IR 05000382/1985023

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)

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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 w

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)

i 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 inspector '

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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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DETAILS 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 i

• 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

• 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 trainin * Denotes those present at the exit intervie . .

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3 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 close (Closed) Open Item (382/8402-04) - The training lesson plan had been revised to include the use of the nomogram. This item is close (Closed) Open Item (382/8402-05) - Meteorological data selection hierarchy for dose projections had been included in EP-2-05 This item is close (Closed) Open Item (382/8402-06) - EP-2-050 had been revised to include meteorological tower heights in meters and fee This item is close (Closed) Open Item (382/8402-07) - Control room walkthroughs were completed February 27, 1985, using the specified procedures. This item is close . 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 trainin 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 personne Walkthroughs were conducted with operations representatives from all five shift 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 condition 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 procedure * 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 occurrin * Formulate protective action recommendations based on the dose assessment evaluations for transmittal to offsite authoritie * Crews were requested to use any procedure that would be referred to in an actual emergenc 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 procedure * 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 agencie 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 result 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 inspecto :* 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' 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 step f

• 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 procedur * 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, et I (procedures numbered similarly) when in fact control room panels are designated and visibly marked as CP-1, CP-4, and et * '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 Crew * 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 pea .

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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 Aler 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 fue ,

• " 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 topi . 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 finding __ _ - _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _