IR 05000219/1982001
| ML20054H753 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 06/10/1982 |
| From: | Crocker H, Kinney W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20054H750 | List: |
| References | |
| 50-219-82-01, 50-219-82-1, NUDOCS 8206240394 | |
| Download: ML20054H753 (70) | |
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U. S. NUCLEAR REGl'
'0RY COMMISSION Region I Report No. 50-219/82-01 Docket No. 50-219 License No. DPR-16 Priority Category C
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Licensee: GPU Nuclear Corporation Madison Avenue at Punch Bowl Road Morristown, New Jersey 07960 Facility Name: Oyster Creek Nuclear Generating Station Inspection at: Forked River, New Jersey Inspection conducted: J J uary 15, 1982
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7 BZ Inspectors:
_ amLeader/EPS,RI date' signed Kinney,
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E. H. Carbaugh, Battelle, PNL M. J. Gaitanis, EPLB, HQ W. H. Knox, Battelle, PNL W. J. Madden, EPS, RI N. M. Terc, EPS, RI E. J. Wojnas, EPS, RI Approved by: t
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H. W. Crocker, Ctrtef, Emergency Preparedness
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Section, DEPOS l
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B206240394 820611 PDR ADOCK 05000219
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INDEX Page 0.0 SUMMARY
1.0 ADMINISTRATION OF EMERGENCY PLAN
1.1 ' Responsibility Assigned
1.2. Authority-
1.3 Coordination
1.4 Selection and Qualifications
2.0 EMERGENCY ORGANIZATION
2.1 Onsite Organization
2.2 Augmentation of Onsite Emergency Organization
3.0 EMERGENCY PLAN TRAINING / RETRAINING
3.1 Program Established
3.2 Program Implementation
4.0 EMERGENCY FACILITIES AND EQUIPMENT
4.1 Emergency Facilities
4.1.1 Assessment Facilities
4.1.1.1 Control Room
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4.1.1.2 Technical Support Center (TSC)
4.1.1.3 Ope. cations Support Center (OSC)
4.1.1.4 Emergency.0perations Facility (EOF)
4.1.1.5 Post-Accident Coolant Sampling and Analysis
4.1.1. 6 ~ Post-Accident Containment Air Sampling and Analysis-
4.1.1.7 Post-Accident Gas and Particulate Effluent Sampling and Analysis
4.1.1.8 Post-Accident Liquid Effluent Sampling and Analysis
~25 4.1.1.9 Offsite Laboratory Facilities
4.1.2 Protective Facilities
4.1.2.1 Assembly / Reassembly Areas
-4.1.2.2 Medical Treatment Facilities
4.1.2.3.
Decontamination Facilities
4.1.3 Expanded Support Facilities
4.1.4 News Center
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Page 4.2 Emergency Equipment
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4.2.1 Assessment Equipment
i 4.2.1.1 Emergency Kits and Emergency Survey Instrumentation
4.2.1.2 Area and Process Radiation Monitors
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4.2.1.3 Non-Radiation Process Monitors
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4.2.1.4 Meteorological Instrumentation
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4.2.2 Protective Equipment
4.2.2.1 Respiratory Protection
4.2.2.2 Protective Clothing
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4.2.3 Emergency Communications Equipment
4.2.4 Damage Control / Corrective Action and Maintenance Equipment and Supplies
4.2.5 Reserve Emergency Supplies and Equipment
4.2.6 Transportation
5.0 EMERGENCY IMPLEMENTING PROCEDURES
5.1 General Content and Format
5.2 Emergency, Alarm and Abnormal Occurence Procedures
5.3 Implementing Instructions
5.4 Implementing Procedures
5.4.1 Notifications
5.4.2 Assessment Actions
5.4.2.1 Offsite Radiological Surveys
5.4.2.2 Onsite (out-of plant) Radiological Surveys
5.4.2.3 In-Plant Radiological Surveys
5.4.2.4 Primary Coolant Sampling
5.4.2.5 Primary Coolant Sample Analysis
5.4.2.6'
Containment Air Sampling
5.4.2.7 Containment Air Sample Analysis
5.4.2.8 Stack Effluent Sampling
5.4.2.9 Stack Effluent Sample Analysis
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5.4.2.10 Liquid Effluent Sampling
5.4.2.11 Liquid Effluent Sample Analysis
5.4.2.12 Radiological and Environmental Monitoring Program
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Page 5.4.3 Protective Action
5.4.3.1 Radiation Protection During Emergencies
5.4.3.2 Evacuation of Owner Controlled Areas
5.4.3.3 Personnel Accountability
5.4.3.4 Personnel Monitoring and Decontamination
i 5.4.3.5 Onsite First-Aid / Rescue
5.4.4 Security During Emergencies
5.4.5 Repair / Corrective Actions
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5.4.6 Recovery
5.4.7 Public Information
5.5 Supplementary Procedures
5.5.1 Inventory, Operational Check and Calibration of Emergency Equipment, Facilities, and Supplies
5.5.2 Drills and Exercises
5.5.3 Review, Revision, and Distribution
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5.5.4 Audit
6.0 COORDINATION WITH 0FFSITE GROUPS
6.1 Offsite Agencies
6.2 General Public
6.3 News Media
7.0 DRILLS, EXERCISES, AND WALK-THROUGHS
7.1 Program Implementation
7.2 Walk-Through Observations
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0.0 SUMMARY The appraisal of the onsite emergency preparedness program at the Oyster Creek
~ Nuclear Generating Station involved seven general areas. During the appraisal, conditions were found which required licensee corrective action be taken to achieve an acceptable program. These findings were considered to be "Significant Emergency Preparedness Findings." During the appraisal, other conditions were found which required corrective actions be considered to improve the program.
These findings were considered to be " Emergency Preparedness Improvement Items". The table given below shows the seven general areas and the number of findings in these areas.
