ML20212K028
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| ML20212K028 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 08/08/1986 |
| From: | Baird J, Yandell L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20212K020 | List: |
| References | |
| 50-285-86-19, NUDOCS 8608190028 | |
| Download: ML20212K028 (12) | |
See also: IR 05000285/1986019
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APPENDIX
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- ', U.S. ' NUCLEAR REGULATORY COMMISSION
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REGION IV
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NRC Inspection Report: 50-285/86-19 License: DPR-40
Docket: 50-285
Licensee: Omaha Public Power District (0 PPD)
1623 Harney Street
Omaha, Nebraska 68102
Facility Name: Fort Calhoun Station (FCS)
Inspection At: Fort Calhoun, Nebraska
Inspection Conducted: June 24-28, 1986
Inspector: duA \ I E![[#
J.1r. Baird, NRC Team ~Le er Da'te'
Other
Inspectors: B. Bartlett, RI, RIV NRC
R. Hogan, OIE NRC .
L. Rathbun, Pacific Northwest Laboratories
G Bryan, Comex Corporation
Approved: , E!f/fh
L. A. Yandell, Chief, Emergency Preparedness Dat'e '
and Safeguards Programs Section
Inspection Summary
Inspection Conducted June 24-28, 1986 (Report 50-285/86-19)
Areas Inspected: Routine, announced inspection of the licensee's emergency
response capabilities during an exercise of the emergency plan and procedures.
Results: Within the emergency response areas inspected, no violations or
deviations were identified. Five emergency preparedness deficiencies were
identified by NRC and contractor inspectors.
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DETAILS
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1. Persons Contacted
Principal OPPD Personnel
*R. Andrews, Division Manager, Nuclear Production
L. Borcherding, Quality Assurance Inspector
C. Brunnert, Supervisor, Operations Quality Assurance
*A. Christensen, Health Physicist
M. Core, Supervisor, Maintenance
R. Cords, Senior Chemistry / Radiation Protection Technician
T. Epley, Engineer
*F. Franco, Manager, Radiological Health and Emergency Preparedness
*G. Gates, Manager, Fort Calhoun Station
*J. Gasper, Manager, Administrative Services
*M. Gautier, Manager, Media Relations
M. Hultman, Pipe Fitter
R. Hyde, Supervisor, Maintenance Training
*R. Jaworski, Section Manager, Technical Services
*K. Morris, Division Manager, Quality Assurance and Regulatory Affairs
*C, Norris, Supervisor, Radiological Services
G. Parrish, Operator, Auxiliary Building
*T. Patterson, Manager, Quality Assurance
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*G. Roach, Supervisor, Chemistry and Radiation Protection
B. Schmidt, Chemist
*H. Sterba, Division Manager, Corporate Communications
*K. Stultz, Technical Services
Contractor Personnel
J. Andrews, Hydro Nuclear
D. Bloemendaal, Hydro Nuclear
T. Jackson, Hydro Nuclear
State of Nebraska
H. Borchert, Department of Health
R. Medina, Civil Defense Agency
Federal Emergency Management Agency
R. Leonard, Regional Assistance Committee Chairman
M. Carroll, Senior Technological Hazards Specialist
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-NRC Personnel
*P. Harrell, Senior Resident Inspector
Other OPPD, state, and contractor personnel were also contacted during
the. inspection.
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* Denotes those present at the exit interview.
2. Licensee Action on Previously Identified Deficiencies
(0 pen) Deficiency (285/8516-01): The NRC inspector noted that the ,
scenario was improved in the areas of completeness and instructions for
players and controllers; however, internal inconsistencies in plant
systems status and source term impacted demonstration of scenario
objectives. This item remains open.
(Closed) Deficiency (285/8516-02): The NRC inspector determined that
initial notifications to offsite agencies from the control room were
adequate and sufficiently timely. This item is closed; however, a similar
deficiency was observed in the emergency operations facility during this
exercise (see paragraph 7).
(Closed) Deficiency (285/8516-03): The NRC inspector noted that
protective action recommendations released by the control room were
performed and approved in accordance with procedures. This item is
closed.
~ ~ (Closdd) Deficiency'(285/8516-05): The NRC inspector noted that control
_ room: personnel did respond according to procedure and when a release rate
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was calculated withLa result of 1 E-8 Ci/sec but was transmitted as
1*E+8 Ci/sec, personnel in both the technical support center (TSC) and
, control room reccgnized the impossible number. This item is closed.
(Closed) Deficiency (285/8516-06): The NRC inspector noted that
.information flow in the TSC was sufficiently prompt to allow the efficient
handling of accident conditions. This item is closed.
