ML20135H739

Insp Rept 50-285/85-16 on 850722-26.No Violations or Deviations Noted.Major Areas Inspected:Emergency Preparedness Exercise Observations,Evaluation & Insp

ML20135H739
Person / Time
Site:	Fort Calhoun
Issue date:	09/10/1985
From:	Baird J, Terc N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20135H737	List: ML20135H736 ML20135H739
References
50-285-85-16, NUDOCS 8509240181
Download: ML20135H739 (8)

See also: IR 05000285/1985016

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APPENDIX

U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report:

50-285/85-16

License: DPR-40

Docket: 50-285

Licensee: Omaha Public Power District

1623 Harney Street

Omaha, Nebraska 68102

Facility Name:

Fort Calhoun Station

Inspection At:

Fort Calhoun, Nebraska

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Inspection Conducted: July 22-26, 1985

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Inspector:

Nemerf M. Terc, NRC Team Leader

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Other Inspectors:

W. V. Thomas, PNL

D. H. Schultz, Comex

G. R. Bryan, Comex

E. A. King, PNL

E. C. Watson, PNL

Approved:

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J/ B. Baird, Acting Chief, Emergency Preparedness

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and Safeguards Programs Section

Inspection Summary

Inspection Conducted July 22-26, 1985 (Report 50-285/85-16)

Areas Inspected: Routine, announced emergency preparedness exercise

observations, evaluation and inspection. The inspection involved 294

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inspector-hours by seven NRC and contractor inspectors.

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Results: Within the emergency response areas inspected no violations or

deviations were identified. Ten deficiencies were identified by NRC and

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contractor inspectors.

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DETAILS

1.

Persons Contacted

Omaha Public Power District

D. Hyde, Maintenance Supervisor

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M. Kallman, Supervisor, Administrative Services and Security

• G. Roach, Health Physics / Chemistry Supervisor

• G. Gates, Manager, Fort Calhoun Station

• F. Franco, Manager, Radiological Health and Emergency Preparedness

• R. Jaworsky, Manager, Technical Services

• D. Freighert Emergency Planning Coordinator

J. Fisicaro, Supervisor, Nuclear Regulatory and Industry Affairs

• R. Andrews, Division Manager, Nuclear Protection

• J. Gasper, Manager, Administrative Services

J. Michael, Shift Superintendent

• E. Pape, Senior Vice President, OPPD

• M. Gautier, Media . Relations & Publications Manager

• K. Morris, Manager, Quality Assurance

• K. Hothaus, Supervisor, Reactor Performance Analysis

W. Jones, Vice President, Nuclear. Operations

R. Mueller, Maintenance Supervisor

J. Tesark,. Instruments and Control Electrical Support Coordinator

R. Mehaffby, Instruments and Control Mechanical Support Coordinator

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The inspectors also contacted other licensee employees during the course

of the emergency exercise. They included chemistry and health physics

technicians, reactor and auxiliary operators, members of the security

force and maintenance personnel.

• Denoted those present at the exit interview.

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2.

Licensee Action on Previous Inspection Findings

(Closed) 0 pen Item (285/8423-01): The inspectors determined that offsite

~ monitoring teams were efficient in their.use of-survey instruments,

protective clothing and dosimetry.

This item is closed; however, see

deficiency identified in paragraph 5 of this. report.

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3.

Exercise Scenario

The exercise scenario was'~ reviewed to determine if provisions had been

.made for.the required level of participation by state and local agencies,

and that all the major elements of emergency response would be exercised

in accordance with the requirements of 10 CFR 50 and the guidance

criteria in NUREG 0654,'Section 11.n.

The review included an~ evaluation

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of the technical adequacy of both, operational and radiological aspects

of the scenario.

In addition, a review of the internal consistency and

thoroughness of information provided to participants, observers,

controllers and evaluaturs, was made.

Results of this review were as

follows:

The scenario did not include a narrative summary of physical

events which occurred in the reactor and associated systems,

nor the rationale behind the same.

Various scenario events were unrealistic. For example, a cue

card suggested a reactor trip to the operator solely for a

medical emergency; a worker burned by radioactive steam was

required by the scenario to make a complete report of conditions

in the location he was injured.

In addition, inadequate timing

of scenario events was found in a message at 9:20 a.m., reporting

an alarm. Suddenly, at 9:21 there was already someone in the

auxiliary building who had been briefed by control room operators

and was ready to report the reason for the alarm.

