IR 05000285/1986011

Emergency Preparedness Insp Rept 50-285/86-11 on 860414-18. No Violations or Deviations Noted.Major Areas Inspected: Emergency Detection & Classification,Protective Action & Assessment & Shift Staffing & Augmentation

ML20206F189
Person / Time
Site:	Fort Calhoun
Issue date:	06/03/1986
From:	Baird J, Hackney C, Yandell L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20206F185	List: IR 05000285/1986011 ML20206F180
References
RTR-NUREG-0654, RTR-NUREG-0737, RTR-NUREG-654, RTR-NUREG-737 50-285-86-11, NUDOCS 8606240303
Download: ML20206F189 (8)

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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-285/86-11 License: DPR-40 Docket: 50-285 Licensee: Omaha Public Power District (0 PPD)

1623 Harney Street Omaha, Nebraska 68102 Facility Name: Fort Calhoun Station (FCS)

Inspection At: Fort Calhoun, Nebraska Inspection Conducted: April 14-18, 1986 Inspectors: hb / /ww$/

J. M. Baird, Emergency Preparedness Analyst

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Datd (paragraphs 5 and 6)

. 0 . Y L_ A _~ t / S ~ 16 - 96 C. A. Hackney, EmergencjbPreparedness Analyst Date (paragraphs 3 and 4)

_ a ud 423 APA Approved: L. n.'Yandell, Chief, Emergency Preparedness Ddte'

and Safeguards Programs Section

. Inspection Conducted April 14-18, 1986 (Report 50-285/86-11)

Areas Inspected: Routine, unannounced emergency preparedness inspection in the areas of emergency detection and classification, protective action decisionmaking, dose calculation and assessment, and shift staffing and augmentatio Results: Within the emergency response areas inspected, no violations or deviations were identifie pB606240303 860619 G ADOCK 05000285 PDR

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-2-DETAILS Persons Contacted Principal Licensee Personnel V. Anderson, Shift Supervisor

• R. Andrews, Division Manager, Nuclear Production

• C. Brunnert, Supervisor, Operations Quality Assurance

• A. Christensen, Chemical / Radiation Protection Technician M. Christensen, Instructor T. Dixson,. Chemical / Radiation Protection Technician D. Feighert, Emergency Planning Coordinator

• F. Franco, Manager, Radiation Health and Emergency Preparedness

• Gates, Manager, FCS S. Gebers, Health Physics Technician L. Kusek, Supervisor, Operations

• K. Morris, Division Manager, Quality Assurance and Regulatory Affairs C. Norris, Technical Services

• G. Roach, Supervisor, Chemistry and Radiation Protection F. Rutar, Engineer F. Smith, Plant Chemist J. Spilker, Acting Shift Supervisor

• K. Stultz, Technical Services C. Vanecek, Shift Supervisor S. Willrett, Supervisor, Administrative Services and Security State of Nebraska

• • J. DeFrame, Radiological Health Specialist, Nebraska Department of Health NRC

• Harrell, Senior Resident Inspector

• Denotes those present at the exit intervie ** Telephone contac . Licenseee Action on Previous Inspection Findings (Closed) Open Item (285/8330-01): The NRC inspectors determined that a new, adequate shower and decontamination facility had been provided in the training building (old EOF). This item is closed.

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-3-3. Emergency Detection and Notification The NRC inspector reviewed the appropriate sections of the Emergency Plan, hereafter called the Plan, and the Emergency Preparedness Implementing Procedures (EPIP's) as they related to the emergency action levels (EAL's)

and emergency classification. Additionally, the NRC inspector compared selected EAL's from NUREG-0654 to EAL's in the Plan. In most cases the-licensee used the same wording in the Plan as appeared in NUREG-0654. The NRC inspector also conducted interviews with selected representatives of the licensee's emergency response team. Personnel interviewed included selected shift supervisors, site directors and recovery managers. The interviews included discussions concerning previous training in dose assessment and post Three Mile Island (TMI) accident radiation monitoring, EAL's, offsite notification, protective action recommendations, authorities and responsibilities, responsibilities which could not delegated, evacuation of nonessential personnel, assignment of duties, activation of emergency response facilities, NRC notification and making a protective action recommendation given the EAL's and emergency classificatio Personnel interviewed were in most cases able to respond to the questions in a timely manner. However, a deficiency was observed in that one individual could not adequately respond to all questions concerning EAL's, classifications, notifications and protective action recommendations in a timely manner. Upon being briefed of the NRC observations, licensee management took immediate corrective action. The individual was given the training module for his emergency response area and licensee management committed to tasting the knowledge of this individual in this area prior to allowing him to resume his shift. The NRC inspectors stated that the licensee's corrective action appeared to be adequate to correct the deficienc The NRC inspector noted that the Plan referred to four emergency action levels. The Plan and EPIP's used the terms interchangably; however, the terms should be defined as they appear in 10 CFR 50, Appendix E.IV.B and Personnel were aware of notification times to offsite agencies; however, the licensee had not updated the Plan or EPIP's to reflect the requirement for notifying the NRC immediately following state and local agencies as stated in 10 CFR 50.7 The following are observations the NRC inspectors called to the licensee's attention. These observations are neither violations nor unresolved items. These items were recommended for licensee consideration for improvement, but have no specific regulatory requiremen EAL charts in each emergency response facility should have revision numbers in order to assure the user that the latest revision is being used.

