ML20215M435
| ML20215M435 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 05/11/1987 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 8705130238 | |
| Download: ML20215M435 (2) | |
See also: IR 05000285/1986020
Text
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MAY l i 198T
In Reply Refer To:
Docket:
50-285/86-20
Omaha Public Power District
ATTN:
-R. L. Andrews, Division Manager-
Nuclear Production
1623 Harney Street
Omaha, Nebraska
68102
Gentlemen:
Thank you for your letter of January 28, 1987, in response to our letter dated
December 22, 1986, pertaining to the ERF Appraisal Deficiencies.
We have reviewed your reply and find it responsive to our concerns. 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.
We apologize for any inconvenience that may have resulted from our delayed
response.
Sincerely,
ORIGINAL SIGNED BY:
J. E. Gagliardo, Chief
Reactor Projects Branch
cc:
W. G. Gates, Manager
Fort Calhoun Station
P. O. Box 399
Fort Calhoun, Nebraska
68023
Harry H. Voigt, Esq.
LeBoeuf, Lamb, Leiby & MacRae
1333 New Hampshire Avenue, NW
Wasnington, D. C.
20036
Kansas Radiation Control Program Director
Nebraska Radiation Control Program Director
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R. D. Martin, RA
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R. L. Bangart
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Omaha Public Power District
1623 Harney Omaha. Nebraska 68102 2247
402/536 4000
January 28, 1987
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LIC-87-059
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U. S. Nuclear Regulatory Commission
FEB - A 1987
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Document Control Desk
Washington, DC 20555
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References:
1.
Docket No. 50-285
2.
Letter NRC (J. E. Gagliardo) to OPPD (R. L. Andrews) dated
December 22, 1986. (Inspection Report 50-285/86-20)
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SUBJECT: Schedule to correct deficiencies identified in Inspection Report 86-20
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Gentlemen:
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Omaha Public Power District (0 PPD) received Reference 2 which forwarded the
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results of a special appraisal conducted to verify completion of the Fort
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Calhoun Station Emergency Response Facilities (ERF).
The appraisal further
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intended to conclude that the related requirements in Supplement 1 to
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NUREG-0737 were met. The appraisal identified 14 deficiencies.
Pursuant to
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the Reference 2 request, the attachment to this letter provides OPPD's schedule
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for correcting the identified deficiencies.
If you have any questions, please
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contact me.
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Since
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R. L. Andrews
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Division Manager
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Nuclear Production
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Attachment
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LeBoeuf, Lamb, Leiby & MacRae
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1333 New Hampshire Ave., N.W.
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Washington, DC 20036
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J. E. Gagliardo, NRC Region IV Director e
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A. C. Thadani, NRC Project Director
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W. A. Paulson, NRC Project Manager
P. H. Harrell, NRC Senior Resident Inspector
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Reficiency 285/8620-01
The licensee failed to establish a routine testing program for the TSC
atmospheric filtration system to adequately verify that the design criterion
filtration efficiency was being maintained.
Response
Fort Calhoun Station will investigate the testing requirements, prepare and
perfom appropriate tests to ensure adequate filtration efficiency is
maintained. This will be completed by July 31, 1987.
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Deficiency 285/8620-02
The number of portable dose rate survey instruments provided were insufficient
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to support the radiation monitoring functions assigned to the TSC and OSC.
Response
Five additional survey instruments have been purchased and are in use.
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Deficiency 285/8620-03
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The number of self-reading pocket dosimeters was insufficient to support
radiation monitoring functions assigned to the TSC and OSC.
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Response
The number of self-reading pocket dosimeters in the TSC/OSC has been increased
to a total of.171. These dosimeters are now in use at the TSC and OSC. The
number of self-reading pocket dosimeters are now sufficient to support
radiation monitoring functions assigned to the TSC and OSC.
Deficiency 285/8620-11
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Meteorological data, appropriately averaged for use in dose assessment, were
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not available in the Control Room, TSC or E0F.
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Resnonse
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Fifteen minutes averaged meteorological data will be available from the ERF
computer af ter the 1987 refueling outage at the Fort Calhoun Station. A
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program to calculate dispersion factors (X/Q) is being prepared for implementa-
tion on the ERF computer during the 1987 outage. This program will utilize
15-minute averaged meteorological data. The data will be made available and
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displayed on the Form FC-197 computer display. Completion is expected by June
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30, 1987.
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Deficiency 285/8620-12
The dispersion model utilized by the licensee inconsistently treated releases
from the Auxiliary Building stack as elevated in some atmospheric conditions
and ground-level in others.
Desponse
This item has been resolved. The dispersion model has been revised and now
treats all releases as ground-lavel, regardless of atmospheric conditions.
This revision will treat releases from the Auxiliary Building stack in a
consistent manner.
Deficiency 285/8620-13
The licensee failed to use a sophisticated realistic model in dose assessment
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calculations (i.e., segmented-plume model) and made no use of tabular and
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graphic options available through the EAGLE program.
In addition, the EAGLE
program verification was not completed.
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Response
Initially, the EAGLE program segmented-plume model results were utilized during
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an evaluated emergency exercise for protective action recommendations (PAR's).
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Correlation between those results and results from NRC and State dose assess-
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ment calculations was relatively poor. Therefore, in the interest of good
correlation of calculational results, OPPD changed to a more simplistic dose
assessment model and has continued in this mode.
