ML20063D454

Forwards Response to NRC Re Four Items Identified as Significant Appraisal Deficiencies in Apps a & B of IE Emergency Preparedness Appraisal Rept 50-285/81-35

ML20063D454
Person / Time
Site:	Fort Calhoun
Issue date:	06/01/1982
From:	William Jones OMAHA PUBLIC POWER DISTRICT
To:	Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20063D444	List: ML20063D454
References
LIC-82-203, NUDOCS 8207020197
Download: ML20063D454 (40)

Text

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'Q Omaha Public Power District 8

8 TELEPHONE S36-4000 AREA CODE 402 1623 HARNEY OMAHA, NEBRASKA 68102 June 1, 1982 LIC-82-203 Mr. J. T. Collins, Administrator p;P c-U. S. Nuclear Regulatory Commission dj, Region IV

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611 Ryan Plaza Drive, Suite 1000

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Reference:

Docket No. 50-285

Subject:

Emergency Preparedness Appraisal The Coninission's letter to Omaha Public Power District dated May 4,1982 reported the results of the Emergency Preparedness Appraisal for the Fort Calhoun Station.

The appraisal included an assessment of our emergency preparedness program and the Fort Calhoun Station Radiological Emergency Response Plan (RERP).

The results of the program assessment were detailed in Appendix A (Significant Appraisal Deficiencies),

Appendix B (Preparedness Improvement Items), letter from J. T. Collins to W. C. Jones dated December 24,1981 (Significant Appraisal Findings),

and Inspection Report No. 81-35 (Emergency Preparedness Appraisal), all of which were attached to your May 4,1982 letter.

The results of the Emergency Plan assessment were detailed in Appendix C of your May 4, 1982 letter.

A descriptive response of the District's completed and planned actions to the four items identified as "Significant Appraisal Deficiencies" in Appendix A (Attachment 1) and the results of our con-sideration of the items of Appendices B and C are attached (Attachments 2 and 3, respectively).

Please note that Appendix A detailed four specific deficiencies which were differently presented tnan in the confirmatory letter dated December 24, The District has addressed both the confirmatory letter finding /

1981.

and the corresponding " deficiency" in Attachment 1.

However, we must express our concern that the initial findings were upgraded to defi-ciencies without consideration of the prompt actions taken by the Dis-trict on these four concerns.

Omaha Public Power District has always demonstrateu a responsible policy in matters involving safety.

Since the adoption of final rule changes on emergency planning,10 CFR 50 and 70, in November 1980, the District has effected many improvements.

A brief review of the District's responses on this issue illustrates the District's commitment to ef-fective emergency preparedness:

8207020197 820628 PDR ADOCK 05000285 G

PDR

s Mr. J. T. Collins r

LIC-82-203 Page Two 1.

January 1981 - Emergency Plan revised to 10 CFR'50' criteria.

2.

March 1981 - New procedures maneal implemented.

3.

July 1981 - Information brcchure to the general public published and disseminated.

4.

August 1981 - Physical construction of new Technical Supportf Center completed.

5.

September 1981 - All-weather vehicles with new field monitoring equipment acquired and operative.

6.

October 1981 - Emergency Plan revised to NUREG-0654 format.

7.

January 1982 - Public alert system including 95 sirens installed.

8.

April 1982 - Construction of new Emergency Operations Facility begun.

The District believes it has been responsive in implementing current emergency preparedness requirements and correcting identified defi-ciencies.

The District is correcting the reported deficiencies within an acceptable time period. The District is cognizant of the" enforcement options quoted in 10 CFR 50.54(s)(2), but firmly believes such actions are not appropriate when equated to our performance and state of emer-gency preparedness. Rather, the District anticipates an; acceptable emergency preparedness program designation based on the results of the appraisal report and the satisfactory correction of the four deficiencies of Appendix A.

Si,ncere; y, jf W. C. Jones Divisio4/ Manager Production Operations l

Attachment cc: LeBoeuf, Lamb, Leiby & MacRae 1233 New Hampshire Avenue, N.W.

Washington, D.C.

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ATTACHMENT 1 OPPD Response to IE Emergency Preparedness Appraisal Dated May 4, 1982 i

Appendix A Significant Preparedness Deficiencies Significant Preparedness Deficinecy #1 - Onsite Emergency Organization Aug.nenta-tion per Confirmatory Action letter of December 24, 1981.

The licensee shall conduct an evaluation of existing augmentation procedures to determine,' for each of the major emergency functional duties listed in Table B-1 of NUREG-0654 (Revision 1, November 1980), the extent to which the augmentation times confona to the staff guidelines of 30 and 60 minutes. The evaluation should provide for a realistic assessment of the times when each position would have been filled under emergency conditions.

(1) Steps which have been taken:

An evaluation of augmentation procedures to determine augmentation times for each of the major emergency functional duties listed in Table B-1 of NUREG-0654 (Rev. 1, November 1980) was conducted. The results were re-ported to the Nuclear Regulatory Commission on March 1, 1982, and indicate realistic assessment times as low as 45 and 60 minutes as compared to the taff guidelines of 30 and 60 minutes.

(2) Steps which wfl1 be taken:

The District will continue to encourage employee residence near the Fort Calhoun Station site and assign emergency duties to the greatest extent practical to those persons with shorter travel distances.

It is expected that this guide'will maintain or possibly reduce the present reasonable reporting times.

(3) Schedule for completion:

The augmentation time evaluation and report were completed on March 1, 1982 as stated.

It is noted that Appraisal Report 81-35 references Finding 285/81-35-13.

-- Revise the emergency plan and procedures to include the augmentation of emergency personnel as specified in NUREG-0654, Revision 1, Table B-1 and provide a method to verify that there is reasonable assurance that the augmentation times can be met for the specified minimum augmentation staff.

The District's March 1_,

1982 response together with the commitment for ten (10) person shift staffing by July 1, 1982 complete action on this deficiency.

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s Significant Preparedness Deficiency #2 - Personnel Accountability per Confir-matory Action letter of December 24, 1981 The licensee shall develop and implement proedures for the notification of appropriate authorities regarding the need for evacuation of offsite personnel who may be present in the owner controlled area daring a site evacuation.

(1) Steps which have been taken:

The Fort Calhoun Station Radiological Emergency Response Plan was revised and new instructions issued on January 25, 1982.

Correction to Section J describes the notification method which utilizes the early warning system.

Section B sets the review and reporting responsibility within the owner controlled area as an onsite monitor duty.

(2) Steps which will be taken:

The District will continue its emergency Preparedness training and exercise program to maintain proficiency of emergency response personnel, including onsite monitors.

(3) Schedule of completion:

This action is presently complete.

Revisions to the Radiological Emergency Response Plan and confirmatory report were completed on January 29, 1982.

It is noted that Appraisal Report 81-35 references Findings 285/81-35-55 and 285/81-35-57.

-- Develop anp implement procedures to ensure that all persons in the licensee controlled areas, including areas across the river from FCS, are notified of any need to evacuate those a:eas and that adequate provisions are available to ensure the evacuation and accountability of those persons (285/81-35-55).

-- Correct the EPIPs related to personnel accountability to provide for accountability of all persons in the owner controlled areas, including those persons across the river from FCS but still within the owner controlled area (285/81-35-57).

The District's January 29, 1982 response and action corrected Finding 81-35-55.

As stated in that response, a review of the Implementing Procedures indicate no change was required related to persons in the owner controlled area as re-ferenced in 81-35-57.

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Significant Preparedness Deficiency #3 - Emergency Action Levels / Procedure Flow per Confirmatory Action letter of December 24, 1982.

The licensee shall integrate the Emergency Action levels (EALs) into the Station Operating Procedures and assure that the procedures are written in such a manner as to enable the reactor operations personnel to effectively and expeditiously move from normal operations, to abnormal operations, through emergency operations and into the emergency plan implementing procedure.

(1) Steps which have been taken:

As stated in the Districts January 29, 1982 response, the Station Emergency Procedures were revised by March 15, 1982 and other ap'plicable operating procedures revised by May 1, 1982. The Emergency Action Levels have been incorporated into the Fort Calhoun Station emergency procedures where re-quired. The District also reviewed the Fort Calhoun Station normal operating procedures and verified that the existing operating procedures adequately lead the operator from the normal to emergency procedures. These improve-ments ensure the transition from normal to abnormal operations through emergency operations and into the EPIPs occur in a timely and effective manner.

