ML20039B151
| ML20039B151 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 11/09/1981 |
| From: | William Jones OMAHA PUBLIC POWER DISTRICT |
| To: | Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20039B146 | List: |
| References | |
| NUDOCS 8112220344 | |
| Download: ML20039B151 (6) | |
Text
'
i Omaha Public Power District e
OMAHA, NEBRASKA 64,102 e TELEPHONE 535 4000 AREA CODE 402 162] HARNEY
't November 9, 1981
's Mr. K. V. Seyfrit, Director
% L5 @g g b qh. N h,h g
U. 5. Nuclear Reaulatory Commission
.5 Office of Inspection and Enforcement is J.,.
~--
4 g l g lggl
'1l)
Region IV '
~
i x
611'Ryan Plazs Drive, Suite 1000
,l
- it u Arlington, Texas 76011 i
Reference:
Docket No. 50-285 Inspection Report 81-19
~
Dear. Mr. Seyfrit:
~?
. The referenced Inspection Report identified two violations related i,
to-the July 22, 1981 emergency exercise at the Fort Calhoun Station.
Omaha Public Power District's response to the two violations is attached.
..~
Sir'cepely, h
i M
W. C.
Jones
,( \\
Divisi on Manager Produdtion Operations
<< 7 4
WCJ/KJM/TLP:jmm
- h. ',
Attachment 3
U. S. Nucle 6r Regakatory Commission cc:
Offica of' Inspection and Enforcement Washington, D.C.
20555 m
LeBoeuf, Lamb, Leiby & MacRae
~
1333 New Hampshire Avenue, N.W.
s L-Washington, D.C.
20036 Ie W 8112220344 811215 PDRADOCK05000g G
~.
- l-UNITED STATES 0F AMERICA
. NUCLEAR REGULATOR'i COMMISSION
- In the Matter of-
)
)
Omaha Public Power Dinrict
)
Doc'Ket No. 50-285 (Fort Calhoun Station,
)
j
. Unit No. 1)
)
..... being duly sworn, hereby deposes and says that he is Division Manager - Production Operations of Omaha Public Power District; that he is. duly authorized to sign and file with the Nuclear Regulatory Com-mission the attached response to the Notice of Violation identified in NRC Inspection Report 81-19; that he is familiar with the content thereof; and that the matters set forth therein. e.true and correct to the'best of his knowledge, information and-tre1)i A W W. C.
ones Divis n Manager Produ ion Operations
- l STATE OF NEBRASKA)
) ss
- COUNTY OF DOUGLAS)
Subscribe'd and sworn-to before me, a Notary Public in and for the State of Nebraska on this
/27a day of November, 1981.
i I4ALa t
- ' Notary Public o....,_...............
' v-
- J. T. GLEASON -
c,k My Com Es. July 26. 482 ;
t e
4 4
~
DISTRICT RESPONSE TO IE INSPECTION REPORT 81-19 Violation 1.
10 CFR 50 Appendix E.IV.D.3., states that "A licensee shall have the capability to notify responsible State and local government agencies within 15 minutes after declaring an emergency. The licensee shall demonstrate that the State / local officials have the capability to make public notification promptly on being informed by the licensee of an emergency condition.
By July 1, 1981, the nuclear power reactor licensee shall demonstrate that adminis-trative and physical means have been established for alerting and providing prompt instructions to the public within the plume exposure pathway EPZ. The design objective shall be to have the capability to essentially complete the initial notification of the public within the plume exposure pathway EPZ within about 15 minutes.
Tbs use of this notification capability will range from immediate notification of the public (within 15 minutes of the time that State and local officials are notified that a situation exists requiring urgent action) to the more likely events where there is l
substantial time available for State and local governmental of-l ficials to make a judgment whether or not to activate the public notification system."
It is recognized that the Notice of Proposed Rulemaking for 10 CFR 50 presently proposes changing the prompt public notification capability requirement from July 1,1981,. to no later than February 1, l
(
1982, however 10 CFR 50 Appendix E.IV.D.3. states that both the physical and administrative means shall have been established.
Contrary to 10 CFR Appendix E.IV.D.3. the licensee could not demonstrate the administrative capabilities for prompt notification throughout the 10-mile Emergency Planning Zone.
This is a Severity Level IV Violation (Supplement I.D.3.).
Response
1.
Corrective steps which have been taken and the results achieved.
A radio activated early warning siren system presently being installed will replace the existing means of alerting the public within the 10-mile Emergency Planning Zone (EPZ). The present method for public alerting was detailed in the District's letters to the Commission dated December 12, 1980 and June 26, 1981 and relied upon state police, fire, and civil defense agencies for public notification.
The early warning siren system will consist of 95 radio-controlled sirens strategically placed throughout Nebraska and Iowa designed to alert 100% of the public within the EPZ within 15 minutes.
This early warning siren system is scheduled to be operational by January 1,1982.
.e The July 22, 1981 emergency exercise brought to the District's attention the need for improved direct communication capabilities with local and state Emergency Operations Centers (E0C's).
In-stallation of dedicated telephone " hotline" circuits to all of the local-and state E0C's has been completed, except for the circuit to the Harrison County, Iowa EOC which is scheduled for completion by November 20, 1981. The three local government E0C's which have responsibility for activation of the early warnirg siren system will then each have direct communication, in addition to dial telephone capability, with the Omaha Public Power District.
