IR 05000285/1998018

Insp Rept 50-285/98-18 on 980831-0902.No Violations Noted. Major Areas Inspected:Changes to Fort Calhoun Station Radiological Emergency Action Levels

ML20154H522
Person / Time
Site:	Fort Calhoun
Issue date:	10/08/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20154H511	List: IR 05000285/1998018 ML20154H507
References
50-285-98-18, NUDOCS 9810140222
Download: ML20154H522 (6)

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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-285

i License No.: DPR-40 i-Report No.: 50-285/98-18 l

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Licensee: Omaha Public Power District Facility: Fort Calhoun Station

Location

Fort Calhoun Station FC-2-4 Ad P.O. Box 399, Hwy. 75 - North of Fort Calhoun Fort Calhoun, Nebraska Dates: August 31 through September 2,1998 i

inspectors: Thomas H. Andrews, Emergency Preparedness Analyst (Team Leader)

Randolph L. Sullivan, Emergency Preparedness Specialist James B. O'Brien, Emergency Preparedness Specialist ;

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Approved By: Blaine Murray, Chief, Plant Support Branch  !

Division of Reactor Safety )

l Attachment: Supplemental Information j l

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l 9810140222 901000 PDR e

ADOCK 05000285

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_ EXECUTIVE SUMMARY Fort Calhoun Station NRC Inspection Report 50-285/98-18 '*

A reactive, announced inspection was conducted involving changes to the Fort Calhoun Station radiological emergency action level Plant Sucoort

An unresolved item was identified related to changes made to emergency action levels that may have resuhN in a reduction in the effectiveness of the emergency plan

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(Section P3).

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3-Report Details IV. Plant Support P3 EP Procedures and Documentation inspection Scope In 1997 and 1998, the licensee made changes to the emergency action levels contained in Emergency Plan Implementing Procedure EPIP-OSC-1," Emergency Classification."

In accordance with 10 CFR 50.54(q), these changes were reviewed by the licensee and a determination was made that the changes did not result in a reduction in the effectiveness of the emergency plan. The changes made by Revision 27 were extensive, and Revision 28 made further changes to the emergency action level Based upon an in-office review, over 80 issues were identified that needed additional information before the significance of the changes could be resolved. During this inspection, the inspectors reviewed documentation associated with these issues to determine their significance.

I Observations and Findinas Discussions with licensee personnel provided useful insight into how the emergency action levels were developed and how they are used at the licensee's facility. Most of the issues identified during the in-office review were determined to be of minor significance or were resolved, Prior to the inspection, the licensee conducted an audit of the changes made to the emergency action levels. The audit was very thorough and comprehensive. The licensee-identified areas where improvements were needed and initiated corrective actions to address these areas. The inspectors noted that one reference used to justify the appropriateness of changes was a draft gt'idance document that had not been endorsed by the NRC. Therefore, some of the results of the audit were different from the findings made by the inspector During the inspection, there were several changes to emergency action levels that may have resulted in a reduction in effectiveness of the emergency plan. If these changes did result in a reduction in effectiveness of the emergency plan, it would be a violation of 10 CFR 50.54(q). The changes identified as potential reductions during the inspection included:

• Emergency Action Level 1.1 - RCS radioactivity exceeds technical specification l

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• Emergency Action Level 8.5 - General area radiation / airborne levels outside containment are > 1,000 times background

• Emergency Action Level 9.1 - A confirmed hostage situation is occurring in the l protected area, but outside of the vital areas l

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• - Emergency Action Level 9.3 - Bomb / sabotage device detected in the protected area, but outside the vital areas ,

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• Emergency Action Level 9.4 - Confirmed protected area intrusion

• Emergency Action Level 9.5 Confirmed hostage situation in a vital area a Emergency Action Level 9.7 - A confirmed bomb / sabotage device has been ,

detected in a vital area

• Emergency Action Level 9.8 - A confirmed vital area intrusion is occurring

• Emergency Action Level 9.9 - Confirmed armed attack is occurring inside a vital area affects the ability to maintain functions needed for cold shutdown

