ML20140C762

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Insp Rept 50-285/97-02 on 970505-09.Violations Noted.Major Areas Inspected:Licensees Emergency Preparedness Program. Emphasis Placed on Changes That Occurred Since Last Routine Emergency Prepardness Insp
ML20140C762
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 06/03/1997
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20140C727 List:
References
50-285-97-02, 50-285-97-2, NUDOCS 9706100062
Download: ML20140C762 (16)


See also: IR 05000285/1997002

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ENCLOSURE 2

i U.S. NUCLEAR REGULATORY COMMISSION f

REGION IV

Docket No.: 50 285

.i . License No.: DPR-40

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' Report No.: 50-285/97-02 .

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Licensee: Omaha Public Power District

Facility: Fort Calhoun Station

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Location: Fort Calhoun Station FC-2-4 Adm.

, P.O. Box 399, Hwy. 75 - North of Fort Calhoun

i Fort Calhoun, Nebraska

Dates: May 5-9,1997

Inspectors: Thomas H. Andrews Jr., Radiation Specialist ,

l Plant Support Branch l

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Ryan E. Lantz, License Examiner i

Operator Licensing Branch- ')

Approved By: Blaine Murray, Cithf, Plant Support Branch

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Division of fieactor Safety

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ATTACHMENT: Supplemental Information . I

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9706100062 970603 [*N l

PDR- ADOCK 05000285 1

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EXECUTIVE SUMMARY

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Fort Calhoun Station

NRC Inspection Report 50-285/97-02

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This routine, announced inspection focused on the operational status of the licensee's '

emergency preparedness program. Emphasis was placed on changes that had occurred

since the last routine emergency preparedness inspection. I

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Plant Support

  • Emergency events were correctly classified. A noncited violation was identified

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related to a late notification made to the State of Iowa regarding declaration of an l

emergency (Section P1). l

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Emergency response facilities, equipment, instrumentation, and supplies were

l maintained in an operational state. A violation was identified related to self-

! contained breathing apparatus corrective lens inserts for licensed operators. Areas

for improvement were identified related to training associated with emergency

l response equipment, and inspecting and maintenance of equipment stored in

l emergency lockers (Section P2).

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l * Emergency plan and implementing procedure changes were submitted to NRC

l within 30 days after changes were made (Section P3).

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  • Overall, the performance of the crews was satisfactory. Communications were

effective with several exceptions noted for one crew. The marginal

communications of one crew presented a challenge to the shift supervisor to make

l correct and timely event classifications (Section P4).

  • Emergency response organization training records were properly maintained

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(Section PS).

  • The emergency planning and emergency response organization staffing was

l sufficient. Offsite support agency letters of agreement were properly maintained

(Section P6).

(Section P7).

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Reoort Details

IV. Plant SuppoE

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P1 Conduct of Emergency Preparedness Activities

a. Inspection Scope (93702)

The inspectors reviewed event notifications made since December 21,1995, to ,

determine if events were properly classified. The following declared emergency )

events were reviewed to evaluate whether the emergency plan was properly l

implemented:

declared due to entry into Emergency Operating Procedure 05, " Emergency

Shutdown."

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declared due to the personnel hazard associated with a main steam leak in I

the basement of the turbine room under the turbine. j

due to a major steam line break in the turbine building.  ;

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due to increased staff awareness due to a component cooling water leak. ]

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b. Observations and Findinas '

After reviewing the event notifications made to the NRC operations center, the

inspectors concluded that all of the events were correctly classified.

During review of licensee documents related to the notification of unusual event I

that was declared on December 31,1996, the inspectors discovered that the j

licensee experienced communication problems notifying the state and local i

authorities during the initial notification. The control room communicator attempted j

to make the required notifications to the state and local government agencies

approximately 14 minutes after the event declaration. However, the conference

operations network phone that was used as the primary method of notification was

" dead." The communicator initiated the notifications using the backup method of

contacting each agency via the commercial phone system. During the call to the

first offsite agency, the communicator noticed that the phone line was disconnected

from the conference operations network phone. The communicator plugged the

phone line into the phone and completed the notifications using the conference

operations network phone.

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10 CFR Part 50, Appendix E, Section IV.D.3, states, in part, " . . . a licensee shall

have the capability to notify responsible State and local governmental agencies

within 15 minutes after declaring an emergency." As a result of the phone problem,

I the notification to the State of Iowa occurred 17 minutes after the event

declaration.

