ML20214E890

Ack Receipt of 870422 Response to NRC & Insp Rept 50-458/85-80 & & Notice of Violation in Insp Rept 50-458/87-06.Implementation of Corrective Actions Will Be Reviewed During Future Insp to Determine Full Compliance

ML20214E890
Person / Time
Site:	River Bend
Issue date:	05/15/1987
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Deddens J GULF STATES UTILITIES CO.
References
NUDOCS 8705220300
Download: ML20214E890 (2)

See also: IR 05000458/1985080

Text

.- . . .--

sp'f<'

-

.

-MAY - 151987

'

In Reply' Refer To:_.

Docket: 50-458/86-35

-

'

-50-458/87-06

'

Gulf States Utilities - '

ATTN: Mr. James C. Deddens

' Senior.Vice President, (RBNG)

. _.

Nuclear Licensing

_ -P.-0. Box-220 . . .

.St.-Francisville, Louisiana-

-

-

70775

. Gentlemen:

Tha'nk you for your letters of April 22,1987, in. response to our letter and

NRC Inspection Report dated December. 29, 1986, which identified deficiency

.458/8580-03-opened previously.in NRC Inspection Report 50-458/85-80,' and to our

~ letter ~and Notice of Violation dated March 23, 2987, pertaining-to NRC

-Inspection Report 50-458/87-06. We-have reviewed your replies and find them

-. responsive to_the concerns raised in'NRC Inspection Report 50-458/86-35 and our

~

Notice of Violation in NRC-Inspection Report 50-458/87-06. We will review the

4 m implementation'of your corrective' actions during a future inspection to

determine that-full compliance has been achieved and will be maintained.

Sincerely,

1. ORIGINAL SIGNED BY:

0705220300 870515

PDR ADOCK 05000458 ,

G PDR .

J. E_. Gagliardo, Chief

Reactor Projects Branch

cc:

Gulf States Utilities

-

ATTN: J. E. Booker, Manager-

River Bend Oversight'

P. O. Box'2951-

. Beaumont, Texas 77704

Louisiana State University,

Government Documents Department

Louisiana Radiation Control Program Director

bec: (see n t page) /

-

h I ,,

RIV:EP&S

NMTerc/jt

C:EP&SPS '

LAYandell

C:R&SPB i

WLF1 her

C: /A

JPJaudon

C:RPB

JEGagl rdo

I{\ /

$~/((/87 T/((/87 5/h/87 f/ll/87 g/jf/ f

ft

4

-

,

e .. - - - , - -__ _ __ . , . , . _ . - _ . _ . _ , , , _ _ . , , , _ . ,

-

p.f ,

..

_- ,

. - ~ +, s -

.;

-

,

.- .

. Gulf States Utilities -2-- '

. .

,

_ -

'

'bec to'DMB (IE35)-

bec distribi by RIV:

RPB

LDRSP.

, Resident) Inspector

R. D.-Martin,- RAr .

Section ~ Chief -(RPB/A) -

D. Weiss, RM/ALF-

. MIS System-

RSB-

'RSTS~0perator:

R&SPB'

'

RIV File

. Inspector

Section Chief

W. L. Fisher -

'ly-L. Bangart

.

~

. R .1 E . ': Ha l l

-Project _ Inspector,:RPB-

. .

'D. B. Matthews, NRR-:

.

-

h

b

_.

i

4

x

F

l-

r

.

4 -

'

.

i-

._

.

,, .,

t

..,

,

.y

..

. =

. .

..

GULF STATES UTILITIES COMPANY 'k$I

RfvtR 8(NO STAflON POST OFFICE BOX 220 ST. FRANCISVfLLE. LOUISIANA 70775

ARE A CODE 504 635 6094 346 8651

April 22, 1987

RBG-25799

File Nos. G9.5, G15.4.1

U.S. Nuclear Regulatory Commission

Document Control. Desk

Washington, D.C. 20555

I[

r --

@ ]"' h3

Gentiemen

( APR 2 91967 j

River Bend Station - Unit 1 '.

-

?

5--

~&

Refer to: Region IV ->

Docket No. 50-458/ Report 86-35 -

In response to your letter dated March 23,'1987, please find attached

the additional information you requested related to Deficiency

458/8580-03 and Protective Action Recommendations for River Bend

Station.

,

Sincerely,

' [ Y-/fk ,

! J. E. Booker

/

Manager-River Bend' Oversight

l g5

..

