ML20154K313
| ML20154K313 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 09/19/1988 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Morris K OMAHA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 8809230281 | |
| Download: ML20154K313 (2) | |
See also: IR 05000285/1988020
Text
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D lk
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SEP 191988
In Reply Refer To:
Docket: 50-285/88-20
Omaha Public Power District
ATTN: Kenneth J. Morris, Division Manager
Nuclear Operations
1623 Harney Street
Omaha, Nebraska 68102
Gentlemen:
Thank you for your letter of August 24, 1988, in response to our letter
and Inspection Report 50-285/88-20 dated July 21, 1988. We have reviewed your
reply and find it responsive to the concerns raised in our report. We will
review the irnplementation of your corrective actions during a future inspection
to determine that full compliance has been achieved and will be maintained.
Sincerely,
Original Signcil By,
l
A.11. Deaeli
L. J. Cellan, Director
Division of Reactor Projects
cc:
Fort Calhoun Station
ATTN: W. G. Gates, Manager 1
P.O. Box 399
Fort Calhoun, Nebraska 68023
Harry H. Voigt Esq.
LeBoeuf, Lamb, Leiby & MacRae
1333 New Hampshire Avenue, NV
Washington, D. C. 20036
Nebraska Radiation Control Program Director
bec: (see next page)
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Omaha Public Power District -2-
bec to DMB (IE-35)
bec distrib. by RIV , with letter dated August 24, 1988:
R. D. Martin, RA
Resident Inspector
Lisa Shea, RM/ALF
RPB-DR$5
Section Chief, DRP/B
MIS System
RIV File '
RSTS Operator
Inspector
Section Chief
B. Murray
R. L. Bangart
R. E. Hall
Project Engineer, ORF..
P. Milano, NRR Project Manager
W. D. Travers, NRR
,
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Omaha Public Power District ?
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1623 Harney Omaha. Whrapa 68102 024 7
402 536 4000
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Augu<.t 24, 1988 M AUG 2 61988
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LIC 88-726
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U. 5. Nuclear Regulatory ComM ssion 1
Attn: Document Control Desk '
l
i Mail Sta+, ion Pl 137
Washington, DC 20555 l
! References: 1. Docket No. 50 285
i 2. Letter from NRC (L. J. Callan) to OPM (K. J. Morris) dated i
l July 21, 1988. 1
I
!
i Gentismen:
!
l SUBJECT: Responsc to inspection Report 50 285/88-20 !
I r
l Omaha Public Power District (OPPD) received the subject inspection report on ,
'
i implementation of the emergency plan and procedures during the annual emergency
1 response exercise. The report identified fifteen deficiencies. As a rr J1t of f
j this inspection a management meeting was held in Arlington, Texas, on July 28
j 1988.
I
l Please find attached OPPD's response to and schedule for correction of the
l
deficiencies as Attachment 1, and copies of the slides and discussion presented
j at the July 28, 1988 meeting as Attachment 2.
!
l If you have any questions concerning this matter, please contact us,
hKvJ. l
orris
,
Division Manager
Nuclear Operations
KJM/jb
Attachments
c: LeBoeuf Lamb, Leiby 1 MacRae
1333 New Hampshire Ave., N.W.
Washington, DC 20036
R. D. Martin, NRC Regional Administrator
P. D. Milano, NRC Project Manager
P. H. Harrell, NRC Seaior Resident Inspector
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ATTACHMENT 1
RESPONSE TO THE DEFICIENCIES
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o Respon:e to Inspection Report 50-285/88-20
In addition to responding to the specific deficiencies cited in the inspection l
report, it is important to address the overall programmatic problems and the
resulting corrective actions taken or planned by OPPD to address them.
OPPD recognizes that the Emergency Preparedness Program did not demonstrate
improved capabilities over previous performances. The exercise scenario was
designed to be very difficult so that shortcomings of the program could be
identified and corrected. The majority of the deficiencies cited in tne report
were identified by OPPD during the evaluation of the drill. In addition, an
internal critique conducted by 0 PPD has identified some generic weaknesses and
correctiva actions have begun ta address these items. A list of these items
was submitted in a letter to the NRC (LIC 88-575) on July 19, 1988. Several
have already been corrected and successfully retested.
The causes of the deficiencies can be attributed to inadeouate procedures,
'
training, or equipment, as presented on the following table.
To address these concerns, OPPD has set forth both short term corrective
actions, as presented in response to the specific deficiencies, and the
following longer term actions to address the programatic concerns:
The Emergency Planning department, in coordination with other
plant departments, will identify and initiate a surveillance '
program for equipment used by various departments for emergency
recovery.
Emergency Preparedness training wil' be evaluated and ungraded to
a performance based program. Expec'ed cowletion for this upgrade
is June 30, 1990.
The Emergency Plan Implementing Procedures will be evaluated and
appropriately upgraded. The scheduled completion for this major
i
task is June 30, 1990.
Along with these program enhancements, an extensive evaluation of emergency
,
staffing will be conducted to improve the assignment of the emergency duties of
l personnel to conform more closely to their regular job functions. OPPD
believes that these actions, along with the specific actions taken to address
the deficiencies, will provide a more prnficient, effective Emergency
Preparedness Program,
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s FORT CALHOUN STATION
. 1988 EXERCISE DEFICIENCIES
NRC OPPO
DEFirIENCY IDENTIFIED ROOT CAUSE
8820-01 X PROCEDURE
8820-02 X TRAINING
8820-03 X EQUIPMENT /0ESIGN/ HUMAN
8820-04 PROCEDURE
8820-05 X PROCEDURE
8820-06 TRAINING / HUMAN
8820-07 X PROCEDURE / SCENARIO
8820-08 X HUMAN / PROCEDURE
8820-09 X PROCEDURE
8820-10 X PROCEDURE
8820 11 SECONDARY PROCEDURE / TRAINING
8820-12 SECONDARY PROCEDURE
8820-13 SECONDARY EQUIPMENT / TRAINING
8820-14 X PROCEDURE
8820-15 SECONDARY SCENARIO
STAFFING OF
EMERGENCY
FACILITIES X PROCEDURE / TRAINING
REC 0VERY MODE
OPERATING PROCEDURE X PROCEDURE
DEPOS!110N DOSE
PROJECTION PROCEDURE X PROCEDURE
HARRISON COUNTY
ANS INITIATION X EQUIPMENT /PROCE0l;RE
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} tem 8820-01
0
The site director (SD) (the shift supervisor in the control room) did not recog-
nize existing plant conditions demanding an Alert classification existing at
7:15 a.m. until prom This is a defi-
ciency (285/8820-01)pted at 7:35 a.m. by a contingency message.
.
REASON FOR THE DEFICIENC1:
The Alert Classification was based on a definition for a loss or challenge to
one fission product barrier. However, definit hns of fission product barriers
are not clearly defined in Chart 1.1 found in EPIP-0SC-1, used by the Site Dir-
ectors for classification. The Site Director evaluated the choice between
Notification of Unusual Event (N0VE) and Alert and in his judgement determined
the NOVE was the proper classification because of being within the Limiting
Condition of Operation for the containment purge valves. He reasoned that
siace the Technical Specifications allowed continued operation, containment
integrity had not been breached. The root cause of this deficiency is lack of
clarity and clear direction ia Procedure EPIP-0SC-1.
ACTIONS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED:
Since the exercise, additional training has been provided for the Site Direc-
tors in the form of a training workbook with examples requiring ciassification
of several emergency conditions. These workbooks were distributed July 21,
1988. Quarterly Table Top Orills were initiated in January 1988 and will
continue through 1988. The third session is scheduled to begin in September.
This frequency will continue for the remainder of 1988 and a retraining
frequency greater than annually will continue for the future training program.
OPPD believed that classification work books were the most effective method to
promptly provide a revies and stimulate discussion regarding classification of
accident conditions to responsible Site Directors.
The Site Director who performed during the exercise has reviewed the classifica-
tion criteria and understands the basis for declaring the ALERT under the postu-
lated accident conditions. The Emergency Action Level (EAL) Chart OSC-1.1 was
evaluated again. It was determined that the chart provides correct classifica-
tion criteria, but doer not provide sufficient detail for situations requiring
classification based on the three barrier definitions.
Given this weakness, a statement is being added to the procedure stating, "When-
ever the initiating conditions are not sufficiently defined to absolutely
distinguish between either the Notification of Unusual Event or Alert emergency
classification in a controlled time period, then an Alert clas31fication should
be declared." A training hot-line was issued August 9, 1988 as an interim
method of training responsible Emergency Managers on the statement recognizing
this situation for a classifl cation higher than the Alert classification that
is already in procedure EPIP-0SC-1.
ACTIONS WHICH WILL BE TAKEN:
The EAL's will be revised into a form outlining Conditions, Emergency Classi-
fication, Criteria, and Related EAL's. The revised method will utilize a
separate page for each emergency condition similar to a method being used by
other utilities. This method clarifies the definition and simplifies the
classification process for the Site Director for initial clasiification during
the initial stages of an emergency.
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. Development of the EAL revisions to CPIP-0SC-1 will be completed by December
31, 1988. Training of the six shift rotations and follow-up testing on the
procedure will be coroleted by April 30, 1989. During the July 28, 1988,
ineeting, a completion date of March 31, 1989 was projected; however, upon
further investigation it was determined that additional time would be required.
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Item 5920-02
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There m re five instances of failure to follow notification procedures as fol-
lows:
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The comunicator in the control room did not complete the 7:20
a.m. Notification of Unusual Event (NOUE) message form correctly,
i.e., did not indicate in the "Remarks" block that an exercise was
taking place, and did not complete the "Report Received by" for
the state of Nebraska Emergency Operations Center.
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The above message did not show wind speed, wind direction,
affected sectors and recomended protective action recomendations
for the radioactive release in progress.