Significant Improvement Area Findings Items Administration of the Emergency Plan
3 Emergency Organization
3 Emergency Plan Training / Retraining
11 Emergency Facilities and Equipment
16 Emergency Implementing Procedures
26 Coordination with Offsite Groups
2 Orills, Exercises, and Walk-Through
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63 As demonstrated in the table above, training, facilities and equipment, and emergency implementing procedures were the areas where most of the problems were encountered.
1.0 ADMINISTRATION OF EMERGENCY PLAN The auditor examined the Emergency Plan, Revision 7, and the Emergency Plan Administrative Procedures (EPAP's) which pertain to the administration of emergency preparedness. Also, the auditor interviewed appropriate licensee representatives.
1.1 Responsibility Assigned According to section 8.0 of the Emergency Plan, MAINTAINING EMERGENCY PREPAREDNESS, the Vice President, Nuclear Assurance, located at the GPU Nuclear Corporation headquarters in Parsippany, New Jersey, has the overall responsibility for emergency planning and preparedness for the Oyster Creek Nuclear Generating Station (OCNGS). Reporting to the Vice President, Nuclear Assurance, is the Manager, Emergency Preparedness, who is located at Three Mile Island, Middletown, Pennsylvania.
The Emergency Preparedness Supervisor, Oyster Creek, is the individual onsite on the Nuclear Assurance Vice President's staff appointed to: supervise onsite planning for response to radiological emergencies, prepare the Emergency Plan and the Emergency Plan Implementing Procedures, contribute
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to emergency preparedness training, and audit emergency preparedness.
The licensee has a job description for the Supervisor, Emergency Preparedness which defines the nature and scope of the position and the areas of accountability.
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The Nuclear Assurance organization has been responsible for emergency preparedness coordination since June 1980.
Prior to that date, Nuclear Safety and Licensing of the Division of Environmental Affairs of Jersey Central Power and Light was responsible for the administration of emergency preparedness at the Oyster Creek Nuclear Generating Station.
The Emergency Preparedness Manager has been in his position since October IC90.
Tne present Emergency Preparedness Supervisor has been in the position fo, a little over a month. He reported to the position from outside the cor 3 ration on December 7, 1981. The licensee did not have the position of Su srvisor, Emergency Preparedness, filled from March until December 1981.
The licensee relied on the Emergency Preparedness Manager, who was onsite
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part-time, and consultants to perform the emergency preparedness functions.
According to the licensee, this lack of supervision of, and management attention to emergency preparedness functions caused delays in the performance of important tasks, such as the revision of the Emergency Plan and the revision of the Emergency Plan Implementing Procedures.
However, with the new Supervisor of Emergency Preparedness on the staff, the licensee expects to achieve better supervision and management of the emergency preparedness functions at the OCNGS.
Presently, the Emergency Preparedness Supervisor has a staff of five engineers and three secretaries. All of these people are contractor employees, except one secretary. The supervisor is attempting to hire.three qualified engineer
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planners for his staff during calendar year 1982.
The licensee has signed
" Requests for Personnel" for the positions of senior emergency planner and emergency planner.
It appears that the licensee recognizes the importance of the emergency prepared-ness function and is attempting to improve their emergency preparedness position.
The licensee should expedite this effort to fill these prominent Emergency Preparedness organizational positions with qualified personnel so that the performance of these necessary tasks will be expedited.
Discussions with members of plant management and the professional staff disclose that these individuals are aware of Emergency Preparedness being responsible for emergency planning.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
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Expedite the hiring of permanent staff Emergency Preparedness Planners.
(219-82-01-01)
1.2 Authority The licensee's organizational structure is such that Emergency Preparedness reports to the Vice President, Nuclear Assurance; Station Operations reports to the Vice President, Oyster Creek; Systems Engineering reports to the Vice President, Technical Functions; Radiological Control and Environmental Control each report to the Vice President, Radiological and Environmental Controls;
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and Public Information reports to the Vice President, Communication. All of I
these organizations have vital emergency response functions, and the Office of the President of GPU Nuclear Corporation is the only common head of the organizations performing these vital functions. There is great need for cooperation among the organizations to achieve an adequate state of emergency preparedness, since the Emergency Preparedness Supervisor does not have any direct authority over the other organizations in the fulfillment of their required emergency response functions. The new Emergency Preparedness Supervisor feels that he has the necessary authority to enable him to satisfy his assigned responsibilities. However, the actual authority of the Emergency Preparedness Supervisor over matters concerning the implementation of the Emergency Plan has not been defined.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
Define the authority of the Emergency Preparedness Supervisor over matters
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concerning the implementation of the Emergency Plan.
(219-82-01-02)
1.3 Coordination As pointed out in the foregoing section, Emergency Preparedness must rely on the coordination of the activities of many groups to achieve emergency prepared-ness.
The new Supervisor of Emergency Preparedness must initiate these coordination activities in most cases.
No member of the Emergency Preparedness staff is a member of the Plant Operations Review Committee (PORC). Also, Emergency Preparedness does not participate in the coordination of matters being presented to the PORC for their review and action.
It appears that Emergency Preparedness participation in this coordination effort would be beneficial in areas such as reviewing Abnormal and Emergency Operating Procedures from an Emergency Preparedness viewpoint.
The Emergency Preparedness group has an operating budget to manage. Normally, the budget is mainly for operation of the staff and some equipment maintenance.
According to the Manager of Emergency Preparedness, Emergency Preparedness had special funds to buy equipment needed for emergency preparedness during 1981.
According to the Manager of Emergency Preparedness, he advises corporate management of the costs involved for emergency preparedness for the corporation.
The coordination between the licensee and offsite groups is discussed in Section 6.1, 6.2, and 6.3 of this report.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
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Require Emergency Preparedness to review documents such as Emergency Operating Procedures for adequacy from Emergency Preparedness standpoint prior to the PORC review.
(219-82-01-03)
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1.4 Selection and Qualifications The licensee has established job descriptions for emergency preparedness personnel which provide the qualifications required for incumbents of emergency preparedness positions. As indicated previously, the licensee only has the position of Emergency Preparedness Supervisor filled at this time. The incumbent of that position meets the qualifications listed in the job description. The contractor personnel working in emergency preparedness positions had prior emergency preparedness experience at Three Mile Island.
