IR 05000458/1998001

Insp Rept 50-458/98-01 on 980210-13.No Violations Noted. Major Areas Inspected:Licensee Performance & Capabilities During Fullscale,Biennial Exercise of Emergency Plan & Implementation Procedures

ML20203L883
Person / Time
Site:	River Bend
Issue date:	03/04/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20203L882	List: ML20203L879 ML20203L883
References
50-458-98-01, 50-458-98-1, NUDOCS 9803060284
Download: ML20203L883 (20)

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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-458

License No.: NPF-47 '

Report No.: 50-458/98-01 Licensee: Entergy Operations, In Facility: River Bend Station Location: 5485 U.S. Highway 61 St. Francisville, Louisiana Dates: February 10 to 13,1998 Inspector (s): Gail M. Good, Senior Emergency Preparedness Analyst, Team Leader Michael E. Murphy, Reactor Engineer

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Thomas H. Andrews, Emergency Preparedness Analyst Michael C. Hay, Radiation Specialist Observer: John C. Edgerly, Reactor Engineer

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Approved By: Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety Attachment: Supplemental Information I

9803060284 980304 PDR ADOCK 05000458 G PDR

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EXECUTIVE SUMMARY River Bend Station NRC Inspection Report 50-458/98-01 A routine, announced inspection of the licensee's performance and capabilities during the ful scale, biennial exercise of the emergency plan and implementing procedures was performe The inspection team observed activities in the control room simulator, technical support center, operations support center, and emergency operations facilit Plant Sucoort

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Overall, performance was generally very good. The control room (CR), technical support center (TSC), and emergency operations facility (EOF) successfully implemented all assigned emergency plan functions. Performance in these facilities was very goo .

The CR crew's performance was very good. Operators promptly responded to plant events and applied proper mitigating actions. The initiating emergency event was properly classified. Corresponding offsite agency notifications were correct, and timel CR briefings were frequent, structured, and interactive. Normal CR communications, both intemal and extemal, were very good. Confusion about who was coordinating and directing operations response teams or individuals could have affected personnel accountability (Section P4.2).

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The TSC staffs performance was very good. The facility was promptly activated in an orderly fashion. Event classifications were made in a timely manner using the proper emergency action levels. Notifications to NRC were accurate and timely. Protective actions for onsite perso, nel were very good. Tasks and priorities were not clearly tracked. Habitability surveys were frequently performed but did not include all areas (Section P4.3).

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The Operations Support Center (OSC) staffs performance was satisfactory. Due to the potentialimpact on mitigation efforts, the failure to promptly and properly dispatch inplant response teams was identified as an exercise weakness. It took up to an hour to dispatch several teams, and some teams, including a high priority team, were canceled before the teams could be dispatched. Work team order documentation was incomplete and would have hampered event response reconstruction. Habitability controls were properly implemented. Team tracking status boards were not always maintained and could have affected personnel accountability. Good ALARA practices were demonstrated by radiation protection personnel assigned to assist work teams, although one team did not use proper contamination controls (Section P4.4).

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The EOF staffs performance was very good. Facility activation was timely and controlled, although there were no precautions taken for personnel who traveled from the s

site to the EOF during simulated sevce weather conditions. Management oversight was very good. Facility briefings were comprehensive and made a positive contribution to iacility performance. With one relatively minor exception, offsite agency notifications

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3-were correct and timely. Dose assessment and field team control activities were well managed and performed to support protective action recommendations. Protective action recommendations to offsite authorities were correct and timely. Interactions with offsite response team members were open and informative (Section P4.5).

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The exercise objectives were appropriate to meet emergency plan requirements. ~ The initially submitted scenario was not acceptable because it was too similar to the 1996 exercise scenario (two of four events were the same). Appropriate actions were taken once the concems were raised. The final exercise scenario was sufficiently challenging to test onsite emergency response capabilities (Section P4.6),

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The critique process was identified as a program strength and was significantly improved when compared to the 1996 biennial exercise self critique. The evaluation team identified several important areas in need of correction / improvement (Section P4.7).

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IV. Plant Sunnort  !