Attachment

cc

Mr. Robert D. Martin, Regional Administrator

l U.S. Nuclear Regulatory Commission

-

l

Region IV

611 Ryan Plaza Drive, Suite 1000

Arlington, TX 76011

NRC Resident Inspector

P.O. Box 1051

St. Francisville, LA 70775

.t .

- n.e ,1 m n - -- <  ;.

s W / h & h' \f,?

15%1 i

--

.

_. .- ._ =._.

. = -. . - _ - -- - _ - . - - .

e- as , *

.*

ATTACHMENT

-> DEFICIENCY 458/8580-03

ADDITIONAL INFORMATION

~

The ability of the River Bend Station Emergency Response Organization to

perform dose assessment activities and to determine an appropriate

, Protective Action ' Recommendation (PAR) was demonstrated during the

February 25, 1987 NRC evaluated full-scale emergency preparedness

exercise. These functions were completed in 9 minutes (1335 to 1344)

-and included . discussions, coordination and concurrence with

representatives of the Louisiana Nuclear Energy Division. As indicated

. during both the GSU critique and the NRC exit meeting,.the time delays

are caused by the inherent problems associated with ' communicating

verbally over the RBS State and Local Hotline with five local

'

, . governments and state agencies from the States of Louisiana and

_

- Mississippi.

i

GSU is currently pursuing an alternate method for making these

!

notifications so that a hardcopy of the approved notification message

' form' with PAR's would be transmitted- to all points in a shorter

timeframe.

In response to the question relative to offsite concerns, the PAR flow

!

chart in Emergency Implementing Procedure (EIP)-2-007 (Attachment 2)

will be revised during the current and ongoing annual review of the RBS

i. Emergency Plan and EIP's. The change to the PAR flow chart will make it

clear that review of these notes is not mandatory and should be reviewed

only .if time permits and such review would not interfere with a timely

<

and accurate transmittal of PAR's to offsite officials.

i

l

l

-  ;

,

9.

-

1

.-

--

e c. .

.

v4

e

.

GULF STATES UTILITIES COMPANY '

PoSToFFICESox220 . ST FRANCISViLLE LOUISIANA 30776

AREA CooE 504 636-3237 387-4257

April 22, 1987

RBG- 25801

File Nos. C9.5, G15.4.1

U.S. Nuclear Regulatory Commission

Document Control Desk

[

,I I -

[}d

-'

-

Washington, D.C. 20555 'O '

g

'

APR 2 919 fit i -

-

Gentlemen:

River Bend Station - Unit 1

Refer to: Region IV

Docket No. 50-458/ Report 87-06

This letter responds to the Notice of Violation contained in NRC

Inspection Report No. 50-458/87-06. The inspection was performed by Mr.

N. M. Terc during the period February 23-27, 1987 of activities

authorized by NRC Operating License NPF-47 for River Bend Station.

Gulf States Utilities Company's (GSU) response to Notice of Violation

8706-01, " Failure to Perform Training", and to Deficiencies 8706-02,

8706-03, and 8706-04 are provided in the enclosed attachments pursuant

to 10CFR2.201. This completes GSU's response to these items.

Sincerely,

f

.

. C. Daddens

Senior Vice President

River Eend Nuclear Group

JCD/ C/hLA/je

.

Attachments

cc: Mr. Robert D. Martin, Regional Administrator

U.S. Nuclear Regulatory Commission

Region IV

611 Ryan Plaza Drive, Suite 1000

Arlington, TX 76011

i

NRC Resident Inspector

~~

P.O. Box 1051

St. Francisville, LA 70775

e r, , ,n . i .i o

g n . - - p

g_g .

. - - _ _ -.

. . . , . ..

.

O

GEND SDEES & NERICA

urrYFAR REGIJGGN G30ESSIGi

S'!1'IE & IDUISIANE * -

PARISH & WEST FELICIANE *

In the Matter of * Docket Nos. 50-458

GIF SDGES UTILITIES GDFANY *

(River Bend Station,

Unit 1)

.

.

AFFIDAVIT

J. C. Doddens, being duly sworn, states that he is a Senior Vice

President of Gulf States Utilities Capany; that he is authorized on the

part of said Cmpany to sign and file with the Nuclear Regulatory

Ommission the h==nts attached hereto; and that all such h= ants

are true and correct to the best of his knowledge, information and

belief.

i

/

,

J. 7.'Deddens

l

Subscribed and sworn to before me, a Notary Public in and for the

State and and Parish above named, this-OS' day of [O/, f ,19

l

r .