• Emergency Action Level 9.10 - Confirmed Armed Attack inside a Vital Area That Affects The Ability to Maintain Functions Needed For Hot Shutdown The most significant concerns were associated with emergency action levels for security ,

events for the site area emergency and general emergency classifications. Emergency Action Levels 9.9 and 9.10 did not appear to be consistent with regulatory guidanc According to NUREG-0654/ FEMA-REP-1, " Criteria for Preparation and Evaluation of i Radiological Emergency Response Plans and Nuclear Power Plants," Revision 1, a site area emergency would be declared for imminent loss of physical control of the plant. A .

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general emergency would be declared for loss of physical control of the facility. The regulatory guidance provided in NUMARC/NESP-007,"NUMARC Emergency Action Levels," Revision 2, indicated that a site area emergency would be declared for a

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security event in the vital area and a general emergency would be declared for loss of physical control of the plant or systems required to achieve and maintain cold shutdow i On September 30,1998, in a phone call between Mr. Ronald Meng and the team leader, i Mr. Meng stated that Emergency Action Levels 9.9 and 9.10 were being revised to I address the inspector's concerns. The revisions being made were:

Site Area Emergency - Confirmed armed attack occurring in plant vital area General Emergency - Physical loss of control to control room or auxiliary feed water panel, or remote shutdown panel The inspectors determined that these changes were consistent with the NUMARC emergency action levels, and sufficient to address the immediate concerns identified '

during the inspectio The Office of Nuclear Reactor Regulation (NRR) was requested to provide an agency position regarding the appropriateness of the plan changes. This matter is considered an unresolved item pending NRR action (50-285/98018-01).

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c. Summary I

An unresolved item was identified related to changes made to emergency action levels '

that may have resulted in a reduction in the effectiveness of the emergency pla V. Manaaement Meetinas .

X1 Exit Meeting Summary

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The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on September 2,1998. The licensee acknowledged the facts presented. No proprietary information was identifie Following NRC management review, one issue characterized as a potential violation  ;

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during the exit meeting was changed to an unresolved item. A second exit meeting was conducted by telephone on September 9,1998, to inform the licensee of this change.

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On October 8,1998, in a telephone conversations between Mr. R. Meng, Mr. E. Matzke, and the team leader, the licensee was informed that Emergency Action Level 1.1 had been omitted from the discussion during the exit meeting. Mr. Meng stated that adding this as an additional example to the unresolved item did not require another exit meeting. Mr. Meng stated that Omaha Public Power District management had been j informed of the addition. Mr. Matzke stated that in response to NRC concerns, the emergency action level procedure had been revised to address Emergency Action Levels 1.1, 8.5, 9.9 and 9.10.

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I ATTACHMENT SUPPLEMENTAL INFORMATION

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PARTI AL LIST OF PERSONS CONTACTED Licensee ,

l lJ. Chase, Manager, Nuclear Assessment

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O. Clayton, Manager, Emergency Planning' 7

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S. Gebers, Manager, Radiation Protaction T. Herman, Senior Quality Assurance Lead Auditor R. Meng, Senior Emergency Planning Representative ,

H. Sefick, Manager, Security Services INSPECTION PROCEDURES USED i IP 82701 Operational Status of the Emergency Preparedness Program ITEMS OPENED ,

Opened 50-285/98018-01 URI Emergency action level changes may result in a reduction in effectiveness of the emergency plan l

DOCUMENTS REVIEWED Emergency Plan implementing Procedures:

EPIP-OSC-1, " Emergency Classification," Revision 26 EPIP-OSC-1, " Emergency Classification," Revision 27 EPIP-OSC-1," Emergency Classification," Revision 28 Other Documents: l l

Emergency Action Level Basis Document for EPIP-OSC-1," Emergency Classification,"

Revision 27 Nuclear Safety Evaluation ID No. 47784 l

l Nuclear Safety Evaluation ID No. 47784A f Condition Report No: 199801731

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l- Memorandum FC-RP-119-98