(2) Steps which will be taken:

The District will continue periodic review and improvements of operating and emergency procedures to maintain adequate operator instruction during the transition from normal plant operations.

(3) Schedule for completion:

These actions are complete i

Applicable operating procedure revision was completed on April 30, 1982.

a It is noted that Appraisal Report 81-35 references Findings 285/81-35-41 and 285/81-35-45:

-- Correct the Emergency Procedure (EOPs) to provide specific guidance to the operator as to when Emergency Action Levels may be approached or exceeded and provide specific reference as to the exact EPIPs which should be initiated (285/81-35-41);

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-- Correct the appropriate E0Ps and AOPs, where necessary to identify when Emergency Action Levels may be approached or exceeded and insure that the station operators can effectively and expeditiously move from normal operations, to abnormal operations, through emergency operations and into the appropriate EPIPs (285/81-35-45).

The District actions completed by March 15, 1982 and May 1, 1982 have provided the necessary corrections.

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4 Significant Preparedness Deficiency #4 - Respiratory Protection per Confirmatory Action letter of December 24, 1981.

The licensee shall determine the expected number of onsite emergency personnel who may be required to perform essential duties under conditions of significant airborne radioactive contamination and who, therefore, require self-contained breathing apparatius in order to safely perform their assigned tasks. The licensee shall make provisions for acquisition of the necessary quantities of appropriate respiratory protection equipment and for locating the equipment in areas safely and quickly accessible to all onsite emergency response personnel. The licensee shall assure the h'RC that all emergency response personnel will maintain their capability to safely and efficiently don appropriate respiratory protective equipment.

(1) Steps which have been taken:

As stated in the Districts March 19, 1982 response and the April 1, 1982 addendum to significant Finding #4, eighteen (18) additional self-contained breathing apparatus (SCBA) units are in the process of procurement. This action is the result of an internal evaluation which identified the expected number of onsite emergency personnel requiring SCBA units in order to better perform their tasks.

The evaluation results set the number and location as forty (40) total units at seven (7) emergency response stations.

Each area is quickly and safely accessible to persons who require the respirators.

The District has also verified that the applicable personnel maintain a capability to don and use respiratory equipment in accordance with the Fort Calhoun Station Radiation Protection Program.

(2) Steps which will be taken:

Following receipt of the eighteen (18) additional SCBA units, the District will place these units into service within one month of delivery.

Personnel whose duties require use of respiratory equipment will be identified and shall maintain the District respiratory use qualification.

(3) Schedule for completion:

Based on requisition processing and manufacturers delivery time, it is expected that eighteen (18) additional SCBA will be received, tested and placed into service prior to September 15, 1982.

It is noted that Appraisal Report 81-35 references Fingings 285/81-35-19 and 285/81-35-40.

-- Provide adequate respiratory protection equipment, in the Technical Support Center, for all emergency workers assigned to that.rea during an emergency (285/81-35-19);

-- Provide adequate respiratory equipment for all emergency personnel that remain onsite during an emergency (285/81-35-40).

The District response to Significant Finding #4 and this response identified as Significant Deficiency #4 include consideration and action of the above j

improvement items.

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ATTACHMENT 2 Responses to NRC Emergency Preparedness

. Appraisal, Dated May 4, 1982, Appendix B items

Page B-2 OMAHA PUBLIC POWER DISTRICT CONSIDERATION IE EMERGENCY PREPAREDNESS APPRAISAL APPENDIX B PREPAREDNESS IMPROVEMENT ITEMS SCHEDULE FOR ID STEPS WHICH HAVE BEEN TAKEN STEPS WHICH WILL BE TAKEN COMPLETION Assign the site Supervisor - Chemistry & Radiation-Protection Assign appointment by Appointment representative has been selected to be site representative official memorandum letter 7/1/82 1

for the Emergency and record in Emergency Preparedness De-Plan Plan Revision velopment Program.

9/1/82 Develop and im-Emergency Preparedness. Training Manual (Section The District believes that COMPLETE plement a program

5).was reviewed and the program provides suf-the existing programs for professional ficient development to attain and maintain adequately address this development train-proficiency through the commitment " training concern.

ing for indivi-shall include development courses to main-duals who are tain state of the art knowledge".

assigned Emergency 2

Planning responsi-bilities which will enable them to attain and maintain a state-of-the-art knowledge in the field of emergency preparedness.,

Develop and im-Plant staff provides substantive input through The District believes that COMPLETE plement a method existing training, drills, exercises partici-the existing programs ade-to provide su-pation, critiques, maintenance orders, safety quately address this concern.

3 bstantive input meetings and suggestions programs.

of emergency pre-paredness plans and procedures.

Pega B-3 APPENDIX B (Continued)

SCHEDULE FOR ID STEPS WHICH HAVE BEEN TAKEN STEPS WHICH WILL BE TAKEN COMPLETION Develop and im-Position descriptions for the Manager - Rad The District believes that COMPLETE plement explicit Health and Emergency Planning'and his staff the existing programs ade-selection and contain sufficient information for selection quately address this concern.

qualificatina and qualification.

14 criteria for indi-viduals performing emergency prepared-ness development activities.

Develop and im-Quality assurance audits and Safety Audit and The District believes that COMPLETE plement quality Reveiw Committee audits are routinely performed the existing programs ade-assurance pro-to evaluate the emergency preparedness program quately address this concern.

cedures to evalu-and include a full review of conformance to ate the effec-training commitments.

tiveness of the emergency pre-paredness de-5 velopment train-ing including the professional de-velopment program developed for persons assigned emergency prepared-ness development activities.

Correct Emergency The Emergency Plan and EPIPs have been reviewed The Emergency Plan, EPIP 12/1/82 Plan, EPIPs and and presently show the proper date of issue and and EPT will be reviewed EPTs to be con-revision. A review of the EPTs indicates the and all identified de-sistent with the dating requirements have not been consistent ficiencies corrected by 6

dated require-or complete, addition of the proper ments of 10 CFR revision number and date.

Part 50, Appendix E, and the gui-dance contained in NUREG-0654.

Page B-4 APPENDIX B (Continued)

SCHEDULE FOR ID STEPS WHICH HAVE BEEN TAKEN STEPS WHICH WILL BE TAKEN COMPLETION Correct the EP The Manager - Fort Calhoun Station periodi-After review of this comment, COMPLETE and EPIPs to cally issues an assignment and designation the District believes desig-unambiguously notice for the onsite emergency organization.

nating onsite emergency specify, by This document specifies the duty position organization duty positions duty title and for the onsite emergency organization and the by normal duty position title 7

emergency duty persons by name assigned to this position restricts selection of a best title, all per-tion. Recovery Organization designates all qualified individual and will sons assigned persons assigned by normal duty title and emer-continue to make appointment to the licensee's gency title in RERP, Section M and EPIP-RR-10 by individual name.

Onsite Emergency thru 62.

Organization and Recovery Organiza-tion.

Provide docu-The latest issue of Onsite Emergency Organza-After review of this comment, COMPLETE mentation that tion assignments is Memo EP-82-60 dated March 26, the District believes the formal assign-1982. The Recovery Organization is assigned optimum method for formal ments of all per-in Section M of the Emergency Plan and EPIP-RR assignment of persons by i

6 sons assigned to series by title.

Identification of the Recovery name is by the periodic the Onsite Emer-Organization personnel by name was last done in update and distribution gency Organiza-Memo EP-82-49, dated 3/19/82 issued by the of memorandum issued by ation and Re-Division Manager / Production Operations.

the responsible manager.

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covery Organiza-tion have been made.

Remove incon-The duplication identified is in the process The District will complete EP & EPIP sistencies be-of correction. The District is unaware of this correction and future Revision tween the EP other inconsistencies.

identified duplications 9/1/82 and EPIPs in-through the normal pro-9 cluding correc-cedure change process.

tions to remove unintended dupli-cation of assigned responsibilities.

