ML20066H760

Forwards Addl Info Requested in Re Response to IE Emergency Preparedness Appraisal Rept 50-285/81-35

ML20066H760
Person / Time
Site:	Fort Calhoun
Issue date:	10/15/1982
From:	William Jones OMAHA PUBLIC POWER DISTRICT
To:	Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
LIC-82-348, NUDOCS 8211230344
Download: ML20066H760 (26)

Text

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Omaha Public Power District 1823 HARNEY a OMAHA, NEBRASKA 68102 e TELEPHONE 530 4000 AREA CODE 402 October 15, 1982 LIC-82-348 Mr. W. C. Seidle, Chief j

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Reactor Project Branch 2 d

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i U. S. fluclear Regulatory Commission i

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Region IV l0N f

3 611 Ryan Plaza Drive, Suite 1000

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Arlington, Texas 76011

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Reference:

Docket tio. 50-285

Dear Mr. Seidle:

Emergency Preparedness Appraiscl Your letter to Omaha Public Power District dated August 18, 1982 re-quested additional information in support of our response to the Emer-gency Preparedness Appraisal conducted by your office in December, 1981.

The District had responded to the appraisal findings by letter dated June 1, 1982. Your August 18, 1982 letter asked us to "specify, where appropriate, the exact location of the procedures described in attach-ments 1 and 2" of our June 1, 1982 letter. Accordingly, please find attached the requested information.

Sincere,1y, Aji a&?.d(yY W. C. Jones Division ~ Manager Production Operations WCJ/TLP:jmm Attachment cc:

LeBoeuf, Lamb, Leiby & MacRae 1333 New Harrpshire Avenue, N.W.

Washington, D.C.

20036 Mr. L. A. Yandell, flRC Senior Resident Inspector Mr. E. G. Tourigny, flRC Project Manager g

K Ok&fgg POR

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Paga 1 Plan /Procedura Item Description Corrective Action Response Reference A.1 The licensee shall conduct An evaluation of augmentation procedures to deter-Not appropriate an evaluation of existing mine augmentation times for each of the major augmentation procedures to emergency functionai duties listed in Table B-1 of determine, for each of the NUREG-0654 (Rev. 1, November 1980) was conducted.

major emergency functional The results were reported to the Nuclear Regulatory duties in Table B-1 of Commission by letter dated March 1, 1982, and NUREG-0654 (Revision 1.

indicate realistic assessment times as low as November 1980), the extent 45 and 60 minutes as compared to the staff to which the augmentation guidelines of 30 and 60 minutes.

times conform to the staff The District will continue to encourage employee residence guidelines of 30 and 60 near the Fort Calhoun Station site and assign emergency minutes. The evaluation duties to the greatest extent practical to those persons should provide for a with shorter travel distances.

It is expected that realistic assessment of the these measures will maintain or possibly reduce the present times when each position reasonable reporting times.

would have been filled under emergency conditions.

A.2 The licensee shall develop The Fort Calhoun Station Radiological Emergency RERP: Sections B.2.4.F, and implement procedures Response Plan was revised and new instructicns J.1.1 and J.l.2 for the notification of issued on January 25, 1982. Correction to Section J appropriate authorities describes the notification method which utilizes the regarding the need for early warning system.

Section B sets the review and evacuation of offsite reporting recponsibility within the owner controlled personnel who may be area as an onsite monitor duty.

present in the owner controlled area during The District will continue its emergency preparedness a site evacuation.

training and exercise program to maintain proficiency of emergency response personnel, including onsite monitors.

A.3 The licensee shall inte-As stated in the District's January 29, 1982 response, Fort Calhoun Station grate the Emergency the Station Emergency Procedures were revised by Operation Manual Action Levels (EALs)

March 15, 1982 and other applicable operating pro-Volume V into the Station cedures revised by May 1, 1982. The Emergency

" Emergency Operating Procedures Action Levels have been incorporated into the Fort Procedures".

and assure that the Calhoun Station emergency procedures where required.

procedures are written The District also reviewed the Fort Calhoun Station in such a manner as to normal operating procedures and verified that the enable the reactor existing operating procedures adequately lead the operations operator from the normal to emergency procedures.

Pega 2 Plcn/Procsdura ltem Description Corrective Action Response Reference A.3 (Continued) personnel to effectively These improvements ensure the transition from 1

and expeditiously move from normal to abnormal operations through emergency abnormal operations, operations and into the EPIPs occur in a timely through emergency and effective manner.

operations and into the The District will continue periodic review and emergency plan implementing improvements of operating and emergency procedures procedure.

to maintain adequate operator instruction during the transition from normal plant operations.

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

A.4 The licensee shall As stated in the District March 19, 1982 response RERP: Section J.1.4 determine the expected and the April 1, 1982 addendum to significant number of onsite emergency Finding #4, Eighteen (18) additional self-contained personnel who may be breathing apparatus (SCBA) units have been procured.

required to perform This action is the result of an internal evaluation essential duties under which identified the expected number of onsite conditions of signif-emergency personnel requiring SCBA units in order to icant airborne radio-better perform their tasks. The evaluation results set active contamination the number and location as forty (40) total units at and who therefore seven (7) emergency response stations. Each area is require a self-contained quickly and safely accessible to persons who require breathing apparatus in the respirators. The District has also verified that order to safely perform the applicable personnel maintain a capability to don their assigned tasks.

and use respiratory equipment in accordance with the The licensee shall make Fort Calhoun Station Radiation Protection Program.

provisions for acquisi-Additional personnel whose duties require use of tion of necessary respiratory equipment have been identified and shall quantities of maintain the District's respiratory use qualification.

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 NRC that all emergency response personnel will

Pago 3 Plan / Procedure Item Description Corrective Action Response Reference t

A.4 (Continued) maintain their capability to safely and efficiently don appropriate respiratory protective equipment.

B.1 Assign the site Supervisor - Chemistry & Radiation Protection RERP: Section P. 1, representative has been selected to be site representative.

Rev. 1 " Responsibility for the Emergency Appointment assigned by official memorandum for the Planning Effort:

Preparedness De-and recorded in the Emergency Plan.

Development, Periodic velopment Program.

Review and Distribution".

B.2 Develop.and im-Emergency Preparedness Training Manual (Section Emergency Preparedness plement a program

5) was reviewed and the program provides for spffi-Training Manual:

,_f.

~

for professional cient development training to attain oad maintain-

'Section 5.0 -

development train-proficiency througli the plan commitment " training "Planq)ng Personnel ing for indivi-shall include development courses to maintain state Training",'Part'5 6.3.

4 duals who are of the art knowledge."..

assigned Emergency Planning responsi-

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bilities which will

.s' I

enable them to attain and maintain' a state-of-the-art knowledge in the field of emergency preparedness.

- r

.s Plant staff provides substantive input through

1) EPT:

10.F.3 " Annual B.3 Develop and imple-existing training, drills, exercise participation, Radiation Emergency ment a method to provide substantive input critiques, maintenance orders, safety meetings and Exercise".

to emergency pre-

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suggestion programs. 3

2) RERP: Section P.2.0,

^,

,e

" Review and Update of paredness plans

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the' Emergency Plan".

and procedures.

3)'EPT-9: " Emergency r

Plan Reviews"

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Pcgs 4 s

P'Isn/ Procedure Reference Item Description Corrective Action Response

~

B.4 Develor and im-Position descriptions for the Manager - Rad

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(1) OPPD Position plemene a program licalth and Emergency Planning and his staf f Descriptions. (2) selection and contain sufficient information for selection Performance Appraisal qualification and qualification.

System - Supervisory Procedure 8.13.

criteria for indi-viduals performing emergency prepared-ness development y

activities.

B.5 Develop and imple-Quality Assurance and Safety Audit and

1) Quality Assurance ment quality assurance Review Committee audits are routinely performed Procedure #16, procedures to evaluate to evaluate the emergency preparedness program Appendix A-the effectiveness and include a full review of conformance to

" Internal Audits of the emergency training commitments.

for the QA Program" preparedness (Annual Audit performed development t raining April 1982, Audit #13-82) including the

2) RERP: Section P.2.2.1, professional develop-

" Safety Audit and Review ment program developed Committee Audit" for persons assigned

3) EPT-9, F.3 " Emergency emergency preparedness Plan Reviews" (Biennial development activities.

audit performed by SARC in August 1982, Audit #3-82.)

B.6 Correct Emergency The Emergency Plan and EPIPs have been reviewed RERP: Section P Plan, EPIPs and EPTs and presently show the proper date of issue and

" Responsibility for the to be consistent revision. A review of the EPTs has also been Planning Effort:

Develop-with the date completed and corrections have been made to ment, Periodic Review and requirements of 10 identify the proper revision number and date.

Distribution", Part P-1.

CFR Part 50, Appendix E, and the guidance contained in NUREG-0654

Page 5 Plan / Procedure Item Description Corrective Action Response Reference B.7 c,rrect the EP and The Manager - Fort Calhoun Station periodi-1)RERP: Section B PIPS to unambiguously cally issues an assignment and designation

" Organizational Control' specify, by duty notice for the onsite emergency organization.

of Emergencies", Part B.2.

title and emergency This document specifies the duty position

2) EPIP : RR-10 thru RR-62 duty title, for the onsite emergency organization and the Recovery Organization all persons persons by name assigned to this position.

Procedures.

assigned to the Recovery Organization designates all

3) Also, refer to item B.8 licensee's Onsite persons assigned by' normal duty title and Emergency Organiza-emergency title in RERP, Section M and EPIP-RR-10 tion and Recovery thru 62.

Organization.

B.8 Provide documentation Af ter review of this comment, the District 1)Onsite Emergency that formal assignments believes the optimuru method for formal Organization: As per of all persons assigned assignment of persons by name is by the Interoffice Memo to the Onsite Emer-periodic update and distribution of a

1. FC-1701-82 dated gency Organization memorandum issued by the responsible manager.

September 2, 1982.

and Recovery Organi-

2) Recovery Organization zation have been made.

As per Interoffice Memo

1. EP-82-186, dated September 1, 1982.

B.9 Remove inconsistencies The duplication identified has been corrected.

EPIP:

EOF-9, Rev. 2 between the EP and EPIPs The District is unaware of other inconsistencies.

" Personnel including corrections Any future identified duplications will be corrected Accountability" to remove unintended through the normal procedure change process.

duplication of assigned responsibilities.

B.10 Correct the EP and EPIPs On December 17, 1981 the OPPD Board of Directors RERP: Appendix D-by unambiguously de-approved Resolution #3083 which authorizes and "0 PPD Resolution #3083 fining the authorities directs the General Manager to take actions required Radiological Emergency of all individuals by the Radiological Emergency Response Plan. The Response Plan Authority".

assigned to the Onsite General Manager subsequently designated the RERP Emergency Organization as the official District Plan and authorized persons and Recovery Organization.

filling a position identified in the plan to conduct activities necessary to fulfill their responsibilities described in the Plan. Resolution #3083 is being added to the Emergency Plan as Appendix D.

_.__m Pogs 6 I

Plan / Procedure Item Description Corrective Action Response Reference

• ~

B.ll Develop and Implement The District has reviewed this consideration and Not Appropriate i

specific lines of believes a line of succession already established succession for all for the EDO position is necessary.

It ensures one positions in the individual is responsible for the complete corporate unnagement st ructure emergency response decisions. The preparation for the for the unrious position can be accomplished by a strong, general functional response knowledge of the RERP. However, for the positions I

areas of the Onsite in the Onsite Emergency Organization, an experienced Emergency Organization.

Individual with technical preparation for the special-ized duties is required. This is best accommodated by technical training of a primary and alternate member which is considered more appropriate than a line of succession arrangement.

1 l

B.12 Develop and implement The Emergency Preparedness Training Manual establishes Emergency Preparedness selection and quali-the selection and qualification requirements for Training Manual:

fication criteria for personnel assigned duties within the RERP. Completion

1) Section 2 " Emergency individuals assigned of the training ensures the requirement has been Organization Training".

to perform emergency satisfied. Personnel selection includes adherence to

2) Section 3

" Recovery I

actions and decision appropriate standards and experience requirements Organization Training".

making as members of followed by rigid, specific training with practical the Onsite Emergency demonstration of duties prior to final qualification Organization and acceptance.

I Recovery Organization.

1 B.13 Provide in the Emergency The letters of agreement contained in Appendix RERP: Appendix A, Plan copics of up-to-date A have been reviewed in accordance with the annual Rev. 1 " Letters of letters of agreement commitment and generally contain sufficient Agreement".

or contracts which specificity and are up to date. Authority and demonstrate that responsibility are also encompassed by governmental arrangements have and corporation policies. However, limits of action been made with offsite are usually not defined. When required, new letters organizations (both will be obtained with emphasis on limit of actions commercial & private) for support groups.

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Peg 2 7 Plan /Procsdura Item Description Corrective Action Response Reference B.13 (Cont'nued) to supply specifically defined support or cooperation during an emergency including their authorities, responsibilities and limits of actions.

B.14 Complete the New procedures and procedure revisions New Procedures implementation of have been iscued.

EPIP-OSC-9 all existing EPIPs.

OSC-10 OSC-11 EOF-15 EOF-16 EOF-17 EOF-18 were issued between l-1-82 and 4-30-82.

B.15 Develop and im-A review identifing personnel Radiation Protection plement a program expected to remain at Fort Calhoun Manual to train all emergency Station during emergencies is being

1) Section 2.12.2 response personnel conducted. These persons shall be

" Respirator Equipment in the proper use of designated as respirator wearers, Training".

all equipment which included in the Station Respirator

2) Section 9 Operating would actually be Program and as such receive SCBA Procedure HP-7 " Annual required to safely instruction as a qualification Review For Personnel perform their assigned requirement.

Authorized to wear tasks under emergency Respirators".

conditions, incluiing walking through ttsining while wearing full respiratory protection

& protective clothing.

Pzgs 8 Plan / Procedure

• ~

Item Description Corrective Action Response Reference B.16 Develop and implement, EPIP-OSC-2 and EPIP-RR-1

1) EPT: 5.1 " Emergency for the Control Room, have been revised, issued and implemented.

Telephone Numbers".

a controlled telephone A controlled telephone list for the Control

2) EPIP: OSC-2 list of personnel &

, Room has been provided and is verified on

" Emergency Plan agencies to be a quarterly basis.

Activation".

contacted during 3)EPIP: RR-1 emergencies, including

" Activation of Recovery provisions to maintain Organization".

and verify the phone numbers at least quarterly.

B.17 Provide Radiological In response to NUREC-0737 items II.B.2, III.D.3.3 RERP: Section H.4.3 monitoring equipment and III. D.3.4 modifications were implemented at the and Table H with both visual Fort Calhoun Station to:

(1) provide means to

" Emergency Facilities and audible alarms measure airborne activity in all areas required and Equipment".

to detect radiation to be accessible following a DBA and (2) to ensure

& airborne radioactive adequate shielding is provided to allow entry to all contamination in the areas which must be accessible. Accordingly procedures Control Room.

have been established to protect people located in the Control Room f rom direct or airborne radiation.

B.18 Provide permanently See answer to B.17.

RERP: Section H.I.3 installed radiation

" Emergency Facilities monitoring equipment, and Equipment".

with both visual &

audible alarms to indicate both radioac'ive airborne contamination and direct radiation in the TSC.

B.19 Provide adequate The main Conference Room was an interim TSC 1)RERP: Section H. 1.2 communications with adequate communication in the adjacent

" Emergency Facilities and in the main con-main office area.

The District has erected a Equipment" (Note the TSC ference room of new TSC building. Outfitting of the new TSC was activated on Sept. 13,

Page 9 Plan / Procedure Item Description Corrective Action Response Reference B.19 (Continued) the TSC for has been completed with special attention to 1982 as per Interaffice communicating communication, monitoring and assessment Memorandums FC-1787-82 &

with the Control equipment.