The licensee indicated they desire to fill the three permanent Emergency Preparedness Planner positions during 1982. The licensee should expedite this effort as discussed in Section 1.1 of this report.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
2.0 EMERGENCY ORGANIZATIOJ
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The auditor examined the Emergency Plan, Revision 7, and the licensee's roster of members on the Initial Response (Onsite) Emergency Organization and the Full Mobilization (Offsite) Emergency Organization. Also, the auditor interviewed appropriate licensee representatives concerning the emergency organization.
2.1 Onsite Organization In Section 5.0 of the Emergency Plan, ORGANIZATION CONTROL OF EMERGENCIES, the licensee describes the emergency response organizations.
In the event of an emergency, the Group Shift Supervisor initially assumes the position of Emergency Director.
The Group Shift Supervisor uses the shift personnel to cope with the emergency conditions, classify the emergency, and make necessary notifications to on-call personnel and offsite agencies. The definition of the shift emergency organization and assignment of personnel to such an emergency type organization has not been accomplished.
It would be beneficial to assign communicators and assure that they are trained.
The licensee has defined an "onsite" emergency organization which must report to the facility within one hour to augment the operating shift. Another member of top plant management reports to the facility and becomes the Emergency Director. Other plant personnel report and take predetermined positions of Operations Coordinator, Radiological Protection Coordinator, Security Coordinator, Technical Support Center '.oordinator, Communications Coordinator, Emergency Advisor, and Media Affairs Representative.
These positions all report to the Emergency Director.
In turn, other emergency organization members, who have also been notified, report to these positions in appropriate manner.
The Operations Coordinator takes control of the plant systems operation and coordinates necessary repairs and maintenance. The Technical Support Center Coordinator takes control of operational accident assessment by directing
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engineers in plant technical assistance and acting as liason between Parsippany Technical Functions and the Emergency Director. The Radiological Protection Coordinator takes over the radiation protection aspects and the initial radio-logical accident and dose assessment activities.
The Security Coordinator maintains control of security of the plant and site access contrcl and takes control of personnel accounting. The Communications Coordinator provides current information and direction to the two Emergency Control Center Communicators and ensures the maintenance of records. The Emergency Advisor assists and advises the Emergency Director in the implementation of the Emergency Plan and the Emergency Plan Implementing Procedures. The Media Affairs Representative i
implements the Emergency Public Information Plan and prepares the accurate information for release to the media.
As previously stated, the Radiological Protection Coordinator has the responsibility for the onsite and in plant radiological accident assessment I
and the initial responsibility for the offsite dose assessment activities. A Radiological Assessment Coordinator initially controls radiological environmental
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surveying and monitoring.
The Offsite Monitoring Teams initially report to this Radiological Assessment Coordinator.
(Later, the Environmental Assessment Coordinator takes over the dose assessment activities, and the offsite monitoring teams report to the Environmental Assessment Coordinator). A Radiological
Controls Coordinator provides the onsite and in plant radiological controls for activities such as access control, emergency repair, search and rescue, first aid, and fire fighting.
First Aid and rescue personnel are designated shift personnel trained in first aid, and they report to the Operations Support Center Coordinator. The Radio-logical Controls Coordinator and the Operations Support Center Coordinator work together in directing personnel in emergency first aid and rescue, personnel monitoring, decontamination, and repair and corrective actions.
Plant chemistry is under the Chemistry Coordinator, who reports to the Operations Support Center Coordinator.
The Emergency Plan provides written descriptions, organization charts, and a table (Table 5.1) which designates the emergency management positions responsible for the performance of the emergency functions. However, the Emergency plan Implementing Procedures do not include checklists to assure that key emergency organization members perform their required functions.
It would be beneficial if such checklists be included in the implementing procedures.
The licensee attempts to use personnel in the emergency organization whose work experience would tend to prepare and qualify the person in the emergency function.
However, the licensee must rely on training of personnel to qualify personnel to perform their assigned emergency response functions. This training is discussed in Section 3.0 of this report.
The licensee made a major revision to its Emergency Response Plan in late.
1981, and the latest revision, revision 7, was just approved by the licensee in early January 1982.
The organization discussed in this section was described
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in this latest revision, and the organization is different from that given in the previous Emergency Response Plan. Therefore, the licensee has been reassigning
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people to the new Initial Response (0nsite) Emergency Organization.
The licensee must assure that all the Emergency Organization members are trained in their emergency response functions as discussed in Section 3.0 of this report.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
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Include in the Emergency Plan Implementing Procedures checklists to assure that key Initial Response (Onsite) Emergency Organization members perform their required functions.
(219-82-01-04)
2.2 Augmentation of Onsite Emergency Organization An emergency orgcnization designated as the " Full Mobilization (Offsite)
Emergency Response Organization" augments the previously described onsite organization. The affsite organization is responsible to respond within four hours of notification.
Section 5.6 of the Emergency Plan gives a limited description of the offsite emergency response organization. This section describes the responsibilities of four positions: Emergency Support Director; Environmental Assessment Coordinator; Group Leader, Administrative Support; and Group Leader, Technical Support.
Table 5.2 of the plan lists the emergency duties, the reporting location, and the position to whom the emergency position reports. This table lists the data for 27 emergency positions.
The duties of the Public Information Coordinator is not included in the table.
The Emergency Plan Implementing Procedures do not include checklists to assure that key emergency organization members perform their required functions.
It would be beneficial if such checklists be included in the implementing procedures.
The Emergency Support Director assumes the overall management control of the entire emergency organization. Until the Emergency Support Director is at the Nearsite Emergency Operations Facility (NE0F) and the NEOF is fully functional, the Emergency Director initially assumes the responsibilities of the Emergency Support Director. The Emergency Support Director has the authority to expend GPU Nuclear Corporation resources including money, manpower, and equipment to mitigate or terminate the emergency situation.