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Y Page B-5 APPENDIX B (Continued)

SCHEDULE FOR ID STEPS WHICH HAVE BEEN TAKEN STEPS WHICH WILL BE TAKEN COMPLETION Correct the EP On December 17, 1981 the OPPD Board of Resolution #3083 approved by RERP Revision and EPIPs by un-Directors approved Resolution #3083 which the Board and the disigna-9/1/82 ambiguously de-authorizes and directs the General Manager tion of authority issued fining the auth-to take actions required by the Radiological by the General Manager orities of all Emergency Response Plan. The General Manager shall be added to the 10 individuals subsequently designated the RERP as the Emergency Plan as an assigned to the official District Plan and authorized per-Appendix.

Onsite Emergency sons occupying positions in the Plan to Organziation and conduct activities necessary to fulfill their Recovery Organi-responsibilities described in the Plan.

zation.

Develop and Im-The District has reviewed this consideration The District believes the COMPLETE plement specific and believes a line of succession already es-line of succession for lines of succes-tablished for the EDO position is necessary.

the EDO position and the sion for all It ensures one individual is responsible for member-alternate staffing j

positions in the the complete corporate emergency response of other onsite emergency i

11 management decisions. The preparation for the position organization positions structure for can be accomplished by a strong, general provides the strongest the various knowledge of the RERP. However, for the emergency staffing.

functional re-positions in the Onsite Emergency Organization, sponse areas of an experienced individual with technical the Onsite Emer-preparation for the specialized duties is gency Organi-required. This is best accommodated by zation technical training of a primary and alter-nate member which is considered more appro-priate than a line of procession arrangetient.

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Page B-6 APPENDIX B (Continued)

SCHEDULE FOR ID STEPS WHICH HAVE BEEN TAKEN STEPS WHICH WILL BE TAKEN COMPLETION Develop and im-The Emergency Preparedness Training Manual The District believes an COMPLETE plement selec-establishes the selection a.nd qualification adequate selection and tion and quali-requirements for personnel assigned duties qualification criteria fication cri-within the RERP. Completion of the training currently exists.

teria for in-ensures the requirement has been satisfied.

dividuals Personnel selection includes adherence to The District believes after assigned to appropriate standards and experience require-its review that the Train-perform emer-ments.followed by rigid, specific training ing Manual controls provide i

12 gency actions with practical demonstration of duties prior adequate selection and and decision to final qualification acceptance.

qualification criteria.

I making as mem-l bers of the On-site Emergency i

Organziation and Recovery Organiza-tion.

Provide in the The letters of agreement contained in Appendix Appendix A shall be re-Revise Emergency Plan A have been reviewed and generally contain reviewed in accordance letters copies of up-to-sufficient specificity and are up to date.

with the annual schedule 6/1/83 date letters of Authority and responsibility are also en-commitment with the goal agreement or con-compassed by governmental and corporation to improve specificity, tracts which de-policies. However, limits of action are with emphasis on limit of monstrate that usually not defined.

actions for support groups.

arrangements have Where required new letters been made with off-will be obtained based on 13 site organizations this review.

(both commercial and private) to supply specifically defined support or cooperation during an emergency in-cluding their auth-orities, responsi-bilities, and limits of actions.

Page B-7 APPENDIX B (Continued)

SCHEDULE FOR i

ID STEPS WHICH HAVE BEEN TAKEN STEPS WHICH WILL BE TAKEN COMPLETION Complete the im-Thirteen procedure changes and four new pro-Complete implementation of' EPIP revisions lh plementation of cedures have completed formal review and ap-all existing EPIPs will be 7/1/82 all_ existing proval. They are presently being printed completed within 30 days.

EPIPs prior to issue and distribution. Two of the five procedures cited were implemented during the early part of 1982.

Develop and im-Radiological training for restricted (blue)

A review of personnel re-Revise RERP plement a pro-classification and unrestricted (red) classi-required to remain at Fort and/or Train-gram to train fication includes instruction in proper use Calhoun Station will be con-ing Manual all emergency of protective clothing and respiratory pro-ducted. Controls will be 9/1/82.

response person-tection. Respirator fit test and class cloth-initiated to ensure all nel in the pro-ing wear ensure practical application of this persons identified main-per use of all knowledge is demonstrated.

tain either the restricted equipment which or unrestricted radio-2 would actually be logical classification required to safely and receive SCBA instruc-15 perform their

tion, assigned tasks under emergency conditions, in-cluding walk-through training while wearing full respiratory protection and protective clothing.

Develop and im-EPIP-0SC-2 and EPIP-RR-1 have procedure changes EPIP-OSC-2 and EPIP-RR-1 EPIP Revision plement, for the (re: item 14 above) in progress which provide will be revised, issued 7/1/82 Control Room, a controlled telephone lists and quarterly veri-and implemented within controlled tele-fication.

30 days including a con-16

. phone list of per-trolled telephone list sonnel and agencies for the Control Room.

to be contacted during emergencies, including provisions to maintain and w

w yy

Page B-8 APPENDIX B (Continued)

SCHEDULE FOR ID STEPS WHICH HAVE BEEN TAKEN STEPS WHICH WILL BE TAKEN COMPLETION 16 (Continued) verify the phone numbers at least quarterly.

Provide radio-In response to NUREG-0737 items II.B.2, No further action required COMPLETE logical monitor-III.D.3.3 and III.D.3.4 modifications were ing equipment, implemented at tl.e Fort Calhoun Station to:

with both visual (1) provide means to measure airborne activity 17 and audible in all areas required to be accessible follow-alarms to detect ing a DBA and (2) to ensure adequate shielding radiation and is provided to allow entry to all areas which airborne radio-must be accessible. Accordingly the means have active contami-been established to protect people located in nation in the the Control Roca from direct or airborne radia-Control Room.

tion.

Provide per-See answer (above)

No-further action required COMPLETE manently in-stalled radia-tion monitoring equipment, with both visual and 18 audible alarms to indicate both radioactive air-borne contamina-tion and direct radiation in the TSC.

Page B-9 APPENDIX B (Continued)

SCHEDULE FOR ID STEPS WHICH HAVE BEEN TAKEN STEPS WHICH WILL BE TAKEN COMPLETION Provide adequate The main Conference Room is an interim TSC Outfitting of the new TSC 9/1/82 communications with adequate communication in the adjacent will continue with special in the main con-main office area. The District has erected a attention to communication, ference room of new TSC building. The physical construction monitoring and assessment 19 the TSC for com-is completed. -The final stages of equipping equipment until the TSC is municating with the Center is now in progress.

satisfactorily equipped. At the Control Room that time the transition for and the Emergency use of the new b1dg for emer-Operations Facility.

gency response will be completed.

Develop or The location of the alternate EOF and direc-The District is constructing Revised Plan revise existing tions to the facility are adequately described a new EOF approximately 17 and Procedures procedures to in the RERP, These instructions have also miles from Fort Calhoun 60 days after reflect the been included on a video training tape recently Station. Completion of completion of 20 location of the prepared.

structure will allow the EOF., Present Alternate EOF and emergency response to be schedule is directions from directed always from one 1/1/83.

the station to the facility and an alternate facility.

facility a greater distance from the site will no longer be necessary. The Plan and procedures will be corrected at that time to accurately describe the new facility.

Develop and im-The District has developed and implementhd The District believes its COMPLETE plement methods procedures ST-RM-3 and EPT-2 as monthly present surveillance and procedures surveillance inspections to assure that the method is more comprehensive (e.g., seals, dedicated emergency equipment and supplies than the suggested seal minimum stock are available as planned. The test consists method.

In addition it 21 levels etc.) to of inventory and function test of instruments provides instrument and assure that for operability.

battery operability veri-dedicated emer-fication. The District gency equipment intends to continue the and supplies are present surveillance tests.

indeed available when needed for emergency response.

page B-10~

APPENDIX B (Continued)

SCHEDULE FOR ID STEPS WilICllIIAVE BEEN TAKEN STEPS Wi!ICil WILL BE TAKEN COMPLETION Develop and im-As stated for Item B-21 the District review The District appreciates COMPLETE plement proced-indicates the full monthly inventory now being the proposal of alternate ures for rein-done is more effective than the suggested seal methods, but opts to con-ventory of device.

tinue its preferred method.

