ML20086S105
| ML20086S105 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/20/1991 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F191-0825, W3F191-825, NUDOCS 9201030043 | |
| Download: ML20086S105 (5) | |
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W3F191-0825 A-1. 05 QA December 20. 1991 U.S. huelear llegulatory ( oininission ATTN: Docunies:.t Control liesk Washingtoni, D.C.
20555 Subject : Waterford 3 SES Dochet No. 50-382 1,1 cense No NPF-38 NitC luspection lleport 91-27 Gentleinen t l'ntergy Operations, Inc. hereby subnilts the responses to the thleo cinergency exercleo weaknesses, whleh were klentiflod during the 1991 nuntial eineigency exerciso and docuinented in the subject Insliection Iteport. These responses arc attached and include descriptions of correctivo inensures and schedules for 2oinpletion as requested, if you have any cluestions concerning these responses, please coittact F.J. Englebracht. Einergency l'lanning & Admhdstration Main.ger, at (501) 739-6007.
Very truly yours.
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ATTACllMENT INC. RESPONSES TO EMEltGENCY EXEllC!SE ENTEltGY OPElt ATIONS,IK1 ENTE!) IN INSPECTION ItEPollT 91-27 WEARNESSCS 1) ort WEAKNESS NO. 9127-01:
The Control lloom (Cit) staff experienced problems in performing off-site dose i
usannsments while attem > ting to evahmte the radiologleal consequences of the waste gas decay tank re ease. From about 9 to 9:15 a.m. following the declaration of an Alort, doso assessment was performed using the computer based dose assessment program as speelfled in Procedure El' 002-050, "Offsite Doso j
Assessment," Revision 11. The stack monitor readings were entered into the dose assosoment program in such a way that the exponent of the readhig was not roeognized. This resulted in the off-sito doso calculations being in error high by-the same order of magnitudo as the exponent. The calculation, whleh Judicated General Emergoney conditions, was questioned by the CR staff. No action was taken as a result of the erroneous results becauso in the judgemout of the Cit staff, the results did not correlato to the actual plant conditions, a
Because of the questionable results obtained using the computer dose assessment i
method, off-sito dono projections woro calculated a second timo using the manual nomogram method. With this method the Cit staff incorrectly entered the plant' stack flow rate onto the logarithmic scale. This resulted in a calculated doso rato at the exclusion area boundary of 5 millirem per hour (mrem /hr) versus tho i
correspondhig scenarlo value of about 40 mrem /hr. The actual value was finally calculated using the computer method, when the Cit staff correctly ontored tho plant stack data.
itESPONSE i
(1)_
lienson For The Weakness The failure to calculato correctly off-sito doso projections via the Control lloom personal computer (PC) is attributed to the presentation of stack monitor readings in an atypteal format. These readings were presented to the Control lloom (Simulator) staff without the selentific notatioit exponent identifier "E" In the reading (l.c., the readings were in the format-X.XXiXX vico X.XXEiXX). The operator entered the readings into the PC oxuctly as they were prosented. Consequently, the PC Interpreted'the readings as havhig no exponential values, which resulted in significantly~
i highor calculated off-sito doses.
The failure to calculato correctly off-sito dow projections-vla the backup 1
manual nomogram method is considered to be ir anan error-.
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(2)
Corrective Actions /Scheduto for Completion l
The computerized nomogram prograta for performing off-site dosu assessments has been revised to accept monitor reading entries in tho formats X.XXAXX and X.XXEiXX. This program revision will allow the PC to recognize exponential values should the operator inadvertently omit tho scientific notntion exponent identiflor "E" in futuro similar entries. In addition, EP-002-050 will be revisod to includo guidance on the proper format to enter monitor reading values.
The manual nomogram will be revised to implement human factor
. improvements. Theso improvements will include numbering all visible scale lucrements (as opposed to just one increment on each scalo) and providing arrows to hulicate the direction of increasing scale values.
Speelal taalning seminars will be conducted by Emergency I'lanning for each Operations shift. A portion of those seminars will be devoted to actual performance of doso assessment using both' the computerized and manual methods, and to a lessons learned discussion of the doso asucasmont nroblems documented by this exercise weakness in addition, a similar lessons learned discussion will be included in lesson plans for Control Itoom personnel. Tim above actions will be completed by April 3,1992.
