IR 05000285/1986019

Insp Rept 50-285/86-19 on 860624-28.No Violation or Deviation Noted.Major Areas Inspected:Emergency Response Capabilities During Exercise of Emergency Plan & Procedures

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: ML20212K017 ML20212K028
References
50-285-86-19, NUDOCS 8608190028
Download: ML20212K028 (12)

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APPENDIX

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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 procedure 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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l l-2-DETAILS l l 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
* 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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* 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
* Harrell, Senior Resident Inspector Other OPPD, state, and contractor personnel were also contacted during the. inspectio ,
* Denotes those present at the exit intervie . 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 ope (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 close ~ ~ (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 close (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 close (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 close (Closed) Deficiency (285/8516-08): The NRC inspector noted that radio communications with offsite field monitoring teams were adequate. This item is close (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 close .

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_4_ g . . )[ _, 9 , ' _ .(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 close :M l? .

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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

- y)'*,- e 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 I ;. f _/ .

" - ' 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 deficienc l No violations or deviations were identifie i

       * 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 ; 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 barrie At approximately 9:15 a.m., a Site Area Emergency was declared resulting from damage to the station from a second, more severe seismic shoc : 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 suppor t

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   -5-   1 Plant conditions continued to deteriorate with an increase in the leak rate and radioactivity releas 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 barrie Offsite power was subsequently restored, the leakage controlled and the release of radioactivity to the environment terminate De escalation, recovery and reentry activities were initiated and the exercise concluded at approximately 3:25 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 event In addition, it was noted that control room operators demonstrated a good knowledge of plant systems design and system component locations and characteristic 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 procedure 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 tabl This helped the operators know the core was at saturated conditions at a time when there was some discussion concerning superhea . 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 reache . 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 hea 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 condition _ -

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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)

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: i

. 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 roo No violations or deviations were identifie . 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 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 TS 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 Aler This exceeded the goal of 1 hour for activation established by item 8.2.1 J of Supplement 1 to NUREG-073 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 cente 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 acciden 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 leve The following are observations the NRC inspectors called to the licensee's attention. These observations are neither violations nor unresolved

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item 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 calculation . 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) telephone . Dedicated emergency response facility / safety parameter display system (ERF/SPDS) terminal operators should be trained and provided to operate the syste No violations or deviations were identifie . 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 TS 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 fille 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 exercis 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 are 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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  -8-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 tas 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 mad '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 personne . Personnel who were issued self-reading dosimeters in the OSC/TSC (other than teams) were required to zero their own dosimeter . There was no procedure for maintaining dose records or controlling doses for OSC/TSC personnel other than for teams that entered the plan . The use of previous dose records was not demonstrated during the 1 exercis . 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 contaminate . Safe routing through the plant was not discussed adequately for repair teams or visitor . Contamination control techniques were not demonstrated during the collection and analysis of sample . 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 locat , .

  -g-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 item 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 emergenc ~

. A method of accountability should be developed which does not depend on a predetermined list of personnel assigned to the OSC/TS . 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 exercis No violations or deviations were identifie *
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. 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 exercis 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 activitie 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 emergenc 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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  -10-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 projection 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 thir 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 mile 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

' in the source ter 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 statu (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

. manager prior to transmission to offsite authorities, i

. A dosimeter log should be established and maintained for offsite monitoring team member r
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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 authoritie No violations or deviations were identifie .

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 Cente 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 exi 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 repor 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 proble No violations or deviations were identifie . 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 staf 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 chang i ,
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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 recommendation . Offsite monitoring-teams were not briefed on plant and release conditions prior to being dispatched to the fiel . 5,ecurity guards did not respond to the EOF in a timely fashio The following is an observation the NRC inspector called to the licensee's attention. This observation is neither a violation nor unresolved ite 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 exercis No violations or deviations were identifie . 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

- previous annual exercise.

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