22 equipment or supplies when tamper indicating devices are re-moved or broken.

Upgrade existing The Ditrict has established a personnel decon-Sodium citrate and large 9/1/82 personnel decon-tamination monitor team and a decontamination containers required by the tamination faci-station at the EOF. A specific procedure and procedure when iodine on 4

lities to prc-decon supplies are available to perform decon the skin must be removed, 23 vide ready ac-properly.

Ample soaps, brushes, and towels have been available at the cess to all ne-are stored in the cabinet within the decon adjacent storeroom. These cessary decon-station.

supplies will be permanently tamination agents transferred to the emergency at the decontami-decon station for optimum nation room, access.

Provide addi-01-PAP-1 is being revised to resolve this Revision of OI-PAP-1 7/1/82 tional fixed and concern.

portable radio-logical shield-ing where practical, 2h to aid in the re-duction of exposure to sample and anal-ysis personnel (in-cluding sample transport devices)

P Page B-11 APPENDIX B (Continued)

SCHEDULE FOR ID STEPS WHICH HAVE BEEN TAKEN STEPS WHICH WILL BE TAKEN COMPLETION Evaluate capa-See next column The counting system at Evaluation bilities for meet-North Omaha Station will Complete ing the 3-hour be evaluated and if neces-9/1/82 sample and analy-sary upgraded.

25 sis time frame if the radio-chem lab becomes uninhabit-able due to elevated radiation levels.

Evaluate high-Analytical procedures will be revised or Counting limitations will be 9/1/82 level sample count-developed to resolve this concern.

evaluated.

Sample size count-26 ing limitations of ing time, and geometrics will both GeLi systems be modified if shown necessary.

under present count-ing geometries, i

Develop and im-Administrative Procedure S.O. T-13 establishes The District believes that COMPLETE I

plement procedures calibration and functional check frequencies.

SO T-13 and CP-LAB-10 for maintaining All District gamma spectrometers including the provide adequate control routine efficiency Model 901 multichannel analyzer, are calibrated to maintain efficiency and and calibration bi-annually and function checked either weekly, calibration of the MCA at 27 checks of the NaI or prior to use.

Procedure CP-LAB-10 controls the alternate EOF.

backup counting the calibration method.

I system at the

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North Omaha Station.

t Install in the The District has reviewed this consideration An Engineering Evaluation EEAR Submittal station decontami-and concerns that a communication station in Assistance Request (EEAR) 7/1/82 nation area ade-the decontamination area would provide improved will be initiated through Expected i

28 quate communica-health physic assistance.

the Plant Staff as the Installation tions for contact-normal procedure to in-12/31/82 ing Health Physics stall a Gaitronic set personnel.

at the Station Decon Area.

Page B-12 APPENDIX B (Continued)

SCllEDULE FOR ID STEPS WlIICilllAVE BEEN TAKEN STEPS WilICll WILL BE TAKEN COMPLETION Provide in both Both decontamination facilities are equipped Access to sodium citrate COMPLETE decontamination with basic supplies. The quantities were in-and a large storage con-29 facilities adequate stalled, evalut.,ted and operating experience tainer for the EOF decon and necessary sup-has proven them to be adequate, especially station is being taken as plies for personnel within the plant.

In addition; great quantities action to item noted on decontamination.

are stored in areas in close proximity to decon page B-10.

facilities.

Provide permanent The decon area within the plant has personal The District believes its COMPLETE instructions in decon instructions identical to those in the decon procedures at each both decontamina-Radiation Protection Manual posted.

Standard facility are commensu-tion facilities to operating practice is for each individual to rated with its mode of contact llealth start self decontamination prior to arrival of operation and present Physics upon deter-IIP personnel. The EOF decon facility is policies are adequate 30 mining that the continuously manned during emergencies by a and appropriate.

individual (s) are decon monitor. The decon minitor is guided contaminated and by an EPIP. The District program places provide a communi-decon duties with the monitor and not the cation system to contaminated person. Therefore the District accomplish the believes it inappropriate for decon procedures notification.

to be posted. The EPIPs are available at the Emergency Operation Facility.

The adequacy As noted, the District has a new TSC under construc-The District interprets COMPLETE of the Ex-tion and has planned construction of an offsite EOF.

that no additional con-panded Support sideration or response Facilities will is required to this item.

remain an Open Item f r future 31 resolution until final plans are prepared and con-struction autho-rized by OPPD for those facilities.

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d Page B-13 APPENDIX B (Continued)

SCHEDULE FOR ID STEPS WHICH HAVE BEEN TAKEN STEPS WHICH WILL BE TAKEN COMPLETION Perform an The Omaha / Douglas County Civil Defense Emergency The District will re-evalu-9/1/82 evaluation to Operating Center was selected as the Media Re-ate whether the Omaha / Douglas determine what lease Center because the facility is specifi-County Civil Defense Emergency additional elec-cally designed and constructed for this type of Center should have additional trical service service.

It has been used successfully during electrical service for news would be needed disasters such as the Omaha Tornado of 1975.

needs.

32 by news media representatives during an emer-gency and pro-vide such a capability in the MRC.

i Replace the The District has reviewed this improvement item ST-RM-3 will be revised to 8/1/82 i

small hand-held and believes it's adaption is commensurate with replace the hand-held high' high range in-District ALARA policies.

range instrument in the strument in the Control. Room with an ex-Control Room tended probe high range 33 Locker with an instrument.

extendable probe high range in-strument.

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Develop and im-The calibration of metorological equipment and The District believes the COMPLETE plement proce-instruments has been performed for many years operating experience of dures to calibrate in accordance with procedures CP-6272 through six years with the present 3h all meteorological 6285. The calibration tests and frequency, meteorological instruments instruments and initially once per year and later increased and procedures demonstrate l

equipment on a to biannually, have provided a very good reliable service with 6 quarterly basis.

availability and performance of the equipment.

month calibration frequencies.

i This record provides sufficient l

basis to continue the present l

calibration.

I 4

e

-_n

,,e

-3

Page B-14 APPENDIX B (Continued)

SCHEDULE FOR ID STEPS WHICII liAVE BEEN TAKEN STEPS WilICll WILL BE TAKEN COMPLETION Develop the capa-See next column These provisions will be pro-June 1983,

bility for remote vided following the full interrogation of implementation of the emer-the meteorological gency response facilities.

35 system by off-site agencies in accord-ance with Regula-tory Guide.

Provide a detailed The detailed descriptien of the-dose assesment The District believes ex-COMPLETE description of methodology is described in Section I.3 of the isting models are ade-the dose assess-Plan and in the appropriate emergency plan in-quate as described.

ment methodology plementing procedures (EPIPs). All of the and how meteoro-applicable EPIPs require the use of on-line 36 logical informa-(real time) meteorological data as a primary tion is used in source. The meteorological models for the on-that model.

line computer have been reviewed by the NRC in the past; i.e., 1974, 1975 and 1976.

If the real time meteorological data are not available then the dispersion factors are obtained from the overlays. The meteorological model for the development of overlays is based on the following standard caussian diffusion model:

2 2

Xu/Q = (

1

) exp (-y /2 0Y)

( 2n a o x(Exh{-)*-h)2 2

+exp{-({+h)2/20f)}

/20 2

Where:

3 X is the radionuclide downwind concentrate, Ci/m

- is the average wind speed. m/sec, distheradionclidereleaserate,Ci/sec.

cy is the horizontal dispersion coefficient of the plume per Pasquill class, m.

1 y is the vertical dispersion coefficient of the plume per Pasquill class, m.

y is the crosswind distance from the plume centerline, m z is the vertical distance from the plume centerline, m h is the release altitude, m

Page B-15 APPENDIX B (Continued)

SCHEDULE FOR ID STEPS WHICH HAVE BEEN TAKEN STEPS WHICH WILL BE TAXEN COMPLETION (Continued)

Z is assigned a value of zero, corresponding to a ground level dose point for the preceptor and for a ground level release

'h' is equal to zero.