P4 Staff Knowledge and Performance in Emergency Preparedness P4.1 ' Exercise Conduct and Scenario Descriotion (82301 and 82302)

The licensee conducted a full-scale, biennial emergency preparedness exercise on February 11 and 12,1998. The exercise was conducted to test major portions of the onsite (licensee) and offsite emergency response capabilities. Day 1 consisted of plur a pathway elements, and Day 2 consisted of ingestion pathway elements. During Day 1, the licensee activated its emergency response organization and all emergency response

~ facilities. The Federal Emergency Management Agency evaluated the offsite response capabilities of the state of Louisiana and West Feliciana, East Feliciana, Pointe Coupee, West Baton Rouge, and East Baton Rouge Parishes. The Federal Emergency Man 0gement Agency willissue a separate report.

i The exercise scenario was run using the CR simulator in a dynamic mode. The exercise scenario began at 7:51 a.m., with the plant operating at 100 percent power. Normal weekday personnel were available for duties. At the start of the exercise, the area was under a severe thunderstorm and tomado watch with grid perturbations reported due to the weather. The crew was in Abnormal Operating Procedure 0029, " Severe Weather Operation," Revision 12. The low pressure core spray pump was tagged out of cervice for motor inspection, and Condensate Transfer Pump CNS-P1B was tagged out for replacement of the motor end bearin At 8:02 a.m., the CR received telephone notification from a security guard that a tornado had touched down just south of the turbine building and that there was apparent damage to the fire pump hous At 8:06 a.m., a ground on Condensate Transfer Pump CNS-P1 A occurred, but its breaker failed to trip. ACB300, load center feeder breaker, tripped causing a loss of 480VAC NJS-LDCIL. At 8:07 a.m., the shift superintendent declared an alert based on Emergency Action Level 14.3 (tomado touchdown onsite). Plant power reduction, at 10 percent per hour, was in progress due to the deteriorating weather condition At 9:01 a.m., an electrical transient caused a fault on Bus 1NNS-SWG1C which resulted in a trip and lockout of all feeder breakers to the bus. Significant electricalloads affected were Chiller HVN CHLR1C and 1E22*S004, Division til 4160 volt bus, causing the high pressure core spray diesel generator to start and tie on to the E22 switchgea At 10:01 a.m., a condensate line common header pipe weld cracked causing a leak in the turbine building. Reactor feed pumps tripped off, a ma..ual reactor scram was inserted but all rods did not insert, the turbine inadvertently tripped, and alternate rod insertion and standby liquid control both failed. At 10:05 a.m., the TSC declared a site area emergency based on Emergency Action Level 7 (anticipated transient without scram).

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. Shortly thereafter, the CR operators responded to the first turbine building radiation alarm. As a result, the TSC declared a genomi emergency at 10:17 a.m. based on a loss of two of three fission product baniers with a potential loss of the thir At 10:20 a.m., a reactor core isolation cooling steam line break occurred in the steam -

tunnel at the upstream weld on E51*MOVF064, resulting in a reactor _ core isolation cooling isolation signal on high main steam tunnel temperatures. - The inboard isolation valve failed to isolate which caused a loss of all high pressure feed and a loss of coolant accident pathway from the reactor pressure vessel to the steam tunnel. Radioactivny -

was released through the turbine building ventilation system with no charcoal or high efficiency particulate air filtratio At 11:11 a.m., all rods were reported in, and the CR personnel continued to work on the established priorities: recover injection and isolate the leak. At 12:41 p.m., injection was >

reestablished, and the reactor core isolation cooling system was isolated at 1:10 p.m. to stop the leak. At 1:13 p.m., the CR received confirmation that the release had stopoed The exercise was terminated at 1:41 P4.2 Control Room (CR) Inanection Scone (82301-03.02)  ;

The inspectors observed and evaluated the CR simulator staff as they performed tasks in response to the exercise scenario conditions. These tasks included event detection and classification, analysis of plant conditions, offsite agency notifications, intomal and extemal communications, and adherence to the emergency plan and procedures. The inspectors reviewed applicable emergency plan sections and procedures, operations procedures, logs, and notification form Observations and Findinas During the exercise, the CR crew quickly recognized, analyzed, and responded to emergency events. The shift superintendent declared an alert within minutes of being informed of the initiating conditions, using the correct emergency action leve Corresponding offsite agency notifications were made within regulatory time limits. The pager system activation (emergency response organization call-out) was promptly activated following the alert declaration. H owever, the wrong code was used and the resulting activation was for an actual emergency, rather than a drill. When the error w recognized, the shift superintendent immediately ordered another pager system activation with the proper code. The pagers reactivated with the proper drill announcement. A plant wide announcement was also made to advise all personnel of the erro The CR crew consistently responded to system annunciators using the proper annunewtor response procedure. The crew exhibited excellent team work. Normal CR communications, both intemal and external, were very good. However, when the tempo of events increased, there were instances when expected three-part communications-

