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Insp Rept 50-285/85-19 on 850826-30.Violations & Deviation: Inadequate Training of Personnel,Inadequate Review of Emergency Preparedness Program & Failure to Implement Annual Requalification Training
	ML20140E034
Person / Time
Site:	Fort Calhoun
Issue date:	01/03/1986
From:	Terc N, Yandell L; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	;
Shared Package
ML20140D970	List: ML20140D966; ML20140D984; ML20140E006; ML20140E034;
References
	50-285-85-19, NUDOCS 8602030166
	Download: ML20140E034 (9)
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APPENDIX C

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-285/85-19 License: DPR-40

Docket: 50-285

Licensee: Omaha Public Power District

1623 Harney Street

Omaha, Nebraska 68102

Facility Name: Fort Calhoun Station

Inspection At: Fort Calhoun Station, Blair, Nebraska

Inspection Conducted: Augu t 26-30, 1985

Inspector: b 4-- l-t - H

NemenM.Terc,EmergencyPreparednyssAnalyst Date ,

EmergencyPreparednessandSafegua{dsPrograms

Section

Accompanying

Personnel: Gordon R. Bryan Jr.

PNL (Comex) ,

Approved: l-3-24

L. A. Yandell, Chief, Emergency Preparedness Date

and Safeguards Programs Section

Inspection Summary

Inspection Conducted August 26-30,1985 (Report 50-285/85-19)

Areas Inspected: Routine, unannounced inspection of the licensee's emergency

preparedness program including personnel proficiency and training, changes to

the emergency program and audits. The inspection involved 110 inspector-hours

onsite by 2 NRC inspectors.

Results: Within the three areas inspected, no violations were identified in

one area. 'Three violations were identified in the two remaining areas

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(Inadequate training of personnel paragraph 3; and inadequate program

review paragraph 4). In addition, one deviation was found in one area

(failure to implement annual requalification training paragraph 3). Nine open

items from previous NRC inspections were closed.

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DETAILS

1. OPPD~ Personnel Contact'ed

R. Andrews, Division Manager, Nuclear Production

J. Fluher, Supervisor, FCS Training

D. Feigher, Emergency Planning Coordinator

F. Franco, Manager, Radiation Health and Emergency Preparedness

J. Gasper, Manager, OPPD Administration

R. Jaworski, Section Manager, Technical Services

L Kusek, Supervisor, Operations

'O. Munderloh, Licensing Engineer

G. Roach, Supervisor, Chemistry and Radiation Protection

F. Thurtell, Division Manager, Quality Assurance and Regulatory

Affairs

C. Vanecek, Shift Supervisor

M. Christensen, Instructor

The NRC inspectors also contacted other licensee employees during the

course of the inspection. They included shift chemistry and health

physics technicians, shift supervisors, shift technical advisors,

senior operators, and reactor operators.

Denotes those present at the exit interviews.

2. Action on Previous Inspection Findings

(Closed) Open Item (285/8135-27; 285/8227-27): The NRC inspectors noted

that the licensee had installed and implemented a new primary means for

performing post accident sampling and analysis.

(Closed) Open Item (285/8135-37; 285/8227-37): The NRC inspectors noted

that in June 1985 the licensee provided State Emergency Control Centers

with computer terminals which allow remote interrogation of meteorological

parameters.

(Closed) Open Item (285/8135-52; 285/8227-52): The NRC inspectors noted

that the licensee had installed additional shielding in the counting

facility. In addition, see item 285/8135-27; 285/8227-27 above.

(Closed) Open Item (285/8135-33): The NRC inspectors noted that the

Emergency Operations Facility was made operational on February 1,1983.

(Closed) Open Item (285/8135-50): The NRC inspectors noted that the

licensee revised chemistry procedures and operational instructions to

incorporate sample labeling, storage and disposition.

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(Closed) Open Item (285/8135-47): The NRC inspectors noted that a new

procedure, OSC-13, "Onsite Radiological Monitoring" was developed to allow

for documentation of radiological survey results.

(Closed) Open Item (285/8406-01): The NRC inspectors determined that

Procedure OCS-1, " Emergency Classification," was revised in October 1984,

to include decision making criteria for classifying emergencies which

a'pearad

p to fall between two emergency classes.

(Closed) Open Item (285/8406-07): The NRC inspectors noted that the

licensee had verified the accuracy of names and telephone lists pertaining

to state patrolmen.

(Closed) Open Item (285/8423-01): The NRC inspectors noted that a

training session was conducted for offsite teams.