The licensee initiated an investigation and conducted additional training for

communicators to ensure that the phone was connected when attempting to make

emergency notifications. The inspectors noted that there were no other instances

of late notifications aad determined that the licensee's corrective actions were

appropriate. The late notification was a violation of 10 CFR Part 50, Appendix E.

The violation was licensee identified, nonrepetitive, corrected within a reasonable

time, and nonwillful. Accordingly, the violation is being treated as a noncited,

violation consistent with Section Vll.B.1 of the NRC Enforcement Policy

(50-285/9702-01).

c. Conclusions

Emergency events were correctly classified. A noncited violation was identified

related to a late notification made to the State of Iowa regarding declaration of an

emergency.

P2 Status of Emergency Preparedness Facilities, Equipment, and Resources

a. Inspection Scope (82701)

The inspectors reviewed the status of emergency response facilities, equipment,

instrumentation, and supplies to ensure that they were maintained in a state of

operational readiness. The inspectors toured the following facilities:

  • Control room
  • Alternate shutdown panel
  • Operational support center

b. Observations and Findinas

The inspectors observed that, with the exception of the operational support center,

all emergency response f acilities were dedicated, sole-use facilities. Telephones in

each facility were tested and found operable. The inspectors also verified that

monthly communications tests were conducted in accordance with emergency plan

and procedure requirements. The inspectors concluded that the emergency facilities

were maintained in a proper state of operational readiness.

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On May 6,1997, during the tour of the control room, the inspectors observed the

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analysis report. The licensee had a sufficient number of these devices available.

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The licensee pointed out that only medium sized face-pieces were stored in the kits. (

'Small and large face pieces were availableLto operators in a storage locker in the

same area where the self-contained breathing apparatus were stored. {

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The inspectors observed that there were two personnel on duty in the control room j

l- who wore corrective lenses. The licenses for these individuals was reviewed and it l

was determined that they required corrective lenses as a condition of their licenses, j

l When questioned, these two individuals stated that they did not own corrective lens  !

inserts for the self-contained breathing apparatus. The inspectors later returned to  !

the. control . room to observe a second crew and found four of the personnel on duty _ l

that also did not own the corrective lens insert. After the initial discover /, the

inspectors notified licensee management.

The licensee began an investigation and began expediting the procurement of  !

corrective lens inserts for licensed operators who required corrective lenses as a

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condition of their license. On Friday, May 9, the licensee took additional j

compensatory measures to ensure that each shift crew had one licensed senior '

operator on-shift who either did not require corrective lenses or who had a  ;

corrective lens insert. .This was considered a temporary measure to address

concerns regarding the ability to safely operate the facility during a toxic gas event.  :

.The licensee was continuing their evaluation to determine if additional immediate i

actions were needed. The licensee estimated that they would have a sufficient

- number of licensed operators with corrective lens inserts available to staff full shift l

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compliments within 1 week.

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10 CFR Part 50, Appendix B, Criterion V, states, in part, that " . . . activities

affecting quality shall be prescribed by documented instructions, procedures, or

drawings, of a type appropriate to the circumstances . . . Instructions, procedures,. ,

or drawings shall include appropriate quantitative or qualitative acceptance criteria '

for determining that important activities have been satisfactorily accomplished."

On May 6,1997, the NRC inspectors discovered that there were no instructions or I

procedures to ensure that alllicensed operators, who were required to wear

corrective lenses as a condition of their individual licenses, had corrective lenses of

the appropriate type available should these individuals be required to wear self-  ;

contained breathing apparatus while performing licensed duties. The failure to

establish procedures regarding the wearing of corrective lenses when using self-

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contained breathing apparatus is a violation of 10 CFR Part 50, Appendix B,

Criterion V (50-285/9702-02).

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The licensee informed the inspectors that the locker containing the small and large

face pieces was a recent addition to the control room. The inspectors queried on

shif t operators regarding the location of small and large f ace-pieces for the self-

contained breathing apparatus. Operators who were qualified to wear large or small

face pieces were not able to locate these face pieces. The inspectors informed

licensee management of this observation.

