ML20135H719
| ML20135H719 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 09/08/1985 |
| From: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| To: | Hunter D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| LIC-85-397, NUDOCS 8509240158 | |
| Download: ML20135H719 (6) | |
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Omaha Public Power District 1623 Harney Omaha. Nebraska 68102 2247 s
402/536 4000 Septenber 8,1985 ggg{r "g
L 1C-85-397 i;
)f SEP 161985 c__-_.
'l Mr. Dorwin R. Hunter, Chief
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J Reactor Project Branch #2
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U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011
References:
(1)
Docket No. 50-285 (2)
Letter NRC (D. R. Hunter) to OPPD (R. L. Andrews) dated June 6, 1985 (3)
Letter OPPD (R. L. Andrews) to NRC (D. R. Hunter) dated July 9,1985 (LIC-85-275)
Dear Mr. Hunter:
Fort Calhoun Station Emergency Plan In Reference (3) the Omaha Public Power District stated that the infonnation requested by Reference (2) would be provided by September 8,1985. Pursuant to that conmitment, please find attached the requested infonnation.
Si r
y, d Rhl'Y R. L. Andrews Division Manager Nuclear ProdJction 1
RLA/TPM/rh Attachment cc:
LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.
Washington, D.C.
20036 Mr. E. G. Tourigny, NRC Project Manager
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Mr. L. A. Yandell, NRC Senior Resident Inspector l
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Responses to NRC Request Letter Dated June 6,1985 Request 1 In Paragraph M.1.1.2 it is not clear where the Recovery Manager, Emergency Coor-dinator, and the EOF Information Specialist with their support groups will re-po rt.
Response
For all emergency classifications, the Recovery Manager, Emergency Coordinator and the E0F Infomation Specialist report to the Emergency Operations Facility during ongoing emergencies.
Request 2 The Plan does not define the operational meaning of " activating" an Emergency Response Facility (ERF).
Response
OPPD's program is that whenever a designated emergency person reports to the assigned emergency work area, such action automatically causes partial activa-tion of that facility. Full activation of a particular facility is required at a predesignated emergency classification and completed when all emergency post-tions needed to perfonn that facility's functions are manned and when announced by the facility manager.
Request 3 Table B-1 shows the Shift Technical Advisor (STA) as a primary organizational element for Emergency Direction and Control. This appears to be contrary to
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the intent of the rest of Section B describing your emergency organization.
Response
4 The iten referenced in Table B-1 was extracted directly from NUREG-0654, Rev.
1.
Our interpretation of this individual's responsibilities are.to respond to the Control Room and to obtain details of the full emergency situation and make mitigating and corrective action recommendations to the Shif t Supervisor. The OPPD emergency plan utilizes the Shift Technical Advisor in a technical support role and does not utilize this person for providing the emergency direction.
I Request 4 The structure of the initial phase of your emergency organization is not de-scribed by a block diagram in accordance with NUREG-0654, Criterion B (6).
Response
Figure M-1 describes the ' structure of the initial phase of the emergency organ-ization under the resonsibility of the Site Director.
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Request 5 Section P does not clearly indicate whether the Corporate Emergency Planner is the Manager, Radiological Health and Emergency Planning.
Response
Tne Manager, Radiological Health and Emergency Planning is the person identi-fied as the Corporate Planner. This identification will be better described in the next review and revision of Section P.
Request 6 Section B does not clearly describe the transitional phases of the Emergency Organization, as it is transformed fran the initial shift organization to the full onsite organization, and finally to include the extended corporate support group. For example, Paragraph 2.2.2, states that the Emergency Recovery Organ-ization makes the Recovery Manager available to replace the Shift Supervisor, apparently bypassing the Emergency Duty Officer (EDO). Thus, the transmittal of emergency direction and control functions from the Shift Supervisor to the Emergency Duty Officer and up to the Recovery Manager does not appear to be clearly explained.
Response
Section B was revised on June 20, 1985 to describe the present Emergency Re-sponse Organization and at that time all references to the EDO were deleted.
Paragraph 2.2.1 now states the Site Director has initial responsibility for the Initial Response Organization (IRO). This position is initially filled by the Shif t Supervisor until a designated Site Director reports and transfer of re-sponsibility is accomplished in accordance with procedure EPIP-E0F-13 Shift Supervisor to Site Director Transition. Once the Site Director assumes respons-ibility from the Shift Supervisor he will remain in that capacity until he is relieved by another Site Director or the Recovery Manager. Paragraph 2.2.2 de-scribes the transfer to the Recovery Hanager which is automatic at the Site Area Emergency or General Emergency. The Site Director position will be tennin-ated when the plant is returned to a normal status. As defined in Paragraph 2.2.2, transition of authority from the Site Director to Recovery Manager is carried out in accordance with procedure EPIP-E0F-14 Site Director to Recovery Manager Transition.
Request 7 The plan does not describe the emergency organization role of the Manager -
Fort Calhoun Station, who is not shown as qualified to be an EDO in Figure B-1.
Response
This item was corrected daring revision number 5 to Section B which was issued on June 20, 1985. Paragraph 2.2.1 now states "The Site Director will be the plant manager or his designated alternate in the Fort Calhoun Station Quarterly Assignment Letter."