,

/

mM/MM4h

• fToan W.Public

Middlebrooks

Notary in and for

West Feliciana Parish,

t Iouisiana .e

i

My Cm mission is for Life.

._- - .

. -- - _ , _ . -_ . - - ___ --- _ _ __

. . .- . .. .- - - . ~ . ..

n

l' ,- ., '

,;,.

'

,

ATTACHMENT 1

RESP 01;SE TO NOTICE OF VIOLATION 50-458/8706-01

LEVEL IV

REFERENCE

- .

'

Notice of Violation - J. E. Gagliardo letter to J. C. Doddens, dated

March 23, 1987.

FAILURE TO PERFORM TRAINING

10CFR50.54(q) requires that licensees shall follow. and maintain in

i

effect energency plans which meet the standards in 10CFR50.47(b) and the

requirements in Appendix E to Part 50.

,

10CFR50.47(b)(15) requires that radiological emergency response training

-

be provided to those who may be called on to assist in an emergency.

.

10CFR50, Appendix E, paragraph IV.F requires, in part, that specialized

initial training and periodic retraining be provided to first aid teams.

River Bend Station Emergency Plan, Section 13.3.7.1.1.2, " Specialized

'

Training," . states, in part, that first aid and rescue personnel will

receive training, at least annually, in both Red Cross Multi-Media First

Aid and in the Special Handling of Radioactively Contaminated Personnel.

!'

Contrary to the above, on February 25, 1987, the NRC inspector

determined that first aid and rescue personnel had not received

specialized annual retraining in handling injured 'and contaminated

l

persons.

l

This is a Severity Level IV violation.

REASON FOR THE VIOLATION

Although training in the special handling of injured and radioactively

- contaminated personnel was conducted, this program was presented as a

separate training course and was not incorporated into Emergency

Response Organization training requirements; therefore, scheduling _

personnel for this training was inconsistent with emergency plan

requirements.

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED

A review of personnel assigned to the First Aid Team indicates a

sufficient number have received the appropriate Multi-Media First Aid

Training and Annual First Aid for Radiological Accident Victims Training

to meet the on-shift requirements. These individuals have been

identified to Operations so that only currently trained individuals will

be assigned to the First Aid Team.

S

. - - . . - ._ .

. . - - . ._ _ .. ..

.:., ,-

, ,

e

. ATTACHMENT 1 (CONT'D)

.

. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN TO AVOID FURTHER VIOLATIONS

GSU will schedule additional' NE0/NCO personnel to attend Red . Cross

Multi-Media First Aid or equivalent training and First Aid for

Radiological Accident Victims training to ensure adequate long term

-coverage of this function.

The First Aid and Handling Injured and Contaminated Individual's

training will be incorporated into Module 7 of the Emergency Response

Organization training program.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED

l

- Trained and qualified individuals were identified to Operations on March

-

4, 1987.

Additional personnel will be trained in First Aid and Handling Injured

and Radiologically Contaminated Persons by September 1, 1987.

'

First Aid _and Handling Injured and Contaminated Persons training will be

incorporated into Module 7 of the Emergency Response Organization

training program by September 1, 1987. Annual training on this module

is an existing requirement in procedure EIP-2-102, Training, Drills and

Exercises.

.

I

e.

..

- . . . . - . . - - , - , . . . - . . - . - . . _ ,

, . . _ - . . . . . . -. . . .. ~ - . .

-

s 'l.s . . ,

EM

' ATTACHMENT'2

C

RESPONSE TO DEFICIENCY 50-458/8706-02

4'

[\s

REFERENCE

" procedure pr'ovides instructions for performing radiological surveys in

the plant and onsite out-of-plant 'during a radiological emergency", and

in Sections 3.1 and 3.2 that "onsite radiological surveys are performed-

for two basic purposes. _ One is to support Emergency Response Team

efforts inside the plant building. The second is to verify release.

. assumptions by monitoring the area outside but adjacent to the plant

building", and "to minimize radiation exposures to Radiation Protection

- personnel, general area surveys inside the plant shall not usually be

conducted during an' emergency." With these limitations on the scope of

.. the procedure,- no mechanism exists directing the Emergency Director to

4- refer to this procedure for habitability requirements.

The need to perform habitability surveys in the Control Room was

'

discussed' with the affected Emergency Director. The Nuclear Training .