The licensee provided documentation showing that a training notice had been issued

that was to be discussed with all operating crews. In the observed instance, the

shift supervisor had not briefed the crew on the recent addition of the locker

containing small and large face pieces due to priorities associated with the ongoing

outage. However, the . licensee added a shift tumover note that discussed this

change. The inspectors noted that all operators questioned on later shifts were

cognizant of the location of small and large f ace pieces. The inspectors identified

the process for informing operations personnel of changes related to emergency

equipment as an area for improvement.

During review of equipment stored in emergency lockers in the operations support

center and control room, the inspectors observed that lockers contained air sampler

cartridge heads that were missing o-rings. Seven of the ten air sampier cartridge

heads located in the operations support center and both air sampler cartridge heads

located in the control room were identified in this condition. The inspectors noted

that this could create a poor seal and affect sample volume. The licensee

immediately replaced all of the air sampler cartridge heads located in the emergency

response facilities and in emergency lockers. The inspectors verified that selected

air sampler cartridge heads that had been placed in the lockers had good o-rings.

The inspectors observed charcoal filter cartridges stored in the operations support

center lockers. Some were in sealed bags from the manufacturer. Others were

loose, exposed to the atmosphere, and stored in the same location. The inspectors

could not determine if these cartridges had been used or if they had been exposed

to agents that would adversely impact the adsorption properties of the charcoalin

the filter cartridges. This was discussed with the licensee. The licensee

subsequently discarded the filters that were not in sealed bags.

Based upon the observation of the air sampler cartridge heads and the charcoal filter

cartridges, the inspectors expressed concern about the " operational readiness" of

equipment stored in emergency lockers. The licensee stated that emergency

response personnel were expected to inspect the equipment prior to use, but agreed

that the existing conditions did not meet management expectations. Condition

reports were generated by the licensee to investigate root cause and to identify

additional corrective actions. The process of inspecting and maintaining equipment

stored in emergency response lockers was identified as an area for improvement.

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c. Conclusions {

Emergency response facilities, equipment, instrumentation, and supplies were

maintained in an operational state. A violation was identified related to self.  ;

contained breathing apparatus corrective lens inserts for licensed operators. Areas i

for improvement were identified related to training associated with emergency i

response equipment, and inspecting and maintenance of equipment stored in [

l emergency lockers. l

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-P3 Emergency Preparedness Procedures and Documentation f

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a. insoection Scoce (82701) j

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The inspectors reviewed emergency plan and implementing procedures. The  !

l inspectors reviewed licensee records to verify that emergency plan and  ;

implementing procedure changes were submitted to NRC within 30 days after '

changes were made.  !

b. Observations and Findinos

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The inspectors reviewed copies of transtnittal records for emergency plan and ,

l procedure changes. Changes were provided to the NRC within 30 days of  ;

j ' implementation. .The licensee determined that none of the changes reduced the i

effectiveness of the emergency plan. The inspectors concluded that the process for i

submitting emergency plan and implementing procedure changes was properly l

implemented.

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c. Conclu. signs 1

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Emergency plan and implementing procedure changes were submitted to NRC

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P4 - Staff Knowledge and Performance in Emergency Preparedness

a. Ipsoection Scope (82701)

The inspectors conducted walkthroughs with two crews (one operating crew and

one staff crew) using a dynarnic simulation on plant-specific control room

simulators. During the walkthroughs, the licensee was evaluated on the ability to:

  • Evaluate plant conditions
  • Identify ' respective err'ergency action levels

i * Evaluate or, where appropriate, perform dose calculations

  • Classify the emergency using the latest procedures

l * Recommend appropriate protective actions

  • Make timely notifications to offsite agencies

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The scenarios consisted of a sequence of events requiring escalation of emergency i

classifications, culminating in a general emergency. Each walkthrough laste:I  !

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, approximately 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.  ;

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b. Observations and Findinas I

i- The following scenario time line was used to evaluate the two crews: i

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00:00 Initial conditions - plant is operating at 100 percent rated thermal l

power in middle of core life. l

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00:05 An earthquake occurs, producing a " strong motion" seismic alarm and I

a 100 gallon per minute reactor coolant system leak. An alert is l

expected to be declared due to reactor coolant system leakage greater i

than 40 gallons per minute (Emergency Action Level 1.4) or due to an )

earthquake causing damage to vital area (Emergency Action Level  !

