ML20064L049
| ML20064L049 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 12/08/1982 |
| From: | William Jones OMAHA PUBLIC POWER DISTRICT |
| To: | Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20064L027 | List: |
| References | |
| LIC-82-397, NUDOCS 8302150095 | |
| Download: ML20064L049 (7) | |
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Omaha Public Power District 1623 HARNEY a OMAHA. NEBRASKA 68102 E TELEPHONE S36 4000 AREA CODE 402 December 8, 1982 LIC-82-397 Mr. W. C. Seidle, Chief Reactor Project Branch 2 U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011
Reference:
Docket No. 50-285
Dear Mr. Seidle:
IE Inspection Report 82-23 The subject Inspection Report identified fourteen (14) open items resulting from an inspection completed during the 1982 Fort Calhoun Station emergency preparedness exercise.
The District's responses and corrective actions to these open items are attached.
ne W. C. Jor) Manager es Divisio:Y Production Operations WCJ/TLP:jmm Attachment cc:
LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.
Washington, D.C.
20036 Mr. J. L. Montgomery, NRC Emergency Preparedness Analyst Mr. E. G. Tourigny, NRC Project Manager j
Mr. L. A. Yandell, NRC j y Senior Resident Inspector
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8302150695 830207 PDR ADOCK 05000285 G
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ATTACH"ENT OfVHA PUBLIC POWER DISTRICT'S RESPONSE TO IE INSPECTION REPORT 82-23 Open item Completion
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No.
Description Steps Which Will Be Taken Schedule 8223-01 In the interest of realism, The District believes this open item refers to the place-Prior to the 1983 future scenarios and exer-ment of the extra or training operations shift in the Emergency Exercise cises should be carefully control room for emergency response assignment.
It has controlled with no pre-always been the policy of the District that, during emer-staging of equipment or per-gency exercises, the shift assigned normal plant oper-sonnel allcwed.
ational responsibilities continue the safe operation of the plant and that the extra or normally eff-duty shift provide the emergency exercise participation. The Dis-trict believes official 0 PPD observers may have established their stations several minutes prior to 0645.
In the absence of specific actions or activities identified either within Inspect'on Report 82-23 or observer comments, the District assumes these two examples constitute the prestaging.
The District will evaluate its policies for extra shift participation and observer stations in the con-trol room and initiate methods to reduce prestaging of per-sonnel or equipment.
8223-02 Accountability of personnel The District will review Emergency Procedures EPIP-0SC-2 May 1, 1983 dispatched from the control through EPIP-0SC-9 and EPIP-E0F-9 and establish a method room should always be main-to maintain continuous control room accountability.
tained.
8223-03 Health physics monitoring and Health physics procedures HP-5, HP-9, and HP-15 and.EPIP-Review Completion:
sampling in the control room E0F-3 will be reviewed to ensure proper procedures are March 31, 1983 should be reviewed to ensure identified and can be followed. The corrective action that proper procedures are based on this review will be to either revise the exist-Corrective Action being followed.
ing procedure or establish a new, specific procedure Completion:
identified in the EPIP's to ensure health physics moni-July 1,1983 toring and sampling can be accomplished in the control room. >
Open Item Completion No.
Description Steps Which Will Be Taken Schedule 8223-04 The OSC should serve as the The Fort Calhoun Station OSC properly provides plant July 1, 1983 plant logistic support center logistic support which is coordinated during an emer-as described in NUREG-0696.
gency and restricts control room access to support per-The OSC functions should not sonnel.
These activities are conducted at the Shift be dispersed in other emer-Supervisor office area and a designated area of the gency support facilities.
Technical Support Center building as identified in the Radiological Emergency Response Plan.
The District believes available plant spaces for emergency occupancy mandate these locations.
The District believes the assembly area for maintenance support personnel should remain near the TSC structure, but will re-evaluate our OSC concept and function for the capability to better consolidate operational logistic support personnel.
8223-05 The management structure in As evidence by the operation of the Technical Support July 1, 1983 the TSC should be reviewed Center staff during the afternoon period of the emer-with emphasis given to en-gency exercise, the manager and members of this group suring strong leadership and demonstrated their ability to provide plant management management in the early and technical support to reactor operating personnel.
phases of TSC operation.