Therefore, the above equation can be simplified as:

~2 as: Xu/Q = (

1

) exp ( y /2 02)

(

oo

)

yz Perform an analysis The terrain in the vicinity of Fort Calhoun This information will be 12/31/82 to determine how a Station is generally flat from the north, incorporated into the release plume from northeast, east and southwest sectors, with next major revision of FCS may be modified an elevation of approximately 1000 feet above the Rad Emergency Response by terrain induced mean sea level (MSL), for a radius of at least Plan.

37 effects and pro-10 miles. This terrain is generally the flood vide the results of plain of the Missouri River. The terrain in the study in the the remaining sectors, south-southeast through emergency plan.

west-northwest show much greater relief from the low lying, cut by numerous ravines. These bluffs extend along the western bank of the Missouri River, which runs generally from the northwest to the southeast and comes within about one mile of the Fort Calhoun Station in the south through west-southwest sectors.

Two possible weak effects in the site meteoro-logy are: 1) under very light westerly vind flow there is a possibility of weak drainage flow off the bluffs to the west toward the river, and 2) there will possibly be a slowing down of weak winds as air flows across the river from the east to west and meets the slowly rising terrain to the west. Neither of these effects are regarded as significant in their influence in the site metco-rology.

Page B-16 APPENDIX B (Continued)

SCEEDULE FOR ID STEPS WHICH HAVE BEEN TAKEN STEPS WHICH WILL BE TAKEN COMPLETION Correct the EPIPs The District identifies in its Emergency Pre-The District believes the COMPLETE to identify the paredness Training Program the specific im-identification of emergency individuals by plementing procedures which each member per-personnel by title with title who have forms. The training manual as well as the' authority responsibilities the authority, re-lesson plan for each member includes the and qualifications is pro-38 SPonsibilities, title with responsibilities and qualifications perly proviued in both the and qualifications to function in the emergency position.

RERP and Training Manual.

necessary to per-EPIP would be repititious form the tasks and not enhance the present governed by the p rogram.

procedures.

Correct the EPIPs The District has designed its implementing The District believes its COMPLETE to allow on a procedures to accomplish the required task method of training emergency single individual in an efficient and expeditious manner. Each personnel to perform the to perform the person who has received training and been complete procedure rather procedure or assigned to perform that task is equally quali-than only a part provides 39 Separate all steps fied to perform it_in its entirety. The Dis-for a stronger and more to be performed tricts method provides cross training of per-knowledgable emergency by an individual sonnel and builds a larger manpower resource response organization.

from the steps to to cope with unforeseen emergency circumstances The District will con-be performed by within the planning criteria.

tinue to review and up-other individuals.

grade procedures as a method to maintain effective performance.

Correct tl'e EPIPs Although the EPIP do not contain specific check The District believes a COMPLETE to provide check-lists, they have been prepared in a performance firm sign off policy with lists or other sequence with a more important action placed a set sequence completed LO methods to ensure prior to a lesser important action. However, before the next action can that all necessary in many instances more than one action may be be performed is not desir-procedural steps in progress similtaneously. The present form able. The District be-are completed at of the EPIPs allow these corrective actions to lieves its procedural the proper time.

be occuting within specific time intervals.

method patterned after This procedural method together with the cor-Chemistry and Health responding training provides a more timely Physics procedures is emergency response.

more workable and preferred.

Page B-17 APPENDIX B (Continued)

SCHEDULE FOR ID STEPS WHICH HAVE BEEN TAKEN STEPS WHICH WILL BE TAKEN COMPLETION Correct the EPIPs The RERP and the lesson plan for the EDO speci-The District agrees that the 4/1/83 to specifically fically identify those duties and responsibili-delineation of EDO duties identify those ties which may not be delegated by the EDO.

and responsibilities which kl duties and re-These programs.have provided the requirement cannot be delegated can sponsibilities and training to ensure these duties clearly be more effectively con-which may not be remain with the EDO.

trolled in an EPIP. This delegated by the change will be accomplished.

EDO.

The District will also evaluate the removal of this duty list from the RERP or lesson plan in order to avoid repetition.

Develop and im-Procedures have been developed and implemented The District believes its COMPLETE plement procedures to document emergency _ radiological survey re-new procedure and pro-to provide adequate sults. EPIP-OSC-10, EPIP-EOF-4, EPIP-EOF-5, cedure change efforts 42 forms for the docu-EPIP-EOF-6, EPIP-EOF-15, EPIP-EOF-16, EPIP-EOF-18 provide adequate forms mentation of emer-and EPIP-RR-6 contain tables to document either for recording survey gency radiological survey or dose assessment results.

results now.

The District survey results.

does not believe more changes are warranted unless identified through training and exercises.

l Provide a con-As noted by the Appraisal, only two controlled Standing Order G-30 COMPLETE trolled copy of or official copies of all documents are " main-provides the administra-h3 the OI-PAPS for tained at the station. However, additional tive procedure and control use in the RAD-numbered copies are maintained up-to-date for updating the Operating CHEM Office.

with all revisions and issue changes.

Up to Instructions.

date copies have been placed and will be maintained in the Chemistry office and the Health Physics office.

I f

g

Pegn B-18 APPENDIX B (Continued)

SCHEDULE FOR ID STEPS WHICH IIAVE BEEN TAKEN STEPS WHICH WILL BE TAKEN COMPLETION Incorporate speci-The District has issued a formal management The District will continue COMPLETE fic ALARA measures policy and adininistrative procedure effec-to formalize its ALARA 44 and considerations tive June 1, 1982 to confirm its commitment program by specific pro-into the OI-PAPS to ALARA practices. However, the District cedures within the FCS and CMPs.

has previously applied ALARA principles in a Radiation Protection less formal manner. ALARA measures and con-Manual and departmental siderations in this form were included during instructions.

the preparation of operating and emergency procedures such as the OI-PAPS and CMPs referenced.

Correct the Secton 2 of the Chemistry Procedures Manual A review and evaluation 2/28/83 OI-PAPS and CMPs (CMP-2) provides general philosophy for will be conducted within to include pro-sampling _ techniques including labeling and the normal bi-annual review 45 visions for label-storage of samples.

Individual chemistry schedule to ensure suffi-ing storage, and procedures also contain provisions and cient provision for label-disposition of precautions auring the handling of radioactive ing, storage, and disposition

sample, samples, of sample as provided in OI-PAP and CMP procedures.

4 i

a Provide the shield-See Item ID B-24 OI-PAP-1 will be revised.

7/1/82 ed sample transport 46 cart for use as I

stated in OI-PAP-1.

Take measures to See response to item ID B-25 above.

See Item page B-11 above EVALUATION assure habitability COMPLETE of an adequate 9/1/82 47 sample analysis facility under severe accident situations.

v w

s v -

w w

,v-

-a

Page B-19 APPENDIX B (Continued)

SCliEDULE

~

FOR ID STEPS WilICH IIAVE BEEN TAKEN STEPS WilICil WILL BE TAKEN COMPLETION Evaluate present See response to item ID B-26 above.

See item ED B-26 above.

EVALUATION counting systems for COMPLETE 48 high-level sample 9/1/82 counting abilites and limitations.

Develop and im-The General Employee Training program provides The District believes that COMPLETE plement methods to the description of.the on-site assembly area adequate methods for desig-adequately mark and instruction for the normal route to the nating emergency assembly 49 assembly areas and area.

EPIP-OSC-2 directs the Shift Supervisor areas and exit routes exist the routes to be to make a general announcement along with the within the GET and EPIP i

j taken to get to sounding of the plant nuclear alarm. The im-p rograms,

the assembly areas. plementing procedure also provides for special instruction if the normal plant exit route must be altered.

11 Correct the EPIPs EPIP-EOF-9 Personnel Accountability was re-EPIP-E0F-9 will be reviewed 9/1/82 to reflect the viewed and Rev. 1 issue 4/23/82.

Improved again and a single person single individual accountability methods were incorporated designated for maintaining that will recieve into this procedure.

immediate and continuous and account for accountability thereafter.

50 personnel imme-diately following l

the incident and maintain continuous accountability thereafter.

i 4

Develop and im-In response to the recent INPO evaluation, the The Radiation Protection 11/1/82 plement specific District committed to establishing a program Manual will be revised personnel monitor-for improving the reporting, investigation and to include the subject 51 ing and decontami-tracking of personnel contamination incidents.

program. The EPIPs nation procedures will be revised to re-in the EPIPs which ference the appropriate will provide for procedures in the RPM.

l

. _ - ~.. -.

