ML20235U961

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-285/87-19.Reply Responsive to Eight Deficiencies Mentioned in Rept
ML20235U961
Person / Time
Site: Fort Calhoun 
Issue date: 10/08/1987
From: Gagliardo J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Andrews R
OMAHA PUBLIC POWER DISTRICT
References
NUDOCS 8710140338
Download: ML20235U961 (2)


See also: IR 05000285/1987019

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OCT

.8 1987

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In Reply Refer To:

Docket:

50-285/87-19

Omaha Public Power District

ATTN:

R. L. Andrews, Division Manager-

Nuclear Production

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1623 Harney Street

Omaha, Nebraska

68102

Gentlemen:

Thank you for your letter of September 25, 1987, in response to our letter

and inspection report 50-285/87-19 dated August 20, 1987. We have reviewed

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your reply and find it responsive to the eight deficiencies described in the

report. We will review the implementation of your corrective actions during a

future inspection to determine that full compliance has been achieved and will

be maintained.

Sincerely,

J. Callan

for

James E. Gagliardo, Chief

Reactor Projects Branch

cc:

W. G. Gates, Manager

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Fort Calhoun Station

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P. O. Box 399

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Fort Calhoun, Nebraska

68023

Harry H. Voigt, Esq.

LeBoeuf, Lamb, Leiby & MacRae

1333 New Hampshire Avenue, NW

Washington, D. C.

20036

Program Manager

FEMA Region 7

911 Walnut Street, Room 300

Kansas City, Missouri 64106

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Kansas Radiation Control Program Director

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U.S. Nuclear Regulatory Commission

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ATTN: Document Control Desk

Washington, DC

20555

References:

(1)

Docket No. 50-285

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(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

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Omaha Public Power District (OPPD) 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

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R. L. Andrews

Division Manager

Nuclear Production

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Enclosure

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LeBoeuf, Lamb, Leiby & MacRae

1333 New Hampshire Avenue, N.W.

Washington, DC

20036

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E D."M5EtIn~, NRC Regional Administrator

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A. Bournia, NRC Project Manager

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P. H. Harrell, NRC Senior Resident Inspector

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ENCLOSURE

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Deficiency 285/871]L-Q1

The information flow between Emergency Response Facilities was deficient in

that:

The ihift' Supervisor failed to make announcements in the control room

pertaining to the. activation of the Emergency Operation Facility (EOF)

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 E0F, .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

c'ntrol room did not~ confirm information requested by the OSC staff dur-

in 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,

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As a result of deficient information flow, necessary corrective and pro-

tective actions were not coordinated adequately among'these' facilities.

OPPD's Resoonse

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A request- has been initiated to add an additional dedicated telephone li e be-

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tween the Control Room, TSC and EOF. Additionally, OPPD will develop a lesson

plan on communication techniques specifically covering information flow, giving

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and receiving orders and directions.

This training will be given as part of~

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- the 1988 Annual Training. The completion date will be December 31, 1988.

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Deficiency 285/8719-02

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The NRC inspectors noted that Procedure EPIP-0SC-2 did not provide an NRC noti-

fication form.

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In addition, Paragraph-IV 1A3A of the procedure requires use of the initial

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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 Attachment 2 - the update form.

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The OSC' communicator failed to relay information to the Site Director in the

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TSC pertaining to an actual. event (a small fire in the ControT Room area).

- OPPD's Resoonse'

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Procedure EPIP-OSC-2 is being revised to clearly identify initial and update

notification procedures.

Completion date for issuance of a revision is

December'31, 1987.

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Deficiency 285/8719-03

The TSC communicator 'did not follow Procedure EPIP-0SC-2 in accomplishing state

and local notification of declaration of the Alert. . As a result, the completed '

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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 emphasiz,d 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

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- 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.

- 0 PPD's Resoonse

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 OPPD 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.

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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-

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stitutes a repeat deficiency (See 285/8619-03) from the previous exercise.

OPPD's omoonse

The Monitor Coordinator currently has this function detailed in his implement-

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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-

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ed in the 1988 Annual Training.

Training will be completed by March 31, 1988.

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Deficiency 285/8719-06

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Recordkeeping by the Recovery' Manager was not accurate or complete.

In addi-

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tion, it distracted him from other more vital duties,

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The. maintenance supervisor was unable to keep complete and accurate records

pertaining to activities in the OSC.

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OPPD's Response

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The Recovery Manager Secretary's duties will be revised to include maintaining

records and. logs for the Recovery Manager.

The checklist and training devel-

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oped for. deficiency 285/8719-05 will also rectify the problem the Maintenance

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Supervisor had with maintenance of records.

Procedure revisions and Annual

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Training will be completed by June 1,1988.

Deficiency 285/8719-07

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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

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example, teams did not take representative airborne contamination samples or

general area radiation surveys when entering potentially hazardous areas during -

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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.

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The scenario did not anticipate that component cooling water pumps were

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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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. Control Room operators were not given alarms indicating high radiation.

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levels, although this data would be readily accessible to them during'a

real rui tent.

On two~ occasions, the scenario required reactor ~ operators to continue-

plant operations in violation of Technical Specifications. At 9:10

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la.m., scenario data given to operations reflected temper'atures 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 good reactor operational practices

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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

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realistic considerations for that location.

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During the fire' scenario, there were various instances of unnecessary

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simulation.

For example, fire hoses were not charged with water, the-

access to post accident sampling system was simulated, and the re-entry

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team simulated dressing and entering into the safety injection rooms.

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Furthermore, the players did not' climb the extension ladder through

loading hole ~that would have given them access to Room 69.

OPPD's Resoon a

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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-

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ulations.' This procedure had been developed prior to the'1987 Annual Exercise

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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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