The Environmental Assessment Coordinator and his staff are responsible for all offsite radiological and environmental monitoring and offsite radiological dose assessment.
These people are located in the Environmental Assessment Command Center (EACC), which is located in close proximity to the Nearsite Emergency Operations Facility.
The Environmental Assessment Coordinator reports to the Emergency Support Director.
The Group Leader, Administrative Support, and his staff provide logistical, communication, manpower planning and scheduling, and security support to the emergency organizations. These people are located in the Nearsite Emergency Operations Facilit.
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The Group Leader, Technical Support, and his staff are responsible for providing technical leadership and guidance, technical analyses, evaluations, and recommend-ations to the onsite Technical Support Center Coordinator and staff with respect to plant conditions, reactor core status, and subsequent plant operaticns.
This Group Leader and his staff report to the Parsippany Technical Functions Center located in Parsippany, New Jersey. A representative of this group is stationed at the Oyster Creek Nuclear Generating Station, and he reports to the Nearsite Emergency Operations Facility for the purpose of providing assistance to the Emergency Support Director.
The area of Technical Support to the Emergency Director and the Emergency Support Director appears to be suspect because the personnel providing technical leadership are located in a facility far removed from the Control Room and the onsite Technical Support Center. Also, the Technical Support Center located onsite is not an adequate facility as discussed in Section 4.1.1.2 of this report.
As was the case with the onsite organization discus nd in Section 2.1, the licensee has just approved a major revision of the Emergency Plan. Therefore, the licensee has just assigned people to this new Full Mobilization (Offsite)
Emergency Organization.
The licensee attempts to use personnel in the emergency organization whose work experience would tend to prepare and qualify the person in the emergency function.
However, the licensee must rely on training of personnel to qualify personnel to perform their assigned emergency response functions. This training is discussed in Section 3.0 of this report.
In regard to this newly defined organization, the inspector compared the " Full Mobilization Emergency Response Roster" effective January 14, 1 82 to the positions listed in Table 1 of the Emergency Plan.
It was noted that the roster did not include the positions: Environmental Assessment Coordinator, Assistant Environmental Assessment Coordinator, and Environmental Assessment Staff.
Examination shows that these positions appear on the " Initial Response Emergency Roster".
Placement of these positions on the roster to be called initially is wise, since this staff of people can then take over the radiological dose assessment activities from the Radiological Assessment Coordinator of the Initial Response Emergency Organization as soon as possible.
The extension of the organizational capabilities provided by local services for handling emergencies requiring ambulance, medical, hospital, and fire fighting organization are discussed in section 6.1 of this report.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be considered for improvement:
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Include in the Emergency Plan Implementing Procedures checklists to assure that key Full Mobilization (Offsite) Emergency Organization members perform required functions.
(219-82-01-05)
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Move the location of the technical leadcrs and experts and technical information from the Parsippany Technical Functions Center to the onsite Technical Support Center.
(219-82-01-06)
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3.0 EMERGENCY PLAN TRAINING / RETRAINING The auditors examined the Emergency Plan, Emergency Plan Administrative Procedures (EPAP's), Emergency Plan Implementing Procedures, the Emergency Plan Training Matrix, lesson plans, and training records. Also, the auditors interviewed.
the licensee representatives responsible for the training and many emergency response organization members.
-3.1 Program Established The emergency preparedness training / retraining program for various categories of emergency response personnel is described in EPAP-6 through 11, table 8.1 of the Emergency Plan, the. Emergency Plan Training Matrix, and lesson plans.
There are a number of inconsistencies existing among these documents. The inconsistencies apparently_resulted from changes in organizational structure and implementing procedures being made without changes being made in these documents.' In general, definitions of emergency response categories, training requirements, and criteria vary from document to document.
The licensee requires that training / retraining of emergency response personnel listed on their emergency organization roster be performed annually.
The Training Department is currently developing a new training program with emphasis on emergency preparedness; however, the current program has not been developed to the point where it could be considered as being effectively established. The following items demonstrate the lack of an adequately established emergency preparedness training / retraining program.
Training in post-accident sampling and analysis is not included in the
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training program because of the unavailability'of implementing procedures and. equipment, even though post-accident sampling was included in a recent revision to Table 8.1 of the Emergency Plan.
(See Section 4.1.1.7 and Sections 5.4.2.4 through 5.4.2.11 of this report).
The training program does not include the qualification criteria for
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personnel. selected for the various emergency response positions. This criteria is particularly important for radiological monitoring teams.
This is because team members are selected from non-bargaining unit personnel, and these team members do not normally perform radiological monitoring in their routine work.
(See Sections 5.4.2.1, 5.4.2.2, and 5.4.2.3 of this report).
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Specialized emergency preparedness training has not been fully established
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for bargaining unit personnel, since they do not appear on the emergency roster or organization as emergency workers. During an emergency, this group of personnel would be called upon to provide technical services; therefore, they should be trained for performing their actions under emergency conditions.
Comprehensive lesson plans which provided sufficient information have not
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been developed for all training categories such as Chemistry and Radiological Control.
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Some hands-on, walk-through, and talk-through training are included in
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the program; however, it is considered to be inadequate by personnel, particularly in the technical areas.
(See Sections 5.4.2.4 through 5.4.2.11 and Section 7.2 of this report.)
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Respiratory protection training is not routinely provided to all members of the Onsite/0ffsite Radiological Monitoring teams.
(See Section 7.2 of this report).
General information on hazardous conditions, which are expected to exist
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during an accident, is provided in the Mitigation of Core Damage course.
The level of information provided by the course is considered to be too general by most personnel interviewed.
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The training program generally does not include written examinations and performance tests to demonstrate that trainees understand and can perform emergency functions.
The training procedures do not provide for the immediate retraining of
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personnel in changes to procedures and changes in equipment which occur during the interim between training periods. -(See Section 7.2 of this report).
From a positive side, training for the first aid team includes Red Cross Standard First Aid-Multimedia.