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While the release of radioactivity to the environment was going on
during the NOVE, the shift supervisor (who was acting as the site
director) instructed the control room comunicator to tell
officers of the states of Nebraska and Iowa there was ro current
dose assessment at the time, and did not provide information about
the current release.
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At 7:42 a.m., the control room staff did not prepare a
Notification Message according to written procedures for the Alert
declaration.
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The TSC staff, during the 8:10 a.m. update report to offsite
authorities, did not reflect the radioactive release in progress.
At that time, the stack release rate was more than Technical
Specification requirements.
This is a repeat deficiency (285/8820-02).
REASON FOR THE DEFICIENCY:
Previous training of facility Communicators was classroom training with little
actual performance. Individuals were trained on the procedure and then tested
on their comprehension of the procedure. Practical experience is gained during
subsequent drills and exercises. Hands-on experience of performance of these
procedures has been limited. Training was not conducted in the control room to
avoid distracting the operating shift.
It should be noted that during the exercise, contrcry to the Inspection Report,
the stack release never exceeded Technical Specification limits or limits found
in Appendix B of 10 CFR 20. The postulated leak rate f om containment was only
18,000 cc/ min and the stack dilution flow was 60,000 ft b/ min. This did not
result in a significant releases from the Auxiliary Building stack. The data
sheets from the scenario show only a random change in background activity as
would be expected from normal counting statistics. The root cause of this
deficiency is that the annual training provided to facility Communicators is
not performance based.
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- ACTIONS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED:
.
(a) A Performance Evaluation Checklist (PEC) was developed which requires
each trainee to physically perform important steps required by the
procedure as part of their requirements for passing the training. The
facility Communicator during the exercise wds reinstructed on performing
offsite notifications. The PEC was utilized during this training.
(b) A training memo has been issued, as an interim training measure, to l
facility communicators reinstructing them to follow EPIP-OSC-2,
"Notification & Activation for Offsite Notification", completely until ,
the communicators have been trained and evaluated against the
requirements of the PEC.
(c) A duplicate Rolm 240 conference telephone, identical to the unit in the
control room has been procured and used for demonstration training.
This telephone is used as a training tool, so that the control room is
not interrupted during training sessions.
The above measures have been taken to make facility Connunicators aware of the
procedure and OPPD believes that more performance based training will improve
their performance. The facility communicator during the exercise can perform
correctly, based on performing steps required by the PEC.
ACTIONS WHICH WILL BE TAKEN:
The PEC requirements are being incorporated into existing annual training
requirements for control room communicators beginning in August 1988 and should
be completed during normal shift rotation by October 27, 1988. The intent is
to move toward performance based training conforming to the INP0 accreditation,
not only for communicators, but all emergency response positions.
The Emergency Preparedness Training Program will be evaluated and upgraded
,
accordingly to a performance based program. The scheduled completion date is
>
expected to be June 30, 1990,
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Item 8820-03
[
The reliability of the primary connunication link of the Control Room (CR) with
the other Emergency Response Facilities (ERF) was questionable. The telephone
system with conference capabilities was interrupted several times during the
exercise. This interruption was caused by the inadvertent removal of the
handset from its closed position.
This is a deficiency (285/8820-03).
REASON FOR THE DEFICIENCY:
1. Four of the eight telephone trunks tying Fort Calhoun Station to the E0r
failed due to a blown fuse, and were taken out of service by the North-
western Bell Telephone Company at approximately 1:45 p.m. for 10-15
minutes. This left only four trunks available for incoming and outgoing
calls between facilities in the early afternoon. The result was an
overloading of the telephone system and reduction of communication
capabilities during this time period.
2. An individual in the Control Room, who was not a communicator, lifted
the hand set to listen and to provide additional information. However,
when the hand set was replaced in the cradle, the circuit was broken,
and the conference in progress was reinitiated.
The cause of this deficiency can be categorized into equipment failures,
poor design and human error.
ACTIONS THAT WHICH BEEN TAKEN AND RESULTS ACH12VED:
1. A software change to the Fort Calhoun telephone system was completed on
June 24, 1988. This change attomatically switches calls to other addi-
,
tional trunks when they become unavailable. This arrangement utilizes
available trunks through the Huntel (Blair) and OPPD telephone system,
thus increasing the number of trunks available from 8 to 26.
2. The individual listening on the hand set has been counseled, realizes
the poor result of his actions and understands this caused the problem
with conferencing.
The telephone system is better configured to accommodate reliable
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communications between emergency response facilities.
A.CTIONS WHICH WILL BE TAK W:
A digital microwave system linking Fort Calhoun, the Electric Building, North
Omaha Power Station, and the EOF is expected to be in operation by September
>
30,1988. Thi:: will increase the availability and reliability of the OPPD
l telephone system.
,
l OPPD will have small signs made and placed on conference phones indicating not
i to lift receiver while in conference. Scheduled completion is September 30,
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1988. This is a change from the September 4, 1988, date presented at the
meeting due to this task being larger than originally anticipated.
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Item.8820-04
.
The control room staff did not follow Procedure A0P-21, "Reactor Coolant System
High Activity," and as a consequence did not start reactor shutdown until 7:54
a.m., 12 minutes after the Alert declaration.
This is a deficiency (285/8820-04).
REASON FOR THE DEFICIENCY:
Interviews with the exercise operating crew and the OPPD Exercise Controller
indicate the staff did review procedure A0P-21 when the reactor coolant system
high activity condition occurred.
1. They realized at the time the reactor coolant activity exceeded
Technical Specifications.
2. The operators failed to follow the procedure in that they left letdown
flow at a minimum due to the leak rate being greater than one charging
pump capacity.
3. The plant staff was proceeding with a rapid, but controlled, shutdown.
4. The emergency implementing procedures were already in effect.
The procedure was quickly reviewed by the operating crew and it was determined
that all the corrective measures were already in place. Technical Specifi-
cations require plant shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The root cause of the
deficiency was lack of clear guidance in the procedure.
ACTIONS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED:
After reviewing procedure A0P-21, it was concluded that Step 3 should provide
the operators more guidance for conditions such as large leak rates in the
! ACTIONS WHICH WILL BE TAKEN:
!
A technical evaluation of procedure AOP-21 will be comoleted to determine if an
improved abnormal operating procedure is necessary when high reactor coolant
activities are present with reactor coolant leak rates less than those requir-
ing implementation of E0P 3 (Loss of Coolant Accident). This evaluation and
possible revision to the procedur9 will be completed by September 30, 1988.
.
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Item 8820-05
.
Control room personnel did not advise plant personnel of adverse radiological
conditions in containment. When the Alert was declared, the control room staff
announced it on the Gaitronics system without explaining the reasons for the
emergency classification. The NRC inspector noted that the written prccedure
was inadequate because it did not instruct the shitt supervisor on how long to
sound the siren, how to inform personnel of hazards, and how to instruct per-
sonnel to evacuate hazardous areas.
This is a deficiency (285/8820-05).
REASON FOR THE DEFICIENCY:
Procedure EPIP-0SC-2 contained general instructions to be made during plant
evacuation, but did not have a specific standard notification messages for the
various evacuation routes which may be required based on :he risk to personnel
and wind direction. The procedure did not contain a standard message guiding
the control room operators to provide station personnel a warning message prior
to or while evacuating the hazardous area.
ACTIONS WHICH HAVE BEEN TAKEN AND RESVLTS ACHIEVED:
Procedure EP!P-05C-2 was revised to include standard notification messages to
be read by Control Rooni Operators over the public address system. When an evac-
uation drill was conducted on July 6, 1988, these standard messages were used.
The announcements made during the July 6, 1988 drill were very effective as
demonstrated by rapid evacuation and the 25 minute accountability completion.
These actions are documented, and were observed by the NRC resident inspector.
ACTIONS WHICH WILL BE TAKEN:
OPPD will conduct evacuation drills every six months until consistent
proficiency is demonstrated.
Procedures EPIP-0SC-2 and EPIP-0SC-14 will be revised to include advising
personnel of adverse plant conditions along with any releases in progress.
These procedures will also be revised to include the duration of sounding the
Nuclear Emergency Alarms. These revisions will be completed by September 30,
1983.
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Item 8820-06
.
Information flow was deficient because critical plant conditions were not
promptly consnunicated to the T3C. Reactor coolant radiochemistry sample
results showed a large increase in radioactivity at 6 a.m., but the chemist did
not communicate results to the TSC until 8 a.m. The site director at the TSC
recognized the need for improved connunications, and requested at 9:10 a.m.
that an additional communication link be established with the control room.
This is a repeat deficiency (285/8820-06).
REASON FOR THE DEFICIENCY:
An interview with the Control Room Evaluator and Shif t Chemist indicated the
High Reactor Coolant Activity cue card was passed to the Control Room Staff at
07:15. However, tne information was placed on the control room desk and the
staff did not immediately act on it. The Operations Support Manager
approximately 30-45 minutes later recognized the increased activity and the
information was passed to the Shift Chemist in the Control Room, who in turn
quickly passed the information to the HP/ Chem Supervisor. Concurrently, the
Operations Support Manager passed the same information to the Site Director,
an extra telephone is stored in the Control Room specifically for the purpose
of providing additional communication, if it beromes necessary. Therefore, the
Site Director, realizirg that additional commun aation was necessary,
appropriately requesteJ the use of the additional line. The root cause of this
deficiency was human trror, due to inadequate training.
ACTIONS WHICH HAVE BE*N TAKEN AND RESULTS ACHIEVED:
A memo instructing lat. oratory personnel to pass results of antiyses to the HP/
Chem Supervisor as soor as possible was distributed to Chemistry pe'sonnel. I
Control Room orders were issued to emphasize the importance of processing tech-
nical information to appropriate support groups.
ACTIPS WHICH Will BE TAKEN: )
The above measures have been taken to make Radiclogical, Chemical and system
information more readily available to technical stpport groups. Fersonnel will
continue to be instructed on proper communications.