EP-82-215.)

Room and the 2)EPIP: TSC Emergency Oper-

" Technical Support Center ations Facility.

Communication" (Presently being revised to include updated communications.)

B.20 Develop or revise The location of the alternate EOF and direction RERP: Section 11 existing procedures to the facility are adequately described in the

" Emergency Facilities and to reflect the RERP. These instructions have also been included Equipment" and Section location of the on a video training tape recently prepared. The J.l.2

" Evacuation".

Alternate EOF &

District is constructing a new EOF approximately directions from 17 miles from Fort Calhoun Station. Completion the station to the of structure will allow the emergency response facility.

to be directed always from one facility and an alternate facility a greater distance from the site will no longer be necessary. The Plan and procedures will be corrected to accurately describe the new facility within 60 days after completion.

B.21 Develop and implement The District has developed and implemented 1)RERP:

Section 11.2-methods and procedures procedures ST-RM-3 and EPT-2 as monthly

" Emergency Facilities (e.g., seals, minimum surveillance inspections to assure that the and Equipment".

l stock levels etc.) to dedicated emergency equipment and supplies

2) EPT: #2 -

assure that dedicated are available as planned.

The test consists

" Emergency Plan Instru-emergency equipment of inventory and function test of instruments ments and Equipment".

and supplies are indeed for operability. The District believes its present

3) Surveillance Test available when needed surveillance method is more comprehensive than ST-RM-3 " Emergency for emergency response.

the suggested seal method.

In addition it provides Plan Radiation Instru-instrument and battery operability verification.

ments and Equipment".

The District intends to continue the present surveillance tests.

Pege 10 Plan / Procedure Item Description Corrective Action Response Reference B.22 Develop and implement As stated for Item B-21 the District review 1)EPT: #2 " Emergency procedures for rein-indicates the full monthly inventory now Plan Radiation Instru- -

• i ventory of equipment or being done is more ef fective than the ments & Equipment".

supplies when tamper suggested seal device.

2)ST-RM-3 " Emergency indicating devices.

Plan Radiation Instru-are removed or broken ments & Equipment".

i B.23 Upgrade existing The District has established a personnel decon-EPIP:

EOF personnel decon-tamination monitor team and a decontamination

" Personnel De-tamination faci-station at the EOF.

A specific procedure and contamination".

lities to pro-decon supplies are available to perform decon EPT-2, " Emergency l

vide ready ac-properly. Ample soaps, brushes, and towels are Plan Radiation cess to all ne-stored in the cabinet within the decon station.

Instruments and cessary decon-Sodium citrate and large containers required by the Equipment",

tamination agents the procedure when iodine on the skin must be Part F.1.

i at the decontami-removed, were available at the adjacent ST-RM-3, " Emergency nation room.

storeroom. These supplies have been permanently Plan Radiation transferred to the emergency decon station for Instruments and optimum access.

Equipment".

B.24 Provide additional 01-PAP-1 has been revised to update the present Operating Instruction:

fixed and portable sempling method and shielded equipment.

PAP-1.

Rev. 2-4 radiological shield-

" Post Accident Sampling Ing where practical, of Primary Coolant to aid in the re-Sample".

l duction of exposure

]

to sample and anal-l ysis personnel (in-l cluding sample transport devices)

.(

1 1

Page 11 Plan / Procedure i

Item Description Corrective Action Response Reference B.25 Evaluate capabilities The counting system at the North Omaha Station Not appropriate for meeting the 3-hour has been evaluated and improved methods will be sample and analysis initiated.

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

B.26 Evaluate high level Analytical procedures will be revised or

1) FCS Operating Manual sample counting developed to resolve this concern. Counting Volume 8, Chemistry limitations of both limitations will be evaluated.

Sample size Manual CMP-2 " Sample Celi systems under counting time, and geometrics will be modified Collection".

present counting if shown necessary.

2) 01-PAP-1, " Post geometries.

Accident Sampling of Primary Coolant Sample",

Revision 2.

B.27 Develop and implement Administrative Procedure S. O. T-13 establishes

1) Admin Procedure procedures for calibration and functional check frequencies.

Standing Order T-13 maintaining routine All District gamma spectrometers including the

" Quality Control Program efficiency and Model 901 multichannel analyzer, are calibrated for Chemistry Equipment".

calibration checks bi-annually and function checked either weekly,

2) Calibration Procedure of the NaI backup or prior to use.

Procedure CP-LAB-10 controls CP-LAB-10 "Na1 Gamma counting system at the calibration method.

Spectrometer".

the North Omaha Station.

B.28 Install in the The District has reviewed this consideration and con-EEAR/MR-FC-82-69 station decontami-cerns that a communication station in the decontamin-nation area ade-ation area would provide improved health physic assis-quate communications tance. An Engineering Evaluation Assistance Request for contacting Health (EEAR) was initiated to install a Gaitronic set at the Physics personnel.

Station Decon Area and the subject modification was recently completed.

Page 12 Plan / Procedure Item Description Corrective Action Response Reference B.29 Provide in both Both decontamination facilities are equipped EPIP-EOF-10 decontamination with basic supplies. The quantities were in-

" Personnel Decon-facilities adequate stalled, evaluated and operating experience has tamination".

and necessary sup-provcq them to be adequate, especially within the plies for personnel plant.

In addition; great quantities are stored decontamination.

in areas in close proximity to decon facilities.

