ML20207T152

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-285/86-31. Implementation of Corrective Actions Will Be Reviewed During Future Insp to Determine That Full Compliance Achieved

ML20207T152
Person / Time
Site:	Fort Calhoun
Issue date:	03/18/1987
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Andrews R OMAHA PUBLIC POWER DISTRICT
References
NUDOCS 8703230256
Download: ML20207T152 (2)

See also: IR 05000285/1986031

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In Reply Refer To:

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Docket:

50-285/86-31'

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MAR 181987

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-Omaha Public Power District?

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ATTN:

R. L. Andrews, Division Manager-

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Nuclear Production

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Thank you for your letter of February 18,, 1987, in response to our letter

.and Notice of Violation dated January 22, 1987. We have reviewed your reply

and find it responsive to the concerns raised in our Notice of Violation. We

will review the implementation of-your corrective actions during a future

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

maintained.

Sincerely,

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J. E. Gagliardo, Chief

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Reactor' Projects Branch

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W. G. Gates, Manager

Fort Calhoun Station

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Fort Calhoun, Nebraska

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Harry H. Voigt, Esq.

LeBoeuf, Lamb, Leiby & MacRae

1333 New Hampshire Avenue, NW

Washington, D. C.

20036

Kansas Radiation Control Program Director

Nebraska Radiation Control Program Director

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February 18, 1987

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J. E. Gagliardo, Chief

Reactor Projects Branch

U.S. Nuclear Regulatory Commission

Region IV

611 Ryan Plaza Drive, Suite 1000

Arlington, TX

76011

Reference:

Docket No. 50-285

Gentlemen:

SUBJECT:

Inspection Report 86-31

The subject inspection report, dated January 22, 1987, identified one (1)

violation concerning the training of personnel assigned to the Emergency

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Response Organization.

Please find attached the Omaha Public Power

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District's response to this violation.

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Sincerely,

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R. L. Andrews

Division Manager

Nuclear Production

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LeBoeuf, Lamb, Leiby & MacRae

1333 New Hampshire Avenue, N.W.

Washington, D.C.

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Mr. A. C. Thadani, Project Director

Mr. W. A. Paulson, HRC Project Manager

Mr. P. H. Harrell, NRC Senior Resident Inspector

Mr. R. D. Martin, Regional Administrator

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ATTACHMENT

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During an NRC inspection conducted on November 17-21, 1986, a violation of

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NRC requirements was identified. The violation involved inadequate train-

ing for personnel assigned to the emergency response organization.

In

accordance with the " General Statement of Policy and Procedure for NRC

Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the violation is

listed below:

Violation

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Inadeauate Trainina of Personnel

10 CFR 50.54(q) requires that licensees authorized to operate a

nuclear power reactor follow and maintain in effect emergency plans

which meet the standards in 10 CFR 50.47(b) and in Appendix E.

10 CFR 50.47(b)(15) requires that radiological emergency response

training be provided to those who may be called to assist in an

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emergency.

10 CFR 50, Appendix E, paragraph IV.F requires, in part, that employ-

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ees of the licensee be trained to ensure that they are familiar with

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their specific emergency response duties.

Contrary to the above, the NRC inspector determined during emergency

preparedness walkthroughs and training interviews that radiological

emergency. response training had not been provided adequately as evi-

denced by the following examples:

1.

One of two shift supervisors failed to notify the NRC that a

station blackout was in progress, as required by 10 CFR 50.72(b)

(iii) and by Section E(1.1) of the Radiological Response Emer-

gency Plan (RERP) for Fort Calhoun Station.

2.

The two shift supervisors and two site direc. tors interviewed

failed to demonstrate a basic understanding of the design, oper-

ation, capabilities and emergency uses of the post accident

sampling system (e.g., ability to perform in situ versus grab

sample analysis).

3.

The two shift supervisors and two site directors interviewed

failed to demonstrate a basic understanding of those aspects of

meteorology (e.g., difference between stable and unstable

conditions) that would have a major impact on the effects of a

radioactive release and on their decisions pertaining to

protective action recommendations.

4.