The effectiveness of these measures will be tested in future drills. The next
large scale drill is scheduled for December 1988.
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Item 8820-07
.
The following findings indicated that the TSC staff was not effective in their
evaluation of plant conditions and in providing technical support to
operations:
The Technical Support Staff (TSS) did not promptly differentiate
between the reactor coolant leak rate through the pressurizer to
the containment atmosphere and the primary to secondary leak in
the steam generator. As a consequence, the TSS did not recognize
that it was the steam generator safety valve failure which caused
Room 81 to be filled with steam.
At 9:17 a.m., the TSS could not determine the location and extent
of the steam generator tube rupture in spite of existing plant
conditions.
At 9:22 a.m., the TSS erroneously concluded that there was a steam
generator tube rupture and a steam line break.
At 9:25 a.m., the TSS was unable to give any information to the SD
at the T5C when he asked the status of the steam generator. This
occurred after the 50 received a report from the onsite monitoring
team informing him that the facada of the containment had blown
off. The TSS should have been aware that the location of the steam
generator's safety relief valves was such that a steam release
could cause the containment facade to be blown off.
At 9:32 a.m., the TSS confirmed that there was no increase in con-
tainment sump level nor containment pressure. However, they did
not notice significant increases in the main steam line radiation
monitor readings while the containment radiation monitors remained
relatively constant. The TSS had not recognized that a large
release of radioactivity to the environment was taking place.
The TSS's lack of understanding of plant conditions during the re-
leasedelayedinputdata(e.g.,massflowrate)requiredto
perfonn dose assessment calculations. The staff did not complete
the first mass flow calculation until 9:38 a.m., that is 38
minutes after plant conditions indicated that the steam generator
tube rupture and failure of a safety valve had occurred. At that
time the steam generator was losing about 800 gallons per minute.
The above is a deficiency (285/8820-07).
REASON FOR THE DEFICIENCY:
OPPD believes an effective technical support function was demonstrated based on
discussions with scenario developers, OPPD TSS observers, and players from
groups supported by the TSS during the exercise, as well as the TSS and Site
Director (50) log book entries. Throughout the day, the TSS effectively
provided supcort ta various groups as evidenced by these examples:
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. 1. Recommendations to the OSC and 50 on E0P utilization and operators
actions;
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2. Evaluaticn of cooldown rate, natural circulation conrtitions, fuel
failures; and .
3. Initiation of procedure changes and safety evaluations for off-normal
conditions.
However, improvement in the performance of the Technical Support Staff is ,
required. This deficiency is the result of two primary factors: ,
A. The lack of timeliness of the determinatior of elease rates was caused
by a lack of prepared guidance materials which are immediately available
for use during an event. Examples of this are:
1) The release rate through the failed safety valve was determined
promptly by the TSS after it was requested to do so by the dose
assessment group. However, the leak rate determination required
,
that information be retrieved from plant system files, evaluated
and the leak determined from engineering principles. This process
.
prevented immediate determination of the safety valve release
! rate.
2) The release rate through the failed steam generator tube, or
tubes, was also derived from data and engineering principles
during the exercise. This prevented immediate assessment of the
extent of the steam generator tube rupture.
B. Information provided by the scenario on plant transient conditions was
i in some cases incomplete and inconsistent. This resulted in TSS
actions, evaluations, and discussions which were perceived by the
evaluator as ineffective. Examples include:
4
1) Evaluation of the reactor coolant leak through the pressurizer was
4
attempted prior to 7:00 a.m.; however, the scenario did not
'
provide data on pressurizer safety valve sonic detector or tail
! pipe temperature which would be the immediate indications of a
pressurizer leak. Sump levels and quench tank data level or
. temperature also showed no change in conditions to allow an
'
evaluation of leak rate to differentiate between leak paths from
the pressurizer.
Further, simultaneous evaluation of three simultaneous accidents;
a pressurizer leak, a steam generator tube rupture and an
4
uncontrolled heat extraction, was a difficult situation which
i hampered clear differentiation by the TSS.
- Throughout the steam generator release, the TSS continued
monitoring the status of the pressurizer to containment release as
a prudent measure.
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2) When information was received by the TSS that a loud noise was
heard from a direction south of the control room and steam was
coming from Room 81, the immediate conclusion was that an
uncontrolled heat extraction and a release due to an unknown
failure was in progress.
There was not immediate information available to eliminate all
other steam piping in Room 81 as a steam source and only focus on
a safety valve failure until observations from Room 81 were
reported to the TSS.
.
3) Experienced individ'Jals within the TSS, wno had been present in
the plant during previous safety valve actuations, knew the
configuration in relationship of the facade to safety valves, and
were aware of potential effects on the faca'de of safety valve
lifting.
4) Information that the blowout panel pieces were on the floor of
Room 81 was not immediately available to the TSS. Without this
information the TSS was initially lead to conclude that a steam
line break was in progress, which is the design basis for bursting
out the blowout panels. Safety valve tail pipes exhaust through
the roof and would have to be broken or disconnected in order for
the safety valve exhaust to be in Room 81. This was not perceived
by the TSS a:: realistic.
E0P response to an uncontrolled heat extraction is the same whether the
heat extraction is a steam line break or a steam generator safety valve
failure. The root causes of this deficiency are:
1) The lack of prepared guidance materials for immediate use to
determine leak rates during emergencies.
2) Scenario information during the transient was sometimes incomplete
' r
and inconsistent. I
i
ACTIONS WHICH HAVE BEEN TAKEN:
Planning is in progress to develop guidance materials to determine flow rates
through the various leak pathways for a wide range of plant conditions and
transients. Procedure EPIP-EOF-6 was revised pending approval by the PRC with
flow curves in support of this objective. Calculation of dowr, wind doses can be
performed based on maximum steam flow versus steam pressure in the system.
,
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This will provide a method to calculate downwind doses if the relief valves
malfunction and stick open for a period of time.
! ACTIONS WHICH WILL BE TAKEN:
i
The following actions will be completed prior to-the 1989 Annual Exercise:
1) Emergency Responso Organization positions, as well as TSS positions and ,
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incumbent experience, will be evaluated and if appropria'.e restructured
by October 1, 1988 to better utilize OPPD technical experience.
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2) Guidance ma.crials will be developed to facilitate determinatior, of flow
rates through the various leak pathways for a wide range of plant
conditions and transients by December 31, 1989.
3) Prior to the next exercise, the 1989 scenario will be independently
reviewed for technical details and consistency of information important
and significant to the TSS to allow demonstration of the TSS
effectiveness and capability. These measures will be completed by June
1, 1989.
After its installation, the Fort Calhoun Stat!on training simulator will be
uiilized to verify technical consistency of exercise information.
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It'em 8820-08 -
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While the site director was coordinating and directing the emergency organiza-
tion from the TSC, the recovery manager at the EOF made an inadequate
appropriation of responsibilities. The recovery manager took over Dose Assess-
ment and Offsite Monitoring Team functions. This was a source of confusion for
the TSC dose assessment staff.
This is a deficiency (285/8820-08).
REASON FOR THE DEFICIENCY:
While in the ALERT classification, the dose assessment team in the TSC had the
official responsibility of radiological measurements and decisions. The dose
assessment team in the EOF was staffed and ready, monitoring the progress of
the measurements and evaluations. When the TSC experienced difficulty with the
dose assessment computer, the Emergency Coordinator suggested to the HP Chemis-
try Supervisor, that the plant revert to manual methods and allow the E0F staff
to operate the EAGLE coniputer sof tware. Miscommunication between the two
facilities as to who officially had the responsibility caused confusion and was
contrary to the responsibility transfer in the Emergency Plan which states
complete transfer of all emerger.cy responsibility from the Site Director to the i
Recovery Manager occurs at one specific time. The Emergency Coordinator also
misinterpro ed the Recovery Manager's statement at this time, "let's go with
it" to mean immadiately rather than the projection of 9:00 as the time for
transfer of authority. The root cause of this deficiency is personnel error
and the failure to implement the intent of the procedure.
ACTIONS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED:
The three Emergency Coordinators have reviewed their position specific proce-
dure and confirmed dose assessment operation and offsite monitor team control
by them is not authorized until the responsibility of the emergency has been
transferred to the Recovery Manager. The review was completed July 26, 1983.
The review indicated that the procedure should establish the requiremen'. more
firmly. This review has made the supervision of dose assessment and offsite
monitor team control aware of the improper appropriation of responsibility and '
informed them that individual responsibilities should not be fragmented. These
measures informed them that all dose evaluation responsibilities should be
assumed as one unit when the transfer of authority is officially completed.
ACTIONS WHICH WILL BE TAKEN:
Section 8 of the Emergency Plan, the Recovery Manager procedJre, EPIP-RR-10,
the Emergency Coordinator procedure, EPIP-RR-24, and the Responsibility Transi-
tion procedure, EPIP-E0F-14 will be reviewed and revised to describe the
transition of responsibility more firmly and clearly. It is expected that the
procedures will be reviewed, revised and reissued by October 31, 1988.
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Item 8820-09
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The dose assessor in the TSC made several inappropriate entries which resulted
in inaccurate offsite dose projections. The estimated time of release duration
at 9:10 a.m. was about one hour. Instead, the dose assessor entered a release
duration of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. In addition, he erroneously entered containment stack and
condenser as the release location. The main steam isolation valves were shut
making the condenser not applicable.
This is a deficiency (285/8820-09).
REASON FOR THE DEFICIENCY:
OPPD believes that some inappropriate entries were made during dose assessment
efforts due to the limitations of the EAGLE code for accepting and processing
inputs.