3. Personnel Proficiency and Training

The NRC inspectors reviewed sections of the Radiological Emergency

Response Plan (RERP) for Fort Calhoun Station, the RERP Implementing

Procedures, Technical Specifications, the Station Training Manual (STM),

the Emergency Plan Training Manual (EPTM), and previous NRC inspection

reports._ In addition, the NRC inspectors reviewed training records, and

conducted interviews and walkthroughs with on-shift emergency response

personnel including: shift supervisors, reactor operators, shift l

technical advisors, and health physics and chemistry technicians. l

Three walkthroughs involving three different shift operating crews were

conducted in the control room. Two of these took place at 0530 and one at

1700 and each lasted an average of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Interviews of chemistry and

health physics technicians were conducted during the day shift, but

included personnel that could work on back shif ts.

10. CFR 40.47(b)(15) requires that radiological emergency response training I

be provided to those who may be called on to assist in an emergency.

10 CFR 50, Appendix E, Section IV.D.3 states that a licensee shall have

the capability to notify responsible state and local government agencies

within 15 minutes after declaring an emergency.

Section E(1.1) of the RERP for the Fort Calhoun Station states that the

initial notification of the States of Nebraska and Iowa and local

emergency organization will be made within 15 minutes after plant

personnel recognize that events have occurred which make declaration of an

emergency class necessary.

Contrary to the above, the NRC inspectors found that:

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The staff of three operating shifts, which would become the initial

emergency response organization during an emergency were unable to perform

the notification of offsite authorities within the 15 minute time

requirement. Out of the five notification instances required by each

walkthrough scenario, none was completed within the time constraints. In

some cases the operators acknowledged that they did not know how to

complete the notification form. In all cases, the operating staff gave up

after their attempts were unsuccessful and the NRC inspectors proceeded

with the remainder of the walkthroughs. Faced with the same scenario, two

shifts used one notification form while the other used tour different

forms.

The above constitutes an apparent violation of 10 CFR 50.47(b)(15)

(285/8519-01).

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The NRC inspectors reviewed past inspection records and noted that during

the December 1983 exercise, notification of the State of Iowa took place

23 minutes after the declaration of the Notification of Unusual Event

(NOUE). A previous NRC inspection (NRC Report No. 285/83-10, Section 4)

noted that shift supervisors performed poorly in emergency classification

and notification tasks. A violation against 10 CFR 50.54(q) and

Appendix E,Section IV.F was issued at that time.

During the July 1985 exercise, notifications were completed 49 minutes

after the declaration of the initial emergency classification.

10 CFR 50.47(b)(15) requires radiological emergency response training is

provided to those who may be called on to assist in an emergency.

Contrary to the above, the NRC inspectors found a series of discrepancies

in training as follows:

The NRC inspectors interviewed four health physics and chemistry

technicians that would have on-shift assignments and found that they

were unable to perform the two main tasks that they would be

responsible for during accident conditions, in particular if the

accident occurred on a back shift they were not trained to ascertain

habitability and whether a criterion of habitability existed for the

control room. The same technicians could not perform dose assessment

calculations adequately.

The NRC inspectors noted a similar problem occurred during the

July 1985 exercise (NRC Report No. 285/8516, Section 4a) when the

health physics technician failed to recognize large discrepancies

between the range of release values physically feasible and

calculated release values.

The NRC inspectors noted that out of 33 walkthough scenario

requirements to classify emergency events, the licensee improperly

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classified six events. Two of the three shifts in question made an

incorrect initial protective action recommendation at General

Emergency. One of the shifts was unable to determine the population

sectors impacted. Faced with identical conditions (i.e., containment

high range monitors reading 20,000 R/hr due to noble gases and no

other contribution from other sources), two of the shifts were

requested to determine the containment activity release rate. Both

shifts provided different incorrect answers that were incorrect by

several orders of magnitude.

The shifts were inconsistent in their assessment of what conditions

would allow downgrading of the emergency. Only one out of the three

shifts recognized that containment isolation was not identical to

zero leakage to the environment.

The NRC inspectors observed that except for shift supervisors,

training documentation did not require control room shift personnel

such as the senior reactor operators, and shift technical advisors

(STAS) to be trained nor qualified to perform their emergency duties.

During an interview with the supervisor in charge of training for

operators licensing he confirmed that there were no other specific

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emergency preparedness training requirements for licensed personnel.

The NRC inspectors determined that neither the RERP nor the EPTM

established emergency preparedness training requirements for on shift

control room personnel other than the shift supervisor. This

omission is particularly significant in the case of the senior

reactor operators, because according to the RERP, during accident

conditions they would relieve the shift supervisor if necessary.

The NRC inspectors noted that the .PTil did not specify to which

subgroups of emergency organizati nal elements the training course

would be applicable, and as a consequence a correlational matrix

between emergency titles and required training was not

available. .

The NRC inspectors determined that the EPTM tasks the plant manager

to designate the members of the initial emergency response

organization prior to training and qualification of the same. As a

consequence, emergency assignments included persons which had not

been qualified. For example, three of five STAS listed on the

current emergency assignment letter had not been trained nor had been

scheduled for training.