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Prior to reimplementation of the segmented-plume model for PAR's there are
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three tasks which should be completed:
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1) OPPD, NRC, Nebraska and Iowa should agree upon the information necessary
for developing PAR's. Either plume centerline doses or doses at discrete
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special interest receptor locations should be the criteria. OPPD will lead
this endeavor, but the final success is contingent on agreement of the
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other. parties.
2) OPPD needs to complete the verification of the segmented-plume model.
3) The parties performing dose assessment calculations should all use models
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of equivalent sophistication (i.e., segmented-plume models).
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Contingent upon agreement of all parties, reimplementation of EAGLE's segmented
-plume model will be completed by June 1,
1988. This date will allow suf-
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ficient time for the parties involved to agree upon a dose assessment
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methodology, revise procedures and practices relevant to development of PAR's,
conduct training on the new procedures, obtain a model (if necessary) usirg the
agreed upon methodology, revise the backup method that is now based on Straight
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-Line Gaussian, and complete verification of models and the backup method.
Until such time as the segmented-plume methodology is adopted, OPPD will
continue to use the present method (i.e., Straight-Line Gaussian). The verifi-
cation of the Straight-line Gaussion method is in progress and is expected to
be complete by February 27, 1987.
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Deficiency 285/8620-13 (Continued)
Additional equipment is on order to permit utilization of the tabular and
graphic options available in EAGLE.
Receipt is expected soon and will be
utilized when plume follow is implemented. This effort will be completed at
the same time that the segmented plume model is reimplemented.
Deficiency 285/8620-14
Readily available records to evaluate historical data recovery performance of
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meteorological instrumentation were lacking.
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Response
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OPPD believes that the question / deficiency concerned verifying that 90% of the
meteorological data was available. Calculations are done when the semiannual
report is written that determine availability. When the meteorological tower
is not functioning, data is extrapolated from other meteorological sources so
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that OPPD does have 90% availability of weather data.
In the future, when data
is extrapolated, the percent that is extrapolated will be reported in the
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semiannual summary that determines a percent recovery of valid data for each
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month and an annual percent value.
Deficiency 285/8620-15
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Procedures for dose assessment failed to consider scenarios where a release of
radioactivity to the environment was eminent.
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Response
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A manual calculation method will be developed to resolve this item by August
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15, 1987. At the present time, the EAGLE program does not have the capability
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to model scenarios where a release is not in progress.
Provision to include
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the capability for EAGLE to model scenarios when a release of radioactivity to
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the environment is eminent will require program additions, testing, verifica-
tion, procedures, training and documentation.
Program modifications to allow
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computerized calculation by the EAGLE software will be complete by June 1,
1988. This date is concurrent with the commitment for completion of the
segmented plume option. We intend to use the Gaussian model and backup
calculations which are validated and verified until the segmented model is
implemented.
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Deficiency 285/8620-16
Procedures lacked adequate guidance for obtaining meteorological data in the
event of a partial or complete failure of the ERF or of the Fort Calhoun
meteorological system.
Response
Emergency Plan Implementing Procedures EPIP-OSC-16, EPIP-RR-63 and EPIP-RR-72
have been revised to include procuring meteorological data from the U.S.
Weather Service as an alternate method to Fort Calhoun Station measurements,
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Deficiency 285/8620-17
Formal maintenance logs on the ERFCS have not been kept since the OAD test
concluded in November 1984.
Resnonse
A formal maintenance log on the ERFCS is now being kept and updated from a
maintenance log book. The log date began May 1, 1986 when the SPDS and ERFCS
were officially declared operational.
Deficiency 285/8620-18
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System unavailability calculations have not been made and recorded since
November 1984.
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Response
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A procedure will be developed by October 31, 1987 to provide guidance for
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calculating system unavailability.
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Deficiency 285/8620-19
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The Licensee failed to obtain site director or recovery manager signature
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authorization prior to transmitting protective action recommendations as
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required by 10 CFR 50, Appendix E, paragraph IV.A.2.C and guidance of
NUREG-0654, II.B.4.
(This is a repeat item from earlier exercises and most
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recently identified in NRC Inspection Report 50.285/86.11.
The deficiency
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Response
Emergency Implementing Procedures EPIP-RR-69 and EPIP-RR-73 have been revised
to ensure that the Recovery Manager's or Site Director's signature hus been
obtained and verified prior to issuance of protective action recommendations.
Deficiency 285/8620-20
The licensee has not demonstrated that the OSC can be operational within about
I hour.
Response
OPPD is evaluating and clarifying what constitutes the minimum staffing of the
OSC to correlate the requirements of Table B1 in NUREG-0654 for one hour
actuation. The call list is being reorganized so personnel required for
minimum staffing have priority notification.
In addition, the phone
notification has been supplemented with an offsite facility to expedite initial
notification of OSC personnel.
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Deficiency 285/8620-20 (Continued)
Corrective actions will be implemented by procedure change by March 1, 1987.
They will be demonstrated during 1987 Spring drills, with the final evaluation
during the July 1987 Annual Emergency Exercise.
Deficiency 285/8620-21
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An insufficient depth of trained personnel was provided in their emergency
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organization to ensure the ERF staffing will be adequately staffed during long
term emergencies.
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ResDonse
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OPPD has added 3 persons to the Emergency Response Staff so that at least two
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individuals are assigned to each designated emergency position.
In addition,
most of the more responsible positions have more than two trained persons to
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satisfy staffing. OPPD continues to evaluate emergency response positions for
adequate staffing at least quarterly.
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