In the exercise scenario, one main steam safety valve malfunctioned and
remained open at pressures where the valve should normally be closed. There
were no emergency pror:edures in place which addressed this particular situation
and maximum flow rate out of ten steam safety valves had to be assumed. Input
of this maximum flow rate into the EAGLE program resulted in overly conserva-
tive offsite dose projections. However, since the containmer.t purge valves
were still leaking and containment had a leak rate, stack and containment
releases would be appropriate as part of the summation of downwind exposures.
The input menus for the dose assessment program are divided into three main
categories: (1) Auxiliary Building stack, (2) Condenser / Main Steam, and (3)
Containment leak rate. Therefore, using Option (2) Condenser / Main Steam
release condition was appropriate. This menu is divided into two submenus
containing condenser and nain steam release points. The final calculation
would result in a summetion of downwind exposure from all release paths.
Interviews with the exercise TSC dose assessors indicate an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> release
period was initially passed to them froM the control room. The eight hour
release duration was used in one assessment with the 0845 monitor data (28 cpm
for RM-064). This entry resulted in only background exposures downwind. This
assessment was never officially issued since exposures were only background.
Sub;equent to this one data entry, either one hour or four hour duration were
used for the remaining assessments. The root cause of this deficiency is that
procedures EPIP EOF-6 and 01-PAP 8 did not contain provisions for determining
mass steam flows if valves open or remain open after steam pressure falls below
,
the pressure setpoi*t.
ACTIONS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED:
A procedure change to Emergency Plan Implementing Procedure EOF 6, "On-
site /Offsite Dose Assessment," Section C, and Operating Instruction O! PAP 8
have been submitted for PRC approval. These procedure changes provide a n'ethod
to calculate a flow rate to the environment in the event a main steam safety is
opened bel w its particular set pressure.
Inputting a more accurate flow rate into the EAGLE program will result in more
accurate and realistic dose projections and Protective Action Recommendations
for offsite locations.
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. ACTIONS WHICH WILL BE TAKEN:
Procedure EPIP-EOF-6 will be revised directing the TSC Dose Assessment i
Operators to obtain the estimated duration of release from the Technical
'
Support Supervisor. This revision will be completed by November 30, 1988.
Instructions will be revised in the Technical Support Supervisor procedure,
EPIP-RR-14, to provide estimatea duration of release information to the Oose
Assessment Operator. The revision will be completed by November 30, 1988,
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item 8820-10
The Recovery Manager did not classify the General Emergency until about 44 min-
utes after the conditions warranting the classification were in place, and 33
minutes after dose assessment results supported a General Emergency classifi-
cation.
This is a deficiency (285/8820-10).
REASON FOR THE DEFICIENH:
The first indication of the steam generator tube rupture occurred at 9:01 a.m.
The NRC team had recently arrived and the Recovery Manager was presenting a
facility briefing and did not immediately receive the plant data. However, the
asse.;sment of plant events was completed and allowed the correct upgrade to
Site Area Emergency at 9:15 a.m. Dose assessment results for site boundary
exposure, the important guide to a General Emergency, were not available at
this time. Dose assessment personnel collected radiological data at 9:10 a.m.
for a 9:15 a.m. analysis. Due to an unmeasured release path, the release flow
rate was not readily available. A prolonged evaluation concerning use of the
procedure default value and a calculated value occurred with the decision
finally made to use the default number. At 9:29 a.m. the dose assessment
results were printed and presented to the Recovery Manager. After discussion
with the Site Director, the Recovery Manager upgraded to a General Emergency at
9:44 a.m. The dose assessment results were available to the Recovery Manager
for 15 minutes when the discussion was completed. Basic reasons for the delay
were that (1) the dose assessment computer was in use for a previous assessment
at 9:00 a.m. and not cleared to assess this important data increase, (2) the
procedure did not provide clear direction to determine a precise flow rate when
the release flow rate is from an unmeasured path, and (3) participants did not
place sufficient emphasis on completing this -quirement within the allowed
time restriction. The root cause of this deficiency is procedural weaknesses.
ACTIONS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED:
A procedure change to Section B of EPIP EOF-6, "0nsite/0ffsite Dose
Assessment," was submitted on July PS, 1988, for PRC approval. This change
directs dose assessment personnel to abort insignificant dose assessment data
being processed on the computer when new data indicating rapid increases are
available for more timely and valuable dose usessment information. This will
eliminate delays caused by automatic 15 minute data processing.
Procedure changes have also been submitted to the Plant Review Committee to
improve the method for obtaining release flow rates from unmeasured paths. The
method is discussed in deficiency 8820-09.
Dose assessment personnel have been reinstructed by memorandum to emphasize
completing dose assessment as quickly as possible to allow issuance of protec-
tive action recommendations within 15 minutes of the recognized event.
The measures discussed above have been taken to make dose assessment and the
rerponsible emergency managers aware that emergency classifications, dose
assessments and protective action recommendations are required within 15
minutes of the recognized event. The effectiveness will be measured at future
drills.
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. ACTIONS WHICH WILL BE TAXEN:
The actions in progress are believed to be sufficient to correct the problert.
The revised procedures will be approved and issued by October 31, 1988.
In addition, EPIP-E0F-6 will be reevaluated in its entirety to ensure the
procedure provides consistent and accurate dose assessment instructions. The
procedure will be revised by March 31, 1989 if appropriate.
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Item 8820-11 )
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Briefings and debriefing of in-plant repair teams dispatched from the OSC were
inadequate. The radiation protection technic,ans did not provide in-plant
teams with information mandated by Procedure EPIP-OSC-9, "Emergency Repairs,
Corrective Actions, and Damage Control." Briefers did not provide repair teams
with diagrams, procedures, floor plans, nor give specific instructions on how
to perform complex tasks.
This is a repeat deficiency (285/8820-11).
REASON FOR THE DEFTCIENCY:
The procedures for Monitor Coordinators - Basic Responsibilities are not
specific for providing briefings of teams re-entering evacuated plant areas.
There was a lack of coordination between the Monitor Coordinator and the
Maintenance Supervisor in preparing maintenance for emergency repair. The root
causes of this deficiency are (1) the lack of a single governing procedure
providing)
tions; (2 lackguidance and reference
of performance based to applicable
training requirements
for Monitor forRepair
Coordinator, certain/ situa-
Re-entry, and rescue teams with regard to emergency conditions, and (3) failure
to identify the deficiency and initiate corrective action during previous
damage control drills.
ACTIONS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED:
A review of procedures EPIP-0SC-9, "Emergency Repairs, Corrective Actions and
Damage Control," and EPIP-RR-3, "Re-entry into Evacuated Aren," was conducted
with the present personnel assigned to the Monitor Coordinator position. The
importance of ensuring the requirements of these procedures are met prior to
dispatching repair / rescue crews was stressed. A new draft procedure
EPIP-0SC-20, "Radiation Protection Guidelines - Emergency Condition," was also
- reviewed with the Monitor Coordinators. This procedure provides them with a
i single procedure for developing pre-job briefings and referencing of other
applicable procedures. These measures have been taken to make the Monitor
- Coordinators more aware of these procedures and their use during an emergency
situation.
ACTIONS WHICH WILL BE TAKEN:
l
A new procedure, EP!P-0SC-20, "Radiation Protection Guidelines - Emergency Con-
ditions," is currently being developed to provide instruction to appropriate
emergency personnel and will be issued by August 31, 1988. Individual specific
procedures will reference EPIP-05C-20 for guidelines to consider during
- Emergency Conditions. In addition, a specific Monitor Coordinator procedure
will be developed with an operational checklist. The Maintenance Supervisor
procedure, EPIP-RR-21, will also be revised to contain a checklist. Both
procedures will direct use of EPIP-0SC-9 and EPIP-05C-20. The revision to
- procedure EPIP-RR-21 will be completed by December 31, 1988. A new Monitor
[
Coordinator procedure will be completed by December 31, 1988.
- The procedure EP!P-0SC-20 includes guidance for pre-job briefings as well as
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guidance for personnel monitoring, Contamination and Air-Sampling surveys,
Respiratory Protection, Radiation, and for the Control Point Determination and
Shielding Calculations,
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. OPPD believes the general health physics deficiency is correct, and has
initiated an extensive Radiation Protection Improvement Program for all station
health pnysics personnel. Specific areas identified in past exercises have
been corrected, showing a positive improvement towards a total resolution of
the inadequate station health physics practices deficiency.
OPPD will continue Semi-Annual Health Physics drills and include scenarios
which increase the use of re-entry teams as part of the drill. Damage control
drill frequency will be increased to quarterly until sufficient proficiency is
demonstrated. These drills will contain more difficult radiological / mainte-
nance problems and involve larger teams. Procedure EPIP-OSC-20 will be
completed by August 31, 1988, and issued with subsequent training of all
appropriate personnel by March 31, 1989. This new procedure will also include
an official Operation Support Center Log to better document HP activities
within the plant.
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Item 88?0-12
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The OSC staff did not have a method to maintain continuous personnel account-
ability of in-plant teams.
Thisisadeficiency(285/8820-12).
REASON FOR THE DEFICIENCY:
This deficiency is related to item 8820-11. The procedure for recording and
tracking emergency worker exposures, EPIP-EOF-11, Dosimetry & Records, provides
general instruction to emergency team members but does not specifically
describe the method for maintaining continuous accountability. The root cause
of the deficiency is inadequate emergency health physics procedures.
ACTIONS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED:
A section of new draft procedure EPIP-0SC-20, "Radiation Protection Guidelines
- Emergency Conditions," is devoted exclusively to personnel dosimetry and
exposure control. Monitor Coordinators have been briefed on the draft of
EPIP-0SC-20 and the revised Operations Support Center Log.
The Monitor Coordinators were briefed as outlined in Item 8820-11 of the
- mportance and proposed method for documenting exposure histories and ensuring
accountability of Re-entry Teams.
The revised OSC log provides a methodology for tracking and maintaining
Re-entry Team exposure and work locations.
