ML20212B224

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Responds to NRC Re Violations Noted in Insp Rept 50-285/85-16.Corrective actions:non-util Emergency Preparedness Persons Will Be Used to Address Internal Inconsistencies in Preparation of 1986 Exercise Scenario
ML20212B224
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 10/24/1985
From: Andrews R
OMAHA PUBLIC POWER DISTRICT
To: Johnson E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20212B193 List:
References
LIC-85-484, NUDOCS 8612290201
Download: ML20212B224 (6)


Text

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g Omaha Public Power District 1623 Harney Omaha. Nebraska 68102-2247 gg g

402/536-4000 L I~~ g j

OCT 29 085 October 24, 1985 L IC-85-484 yg i

a Mr. E. H. Johnson, Chief Reactor Projects Branch U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011

Reference:

Docket No. 50-285

Dear Mr. Johnson:

IE Inspection Report 85-16 Emergency Plan and Procedures Deficiencies OPPD received the subject report dated Septonber 19, 1985.

This report iden-tified deficiencies in the emergency praparedness program observed during the emergency exercise. Please find attachcd OPPD's corrective action and sched-uled completion dates for the deficiencies noted.

Si ncerely,

p/

f ( l,*Lhip &

R. L. Andrews t

Divi sion Manager Nuclear Production RLA/Hf1T/rh Attachnent cc:

LeBoeu f, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.

l Washington, DC 20036 Mr. E. G. Tourigny, NRC Project fianager Mr. P. H. Harrell, NRC Senior Resident Inspector 8612290201 861219 PDR ADOCK 050002a5 O

PDR

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OPPD has reviewed the deficiencies noted in IE Inspection Report 85-16 and has prepared the following response. Each response identifies the corrective ac-tion to be taken to correct the deficiency and the target date when the action will be complete. Corrective actions for a number of the deficiencies are com-plete and are so noted.

1.

NRC Open Item Internal inconsistencies and lack of completeness in the scenario data and instructions for players and controllers resulted in various in-stances of unnecessary simulation, coaching and lack of realism. As a consequence some exercise objectives were not adequately demonstrated.

(285/8516-01)

District Response OPPD will utilize non-0 PPD emergency preparedness persons to address these concerns in the preparation of the 1986 scenario. The scheduled cmpletion date for this item is May 1,1986.

2.

NRC Open Item Initial notification with appropriate descriptive contents, including whether a release was taking place, potentially affected population and areas, and whether protective measures must be perfonned within 15 min-utes after declaring an emergency, were delayed up to 50 minutes or not made at all as in the case of Harrison County Emergency Operations Center (E0C), and Iowa State Forward Operating Location at Logan, Iowa.

(285/8516-02)

District Response Procedures will be reviewed and revised, training and drills will be pro-vided, and additional steps will be taken as necessary to ensure 15 min-ute initial notification requirenents can be demonstrated. The sched-uled completion date for this item is prior to power operations after the 1985 refueling outage.

3.

NRC Open Item a.

The transnission by telefax of technical data during the notifica-tion process included protective action recommendations (PARS) which had been automatically generated by the cmputer but had not j

been approved by the emergency coordinator (Recovery Manager).

District Response I

Procedures will be reviewed and revised to ensure emergency coordinator approval. The scheduled completion date for this item is prior to power operations af ter the 1985 refueling outage.

4 NRC Open Item b.

In addl tion, these PARS did not take plant conditions into consid-eration.

(285/8516-03) i i

i t

District Response OPPD does consider plant conditions when making protective action recm-mendations and these considerations were done during the exercise.

Corrective action for this iten is emplete and no further action is required.

4.

NRC Open Item Written notification procedures were found to be organized in a manner which did not lend themselves to providing technical information content to of fsite authorities. Furthemore, written procedures did not reflect the licensee staff's actual notification practices during exercises.

(285/8516-04)

District Response Procedures have been reviewed and revised and training and drills were provided to ensure proper notifications are perfomed. Corrective action for this iten is emplete and no further action is required.

5.

NRC Open Item The licensee failed to respond to release rate calculations in the con-trol room indicating extremely hazardous radiological conditions that would have required a general emergency classification. Technicians per-forming the calculations, yielding 8.22 E13 Ci/sec, failed to recognize this as a physically impossible release rate for cmmercial nuclear power plants.

In addition, the individual failed to communicate these results prmptly to the Shift Supervisor, who at that time was acting as the emergency coordinator.

He in turn failed to recognize the unlikely nature of the data, and it was not until 33 minutes af ter the initial results were at hand that an assistant reactor operator requested veri-fication of this calculation. (285/8516-05)

District Response Successful training and testing of all C/RP Technicians was perfomed during the period August 30, through September 4,1985. Testing is documented in FC-C-073-85 report dated Septenber 9,1985. Corrective action is complete and no further action is required.