Pag B-20 APPENDIX B (Continued)

SCHEDULE FOR ID STEPS WHICH HAVE BEEN TAKEN STEPS WHICH WILL BE'TAKEN COMPLETION 51-(Continued) thorough investi-gation of any con-tamination incident and documentation of the results of any decontamination procedure and sub-sequent bioassay.

Develop and im-As noted, cecurity actions during emergency con-The District will review 12/1/82 plement specific ditions are described in EPIP-OSC-7 and SCP-19.

existing procedures and

]

procedures govern-An additional procedure EPIP-EOF-12 Site Se-issue revisions as neces-ing the duties, curity was.not referenced but has been imple-sary to-implement specific j

52 authorities, and mented as the main instruction during radio-duties of Security per-responsibilities logical emergencies.

sonnel, especially upon of Security Per-declarations of a General

~

sonnel during an Emergency.

emergency.

1 Develop and im-As noted by the appraisal, specific procedures The District believes the COMPLETE plement procedures EPIP-OSC-1 and EPIP-RR-1 are in effect to present accident procedures

}

with specific cri-categorize emergencies into one of.four classi-with provision to reduce teria upon which fications based on the guidelines of Appendix I the accident classification the emergency of NUREG-0654. The licensee is. responsible to designation are appropriate class may be establish the classifications and consistently and intends to maintain a

53 downgraded and provide this information to local, state and this method.

a provisions for Federal response groups. The responsibility of notification of the licensee to set the accident classification Federal, State does not appear to be limited to increasing and local offi-accident severity only.

cials prior to entering a down-

. graded mode of emergency response operation.

. _ _ _ _ _ _ - - _ _. _ _ _ _. ~.

I Page B-21 APPENDIX B (Continued)

SCHEDULE 4

FOR ID STEPS WHICH HAVE BEEN TAKEN STEPS WHICH WILL BE TAKEN COMPLETION Include the NRC Figure B-4 depicts the principal interfaces In accordance with the 12/15/82 and FEMA on the

.among onsite organization and offsite response appraisal report request, list of interfacing centers. As such, the NRC is shown with prin-Figure B-4 will be cor-organizations in cipal interface to the licensee TSC and EOF rected to show the NRC j

34 the MRC Section B, for which space has been allocated, and FEMA interface in Figure B-4, of the the NRC.

j Emergency Response Plan.

I i

i Develop and im-During-the nine. years of reactor operation Fort The District believes it

' COMPLETE plement fo rmal Calhoun Station has developed and implemented has sufficient procedures l

procedures for adequate procedures for controlling calibration, and controls for optimum i

radiation moni-function test, inventory, repair, etc for radia-utilization of radiation toring equipment tion monitoring equipment as evidenced by proce-monitoring equipment for 55 invent ry, includ-dures S.O. T-13, CP-HP-1 thru 19 and FCP-HP 1 reactor plant operations.

ing acquiring new thru 3.

instruments retir-ing old or lost j

instruments, and

~'

i instrument cali-j, bration due dates, f

l Review and evalu-'

To the greatest extent practical,. implementing As a viable program encom-COMPLETE j

ata the usability procedures are developed.by persons experienced passing training, reviews, i

of existing pro-in the specific instrumentation. The author drills and critiques, the cedures and in-then tests the procedure. The procedure'*is also emergency program reviews 56 struments, used tested during training.and drill sessions.

continuously. human engineering during emergencies, Human factors inputs are included in resulting factors or comments are which-for human factors revisions. Human factors engineering is in-evaluated and adopted into engineering cor-corporated into instruments based on initial the program. The District l

rection.

selection by experienced technicians and super-

. believes human factor visors knowledgable in many areas. The pro-engineering is inherently 4

curement of instruments from leading manufac-included in the existing-turers receptive.to customer preference.is RERP and EPIP.

another means of acquiring human factor engineering for the District program.

l

. ~ - -

Pags B-22~

APPENDIX B (Continued)

SCHEDULE FOR ID STEPS WHICH HAVE BEEN TAKEN STEPS WHICH WILL BE TAKEN COMPLETION Review all letters As evidenced by Appendix A'of the RERP, letters As stated in the response to RERP review of agreement with of agreement exist and are reviewed annually.

item page B-6 above, the 12/1/82 offsite support The District has entered into these agreements District shall continue the i

organizations to in good faith and firmly believes each group annual review of letters of ensure that all

-will honor its commitments. However, no agreement to ensure they are still accept-absolute certainties are possible. Each are still acceptable, able and will be organization is known to have operated re-honored, and en-putably in the past and has demonstrated 57 sure that ade-moral obligation to the public.

quately detailed i

letters of agree-ment exist for all organizations the licensee will de-pend on for aid during an emer-gency.

Ensure that the

1) Emergency action levels (EAL) were discussed The District believes ade-COMPLETE EALs and their with and agreed on by the licensee, state quate methods exist to associated re-and local governmental authorities as evi-maintain consistent and sponse actions denced by the publication of consistent correct EAL with state 4

are discussed EAL tables in the OPPD, Nebraska, Iowa, and local governmental with and agreed Washington County and Pottawattamie County authorities.

on by the licensee, Emergency Plans.

State, and local

2) Emergency Preparedness Tests (EPT) have been i

j governmental developed and implemented to administer sur-l authorities and veillance commitments. EPT-9 provides a con-58 develop and im-trolled method for the review and cortectica plement a method of the RERP including the EAL on an annual to review the frequency. EPT-12 provides a controlled continued accept-method for District and offsite governmental i

ability of the officials to review emergency preparedness EALs and their programs and discuss improvements.

associated re-l sponse action j

with the State and local govern-mental authorities on an annual basis.

ATTACHMENT 3 Responses to NRC Emergency Preparedness Appraisal, dated May 4, 1982, Appendix C items

Page C-2 OMAHA PUBLIC POWER DISTRICT CONSIDERATION IE EMERGENCY PREPAREDNESS APPRAISAL APPENDIX C EMERGENCY PLAN EVALUATION REPORT 4

SCHEDULE YOR ID STEPS WHICH ILWE BEEN TAKEN STEPS WHICH WILL BE TAKEN COMPLETION The levels of on-The District has committed to meeting Table B-1 The District will ocet Table 7/1/8.?

shift staffing on shift staffing requirements by July 1, 1982.

B-1 on shift staffing re-shown in Table B-1 The Districts augmentation capabilities have quirements. The District of the plan do not been identified in our letter dated March 1, presently provides for meet the require-1982.

timely augmentation as j

ments of Table B-1 detailed in our letter of of NUREG-0654. a)

March 1, 1982.

there should be one Shift Foreman (SRO) on shift rather than the Reactor Operator (RO); the Not i fi ca t ion,'com-munication position should not be pro-vided by a shift person assigned to other functions; c) for the in plant surveys, there should be ene HP technician avd ane Rad / Chemical Technician.

Ia addi-tion: a) no times of arrival are given for the staf f aug-mentations; b) no electrical maint-

~ enance personnel additions are pro-Vided where two are required; and c)

. -the total number of

~

staff additions is

~

listed as-26, while

. 't

~

t s

s

~x 3

Page C-3 APFENDIX.C (Cortinued)

ScilEDULE FOR s

ID STEPS WiTICl! IIAVE BEEN TAKEN STEPS WilICH VILL BE TAKEN COMPLETION (Continued) the correct total in Table B-1 is 24.

The plan provides no statement of the 1icensee's inten-tion to meet the required staffing by July 1, 1982.

Also the EDO duties Section 2.2.1 and Section 2.2.3 specify the EDO The District believes the COMPLETE do not specify who as the person responsible for the overall emer-Radiological Emergency 1

is responsible to gency effort which must include notification of Response Plan supported notify the off-site offsite authorities.

Implementating procedures by the appropriate im-a t ti,e cities and EPIP-OSC-2, 5, and 6 provide the method for plementing procedure Set..ans 2.6.2, notification of local and state authorities by provide sufficient 2.6.3, and 2.6.4 the " Shift Supervisor and/or ED0" "or his authority and dirce-do not specifically designee."

tion to perform offsite indicate that the notification.

local county author-ities will be noti-fied along with the State authorities.