(Closed) Deficiency (285/8516-07): The NRC inspector determined that the
analyses of events by the technical staff in the TSC were proper and
adequate. This item is closed.
(Closed) Deficiency (285/8516-08): The NRC inspector noted that radio
communications with offsite field monitoring teams were adequate. This
item is closed.
(Closed) Deficiency (285/8516-09): The NRC inspector observed that first
aid practices had been improved and determined that a new stretcher with
security straps had been ordered. In addition, the health physics related
observations during the previous exercise were adequately addressed
although other radiation protection problems were identified during this
exercise (see paragraph 6). This item is closed.
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_ .(Closed). Defic eh (285/8516-10): The NRC inspector determined from
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exercise observers that the offsite monitoring teams properly identified
y'(- c , samples.';This item is closed.
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3. ~ Exercise Scenario ,
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p, j MThe_0 PPD exerciseiscenario was reviewed prior to the exercise to determine
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that. provision-had been made for the required level of participation by
state and local agencies, and that all major' elements.of emergency
;- g ;, response would b'e exercised by OPPD in accordance with the requirements of-
fN7 10'CFR-50.47(b),310 CFR'Part 50, Appendix E, paragraph IV.F, and the
y% guidance criteria =in.NUREG-0654, Section II.N.
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Comments from'this review were transmitted to the OPPD scenario committee-
, chairman prior'to'the inspection date and each of the comments were
addressed prior to the exercise. The scenario was considered to be much<
Jimproved over the previous exercise in terms of completeness of scenario
data and instructions for players and controllers; however, during this
exerr:ise, scenario inconsistencies which were not detected in the scenario
review impacted the demonstration of objectives.- The most significant -
problem was an error of approximately two orders of magnitude too large
for the radioactivity release source term. This conflicted with core
damage assessments and offsite monitoring data, and resulted in
significant problems in formulating and making protective action
recommendations. The presence of internal inconsistencies'was an element
in the deficiency (285/8516-01) identified during the previous exercise,
and therefore, additional corrective actions must be implemented to close
this emergency preparedness deficiency. l
No violations or deviations were identified.
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4. Control Room
Initial conditions were provided to the control room staff assigned to
respond to the simulated emergency at approximately 5:40 a.m. by the
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controller, and the exercise was initiated with a seismic event centered
south of the station which damages the 345 kV southern grid lines. This
resulted in declaration ~ of a Notification of Unusual Event (WOUE) by the .
licensee at approximately 5:45 a.m. ;
An Alert was subsequently declared at approximately 6:10 a.m. due to
detection of a decrease of containment pressure and the elevation of stack
flow and radioactivity indicating the. loss of one fission product barrier.
At approximately 9:15 a.m., a Site Area Emergency was declared resulting
from damage to the station from a second, more severe seismic shock. :
Following the seismic shock, all offsite power is lost, one of the diesels
fails to start, and a leak in containment results in a high containment
radiation monitor alarm. This indicates the loss of two fission product ,
barriers. In the same time frame, a maintenance technician working on the ,
containment purge valves was injured and contaminated, requiring first aid '
and rescue team support.
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Plant conditions continued to deteriorate with an increase in the leak
rate and radioactivity release. At approximately 10:15 a.m., a General
Emergency was declared based on the loss of two fission barriers and the
projected loss of the third barrier. Offsite power was subsequently
restored, the leakage controlled and the release of radioactivity to the
environment terminated. De escalation, recovery and reentry activities
were initiated and the exercise concluded at approximately 3:25 p.m.
The NRC inspector in the control room observed that personnel demonstrated
appropriate use of emergency and abnormal operating procedures, together
with classification and notification emergency plan implementing ;
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procedures for the exercise events. In addition, it was noted that
control room operators demonstrated a good knowledge of plant systems
design and system component locations and characteristics.
The NRC inspectors observed several instances of prompting during the
exercise which impeded evaluation of the ability of the licensee's control
room staff to implement procedures. Examples are as follows:
. When the TSC requested core temperature, a controller gave the answer
"just use Psat" instead of looking up the value in a steam table.
This helped the operators know the core was at saturated conditions
at a time when there was some discussion concerning superheat.
. On one occasion a controller said to the shift supervisor, "You're in
an LCO now, aren't you?" instead of letting the shift supervisor
determine if a limiting condition for operation (LCO) had been
reached.
. A controller responded to a shift supervisor's question regarding
what would happen if safety injection was throttled with the
statement "nothing will happen, level will continue to climb and I
will tell them later." This was at a time when the shift supervisor
expected pressurizer level to be climbing due to injection flow when,
in fact, level was climbing due to the bubble being formed in the
reactor head.