6.

NRC Open Item Infomation frm within the TSC was not sufficiently prmpt to allow the efficient handling of accident conditions. For example, the average of a sample of six observations, showed that it took 21 minutes frm the time data were received from the control roon to the time the status board was updated. (285/8516 06)

District Response Two problems contribute to this deficiency.

a.

The first problem is a drill induced problem pertaining to times recorded on the cue cards with relation to the actual time that infonnation is being transmitted to TSC and EOF for posting. A review of the present system will be made and a quicker method devel oped.

b.

The second problem is created by the personnel doing actual posting of the status board. Additional emphasis for Emergency Tean Tag #1 will be placed on posting of the status board and keeping the "AS OF" time and date current. The scheduled canpletion date of these itens is May 1,1986.

7.

NRC Open Item The analysis of events by the technical staff at the TSC was not always adequate. For example, at one time the status board indicated an in-creasing pressurizer level although the leak rate was greater than the charging rate; this inconsistency was not questioned.

In another case, the TSC staff failed to utilize isometric dravings at hand in attenpting to determine the correct valve line-up needed to isolate the loss of coolant. This caused a delay of 30-45 minutes, and resulted in an im-proper valve line-up recommendation being forwarded to the control rom.

(285/8516-07)

District Response Training of technical staff in abnonnal configuration and appropriate response to status board information is being evaluated. After completion of training, drills will exercise the staff in making proper evaluations of events. The scheduled completion date for this item is April 1,1986.

8.

NRC Open Item The base radio used to conmunicate with of fsite teans was found to be in-adequate. As a consequence, directions and information flow between off-site teams and personnel in the TSC was disrupted, depending on loca-tion. Similar problems were observed when attempting to communicate with their supervisor in the security building. (285/8516-08)

District Response The radio battery was found to be defective and was replaced. The radio now functions properly. The corrective action is complete and no further action is required.

9.

NRC Open Item The NRC inspector noted that the medical scenario indicated a lack of training of site personnel in tasks requiring a combined expertise of health physics, first aid and rescue operations..... 0bservations in these areas indicate a deficiency in training and qualification for health physics and first aid personnel, and inadequate first aid equipment. (285/8516-09)

P.

District Response The following actions will be taken to correct the deficiency.

a.

Health physics personnel are now assigned to perform sample count duties and are familiar with proper prccedures.

b.

Training manual lesson plans for onsite monitor teams will be revi sed.

c.

Personnel required to receive First Aid Training have been identified and will receive required training.

d.

Emergency first aid kits have been ordered and will be pre-positioned in the control room and TSC.

The corrective action for iten a. is conplete and no further action is required. Corrective action for items b. and d. is scheduled to be canpleted by Decenber 31, 1985. Corrective action for iten c. is scheduled to be completed by May 16, 1986, 10.

NRC Open Item The NRC inspectors observed that of f-site team actions were greatly im-proved from previous performances. However, they failed to properly label each sample with location, date, time and nane of the person con-ducting the survey. The environmental monitoring teams consistently placed filter cartridges and filter paper in individual plastic bags without identifying each of them. Samples were then placed in a larger bag and this bag was carefully labeled. Failure to identify each indi-vidual sample bag could result in the loss of sample identity upon re-moval and separation prior to analyzing then. (285/8516-10)

District Responses The monitor who failed to label individual samples was retrained within four hours after the exercise.

Instructions were sent to all offsite monitor team persunnel with specific instructions for tagging samples.

The corrective action for this item is complete and no further action is requi red.

11.

NRC Observed OPPD Critique Item The description in written procedures of the Operations Support Managers duties, responsibilities and place within the organizational structure, were not consistent with observed practices nor with the responsibili-ties of the shif t supervisor.

District Response Duties will be stresscd during training of the Operations Support Mana-ger and that his duties are different than those of the shift super-vi so r.

The scheduled completion date for this iten is Decenber 1,1985.

12.

NRC Observed OPPD Critique Item The technical support center staff was not aggressive in attepting to evaluate core damage. This was partially the result of not having ade-quate means for estimating core damage in lieu of taking a post accident sample.

District Response OPPD will develop a new procedure that does not require post accident samples for making decisions. The scheduled completion date for this item is April 1,1986.

13.

NRC Observed OPPD Critique Item Accountability was not demonstrated to be prompt. Establishing the whereabouts of 132 persons onsite took 48 minutes. This is contrary to the guidance of NUREG-0654, II.J., which states that accountabili ty should be accmplished within 30 minutes.

District Response OPPD has reviewed the accountability procedures and believes these pro-cedures are adequate as written. The basic problem was the large number of persons who were onsite but exempt from participating in the exer-ci se. The number of exempt personnel will be reduced in future exer-ci ses. Corrective action for this iten is complete and no further ac-tion is required.