The licensee has The Eats as defined in Section D. I.0 of the plan The District will evaluate 12/31/82 appartenly inter-are based specifically on Appendix 1, NITREG-0654, Section D to determine preted the term Rev.

1.

The example initiating conditions are which improvements, i f any, "EAL" to mean defined f or each EAL similar to ones provided in can be implemented.

" initiating condi-Appendix 1, NUREG-0654.

It should be noted that tion" inasmuch as the Dictrict has used the same format in the he has used in-Plan as provided in NUREG-0654, Appendix 1.

The itiating conditions District believes it is in compliance with this as EALs and has not document.

developed EALs cbmpatible with

Pcge C-4 '

APPENDIX C (Continued)

SCIIEDULE

~

FOR ID STEPS kilICH HAVE BEEN TAKEN STEPS L111CH k'ILL BE TAKEN COMPLETION (Continued) those in NUREG-0818. The li-censee should review applicable portions of the plan and develop EALs for the example initiat-ing conditions in Appendix 1, NUREG-0654 in accordance with criteria in NUREG-0818.

The following in-

1) Initiating conditions 12 of unusual event; The District will continue COMPLETE titiating condi-16 of alert; 14 of site area and 3 of general an annual review program tions, incorrectly emergency are related to plant security and incorporate proper im-called EALs in the and are, therefore, detailed in the Fort provements as they are plan, were not Calhoun Station Security Plan.

identified.

addressed:

2) Initiating conditions 17 of notification of Unusual Event: 12 unusual event; 19 of alert; 9 and 17 of site and 17.

area and 7 of general emergency are not ap-Alert: 16 and 19.

plicable as EAL's for Fort Calhoun Station Site Area: 9, 14, operation.

and 17.

Also, Section 6.0 Section E.1.1 Initial Notification commits The District will revise Section 8/1/82 j

indicates that notification to the NRC and offsite govern-D.6.0 and re-write or eliminate "Only those events mental agencies for all emergency classes.

this statement in order to de-which have the EPIP-OSC-2 supports and directs this method. monstrate the intent of 10CFR50.

clear potential The intent of the ttatement quoted in Section for escalating to 6.0 was to illustrate that a Notification of a Site Area Emer-Unusual Event may have been experienced and gency warrant corrected prior to the offsite notification.

l

Pag? C-5 APPENDIX C (Continued)

SCHEDULE FOR ID STEPS WHICH HAVE BEEN TAKEN STEPS WHICH WILL BE TAKEN COMPLETION (Continued) prompt notifica-tion of offsite authorities." This does not meet eith-er the letter or the intent of the NRC regulations.

Even though the Construction and ventilation equipment provides The District will continue COMPLETE OSC appears to the same habitability to the control room and the use of the Shif t Supervisor be part of the shift supervisor area utilized for the Operations area as the OSC based on control room com-Support Center.

its acceptable habitability plex (Figure Hl) and proximity to the control the plan should room.

indicate if the OSC has the same

+

habitability as the control room.

The plan does Section H.2.3 describes emergency equipment and The District believes wound, COMPLETE not specifically supplies and references Table H-1 for the de-portable monitors or sampl-identify wound, tailed list according to emergency response ling equipment are identi-portable monitors, facility location.

Portable monitors and sar.ip-fied in Table H-1 adequately or sampling equip-ling are readily identifiable. The RM-l% and for persons familiar with ment.

RM-15 with hand probe are designed zor per-basic radiation protection.

sonnel frisking and are used per procedure The District will verify EPIP-EOF-3 for skin and wound surveys.

this understanding during training and drill sessions, but initiate appropriate classification thru normal plan administration if future need is shown.

i Page C-6' i

APPENDIX C (Continued)

SCHEDULE FOR ID STEPS MIICH HAVE BEEN TAKEN STEPS MIICH WILL BE TAKEN COMPLETION The plan does not Two sources appropriate for river level indi-No.further action required.

COMPLETE indicate if hydro-cation are provided in Section I.2.1.3 of the i

logic information Plan.

is available from any other source than the one indicated in Section I.2.1.3.

l The plan does not The guidelines provided in the NRC Branch Tech-The District believes that COMPLETE indicate if offsite nical Position were considered for the selection the selected locations for i

i monitoring devices of dosimetry instruments.

the offsite monitoring meet the minimum devices are adequate for NRC Radiological the important data acqui-Assessment Branch sition following an acci-i Technical Position dent.

for the Environ-mental Radiological l

Monitoring Program.

l i

L

{

Cameras are not The District has demonstrated the criteria of the District believes COMPLETE j

listed as part H-9 and used items termed ' examples' as guid-cameras are not required

[

t of the contents ance in the development of the RERP. Sample for emergency response at of emergency kits, items respiratory equipment, protective clothing, the onsite operations portable lighting, portable monitoring equip-support center. However, ment and communciations equipment are ir*cluded cameras are a resource in the Plan and at response facilities because within the Recovery their use is necessary to perform appropriate Organization.

emergency actions. The District was unable 2

to identify the use of_ cameras.for emergency actions.

l l

- ~

. ~. _ _ -, _

Paga C-7 APPENDIX C (Continued)

SCHEDULE FOR ID STEPS WHICH HAVE BEEN TAKEN STEPS WHICH WILL BE TAKEN COMPLETION The plan does not Criterion 10 requires provisions to inspect, The District believes that COMPLETE categorically ad-inventory and operationally check emergency adequate provisions pre-dress provisions equipment / instruments at least each calendar sently exist with the RERP of this criterion quarter and af ter each use.

Section H-2.3. of and supporting procedures for the operation, the RERP address the provision in reference to program to ensure proper inventory, calibra procedures ST-RM-3 and Standing Order T-13.

operations, inventory, re-tion, repair, and/ The OPPD commitment goes beyond the criteria pair, and replacement of or replacement of with a monthly surveillance frequency.

Pro-emergency response equip-emergency equip-visions for repair and/or replacement of in-ment and instruments.

ment /instrumenta-struments is not directly addressed in Cri-tion.

Section terion 10.

Therefore the statement in Section M2.3.5(7) does M2.3.5(7) provides assurance that these actions state that the are provided by normal plant operating pro-Supervisor of cedures under the responsibility and direction Health Physics /

of the Supervisor of Heath Physics / Chemistry.

Chemistry has responsibility for ensuring optimum operation of radia-tion / chemistry instruments / equip-ment.

Section 1-1.0 of The plant system status and the effluent pars-The District believes plant COMPLETE the plan does not meter values are discussed throughout Section I, system status or effluent identify plant

" Accident Assessment", of the Plan. They are parameters have been ade-system status or based on/ derived from the the example initiating quately addressed. The effluent parameter conditions in Appendix 1 of NUREG-0654 Rev. 1.

District will continue values correspond-annual reviews of the Plan ing to initiating and provide proper correc-conditions in Appendix tions as identified.

L, NUREG-0654 (see Standard D comments).

The Plan indicates that the kinds of instru-ments used and their capabilities are in the facility procedures.

Page C-8 APPENDIX C (Continued)

SCHEDULE FOR ID STEPS WHICH HAVE BEEN TAKEN STEPS WHICH WILL BE TAKEN COMPLETION The licensee fails NUREG-0578 is modified by NUREG-0737 including The District's position on COMPLETE to state in the short term as well as long term modifications, NUREG-0578 requirements is plan if onsite many of which are still being implemented. Any well documented and inclu-capabilities and deviations in requirements or schedule have been sion in the Emergency resources defined communicated to and approved by the NRC to date.

Plan would be inappro-in the criteria In fact, much criteria of NUREG-0578 has been priate.

are in accordance superceded by NUREG-0737 and later guidance and with NUREG-0578.

is expected to undergo future changes. Therefore, the District cannot make an unequivocable statement that on-site capabilities and resources defined in the criteria are in accordance with NUREG-0578.