The NRC inspector in the control room also noted problems with the
licensee's response related to an apparent lack of adequate coordination
between the radiological emergency response plan (hereafter referred to as
the Plan) and the security plan. For example, members of the licensee's
emergency team responding tu the site were delayed access at the security
building because security personnel did not know who was to be allowed
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access to the plant in an emergency. In contrast, the NRC emergency site
team badges were recognized by security as allowing access to the plant,
but'the control room staff did not know that they were approved badges for
this access. In addition, it was subsequently determined during the
exercise that no procedures had been provided to control actions if the
security' building had tp be evacuated due to radiological conditions.
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Based on the observations above, the following items are considered to be
emer0ency. preparedness deficiencies:
. Prompting of exercise players in the control room detracted from the
exercise realism and impeded the demonstration of the control room
staff's capabilities to perform during an emergency. (285/8619-01)
. Security practices and procedures were not demonstrated to be
adequately coordinated with the Plan and emergency plan implementing
procedures. (285/8619-02)
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The following is an observation the NRC inspectors called to the
licensee's attention. This item is neither a violation nor an unresolved
item. This item was recommended for licensee consideration for
improvement, but has no specific regulatory requirement:
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. More than one commercial telephone line should be provided in the
control room to support additional emergency communications,
including that expected by the NRC emergency team member (s) stationed
in the control room.
No violations or deviations were identified.
5. Technical Support Center
The NRC inspector noted that the TSC activation was initiated at
approximately 6:08 a.m., when the declaration of Alert was made. TSC
staff began to arrive at about 6:24 a.m. and by approximately 7:00 a.m.
the TSC was ready to be activated except that the TSC communicator was not
present and dose assessment was still being performed in the control room
because of a shortage of staff for this function in the TSC. The NRC
inspector noted that the TSC activation was completed at approximately
7:22 a.m., about 1 hour and 14 minutes after the declaration of Alert.
This exceeded the goal of 1 hour for activation established by
item 8.2.1 J of Supplement 1 to NUREG-0737.
The NRC inspector observed periodic, thorough, effective briefings of the
TSC staff by the site director and timely telephone briefings of the NRC
base team manager located in the NRC Region IV incident response center.
In addition, the NRC inspector noted that the TSC technical and core
physics staff provided good support in assessing plant status and a good
plan of action was develnped for the next 24 hours of the accident.
The NRC inspector also noted that status board time tagging of data was
improved over previous exercises; however, some problems still existed in
the timely display of TSC status board data and the units for containment
pressure and containment sump level.
The following are observations the NRC inspectors called to the licensee's
attention. These observations are neither violations nor unresolved
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items. These items were recommended for licensee consideration for
improvement,,but they have no specific regulatory requirement:
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. LProvisions'should be made for the TSC staff to continue to perform
, dose assessment;after the responsibility for this function has been
< transferred to the emergency operations facility (E0F) as a cross
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check on EOF calculations.
. Additional communicator support should be provided for the TSC, such
as more alternate responders for the TSC communicator and staffing of
the NRC emergency notification system (ENS) and health physics
network (HPN) telephones.
. Dedicated emergency response facility / safety parameter display
system (ERF/SPDS) terminal operators should be trained and provided
to operate the system.
No violations or deviations were identified.
6. Operational Support Center
The operational support center (OSC) functions are performed in two
separate areas. The operations manager and shift operations personnel set
up part of the OSC in the shift supervisors office adjacent to the control
room, and all other OSC personnel operate from designated locations in the
TSC building. All personnel in the TSC building report to the site
director. The NRC inspector noted that this provided excellent
face-to-face communication between the OSC and TSC. After initiation of
the exercise, the OSC/TSC was declared operational in a timely manner;
however, it was noted that the names of individuals filling each of the
key positions were not posted or listed. As a result, it was not clear
when the staff positions were actually filled. In addition, insufficient
personnel in the functional areas of health physics, maintenance and
communications were available at various times during the exercise. In
some instances, personnel assigned to normal plant functions were
recruited to participate in the exercise.
The NRC inspector noted that accountability was accomplished using a
pre-determined list of personnel who are assigned to the OSC/TSC. Other
personnal who may report to the OSC/TSC were added to the list and
personnel who did not report were deleted. This revised list was used to
provide continuous accountability during the exercise. The NRC inspector
noted that this method did not provide assurance that personnel added to
the list were not missing elsewhere or that personnel deleted from the
list were accounted for in another area.