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00:25 An aftershock causes the reactor coolant system leak to increase to l

500 - 600 gallons per minute and forces containment purge valves to I

partially open. A site area emergency is expected to be declared l

based on a failure / challenge to two fission product barriers -l

(Emergency Action Level 1.13). l

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00:55 A large break loss of coolant accident occurs. A general emergency

is expected to be declared due to imminent core uncovery with

containment failure or challenge (Emergency Action Level 1.16) or

failure / challenge to three fission product barriers (Emergency Action

Level 1.17).

Overall, shift crew performance during the simulator walkthroughs was good.

Emergency classifications and offsite agency notifications were correct and timely, j

with one exception. There was one instance where the incorrect emergency action

level was used, but the conect classification and declaration was made.

The first crew executed proper use of three-leg communications. Three-leg

! communications involve the first' individual stating a condition or giving a direction,

l the second individual repeating the statement or request, followed by confirmation

by the first individual. The same crew also conducted frequent and effective crew

briefings to ensure the entire crew was aware of current plant conditions and shift

priorities to mitigate the simulated plant events in progress.

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The second crew displayed marginal communication practices and several instances

of ineffective crew oversight by the lead senior operator. Three-leg communication

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was not routinely used, with several examples noted where the control board

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operators did not complete tasks as assigned and the lead senior operator did not j

followup to ensure completion of the tasks. i

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i One example occurred when the lead senior operator used the emergency procedure  !

! for response to a excessive reactor coolant leakage and requested a leak rate from  !

the board operators. The request was not given as a firm direction to determine j

L and report a leak rate, but was presented in more of an open ended question. The j

i board operators heard the question, as determined by post-scenario questioning, but  ;

did not take action and never determined a leak rate. The lead senior operator did  !

not followup to ensure a leak rate was determined. Also, the inspectors observed '

} several instances where the lead senior operator was not responsive to reports

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! Only one crew brief was held. The crew brief was initiated and conducted by the

l shift supervisor. The brief was not comprehensive and did not solicit a response

from the board operators, but was used more as a status report from the shift

supervisor to the crew.

The licensee acknowledged the poor communication practices of the second crew

and stated that they had observed some prior concerns with this crew. Based on

'the observations during this inspection, the licensee removed the lead senior

operator from the crew, and initiated a remedial training evaluation to identify

additional training needs for the lead senior operator.

l The second crew shift supervisor was aggressive, and frequently questioned and

l conferred with the lead senior operator to obtain information to make the

l emergency classifications. The shift supervisor made the site area emergency

classification based on greater than 40 gallons per minute reactor coolant leak to

the steam generator and stack area radiation monitors in alarm. At that point in the ,

scenario, there was no steam generator tube leakage, which, therefore, did not 1

meet the conditions of the emergency action level. The inspectors and the licensee

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! training staff had expected an emergency action level declaration based on a

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l' challenge to the containment barrier, which also resulted in a site area emergency. l

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j Post scenario questioning confirmed that the shift supervisor was aware that he did

not meet the emergency action level conditions in that there was no primary to

secondary leakage, however, the shift supervisor stated that with an actual release

j in progress from the stack and loss of primary inventory to the auxiliary building, he j

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knew a site area emergency was appropriate. The shift supervisor stated that he

did not have adequate information to meet the challenge to containment criteria.

The inspectors noted that had a leak rate been determined and reported, which at  ;

the time was over 400 gallons per minute, the shift supervisor may have been more

willing to make the challenge to containment determination.

Neither crew diagnosed the source of radioactivity in the auxiliary building as the j

partially stuck open containment purge valves. This information was available in

the control room simulator and would have supported the containment challenge I

determination. '

During the simulator walkthroughs, the inspectors observed both shift supervisors l

announce, following indications of a leak from containment, that no eating, drinking,

or chewing was permitted until habitability of the control room had been confirmed. i

in the case of the first crew, there were individuals who were performing dose

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assessment in the shift supervisor's office and out-of-hearing range of the shift

supervisor in the case of the second crew, the inspectors observed that the

radiation protection technician who was requested to perform the habitability survey

was chewing gum throughout the scenario. The inspectors noted that there was no

mechanism provided to ensure that the directions of the shift supervisor would be

provided to all personnel in the control room and that those subsequently entering i

the control room were informed of those directions. This was identified as an area  !

for improvement,

c. Conclusions ,

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Overall, the performance of the crews was satisfactory. Communications were

generally effective with several exceptions noted for one crew. The marginal

communications of one crew presented a challenge to the shift supervisor to make

correct and timely event classifications.