There were numerous scenario messages which prompted or coached

the players, giving them an anticipated, premature idea of

events and conditions thus diminishing the amount of realism

and freeplay expected during an emergency exercise.

For

example, some messages were given to the wrong organizational

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members, others clearly hinted to personnel on what action to

take, and final values and physical units were given to field

teams before they performed appropriate calculations. Other

messages conveyed technically incorrect data.

Contingency messages, which are normally given to players only

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after they have failed to respond adequately in order to

prevent the exercise from reaching an impasse, were inadequate

in number and content.

The scenario lacked technical consistency with actual practices

and as a consequence restrained control room operators from

following actions expected during actual emergencies.

For

. example, after the shift supervisor had adequately classified

an event as an Alert in accordance with procedures, he was

forced by the scenario to de-escalate to a Notification of

Unusual Event (NOVE) contradicting his training and approved

emergency procedures. Other examples included the prevention

of alteration of the ventilation path following the fuel

handling accident scenario.

The format and content of data given to players was in many

cases inadequate or lacking.

For example, data for the injured

victim and offsite radiation monitoring data originating from

the radioactive plume were not flexible, but limited to fixed

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locations and without distinguishing iodine from noble gas

components.

In addition, data for containment radiation

monitors was lacking.

Based on the above, the following item is considered to be emergency

preparedness deficiency:

Internal j.nconsistencies and lack of completeness in the scenario data

and instructions for players and controllers resulted in various

instances of unnecessary simulation, coaching and lack of realism. As a

consequence some exercise objectives were not adequately demonstrated

(285/8516-01).

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No violations or deviations were identified.

4.

Deficiencies Identified by NRC Inspectors

The following deficiencies, grouped by location or activity, were

identified by NRC inspectors:

a.

Control Room

Initial conditions were provided to the control room staff assigned

to respond to the simulated emergency at 6:45 a.m.

Among significant

. initial conditions were the following:

1.

The reactor was operating at full power.

2.

A high pressure injection pump was out of service for

maintenance.

3.

Inspection reactor fuel elements from a previous fuel cycle

was in progress.

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The exercise was started at 6:45 a.m., with a leak of chlorine gas due

to the failure of a safety valve on a cylinder stored on the loading

dock next to the cafeteria. This event prompted the shift supervisor

to declare an Alert classification at 7:07 a.m. (this emergency class was

changed by the controller to a' Notification-of Unusual Event). At

7:50 a.m., a radiation alarm in the spent fuel pool area indicated

abnormal levels of direct radiation and airborne radioactive contamin-

ation, and at 7:56 a.m., personnel in the fuel area were evacuated. A

high level alarm from the stack radiation monitor indicating a

release _of radioactivity offsite was investigated and confirmed. The

shift supervisor declared an Alert emergency class, and sounded the

site evacuation alarm. 'A sequence of system failures resulted in a

' loss of coolant accident which eventually led to the uncovering of

the fuel elements within-the reactor vessel and consequently to a

release of a substantial amount:of fission products to the environment

and a declaration of a General Emergency condition.

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The NRC inspectors in the control room observed the appropriate use

of emergency implementing and operating procedures in responding to

the various aspects of the emergency as the scenario unfolded.

Accident' mitigation schemes were thoughtful and innovative, and

references to plant and instrumentation diagrams contributed to early-

diagnosis and corrective action plans.

The NRC inspectors, however, observed the following deficiencies:

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Initial notification with appropriate descriptive contents, including

whether a release was taking place, potentially affected population

and areas, and whether protective measures may be necessary (see

example, 10 CFR 50, Appendix E, Section 4.0.3 and NUREG 0654,

Sections 11.E.3 and II.E.4), which must be performed within.15

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minutes 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).

The transmission by telefax of technical data during the notification

process included protective action recommendations (PARS) which had

been automatically generated by the computer but had not been approved

by the emergency coordinator (Recovery Manager).

In' addition, these

PARS did not take plant conditions into consideration (285/8516-03).

Written notification procedures were found to be organized in a

manner which did not' lend themselves to providing technical informa-

tion content to offsite authorities.

Furthermore, written procedures

did not reflect the licensee staff actual notification practices

during the exercise (285/8516-04).

The licensee failed to respond to release rate calculations'in the

control room indicating extremely hazardous radiological conditions

that would have required a general emergency classification. Technicians

performing the calculations, yielding 8.22 E13 C1/sec, failed to

recognize this as a physically impossible release rate for commercial-

nuclear power plants.