B.30 Provide permanent The decon area within the plant has personnel

1) EPIP-EOF-10 " Personnel instructions in decon instructions identical to those in the Decontaminiation".

both decontamina-Radiation Protection Manual posted. Standard

2) Radiation Protection tion facilities to operating practice is for each individual to

. Manual Section 2.9 contact Health start self decontamination prior to arrival of

" Decontamination Physics upon deter-IIP personnel.

The EOF decon facility is Procedures".

mining that the continuously manned during emergencies by a decon

3) RPM-Radiation individual (s) are monitor. The decon monitor is guided by an EPIP.

Protection Procedure contaminated and The District program places decon duties with the RPP-7 " Personnel provide a communi-monitor and not the contaminated person. Therefore, Decontamination" cation system to the District believes it inappropriate for decon pro-accomplish the cedures to be posted. The EPIPs are available at the notification.

Emergency Operations Facility. The District believes its decon procedures at each facility are commensurated with its mode of operation and present policies are adequate and appropriate.

B.31 The adequacy The District has a new TSC and is in the process of Not appropriate of the Expanded constructing an offsite EOF.

Support Facilities will remain an Open Item for future resolution until final plans are prepared and construction autho-rized by OPPD for those facilities.

Page 13 Plan / Procedure Item Description Corrective Action Response Reference B.32 Perform an The Omaha / Douglas County Civil Defense Emergency Not appropriate evaluation to Operating Center was selected as the Media Re-determine what lease Center because the facility is specifically additional elec-designed and constructed for this type of service.

trical service It has been used successfully during disasters such would be needed as the Omaha Tornado of 1975. The District is by news media evaluating whether the Omaha / Douglas County Civil representatives Defense Emergency Center should have additional during an emer-electrical service for news needs.

gency and pro-vide such a capability in the MRC.

B.33 Replace the small The District has reviewed this improvement

1) Operating Manual hand-held high item and believes its adoption is commensurate Volume X, Surveillance range instrument in with District ALARA policies.

ST-RM-3 will be Tests ST-RM-3 " Emergency the Control Room revised to replace the hand-held high range Plan Radiation Locker with an ins t rument in the Controi Room with an extended Instruments & Equipment".

extendable probe probe hi;h range instrument.

2) RERP-Table Il-1 high range instru-

" Fort Calhoun Station ment.

Emergency Kits".

B.34 Develop and implement The calibration of meteorological equipment and Not appropriate procedures to instruments has been performed for many years calibrate all in accordance with procedures CP-6272 through meteorological instru-6265. The calibration tests and frequency, ments and equipment initially once per year and later increased to on a quarterly basis.

semi-annually, have provided c very good availa-bility and performance of the equipment. The District believes the operating experience of six years with the present meteorological instruments and procedares denonstrate reliable service with 6 month calibration frequencies. This record provides sufficient basis to continue the present calibration.

Page 14 Plan / Procedure Item Description Corrective Action Response Reference B.35 Develop the capa-These provisions will be provided following the Not applicable bility for remote full implementation of the emergency response facilities.

interrogation of the meteorological system by off-site agencies in accord-ance with Regula-tory Guide.

B.36 Provide a detailed The detailed description of the dose assessment

1) RERP,Section I.3 description of methodology is described in Section I.3 of the

2) EPIP-OSC-10 the dose assess-Plan and in the appropriate emergency plan in-

" Initial Assessment of ment methodology plementing procedures (EPIP.9).

All of the of Plant Parameters and and how meteorological applicable CPIPs require the use of on-line Effluent Monitors to information is used (real time) meteorological data as a primary Determine Source Term".

in that model.

source. The meteorological models for the online

3) EPIP-OSC-Il " Initial computer have been reviewed by the NRC in the Dose Assessment Based past; i.e., 1974, 1975 and 1976.

If the real on Plant Instrumentation".

time meterological data are not available

4) EPIP-EOF-6 "Onsite and then the dispersion factors are obtained from Offsite Dose the overlays. The meteorological model for the Assessment".

development of overlays is based on the following

5) EPIP-RR-6 standard Caussian diffusion aodel:

" Population Exposure 2

^/,II/Q = (

1

) exp ( y /2 g 2) y

( 2 tra ez

)

x (yexp(-(z-h)2/2d 3

+exp(-(zfh)2/2cr2

Page 15 Plan / Procedure Item Description Corrective Action Response Reference B.36 (Continued)

Where: '(

is the radionuclide downwind concentrate, Ci/m3

/

is the average wind speed, n/sec.

u Q

is the radionuclide release rate, Ci/sec.

C'q is the horizontal dispersion coefficent of the plume per Pasquill class, m.

g is the vertical dispersion coefficent 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.

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

~).u/Q=(

1

) exp ( y /2 d 2 as:

z)

(

O' yd'z

)

B.37 Perform an analysis The terrain in the vicinity of Fort Calhoun RERP,Section I.3 to determine how a Station is generally flat from the north, release plume from FCS northeast, east and southwest sectors, with may be modified an elevation of approximately 1000 feet above by terrain induced mean sea level (MSL), for a radius of at least 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 ona mile of the Fort Calhoun Station in the south through west-southwest sectors.

Page 16 Plan / Procedure Item Description Corrective Action Response Reference B.37 (Continued)

Two possible weak effects in the site meteoro-lagy are:

1) under very light westerly wind flow there is a possibility of weak drainage flow off the bluffs to the west towawrd 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 meteo-rology.