P5 Staff Training and Qualification in Emergency Preparedness  ;

a. Insoection Scope (82701)

The inspectors reviewed training records for selected individuals to ensure that

training requirements were satisfied,

b. Observations and Findinas

There were few changes to the emergency response organization since the last

inspection. There were no significant changes to responsibilities of assigned

positions.

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The inspectors determined that the licensee maintained sufficient emergency

response organization training records. The process provided a good method to

ensure that personnel were qualified to perform assigned response functions and to

ensure that retraining was completed in a timely manner,

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c. Conclusions

Sufficient emergency response organization training records were maintained.

P6 Emergency Preparedness Organization and Administration

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a. Inspection Scoce (82701)

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  • Emergency planning organization staffing j
  • Emergency response organization staffing '
  • Changes in offsite support organization agreements j

b. Observations and Findinas l

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The emergency planning section consisted of four senior emergency planning

representatives and two emergency planning representatives. The six individuals

reported to the emergency planning manager. The inspectors reviewed task

assignments for the section and determined that staffing levels were sufficient. '

According to the licensee three emergency response teams were maintained and

l rotated on a weekly basis. During review of the emergency response organization

! roster, the inspectors noted that there were positions that only had two individuals

! identified as qualified for ti.e position. The licensee stated that in the event of

activation of the emergency response organization, all personnel were expected to

respond. This would ensure that all positions would be filled.

The licensee further stated, that in the case where there were two instead of three

qualified individuals identified, the individuals were aware of the limitations on travel

outside of the area, vacation time, etc. The inspectors queried a sample of

personnel in these positions and confirmed that they were aware of the limitations

, imposed upon them. As a result, the inspectors determined that the emergency

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response organization was not impacted by having less than the full compliment of

three qualified individuals for these positions.

The inspectors reviewed the licensee's process for maintaining current letters of

agreement with offsite support organizations. The licensee had established a

process of reviewing the agreements each year.

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The emergency planning and emergency response organization staffing was  !

sufficient. Offsite support agency letters of agreement were reviewed as required.

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-P7 . Quality Assurance in Emergency Preparedness Activities  ;

a. Insoection Scoce (82701)

The inspectors examined the latest audit and surveillance reports for the emergency l

preparedness program to determine compliance with NRC requirements and licensee l

commitments.  ;

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b. Observations and Findinas )

The inspectors reviewed the program audit and determined that the audit met the  !

10 CFR 50.54(t) audit scope requirements. The audit involved review of  ;

documentation and interviews with state and local authorities. The licensee

provided documentation to demonstrate that offsite agencies were provided with

the information related to the assessment of interfaces with offsite agencies.

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The inspectors interviewed the audit team leader to determine individual

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qualifications. The lead auditor had several years experience conducting emergency

planning audits, and had at one time worked in the emergency planning section. l

The inspectors concluded that the audit was conducted by personnel who had

, satisfactory knowledge of emergency preparedness regulations and programs. )

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c. Conclusions

l Effective audits were performed by personnel with satisfactory expertise.

P8 Miscellaneous Emergency Preparedness issues

P8.1 (Closed) Inspection Followuo item 50-285/9523-01: Exercise Weakness - Failure to

Notify State / County Aaencies Within 15 Minutes of Alert

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. During simulator walkthroughs conducted in December 1995, one crew f ailed to I

make ernergency notification of an alert declaration to State and County agencies

within 15 minutes as required by procedures. The licensee determined that the

t; cause of the weakness was attributed to the procedure used. The scenario was a

' fast-progression scenario and the shift supervisor had not completed the notification

process of the alert declaration when a site area emergency was declared. The ,

licensee revised their procedures to ensure that even when the classification has '

been escalated, the notification of the earlier emergency declaration will be

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The inspectors noted that the cause of this weakness was not rolated to the same

l cause as the noncited violation discussed in Section P1 of this report.

