IR 05000285/1990029
| ML20055E447 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 07/05/1990 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Gates W OMAHA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 9007110348 | |
| Download: ML20055E447 (3) | |
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In Reply Refer To:
Docket:
50-285/90-29 Omaha Public Power District ATTN:
W. G. Gates, Division Manager Nuclear Operations 444 South 16th Street Mall Mail Stop 8E/EP4 Omaha, Nebraska 68102-2247 Gentlemen:
Thank you for your letter dated June' 22,1990, in response to'our'
emergency preparedness inspection report and Notice of Violation dated May 23, 1990.
We have reviewed your reply to the training violation,'and the violation involving failure to perform an emergency preparedness surveillance, and find them responsive to the concerns raised in our inspection report.
We will review the implementation of your corrective actions during a future inspection.
Sincerely,
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Original Signed By Samuel J. Collins, Director
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l Division of Reactor Projects cc:
LeBoeuf, Lamb, Leiby & MacRae ATTN:
Harry H.-- Voigt Esq.
1333 New Hampshire Avenue, NW Washington, D.C.
20036
Washington County Board of Supervisors ATTN:
Jack Jensen, Chairman Blair, Nebraska 68008 l
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Combustion Engineering, Inc.
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Charles B. Brinkman, Manager Washington Nuclear Operations
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Rockville, Maryland < 20852 Department of Health ATTN: ' Harold Borchert ' Director
_ Division of Radiological Health 301 Centennial Mall, South
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P.O. Box 95007 Lincoln, Nebraska 68509 Fort Calhoun Station ATIN:!
G.'R. Peterson, Manager P.O.' Box 399
.FyrtCalhoun, Nebraska 68023'
U.S. Nuclear Regulatory Commission
ATTN:
Resident, Inspector-
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Fort Calhoun, Nebraska U.S. Nuclear Regulatory Commission ATTN:
Regional Administrator, Region'IV; 611 Ryan Plaza Drive.-Suite 1000'
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1623 Harney Omana. Nebrana 68102 2247
402/536 4000 June 22, 1990 AH 2 51990 LIC-90 0517 f
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U. S. Nuclear Regulatorbesk Commission Attn: Document Control Matl Station Pl 137 Washington, DC 20555 REFERENCES:
1.
Docket No. 50 285
Letter from NRC (S. J. Collins) to OPPD (W. G. Gates) dated May 23, 1990 3.
Letter from OPPD (W. G. Gates) to FAC (Document Control Desk) dated April 27, 1990 (LIC-90 0351)
Gentlemen:
SUBJECT:'
Response to Notice of Violation (Inspect 17n Report 50285/9029)
Omaha Public Power District (OPPD) received the subject inspection report which identified two violations.
Violation 1 pertains to some key emergency personnel not having been adequately trained to perform accurate and t.imely i
offsite dose projections early in an emergency.
Violation 2 involved the failure to complete a procedure during 1989 that requires an annual I
verification of the completion of training of emergency response personnel.
Please find attached OPPD's response to the Notice of Violation in accordance with 10 CFR Part 2.201.
If you should have any questions, please contact me, j
Sincerely, MN
. G. Gates Division Manager Nuclear Operations
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Attachment c:
LeBoeuf Lamb. Leiby & MacRae A. Bournia, NRC Project Manager i
R. D. Martin -NRC Regional Administrator, Region IV P. H. Harrell, NRC Senior Resident inspector n 9 W2-- kl) %
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ATTACHMENT RESPONSE TO A NOTICE OF VIOLATION Ouring an NRC inspection conducted on April.23 27,1990, two violations of NRC-P requirements were identified.
In accordance with the " General Statement of
Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C
(1990) (Enforcement Policy), the violations are listed below:
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shall be prov(b)(15)-states that' radiological emergency response training I
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ided for those who may be called to assist in an emergency.
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Section 7.1 of the emergency preparedness training manual ' states that the L
objective of the emergency preparedness training program is to maintain the qualifications for those individuals-assigard to the emergency response organization.
The Fort Calhoun Radiological Emergency Response Plan, Part H Section 4.1 states, in part, that the shift supervisor _is responsible that several key emergency-preparedness' actions.are performed including, i
among others listed, classifying the emergency, providing initial dose assessments, and making. protective action recommendations to 'offsite authorities.
Emergency Plan laplementing Procedure EOF-6-A-1,
"Onsite/Offsite Dose Assessment "Section IV.A.1 states that the shift
- chemist shall perfom dose asses,sments with the shift health physicist as the alternate.-
Contrary to the above, at the time of the inspection, the inspector
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determined from interviews of key emergency responders, who;might be called i
upon to assist in an emergency, that their radiological emergency response training was not sufficient to maintain' their qualifications.
Specifically, these personnel could not provide ^ accurate and timely dose assessments and they made errors in classifying.certain emergency conditions and in making proper offsite authorities in response protective action recommendations to
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to hypothetical emergencies.
This is a Severity Level IV violation.
