ML20082D182

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Responds to NRC Re Violations Noted in Insp Rept 50-285/91-08.Corrective actions:EPIP-EOF-11 Will Be Revised & Further Evaluations Into Method to Perform Release Path Analysis & Verification Will Be Conducted
ML20082D182
Person / Time
Site: Fort Calhoun 
Issue date: 07/17/1991
From: Gates W
OMAHA PUBLIC POWER DISTRICT
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LIC-91-189R, NUDOCS 9107230250
Download: ML20082D182 (3)


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' -- %wai Omaha Public Powtr District 444 South 16th Street Mall July 17, 1991 Omaha, Nebraska 68102-2247 Lit-91-189R 402/630 2000 U. S. Nuclear Regulatory Commission Attn: Documant Control Desk Mail Station Pl 137 Washington, DC 20555

References:

1.

Docket No. 50 285 2.

Letter from NRC (S. J. Collins) to Omaha Public Power District (W. G. Gates) dated June 14, 1991 (NRC Inspection Report No. 50-285/91-08)

Gentlemen:

SUBJECT:

Responses to Weaknesses identified During 1991 Annual Emergency Exercise In Reference 2, Omaha Public Power District was requested to provide to the NRC responses to the subject exercise weaknesses.

The attached responses include causes, corrective measures, and schedules for completing these measures.

Please contact me if you should have any questions.

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Sincerely, n.3 %

W. G. Gates Division Manager Nuclear Operations

'3G/sel Attachment c:

LeBoeuf, Lamb, Leiby & MacRae R. D. Martin, NRC Regional Administrator, Region IV W. C. Walker, NRC Project Manager R. P. Mullikin, NRC Senior Resident inspector 9107230.150 910717

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o' RESPONSES TO ANi1UAL [MERGEl4CY EXERCISE WEAKl4 ESSES e

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'failura to exerr'se proper radiological controls in the OSC was identified as an exercise weab ess."

Emplu Omaha Pubite Power District (OPPD) conducted an investigation of thc Radiation Protection (RP) functions performed in the Operations Support CentJr (0SC) and the Technical Support Center (TSC) to determine why the labitability criteria in EPIP-E0f ll

" Dosimetry Records. Exposure Extensions and Habitability",

section 5.4 were not met.

1.

It was determined that the OSC Radiation Protection (RP) Coordinator made a conscious decision to perform only radiation level surveys during the time frame indicated due to the following reasons:

a.

The RP Coordinator and the TSC Protective Measures Coordinator discussed the release pathway in conjunction with the degrading slant conditions.

Based on the information known to both parties at titt time, it was presumed that the noticed increase in radiation levels was due to plume shine as OSC radiation levels were constant regardless of location or sampling height.

b.

The scenario driven loss of normal power in the OSC location caused a loss of lighting and power for counting instrumentation.

c.

Increasing background radiation levels throughout the majority of the station site made counting instruments unusable.

The Protective Measures Coordinator's log indicates that at 1228 hours0.0142 days <br />0.341 hours <br />0.00203 weeks <br />4.67254e-4 months <br />, it was decided to set up an alternate counting location in the TSC; however, access to the TSC was being limited to prevent further contamination of the TSC envelope, making transport of any sampics to the alternate counting location impossible.

Investigation concluded that the decision to suspend air sampling was in error. Air samples should have been continued and saved for later analysis, as needed. Contamination surveys, however, could not be analyzed assuming the background levels presented via the scenario; therefore, that decision was justifiable but not necessarily appropriate.

2.

An OSC RP Technician performed a whole body count after the dose rates had dropped down, but just prior to the discovery of the elevated contamination levels. Once this was discovered, the RP Technician determined that due to the room shielding, the geometry of the counting device and floor level contamination, the count results would not be affected greatly.

3.

OPPD has not identified any exercise participants without dosimetry, however, there were several non players who momentarily were ir, the OSC area until told to stay clear of the exercise.

The OSC logs indicate that dosimetry was issued to OSC participants.

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OPPD will revise EPIP E0f ll,

  • Dosimetry Records, Exposure Extensions and Habitability," to include better guidance on when, and how often, habitability surveys are needed under various radiological conditions.

The revision will also include guidance on alternate sampling locations.

This action will be completed by October 31, 1991.

2.

Further evaluation of the accuracy and availability of the whole body counter at various background 1cvels will be completed and subsequent instructions on its use under emergency conditions will be included in EPIP L0f ll and/or other appropriate operating instructions.

This action will be completed by October 31. 1991.

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'1he use of maps containing obsolete infonnation to describe a field team's location is considered an exercise weakness."

kn0M OPPD conducted an investigation of obsolete maps within the field monitoring vehicles which revealed that both field monitoring vehicles contaiwd the new, updated i.iaps.

However, one vehicle also had a copy of an old 10 mile EFZ map.

Route instructions in both vehicles were found to contain some discrepancies, it should be noNd that the OPPD field team was at the appropriate sampling location, reg edless of the map having incorrect siren numbers.

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The Emergency Flanning Department performed an inventory of both field monitoring vehicles and removed one outdated, incorrect map.

2.

Route instruction books have been produced containing new, updated color maps (including the correct stren numbers) and corrected route instructions; these books were placed in each field monitoring vehicle.

Enkaus 285/910itQ1 "The failure to accurately detect, assess, and correlate plant conditions with radiological releases and dose assessment functions was identified as an exercise weakness."

BMLQai 0 PPD coridr-ted an investigation concerning this weakness.

It was determined that the dise assessment function needs additional support in release path analysis and verification.

Some initial concepts include a flow chart style of procedure to assist in determining potent.al release paths and correlating respective )lant parameters (conditions}.

This would allow someone to verify a release pati and assist the dose assessment function.

Corrective A tignLand_ Schedule t

OPPD will conduct further evaluations into the most appropriate method to perform release path analysis and verification, and determine which ERO position should perform this task.

Results of this determination will be incorporated into appropriare emergency procedures by October 31, 1991.

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