This information will be incorporated into the next major revision of the Radiological Emergency Response Plan.

B.38 Correct the EPIPs The District identifies in its Emergency Pre-

1) RERP:

Section B to identify the paredness Training Program the specific im-

" Organizational Control individuals by plementing procedures which each member per-of Emergencies".

title who have forms. The training manual as well as the

2) RERP: Section M the authority, re-lesson plan for cach member includes the title

" Recovery and Re-Entry sponsibilities, with responsibilities and qualifications to Planning & Post Accident and qualifications function in the emergency position. The District Operations".

necessary to per-believes the identification of emergency personnel

3) E.P. Training Manual:

form the tasks by title with authority responsibilities and Section 2 " Emergency governed by the qualifications is properly provided in both the Organization".

procedures.

RERP and Training Manual. Revising the EPIP's

4) E.P. Training Manual would be repetitious and not enhance the present Section 3 " Recovery program.

Organization".

Page 17 Plan / Procedure Reference Item Description Corrective Action Response B.39 Correct the EPIPs The District has designed its implementing Please refer to the references detailed to allow a single procedures to accomplish the required task In Item B.38 above.

individual to perform in an efficient and expeditious manner.

the procedure Each person who has received training and or separate all steps been assigned to perform that task is equally to be performed qualified to perform it in its entirety. The by an individual Districts method provides cross training of from the steps to personnel and builds a larger manpower resource be performed by to cope with unforeseen emergency circumstances other individuals.

within the planning criteria. The District believes its method of training emergency personnel to perform the complete procedure rather than only a part provides for a stronger and more knowledgable emergency response organization. The District will continue to review and upgrade procedures as a method to maintain effective performance.

B.40 Correct the EPIPs Although the EPIPs do not contain specific check-Not applicable.

Reference is made to provide check-lists, they have been prepared in a performance lists or other methods sequence with a more important action placed to the complete to ensure that all prior to a lesser important action. However, in Emergency Plan necessary procedural many instances more than one action may be in progress Implementing steps are completed simultaneously. The present form of the EPIPs allow Procedures at the proper time.

these corrective actions to be occuring within specific Manual.

time intervals.

This procedural method together with the corresponding training provides a more timely emergency response.

The District believes a firm sign off policy with a set sequence completed before the next action can be performed is not desirable.

The District believes its procedural method patterned after Chemistry and Health Physics procedures is more workable and preferred.

Pege 18 Plan /Procedura Item Description Corrective Action Response Reference B 41. Correct the EPIPs The RERP and the lesson plan for the EDO speci-1)RERP: Section, Part to specifically fically identify those duties and responsibili-2.2.3 "EDO Duties and identify those ties which may not be delegated by the EDO.

Responsibilities" duties and re-These programs have provided the requirement

2) E. P. Training Manual sponsibilities and training to ensure these duties clearly Section 2.1.6(b) "Emer-which nay not be remain with the EDO.

gency Duty Officer delegated by the Training".

EDO.

The District agrees that the delineation of EDO duties and responsibilities which cannot be delegated can be more effectively controlled in an EPIP. This change will be accomplished. The District will also evaluate the removal of this duty list from the RERP or lesson plan in order to avoid repetition.

B.42 Develop and implement Procedures have been developed and implemented to

1) EPIP-OSC-10: Form procedures to provide document emergency radiological survey results.

FC-220 & Table OSC-10.1.

forms for the documen-EPIP-OSC-10, EPIP-EOF-6, EPIP-EOF-15, EPIP-EOF-16,

2) EPIP-OSC-11:

tation of emergency EPIP-EUF-10 and EPIP-RR-6 contain tables to document Table OSC-11.1 radiological survey either survey or dose assessment results. The

3) EPIP-EOF-6:

results.

District believes its new procedure and procedure Form FC-220, change efforts provide adequate forms for recording Table EOF-6.1, 6.2, survey results now.

The District does not believe 6.3, 6.4 more changes are warranted unless identified through

4) EPIP-EOF-15:

training and exercises.

Table EOF-15.1

5) EPIP-EOF-16:

Dose Assessment Worksheet, Table EOF-16.1.

6) EPIP-EOF-18:

Figures E0F-18.1, 18.2 & 18.3.

7) EPIP-RR-6: Table RR-6.1 9

9

Page 19 Plan / Procedure Item Description Corrective Action Response Reference B.43 Provide a controlled As noted by the Appraisal, only two controlled or Not applicable.

copy of the OI-PAPS official copies of all documents are maintained at Controlled copy #44 for use in the RAD-CHEM the station. However, additional numbered copies are of the FCS Operating Office.

maintained up-to-date with all revisions and issue Instructions issued j

changes. Up-to-date copies have been placed and will to this office area.

be maintained in the Chemistry office and the Health l

Physics office. Standing Order G-30 provides the j

administrative procedure aad control for updating the Operating Instructions.

l B.44 Incorporate specified The District has issued a formal management policy and

1) Radiation Protection ALARA measures and con-administrative procedure effective June 1, 1982 to con-Manual, Section 7, siderations into the firm its commitment to ALARA practices. However, the

" Operational ALARA OI-PAPS and CMPs.

District has previously applied ALARA principles in a P rog ram".

lesa formal manner. ALARA measures and considerations

2) Administrative Procedures, 1

in this form were included during the preparation Standing Order G-50 of operating and emergency procedures such as the "ALARA (as low as OI-PAPS and CFTs.

reasonably achievable)

Radiation Expo-sure Program".