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The Plan and EPIP's should address time for the emergency response facilities to become fully activated (refer to NUREG-0737 Supplement No. 1).

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The EPIP's appear to be difficult to use and should have a review by human factors personnel to make the EPIP's " user friendly."

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The emergency and normal organization charts and assignments should be revised to indicate the present licensee organizatio Site directors, recovery managers, and shift supervisors should have

" hands on" drills where they start from EAL's, make classifications, and develop the offsite protective action recommendation. Present training consists of an overview and discussion of those area No violations or deviations were identifie . Protective Action Decisionmaking The NRC inspector reviewed appropriate sections of the Plan as it related to authorities, responsibilities, and protective action decisionmakin The licensee had established a line of succession for overall emergency response to ensure the designation of an emergency coordinator at all times. Following the declaration of an emergency the shift supervisor would be in charge of emergency decisionmaking, and that responsibility would be turned over to the site director upon his arrival onsite. The final transfer would occur upon the arrival of the recovery manager at the emergency operations facility (E0F). The NRC inspector determined by Plan review and personnel interviews that several persons were authorized to make offsite protective action recommendations in addition to the emergency coordinator. It was noted that this was not consistent with the guidance of NUREG-0654, II.B.(4), which states that this is a /

nondelegatable responsibilit The NRC_ inspector also held interviews with selected individuals and discussed onsite protective measures and timely offsite protective action recommendations. The persons interviewed (with one exception identified in paragraph 2) understood the procedures for making timely offsite notifications and protective action recommendations. Personnel were aware of possible plant conditions and its relationship to offsite consequence The NRC inspector discussed the capability for the emergency response personnel to make the 15-minute notifications to offsite agenc'e The licensee representatives responded that they have had no prob 1Ln in making the 15 minute notifications to offsite agencie The NRC inspector determined that most personnel interviewed understood the change of command from the control room to the technical support center (TSC) and finally to the EOF. The personnel interviewed appeared to understand the correlation between plant abnormal conditions and potential offsite consequences. Additionally, it was understood that the licensee would advise the offsite agencies of protective action

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-5-recommendations; however, it would be the responsibility of the offsite agency to make the final decision on implementation of protective actions for the publi Emergency personnel were given a situation where a General Emergency had been declared based on two out of three fission product barriers having been breached with a possible loss of the third fission product barrier. With the exception of the individual reported above, all of the persons interviewed responded corrected and according to Procedure EPIP-0SC-1.1 in a timely manne The NRC inspector also discussed offsite emergency response capabilities by telephone with the Federal Emergency Management Agency (FEMA)

Region VII Radiological Assistance Committee Chairman. The FEMA represen-tative reported that the state of Nebraska plan had been reviewed and determined adequate pursuant to 44 CFR 350, but the state of Iowa plan had not received the 44 CFR 350 approval ye The following are observations the NRC inspectors called to the licensee's attention. These observations are neither violations nor unresolved item These items were recommended for licensee consideration for improvement, but have no specific regulatory requirement:

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Notification forms should have signature approvals (shift supervisor, site director, or recovery manager) for releasing protective action recommendations to offsite agencie Protective action recommendations to offsite authorities should be listed as an authority that cannot be delegated (EPIP-0SC-14-1);

refer to NUREG-0654, 11.B.(4).

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EPIP E0F-7-1, III.B., and other procedures, should be revised to be consistent with the change recommended above relative to NUREG-0654 II.B.(4).