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were not used, and the target individual was not identified. For example, immediately after the attempt to manually scram and identification of a failure of the plant to scram, several communications had to be repeated or personnel had to request a repeat of the communication. Also, at one point the CR supervisor had to forcefally direct all personnel to ' slow down" in order to refocus proper communicatiens technique Briefings were frequent, structured, and interactive. However, following the activation of the TSC and OSC, several briefings were conducted to identify field team activities and locations. There was apparent confusion about who was coordinating and directing the operations response teams or individuals (i.e., the CR, TSC, or OSC). As a result, personnel accountability was questionabl Conclusion 6 The CR crew's performance was very good. Operators promptly responded to plant events and applied proper mitigating actions. The initiating emergency event was properly classified. Corresponding offsite agency notifications were correct and timel CR briefings were frequent, structured, and interactive. Normal CR communications, both internal and extemal, were very good. When the tempo increased,- there were instances when expected three-part communications were not used, and the target individual was not identified. The initial activation of the pager system was incorrect but did not affect the emergency response. Confusion about who was coordinating and directing operations response teams or individuals could have aWeted personnel accountabilit ,

' Technical Sucoort Center (TSC) Insoection Scooe (82301-03.03)

The inspectors observed and evaluated the TSC staff as they performed tasks necessary to respond to the exercise scenario conditions. These tasks included staffing and activation, accident assessment, NRC notifications, personnel accountability, facility management and control, onsite protective action decisions and implementation, intemal and external communications, assistance and support to the CR, and prioritization of mitigating actions. The inspectors reviewed applicable emergency plan sections, procedures, and log Observations and Findinos The TSC was staffed and activated in a timely manner. The first responder arrived immediately after the 8:10 a.m. plant announcement for the alert declaration. Upon arrival, responders signed in on the position staffing board. The last " minimum staffing" position was filled at 8:26 a.m., and ihe last person signed in at 8:31 a.m. The TSC was activated at 8:54 a.m. when emergency director / recovery manager duties were transferred from the C __n

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The emergency director requested current meteorological cla from dose assessment personnel, because the alert was based on severe weather, Upon learning that the current indications showed 45 mph sustained winds, the emergency director asked security to consider suspending any outside walking patrols and use attemative methods. The emergency director then cautioned against dispatching any personnel outside of the buildir'g until the weather abated. The emergency director's actions demonstrated good awareness of conditions and concern for plant personnel protectio Upon notification from the CR that the reactor scram was not successful (automatic and manual), the emergency director promptly declared a site area emergency using the correct emergency action level. Shortly after the anticipated transient without scram, plant conditions begati to degrade: reactor water level was dropping, tb core was not

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subcntical, and there was indi(Ation of a :eak within the steam tunnel. Ine emergency director determined that general emergency conditions existed due to a loss of two fission product barriers with a potential' ,s of the third. The decision was challenged by one of the TSC staff to confirm lost /potentially lost barriers. Based on the emergency director's explanation and th9 available information, the inspectors determined that the

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general emergency declaration was performed properly. The questioning attitude ci the TSC Waff demoratrated good cross checkin Following the emergency classification upgrade, a communicator simulated the NRC notifications. The information provided wap tecurate and timel Personnel accountability within the TSC was quickly established and maintained throughout the exercise. There were three doors into the TSC envelope: one door led into the computer room ares and was not used, another door led into the main TSC work area and was quickly disabled to prevent entry into the center, and the other door had a key card reader for accountability purposes. Participants used the card readei when enterirg and exiting the cente Following the site area emergency declaration, a plant evacuation was simulate Security perscnnel performed the prccedural actions to determine personnel accountability. Using simulated information, accountability was properly established within 30 minutes of the site area emergency declaratio The emergency director conducted frecuent and comprehensive briefings. The briefings were announced in advance and contained a F .cussion of priorities. Occasionally, the briefings contained a summary of previous ever;ts. Functional area coordinators participated in the briefing The emergency director made good onsite protective action decisions and implemented them approp iately. Examples included:

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The decision to make potassium iodide available to workers was made in accordance with procedures. Personnel in the TSC and OSC were told to consider taking potassium iodide before leaving the center .

