ML20209J511
| ML20209J511 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 01/28/1987 |
| From: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 LIC-87-059, LIC-87-59, NUDOCS 8702060338 | |
| Download: ML20209J511 (6) | |
Text
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l Omaha Public Power District 1623 Harney ornaha, Nebraska 68102 2247 402/536 4000 January 28, 1987 LIC-87-059 U. S. fluclear Regulatory Commission Document Control Desk Washington, DC 20555
References:
1.
Docket flo. 50-285 2.
Letter tiRC (J. E. Gagliardo) to OPPD (R. L. Andrews) dated December 22, 1986. (Inspection Report 50-285/86-20)
SUBJECT:
Schedule to correct deficiencies identified in Inspection Report 86-20 Gentlemen:
Omaha Public Power District (OPPD) received Reference 2 which forwarded the results of a special appraisal conducted to verify completion of the Fort Calhoun Station Emergency Response facilities (ERF).
The appraisal further intended to conclude that the related requirements in Supplement I to flVREG-0737 were met.
The appraisal identified 14 deficiencies.
Pursuant to the Reference 2 request, the attachment to this letter provides OPPD's schedule for correcting the identified deficiencies.
If you have any questions, please contact me.
A R. L. Andrews Division Manager Nuclear Production RLA/me Attachment c:
LeBoeuf, Lamb, Leiby & MacRae 1333 flew ilampshire Ave., fl.W.
Washington, DC 20036 J. E. Gagliardo, flRC Region IV Director A. C. Thadani, NRC Project Director W. A. Paulson, NRC Project Manager P.11. liarrell, NRC Senior Resident Inspector f
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Deficiency 285/8620-01 The licensee failed to establish a routine testing program for the TSC atmospheric filtration system to adequately verify that the design criterion filtration efficiency was being maintained.
Response
Fort Calhoun Station will investigate the testing requirements, prepare and perform appropriate tests to ensure adequate filtration efficiency is maintained. 1his will be completed by July 31, 1987.
Deficiency 285/8620-02 The number of portable dose rate survey instruments provided were insufficient to support the radiation monitoring functions assigned to the TSC and OSC.
Ecipe Five additional survey instruments have been purchased and are in use.
Deficiency 285/8620-03 The number of scif-reading pocket dosimeters was insufficient to support radiation monitoring functions assigned to the TSC and OSC.
8919M The number of self-reading pocket dosimeters in the TSC/OSC has been increased to a total of 171. These dosimeters are now in use at the TSC and OSC. The number of self-reading pocket dostmeters are now sufficient to support radiation monitoring functions assigned to the TSC and OSC.
Deficiency 285/8620-11 Meteorological data, appropriately averaged for use in dose assessment, were not available in the Control Room, TSC or E0F.
EUPM fifteen minutes averaged meteorological data will be available from the ERF computer after the 1987 refueling outage at the fort Calhoun Station. A l
program to calculate dispersion factors (X/Q) is being prepared for impicmenta-tion on the ERF computer during the 1987 outage.
This program will uttilze 15 minute averaged meteorological data.
The data will be made available and displayed on the form FC-197 computer display.
Completion is expected by June i
30, 1987.
Deficiency 285/8620-12 The dispersion model utilized by the licensee inconsistently treated releases from the Auxiliary Building stack as elevated in some atmospheric conditions and ground-level in others.
Response
This item has been resolved. The dispersion model has been revised and now treats all releases as ground-level, regardless of atmospheric conditions.
This revision will treat releases from the Auxiliary Building stack in a consistent manner.
Deficiency 285/8620-13 The licensee failed to use a sophisticated realistic model in dose assessment calculations (i.e., segmented-plume model) and made no use of tabular and graphic options available through the EAGLE program.
In addition, the EAGLE program verification was not completed.
Response
Initially, the EAGLE program segmented-plume model results were utilized during an evaluated emergency exercise for protective action recommendations (PAR's).
Correlation between those results and results from NRC and State dose assess-ment calculations was relatively poor. Therefore, in the interest of good correlation of calculational results, OPPD changed to a more simplistic dose assessment model and has continued in this mode.
Prior to reimplementation of the segmented-plume model for PAR's there are three tasks which should be completed:
Either plume centerifne doses or doses at discrete special interest receptor locations should be the criteria. OPPD will lead this endeavor, but the final success is contingent on agreement of the other parties.
- 2) OPPD needs to complete the verification of the segmented-plume model.
- 3) The parties performing dose assessment calculations should all use models i
of equivalent sophistication (i.e., segmented-plume models).
