ML20235H853
| ML20235H853 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 09/25/1987 |
| From: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| LIC-87-637, NUDOCS 8710010195 | |
| Download: ML20235H853 (5) | |
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Omaha Public Power District 1623 Harney Omaha. Nebraska 68102 2247 402/536 4000 Sa w
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September 25, 1987
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LIC-87-637
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.J 57 U.S. Nuclear Regulatory Commission to ATTN:
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References:
(1)
Docket No. 50-285 (2)
Letter from NRC (J. E. Gagliardo) to OPPD (R. L. Andrews),
dated August 20, 1987 Gentlemen:
SUBJECT:
Responses to Deficiencies Identified in Inspection Report 50-285/87-19 Omaha Public Power District (0 PPD) received the subject inspection report on August 26, 1987. As requested, a schedule addressing these exercise defi-ciencies is provided in the enclosure to this letter.
If you have any ques-tions, please contact us.
Sincerely R. L. Andrews Division Manager Nuclear Production RLA/rh Enclosure c:
LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.
Washington, DC 20036 R. D. Martin, NRC Regional Administrator A. Bournia, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector gjo01o195870925 h
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ENCLOSURE Deficiency 285/8719-01 The information flow between Emergency Response Facilities was deficient in that:
The Shif.t Supervisor failed to make announcements in the control room pertaining to the activation of the Emergency Operation Facility (E0F) and the transfer of overall command and control responsibilities to the Recovery Manager. As a result, the control room staff was not aware that the Recovery Manager was in charge of classifying emergencies.
When the Site Area Emergency was declared at 9:42 a.m. by the Recovery Manager at the EOF, the control room staff erroneously assumed that the decision to escalate to a Site Area Emergency was made by the Site Director at the Technical Support Center (TSC).
The control room staff failed to inform the TSC that a second explosion, with a potential to jeopardize safety equipment, had occurred in the auxiliary building.
The TSC staff performed independent leak rate cal-culations but neglected to inform the control room.
In addition, the control room did not confirm information requested by the OSC staff dur-ing a 49-minute period. Verification of flow through the stack was need-ed by the health physics staff in the OSC to perform dose assessment.
As a result of deficient information flow, necessary corrective and pro-tective actions were not coordinated adequately among these facilities.
OPPD's Response A request has been initiated to add an additional dedicated telephone line be-tween the Control Room, TSC and E0F. Additionally, OPPD will develop a lesson plan on communication techniques specifically covering information flow, giving and receiving orders and directions. This training will be given as part of the 1988 Annual Training.
The completion date will be December 31, 1988.
1 Deficiency 285/8719-02 I
The NRC inspectors noted that Procedure EPIP-0SC-2 did not provide an NRC noti-i fication form.
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In addition, Paragraph IV 1A3A of the procedure requires use of the initial notification form (Attachment 1) for all changes in emergency classification.
This conflicts with Paragraph IV 2A7 of the same procedure, which refers the user to Attachrsent 2 - the update form.
The OSC communicator failed to relay information to the Site Director in the TSC pertaining to an actual event (a small fire in the Control Room area).
OPPD's Response Procedure EPIP-0SC-2 is being revised to clearly identify initial and update notification procedures.
Completion date for issuance of a revision is December 31, 1987.
Deficiency 285/8719-03 The TSC communicator did not follow Procedure EPIP-OSC-2 in accomplishing state and local notification of declaration of the Alert. As a result, the completed form (Attachment 2) lacked information on release rates, dose assessment, and protective action recommendations.
In addition, the completed form did not specify the name of the caller, and was not approved by the Site Director.
OPPD's Response Additional training has been completed with 4 of 6 individuals assigned to this position.
This training emphasized the necessity of completing notification forms prior to passing this information to government agencies and the impor-tance of properly following procedures.
The remaining two individuals are scheduled to receive this training.
Completion date will be March 31, 1988.
Deficiency 285/8719-04 The NRC inspector noted that airlock doors in the TSC did not close tightly.
This could result in potential contamination and radiation exposure of per-sonnel in this facility.
OPPD's Response The TSC is maintained at a positive air pressure in relation to adjoining spaces by a filtered air supply system. This is done to reduce the possibility of airborne radioactivity entering the TSC.
Engineering Evaluation and Assis-tance Request (EEAR) FC-87-041 has been initiated to determine the adequacy of the airlock door seal. Modifications, if necessary, will be made based upon this study.
This deficiency was previously identified by 0 PPD during drills.
