ML20140E034
| 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: |
| References | |
| 50-285-85-19, NUDOCS 8602030166 | |
| Download: ML20140E034 (9) | |
See also: IR 05000285/1985019
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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
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l-t - H
NemenM.Terc,EmergencyPreparednyssAnalyst
Date
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EmergencyPreparednessandSafegua{dsPrograms
Section
Accompanying
Personnel:
Gordon R. Bryan Jr.
PNL (Comex)
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Approved:
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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 to fall between two emergency classes.
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(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
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technical advisors, and health physics and chemistry technicians.
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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 <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
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
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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.
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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 <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> 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).
D~ ring an interview with the training staff, a statement was made that
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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
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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