A restructured " Radiological Emergency Response Plan" (the Plan) was issued on October 22, 1981.
Section E of the Plan, entitled
" Notification Methods and Procedures", details administrative cuidelines for notification of and ccmmunication with the county governments responsible for physically initiating the early warning sirens. Administrative control of public notification throughout the siren system is managed by the District using the Emergency Plan form entitled " Initial Report to Offsite Government Agencies".
The revised Emergency Plan provides improved guidance for develop-ing and coordinating the administrative procedures to be used by tne District and state and local government agencies for notifying the public.during an emergency.
2.
Corrective steps which will be taken to avoid further violations.
The Fort Calhoun Station Emergency Plan Implementing Procedures (EPIP's) are being reviewed with the goal to improve the admini-strative capabilities for public notification. Procedure EPIP-0SC-5,
" Site Area Emergency Actions", and Procedure EPIP-0SC-6, " General Emergency Actions", are being revised to specify the administrative controls to be followed by the. District for prompt public notifi-cation.
In addition, a new procedure, EPIP-E0F-17, " Initiation of Public Warning", is being written to specify the administrative duties of Omaha Public Power District personnel for public notifi-cation. An appendix to EPIP-EOF-17 will outline the duties of lo. cal governments, which is the final step in the public notifi-cation procedure.
In conjunction with this, the District is actively participating with local and state governments in the development of their public notification administrative procedures to ensure adequate administrative means and controls exist for prompt public notification within the' EPZ.
It is the District's intent to complete revisions to District procedures and to ensure state / local government procedures are developed and implemented by January 1,1982. This schedule is consistent with the planned date for the siren system to be operational.
3.
Date when full compliance will be achieved.
The Harrison County, Iowa E0C dedicated telephone line is scheduled for completion by November 20, 1981. The early warn'rq siren system is scheduled to be fully operational by January 1,1982.
Emergency Plan Implementing Procedures revisions and state and local government administrative procedures for public notification will be completed by January'I, 1982.
The District'will be in full compliance upon completion of these items.
r Violation 2.
10 CFR 50 Appendix E.IV.B., states that "The means to be used for determining the magnitude of and for continually assessing the impact of the release of radioactiva materials shall be described, including-emergency action levels that are to be used as criteria for determining the need for notification and participation of State and local agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outsi4 the site boundary to protect health and safety.
The en argency action levels shall be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring.
These emergency action levels shall be discussed and agreed on by the applicant and State and local governmental autnorities and approved by NRC.
They shall also be reviewed with the State and local governmental authorities on an annual basis."
Contrary to the above, on July 22, 1981, during the emergency exercise, it was determined by the NRC Inspectors that the licen-
- ,c's offsite radiological monitoring teams were unable to deter-mine the plume location for dose projections. The reasons were due to lack of training. equipment problems and intufficient supplies.
This is a Severity Level IV Violation (Supplement I.D.3.).
Response
1.
Corrective steps which have been taken and the results achieved.
Corrective steps have been taken which include training for the offsite monitor team, improving the survey Equipment perfonnance, and procuring additional personnel protective supplies.
Offsite monitor team personnel received training after the July 22, 1981 exercise to improve their knowledge and skills.
The offsite monitor team participated in a health physics / radiological drill on September 2,1981 and additional training sessions were conductad
-on September 9, 1981.
Emphasis was placed on locating and defining the size of the effluent plume, independent of State monitor' teams.
Two stable assay meter instruments (SAM II) have been procured and tes ted. These instruments were acquired and one was temporarily installed in a vehicle shortly before the July 22, 1981 exercise.
This resulted in monitor personnel having limited experience in the instrument's operation, which has been arrected through the training sessions. One SAM II field iodine monitor is now per-manently installed in a dedicated 4-wheel drive all weather vehicle and the second is scheduled to be installed'in a similar dedicated vehicle by November 20, 1981.
Protective clothing, respiratory equipment,-and potassium iodide tablets also are being added as standard supply items, stored in each dedicated vehicle. Major equipment problems have been eliminated by the permanent instrument installation and appropriate training.
The corrective actions identified have improved the ability of offsite monitors to perform assigned duties, including plume tracking for radiological assessment.
2.
Corrective steps which will be taken to avoid further violations.
A Chemistry / Radiation Protection Technician will be assigned to each offsite monitor team. The intent is that the C/RP Technician will serve as the team leader and provide expert radiological direction for specific monitoring duties and general health physics practices.
A booklet currently in preparation will provide better guidance for offsite monitor actions. The booklet will contain a stepwise operating procedure, maps detailing permanent radiological measure-ment stations in each sector, and a description of each station by geographical features. Communication between the dose assessment group at the Emergency Operations Facility and the offsite monitors performing field measurements will thus be more efficient and accurate. The time to identify the effluent plume locatior, and subsequent dose assessment provided to the general public will be reduced by this instruction. This booklet will be completed and distributed by January 11, 1982.
3.
Date when full compliance will be achieved, The training and equipment upgrading since the July 22, 1981 exercise provides assurance that offsite. monitors can identify the radioactive plume. Additional training for offsite monitors is in progress. The District will be in full compliance by November 30, 1981 when the second SAM II iodine monitor is installed in a dedicated vehicle and the additional training is completed.
i l
A
__-_._____________s_
_ _ _