Site access information is provided to local support service personnel who may enter the site during an emergency.
Provisions have been made to train additional contractor, vendor, and other non-licensee support personnel upon arrival at the site during emergency / recovery operations.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
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Complete the development of and the establishment of a more comprehensive training / retraining program for all emergency response personnel which is consistent with the Emergency Plan and Emergency Plan Implementing Procedures.
(219-82-01-07)
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Include training in post-accident sampling and analysis of reactor coolant, containment air, and stack effluents in the training program after the implementing procedures and equipment are available.
Hands-on, walk-through, and talk-through training should be a part of this training.
(219-82-01-08)
In addition to the above findings, the following matters should be considered for improvement:
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Provide consistency among all the documents which specify emergency response training.
(219-82-01-09)
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Develop qualification criteria for all members of the emergency response organization.
(219-82-01-10)
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Include in the emergency training program the training of bargaining unit
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emergency procedures used under emergency conditions.
(219-82-01-11)
Develop comprehensive lesson plans.
(219-82-01-12)
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Ferform more hands-on type training with people dressed in the full protective clothing and wearing respiratory protection.
(219-82-01-13)
Provide respiratory protection training for all members of the Radiological
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Monitoring teams.
(219-82-01-14)
Include more site-specific information in the " hazardous conditions"
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section of the Mitigation of Core Damage course.
(219-82-01-15)
Provide written examinations and performance tests which demonstrate
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training of personnel.
(219-82-01-16)
Provide retraining of personnel in changes to procedures and equipment
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which occurs between training periods.
(219-82-01-17)
3.2 Program Implementation The implementation of an effective training program is affected by the previously described lack of a fully-developed and established training program. Also, as discussed in Sections 2.1 and 2.2 of this report, the licensee has recently revised both the Initial Response (Onsite) Emergency Organization and the Full-Mobilization (Offsite) Emergency Response Organization, and the licensee has just assigned people to these organizations.
The licensee must assure that all members of these organizations are trained in their specific emergency response functions.
In addition, all emergency response personnel had not been properly trained in accordance with the current training program.
For instance,' Damage Control and Radiological Control Team members had not received Multimedia First Aid training. According to training records, personnel have been assigned to emergency response positions without first having the required trainina.
Training program implementation should include the training of
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bargaining unit personnel in their emergency-type duties.
Personnel indicated that some training had been conducted; however, most considered the level of training to be inadequate and expressed a need for more hands-on training. During walk-through in the areas such as offsite, onsite, and in plant radiological surveys, most personnel were unable to satisfactorily demonstrate their ability to perform the tasks for which they
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were trained.
(See Section 7.2 of this report).
The training conducted appeared to be consistent with the lesson plans; however, some lesson plans were limited in scope.
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Based on the above findings, improvement in the following area is required to achieve an acceptable program:
Implement an effective training program, and train members of the newly
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defined Initial Response (ONSITE) Emergency Organization and Full Mobilization (0FFSITE) Emergency Organization in the emergency response functions.
(219-82-01-18)
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Train all personnel who will perform emergency response functions.
(219-82-01-19)
In addition to the above findings, the following matters should be considered for improvement:
Train personnel prior to assigning them on an emergency organization
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roster.
(219-82-01-20)
Provide Red Cross Standard First Aid Multimedia training for Damage
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Control and Radiological Control team members.
(219-82-01-21)
4.0 EMERGENCY FACILITIES AND EQUIPMENT The auditors examined the Emergency Plan, Revision 7; a letter dated September 11, 1981 to the Director of the Office of Nuclear Reactor Regulation concerning Emergency Operations Facilities; and letters dated August 27, and December 24, 1981, concerning projects to be completed during the Cycle 10 Refueling Outage scheduled for mid-1982 until mid-1983.
The auditors examined the physical emergency facilities and equipment.
4.1 Emergency Facilities 4.1.1 Assessment Facilities 4.1.1.1 Control Room The control room for the single reactor at this site is located in the office building on the 46 ft. elevation.
Emergency supplies such as respirators (30), self-contained breathing apparatus (12), dosimeters, chargers, and portable G-M tube monitors were available in the immediate area and appeared adequate. Emergency Plan Implementing Procedures were available in the control room, and an outdated Emergency Plan was available in the Group Shift Supervisor's
office.
Dedicated communications links between the control room and supporting emergency facilities (e.g., NRC Emergency Notification System, NRC Health Physics Network, Emergency Directors'. Hot Lines, Technical Support Center and Operational Support Center Lines, Notification and Verification Lines between the State and local governments) were available in addition to microwave and radio (FM)
systems.
These phones were all located very close to each other in a long row. Mutual interference problems and confusion will be a problem with these phones being located as they were.
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The licensee has designated the control room as the location for their Emergency Control Center (ECC). According to the Emergency Plan, the Emergency Director and his emergency staff will be in this ECC, the control room, during an emergency. This will result in overcrowding of this relatively small control room and will cause significant congestion and confusion.
The location of this ECC in the control room is counter to the requirements given in NUREG-0696, Funccional Criteria for Emergency Response Facilities.
NURE3-0696 states that Emergency Response facilities are to help personnel in the control room to mitigate the consequences of accidents by providing various services. Among these services are:
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Relieve the reactor operators of peripheral duties and communications not directly related to reactor systems manipulations; and prevent congestion in the control room.
According to NUREG-0696, during emergency conditions, the Technical Support Center is the onsite facility located close to the control room that shall provide plant management and technical support to the reactor operating personnel located in the control room. Therefore, according to NUREG-0696, the licensee should locate their Emergency Control Center in the Technical Support Center.
Based on the above findings, improvement in the following area is required to achieve an acceptable program:
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Relocate the Emergency Command Center away from the control room.
(219-82-01-22)
In addition to the above finding, the following matters should be considered for improvement:
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Make updated Emergency Plans and Emergency Plan Implementing Procedures available both in the control room and in the Group Shift Supervisor's Office.