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7 WEAKNESS NO. 9127-02:
The emergency coordinator in the TSC as well as the EOF director mistakenly believed that a fuel barrier breach had occurred. The Inspectors did not observo this error being challenged by the respective staffs. Proceduro EplP EP-001-001, EAL B/Allit defines a fuel barrler breach as (1) dose equivalent lodine concentration in the reactor euciant system greater than 300 microcurles per gram, or (2) core exit thermocouple temperatures greater than 700 degrees Fahrenholt, or (3) reactor coolant pump shaft seizure in Mode 1.
During the exerciso, none of these conditions applied to known plant conditions; therefore, the assessment of fuel barrier breach was not appropriate.
The detection and assessment of the failed fuel barrier and its use for classification purposes without having met the speelfled criteria for this condition.
was identitled as an exercise weakness.
It EspONSE:-
(1)
Reason For The Weakness The root cause of this weakness has not been determined. Ilowever, Entergy Operations, Inc. believes that EP-001-001, " Recognition und Classification of Emergency Conditions," may not clearly present the indicators of fuel cladding failuro and challenged conditions. In addition, this condition may have given rise to an overly conservative training approach with respect to the detection and assessment of fuel failuro and its use for classification as loss of a fission product barrier. Furthermore, it should be noted that these ludicators are not intended to constituto the full definition of fuel cladding failure, but rather are presented as tools that provide assistance hi interpreting or clarifying this condition.
(2)
Corrective Actions /Schedulo For Comnletion EP-001-001 and its associated Basis Document will be ovaluated in concert -
with this exercise weakness to identify changes to enhanco emergency -
training and the decision-making process with regard to failed fuel. In addition, lesson plans for Shift Supervisors / Control Room Supervisors, Emergency Coordinators,. EOF Directors, TSC Operations Coordinators, TSC Supervisors, TSC Lead Engineers, TSC Nuclear Engineers, EOF Operations / Engineering Coordinators, EOF Operations / Engineering Coordinator Assistants. EOF Nuclear Engineers, and Deputy EOF Directors
- will be revised to include a discussion of this weakness as a lesson learned.
Furthermore, Emergency Planning will conduct special training seminars for each of these emergency positions. These seminars will be devoted to a discussion of classifiention activities associated with barrier failures and will be used as a forum to discuss the problems documented by. this weakness as lessons learnedc-The above actions, includin~g the implementation of any procedure revisions deemed appropriate by the evaluation, will be completed by April 3,1002.
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Attaciunent to W3F191-0825 Pagu 1 of 1 WEAKNESS NO. 91027-03:
L The inspectors observed that official notifications and updates of the etrergency elassification were made to of f-site agencies as required from the EOF. In revlowing the notification message sheets which contained the Information conveyed in the notifications, the inspectors found that certain errors or omissions were contained in the messages. For examplo, in the notifications of I
the Alert and GE, the information on expected releana duration was omitted, as was the information on the type of radioactivo gas release in progress, hi addition, the value for the wind speed, ludicated in miles por hour, actually corresponded to the wind speed in meters per second. The Alert notification gave no indication of the release rate for noblo gases, lodinoa, and partleulates; or for particulates in the GE notification, nor was "not available" ontered in the abseneo of tids information. These errors and omissions could cause off-site agencies to base their independent assessments on incomplete or erroneous information and, hence, to reach incorrect or inapproprinto conclusions. The failure to complate all applicable entries in the notification mensages supplied to off-site agencies with accuruto information was identified as an exercise weakness.
R ESpONSE:
(1)
Reason For The Weakness The root causes of this weakness were inattention to detail and failure to review Notification Messago Forms against the Notification Messago Form Guidelines in Ep-002-010, " Notifications and Communications."
(2)
Corrective Actions /Schedulo For comnletion Lesson plans for individuala assigned to complete and technically review offsite notifications will be revised to emphasize the use of the Notification Message Form Guidelines and to provide a discussion of this exercise weakness. The lesson plans to be revised are those for Shift Supervisor / Control Room Supervisor, Control Room Emergency -
Communicator, TSC Dose Assessment Coordinatori TSC llealth Physics Coordinator, TSC llealth physics Coordinator Assistant, TSC Communicator, EOF Field Team Controller, EOF Radiological Assessment -
Coordinator, EOF Radiological Assessment Coordinator Assistant, and EOF Communicator. In addition, special training seminars will be conducted by i
Emergency planning for each of these emergency positions. The abovo -
actions will be completed by ' April 3,1992.
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