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Frequent announcements were made in the TSC and OSC regarding the release in progress, general direction of the plume, and need to avoid affected area l

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During the planning discussions for the steam tunnel Ontry, the T3C considered the increased consumption of ak from self contained breathing apparatuses in tb high temperature environment. The plans included staging extra air bottles at the location, prior to actually entering the steam tunne The process for tracking tasks, assignments, and pr%rities was confusing. The TSC staff used several methods to display tasks, assignments, and prior; ties within the center. A video link was used to transmit a list of tasks and priorities to the OSC. Tasks and l priorities were updated and revised as plant conditions changed. A status board was used to track TSC priorities. A large paper tablet was used to track TSC engineering tasks. Engineering tasks were listed in sequential order as they wero assigned. On several occasions, the priorities for the OSC and TSC were not consistent for extended periods. In addition, the lack of a mechanism to link the engineering tasks to the TSC priorities could have led to conflicting prioritie The TSC staff correctly performed dose assessments and projections. TSC personnel used a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> default release duration time for dose projections. When it appeared that the release duration woWd exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, doss assessment personnel performed several calculations to determine the release duration that would cause the Environmental Protection Agency protective action guidelines to be exceeded at

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10 miles. The result was effectively used to establish / focus equipment repair priorities to

! terminate the release. The inspectors determined that this was a good use of dose projection capability within the TS TSC habitability surveys, including area radiation surveys, contamination surveys, and air sample measurements, wer? conducteo frequently but wee not alway;. ; .operly completed Forexample:

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Area radiation and contamination surveys were only performed in occupied areas. Rooms that were not routinely occupied were not surveyed. As a result, contamination could have gone unnotice .

The air sampler was placed in the TSC access hallway inside the TSC ventilation envelope but outside the door used for accountability control. Sir.ce the location was different ti,an the main TSC work area, the air sample may not have been representative of the TSC environmen .

The ak sampler was operated through the exercise with the flow rate showing about 85 titers per minute. The applicable procedure stated that the flow through the charcoal cartridge was to be about 2 cubic feet per minute. Using the licensee's procedure, the indicated flow rate was actually about 3 cubic feet per minute. Since there was no mechanism to adjust the air sampler flow rate, it appeared that the flow indication was simply an indicator that there was air flow inrough the sampler at the calibrated flow rate. Following the exercise, the

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licensee detonnined that the actual flow rate was about 2 cubic feet per minute and that the indicator was in error. Had the flow rate been as indicated, the air sampling results could have been nonconservativ Conclusion _s The TSC stdrs performance was very good. The facility was promptly activated in an orderly fashion. Event classifications were made in a timely manner using the proper emergency action levels. Notifications to NRC were accurate and timely. Protective actions for onsite personnel were very good. Precautions were taken for the simulated, severe weather, arrangements were made for additional air bottles for the steam tunnel entry, potassium iodide was authorized, and pt'ar.t personnel were cautioned to avoid areas affected by the plume. Tasks and priorities wem not clearly tracked. Habitability surveys were frequently performed but did not include all area P4A Qoerations Suooort Center (QSC)

' Insoection Scope (82301-03.05)

The inspectors observed and evaluated the OSC staff as they performed tasks in response to the scenario conditions. These tasks included functional staffing and emergency response team dispatch and coordination in support of CR and TSC requests. The inspectors reviewed applicable emergency plan sections, procedures, logs, checklists, and form Observation 1 add Findinas The OSC was promptly staffed and activated. Activation began shortly after the 8:07 a.m. alert declaration and was completed at 8:54 a.m. The OSC director properly announced the activation to center personne!.

Center briefings were provided on a regular basis by the TSC (via loudspeakers). The briefings appropriately addressed plant parameters, current emergency classification, task priorities, and response team work status. The detail and frequency of the briefings precluded the need for the OSC director to personally conduct regular OSC briefing The process used to form and dispatch teams, coupled with the level of activity and the distribution of responsibilities, inhibited the OSC's ability to promptly and properly dispatch response teams. This determination was based on the following observations:

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The OSC director sometimes logged when the TSC notified the OSC to dispatch a repair team. Using the OSC director'c log and the corresponding team work order dispatch time, inspectors quantified dispatch times for 6 teams (a total of 16 teams were dispatched). There was insufficient documentation to quantify dispatch times for the other 10 teams. Of the 6 teams that could be quantified, 4 took opproximately 53-60 minutes to be dispatched following OSC notification (one may have been 25 57 minutes).