(219-82-01-23)
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Provide more space in the area of the control room communications systems.
(219-82-01-24)
4.1.1.2 Technical Support Center (TSC)
Section 7.1.2 of the Emergency Plan described the facilities presently used as the Technical Support Center (TSC). This TSC was located on the 23rd foot level of the Machine Shop building in the Radiological Controls Office area.
The auditors inspected the facilities, held conversations with licensee's personnel, and observed an onsite emergency drill during which the TSC was activated to ascertain its adequacy.
The auditors found that the TSC had an area of 788 square feet. According to Section 2.4 of NUREG-0696, approximately 75 square feet of working space per person shall be provided in the TSC.
Therefore, this TSC would accommodate only 10 individual..-.
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The auditors also noted that, as given in a licensee review, the breathing air ventilation system for the TSC had neither recirculatica nor filtration features which would ensure its habitability for personnel during an accident involving airborne releases of radioactivity. Moreover, there were no dedicated instruments for detecting direct radiation or airborne radioactivity in _ the TSC.
In this regard, during the drill conducted during the appraisal, the auditors noted that radiological measurements and precautions were neglected.
Potassium iodide tablets, self-contained breathing apparatus, and other protective supplies were also lacking in the TSC.
The auditors noted that, although some drawings of systems were available, many schematics and diagrams were not in place. Additionally, the plant's parameters provided by a computer terminal failed to include a complete set of-parameters which would be needed by technical personnel to fully ascertain plant conditions and make adequate recommendations. However, there were means to retrieve meteorological information, although its interpretation and use in the TSC was not clear to personnel involved in the observed drill.
There are approximately 15 dedicated telephone lines installed against one wall of the building.
The telephone were close together, making communications cumbersome and difficult because of mutual interference among users.
Face-to-face interaction between TSC personnel and control room personnel involved going outside of the building, walking in open space about 400 ft.
from the plant stack (possibly being exposed to high airborne contamination),
and using the stairs or elevator to the third floor (approximately 275 steps).
The auditors concluded that the location of the TSC would not be conducive to safe and timely movement between the TSC and the CR. Measured walking time was greater than 2 1/2 minutes.
According to licensee management personnel, the location of the TSC away from the control room and the inadequacy of the TSC to permit management to direct and coordinate emergency response actions was the reason for having an Emergency Contsal Center (ECC) in the control room and having the Emergency Director and his staff located at this ECC. As noted in the foregoing section of this report, this will cause overcrowding and confusion in the control room.
In their September 11, 1981 letter to the Director of the Office of Nuclear Reactor Regulation the licensee presented their conceptual system design description of the Emergency Operations Facilities to be implemented at the Oyster Creek station.
In section 1.0, PURPOSE AND SCOPE, of this discription the licensee stated, "The TSC is to provide, in the event of an emergency, an area outside the Control Room that can accommodate personnel acting in support of the control room personnel.
The TSC is to take over the communications interfacing functions of the control room and is to be used by technical and management personnel in lieu of the Control Room, thereby eliminating the possibility of Control Room congestion." In subsection 3.1, Technical Support Center, of Section 3.0, DESIGN REQUIREMENTS, the licensee stated that the TSC is to be located in the new three-story administration building extension which will be constructed adjacent to the turbine building and the existing office building.
The description of a TSC which would meet the requirements
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of NUREG-0737 and NUREG-0696 was then given. The licensee indicated that they (planned to have the Emergency Operational Facilities operational by October 1,
{1982, dependent upon construction, procurement, and delivery schedules.
During the appraisal, the licensee indicated that they did not plan to build the new three-story administration building extension.
Therefore,.the new TSC wou.d not be provided in accordance with their September 11, 1981, letter to the Director of the Office of Nuclear Reactor Regulation. The licensee had not redefined the conceptual system description for an adequate TSC and had not established a schedule for the provision of the adequate TSC at the time of the appraisal.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
Upgrade the present Technical Support Center with a ventilation system
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providing adequately filtered air, instrumentation to detect direct radiation and airborne contamination, a more comprehensive set of plant drawings, more comprehensive plant parameter data from the computer terminal, more space for the occupants, and better spacing of the telephones.
Also, provide a copy of the results of the TSC shielding study to Region I of the NRC.
(219-82-01-25)
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Resubmit conceptual design information for a suitable TSC which-meets the requirements of the Office of Nuclear Reactor Regulation, February 18,-
1981, Generic Letter 81-10 concerning " Post-TMI Requirements for the Emergency Operations Facility." Also include a schedule showing milestones and the date when the facility will be operational.
(219-82-01-26)
4.1.1.3 Operations Support Center (OSC)
Section 7.1.3 of the Emergency Plan described the Operations Support Center (OSC) as being located in the second floor of the maintenance building.
Presently, it is in the clean instrument shop located near the control room.
The auditors inspected the OSC area described in the Emergency Plan. The space and location would be acceptable. However, communications were totally lacking in that location.
The present OSC location is away from tools and equipment that would be needed for operational support functions. -This location lacks the space to enable simultaneous airborne radioactivity monitoring and communications; and there is no space for personnel to dress in protective clothing or for personnel to sit between assignments.
The licensee acknowledged the desireability of moving the OSC into the maintenance building, but has yet to install the communications system and supplies needed for OSC personnel during emergencies.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
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Locate the Operations Support Center in the maintenance building as
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described in the Emergency Plan. Assure that it has adequate-space, a communications system, personnel protection equipment and supplies, and other equipment and supplies needed for the performance of tasks during an emergency.
(219-82-01-27)
4.1.1.4 Emergency Operations Facility (E0F)
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A brief description of the Nearsite Emergency Operations Facility (NE0F) is given in Section 7.2.1 of the Emergency Plan. The auditors examined the facility, which is located in Building 12 on the adjacent Forked River site.
Building 12 is approximately 1000 meters away from the reactor building on the Oyster Creek site.
The Building 12 structure is such that it can withstand high winds. The ventilation system does not include filtration of the breathing air.