ACTIONS WHICH WILL BE TAKEN:
Procedure EPIP-0SC-20 will be submitted to the Plant Review Committee by August
31, 1988. Training will be provided to appropriate personnel by March 31,
1S39. The ability to account for and maintain exposure histories for In-plant
Team personnel will be demonstrated and tested during subsequent drills and the
1989 Annual Exercise.
OPPD will evaluate the Radiological Emergency Response Plan and the Emergency
Implementing Procedures ar.d upgrade as needed. The completion date is expected
to be June 30, 1990. During the upgrade of these procedures, Emergency Health
Physics related procedures will be consolidated together for easier reference.
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Item 8820-13
.
The rescue team was not well equipped and their practices were poor in the
areas of radiation protection and first-aid (e.g., cross-contaminated accident
victim, areas adjacent to Room 81, and waited about 5 minutes before taken
vital signs or giving shock treatment). In addition, a member of the medical
team was not trained in First-Aid Multi-Media nor decontamination practices.
Only one steam suit was available and the internal face shield was damaged.
The other rescue team member entered the room where a steam leak was going on
without a steam suit. The licensee did not have a comunication device to be
used while wearing the steam suit.
This is a deficiency (285/8820-13).
REASON FOR THE DEFICIENCY:
1. The rescue team members were poorly prepared and did not have adequate
supplies to cope with this emergency in a steam atmosphere.
2. Voice amplification equipment for Self Contained Breathing Apparatus
(SCBA) is judged by the OPPD Health Physics program to be ineffective
and is currently not part of the respiratory protection program at Fort
Calhoun Station. The root causes of this deficiency are (1) lack of
adequate rescue equipment which subsequently caused personnel errors and
(2) inadequate training being demonstrated by the individual not
officially assigned rescue team duties.
ACTIONS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVE 0:
1. Additional first-aid equipment and 4 steam suits are being procured. A
member of the health physics staff with EMT qualifications is coordin-
ating its implementation.
The formal first-aid training program is being transferred to the
Nuclear Operations Division and will include dedicated staff personnel.
Communicati , equipment while wearing a SCBA and steam suit is being
investigated.
2. The Emergency Planning and Radiation Protection departments have
contacted the manufacturer of our respiratory equipment for samples and
demonstration of voice amplification equirment. OPPD is currently
evaluating state-of-the-art amplification for ust with our SC8A.
3. Additional rescue equipment is being evaluated and procured.
l
ACTIONS WHICH WILL BE TAKEN:
1. The Emergency Planning Department will add basic contamination control
practices and frisking techniques to the rescue squad monitor and
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re-entry team training modules by March 31, 1989.
OPPD will implement and practice improved first-aid abilities during
drills and demonstrate for the 1989 Emergency Exercise.
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. 2. OPPD will complete evaluation of equipment and procure, if acceptable,
voice communication equipment for SCBA's by December 31, 1988.
3. OPPD will evaluate a method for surveillance of personnel protective
equipment necessary for responding to radiological emergencies by June
30, 1989.
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. tem 8820-14
.
The licensee did not perform personnel accountability during the site
evacuation within the 30-minute guidelines of NUREG-0654. The evacuation alarm
sounded at 7:39 a.m. The licensee could not complete accountability until 8:18
a.m.
The above is a deficiency (285/8820-14).
REASON FOR THE DEFICIENCY:
Personnel on site failed to evacuate immediately when the Nuclear Emergency ,
Alarm was sounded. The initial sounding of the alarm was terminated by the
Control Room in one minute, rather than the normal two minutes. The announce-
ment following the sounding of the alarm was not clear in content nor distinct
in tone, and personnel were unsure what they should do and where they should
go. When the Site Director realized the evacuation process was not proceeding
as planned, he reinitiated the alarm. However, 10 minutes had already passed,
and only 20 minutes remained to complete the accountability. The root cause of
this deficiency was a lack of clear and completc guidance in Procedure
EPIP-OSC-2, regarding announcements to station personnel.
AJGJIONS WHICH HAVE BEEN TAKEN AND RESULTS A{HIEVE0:
A standard notification message was added to EPIP-05C-2 which is used by the
Site Director to inform personnel of proper evacuation routes.
An evacuation / accountability drill was conducted on July 6, 1988 using the
revised EPIP-0SC-2 procedure. Accountability was completed in 25 minutes.
This accountability drill was observed by the NRC Resident Inspector.
ACTIONS WHICH WILL BE TAKEN:
A modification to the Plant Nuclear Emergency Alarm System is currently in the
preliminary design stage. This change will increase the coverage area of the
plant and ensure plant areas meet the requirements of ANSI-N2.3, 1979,
"Immediate Evacuation Signal Used in Industrial Installation." This
modification will also improve evacuation notification to those persons outside
of the Security area, such as the temporary trailers. ;
OPPO will increase drill frequency and conduct evacuation / accountability drills i
every :ix months. The next drill will be held in December 1988.
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Item 8820-15
.
The NRC inspector noted that since the last exercise, the licensee has devoted
substantial resources to the development of an adequate scenario. For the most
part, the scenario developed for the observed annual exercise was technically
sound and challenging to the players; however, the NRC inspector found some
scenario incongruences during the exercise which detracted from the realism and
free play of the exercise. Some examples follow:
-
Some controllers prompted players and did not provide data that
would normally be accessible to the players under actual accident
conditions.
-
At 8:50 a.m. (10 minutes before the scenario major event of a
steam generator tube rupture), the controller in the control room
noted that the initial conditions of the scenario did not include
a slight increase in radioactivity in the B steam generator. He
gave this information directly to the players, prompting them to
vital scenario infonnation that would not have been readily
acessible to them at that time.
-
The scenario did not provide information to the TSC staff that
would be accessible to them during nonnal operations. For
example, the maintenance unager wa:, not told by the scenario or
by the controllers that maintenance work was being planned on
Iraking containment purge valves. As a consequence, he was forced
to dispatch a team to lean about the valve status.
,
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The scenario did not anticipate plant conditions that would result
from control room operators' actions under Emergencv Operations
Procedures ard Recovery Procedures. For example, the TSS directed
isolation of the steam generator in question. After this
isolation, there should be no pressure differential within the
t primary system. Scenario data, however, showed a large pressure
differential betwcen the primary system and the steam generator.
-
Data on instrument readings presented eo the TSC staff was
ambiguous because various range could be implied. This caused
artificial delays and hesitations that would not have existed
under more realistic conditions. ,
The above is a repeat deficiency (285/8820-15).
REASON FOR THE DEFICIENCY:
Initial conditions contained in the narrative summary were omitted from the
initial conditions cue card passed to the Site Director in the Control Room.
.
This error resulted in the prompt by the Controller.
After evaluating the source code used to model the accident, it was determined
the cause of steam generator pressures remaining higher than expected, was the
'
Way tne model was developed. A requirement of the Emergency Operating
Procedure E0P-4 is to drain the 6dditional ccolant to the_ radioactive waste
system. Hor.ever, the model utilized did not have the ability to route the
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. additional volume to waste. Therefore, the scenario developers elected to
reduce the volume by opening an additional safety valve. The model only
considered this ss a loss of energy and, therefore, the energy and mass
equation did not balance and the steam generato. pressures did not respond as
expected. In retrospect, steam generator pressures should have been an input
parameter to force the model to create data more appropriate for this scenario.
The Scenario Development Group placed emphasis on preparing detailed radiolog-
ical and operator parameters, so previous deficiencies could be eliminated.
However, by focusing on these areas, they f ailed to provide a sufficient
evaluation of important parameters used by the Technical Support Staff.
The root cause of the deficiency was that the algorithm used to model the
accident was not adequate for the postulated conditions. The developer failed
to include all of the initial conditions necessary to brief plant staff. The
technical review of the final scenario was inadequate.
ACTIONS WHICH HAVE BEEN TAXEN AND QESULTS ACHIEVED:
It has been identified that insufficient resources were devoted to scenario
development and testing. Corrective actions will be taken prior to develormen+.
of the next exercise scenario. Results of actions taken will be demonstrated
for the 1989 Annual Exercise.
ICTIONS TO BE TAKEN:
OPPD will organize the Scenario Development Group earlier tnan previous years
and Assure that some members of the organization are dedicated to scenario
development. For 1989 additional contractor support will be used to assist the
group. Scenario development will ce assigned by September 1, 1988 and be
completed by June 1, 1989.
OPPD will use the CE simulator to verify the scenario, aspecially technical
data, prior to using it for the 1989 annual exercise. The Emergency Exercise
Development / Execution procedura EPT-10 will be reviewed and upgraded as needed
by January 31, 1969.
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ATTACHtiENT 2
SLIDES AND DISCUSSION PREsiNTED
AT JULY 28, 1988 NEETIt.G
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EMERGENCY PLAflNING
JULY 28, 1983
OPENING REMARKS K. J. Morris /
S. K. Cambhir
Backaround Information F. F. Franco ,
individual Deficienc9es F, F. Franco
-
Reason for Deficient
-
Root Cause
-
Immedi&rs 5.ctions Taken/Results Achieved
-
Correctics Actions P?anned/ Future Upgrades
Summarv/ Conclusions F. f. Franco
- Generic Aspects / Ramifications
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Safety Significance
CLOSING REMARKS X. J. Morris /
S. K. Gambhir
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Opening Remarks - 5. K. Gambhir
t.et r.:e first go through the agenda.
Fred Franco will be making most of the presentations. About 435 people parti-
cipated in tnis exercise. During the 1988 Fort Calnoun Station Emergency
exercise Fred was not a player, but served as Chairman of Scenario development
group.
For this exercise we had establishad some very high standards and the Scenario
was developed to fully challenge and exercise our staff. I believe we suc-
- eeded in pointing out the weak areas. Results of your inspection and our own
critique has pointed out several deficiencies and some programmatic weaknesses.