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+ Of the 21 " Team Work Orders" initiated by the OSC director,5 were cancelled prior to the team being dispatched, because the teams were no longer neede As previously mentioned,16 teams were dispatched. One of the cancelled teams

- the number one priority - y " ready to leue the OSC 40 minutes after the initial TSC request. The team e ince: led because the CR accomplished an alternate success pat . The OSC director was actively involved in arranging work team compositio EIP 2-016, " Operations Support Ceni;r,' Revision 15, Section 4.4, stated that

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work team composition v'as the responsibility of the woA team facilitator and the OSC manager Similarly, the OSC director handled communications from inplant

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work teams, another OSC manager and/or work team fach!tator duty. The involvement in team formation and communications inhibited the OSC director's

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ability to provide direction and contro . Procedurally required documentation was incomplete and would have hampered event response econstruction. Section 4.2 of EIP 2-016 stated that the OSC manager wa: t.. ensure that OSC team work orders were completed for all

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dispatched teams. Attachment 1 to EIP 2-016 stated that tne OSC director was to ensure that work orders were fully completed for teams that had completed assigned tasks, inspectors identified the following incomplete work orders:

(1) Radiation protection br efing/ debriefing sections were not completed for 3 of 4 teams that were redirected to perform other tasks while in the fiel (2) Of the 16 dispatched work teams,7 work team orders did not include dicpatch/ return time (3) Of the 16 dispatched teams,12 work team orders did not indicate that the

"OSC Director / Manager Task Briefing" was complete The failure to promptiv and properly dispatch inpiant field teams was identified as an exercise weakness because of the potential impact on mitigation effeds (50-458/9801 01).

Habitability surveys were performed on a regular basis using calibrated instrument Radiological survey data sheets were reviewed and found to be detailed and comprehensive. Habitability controls implemented in the OSC were very goo The OSC team tracking status board, maintained by the status communicator, was not

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always properly rnaintained and could have adversely affec;ed personnel accountabilit information that was known by the OSC director and/or manager concerning work tear 1 status was not always provided to the status communicator. On one occasion, the OSC had to contact the CR to find out the location of an individual. In general, work teams were satisfactorily tracke __________ ___________________-_ _ _________ -

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-11 Teams observed la the field used proper protective clot: Mg, minimizing the potential for personnel contamination. In contrast, contamination controls were not always properly performed. !nspectors observed that 3 out of 4 members of r work team, including a radiation protection technician, passed through a radiological step-off pad without frisking. Failing to frisk could spread contamination to an uncontrolled are Radiation protection personnel assigned to provide work team coverage exhibited good as low as is reasor, ably achievable (ALARA) job practices. Radiation protection personnel properly located and informed teams of low dose areas for idle teams / team members, Conclusions The OSC staff's performance was satisfactory. */he center was activated in a timely manner, and briefings were frequent and comp ebensivo. Due to the potentialimpact on mitigation efforts, the failure to promptly and properly dispatch inplant response teams was identified as an exercise weakness. It took up to an hour to dispatch several teams,

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and some teams, including a high priority team, were cancelled before the teams could be dispatched. Work team order documentation was incomplete and would have hampered event response reconstruction. Habitability controls were property implemented. Team tracking status boards were not always maintained and could have affected personnel accountability, Good Al. ARA practices wero demonstrated by radiation protection personnel assigned to assist work teams, although one team did not use proper contamination control P4.5 Emergency Ooerations Facility (EOF) Insoection Scooe (8230103.04)

The inspectors observed the EOF's staff as they performed tasks in response to the exercise. These tasks included facility activation, notification of state and local response agencies, development and issuance of protective action recommendations, dose projections, field team control, and direct interactions with offsite agency response personnel. The inspectors reviewed applicable emergency plan sections and procedures, forms, dose projections, and log Observations and Findings The EOF was promptly staffed following the 8:07 a.m. alert declaration. Upon arrival, personnel simulated locking exterior doors, prepared registration forms to log emergency responders, initiated position checklists, established communications with counterparts, and determined facility habitability. Activation steps were completed at 8:57 a.m., and the recovery manager responsibilities (offsite agency notifications, dose assessment / protective action recommendations) were assumed by the EOF at 9:05 a.r The transfer of responsibilities was conducted in a controlled manner to ensure that key response actions were not overlooked or misunderstoo I