The NRC inspectors reviewed testing and grading of emergency

organizational elements and found that there was only one test per

course. In one instance for example, 18 persons took the same test

over a 5 month period. The test given for TSC recorder / phone talker

consisted of only six questions for a 5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months course. Grading of

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tests was found to be irregular. In one case five students gave two

answers, differing by an order of magnitude, and all were graded as

correct.

The above examples constitute an apparent violation of

10 CFR 50.47(b)(15) (285/8519-02).

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u ring an interview with the training staff, a statement was made that

re-scheduling of Site Directors' training was done over 10 times because

of what the staff believed to be lack of interest or reluctance on their

part.

These findings and discussions with the FCS training staff pertaining

to their lack of participation in the development and updating of the

EPTM suggest that a thorough review of the training program and its

implementation would be desirable.

The NRC inspectors noted that Section 0, Paragraph 5.3 of the RERP commits

to annual requalification of emergency personnel. In addition, the NRC

inspectors noted that both the FCS Training Manual and the EPTM made

reference to annual requalification. A review of training records

indicated that the length of time between initial training and retraining

of some personnel was greater than one year. For other individuals, no

records of training were found. The OPPD staff interprets this to mean

once every calendar year, and that a period of almost 2 years may elapse

before requalification is required. The above constitutes an apparent

deviation from a commitment in OPPD's RERP (285/8519-04).

No other violations or deviations were identified.

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4. Audits

The NRC inspectors reviewed Administrative Procedure DAS-EP-1, " Emergency

Preparedness Test Program," the Safety Audit and Review Committee (SARC)

Charter, internal audit schedules, audit plans, and SARC independent

reviews of emergency preparedness for the years 1983-85. In addition,

interviews were held with the SARC chairman.

10 CFR 50.54(t) requires, as a condition of the license, that all nuclear

power reactor licensees perform an independent review of their emergency

preparedness program at least every 12 months by person having no direct

responsibilities for its implementation. Furthermore, the review shall

include an evaluation of the adequacy of interfaces with State and local

governments.

Contrary to the above, the NRC inspectors determined that although the

OPPD audits for the years 1983-84 included as an objective to evaluate

interfaces with State and local governments, theso reviews were limited to

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ascertaining whether letters of agreement were current. At no time did

the licensee hold a meeting with offsite authorities to make an evaluation

of the adequacy of such interfaces. Moreover, the SARC 1983 aunit did not

include the review of interfaces as part of its objectives.

The above constitutes an apparent violation of 10 CFR 50.54(t)

(285/8519-03).

The various objectives listed on the audit reports of the last 3 years

ware statements of a general nature. When requested to give more detailed

information on the specific techniques used by the auditors, the SARC

chairman stated that no supporting information was kept. The NRC

inspectors noted that the audit plans included as references NRC IE

procedures that are used by NRC inspectors as guidelines to perform

inspections. The NRC inspectors concluded, due to the extensive nature of

findings in the training area as described in Section 3 of this report,

and to the failure to adequately perform an evaluation of licensee

interfaces with state and local governments, that the audits appeared to

lack the depth and detail needed to find and resolve deficiencies and

weaknesses that could degrade their emergency response.

No other violations or deviations were identified.

5. Changes to the Emergency Preparedness Program

The NRC inspectors reviewed Part P of the RERP, " Responsibility for the

Planning Effort: Development, Periodic Review and Distribution," Emergency

Preparedness Tests, relevant sections of the FCS Technical Specifications

pertaining to the Plant Review Committee, Licensing Action and Nuclear

Production Logs, and held discussions with selected Quality Assurance

personnel concerning the' mechanisms in place to ensure that changes to the

emergency preparedness program would comply to the requirements of

10 CFR 50.54(q). In addition, the NRC inspectors reviewed a sample of

previous NRC inspection findings, to ascertain whether responsibilities

for the resolution of the same had been assigned, the items had been

followed up and corrective actions had been taken and approved.

The NRC inspectors determined that mechanisms were in place to adequately

control changes to the emergency preparedness program and to followup and

resolve NRC findings in this area.

No violations or deviations were identified.

6. Exit Interview

The exit interview was held on August 30, 1985. The exit interview was

conducted by Mr. Nemen M. Terc, Emergercy Preparedness Analyst, with

Mr. Larry A. Yandell, Senior NRC Resident Inspector at Fort Calhoun

Station in attendance. The licensee was represented by

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Mr. Robert L. Andrews, Division Manager-Nuclear Production, and his staff.

The licensee was given an oral summary of the NRC inspectors findings,

observations and comments. The NRC inspectors identified three violations

and one deviation described above (see paragraphs 3.0 and 4.0 of this

report). The NRC inspectors stated that NRC Region IV management wou1J

review and determine the final status of the findings.

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ML20140E034

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