In addition, the individual failed to communi-

cate these results promptly to the shift supervisor, who at that time

was acting as the emergency coordinator. He in turn failed to recog-

nize the unlikely nature of the data, and it was not until 33 minutes

after the initial results were at hand that an assistant reactor

operator requested verification of this calculation (285/8516-05).

b.

Technical Support Center (TSC)

The NRC inspectors observed that the reorganization which shifted

the-site director from the shift supervisor's office to the TSC

improved the performance of the emergency response over that' observed

during the previous exercise,' and was a . key factor in eliminating

past deficiencies in TSC' direction, control and briefings. The NRC

inspectors also observed that notifications and updates to the NRC

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were timely, that the site director made efficient use of

procedures, and that briefings were timely and concise.

In

addition, the TSC staff was supportive of the control room staff in

technical and other matters; this was demonstrated by the timely

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deployment of a fire brigade team when the control room staff was

unable to do so.

The NRC inspectors observed the following deficiencies:

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Information flow within the TSC was not sufficiently prompt to allow

the efficient handling of accident conditions.

For example, the

average of a sample of six observations, showed that it took

21 minutes from the time data.were received from the control room to

the time the status board was updated (285/8516-06).

The analysis of events by the technical staff of the TSC was not

always adequate.

For example, at one time the status board

indicated an increasing 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 drawings at hand _in attempting 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 improper valve line-up

recommendation being forwarded to the control room (285/8516-07).

The base radio used to communicate with.offsite teams was found to be

inadequate.

As a consequence, directives and information flow

between offsite teams and personnel in the TSC was disrupted,

depending on location.

Similar problems were observed when

attempting to communicate with their supervisor in the security

building (285/8516-08).

c.

Search and Rescue, and Health Physics Training

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The NRC inspe'ctor noted that the' medical scenario indicated a lack

of training ~of site personnel in tasks re. quiring a combined

expertise of health physics; first aid-and rescue operations.

For

example, the rescue team did not take radiation detection

instruments, nor a first-aid kit when entering an area with high

levels of radiation and contamination.

In addition, they failed to

take a breathing mask for.the injured man.

The stretcher used for

transporting the victim was, inadequate in that it had no means for

securing the injured person to prevent his' falling down the stairs

and breathing was' difficult inside the closed container through a

small filter media.

In addition, a health physics technician in charge of TSC habit-

ability surveys,~had no knowledge of the operation of the Particulate-

Iodine-Noble Gas (PING) Monitor, and two clerks in charge of deter-

mining the amount of radioactivity in smears taken onsite did not

have'a working knowledge of radiation protection techniques.

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Observations 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)

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d.

Environmental Monitoring Team

The NRC inspectors observed that offsite team actions were greatly

improved from previous performances. However, they failed to

properly label each sample with location, date, time, and name of

the person conducting 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 individual sample bag could result in the

lo~ss of sample identity upon removal and separation prior to

analysing them.

(285/8516-10)

No violations or deviations were identified.

5.

Exercise Critique

The NRC inspectors attended the post-exercise critique conducted by the

licensee staff on July 25, 1985, 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.

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licensee staff identified the deficiencies listed below and stated that

responsibilities for followup and corrective actions would be assigned

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after a final review of their findings.

Corrective actions for these.

deficiencies will be examined during a future NRC inspection.

The description in written procedures of the Operations Support

Manager duties, responsibilities and place within the

organizational structure, were not consistent with observed

practices nor with the responsibilities of the shift

supervisor.

The technical ~ support center staff was not aggressive in

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attempting to evaluate core damage. This was partially the

result of- not having adequate means for estimating core damage

in' lieu of taking a post accident sample.

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 accountability should be accomplished within.30 minutes.

No violations. or deviations were identified.

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7.

Exit Interview

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The.NRC team met with licensee representatives identified in paragraph 1

above. .The NRC team-leader summarized.the deficiencies observed during

the exercise.

The NRC team leader stated that although a number of

deficiencies had been identified during the exercise, within the scope

and ifmitations of the exercise scenario, the licensee actions were found

to be adequate to protect the health and safety of the public, and that

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such actions were consistent with their Emergency Plan and implementing

procedures. The licensee stated that upon review of exercise findings

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they will. take corrective actions in order to improve their emergency '

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program"... No violations or deviations were reported.

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