Over the last few weeks we have carefully evaluated these deficiencies,
analyzed root causes and generic implications.
As you will notice from Fred's presentation, we have already initiated several
short term corrective actions and plan to carry cut some major progre.mmatic
improvements, it is our goal to demnnstrate to you that the program with short
term corrective actions is adequate to ensure proper response in case of an
emergency and we are confident that the changes that we are proposing will
bring some lasting improvements.
Without further ado I will turn this over to Fred.
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DiscustiM Erod Franco
Today 1 intend to address three topics:
1. The Preparation of the Scenario before the Annual Exercise,
j 2. The Reasons for and Corrective Actions which will occur to correct and
prevent recurrence of the deficiencies identified by the NRC during the
exercise.
3. Summarize those root causes which have been identified in the analyses
>
of individual deficiencies and corrective actions to their generic
aspects.
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During the 1988 Fort Calhoun Station Emergency Exercise I was not a player, but !
served as Chairman of the Scenario Development Group. The Group established
specific goals such as providing an opportunity to demonstrate response to pre- ,
,
vious weaknesses. Another goal was to present a difficult, but accurate and !
reasonably realistic scenario to seriously challenge CPPD response personnel.
< I, as Manager, want a strong Emergency Response program so we set out and pre-
pared a difficult scenario to really test our people and sort out weaknesses to
t
correct as a means to strengthen the program. As part of the verification of
the scenario, it was tested at the CE simulator where licensed operations per- '
sonnel are annually trained and reviewed by control room operators who were not
participants for the exercise. Several changes and improvements were made in
the scenario as a result of these checks, and it was concluded that the scenar-
- io would satisfy the intended goal.
] During the preface remarks to the NRC inspection team during the exercise brief-
ing on June 21, 1988, the day before the e.tercise, several interesting and pro-
phetic observations were made to them.
It was reported to them that the primary objective of the State of Nebraska was
to demonstrate the six year plume ingestion oathway actions. !r, order to pro-
vide a realistic setting for this, the plant and utility malfunctions would be
compressed into the morning so that the State woJ1d have the full afternoon to
i properly perform for FEMA evaluators. During the briefing it was pointed out
j that two prompt contingency messages were incorporated into the cue cards be-
cause timing the two classifications desired in the morning action to get the
<
needed responses and time jump, which we*e critical to the time line, were very i
- difficult to determine. This difficulty had been identified during the siru- '
'
lator and operator review.
! lhe scena-io writers and I accepted the very difficult classification and dose l
assessment problem presented to the participants as a trade off to allow suffi-
! cient time for the State plume exposure pathway demonstration. As a result we
identified more deficient actions from the responders than we expected based on
- observing previous drills. However, we really believe this exercise experience
,
was very beneficial for our Emergency Planning Program by emphasizing to us a
j better realization that problems do exist in the program and we will initiate
! the necessary improvements. There were also many very good performances by the
- 435 OPPD participants. Twenty-three of the tuenty six planned objectives were
i met and it was satisfying to have Mr. Martin, your Director of Site Operations.
- recognize the difficulty of the scenario.
I would next like to discuss each daficiency. Rather than analyzing each one
l in numerical sequence, I intend, with your concurrence, to present the deficien-
- ci n by grouping of subjects.
,
! 2-3
!,
- - - - _. __ , - - . _ _ _ . . _ ,
- _ _
- _ . ~ , , _ _ _ , . _ , _ _ _ _..__i-_..,
_ _ _ _ _ _ _ _ _ _ _ _ - _ _ _
. .
' '
. ,
.
This 9rouping of subjects is by my definition and has no other basis.
1. Classification and Notification / Assessment
2. Classification and Notification / Assessment
3. Communication
4. Technical Actions
5. Evacuation and Accountability
6. Communication
7. Technical Actions
8. Classification and Motification/ Assessment
9. Classification and Notification / Assessment
10. Classification and Notification / Assessment
11. HP/ Rescue Practices
12. HP/ Rescue Practices
13. HPiRescue Practices
14. Evacuation Accountability
15. Technical Actions
Slide Presentation
Classification & Assessments: Nos. 1, 2, 8, 9, & 10
Communicatign: Nos. 3 & 6
Technical Ag. donq _1: Nos. 4, 7, & 15
-
Evacuation & Accountability: Nos. 5 & 14
HP/ Rescue Practices: Nos, 11, 12, 13
2-4
_._ _ _ . _ _ _ _ _ _ _ _ _ . . _ _ _ _ ._ _ .__ _ -. . _ . . . _ _ _ _ _ _ _
. .
. .
,
.
Ce t:::cr. y
I
-
8820-01
l REASC?! FOR "EF!?!?NCY i
l
l
Chart usec for :lassification coes no; :learly define a enallenge I
l ;c a fissten crocuct barrier.
1
i
The Shift Supervisor judged the tiOUE to be the proper classification.
,
l
[
>
ACTIONS TRAT RAVE BEEN TAKEN
l
'M
Training work 00ks have been distribtued to all Site Directors j
,
providing them a scenario to classify. Feedback to proper
'
l
class 1ft:ation will be provided at tne end of eacn montn.
t
l Procedure EPIP-05C-1 "Eme rgency Cl a s s i fi c a,ti on" ha s been revi sed.
I
l
l
RESULTS_
i
,
l
-
3
The Site Director performing during the exercise was provided i
! feedback and understands the basis for classifying the intt:al l
accident as an ALERT emergency. l
l Procedure EPIP-05C-1 was submitted to the Procedure Review Committee
l for approval. l
.
l
1
i
ACTION THAT WTI,I<E TAKEN
l
!
-
t
The classification crocedure. EPIP-05C-1, will be revised in
) a more organi:ed f ashion; delineating eacn Emergency Condition,
i N
) Criteria anc Related Emergency Action Classification.
1
l The final ::moletion will te Mar:n 31, 1989.
,
I
1
(
!
!
!
2-5
,
l _ . . - , , - . . _ - - - . . -
_.____ - . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ _ . _ . _ _ _ _ _
,
. '.
. .
,
.
.
~.:-.:.=- ;
s
S320-02
t
,
-' ' ' ~ " " **
b .' - -
'
'
?- ':t-
( a . . : 2.
-
u/... . . . . .- ... + . .. - - -
,
, Training of f acility communicators is not performance: based. Only
i hancs on experience is gained during drills and exercises. NOTE: Stack
l releas s were never in excess on Technical Specifications or 10CFR20 ;
limits.
'
l 3
--K" A
3,rwamsww ,. mm:--e- - - - - - - - - - -
l
L
'
)
,
ACTIONS THAT HAVE BEEN TAKEN
- -
l
- A Performance Evaluation Checklist (PEC) was developed requiring instruc- l l
- tor evaluated steps be completed while individual is performing the task. '
'
The exercise communicator was evaluated against these requirements on l l
7/23/88. Facility communicators are scheduled to begin this training memo 4
1
August 2, 1988. Training memo was sent to all. facility communicators.
'
I
! r
RESULTS_
i ;
l
The exercise Control Room Cor..municat0r was retrained against the
requirements of the PEC.
!
Steps have been taken to make communicators more aware of the procedures. I
t
.
.
!
ACTICN THAT WILL BE TAKE!!
,.
, . - . . +
,
l Facility t.s h nicators have been scheduled to begin training against tha
j requirement of the PEC cn August 2, 1988 and is expected to be completed ,
j by October 27. 1988. f
I
t
,
I i
!
e
)
i
.
-
l
J
" e # i
i
i r
_ - . - __ _ __ _ __.-_. -_ . - . - _
_ _ _ _ _ _ _ _ _ - _ _ . - . _ _ _ . . _ _ . . _ _ . _ _ _ _ _ _ _ . _ _ _ - _ _ _ _ _ . _ _ . _ _ _ . . _ _ . .
l . '.
.
.
. . . ; _ _ . . r. l
8820 03
EEAsr : mu EFICI*'::"Y
q l :
,
w
Groblems with switching ecuipment at the telephone company caused a fuse -
1
- to blow. This resulted in a recuction in communications for 10-15 ! l
1 l
'
minutes. An individual picked up the telephone receiver to listen to j
. information being passed. This caused the circuit to be broken. !
) l r-! m:s.' i
' ACTIONS THAT HAVE BEEN TAKEli
.. . wn .. . . . . . . . .. . . ~ . . . . . . .
'
.. ~ . . ' ...: ~ ' ' - ' X :' ' c
1
CPPD telepnone system softwara was changed on June 24 1988 wnich automa- ,
titally switches calls to different trunks when they become unavailable, j
i :
Individual picking up the telephone in the Control Room it aware that
'
l
i
hanging it up breaks the circuit. .
,
-
.
-
-
.
-
g-- !
i
RESULTS
f
l
The telephone system is configured to accommodate reiiable communications
between Emergency R3sponse Facilities.
,
i
i
. ..
,
ACT:ON THAT WILL BE TAKEN~ L
t
. . . . - . . . . . . . . .4 ..6-~ s- - -
-4 ' l
v , ... -- .
A digital microwave system linking Fort Calhoun to the EOF 15 scheculed to
be c pleted prior to the outage (Sept 2mber 4 1988), g
,
. .g,a . .
-
-
- .- . . . . . . . .. . . . .
- ;
1
2-7
i
_ _ - - - . . - _ _ _ - - - ____ . . - - . - - . _ . -
. _ _ . - . -
. _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ - _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . - . . _ .
'
.
. .
.
.
i
I -
i
_.._;_.
l S?20-04
i
- PEASC
- F ^ P F F T C : "!:'"'
.
_
,- --mm~ ., -
h :
I i
l Interviews with exercise operating crew and the OPPD Exercise Controller 9
j indicate the staff did review procecure A0P-21 "Reactor Coolant System l
j High Activity," j l
.