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a 12-l Although the EOF was staffed promptly, the safety of facility personnel was not considered after the ?.lert was declared due to a tomado touctdown onsito. No special precautions were taken or considered for those personnel who traveled from the site to the EOF, although precautions were taken for onsite and offsite monitoring team Under some circumstances (e.g., security events and severe weather conditions),

judgement may be needed regarding the decision to activate emergency response facilitie Management oversight in the EOF was very good. Briefings were frequent and comprehensive. Facility members were given prior notice to prepare, and all facility personnel participated in the briefings. The briefings included input from operations, radiation protection, engineering, administrative, and state personnel. Special emphasis was placed on facility priorttles and what effect changing plant conditions would have on EOF activities. As the exercise progressed, briefings included a summary of previous significant events. During periods of relatively low activity, facility personnel were encouraged to review and update individual logs. The recovery manager was also sensitive to noise levels and distractions. On several occasions, the recovery manager limited observer access to the EO Offsite agency notifications for the site area and general emergency were made within the required 15-minute time limit. Short notification m'assage forms were uppropriately used for classification and protective action recommendation changes. Long notification

message forms were usually issued, as necessary, to convey changes in release status l and dose projection data. Inspectors identified two issues conceming the content of the l long notification message forms.

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There was a discrepancy between the affected sectors used by the utility and the state which wculd have been confusing to outside organizations (NRC, media, etc.). The long notification message form for the general emergency (Message 6)

indicated that the affected sectors were D, E, and F. The state included Sector G because Scenario 4 included some areas within Sector G. This would be confusing to organizations who would talk to both the state and the utilit .

On one occasion, valuable information was not properly communicated to offsite autnorities. Although projected doses based on the actual release duration time (2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />) were appropriately calculated, the information was not included on a long notification message form. Forms issued after the release stopped incorrectly stated that there were no projected offsite doses gall zeros).

Protectivo action recommendations, identified as scenario numbers (127 based on different distances and downwind sectors), were correctly formulated and promptly communicated to offsite authorities. Following the general emergency declaration, a default 2 mile radius /5-mile downwind evacuation wa1 correctly recommended (Scenario 4). When the release rate increa,ed, the r9 commendation was appropriately upgraded to a 5-mile radius /10-mile downwind evacuation (Scenario 16). As required by procedures, EOF personnel verified that the offsite agencies received the protective

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13-action recomrnendations and obtained the approved scenario (protective action decision).

Dose assessment and field team control activities were wil managed and controlled to support protective action recommendations. Numerous dose projections were calculated based on plant conditions and field team data. There was good coordination between the utility and state offsite monitoring tearns, and utility offsite monitoring team doses were closely monitored to determine the need to issue potassium iodid However, the radiation protection advisor was not fully aware of procedural provisions for a certain area of responsibility. Specifically, the radiation protection advisor was initially not aware that EIP 2-024, 'Offsite Dose Calculations," Revision 17, allowed the use of release duration times greater than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (Step 6.1.8). As previously discussed, dose projections using the actual release duration time were eventually calculated. The failure to use the actual release duration time could result in incorrect protective action recommendation Facility habitability was appropriahly monitored during the exerc;ae. When the lock failed on the EOF door and repairs were initiated, the effect on EOF habitability was properly determined. Thormoluminescent dosiraeters and pocket ion chambers were distributed to facility personnel during the activation process. Personnel were reminded to read pocket ion chambers during periodic briefing interactions with state response team members who were stationed in the EOF were frequent, open, and constructive. Upon arrival, state representatives were briefed on plant conditions and prognosis. The state's input was solicited during briefings, and changing plant conditions were quickly relayed so that offsite impact could be evaluate c. Conclusions

The EOF staff's performance was very good. Facility activation was timely and controlled, although there were no precautiors taken for personnel who traveled from the site to the EOF during simulated severe weather conditions. Management oversight was very good. Facility briefings were comprehensive and made a positive contribution to facility performance. With ane relatively minor exception, offsite agency notifications were correct and timely. A notification made after the release stopped did not include projected offsite doces. Dose assessment and field team control activities were well managed and performed to support protective action recommendations. However, the radiation protection advisar was not initially aware that the release duration time could exceed the 2-hour default time. Protective action recommendations to offsite authorities were correct and timely. Intera .;vns with offsite response team members were open and informativ e .c ,

14-P4.6 Scenario and Exerciss Control Insoection Scope (82301 and 82302)

