FSAR) postulated accident conditions were incorporated in the Emergency Plan and the EALs contained provisions for detecting and classifying such incident The NRC inspectors interviewed four shift supervisors and two Assistant Plant Managers who would be Emergency Coordinators during an accident, and determined that they understood the relationships between post-TMI (Three Mile Island) core damage indicators (e.g., containment dome monitors, post-accident primary coolant, containment atmosphere analyses) and core statu No violations or deviations were identifie . Protective Action Decisionmaking and Radiation Protection Response The NRC inspectors reviewed emergency plan implementing procedure EP-2-052, Revision 4, " Protective Action Guidelines," and found that in general the procedure was adequate and that it contained decisonmaking

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guidelines necessary to aid Emergency Coordinators in making protective action recommendations (PARS) according to NRC guidance and criteria. The NRC inspectors found, however, that the procedure forced the user to ascertain road conditions, and other undefined criteria prior to making protective action recommendations. In addition, the inspectors noted that Attachment 7.3 " Evaluation Time Estimate," was not designed in a manner that would facilitate timely decision During the interviews with six Emergency Coordinators, the NRC inspectors posed a simple accident scenario where the containment of the reactor would

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be filled with fission products in such concentrations that indicated more than ' gap' activity. The NRC inspectors additionally stated that there was l no reason to suspect an imminent failure of the containment during the l following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The NRC inspectors selected this scenario because it l was contained as one of the decision conditions in Attachment 7.5, to l EP-2-052, " Flow Chart for Protective Action Decision Making based on core l conditions."

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-5-The NRC inspectors also. interviewed four senior health physics technicians qualified for shift duties and gave them two scenarios designed to test their understanding of two basic tasks they would be responsible for during accident conditions. The NRC inspectors described the first scenario as the declaration of an Alert by the control room during the back shift. The first scenario involved abnormally high general area radiation dose rates (1 Rem per hour) in the control room. The NRC inspectors requested that the technician describe his actions. The second scenario required the technicians to describe their actions and technique to determine whether a radioactive plume contained radiolodin Based on these ten interviews, the NRC inspectors made the following findings:

Two of six Emergency Coordinators were able to find Attachment after a couple of minutes, and used it to make adequate protective action recommendation *

One of six Emergency Coordinators stated that he did not remember having seen the decisionmaking flow-chart during training. Another stated that he would try to enforce protective actions, instead of recommending them to offsite authoritie *

One of the Emergency Coordinators told the NRC inspectors that protective action recommendations could not go beyond precautionary shelter at a General Emergency level unless radioactivity could be measured offsite. This individual appeared to be unaware that protective action recommendations could be escalated based on plant conditions alon *

None of the four health physics technicians understood that the protection of control room personnel should be a priority. As a consequence, none of the technicians stated that they would take a radiation su.vey in the control room to determine habitability conditions until prompted by the interviewe *

Two of four technicians stated that their main concern was to establish if there was a radioactive plume release to the environ *

All the technicians indicated that they would prematurely recommend evacuation of the control room when weekly routine administrative radiation dose limits are exceeded. One out of four made reference to exceeding a 500 mR/hr dose rate in the licensee' procedures for the Operational Support Center, but failed to mention stay times associated with it. Another recalled a 500 mR/hr limit, but stated that he would evacuate the control room if weekly limits were exceede *

Three of four technicians indicated that they either had no training on habitability criteria or failed to understand the material

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None of the technicians were able to direct themselves to written procedures that would provide them with guidance on actions and priorities expected of them during emergencies as senior health physics representatives during back shifts. All of them lacket initiative in taking immediate action for protecting personnel i her than personnel in rMiologically controlled area *

All four technicians erroneously misinterpreted negative radiolodine results as either faulty equipment or concluding that the plume had no radioiodine. Three out of four were unable to describe proper techniques to ascertain whether they were immersed in the plume when they took the air sample. Three out of four were not aware of the need to determine whether they were in fact sampling the radioactive plum The above examples of insufficient training are an apparent violation against the requirements of 10 CFR 50.47(b)(15), which states that

" Radiological Emergency Response Training is provided to those who may be called on to assist in an emergency." (382/8604-01).

4. Dose Calculations and Assessment The NRC inspectors toured the emergency response facilities, examined dose assessment equipment and procedures, and held discussions with selected station personnel to determine what provisions the licensee had made for dose calculation and assessment during a radiological emergency. A representative of the state of Louisiana was also contacted to discuss the state capability and compatibility of dose calculation This discussion indicated that the state used essentially the same techniques and no significant compatibility problems had been identified during previous drills and exercise A review of dose assessment procedures showed that toe licensee had provided manual and computerized methods for rapidly performing emergency dose projections. The dose assessment techniques were implemented in EIP's EP-2-050, "Of f-site Dose Assessment (Manual)" and EP-2-51,"

"Off-site Dose Assessment (Computerized)." The manual methods ranged from a simple nomograph procedure for control room personnel, through various procedures using inplant and offsite monitoring results, to microcomputers programmed to execute all of the methods in the manual dose assessment procedure. The computerized method used the Computerized Emergency Planning and Data Acquisition System (CEPADAS) which operates on real-time data from meteorologicel and radiat';n monitoring instrumentation. In reviewing these procedures, the NRC inspectors noted that the licensee had not provided a method of projecting potential offsite do e based on readings from the containment high range radiation monitors. This deficiency was brought to the licensee's attention and a revision to EP-2-050 incorporating use of these monitors was written and approved prior to the end of the inspection.