As a corrective action, warning signs were posted on the doors to remind indi-viduals entering and exiting the TSC to shut the door behind themselves.
It is expected that the study and any modification required, will be completed by December 31, 1988.
Deficiency 285/8719-05 Briefings of in-plant repair and corrective action teams were inadequate.
These teams were not provided technical and radiological information necessary to perform their tasks efficiently.
For example, briefers did not provide re-pair teams with diagrams, procedures, floor plans, specific instructions on how to perform complex tasks, radiation dose rates, or ALARA guidelines.
This con-stitutes a repeat deficiency (See 285/8619-03) from the previous exercise.
OPPD's Response The Monitor Coordinator currently has this function detailed in his implement-ing procedure. A check list will be developed for use by the Maintenance Super-visor and will be included in his implementing procedure, EPIP-RR-21.
This checklist will detail the briefing requirements to be completed prior to dis-patching these teams. The use and importance of this checklist will be includ-ed in the 1988 Annual Training.
Training will be completed by March 31, 1988.
Deficiency 285/8719-06 Recordkeeping by the Recovery Manager was not accurate or complete.
In addi-tion, it distracted him from other more vital duties.
The maintenance supervisor was unable to keep complete and accurate records pertaining to activities in the OSC.
OPPD's Resoonse The Recovery Manager Secretary's duties will be revised to include maintaining records and logs for the Recovery Manager.
The checklist and training devel-oped for deficiency 285/8719-05 will also rectify the problem the Maintenance Supervisor had with maintenance of records. Procedure revisions and Annual Training will be completed by June 1, 1988.
Deficiency 285/8719-07 The NRC inspector determined that in-plant radiological controls were not con-sistently adequate.
During the performance of some tasks, in-plant repair /cor-rective action teams performed poorly in the radiation protection area.
For example, teams did not take representative airborne contamination samples or general area radiation surveys when entering potentially hazardous areas during accident conditions.
In addition, the teams did not use correct procedural sequences when removing anticontamination apparel.
OPPD's Response Annual Training provided to Health Physics Technicians and other members of the Repair Teams will emphasize the importance of good health physics practices and techniques. This training will include proper methods for taking air samples and general area surveys prior to and while entering a potentially hazardous area. Additionally, practical factors have been developed and implemented into the Annual General Employee Training for the proper use of anticontamination clothing. Annual Training of Repair Team members will be completed by June 1, 1988.
Deficiency 285/8719-08 The NRC inspector identified a series of scenario incongruence which detracted from the realism and free play of the exercise.
These appeared to be the re-sult of:
internal inconsistencies in the scenario itself, insufficient control-1ers, poor logistics or improper timeliness in the positioning of controllers, and deficient controller training. The licensee identified a number of these deficiencies in their critique.
Some examples follow:
There was no controller available in Room 69 to hand out data to players pertaining to ongoing fire.
The scenario did not anticipate that component cooling water pumps were safety-related equipment mandating a manual tripping of the reactor when threatened by fire.
This condition in itself would have terminated the accident sequence, prevent the continuation of the exercise.
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d Control Room operators were not given alarms indicating high radiation levels, although this data would be readily accessible to them during a real accident.
On two occasions, the scenario required reactor operators to continue plant operations in violation of Technical Specifications.
At 9:10 a.m., scenario data given to operations reflected temperatures in excess of 200*F in the reactor coolant pump seal return, a condition that would have mandated tripping the pump and the reactor.
This sequence of events was prevented by the scenario. Another instance when the scen-ario forced actions against Technical Specifications occurred at 9:55 a.m. when only one component cooling water pump remained in operation.
This condition would also have mandated a reactor trip but was prevented by the scenario. This is contrary to gond reactor operational practices and opposes the didactic objectives of an emergency exercise.
The duration of the fire assumed to take place in the auxiliary building during the scenario was not consistent with type of materials and other realistic considerations for that location.
During the fire scenario, there were various instances of unnecessary I
simulation.
For example, fire hoses were not charged with water, the access to post accident sampling system was simulated, and the re-entry team simulated dressing and entering into the safety injection rooms.
Furthermore, the players did not climb the extension ladder through loading hole that would have given them access to Room 69.
OPPD's Response A new procedure, EPT-10, has been developed for use in preparing scenarios for the Annual Exercise. This procedure also addresses quality assurance of the scenario, controller training, logistics, and activities associated with sim-ulations. This procedure had been developed prior to the 1987 Annual Exercise but not implemented early enough to be utilized for that exercise.
This proce-dure will be fully used for the 1988 Annual Exercise scenario development.
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