The inspectors evaluated the exercise to assess the cha!!enge and realism of the scenario and exercise contro Observations and Findinas The licensee submitted the exercise objectives and scenario for NRC review on November 13 and 26,1997, respectively. The exercise objectives were appropriate to meet emergency plan requirements (reference NRC letter dated December 3,1997). By letter dated January 22,1998, the licensee was informed that the exercise scenario was not acceptable. The scenario was rejected, because it was too similar to the 1996 biennial exercise scenario (two of four events were the same), if exercise participants participated in the 1996 exercise, reviewed the correspondinj NRC report (60-458/96-07), or were made aware of the outcome during tralning, response actions could have been affected, it would not be accepabie for exercise participants to have prior knowledge of exercise scenario events. Appropriate actions were taken once the concerns were raised. The final exercise scenario was su'ficiently challenging to test onsite emergency response capabilitie Due to the initial scenario concern, the inspectors reviewed scenarios used in practice drills to ensure they did not include exercise scenario events. Emergency planning I

personnel provided scenario summaries for two integrated drills and three mini-drills.

l Although the scenarios were all different and did not include exercise scenario events, the inspehrs expressed concerns about the level of pre-exercise training. The preconditioning was greater than normal and initially caused concerns about whether the other teams were as pwrared as the exercise team. In response, the licensee explained that the '. raining was necessary because of a recent erihancement invoMng the CR simulator. The simulator can now be used to display olant data via computer (in lieu of using paper data). Moreover, additional training for the other teams was planned (beginning the week tollowing the exercise). The planne.1 training would include lessons-leamed by the responding team and mini-drills driven by the simulator. The licensee's planned actions alleviated the inspectors' concern Inspectors identified one isolated instance r f inappropriate controller / participant interaction. A controller showed scenario survey data to a radiation protection technician before the technician earned the data. The technician was not even in the area of concer Conclusions The exercise objectives were appropriate to meet emergency plan requirements. The initially sut mitted scenario was not acceptable, because it was too similar to the 1996 exercise scenario (two of four events were the same). Appropriate actions were taken ,

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once the concerns were raised. The final exercise scenario was sufficiently challenging to test onsite emergency insponse capabilitie ;

P4.7 Licaname Self Craique Inanadion Scope (82301-03.13)

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I The inspectors observed and evaluated the licensee's post exercise facility ortiques and the formal management critique on February 13,1998, to determine whether the process ,

would identify and characterire week or deficient areas in need of corrective actio > Claantations andfindings Post exercise critiques in the CR simulator, TSC, OSC, and EOF were thorough, open, ,

and seti critical. The post exercise critiques included input from controllers, evaluatorc, and participants. The lack of participation by state representatives in the EOF detracted .

from the overall completenus. Participants in all facilities made a sincere effort to '

identify areas where performance could be improve During the February 13,1998, management critique, the emergency planr5g manager and lead River Bend Station evaluators presented the preliminary exercise findings. The -t breakdown of findings was as follows: one area for improvement in the CR/ simulator, one potential weakness and four areas for improvement in the TSC, one weakness and ,

four areas for improvement in the OSC, and five areas for improvement in the EOF.' The '

potential weakness in the TSC involved TSC habitability, and the weskness in the OSC involved command and contro In addition to the River Bend Station evaluators, exercise evaluation was performed by

_ quality assurance personnel, licensee management, representatives from other Region IV sites, and the Entergy peer review groupc- The peer review group consisted of _

the three emergency planning menagers from the other Entergy sites and representatives from the Entergy Corporate Office. The integrated critique process was ,

considered a program strength.. There was a significant improvement when compared to the 1996 biennial exercise self critique. Severalimportant areas in need of correction vrra identifie Conclualons  ;

The critique process was identified as a program strength and was signincantly improved when compared to the 1996 biennial exercise self critique. The process includod site evaluators, corporate evaluators, Entergy peer review group, other site evaluators, and management evaluators. The evaluation team identified several important areas _in need

. of correction / improvement.

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-16-P5 Staff Training and Qualification in Emergency Preparedness Insoection Scope (82701)

The inspectors reviewed the Updated Safety Analysis Report (USAR), plant access training material, emergency plan, and radiolegical controls procedures to determine if training requirements and commitments werts being me Observations and Findings inspectors noted that Procedure EIP-2 012, * Radiation Exposure Controls," Revision 13, I stated that 10 CFR Part 20 occupational exposure limits applied to all members of the I emergency response organization, even if they had not received radiation worker training. Although the licensee required all personnel to attend plant access trainireg, which included a brief discuscion of radiation, the training did not include a discussion of regelatory 1,mits, instructions for frisking, protection of the embryo / fetus per the declared pregnant female program, etc. Since these topics were only discussed in radiation worker training, inspectors questioned whether emergency response organization members received training consistent with 10 CFR Part 19.12. The NRC intends to pursue this matter as an inspection followup item to determine if Part 19.12 training applies to emergency response personnel who do not normally receive radiation worker training (50-458/9801-02).