Contingent upon agreement of all parties, reimplementation of EAGLC's segmented
-plume model will be completed by June 1, 1988. This date will allow sur-ficient time for the parties involved to agree upon a dose assessment 4
i methodology, revise procedures and practices relevant to development of PAR's, conduct training on the new procedures, obtain a model (if necessary) using the agreed upon methodology, revise the backup method that is now based on Straight l
-Line Gaussian, and complete verification of models and the backup method.
Until such time as the segmented plume methodology is adopted, OPPD will continue to use the ) resent method (i.e., Straight-Line Gaussian).
The verifi-cation of the Stralgit-ilne Gaussion method is in progress and is expected to be complete by February 27, 1987.
Deficiency 285/8620-13 (Continued)
Additional equipment is on order to permit utilization of the tabular and graphic options available in EAGLE. Receipt is expected soon and will be utilized when plume follow is implemented. This effort will be completed at the same time that the segmented plume model is reimplemented.
Deficiency 285/8620-14 Readily available records to evaluate historical data recovery performance of meteorological instrumentation were lacking.
Response
OPPD believes that the question / deficiency concerned verifying that 90% of the meteorological data was available. Calculations are done when the semiannual report is written that determine availability. When the meteorological tower is not functioning, data is extrapolated from other meteorological sources so that OPPD does have 90% availability of weather data.
In the future, when data is extrapolated, the percent that is extrapolated will be reported in the semiannual summary that determines a percent recovery of valid data for each month and an annual percent value.
Deficiency 285/8620-15 Procedures for dose assessment failed to consider scenarios where a release of radioactivity to the environment was eminent.
Response
A manual calculation method will be developed to resolve this item by August 15, 1987. At the present time, the EAGLE program does not have the capability to model scenarios where a release is not in progress.
Provision to include the capability for EAGLE to model scenarios when a release of radioactivity to the environment is eminent will require program additions, testing, verifica-tion, procedures, training and documentation. Program modifications to allow computerized calculation by the EAGLE software will be complete by June 1, 1988. This date is concurrent with the commitment for completion of the segmented plume option. We intend to use the Gaussian model and backup calculations which are validated and verified until the segmented model is implemented.
Deficiency 285/8620-16 Procedures lacked adequate guidance for obtaining meteorological data in the event of a partial or complete failure of the ERF or of the Fort Calhoun meteorological system.
EDIP101H Emergency Plan Implementing Procedures EPIP-0SC-16, EPIP-RR-63 and EPIP-RR-72 have been revised to include procuring meteorological data from the U.S.
Weather Service as an alternate method to fort Calhoun Station measurements.
4 D
Dbficiency 285/8620-17 Formal maintenance logs on the ERFCS have not been kept since the OAD test concluded in November 1984.
Response
A formal maintenance log on the ERFCS is now being kept and updated from a maintenance log book. The log date began May 1,1986 when the SPDS and ERFCS were officially declared operational.
Deficiency 285/8620-18 System unavailability calculations have not been made and recorded since November 1984.
ResDonse A procedure will be developed by October 31, 1987 to provide guidance for calculating system unavailability.
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Deficiency 285/8620-19 The Licensee failed to obtain site director or recovery manager signature authorization prior to transmitting protective action recommendations as required by 10 CFR 50, Appendix E, paragraph IV.A.2.C and guidance of NUREG-0654, II.B.4.
(This is a repeat item from earlier exercises and most recently identified in NRC Inspection Report 50.285/86.11.
The deficiency applies to both TSC and E0F).
I ResDonse i
?'
Emergency Implementing Procedures EPIP-RR-69 and EPIP-RR-73 have been revised to ensure that the Recovery Manager's or Site Director's signature has been obtained and verified prior to issuance of protective action recommendations.
Deficiency 285/8620-20 The licensee has not demonstrated that the OSC can be operational within about I hour.
Response
OPPD is evaluating and clarifying what constitutes the minimum staffing of the OSC to correlate the requirements of Table B1 in NUREG-0654 for one hour actuation. The call list is being reorganized so personnel required for minimum staffing have priority notification.
In addition, the phone notification has been supplemented with an offsite facility to expedite initial notification of OSC personnel.
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Deficiency 285/8620-20 (Continued)
Corrective actions will be implemented by procedure change by March 1,1987.
They will be demonstrated during 1987 Spring drills, with the final evaluation during the July 1987 Annual Emergency Exercise.
Deficiency 285/8620-21 An insufficient depth of trained personnel was provided in their emergency organization to ensure the ERF staffing will be adequately staffed during long term emergencies.
Response
OPPD has added 3 persons to the Emergency Response Staff so that at least two in.dividuals are assigned to each designated emergency position.
In addition, most of the more responsible positions have more than two trained persons to satisfy staffing. OPPD continues to evaluate emergency response positions for adequate staffing at least quarterly.
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