The NRC inspector cbserved that the tag team monitor coordinator performed
well in briefing teams, maintaining a log of health physics activities,
assigning tasks to OSC personnel and assisting the health
physics / chemistry supervisor. In addition, the maintenance supervisur and
staff demonstrated awareness of ALARA concerns by performing a thorough
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analysis of tasks to be performed including all equipment needed, the time
to perform the task and the number and type of personnel to accomplish the
task.
The NRC inspector noted that there were frequent habitability checks in
the OSC/TSC after plant conditions warranted it. However, the results of
each survey were verbally transmitted and not entered into the health
physics / chemistry supervisor's logbook. In addition, it was noted that
the particulate, iodine and noble gas (PING) monitor was left in-the
" alert" iodine alarm condition for 45 minutes after the first person
reported to the TSC area and 20 minutes after the first report of
satisfactory TSC habitability was made.
'In addition to the above~ observations, the NRC inspector noted several
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examples of inadequate implementation of radiological protection for
onsite personnel, as follows:
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Insufficient thermoluminescent dosimeters (TLDs) and self reading
dosimeters were provided for OSC/TSC personnel.
. Personnel who were issued self-reading dosimeters in the OSC/TSC
(other than teams) were required to zero their own dosimeters.
. There was no procedure for maintaining dose records or controlling
doses for OSC/TSC personnel other than for teams that entered the
plant.
. The use of previous dose records was not demonstrated during the
1 exercise.
. The chemistry / radiation protection technician assigned to the medical
emergency did not check the uninjured worker for contamination. When
he was informed of a clothing contamination problem at the frisking
station, he did not take action to control the areas which had been
contaminated.
. Safe routing through the plant was not discussed adequately for
repair teams or visitors.
. Contamination control techniques were not demonstrated during the
collection and analysis of samples.
. The tag team monitor coordinator's logbook contained inadequate
information on reentry team status. In addition, the information was
interspersed with other notes which made the information difficult to
locate.
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Based on observations by the NRC inspector in the OSC, the following item
is considered to be an emergency preparedness deficiency:
. OSC/TSC implementation of radiological protection for onsite
emergency personnel was inadequate to demonstrate satisfactory
. achievement of this objective. (285/8619-03)
The following are observations the NRC inspectors called to the licensee's
attention. These observations are neither violations nor unresolved
items. These items were recommended for licensee consideration for
improvement, but they have no specific regulatory requirement:
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A method should be established to show the name of the individual
filling each OSC/TSC staff position, both initially and for any
change in position during the emergency.
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. A method of accountability should be developed which does not depend
on a predetermined list of personnel assigned to the OSC/TSC.
. Sufficient personnel should be assigned to exercise participation to
perform all necessary functions so that personnel assigned normal
plant functions will not have to be recruited to participate during
the exercise.
No violations or deviations were identified. *
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7. Emergency Operations Facility
The EOF activation was initiated at approximately 6:30 a.m. based on
anticipated public interest in the availability of electric service and
the potential for disruption of communications due to the simulated
seismic event. At about 8:10 a.m., the recovery manager announced that
the E0F would be declared to be activated and would assume direction and
control at 8:30 a.m. The activation was not announced at 8:30 a.m. when
it occurred; however, the recovery manager did make subsequent
announcements of significant events throughout the rest of the exercise.
The EOF was fully activated when a Site Area Emergency was declared at
approximately 9:15 a.m. The NRC inspector noted that the recovery manager
provided timely, effective briefings of the EOF staff during the exercise
and demonstrated excellent control and direction of utility activities.
The E0F activation took approximately 2 hours to complete, which is in
excess of the 1 hour activation ~ goal established by Table 2 of
Supplement 1 to NUREG-0737, but the NRC inspector noted that EOF
activation is not required prior to the declaration of Site Area
Emergency. OPPD has established the option to initiate EOF activation
during the Alert state of an emergency.
The NRC inspector noted that status boards were well maintained during the
enercise, but the status of protective action recommendations versus those
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implemented by offsite authorities was not provided. In addition, it was
noted that offsite monitoring team data were not adequately displayed and
compared with the dose assessment projections.