The licensee's emergency plan stated that all personnel would receive emergency

, plan / procedure training in plant access and radiation worker training as described in the

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USAR. The inspectors reviewed the USAR description of the general employee training and compared it to the plant access training content. The USAR stated that the training would include a discussion of Regulatory Guide 8.13 which discusses the effects of radiation on the embryo / fetus. This subject was included as part of the licensee's declared pre 0nant female program but was not discussed in the plant access trainin The inspectors did not have sufficient time to determine if the Regulatory Guide 8.13 subject matter was provided as part of other required training. it.e NRC intends to pursue this matter as an unresolved item to determine if Regulatory Guide 8.13 training is conducted in accordance with the USAR (50-458/9801-03). Conclusions One inspection followup item and one unresolved item were identified involving personnel trainin V. Management Meetings X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee managernent at the conclusion of the inspection on February 13,1998. The licensee a : knowledged the facts presented. No proprietary information was identifie _ - _

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! The Federal Emergency Management Agency conducted a public meeting in St. Francisville, Louisiana, on February 13,1998. Representatives from the Federal Emergency Management Agency and NRC provided a br'ef discussion of preliminary exercise resuNs, e

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ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee J. McGaha, Vice President, Operations (A. Bellamy, Directoi, Site Support M. Dietrich, Director, Quality Programs J. Hurst, Senior Emergency Planner J. Fowler, Manager, Quality Assurance K. Huffstatler, Senior Emergency Planner R. Jobe, Senior Emergency Planner M. Jones, Senior Operations Instructor / Emergency Planner R. King, Director, Nuclear Safety & Regulatory Aftairs D. Lorfing, Supervisor, Licensing W. O'Malley, Manager, Operations P. O'Neil, Specialist, Licensinc B. Ricketts, Supervisor, He .... Physics Shift W. Spell, Supervisor, Health Physics Shift i J. Waid, Director, Training T. Wyrnore, Control Room Supervisor Other Personnel A. Morgan, Manager, Emergency Preparedness, Grand Gulf Nuclear Station NHC G. Replogie, Senior Resident inspector LIST OF INSPECTION PROCEDURES USED IP 82301 Evaluation of Exercises at Power Reacters IP 82302 Review of Exercise Objectives and Scenarios for Power Reactors IP 82701 Operational Status of the Emergency Preparedness Program

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LIST OF ITEMS OPENED Goened 50-458/98001-01 IFl Exercise weakness - Failure to promptly and properly dispatch aplant response teams (Section P4.4)

l 50 4 8/98001 02 IFl Part 19.12 training for emergency response organization members (Soction PS)

50 4 58/98001-03 URI Regulatory Guide 8.13 training per USAR (Section PS)

LIST OF ACRGNYMS USED

- Al. ARA As low as is reasonably achievable l CR Control room EOF Emergency operations facility OSC Operations support center TSC Technical support center USAR Updated Safety Analysis Report LIST OF DOCUMENTS REVIEWED

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Emeroency lmolementina Procedures EIP 2 001 Classification of Emergencies Revision 9 ElP 2-002 Classification Actions Revision 17 ElP 2-006 Notifications Revision 23 EIP 2-007 Protective Action Recommendation Guidelines Revision 16 EIP-2-012 Radiation F.xposure Controls Revision 13 EIP 2-014 Offsite F diological Monitoring Revision 16 EIP 2-018 Operations Support Center Revision 15 EIP 2-020 Emerg.: f Operations Facility Revision 19 EIP 2 024 Offsite Dose Calculations Revision 17 Other Procedures AOP-0029 Severe Weather Operation Revision 12

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o ..o-3-QJher Documents River Bend Station Emergency Plan, Revision 16 River Bend Station Updated Safety Analysis Report, Section 13.2.2,' General Employee Training,' Revision 7, January 1995 EO S LP-GET-PA~ . . 03, 'EOl Plant Access Training,' October 27,1997 EOl S-LP-GET RWT01.05, 'EOl Rad Worker Training," November 5,1997 Prenatal Information Guide for Radiation Workers (undated)

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