, r L
t j 11_- ' ' .'_ i"a
l
' ACTIONS TRAT HAVE BEE!1 TAKEN
)
-
.
. .. . .-,..a........~_-- ..~-==:'u l
l !
>
i
1
,
t
- A review of the procedure indicates certain steps require evaluation. 7
- i
l
4
i
.
!
,
j ,
1
1
'
,
RESULTS f
!
!
!
! '
j Initial evaluation was completed and indicates a more thorough technical
I
review must be done,
' l
i ,
i
!
! '
.
l
i
1 +
l ACTION THAT L?ILL BE TAKEN
i
! !
-
i
e
i i
'
1
) Complete a technical evaluation of procecure AOP-?1 to determine an improv- h
!
l ed method of reacting to High Reactor Coolant Activity.
- Operators were not c'eficient in following the precedure, but ;rececure -
'
A0P-21 *111 be upgraded as a result cf the observation. I
l
1
. . l
1 !
l ;.; l
i !
l
! I
I
_ _ .
- -..- .- - _- - - - -. -_ - _. __ - -. _- - - . _. _- _.. -
',
.
. ', -
,
'
, . _-J:: -
ES20 05
4
l
'
- EAso!: enn " E r !" T rt:'"'
. .. , - . ,. .: - .: ,a y; : _. .: r,c - *'*
l . . . - . : : .- ..
. .
. . . . . .. . , -: . .
.
o
l
j Procedure EPIP 05C-2 did not cor.tain ::ecific standard notification [
'
messages, to be announcec over the public accress system warning personnel I
f of any special conditions. <
l
4
h
"
l _--,,- - _ ~- = -a
a
i.
!
l ACTIOtiS THAT HAVE BEET 1 TAKEtl
1
I \
- .. . .. . ., .
.
, . . .. .. ...--v.. .
-
. ....:. . _ ; . . .: - , ,
. .<:
r I
- Procedure EPIP-05C-2 was revised to include a standard notification mess-
age to be read by Control Room Operators over the public address system.
!
l
An evacuation drill was conducted on July 6. 1983 using these new '
announcements.
.
- -~ ,. .
. . . . . . a n. , .......,-u -
, ,
RESULTS
l
. . . . , . . . ~ . . . . - - . . . -
-- ., . . .-
i
The announcements were very effective as demonstrated by rapid evacuation
and twenty five minute accountability. These actions are documented.
The results achieved by the drill are the same as those in Item 14
ACTIO!! THAT WILL PE TAKEt3
- ... v . u .. ... . 4_.
1
'
Co;itinue to conduct accountability drills.
I
.
- -)
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
. .
. ',
.
- n i:icr.cy
8820 06
REASCt! FOR DEF!C!E! C'l
i
l
Personnel failed to relay critical information to the Technical Support
Staf f in a tin:ely manner. >!
- i,
Communication flow between f acilities and groups ties closely to Item 3. i
ACTIONS THAT HAVE BEEN TAKE!!
, , . , _
.
Control Room orders were issued to emphasize the importance of processing
technical data to support groups. A memo instructing labnratory personnel jla
g
to pass results of analyses to the HP/ Chemistry Supervisor as soon as y
possible has been distributed. ,
i
!
RESULTS
,
I,
I
The effectiveness of these actions will be 'ested in future drills.
t
l
.
'!
l
.
. ,
-,
t
ACT!O!! THAT WILL DE TAKEN
1
'
I
Complete computer information link between facilities. Implement new
procedures, assign and train personnel by December 21, 1989.
Personnel will continue to be instructed on proper communications.
l
'
Measures have been taken to maxe Rautological, Chemic31 and Systems Infor-
mation available to support groups. l
2-10
6.. ..
_ _._ _ . _ _ _
,'.,
'. .'
.
- a:L::.er.;7
.
~
.
SS20-07
FIAscN ?ca cr?trtrucY
, . . . . .
Lack of prepared guidance .aterials for timely determination l
of release rates, t
Scenario information on transients was sometimes incomplete
- . and inconsistent. ;
ACT!CNS TRAT HAVE BEEN TAKEtt
i
. _ _ ,. .. .. ._, ..
-
.
z . . . . - . . .~.. ...%.,*. ,
y I
- A procedure change to EFIP-EOF-6 was submitted pending approvel '
- providing a metnoc f or calculating steam flow out of safety valves
l at pressures < 1 100 psia.
]
.
m
! RESULTS f
I l
'
!
3
Results of completed and future corrective actions will be !
measured in the next drill.
I
i
t
i
ACT!ON TJAT WILL BE TAK2N ;
i
TSS generic guidance materials will be developed for leak rate
determinations. An incependent technical review of the scenario J
will be complete artor to f uture exercises.
TSS will . ore fully utilize :ersonnel with operatons and simulator
expertence.
..
9
'
- '1
I
- _ _ _ . - _ _ _ _ _ _ _ _ _ _ _ _ ___. . _ _ _ _ _ _ _ - _ - _ _ _ _ _ - _ - - -
_ _ _ . . _ . _ _ _ _ _ _ _ . . - . _ _ . _ _ _ _ _ _ _ . _ . _ _ . _ _ . _ . _ _ _ _ . _ . . _ _ _ .. _ . _ ____ . . _
. 1
.
- .
.
,
' :e n. ::c r.:y
.
3820-08
4
. :. . . S C :: FCP rEF!C:E!!CT
% -- e-H
i
- t
i The The Emergency c0orcinat0r inapprocriately directec *ne
cose 3ssessment personnel t0 take over the cose assessment
'
function prior to official transfer of Emergency responsibilities. )
,
.
4
!
- \
! ACT!O!1S TRAT HAVE BEET 1 TEEtt i
! :
'
I
- '
-
c
-
- tv
,__,.;,. .- . .
f
.
.
..- .
]
.
i
The three Emergency C crtinat:rs were retrained by reviewing j
- etr specific procedure requirements. ;
f
i
'
- !
.
,
!
-
l
l
i
!
RESULTS ;
i
i
l
l Measures have been taken to make the Emergency Coordinator (resp. for dose
assessment)and off site monitor teams aware of proper i
transfer of responsibilities. I
- l
,
'
l '
1
- l l
! l
,
I
I ACT!Ot1 THAT WILL RE TME?1 1
..
l
j Section 3 of the Emergency Plan, the Recovery Manager procedure,
- EPIP-RR-10, the Emergency Coorcinator Procedure EPIP-EOF-24, '
'
j anc the Responsibility .ransition pr0cedure, EPIP-EOF-14 111
'
te revise 0.
I
1
i
l ,
..
I
'
s
-
I
. ,
l _ - 1 .,
!
i
1 '
_ _ _ _ . _ - _ _ . _ _ . _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ . . ._ _______ _ _. ,,. __ ,, _ _ _ . . . . _ . _ _ _ , - . . _ , _ _ . . _ -
, .
i
. (
.
$* .
.
- m = r.::
i
j E20- 0 9 \
l
l REASO!! MP " E F T E NG
. ;; , w _- ...
.....;.-
-
.
.- - -
,
. , . . . .. .
i
' The Cose Assessment Coerators mace an inappropriate entry int:
the 00se Assessment program causing overly conservative estimates i
l
of cownwinc exposures.
,
1
'
..
. . . .
s. . . ~ n . . a. ,3
.
_
ACT!CNS THAT HAVE BEEN TAKEN, j
i !
( .
,
- y .. - .
- . 7
...; ... .
.
r
l
The Procecures EPIP-EOF-6 and 01-PAP-8 were revised, pending !
I
PRC approval, adding flow curves to cetermine mass steam flows
at pressures celow < 1000 psta.
1
I
i
, *
I
,
r
a
!
RESULTS I
i ,
, . ,
i
l
!
! This chart will provide for more accurate estimates of downwind ,
! exposure. The effectiveness of these measures will be evaluatec l
} in future crills.
r
!
i i
i
f
1
l ACT!ON THAT 'a'ILL BE TAKEN
I
! '
I '
The actions *nat have been taken at this *ime are believed to '
i be suff!cten; to correct ne croblem.
.
e
l
l
J
i
, ,,~
,,
i
.
. I
,
- -13
i
---. _ _ . . . _ . _ _ _ _ . _ _ _ _ . - - ___ _
. _ . . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ - . _ _ _ _ _ _ _ _ _ - _ _
, .
-
I
j . -
.
J
'A
,
'
.
-
-
ce f :_e..:/
SB20-10
I
i
- Tne Emergency Ccorcinat:r failed :: 'Oll:w :ne trtnsttien !
', procedure EPIP-EOF-14 Dose Assessment courat:rs fallec l
to immeciately use the default parameters, 1
j
.
1
-
ACTIOt1S TRAT RAVE BEE!! T;.XEtt .
i
i
l
l
,
i
'
1
I
'
i
I,
Dose assassment supervisors nave been retrained on their specific l
i procecures. A procecure change to EPIP-EOF-6 with flow curves ;
'
l.
nave been submitted to PRC.
I !
.
l l
! !
1 .
,
i
RESULTS
,
'
.
L
l
I
The assessment personnel have br.en reinstructed by memorandum l
,
l
to e'.ipnast:e completing dose assessmon- as quickly as possible ,
'
'
so PAR's are issued within 15 minutes.
l 1
l .
l
f .
1
1
! ACTION ? RAT WILL BE TAXE!!
.
'
I
i
'
! The acti:ns have been taken are believed to be sufficient to ;
l
,
- orrect tne orcelen. .
.
1
i
i
,
- .
- .; '
l
1
l
'--_-__ - . . - . _ _ _ . __.__ - . - -
_
I .
, ,
.
,
,
.
,
.
.
% .. :. :.- :-
8820 11 and 8820 12
F E Aso!! FOP 9 E F :"! F::r
I
.....~.:~~...- , . :. : : J .i. Q:=.t. c . ..