Section 13.2 im-The instrument used in the field monitoring Add a footnote under Sub-COMPLETION plies the capa-(SAM II) does have the capability to measure /

section I.2.3.3 of the Plan. by 12/31/82.

bility to detect detect the radiciodine concentration in the radioiodine as plume EPZ as low as 1.0E-07 pCi/cc. A foot-low as 10-7 note under subsection I.2.3.3 will reflect mci /cc. The Plan this value.

does not, however, contain a definite statement in this regard.

The relationship OI-PAP-2 has been added to the operating in-The District believes imple-COMPLETE of various measured structions of the Plant Operating Manual.

menting procedures adequately parameters to dose Also the relationship of various measured and properly provide key rates for key iso-parameters to dose rates for key isotopet isotope to dose rate relation-topes (i.e., those is addressed in EPIP-EOF-6. Thirteen copies ships.

in Table 3, page of this procedure have been submitted to 18, NUREG-0654) is the NRC.

not addressed.

Section 12.2.6 re-feres to OI-PAP-2

" Post-Accident De-termination of Iso-topic Specific Acti-vities" that is un-available for comment.

Page C-9 APPENDIX C (Continued)

SCffEDULE FOR ID STEPS WHICH HAVE BEEN TAKEN STEPS WHICH WILL BE TAKEN COMPLETION The Plan does not Section J.1.1. and J.1.2. of the RERP provide The District believes the COMPLETE address the time the information required by criterion I with RERP addresses all the cri-required to warn supporting procedures in the following manner:

teria of J-1 with supporting or advise indivi-

1) Onsite personnel are notified by by a site basis provided by applic-duals of an emer-nuclear emergency alarm and receive additional able implementing and train-gency. There is instruction by the intra-plant public address ing procedures.

In accord-also no specific system (Caitronics).

Implementing procedure ance with the maintenance of discussion of the EPIP-OSC-2 requires this step as the first of the preparedness, the means used for action by the Shift Supervisor after re-District will continue to evacuation of on-cognition of an emergency. Therefore the review, train, and exercise site visitors and District believes the varning time for on-in accordance with the plan contractor / con-site personnel to be immediate or within a and initiate improvements structon personnel, few seconds. 2) The Plan indicates onsite as identified by these In addition, the personnel including visitors, contractors functions.

plan does not and non-cmergency assigned employees, eva-address the means cuate to the storeroom assembly area and used or time re-receive further instruction. The General quired to warn or Employee Training supports this discussion advise people who by requiring alarm recognition, assembly may be outside the area, designation, vehicle availability for protected area but site evacuation and relocation area as re-inside the owner quired knowledge prior to unescorted access controlled area.

to Fort Calhoun Station.

In addition, FCS procedures require trained escorts for visitors who exhibit insufficient knowledge. The refer-renced J Sections of the RERP were revised Jan. 25, 1982 to provide the specific means used for warning, accountability and evalu-ations of all persons within the owner con-trolled area.

The procedure assigns the on-site monitors the responsibility to inspect the area and direct everyone present to vacate in accordance with evacuation instruction.

Thirteen copies of this revision have been sub-mitted to the NRC as required by 10CFR50.

Page C-10 APPENDIX C (Continued)

SCHEDULE FOR ID STEPS WHICH HAVE BEEN TAKEN STEPS WHICH WILL BE TAKEN COMPLETION No reference is

1) The District believes the statement " exer-The District believes Section COMPLETE made to conducting cises shall be conducted as set forth in

'N' adequately addresses the exercises according NRC and FEMA rules" is ambiguous and non-planning standard, including to NRC and FEMA definitive. The District is connitted by the item noted in the report.

rules and specific its Operating License from the NRC to comply During perpetual maintenance provisions for with the provision of 10CFR50 which clearly of emergency plan and proced-conducting cri-provides sufficient rules for the conduct of ures, the District will ann-tiques as part of exercises in 10CFR50.47 and 10CFR50 Appendix ually correct and revise drills are not E.

The District believes the provisions of actions based on review, plan-addressed.

10CFR50 are sufficiently authoritative and ing, training, and exercise do not need replacement by non-specific

findings, rules which may be advanced by contributory agencies. 2) The District has reviewed cri-terion 1 and believes the more appropriate evaluation criterion for provisions of cri-tiques is criterion N-4.

Therefore, note the RERP contains the specific commitment for conducting critiques.

In addition, supporting procedures EPT-7 and EPT-10 ensure observer / evaluators participate in drills and exercises.

Although Section Section 0.7 of the RERP was designed to describe The District will revise COMPLETE 0.7 implies that the provisions of footnote 1, page 75, NUREG-and correct the Plan and all offsite re-0654 rather than only a footnote reference.

procedures annually based sponse agencies The Emergency Preparedness Training Program the result of reviews, receive training Section 4 contains the specific, detailed training, planning and and are trained content of training provided to of fsite -

exercise actions.

in basic funda-Support Groups. Notification, basic radiation mentals, the plan protection, communications and duties are does not specifi-the basic instruction topics.

cally indicate if the response groups listed in footnote 1, page 75, NUREG-0654, will receive the training and instruction noted in the footnote.

• /

Page C-11' APPENDIX C (Continued)

SCHEDULE FOR ID STEPS WHICH HAVE BEEN TAKEN STEPS WHICH WILL BE TAKEN COMPLETION The. plan does not The Emergency Preparedness Training Program A formal procedure change ISSUE CHANGE state if erroneous normally corrects erroneous trainee perfor-to the RERP will be ini-9/1/81 performance by a mance on-the-spot.

However, the District has tated, processed, pub-trainee will re-'

reviewed the Plan and procedures and did not lished and, issued to ensure ceive on-the-spot identify this criterion in a specific state-on the spot correction correction by the ment.

during drills.

drill instruction.

The Plan does not The District has reviewed criteriou 4 and The District believes licen-COMPLETE address the train-identified section 0.6.2 Recovery Organization see headquarters support ing of the licen-as the provision for headquarters support per-personnel training criteria see's headquarters sonnel training. The District concept is is adequately provided in support personnel, that the Recovery Organization is activated Section 0.6.2 and the during the early stage of severe emergencies emergency preparedness and not just a functional group reserved training program.

for long term recovery actions. Therefore, headquarters support is trained within the Recovery Organizations concept.

No mention is In the preparation of Section 0.for Training The District believes it COMPLETE made of training criteria, the District consolidated all train-adequately fulfills the for persons re-ing, including the training of those persons criteria for training sponsible for the responsible for the planning effort. Therefore, persons responsible for planning effort.

Section 0.5.3 describes the training program the planning effort.

of planr.ing personnel in full conformance to Criterion P-1.

The District has reviewe'd this placement again.and continues to believe Section 0.5.3 is the proper location for this training commitment.

While the site The RERP Section P-1 dated October 15, 1981 The District will revise 12/1/82 representative to identifies the Radiological Health and Emer-Section P-1.0 and' provide the total planning gency Preparedness Manager as the person specific identification for effort is identi-whose responsibility shall include the coor-the corporate individual fied, the corporate dination of offsite planning efforts and im-with overall authority.for individual with plies this is a corporate function. However, radiological emergency s

r- -

Peg 2 C-15

()

APPENDl% C (Continued)

SC11EDULE FOR ID STEPS WilICH HAVE BEEN TAKEN STEPS WilICH WILL BE TAKEN COMPLETION (Continued) overall authority the District has reviewed this description response planning.

for radiological and agrees the statements can be more emergency response specific.

planning is not specified.

Although the pre-The District implemented the initial NUREG-0654 The District believes a COMPLETE sentation of the criteria emergency plan on April 1, 1981. A cross-reference is not Plan is structured complete revision into the sixteen planning appropriate due to the on the sixteen standard structure was issued on October 5, small number of section planning Standards, 1981. The present Plan conforms closely to deviations in the Plan.

all of the relevant the outline form.

Deviations were accepted The District will con-material for a only in several cases where the changes im-tinue to review the Plan given Standard is proved the operability of the Plan. The Dis-on an annual frequency not necessarily trict knows of no deviations which reduce the and provide appropriate contained within effectiveness of emergency preparedness.

corrective actions, * -

the section of cluding conformance so the plan devoted the planning standard, to that Standard.

whenever either a de-Either more com-ficiency or improvement plete presentations is identified.

within individual sections or cross-references should be provided.

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