The NRC inspector noted that the recovery manager declared a General
Emergency at about 10:15 a.m., based on the loss of two fission product
barriers and the projected loss of the third. The protective action
recommendation selected from the decision flow chart was to evacuate a
5 mile radius and sectors B, C and D for 10 miles. Consultation with the
state representatives resulted in approval and transmission of'a
recommendation of 2 miles radius evacuation, in disagreement with the
recommendation called for by the emergency plan-implementing
procedure EIP-E0F-01. The time to reach concurrence with~the states of
Iowa and Nebraska on protective actions recommended resulted in delay of
this recommendation to about 10:43 a.m. Thus about 28 minutes,were
required to approve and issue the recommendation to offsite authorities in
noncompliance with the requirements of Section 4.D.3 of Appendix E to
Part 50, which states that this must be accomplished within 15 minutes of
declaring an emergency. In addition, the NRC inspector noted that OPPD
did not consider the dose assessment calculations provided at about
10:13 a.m., which projected whole body doses of 18 rem over a 4 hour
period at 10 miles from the plant. This would have required protective
actions to be recommended out beyond 10 miles. The high doses calculated
by dose assessment were subsequently determined after the exercise to be
attributable to an error of approximately two orders of magnitude too high
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in the source term.
Based on the observations above, the following items are considered to be
emergency preparedness deficiencies:
. Protective action recommendations, which must be formulated and
provided within 15 minutes of declaring an emergency, were delayed by
periods ranging from 28 to 40 minutes. (285/8619-04)
. Protective action decisionmaking was deficient in that OPPD failed to
properly consider dose projection calculations which indicated more
extensive protective recommendations than were made based on plant
status. (285/8619-05)
The following are observations the NRC inspectors called to the licensee's
attention. These observations are neither violations nor unresolved
items. These items were recommended for licensee consideration for
improvement, but they have no specific regulatory requirement:
. The update message forms transmitting protective action
recommendations should have signature approval by the recovery
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manager prior to transmission to offsite authorities,
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. A dosimeter log should be established and maintained for offsite
monitoring team members.
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. A display should be provided showing the protective action
recommendations currently recommended and the status of the actual
actions implemented by offsite authorities.
No violations or deviations were identified.
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8. Inplant Rescue and Medical Scenario
The inplant first. aid portion of the exercise began at approximately
9:05 a.m. with the detection of a simulated injury of a maintenance
technician and contamination of another maintenance technician working on
the containment purge valves. The rescue team _was' dispatched to treat the
injured worker and remove him to an area where the Blair. Rescue team ,
received him for transportation to the Uryiversity of Nebraska Medical
Center.
The NRC inspector noted that the Fort Calhoun rescue team did.not take-
measures to protect themselves from contamination or limit the spread of
contamination in the auxiliary building. In addition,*no check was ,
performed at the exit. By the time the contaminated worker (noninjured
maintenance technician) discovered his contamination he had potentially
contaminated the hallway near the health physics office area. No efforts
were made to survey or decontaminate this area. This problem with inplant'
radiological control was an element in the deficiency identified in .
Section 6 of this report.
The NRC inspector also noted that the stretcher used for transporting the
injured victim was inadequate in that no means for securing the victim on
the stretcher was provided. The NRC inspector noted that a new stretcher
had been ordered to correct this problem.
No violations or deviations were identified.
9. Exercise Critique
The NRC inspectors attended the post exercise critiques by the licensee
staff on February 26 and 27, 1986, to evaluate the licensee's
identification of deficiencies and weaknesses as required by
10 CFR 50.47(b)(14) and Appendix E of Part 50, paragraph IV.F.5. It was
noted that many of the observations by the NRC inspectors during the
exercise were also independently made and reported by the OPPD staff.
Both the NRC and licensee's staff identified the deficiencies listed
below. Corrective action for identified deficiencies and weaknesses will
be examined during a future NRC inspection:
. Protective action recommendations were not made in compliance with
procedure EIP-E0F-01 in that the recommendation selected through use
of the decision chart was changed downward and approved for
transmittal to offsite authorities without a supporting basis for the
change.
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.' .' Radiologic 51 data from offsite field monitoring teams were not
~a dequately maintained and compared with calculated dose projections
to aid in the assessment of offsite radiation doses and formulation
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;of protective action recommendations.
. Offsite monitoring-teams were not briefed on plant and release
conditions prior to being dispatched to the field.
. 5,ecurity guards did not respond to the EOF in a timely fashion.
The following is an observation the NRC inspector called to the licensee's
attention. This observation is neither a violation nor unresolved item.
This item was recommended for licensee consideration for improvement, but
it has no specific regulatory requirement:
. More attention should be given to briefing observers on previously
identified deficiencies and weaknesses prior to initiation of the
exercise.
No violations or deviations were identified.
10. Exit Meeting
The NRC inspector met with licensee representatives (denoted in
paragraph 1) at the conclusion of the inspection on June 27, 1986. The
NRC inspector summarized the purpose and the scope of the inspection and
the findings. The NRC inspection team leader stated that although
deficiencies were identified during the exercise, implementation of the
plan and procedures in many of the areas observed was improved over the
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previous annual exercise.
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