The District believes the actions of this group may be performed in a more efficient manner.
Therefore, a review of the management structure as well as the physical work location of individuals in the TSC will be conducted to ensure effective operation of this facili ty.
8223-06 Surveys and sampling should The concern referenced in the subject Inspection Re-January 1, 1983 efficiently and accurately port appears to be due primarily to the operational determine TSC habitability.
status of the newly acquired particulate, iodine, and Sampled air should be repre-noble gas monitor (PING 1A).
At the time of the exer-sentative of the total TSC cise, the physical installation of PING 1A was near com-ventilation.
pletion, but calibration and setting of alarms was still in progress.
By operating the PING prior to full cali-bration, the radiation protection technician was testing as much of the emergency plan as is reasonably achievable in the spirit of 10 CFR 50 regulations. As of this date, calibration of the PING 1A has been conducted and final Open Item Completion No.
Description Steps Which Will Be Taken Schedule 8223-06 review and incorporation of the alarm setpoint into (Continued) the monitor remains to be completed prior to declaring the unit fully operational.
During operation of the PING 1A, the air sample nozzle is located in the venti-
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lation duct.
During emergency conditions in the recir-culation mode, the sampled air analyzed is representative of the total TSC ventilation.
The District believes the in-stallatica and final calibration of the PING 1A will correct this open item concerning TSC habitability measurements.
8223-07 The Emergency Plan and Imple-The Emergency Plan and Implementing Procedures discuss July 1, 1983 menting Procedures should be health physics control under the Health Physics / Chemistry revised to clearly describe Supervisor function and support of these activities the interface between the under the TSC manager function. As established in the health physics and TSC oper-Emergency Plan, the HP/C Supervisor is a member of the ations.
Plant Operations llanager staff and keeps this individual informed of his activities and determinations. The District will review the organizational arrangement, assignment, and responsibility of these three positions and clearly define their interface.
8223-08 The Health Physics Supervisor As recorded in the emergency log, an accountability of No further Action should be cognizant of the the monitor team dispatched into the auxiliary building is Necessary length of time monitoring teams was maintained.
In addition, voice communication with have been dispatched, parti-this team was conducted. The District believes the HP cularly in high radiation areas.
supervisor was cognizant of their activities and pro-vided adequate control through his initial instructions, outfitting with appropriate instruments, dosimetry and protective equipment in the Radiation Work Permit, re-cording of plant area monitor levels and knowledge of their exit from the radiation area.
8223-09 Prompting and coaching by the The Manager-Radiological Health and Emergency Planning Prior to the 1983 Manager of Radiation Health has stated that his action was based on the Evaluator-Emergency Exercise and Emergency Planning, or any Controller General Instruction that a major deviation licensee personnel, should not from the approved scenario would not be permitted and be allowed as this is contrary events in mid-afternoon appeared to alter the scenario to the licensee's Evaluator-and exercise objectives.
The District disapproves of
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Open Item Completion No.
Description Steps Which Will Be Taken Schedule 8223-09 Controller General Instructions interfering actions by either the Manager-Radiological (Cont.)
and the objective of conducting Health and Emergency Planning or any licensee personnel a realistic scenario that de-and will apply proper controls.
The District will monstrates the licensee's emer-appoint a formal group for preparation of the scenario.
gency response capabilities.
The members of this group will not be participants in exercise response. All members of this group will serve as observers-controllers only. The Manager-Radiological Health and Emergency Planning will not participate in the preparation of the scenario or pre-briefings. His role will be restricted to his emergency function as the Emergency Coordinator.
8223-10 Emergency response status boards New status boards for Fort Calhoun Station emergency Prior to the 1983 should be redesigned to provide conditions were designed utilizing NUREG-0654, Evalu-Emergency Exercise trending of important plant ation Criteria E.4, and installed in mid-1982. Addi-parameters.
tional plcnt parameters are maintained on chalkboard.
Trending of important plant parameters is accomplished by instrumentation located in the control room and TSC.
It is expected that the Emergency Response Facility computer displays to be located in the TSC and EOF will ultimately provide the optimum trending indications.