'

. Department has been directed to emphasize the need to perform

radiological surveys in .the Control Room to ,.C Coordinators and

Radiological Protection Technicians during the 1987 training cycle. >

. Section 4.1.4 of EIP-2-013 will be hela ed from the procedures. It is

not within the scope of th6 I". cet e and is redundant with sections

that are or will be in other p*c 4aor e

i A step will be added to.EIP-2-017. " Operations Support Center - Support

Functions", Section 4.1.1 directing the OSC Coordinator to periodically

dispatch a habitability te:hnician to monitor the radiological

conditic.s'in the Control Roca. EIP-2-013 and E1P-2-017 will be revised

, during the annual review and update by August 31, 1987.

A

.

,,w-- - n .-w4 ,--.u - - .an.,, .-, , _ - - ,n,- ,.,a - . , , - - . - - -_ , , ,- ,- , , - . ,,-.,.g,-- - -,. . ,,

- .- . . ... .. . - -

,

. +. . .-

. ,

c

ATTACHMENT 3

-

RESPONSE TO DEFICIENCY 50-458/8706-03

REFERENCE

.

Letter - J.-E. Gagliardo to J. C. Deddens, dated March 23, 1987.

DESCRIPTION

4

I The conduct of operations in the OSC was not conducive'to efficient

coordination-and direction of in-plant teams. When the OSC Coordinator

was required to attend meetings at the TSC, in-plant teams were unable

to obtain proper direction and coordination from the person relieving.

the OSC Coordinator. .This caused considerable delays in the performance

'

of certain in-depth tasks and caused the potential for unnecessary.

-

radiation exposure of team members.

GULF STATES UTILITIES COMPANY'S RESPONSE

,

In -an effort to ' improve the OSC's response capabilities, the OSC

Coordinator was recently directed to attend the TSC staff briefings.

This .had not previously been done. When this practice was instituted,

- it was found that no position was designated to assume direction of the

OSC.

t The Radiation Protection Foreman position has been designated to assume

direction of the OSC when the OSC Coordinator is not available.

EIP-2-017, " Operations Support Center - Support . Functions", and

[ . EIP-2-102 ," Training, Drills,'and Exercises," will be revised to reflect

'

. the designation of the Radiation Protection Foreman as the OSC

Coordinator in his absence. This item will be emphasized during the

1987 Emergency Plan training cycle and drill program. EIP-2-017 and 102

will be revised during the annual review and update by July 31, 1967.

Training will be completed by November 30, 1987.

.

I

I

A

. - . - . . . . . . . . - . . _ . . - _ . . . . - - _ . - - _ . - - - . . . - . - - . - . . - . - - - . - - -

- . . - _

a .; i ,

c

ATTACHMENT 4

RESPONSE TO DEFICIENCY 50-458/8706-04

REFERENCE

.

Letter - J. E. 'Gagliardo to J. C. Deddens, dated March 23, 1987.

DESCRIPTION

Notifications to parish representatives pertaining to the General

Emergency Declaration were delayed. Total notification time was 21

minutes after declaration. The initial protective action recommendation

took 32 minutes to make. These times exceeded the capabilities required

by 10CFR50, Appendix E, paragraph IV.D.3.

- CULF STATES UTILITIES COMPANY'S RESPONSE

.

The River Band Nuclear Station.must transmit the Notification Message

Forms to 8 state and local agencies. Each of these agencies can and

-frequently does ask questions about the message content. This results

in excessive delay in message transmission (11 minutes in one case and

over 20 minutes in the other).

It should be noted that the times it took to complete notifications were

correctly identified by the NRC. However, the 32 minutes notification

time did not occur during the initial Protective Action Recommendations

.(PAR) notification but rather during the first follow-up notification

message. The delay occurred when one parish (East Feliciana) failed to

respond to the initial all call and had to be contacted after.the

message was transmitted to the other state and local agencies.

Emergency Preparedness and the Nuclear Training Department have

'

conducted additional training on the Notification process. This has

reduced the time needed for notifications from that previously required.

However, it is not anticipated that additional training or practice will

j . .

appreciably reduce the time to make notifications.

'

GSU is currently pursuing an alternate method for making these

l

notifications so that a hardcopy of the approved notification message

!

form with PARS would be transmitted to all points in a sorter timeframe.

l ,

The alternate method will be implemented prior to the next scheduled NRC

l evaluated emergency preparedness exercise.

!-

.

{

l

I'

.t.

l

,

!

,