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Request 8 Explain the apparent contradiction between Paragraph E.1.1 and Figure F-1, per-taining to notification of the Iowa Office of Disaster Services by the Shift Supervi sor and the Administrative Logi stic Manager, respectively.
Response
Initial notification to the Iowa Office of Disaster Services is accanplished in accordance with EPIP-0SC-2 by the plant operations staff for Notification of Un-usual Event classification. For the higher classifications, the Nebraska High-way Patrol is notified, who in turn notifies the Iowa Office of Disaster-Ser-Vices. The Administrative Logistics Manager is no longer required to make these notifications. Figure F-1 will be revised during the annual review and revision to reflect this change.
Request 9 In reference to Paragraph E.1.1, explain the back up means of conmunications that would be available if all offsite means of communications failed.
Response
OPPD believes that the energency preparedness conmunication system precludes failure of all offsite means of communication. The following primary and back up communication systems are available:
a.
The primary means of communciation to the State and county agencies is through the Conference Operations Network (COP) which goes through a network of microwave systems which have alternate backup routes available.
b.
The conmercial telephone systems provide an alternate means of communications.
c.
Facsimile machines which are also on a microwave system is another alternate means.
d.
A third alternate method is the NAWAS from Fort Calhoun Station to Nebraska Highway Patrol who has a teletype network for relaying information to Nebraska and Iowa agencies, e.
Another means of communication is the VHF/VHF radio. These units located at the EOF provide conmunications capabilities with the Nebraska State Civil Defense and Highway Patrol.
Request 10 Explain the rationale in Appendix 3 of EPIP-OSC-2, for not making positive action recommendations.
Response
The words "may be necessary" are apparently being interpreted as not being post-tive protective action recommendations. The rationale for use of these words is that the reconmended protective actions are identified by emergency classiff-cations and automatic actions are identified positively while actions requiring additional assessment are identified as "nny be necessary" actions.
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Request 11 Indicate where you identify the energency organizational members making notifi-cations to offsite agencies as required by NUREG-0654, Criterion F(1).
Response
Table B-1 designates initial notification responsibilities to the operating shift. EPIP-0SC-15 Control Room Communicator is the procedure that identifies the responsibility and method for initial contact with state and county agen-cies. EPIP-OSC-14, Appendix 1 Shift Supervisor / Site Director Checklist pro-vides instructions for the Shift Supervisor to ensure these notifications are made. The procedures, along with EPIP-OSC-2 Emergency Plan Activation are presently under review and revision based on activities of the 1985 Emergency Exerci se.
Reouest 12 4
Explain, in reference to Figure F-2, what is meant by Radiological Conference Capabili ty.
Response
OPPD has a dedicated conference capability Conference Health Physics (CHP) Net-work which allows for discussions relating to radiological and Health Physics matters between Nebraska and Iowa state EOCs and Forward Operating Locations.
Explanation and operation of this system is explained in Figure F-4 (Emergency Conference Health Physics - CHP Nebdork), EPIP-EGF-2 (Emergency Operations Fa-l cility Communciation) and EPIP-TSC-2 (Technical Support Center Communication).
Request 13 Indicate the location of _the Technical Support Center (TSC) and whether it is in the same elevation as the Control Room.
Response
Figure H-1 shows the physical location of the TSC in relationship to the con-trol room and main plant area. These facilities are not at the-same elevation.
The TSC is on ground level (elevation 1004') and the control room is on the third floor (elevation 1056').
Request 14 Indicate how you meet guidance Criterion F(1) of NUREG-0654 which. requires a full description of emergency communication links among ERFs.
Response
Section F.2 and Figure F-2 OPPD/ STATE / LOCAL Communications Int'erface of the RERP provide guidance and a block diagram of the main communication systems available and how these systems are interconnected. As mentioned in Item No.
12, above, a full description on each of the various systems can be found in EPIP-EOF-2 and EPIP-TSC-2.
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Request 15 In Paragraph M.1.3, the phrase " relaxation criteria" is used in connection with the decision to curtail the duties of the Emergency Recovery Organization. Ex-plain the relationships between relaxation criteria and short and long tenn re-covery phases.
Indicate whether the NRC will be consulted before entering a long tenn recovery phase, that is, af ter the reactor is in cold shutdown and no emissions of radioactivity are ensuing.
Response
As referred to in Paragraph M.1.3, relaxation / curtailment guidance is provided to relax and/or curtail any emergency and/or recovery actions. The concurrence of the Recovery Manager, Site Director and Emergency Coordinator is required for this decision. This ' paragraph is not intended to explain the difference be-tween short and long term recovery phases.
Procedure EPIP-EOF-19 Downgrading and Termination of the Emergency Classification provides the instruction for downgrading and terminating all emergencies.
This procedure also describes the difference between response and long tenn recovery. A new procedure EPIP-EOF-20 is planned for implementation that will provide more specific guidance on short and long term recovery actions.
Relaxation criteria may be as simple as terminating one or more activities of the Emergency Recovery Organization that are no longer required or, possibly downgrading the existing emergency classification. Part of the initial recov-ery effort is to first develop a recovery plan.
It.is anticipated that input will be received from the NRC as well as other' Federal, State and local agen-cies during the development and implementation of the recovery plan. Procedure EPIP-RR-4 Re-entry and Recovery, Onsite NRC Coordination provides basic guide-lines for coordination of activities with the onsite NRC team.
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