Equipment and supplies in the NEOF were deficient in various areas.
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Radiation detection instrumentation such as low-range and high-range beta / gamma survey meters, friskers, airborne radioactivity monitoring devices, direct radiation general area meters with alarms was inadequate.
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Portable air samplers were inadequate.
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Sources to check the operation of radiation.datection instruments were not available.
Decontamination supplies were not at the NE0F.
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Respiratory protection equipment and protective clothing were not stored at the NEOF.
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Plant drawings, schematics, and diagrams were' lacking.
Means for retrieving meteorological information from the site meteorological
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tower were lacking.
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A backup power supply was lacking.
The auditors found that there was an adequatr supply of personnel dosimetry devices and equipment for reading.and resetting the dosimeters.
The auditor noted that while isopleths were available for radioactive dose projection, they appeared to be incompatible with the maps.
The licensee does not have a Farsite Emergency Operations Facility (FEOF)
located in their Lakewood business office, as described in their Emergency Plan.
Their present FEOF is located in the basement of-the county jail in a corridor adjacent to the County Emergency Operations Center.
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In their September 11, 1981, letter to the Director of the Office of Nuclear Reactor Regulation the licensee presented their conceptual syste.n design
' description of the Emergency Operations Facility and Backup Emergency Operations Facility. The Emergency Operations Facility was to be the Building 12. Forked River site Nearsite Emergency Operations Facility.
The Backup Emergency Operations Facility was to be located in the Jersey Central Pcwer,and Light Lakewood district office.
In Subsection 3.3, Emergency. Operation Facility,, of Section 3.0, DESIGN REQUIREMENTS, of the conceptual system design, description,
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the licensee describes Emergency Operations Facilities'which meet the intent of NRC requirements for emergency facilities.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program.
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Upgrade the Nearsite Emergency Operations Facility located in Building 12
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of the Forked River site with equipment and supplies to allow management and technical personnel to perform emergency functions as described in your September 11, 1981, letter to the Director of.the Office of Nuclear !
Reactor Regulation.
(219-82-01-28)
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Provide a Farsite Emergency Operation Facility which has the same capabilities
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as the Nearsite Emergency Operations Facility as called for in your
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Emergency Plan and in your Septenber 11, 1981, letter to the Director of the Office of Nuclear Reactor Regulation.
(219-82-01-29)
4.1.1.5 Post-Accident Coolant Sampling and Analysis
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The auditors reviewed the licensee's implementation of Sectif on 2.1.8a of NUREG-0578 and Clarification Item II.B.3 of NUREG-0737 to assess the licensee's ability to collect and analyze a high activity reactor coolant sample under-post-accident conditions. The auditors ins,ected the sampling location and equipment, the chemistry laboratory, the counting room, and procedures (see
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section 5.4.2.4); and discussed design parameters with members of the licensee's staff.
o The licensee has determined that system and plant modifications are required
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for their post-accident cooling sampling facilities to meet,section 2.1.8a of NUREG-0578.
In a letter dated January 4, 1980, to the Office of Nuclear
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Reactor Regulation, the licensee provided a summary description of the post-accident coolant sampling equipment.
In this letter, the licensee indicated
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that the modifications described would be implemented prior to January 1,
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1981.
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NUREG-0737, dated November 1980, further defined post-accident sampling
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requirements and established January 1, 1982, as the date when installation of post-accident sampling equipment should be completed.
In a letter dated
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August 27, 1981, to the Office of Nuclear Reactor llegulation the licensee
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requested that the required installation date for~ post-accident samplirig equipment be postponed. They requested that the commitment date for the N
installation be revised to require the installation be completed prior to startup from their Cycle 10 reload refueling / maintenance outage'. This~ outage
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is currently scheduled for about July 1982 through July 1983.
Subsequently, in a letter dated December 24, 1981, to the Office of Nuclear Reactor Regulation the licensee requested that the installation of the post-accident sampling equipment be further postponed to their 1984 Cycle 11 reload / refueling / maintenance
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outage.
The licensee has procured a sampling system which appears capable of meeting the NUREG-0737 specified design criteria.
The benefit of installing this sampling equipment during the Cycle 10 reload / refueling / maintenance outage is evident in the following discussion.
The licensee has not provided any equipment for sampliag the reactor coolant under post-accident conditions to be used in the interim period before the equipment discussed above is installed.
Normal coolant sampling facilities would be used for post-accident sampling, contingent upon the ability to enter the reactor building.
The sampling facilities consisted of a sample sink -
. located on the 51 foot elevation of the reactor building, immediately adjacent to the drywell, and in the general vicinity of the reactor coolant cleanup
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system pumps.
These facilities appeared to impose major constraints on the collection'of samples under post-accident conditions. The three major constraints
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are: (1) the.high radiation dose rates which personnel would encounter in
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gaining access'to the sampling equipment; (2) the personnel dose rates encountered while performing the sampling; and (3) the problems associated with the lack of containment of the coolant during sampling.
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In regard to the radiation dose rates which personnel would encounter in gaining access to the sampling equipment, access to the sampling sink area required passing through a locked high radiation area (implying potential radiation levels greater than 1000 mR/hr). The locked high radiation area was
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attributed to the cleanup system pumps located approximately 20 feet from the sample sink.
Under post-accident conditions, these pumps and their associated
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piping could contain activity sufficient to preclude or seriously limit the ability to collect a coolant sample.
In regard to the personnel radiation dose rates encountered while performing the sampling, sample lines were observed to be unshielded and routed such that close proximity to them during sampling could not be avoided.
Cooling coils
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were located near head level and would constitute a relatively large-volume of reactor coolant at the sampling station.
The licensee had made no effort to
determine coolant activity levels which personnel could sample without exceeding k)
NRC exoosure criteria or epa protection action guides. The dose rate at the sampling sink was observed to be 20-30 mR/hr during cold shutdown conditions and appeared attributable primarily to a drain header approximately eight' feet away.
