ML20141C649
| ML20141C649 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 02/28/1986 |
| From: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| To: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20141C620 | List: |
| References | |
| LIC-86-078, LIC-86-78, NUDOCS 8604070283 | |
| Download: ML20141C649 (8) | |
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Omaha Public Power District 1623 Harney Omaha. Nebraska 68102 2247 1
402 536 4000 February 28, 1986 LIC-86-078 I@((l.0:ffI)h Mr. J. E. Gagliardo, Chief j F' 1
Reactor Projects Branch i(\\
N 3 S3 U. S. Nuclear Regulatory Commission
'h' lr Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 J
References:
1.
Docket No. 50-285 2.
Inspection Report 50-285/85-19 dated January 29, 1986.
Dear Mr. Gagliardo:
Inspection Report 85-19 Notice of Violation Notice of Deviation Omaha Public Power District received Reference 2 containing Notices of Violation concerning the Emergency Preparedness Program.
These vio-lations concerned the inability to perform prompt notifications, inadequate training for personnel assigned to the emergency response organization, and the inadequate review of the Emergency Preparedness Program. OPPD's response to these violations is found in Appendix A to this letter.
Reference 2 also contained a Notice of Deviation con-sistir.g of failure to implement annual requalifications. OPPD's response to this Deviation is found in Appendix B to this letter.
If you have any questions concerning any of these responses, please do not hesitate to contact us.
i Sincerel,
fh(
ufAl R. L. Andrews [d Division Manager Nuclear Production RLA/DJM:me cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, NW Washington, DC 20036 Mr. E. 6. Tourigny, NRC Project Manager Mr, p. H. Harrell, NRC Senior Resident inspector 0604070203ONh05 1
PDR ADOCK O PDR Ojj h 4s w4 e rnuoyrnen re opponumey
T APPENDIX A
, During an NRC inspection conducted on August 26-30, 1985, three viola-tions of NRC requirements were identified. The violations involved the inability to perform prompt notifications, inadequate training for personnel assigned to the emergency response organization, and the in-
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adequate review of the Emergency Preparedness Program.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the violations are listed below:
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A.
Inadequate Training of Personnel j
10 CFR 50.47(b)(15) requires that radiological emergency response training be provided to those who may be called on to assist in an emergency.
10 CFR 50.54(q) and (s)(2)(ii) require that a licensee shall main-l tain in effect emergency plans which meet the standards of 10 CFR 50.47 and the requirements of 10 CFR 50, Appendix E to provide rea-l sonable assurance that adecuate protective measures can and will be taken in the event of a rac lological emergency (including findings c
based on requirements of Appendix E,Section IV.D.3).
Section E(1.1) of the RERP for the Fort Calhoun Station states that initial notification of the States of Nebraska And Iowa and local emergency organizations will be made within 15 minutes after plant personnel recognize that events have occurred which make declara-tion of an emergency class necessary.
Contrary to the above, the staff of three operating shifts were un-able to demonstrate the ability to perform 15 minute notifications of state and local authorities.
This is a Severity Level IV violation (Supplement VII.0)
(285/8519-01).
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B.
Inadequate Training of Personnel 10 CFR 50.47(b)(15) requires that radiological emergency response training be provided to those who may be called on to assist in an emergency.
Section 0, paragraph 4.0, of the RERP for the Fort Calhoun Station l
states that initial and recovery emergency response organization l
personnel must satisfactorily complete a written examination as l
part of their training.
l Contrary to the above, the NRC inspectors found that radiological omergency response training had not been adequately provided as l
evidenced by the following discrepancies:
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Health physics technicians onshift were unable to perform two main tasks:
ascertaining habitability conditions in the con-trol room, and performing release value calculations, i
Appendix A Page 2 B.
Inadequate Training of Personnel (continued)
During scenario walkthroughs, shift personnel were unable to determine population sectors affected by the radioactive plume, containment activity release rates and failed, in some cases to properly classify and downgrade emergency events.
Two out of three operating shifts failed to recognize that containment iso-lation was not identical H th zero leakage.
Emergency preparedness training requirements were nonexistent for shift technical advisors, and senior reactor operators who were not shift supervisors.
Emergency assignments were made to personnel that had not been trained or qualified.
Tests given to emergency personnel were not commensurate with the scope and depth of training, and grading of tests was irregular in that quantitatively different answers for the same question were graded as correct.