However, for the near term, OPPD will re-evaluate its status boards for methods to better display important plant parameters and trends.
8223-11 Briefing of EOF personnel fol-Log entries do not support these two observations.
During 1983 Annual lowing emergency action level During the exercise, periodic briefings of the EOF Retraining declaration should be timely recovery staff were held by the Recovery Manager and protective action recom-throughout the day.
The Information Specialist was mendations should be given to included in these briefings and news releases were state and local agencies.
forwarded to the Media Release Center as a result of these briefings.
The declaration of the general emergency was recorded at 1431.
Log entries identify-ing 25 rem thyroid dose by the Iowa monitor teams and the potential for a large containment release were the basis for this decision.
Emergency Plan Implementing -
Open Item Completion t
-Description Steps Khich Will Be Taken Schedule No.
8223-11 Procedure EPIP-05C-1, Items IV.4.a. and c., provided (Cont.)
the basis for the determination.
Protective action i
recommendations were provided to the applicable state (Nebraska and Iowa) and local officials (Washington and Harrison) during a conference call in accordance with the EPA guidelines (i.e., evacuation in sectors EFG to 5 miles and in-house shelter between 5-10 miles).
These recommendations were accepted by the state repre-sentatives.
Recommendations to remove the protective actions were made at 1550 when de-escalation was dis-cussed through the conference network. Although the District does not concur that an open item is appropriate here, the District will continue to emphasize timely personnel briefings, application of EPIP-0SC-1 and protective iiction recommendations to sta'.e and local emergency operation personnel during the conduct of an emergency or exercise.
8223-12 Weather forecast information Pre-planning for weather forecast information is des-Prior to the 1983 should be obtained and used.
cribed in the Radiological Emergency Response Plan, Emergency Exercise Section C.1.2.4, " National Weather Service," and with a letter of agreement which states:
"The National Weather Service agrees to provide weather information to the Fort Calhoun Station as needed.
In-versions, wind pattern, direction and speed are among some of the weather information which may be provided in the event of a radiological emergency.
The National Weather Service operates on a twenty-four (24) hour basis."
I Contact with the National Weather Service is checked by regular auarterly telephone number verification and has been tested during drills. However, since this support is not contained in a specific implementing procedure, the District will review its dose assess-ment and projection procedures, especially EPIP-RR-6, and will revise the procedure to reference the source and utilization of weather forecast information.
Open Item Completion fio.
Description Steps Which Will Be Taken Schedule 8223-13 Rescue team equipment should Instruction in the Radiological Emergency Response September 1, 1983 include first-aid supplies Plan (RERP) for emergency re-entry team members enter-and radiation detection in-ing the plant specifies "obtain and battery check high struments.
range survey instrument".
Additionally, the selection of a survey instrument from the instrument cabinets is made by a team member based on training and Radiation Protection Procedure RPP-18. " Instrument Selection".
Further, re-entry teams are not outfitted with first aid supplies.
They are instructed and trained to move injured personnel away from high radiation areas and to utilize first aid kits stationeu at specific locations throughout the plant until arrival of the rescue squad. However, the District will review and revise the RERP, Section B.2.4.b, and EPIP-0SC-7, " Personnel Rescue," during the next annual review to provide specific reference and clarity for use of first aid supplies and proper radiation de-tection instruments by rescue team personnel.
Rescue team personnel will become cognizant of these pro-cedural changes during the annual retraining cycle.
8223-14 More thorough training should The District has reviewed the emergency preparedness During 1983 be given to personnel who are training program and believes it is thorough and Annual Retrain-assigned dose assessment re-comprehensive. All shift health physics technicians ing sponsibilities.
are trained to make initial dose assessment evalu-ations.
The District believes the problems encountered by the subject technician were due to limited experience and were an isolated case.
The District believes that as additional experience is gained by this individual, job proficiency and accuracy will increase. Additionally, the District will continue to parform initial emergency preparedness training with annual retraining for all persons assigned emergency preparedness responsibiTities.
The training for personnel assigned dose assessment re-sponsibilities is detailed and includes a practical factor demonstration observed and approved by the instructor.
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