No violations or deviations were identifie . Shift Staffing and Augmentation The NRC Inspector reviewed Table B-1 of the emergency response plan, discussed shift staffing and augmentation with licensee. representatives and reviewed selected personnel qualification records to determine if the goals and criteria of Table B-1 of NUREG-0654 could be met. A review of augmentation evaluations dated March 3, 1982, June 27, 1983, and July 11, 1985, was also conducted. In addition, the NRC inspector reviewed licensee correspondence providing augmentation study results to the NRC dated March 1, 1982, and June 1, 1982. These reviews indicated that the licensee had made adequate provisions for shift staffing and augmentation to deal with emergencies. However, it was noted that the licensee's augmentation studies completion times for the 30-minute and 60-minute categories of Table B-1 of NUREG-0654 were both essentially consistent with the 60-minutes goal and augmentation goals were not stated in the Plan. No augmentation drills had been conducted at the time of the

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inspection. This area will be reviewed again during a future inspection after an augmentation drill has been conducte The NRC inspector determined that contact of emergency response personnel needed to augment the onshift staff would be by telephone contact initially by the control room communicator and, upon arrival, the TSC communicato Only the duty plant manager and offsite emergency planning staff were assigned pagers. The licensee depended on having a number of personnel qualified and assigned to emergency response positions for availability to respond to an augmentation call. The NRC inspector noted that an emergency response organization telephone book was maintained with home and work telephone numbers for station and offsite staff. The call list was tested once per quarter and a test completion record was maintained. Although no record was maintained of each call, a licensee representative stated that a new autodialer system would be implemented soon which would provide this capabilit The following are observations the NRC inspectors called to the licensee's attention. These observations are neither violations nor unresolved item These items were recommended for licensee consideration for improvement, but they have no specific regulatory requiremen Section N of the Plan should be revised to include a requirement for augmentation call-out drills on an established frequency consistent with the other drills specified in that sectio Time goals for augmentation staffing should be stated in the Plan and implemented through procedure No violations or deviations were identifie . Dose Calculations and Assessment The NRC inspector 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. During the TSC tour, the NRC inspector observed that non-emergency material was stored there and a general state of poor housekeeping existed. This was reported to licensee management. A representative of the state of Nebraska was also contacted to discuss the state capability and compatibility of dose calculation This discussion indicated that the state had experienced good cooperation with OPPD on establishing dose assessment techniques and no significant compatibility problems had been identified during previous drills and exercise A review of dose assessment procedures showed that the licensee had provided manual and computerized methods for rapidly performing emergency dose projections. The dose assessment techniques were implemented in EPIP EOF-6, "Onsite and Offsite Dose Assessment." The dose assessment techniques ranged from a simple graphical procedure for control room use

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~7-during the initial response to an emergency, to various options using inplant and offsite monitoring results on computer terminals located in the TSC and EO The computerized method (EAGLE) was capable of making rapid dose projections as well as assessing the radiation doses received offsite during the emergenc The NRC inspector observed demonstrations of the graphical technique of dose assessment in the control room and the EAGLE method of assessment with the computer terminals in the TSC and EOF. It was determined that each of the dose assessment technioues could be accomplished in a timely fashion. During the demonstration in the control room, it was noted that the shift chemist performing the assessment did not have a desk or table to work on and used his own calculator. In the TSC, the NRC inspector noted that the dose assessment operator had to spend several minutes printing out the print buffer contents prior to getting a hard copy of the dose assessment scenario being demonstrated. Both of these observations were t-ought to the licensee's attentio A subsequent review of the results of each of the dose assessment demonstrations and discussions with licensee personnel revealed that the graphical method could be conservative by factors of up to 100, depending on the release parameters and the stability classificatio This could result in confusion with offsite agencies performing independent dose assessment and an initial recommendation of overly conservative protective action Based on the above, the following item is considered to be an emergency preparedness deficiency:

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The manual graphical method of dose assessment provides excessively conservative dose assessment projections for some release scenarios and atmospheric stability classifications (285/8611-01).

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The following are observations the NRC inspectors called to the licensee's attention. These observations are neither violations nor unresolved items. These items were recommended for licensee consideration for improvement, but have no specific regulatory requirement A work space and calculator should be provided in the control room for the on-shif t person assigned to perform dose assessment calculation A mechanism should be provided to allow rapid printout of the dose assessmert data without waiting for the print buffer to clea Housekeeping in the technical support center should be improved to maintain a state of readiness at all time No violations or deviations were identifie ,~

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-8-7. 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 April 18,;1986. The NRC inspectors summarized the purpose and scope of the inspection, and reported the findings which included a deficiency in the emergency preparedness progra