This is a Severity Level IV violation (Supplement VIII.D)
(285/8519-02).
C.
Inadequate Review of the Emergency Preparedness Program 10 CFR 50.54(t) requires that all nuclear power reactor licensees perform an independent review of their emergency preparedness program at least every 12 months by persons having no direct responsibilities for its implementation. The review shall include an evaluation of the adequacy of interfaces with states and local governments, and relevant specific results shall be made available to the various parties involved.
Contrary to the above, the NRC inspectors determined that although OPPD audits for the years 1984-1985 included the evaluation of inter-faces with states and local governments as an objective, reviews were limited to ascertaining whether letters of agreement were current.
Moreover, the Safety Audit and Review Committee audit for 1983 failed to include the review of interfaces as an objective.
This is a Severity Level IV violation (Supplement VIII.D)
(285/8519-03).
Pursuant to the provisions of 10 CFR 2.201, Omaha Public Power District is l
hereby required to submit to this office within 30 days of the date of the letter transmitting this Notice, a written statement of explanation in re-l ply, including for each violation:
(1) the reason for the violations if admitted,(2) the corrective steps which have been take and the results achieved, (3) the corrective steps which will be taken to avoid further i
l violations, and (4) the date when full compliance will be achieved. Where l
good cause is shown, consideration will be give to extending the response time.
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Appendix A Page 3 l
0 PPD RESPONSE TO VIOLATION A (1) The reason for the violation, if admitted.
j The reasons for the violation were difficult-to-use procedures and inadequate training of personnel.
1 (2) The corrective steps which have been taken and the results achieved.
The notification procedures EPIP-OSC-2 AND EPIP-0SC-14 were reviewed and revised to make the completion of the required forms and the notification of off-site personnel more orderly and quicker.
The forms required for initial and update notifications were organized on a clipboard in the Control Room.
This makes them readily available.
The dose assessment procedures have been completely revised and consol-Idated in one procedure.
EPIP-E0F-6 now contains all dose assessment methods.
This revision also incorporated new graphs.
These graphs have greatly increased the amount of information available and de-creased the time required to obtain this information.
The Shift Supervisor makes the determination of emergency classifica-tion upon consultation with the Shift Technical Advisor. The Shift Technical Advisors have been assigned the task of completing the ini-tial portion of the Emergency Plan activation and notification from the Control Room. The STA's have completed training as Site Directors to perform these assignments accurately. The shift Chemists and Health Physics personnel have completed their training on the new dose l
assessment precedures.
Drills have been conducted with S1As, shift Chemists and Shift Super-visors.
The results of the training and drills are satisfactory.
(3) The corrective steps which will be taken to avoid further violations.
OPPD believes that the corrective action noted in (2) above is ade-i quate to avoid further violations. No additional action is planned at i
this time.
(4) The date when full compliance will be achieved.
OPPD is currently in full compliance.
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Appendix A Page 4 l
OPPD RESPONSE TO VIOLATION B l
(1) The reason for the violation, if admitted.
l OPPD believes that a violation occurred in the first two sections of the violation. Although weaknesses were identified in the emergency planning program in the latter three sections, no violation of Tech-l nical Specification, rules, regulations, or procedures occurred.
For the admitted violations, OPPD believes flaws in training, high turn-over rate of technicians, and heavy reliance on contract technicians were contributing factors.
(2) The corrective stops which have been taken and the results achieved.
l (a) Shift health physics technicians were retrained.
Each person's l
ability to properly monitor control room habitabilit1 was demon-strated by drill. Dose assessment calculations and evaluation i
procedures were reviewed and revised.
Improvements included incorporating several procedures located in various sections of the Emergency Plan Implementing Procedures (EPIPs) into one com-l prehensive procedure, EPIP-EOF-6.
Shift chemistry technicians i
have been trained, drilled, and tested successfully since the violation.
(b) Ten mile emergency planning zone (EPZ) maps with the 16 sectors designated were placed in the control room. Shift technical ad-visors (STA's) and shift chemistry technicians trained on the maps for dose assessment / notification drills. The STA has also participated in additional training for classifying emergencies.
l (c) All STA personnel have been specially trained in the duty of the l
Site Director for emergency response.
Previously, the STA was trained for emergency response in communication and data collec-l tor functions.