The District vill continue to formalize its ALARA pro-

3) OPPD Supervisors gram by specific procedures within the FCS Radiation Manual, Procedure Protection Manual and department instructions.

9.03 " Occupational Radiation Expo-sure ALARA".

B.45 Correct the OI-PAPS and Section 2 of the Chemistry Procedures Manual (CMP-2)

1) Operating Manual CMPs to include pro-providea general philosophy for sampling techniques Volume VI Operating visions for labeling including labeling and storage of samples.

Individual Instructions, Post storage, and disposi-chemistry procedure also contain provisions and pre-Accident Procedures tion of sample.

cautions during the handling of radioactive samples.

OI-PAP-1 thru 9.

2) Operating Manual 1

A review and evaluation will be conducted within the Volume VIII the normal bi-annual review schedule to ensure sufft-Chemietry Manual, cient provision for labeling, storage, and disposition Section CMP-2 " Sample of sample as provided in OI-PAP and CMP procedures.

Collection"; Section CMP-3 " Deter-minations" Procedures 3.1 thru 3.73.

5

Page 20 Plan / Procedure Item Description Corrective Action Response Reference B.46 Provide the shielded 01-PAP-1 has been revised.

Operating Manual - Volume-sample transport ca rt VI, Operating Instructio'ns, for use as stated in Post Accident Procedure OI-PAP-1.

OI-PAP-1 " Post Accident Sampling of Primary Coolant Sample", Revision 2.

B.47 Take measures to assure The counting facility at the permanent EOF is Not applicable.

habitability of an availabic and is presently being upgraded per adequate sample analysis item B.25 above.

facility under severe accident situations.

B.48 Evaluate present Evaluation performed and CMP-2 revised to provide FCS Operating Manual, counting systems for dilution of high activity samples prior to counting Volume VIII, Chemistry high-level sample per item B.20 above.

Manual CMP-2 " Sample counting abilities Collection".

and limitations.

B.49 Develop and implement The General Employee Training program provides the

1) FCS Training Manual methods to adequately description of the on-site assembly area and instruc-Section 2 " General mark assembly areas and tion for the normal route to the area. EPIP-OSC-2 Employee Training" the routes to be taken directs the Shif t Supervisor to make a general announce-Subsection 2.1.2.3 to the assembly areas.

ment along with the sounding of the plant nuclear

" Station Emergency alarm. The implementing procedure also provides for Procedures" and Sub-special instruction if the normal plant exit route section 2.1.5.3 must be altered.

" General Employee The District believes that adequate methods for Training Lesson Plans".

emergency assembly areas and exit routes exist

2) EPIP-OSC-2 " Emergency within the GET and EPIP programs.

Plan Activation".

3) RERP - Section J.1.2 " Protective Response for Onsite Personnel Evacuation".

Page 21 Plan / Procedure Item Description Corrective Action Response Reference B.50 Correct the EPIPs to EPIP-EOF-9 Personnel Accountability was reviewed

1) RERP, Section M 2.2.7 reflect the single and Rev. 1 issued 4/23/82.

Improved accountability

" Security and Technical

• individual that will methods were incorporated into this procedure.

Administ rative receive and account Supervisor".

for personnel immedi-EPIP-EOF-9 has been reviewed again and a single person

2) EPIP-EOF-9 " Personnel ately following the designated for maintaining immediate and continuous Accountability.

incident and maintain accountability theraf ter.

continuous accounta-bility thereafter.

i B.51 Develop and implement In response to the recent INPO evaluation, the District FCS Radiation Pro-specific personnel committed to establishing a program for improving the tection Manual, monitoring and decon-reporting, investigation and tracking of personnel Section 2.0 tamination procedures contamination incidents. The Radiation Protection Personnel Protection in the EPIPs which will Manual will be revised to include the subject program.

and Control is pre-provide for thorough The EPIPs will be revised to reference the appropriate sently being revised.

investigation of any procedures in the RPM.

contamination incident and documentation of the results of any deconta-mination ps.cedure and subsequent bioassay.

B.52 Develop and implement As noted, security actions during emergency conditions

1) RERP, Section J.1.3.1 specific procedures are described in EPIP-OSC-7 and SCP-19.

An additional

" Security" governing the duties, procedure EPIP-EOF-12 Site Security was not referenced

2) EPIP-OSC-7 " Personnel l

authorities, and but has been implemented as the main instruction during Rescue".

responsibilities of radiological emergencies.

3) EPIP-EOF-12 " Site Security Personnel Security" during an emergency.

The District will review existing procedures and issue

4) Security Procedure revisions as necessary to implement specific duties of SCP-19 " Emergency Security personnel, especially upon declaration of a Evacuations".

General Emergency.

i 1

Page 22 Plan / Procedure i

Item Description Corrective Action Response Reference B.53 Develop and implement As noted by the appraisal, speci fic procedures EPIP-

1) RERP: Section D procedures with spe-OSC-1 and EPIP-RR-1 are in effect to categorize emer-Section 6.0, cific criteria upon gencies into one of four classifications based on the

" Action Level Criteria".

which the emergency guidelines of Appendix 1 of NUREG-0654. The licensee

2) RERP: Section M.I.3, class may be down-is respoasible to establish the classifications and

" Relaxation Criteria" graded and provisions consistently provide this information to local, state

3) RERP: Section M.2.1 for notification and Federal response groups. The responsibility of (14) " Recovery Manager of Federal, State and licensee to set the accident classification does not Responsibilities".

local officials prior appear to be limited to increasing accident severity

4) EPIP-OSC-1 "Eme r-to entering a down-only.

gency Classifi-Braded mode of emergency cation".

response operation.