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Based upon review of the procedures and discussions with shift supervisors, as well

l as the performance of the control room crews discussed in Section P4 of this  !

report, the inspectors determined that the licensee had demonstrated resolution of

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( .this weakness. Therefore, this weakness was closed. 1

P8.2 . (Discussed) Inspection Followuo item 50 285/9515-01: Exercise Weakness - 1

l, Failure to Have an individual Properly Trained and Caoable of Performina Core l

Uncovery Predictions

The inspectors discussed this weakness with the licensee. Because there was no

opportunity for the licensee to demonstrate successful resolution of this weakness,

l closure of the weakness was deferred to a future inspection.

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P8.3 (Discussed) Insoection Followuo item 50-285/9515-02: Exercise Weakness - The

Dearee of Simulation Precluded Evaluation of Individual's Knowledae of Duties

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The inspectors discussed this weakness with the licensee. Because there was no

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opportunity for the licensee to demonstrate successful resolution of this weakness, j

closure of the weakness was deferred to a future inspection. -

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V. Manaaement Meetinas

X1 Exit Meeting Summary

The inspectors presented the inspection results to members of licensee management- '

at the co'nclusion of the inspection on May 9,1997. The licensee acknowledged ' ,

j the findings presented. No proprietary information was identified, i

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ATTACHMENT '

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SUPPLEMENTAL INFORMATION

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PARTIAL LIST OF PERSONS CONTACTED

Licensee

R. Andrews, Division Manager - Nuclear Assessments i

J. Chase, Manager - Fort Calhoun Station

M. Christensen, Senior Emergency Planning Representative

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O. Clayton,' Manager - Emergency Planning

B. Fried, Emergency Planning Representative

S. Gambhir, Division Manager - Engineering & Operations Support 1

G ' Gates, Vice President - i

S. Gebers, Manager - Radiation Protection '

R. Hankins, Emergency Planning Representative

T. Herman, Quality Assurance Audit Team Leader' I

E. Matzke, Licensing Representative

R.' Short, Manager - Operations

J. Tills, Manager,- Licensing ,

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NRC

V. Gaddy, Resident inspector

W. Walker, Senior Resident inspector

INSPECTION PROCEDURES USED

82701_ Operational Status of the Emergency Preparednes: Program

92904 Followup - Plant Support

93702 Prompt Onsite Response to Events at Operating Reactors

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ITEMS OPENED, CLOSED, AND DISCUSSED

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Opened

l 50-285/9702-01 NCV Late notification to State of Iowa (Section P1)

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l- 50-285/9702-02 VIO Failure to have instructions / procedures to ensure licensed

i operators maintained corrective lens inserts for self-contained

! breathing apparatus (Section P2)

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Closed

50-285/9702-01 NCV Late notification to State of Iowa (Section P1)

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50-285/9523-01 IFI- Failure to notify state / county agencies with 15 minutes of alert i

declaration (Section P8.1) ,

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Discussed

50-285/9515-01 IFl Failure to Have an Individual Properly Trained and Capable of

Performing Core Uncovery Predictions (Section P8.2)

50-285/9515-02 IFl The Degree of Simulation Precluded Evaluation of Individual's

Knowledge of Duties (Section P8.3)  !

a

List of Documents Reviewed '

Quality Assurance Documents:

l

,

Quality Assurance Surveillance Report R6-95-1, "EP Training," January 31,1996  :

Quality Assurance Surveillance Report R2-96-1' " Emergency Classifications," March 4,

,

'1996 i

i

Quality Assurance Emergent Surveillance Report R-96-1, "Offsite Communications  !

Capabilities," August 27,1996

Quality Assurance Surveillance Report R5-96-01, " Medical Support and Reentry,"

September 13,1996

Quality Assurance Surveillance Report R-96-2, " Drill Activities," January 3,1997

l

Quality Assurance Audit Report 4, " Emergency Response Plan and implementing

Procedures," May 5,1997

.

i- . NRC Event Notifications:

'

NRC Event 29867

.

, NRC Event 29887

NRC Event 30126

NRC Event 30151

j NRC Event 30204

NRC Event 30406

l NRC Event 30546

l- NRC Event 30610

1

_

_

a

e

0

0 1

-3- l

l

I

NRC Event 30635 I

NRC Event 31102

.

NRC Event 31114

NRC Event 31145

NRC Event 31181

NRC Event 31250

NRC Event 31314

NRC Event 31488

NRC Event 31527

NRC Event 31632

NRC Event 31944

NRC Event 32141

NRC Event 32193

NRC Event 32198

NRC Event 32229

NRC Event 32276

.

9