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-7-r The NRC inspectors observed demonstration of the nomograph technique of

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dose' assessment in the control room, and use of CEPADAS and the manual methods of assessment with the microcomputer in the Emergency Operations Facilit It was determined that each of the dose assessment techniques could be accomplished in a timely fashion.

t The NRC inspector also discussed the documentation of models and

! verification of factors and data in the dose-assessment procedures with l licensee repre untatives and determined that this was in progress with

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about two-thisds of the manual assessment procedure completed at the time I of the. inspection. In addition, 3 licensee representative stated that a thorough review of the CEPADAS would be initiated in the near future with an evaluation of the capabilities of the system in meeting current and future needs. This area will be reviewed again in a future NRC emergency preparedness inspectio The following is an observation the NRC inspectors called to the licensee's attention. This observation is neither a violation nor an i unresolved item. This item was recommended for licensee consideration for improvement, but it has no specific regulatory requirement.

l o The nomogram procedure in EP-2-050 should identify the current i

effective nomogram revision number to facilitate identification and l

i use of the current revision.

l No violations or deviations were identified.

l S. ),.icensee Audits l Tre NRC inspector determined that the Operations Quality Assurance (QA)

i staff had conducted an independent review (audit) of the emergency preparedness program within a 12-month period in accordance with internal procedures and 10 CFR 50.54(t) requirements. A review of the QA audit report dated August 15, 1985, showed that the audit of the emergency

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program during the period May 29 through June 28, 1985, included an evaluation of licensee drills, exercises, capabilities, procedures and the adequacy of interfaces with state and local governments. The audit also reviewed the licensee's program for identifying and correcting emergency l ~ preparedness deficiencies and weaknesse A review of the audit documentation showed that the audit report and findings were transmitted to appropriate levels of management and the Safety Review Committee Audits Subcommittee for review. It was also noted that responses to the findings were requested from the responsible l organization and the responses were received and evaluated in a timely An abbrulated version of the report involving evaluation of the

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manne adequacy of licensee interfaces with state and local governments was transmitted to these agencies also.

l The Operations QA Manager stated that expertise in emergency preparedness

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for the audit team had been through training of the auditor This will L

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l be enhanced in future reviews by a cooperative arrangement with other utilities which will provide a team member who has expertise equivalent to that of an emergency preparedness coordinato During a review of the audit report, the NRC inspector noted that at least two items identified by the auditors were potential violations or deficiencies and were not so identified. One of the items was difficulty in contacting St. John the Baptist Parish officials within 15 minutes during an unusual event, and the other was a comment that 4 letters of agreement with offsite agencies were overdue for the annual updatin This was brought to the Operations QA Manager's attention and subsequent review of this area by the NRC inspectors prior to the end of the inspection indicated that both of these items had been satisfactorily addresse The NRC inspectors also reviewed the licensee's open action item tracking system and discussed the system with Station personnel to determine if a l

program had been implemented to identify deficiencies and weaknesses discovered during exercises, and to track the items for corrective actions in accordance with the requirements of 10 CFR 50.47(b)(14) and Appendix E to Part 50, Paragraph IV.F.5. It was noted that all emergency preparedness deficiencies and iteme for improvement were entered into the tracking system, including deficiencies and weaknesses identified during postexercise critique The NRC inspectors also determined that corrective actions for items in the tracking system were being taken in an appropriate time frame. This included corrective actions for weaknesses and deficiencies identified during the critique following the previous emergency exercis The following is an observation the NRC inspectors called to the licensee's attention. This observation is neither a violation nor an unresolved ite This item was recommended for licensee consideration for improvement, but it has no specific vegulatory requirement, o Review audit reports for findings which are potential violations, deviations, or deficiencies and identify them as such so that an appropriate level of attention and priority for corrective action can be provided in parallel with the routine QA audit finding corrective action syste No violations or deviations were identifie . Exit Interview The NRC inspectors and NRC senior resident inspector met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on February 14, 1986. The NRC inspectors summarized the purpose and scope of the inspection, and reported the findings which included an apparent violation of requirements to provide adequate trainin .

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, Inadeouate Trainino of Personnel

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10 CFR 50.47(b)(15) requires that radiological emergency a response training be provided to those who may be called on to assist in an emergenc e

,. The Emergency Plan for Waterford 3 states in Section

8.1," Training" that a training prngram has been established in order to mainatain a high degree of preparedness at all e levels of the Waterford 3 emergency organizatio _

Contrary to the above, the NRC inspectors found that t emergency response training had not been adequately provided

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as evidenced by the following:

's During the period February 11-13, 1986, NRC inspectors

,, conducted interviews with six licensee personnel who could have functioned as Emergency Coordinators during an is accident, and four senior health physics technicians who

,, could have been assigned radiation protection responsibil6 ties during an acciden Three of the Emergency

"- Coordinators failed to demonstrate adequate knowledge of the

,, protective action decisionmaking procedures and al1 of the health physics technicians failed to demonstrate adequate

'e knowledge of fundamental radiation protection techniques in

, determining habitability of emergency response facilities and offsite surveys to characterize a radioactive plume o released in an acciden n This is a violation of the same basic requirement for which n a violation (382/0523-01) was identified in NRC Inspection ~~

y Report 50-382/85-2 n M

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