,' r-wa w. - ._ . . . . . . . . ..
1
l The procedure for Monitor Coordinators Basic Resoonsibilities, are not
i specific for providing criefings to teams reentering evacuated areas of I
the plant. Deficiencies S820-11 and 8820 12 are closely related and, i
! ,
therefore, reasons for deficiencies are closely related.
- ..
,
I
i
! ACTICtlS THAT HAVE BEEll TAKEll
il
~.-
'
' . ' ' # '
.\p* - '
' '
' ' ' ' ' ' - ' '
g.g, 4, j
- -
,
l ,.y,,, ,.
j
! The use of proper entry procedures, EPIP OSC 9 and EPIP RR 3, and a craft !
of a new procedure, EP!P 0CC 20, was reviewed with the Monitor j
,
Coordinators,
! I
l -
i l
'
l
1
RESULTS. l
! .. l
-
- ,. ...
,. .
.
. l
.
. .
,
) Monitor Coordinators were provided additional training en procedures and t
would be expected to .se these procedures during an emergency situation, f
i
< '
i
l
- . . . - - . t
l . , . ., . . . . . .
I !
l ACTIO!! THAT WIr *, BE TAKE:J
i
....-
r- - . . ,=md -
1 '
A r.cw procedure, EPIP 05C-20, "Radiation Protection Guidelines - Emergency
'
(
- Concitions," is currently being developed to provide a more organ):ec ;
! rethod of referencing atorepriate procecures recuired for briefing, precar- !
l ing and trackino reentry teams. I
i
i
I
i
I
'
I
l l
'
- .,c
4 l
I ,
- * .
.
-o
'
l
.
. . . . . . :. ';
SS20-13
P E A e ru.' op EE:":Ency
i T ._ .. . .
'
c.w. w. e . . . . --a-' ~~ ).-~ . . - - . - A . 's ' . i- 'd ' = - : ' F ' ' '
'
i The escue Team members were poorly prepared and did not have adecuate
j supplies to cope with this emergency in a steam atmosphere. Voice
- ampilfication ecuiement is currently not part of the Fort Calhoun Station
5
Respiratory Protection Program. i
+
', }
, ,
i '
i
! ACTIONS THAT HAVE BEEN TAKEN
l
< ,
.
I
J
l
l
l 1. Four steam suits are being procured !
f
f 2. Formal first aid training is being transferred to Nuclear Operations {
'
Emergency Preparedness and Radiation Protection have contacted vendors
'
f 3.
l for samples of SCBA communication equipment
,
! .
'
\
l RESULTS_
'
Pl
1 i
'
j Additional first aid eculpment is being procured. The results of these
{ actions will be demonstrated in future drills.
I
l '
l
! )
I !
ACT!ON THAT WILL BE TAKEN ]
.. ,
,
l ;
i
1
I r eriency Netaredness aill add basic contamination control and frisking 8'
prac' ices to the reentry team member training. l
l '
t
I
l
l
- i
!
!
2- 10
l
l
f
-. ._ _ __ - - - . - - . - .- - . - . . . -
I .
-
I.
- .s
.
g
- .
. .-
3320-14
7 E A F rN r an - r r : E E:"?
--
-
.
_ _ _ - _
1
Personnel f ailed to immediately evacuate when the fluelear Emergency Alarm !
)
sounded.
.
- x- -. m = = , = - ==3 D ' ? ?r = ^ - - >
--
i
~ -- - ~ ,c - .; _ - , = _ . - - - _ _ _
.--_--
ACTIONS THAT HAVE BEEN TA}:E!!
,
1
Standard notification messages were added to procedure EPIP OSC-2,
i
i
f
4
l
1
RESULTS_
l
! An accountability drill was conducted and evacuation with accountabilities
was achieved in twenty five minutes.
l
I
ACTION THAT WILL BE TA};EN 8
. . _ . . . $ . : . . v .ss . .. - . . -
.
.... -4.
!
,
.
-
Conduct attitional accountability drills. Modify Nuclear Emergency Alarm i
I'
System to 1 prove the coverage 3rea offsite.
l
!
!
' ' l
\
.
. .
. : . . , ~ . . . .L . .. . .e - - ,
1
- !
.'. - 1 '
i
l
)
_ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _
/
6..
.* *
.
-
.
, ,
s%
i
l
- e n::.c r.:y l
. t
( 8820-15
l R EAso?: tor rEF: :E!:07
i
~
__ ; y - u n .-, ...,
1) The ::mplexity of the scenario was n0 actcuately accressed. l
!
2) We cic no: cecicate enough resources.
- 3) Inaceouate planning of aeveloping the tecnnical cata re
- :uired -
l
l for One scenario.
! ,
l
l
ACT! Offs THAT RAVE BEE?f TAKE!1
!
'
,
i
I
. - - - . , W m > > . . ,, . . . e - -- ~. . .
- .. + .
.. . ~.<~.. ...-4 ,*.-Y .
,
i j
i
i l
,
- Urgent corrective actions- not requirec at this time. ,
'
t , :
I i
1
4
i
-- . . - - . _ , - - - , . - - .- '.,
l ,
,
l R E S t.",,T S
,1
'
l
1
l l
i
.
- l
I
i
- None at this time. !
1
,
a
1
i
t
1
l
ACTION "HAT WT!.!, BE TAKE!!
.
,
I
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) 1) The scenario development group will be organi:ed 9/1/88.
j 2) Decicatecresources inclucing contrac nelp stil be cevotec ;
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3) The scenario a ti! :e testec using :ne ;E simula :r anc incep;n ;
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FORT CALHOUN STATION
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1988 EXERCISE DEFICIENCIES
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NRC OPPD
DEFICIENCY IDENTIFIED ROOT CAUSE ,
8820 01 X PROCEDURE
8820 02 X TRAINING
8820 03 X EQUIPMENT / DESIGN / HUMAN
8820 04 PROCEDURE
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8820 05 X PROCEDURE ,
8820 06 TRAINING / HUMAN
8820 07 X PROCEDURE / SCENARIO (
8820 08 X HUMAN / PROCEDURE i
8820 09 X PROCEDURE [
8820 10 X PROCEDURE -
8920 11 SECONDARY PROCEDURE / TRAINING
8820 12 SECONDARY PROCEDURE
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8820-13 SECONDARY EQUIPMENT / TRAINING ;
8820 14 X PROCEDURE !
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8820 15 SECONDARY SCENARIO
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STAFFING OF l
EMERGENCY !
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FACILITIES X PROCEDURE /TRA!NING
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l RECOVERY MODE [
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OPERATING PROCEDURE X PROCEDURE
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! PROJECTION PROCEDURE X PROCEDURE i
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- HARRISON COUNTY
ANS INITIATION X EQUIPMENT / PROCEDURE
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. OPPD agrees with the NRC that the Fort Calhoun Station Emergency Preparedness
program did not demonstrate improved capabilities frcm previous performances.
The deficiencies here identified either nave been corrected in a short term fix
or will be improved by actions requiring additional effort.
Our internal critique identified approximately 75 weaknesses and corrective
actions have begun on these items as well. One item from the exercise review is
that CPPD has made improving the method and procedures for coordinating with the
NRC during the recovery operations mode an important improvement task. These
deficiencies identified by OPPD during its internal critique will receive
attention comparable to the NRC identified deficiencies.
We believe the number of deficiencies resulted because there were some generic
weaknesses within the program which we had not fully recognized, and that the
very difficult situations designed into the exercise test served its purpose by
identifying them. With this basic knowledge we are scrutinizing the total
program and plan to strengthen our emergency response effectiveness accordingly.
Therefore, in order to accomplish this improvement while resolving the specific
deficiency corrections, OPPD will review the individual components of Emergency
Planning to identify generic weaknesses.
First. prior to reassignment of personnel to emergency positions on October 1,
1988, an extensive evaluation of emergency staffing will be conducted to improve
the assignment of emergency duties of personnel to more closely reflect their
regular functions. The basis is establishcd in the new CoPD organization which
was effective July 1, 1988.
The following improvement is a major task commitment. The Emergency Preparedness
Training program does not presently conform in structure with all other training
programs at Fort Calhoun Station. The District will evaluate Emergency
Preparedness Training and upgrade to a performance based program. Completion
date is expected to be June 30, 1990.
Next, the Emergency Plan Implementing Procedures (EP!P's) will be evaluated and
improved as needed. Our schedule will be submitted in our formal response to the
inspection report.
To address equipment, the Emergency Planning Department will evaluate and
coordinate a project to identify and place into a surveillance program important
personnel protective equipment for responding to radiological emergencies. A
schedule will be submitted in our formal response to the inspection report.
In closing, OPPO believes that the present program is able to perform sufficient
onsite and offsite emergency functions. It is our commitment to correct the
identified problems. We will also evaluate and initiate other improvements as
needed to prevent degradation, to demonstrate proficiency and to maintain
effective responsibilities of our emergency preparedness program.
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Closing Remarks - S. K. Gambhir i
In your opening remarks you asked us to address the following four items:
1. Individual items and responses
2. Look at the collective nature of these deficiencies
3. Kind of conclusions we have drawn
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4. Reason for repeat deficiencies
In our presentations so far, we have addressed each of the above items except i
item 4 We have discussed this at length and we believe the reason is the '
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band aid approach that we were using earlier. The commitments that we have
made today are aimed at fixing root cause of the problems. Some of you might
know that we are in the process of implementing recommendations from Stone and
Webster's appraisal. The objective is to improve our overall performance. The
emergency preparedness goes beyor.d one department and the improved performance ;
in other areas is bound to improve cur performance in this area. ,
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Our goal is to achieve a SALP rating of one in the very near future and we will ;
be working hard to achieve this goal. '
We will continue to monitor the program through drills and plan to provide you :
with a status report prior to the next exercise. :
I thank you for your time and we will be glad to answer any questions.
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