Emergency training for STAS now includes Site Director training.
l (d) A quarterly assignment, or appointment letter, is issued by the Division Manager, Nuclear Production Division. This memorandum identified by asterisk new appointees requiring emergency pre-paredness training.
The appropriate training is conducted soon after the issuance of the letter. The new appointee is generally in addition to one or more persons already fully trained and qual-l ified to perform that particular function. New appointments are made as replacements in the position or to bolster the resource j
for that duty.
(e) Rewriting of emergency preparedness training tests is in pro-l gress. The new tests are designed to be more difficult than previous tests.
The format of testing requires definite and i
direct answers with less fill in and essay responses.
This method reduces irregularities in test scoring.
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r App:ndix A Page 5 OPPD RESPONSE TO VIOLATION B (continued)
(3) The corrective steps which will be taken to avoid further violations.
(a) A shift dose assessment practice workbook is being initiated to strengthen the annual training cycle and serve as a refresher aid during the period between classroom training.
(b) The training provided to the STA and shift chemistry technician will continue through the annual emergency plan training process.
(c) The STA will continue to train in the annual cycle for Site Direc-tor.
In addition, senior reactor operators (SR0s) will partici-pate in the Site Director training. Other operating personnel on-shift will participate in an annual emergency preparedness training program specific for shift operation. OPPD will have completed the 1986 STA training by December 31, 1986.
(d) OPPD believes the present method of appointing new personnel with an asterisk designation for initial training has been very effect-ive. However, OPPD will strive to complete initial training quickly after the issuance of the assignment memo.
(e) Completion of new tests described above will correct the identi-fied weakness. The emergency preparedness training and test review will be monitored by a single training person who will provide uniformity to these steps. OPPD will have implemented improved testing and scoring methods by December 31, 1986.
(4) The date when full compliance will be achieved.
OPPD is in full compliance.
OPPD RESPONSE TO VIOLATION C (1) The reason for the violation, if admitted.
The violation resulted due to the lack of identification of the need to perform an in-depth review of the adequacy of the interfaces with states and local government. A contributing factor may also have been that audits do not necessarily include evaluations of all activities in a specific functional area. Audits usually consist of representa-tive sampling in a functional area.
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- Appendix A Page 6 OPPD RESPONSE TO VIOLATION C (2) The corrective steps which have been taken and the results achieved.
Steps have been taken to assure that the 1986 review of the Emergency Preparedness Plan include an evaluation of the adequacy of interfaces with states and local governments and relevant specific results will be made available to the various parties involved.
Incorporating this requirement into the 1986 review should result in assisting in assur-ing that adequate interfacing exists.
(3) The corrective steps which will be taken to avoid further violations.
The performance of the 1986 review of the Emergency Preparedness Plan incorporating the interface review will establish a standard for this review which should avoid further violations in this area.
(4) The date when full compliance will be achieved.
The 1986 review is scheduled for April,1986; therefore, full compli-ance will be achieved no later than May 1, 1986.
APPENDIX B During an NRC inspection conducted on August 26-30, 1985, one deviation of your Radiological Emergency Response Plan was identified. The deviation consisted of failure to implement annual requalifications.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the deviation is listed below:
Section 0, Paragraph 5.3 of the Radiological Emergency Response Plan com-mits to an annual requalification of emergency response personnel.
Contrary to the above, 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 training or retrain-ing records were found. (285/8519-04).
Omaha Public Power District is hereby requested to submit to this office, within 30 days of the date of the Notice of Deviation, a written statement or explanation in reply, including:
(1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further deviation from commitments made to the Commission; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown.
OPPD RESPONSE 1
(1) The corrective steps which have been taken and the results achieved.
The annual 1985 training cycle requirement was completed during the calendar year 1985.
(2) The corrective steps which will be taken to avoid further deviation from commitments made to the Commission.
For 1986, a training schedule at a 12 month frequency is being invest-igated in order to better control regular training intervals. OPPD will complete the investigation in progress under Response (1) above.
OPPD will then generate annual training schedules similar to those provided for by Technical Specification 3.1 which provides "a maximum allowable extension not to exceed 25% of the surveillance interval."
This will provide each person's annual training to be conducted every 12 months 3 months.
(3) The date when full compliance will be achieved.
OPPD is currently in full compliance.
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