One of two shift supervisors incorrectly understood that the

containment atmosphere monitoring system discharged to the

auxiliary building.

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5.

One of two shift supervisors failed to demonstrate an understand-

ing of the differences between site area and general emergency

classifications and was not aware of the requirement to-make

protective action recommendations at a general emergency

declaration.

6.

One of two shift supervisors failed to relate challenges to fail-

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ure of fission product barriers to emergency classifications.

7.

One of two shift supervisors exhibited a general weakness in the

knowledge and performance of his emergency preparedness dui.ies,

in that a number of forceful prompts from the shift technical

advisor and senior reactor operator were needed in order for him

to make classification and notification decisions.

8.

Both chemistry technicians failed to demonstrate a knowledge of

the order of severity of the different levels of emergency class-

ification (e.g., failed to name them and confused the order of

severity).-

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9.

One chemistry technician could not find an alternate procedure in

OI-PAP-8 to estimate the magnitude and consequences of offsite

radioactive releases. The other technician had ~ difficulty in

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finding the procedure. Neither was able to perform dose pro-

jections when given the situation .sf failed process monitors.

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This is a Severity Level IV violation.

(Supplement VII.D)

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(285/8631-01).

OPPD's Response

The Reason for the Violation if Admitted

OPPD personnel have been involved in training programs and testing

procedures which were developed based on NUREG 0654, 10 CFR 50 and

reasonable training requirements. All personnel must pass an appro-

priate test for their respective positions prior to approval for an

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emergency response organization.

Employees interviewed by the NRC had

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received this training. The NRC interviews have disclosed a weakness

in the retention of the subject materials as taught and tested, and

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the individuals ability to retain and recall this information.

OPPD

intends to improve emergency preparedness training by administering

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more difficult tests and conducting more difficult drills to prevent

repetition of this violation.

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The Corrective Steps Which Have Been Taken and the Results Achieved

All current shift chemistry / radiation protection technicians have been

retrained in emergency classification levels by distribution of a

training information hotline on October 8, 1986.

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The shift supervisor who performed poorly during the walkthough and

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training interviews was removed from his position on the shift.

The shift supervisors and chemistry technicians presently manning the

operation shift at Fort Calhoun Station satisfy the training and per.-

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formance requirements established by OPPD documents.

The Corrective Steos Which Will be Taken to Avoid Further Violations

The shift supervisor who performed poorly during the walkthrough and

training interviews will be retrained in the " Licensing Operator Train-

ing" program prior to being allowed to resume' shift supervisor duties.

The shift supervisors and site directors interviewed will be given

supplemental training concerning the subjects of post accident sam-

pling system and meteorology, and all shift supervisors and site

directors will receive additional training to these topics during

their annual requalification training.

During the 1987 annual training cycle for shift supervisors and site

directors, the following training items identified by the NRC in-

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spector as weak will be reviewed with the proper emergency actions

stressed:

1.

NRC notification

2.

Post accident sampling system capabilities

3.

Basic meteorological knowledge

4.

Containment atmosphere monitoring

5.

Protective Action recommendations for Site Area and General

Emergency classifications

6.

Emergency classification related to loss of fission product

barriers

7.

Basic emergency preparedness duties

During the 1987 annual training cycle for shift chemistry / radiation

protection technicians, the basis for the four emergency classifica-

tions will be stressed.

For an improved alternate method to estimate

the magnitude and effects of offsite radioactive releases when monitor

indication is not available, Operating Instruction 01-PAP-8, Post Acci-

dent Procedures, is currently under revision. Shift C/RP technicians

are scheduled for training on this procedure after its approval by the

Plan Review Committee and prior to formal issuance. Training for

items 1,2,3,4 and 6 are being accomplished by the Training Department;

items 5,7,8 and 9 are provided in the annual training cycle of the

Emergency Planning Group.

The Date When Full Comoliance will be Achieved

Based upon the above review and training programs, OPPD believes these

personnel have sufficient ability to perform their emergency duties

and OPPD is now in compliance with 10CFR50 requirements. ~However, the

improved procedures and annual training described above will be accom-

plished by the end of the annual training cycle on December 31, 1987.

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