(Supplement VIII)
(1) The Reason For The Violation. It' Admitted OPPD admits to the violation as stated.--The reason for the violation is
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that OPPD did-not properly identify weaknesses with the manual dose assessment procedure nce did OPPD routinely test'the abilities of the-Control Room dose assessment personnel to reinforce, and determine the
'l adequacy of, their annual-dose assessment training.
Additionally, the philosophy of the Shift Supervisor to wait for a final-dose assessment prevented the prompt classification and notification of off-site agencies.
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(2) The Corrective'Steos Which Have Been Taken And The Results Achieved Five chemistry technicians were provided refresher training on April 27, 1990 on the existing EPIP-EOF-6,~ including the requirement to correctly perform six timed manual dose calculations.
This' training was conducted to ensure the availability of at least one requalified technician per shift to handle manual dose calculations, as discussed in-Reference 3.
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EPIP EOF 6, " Manual Dose Calculations," was revised'by a committee i
comprised of Emergency Planning (EP)
Emergency Planning Training,
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Radiological Services, Radiation Protection and Chemistry department
representatives, and provided to the Plant Review Committee (PRC).
Following approval by the PRC, all of the shift chemistry technicians.were trained to the revised EPIP EOF 6 procedure on May 8 and May 9,1990._ This training consisted of a graded examination, including a minimum of one calculation in each applicable section of EPIP EOF-6.
This-process ensured
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that Fort Calhoun had sufficient qualified shift personnel to perform that manual dose assessment calculatic.ts per the revised procedure, prior to:
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start up from the refueling-outage.
Following' successful training, the
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revised procedure was implemented on May 16, 1990.- A copy of EPIP-EOF 6,
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Revision 17, was provided to NRC Region IV personnel on May 23, 1990.
(3) Corrective Actions That Will Be Taken'To Avoid Further Violations
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OPPD will periodically transmit a series of manual dose assessment training packets to the shift chemistry technicians.
The technicians will be required to complete, and then return the training packets to.the Training Department.
The Training Department will evaluate each packet.and reviews
identified weaknesses with the appropriate chemistry technician (s).
This process will help to ensure the. technicians stay abreast of the content and their responsibilities within EPIP-EOF-6.'
l 0 PPD will have shift radiation: protection technicians and dose assessment specialists trained on the new manual-dose calculations, as identified in
EPIP-EOF-6.
To reinforce this training, periodic dose assessment training l
packets will be transmitted to these personnel similar to the shift chemistry technicians above.-
During the next regularly scheduled EP training cycle, the philosophy of classifying an emergency based on plant and radiological conditions, in addition to dose assessment, will be covered with the Shift Supervisors.
(4) Date When Full Come11ance Will Be Achieved 0FPD will implement the transmittal of periodic dose assessment training packets for shift chemistry technicians by Ju;y 1, 1990.
OPPD will have shift radiation protection techaicians and dose assessment personnel trained on the revised EPIP-EOF-6 by Septembwr 30, 1990. 'The follow-up program involv!ng transmittal of periodic dose assessment training packets will be implemented following completion of initial
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training.
Training for the Shift' Supervisors will also be completed by September 30,'1990.
OPPD will be in full compliance by-September 30, 1990.
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10 CFR 50.54 nuclear power (q) requires, in part, that a licensee authorized to operate a
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R reactor shall follow and maintain in e<fect emergency plans which meet the. standards in 50.47(b) and the requirements in Appendix E to this part.
Part 0, Section 9.0 of.the radiological emergency response plan
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states that Emergency Preparedness Test'12 (EPT 12), " Emergency Response i
Training," outlines the proceiure used to verify training received by t.
emergency response personnel.
EPT-12 Section F.3, requires that the
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l annual training of emergency response, personnel will be verified acnually in accordance with the test procedure..
L Contrary to the above during 1989, no verification of annual training of-onsite emergency respo,nse personnel had been performed in accordance with L
EPT-12.
This' is a Severity Level IV violationf(Supplement VIII)
.(1) The Reason For The, Violation. If Admitted-
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OPPD admits to the violation as stated.
The reason for.the violation was-l the lack of proper management of the Emergency Preparedness Test (EPT)
program.. Proper management oversight of the EPT program would have identified'this deficiency at an. earlier date.
(2) The Cor*ective Stoos Which Have'Been Taken And The Results Achieved OPPD took immediate corrective actions to complete EPT-12 Section F.1, on May 1, 1990.
A completed copy of this: test was provided to NRC Region IV:
personnel.on May 23, 1990.
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(3) Corrective Actions That Will Be Taken'To Avoid Further Violations OPPD is currently developing a computer data base to' assist the Supervisor-
- Emergency Planning in the administration.of the EPT program.: The data base will allow the proper tracking of submittal and due dates associated with the various EPTs, in a similar manner to which Fort'Calhoun's surveillance tests are tracked.
a member of the Emergency Planning Department. Currently this process is done m (4) Date When Full Comoliance Will Be Achieved OPPD will have a computer data base completed and usable by September 1, 1990. At this time OPPD will be in full c%.pliance.
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