The District believes the present accident procedures

5) EPIP-RR-1 "Acti-with provision to reduce the accident classification vation of Recovery designation are appropriate and intends to maintain Organization".

this method.

B.54 Include the NRC and Figure B-4 depicts the principal interfaces among RERP, Figure B-4 FEMA on the list of onsite organization and offsite response centers.

interfacing organi-As such, the NRC is shown with principal interface i

zations in MRC Section to the licensee TSC and EOF for which space has been B, Figure B-4, of the allocated.

Emergency Response Plan.

L In accordance with the appraisal report request, Figure B-4 has been corrected to show the NRC and FEMA interface in the appropriate MRC section.

e e

-e w

Page 23 Plan / Procedure Item Description Corrective Action Response Reference B.55 Develop and implement During the nine years of reactor operation Fort

1) Administrative formal procedures for Calhoun Station has developed and implemented ade-Procedure S.O. T-13 radiation monitoring quate procedures for controlling calibration, func-

" Quality Control Pro-equipment inventory, tion testing, inventory, repair, etc. for radiation gram for Chemistry including acquiring monitoring equipment as. evidenced by procedures Equipment".

new instruments, retiring S.O. T-13, CP-HP-1 thru 19 and FCP-HP-1 thru 3.

2) Radiation Moni-old or lost instru-toring Instru-ments, and instrument The District believes it has sufficient procedures ment Procedures.

calibration due dates.

and controls for optimum utilization of radiation CP-HP and FCP series.

monitoring equipment for reactor plant operations.

3) Functional Check Procedures FCP-HP-1 thru 3.

4) FCS Radiation Protection Manual, Section 9.0, HP-15 " Portable Dose Instrument Operation".

5) Surveillance Test ST-RM-3

" Emergency Plan Radiation Instru-ments and Equipment".

B.56 Review and evaluate the To the greatest extent practical, implementing Not Applicable.

usability of existing procedures are developed by persons experienced in procedures and instru-the specific instrumentation. The author then tests ments, used during the procedure. The pr<cedure is also tested during emergencies, for human training and drill sessions. Human factors inputs factors engineering are included in resulting revisions. Human factors correction.

engineering is incorporated.into instruments based on initial selection by experienced technicians and

Page 24 Plan / Procedure Item Description Corrective Action Response Reference I

B.56 (Continued) supervisors knowledgable in many areas. The pro-cu reme nt of instruments from leading manufacturers receptive to customer preference is another means of acquiring human factor en3 neering for the District 1

program. As a viable program encompassing training, reviews, drills and critiques, the emergency program reviews continuously human engineering factors or comnents which are evaluated and adopted into the program. The District believes human factor engi-neering is inherently included in the existing RERP and EPIP.

B.57 Review all letters of As evidenced by Appendix A of the RERP, letters of RERP, Appendix A agreement with offsite agreement exist and are reviewed annually. The support organizations District has entered into these agreements in good to ensure that all faith and firmly believes each group will honor its are still acceptable commitments. However, no absolute certainties and will be honored, are possible. Each organization is known to have and ensure that operated reputably in the past and has demonstrated adequate detailed moral obligation to the public.

letters of agreement exist for all organi-As stated in the response to item page B-6 above, zations the licensee the District shall continue the annual review of will depend on for letters of agreement to ensure they are still aid during an acceptable.

emergency.

mmm

Page 25 Plan / Procedure Item Description Corrective Action Response Reference B.58 Ensure that the EALs

1) Emergency action levels (EAL) were discussed with

1) OPPD-RERP: Section and their associated and agreed on by the licensee, state and local 6.0 " Action response actions are governmental authorities as evidenced by the Level Criteria".

discussed with and publication of consistent EAL tables in the OPPD,

2) Nebraska-RERP:

agreed on by the li-Nebraska, Iowa, Washington County and Pottawattamie Section 5 " Radio-censee, State, & local County Emergency Plans, logical Emergency governmental autho-

2) Emergency Preparedness Tests (EPT) have been Classifications" rities and develop and developed and implemented to administer surveillance and Annex A, implement a method to commitments. EPT-9 provides a controlled method for Appendix 1 " Class-review the continued the review and correction of the RERP including the ification acceptability of the EAL on an annual frequency.

EPT-12 provides a System".

EALs and their assoc-controlled method for District and offsite

3) Iowa Emergency Plan, iated response action governmental officials to review emergency prepared-Annex F, Appendix 7, with the State and ness programs and discuss improvements.

Section VI, " Concept local governmental of Operations".

authorities on an The District believes adequate methods exist to main-

4) Washington County Nebr-annual basis.

tain consistent and carrect EAL with state and local aska RERP: Annex A, governmental authorities.,

" Emergency Action Levels for Nuclear Power Facilities".

5) Pottawattamie County Iowa RERP:

Appendix 7 Section VI,

" Concept of Operations"

6) Emergency Preparedness (Surveillance)

Test EPT-9, " Emergency Plan Reviews".

7) Emergency Preparedness (Surveillance)

Test EPT-12, F.1

" Emergency Response Training - Planning Personnel".

e