Licensee technicians stated that the area dose rate during full power operation was approximately 70-100 mR/hr. An area radiation monitor (ARM)
located in the cleanup system pump vicinity was noted to read about 200 mR/hr
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during cold shutdown.
No other ARM was noted near the sample sink, and the discrepancy between the cleanup system pump ARM and the 20 mR/hr dose rate measure at the sample sink would appear to indicate that the ARM readings are
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In regard to the problems associated with the lack of containment of the coolant during sampling, no containment had been provided for the coolant, other than the sample sink and its associated drain piping. The sample flowed from an open rubber tube into the sink drain.
No hood was provided for ventilation control.
The drain piping was routed to the reactor building equipment drain tank which was openly vented to the reactor building. Therefore, all gases released during the sampling process would be directly released to the sample sink ares and to the reactor building.
The chemistry lab was located in the basement of the office building. The chemistry lab was noted to include two hoods for processing of samples and -
appeared to have an adequate supply of micropipettes, breakers, flasks, etc.
Remote handling tools were contained in a locker in the chemistry lab and included two extension grips (3 foot and 5 foot) and several spare manipulating fingers. These tools appeared adequate for valve manipulation, handling, and transport of samples. The licensee also had sample transport shielded casks suited for 15 m1 sample vials.
The counting room was located in the auxiliary office building.
It had Ge(Li),
sodium iodide, gross beta, gross alpha, and tritium counting systems. No special provisions were made for post-accident coolant sample counting.
The auditors concluded that the licensee's ability to collect high activity post-accident coolant samples is limited to something above normal coolant activity levels (0.1 microcurie / gram), but substantially below (probably several orders of magnitude) the upper NUREG-0737 category B design specification of 10 curies / gram. The auditors were unable to further bracket the licensee's capability.
Based on the above findings, improvements in the following areas are required to. achieve an acceptable program:
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Install a system capable of collecting a high activity sample-(up to 10 curies / gram) under post-accident conditions per NUREG-0737 specifications.
(219-82-01-30)
Define and predetermine conditions under which reactor building accessibility
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for interim-type coolant sampling can be reasonably expected or precluded.
(219-82-01-31)
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Determine reactor coolant radioactivity levels which can be sampled using the interim-type facilities without exceeding appropriate NRC exposure criteria or EPA protective action guides.
(219-82-01-32)
4.1.1.6 Post-Accident Containment Air Sampling and Analysis The auditors reviewed the licensee's facilities for sampling and analyzing containment air under post-accident conditions.
Criteria contained in NUREG-0578 and NUREG-0737 were used for comparison. The auditors inspected the facilities, reviewed sampling and analytical procedures (see Section 5.4.2.6), and held
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discussions with the Manager - Chemistry, Engineer-Chemistry, Chemistry supervisor, and Chemistry technicians.
A post-accident sampling system designed to meet the NUREG-0737 category B
requirements for containment sampling has been procured; however, the licensee has requested permission from the NRC to postpone installation until 1984.
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The benefit of installing this equipment during their Cycle 10 reload /
refueling / maintenance outage scheduled for mid-1982 through mid-1983 is ev' dent in the following discussion.
The current post-accident containment air sampling location was found to be two sample taps in the back panel of the drywell oxygen analyzer in the reactor building.
The ability for personnel to collect a containment air sample was noted to be contingent upon reactor building accessibility. The licensee has determined that the reactor building would not be accessible under an emergency with NRC specified source term conditions; however, the licensee has not evaluated accessibility for less severe releases.
Special shielding for the sampling facility had not been provided, and the need for shielding had not been evaluated.
No prepositioned sampling equipment was maintained at the sampling location, nor was there a designated post-accident. containment air sampling kit.
Sample analysis facilities, including both the chemistry laboratory and counting room, were noted to be the same as those for coolant sample analysis and are described in section 4.1.1.5 of this report. An alternate chemistry lab was not readily available. Alternate counting facilities were noted to be available in the health physics work area of the new maintenance building. No special analytical facilities were provided for post-accident sample analysis.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
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Provide facilities capable of collecting a containment air sample under conditions specified in NUREG-0737.
(219-82-01-33)
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Define and predetermine conditions under which reactor building accessibility for interim-type containment air sampling can be reasonably expected or
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precluded.
(219-82-01-34)
4.1.1.7 Post-Accident Gas and Particulate Effluent Sampling and Analysis The licensee's facilities for collection and analysis of post-accident gas and particulate effluent samples were reviewed by the auditors.
Criteria used for the evaluation are contained in NUREG-0737,Section II.F.1, Attachment 2, Table II.F.1-2.
Selected facilities were inspected, procedures were reviewed (see Section 5.4.2.8), and licensee personnel were interviewed.
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The licensee has identified the following facilities as potential airborne
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release points for post-accident sampling purposes: plant stack, turbine
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building vents, and the augmented-off gas (A0G) building vent. No special post-accident sampling locations had been defined. The licensee intended to use existing normal sample locations and normal monitoring system in-stack -
probes. The turbine building vent ducts have not been routinely sampled, and no samp.ing probe exists.
(This item is further discussed in Section 5.4.2.8).
A new radioactive gaseous effluents isotopic monitoring system (RGEIMS) has been procured for installation on the plant stack. This system appeared to be capable of meeting the NUREG-0737, Table II.F.1-2, criteria. The auditors could not completely appraise the system, since installation had not been completed, calibration had not been performed, and procedures describing its use were not in place. However, the auditor did note that the system consisted of three high purity germanium detectors for continuous on-line monitoring of a particulate cartridge, an iodine cartridge, and noble gas.
The system incorporated automatic variable frequency cartridge change out, gas monitor purging, and remote computer analysis and readout.
The licensee indicated a February 1982 operational date for the RGEIMS had been scheduled, but delays in obtaining calibration standards may cause slippage.
The appraisal team believed that installation of this system should be completed as expeditiously as possible.
The licensee indicated a second RGEIMS had been procured for installation on the turbine building vent system.
Installation would be performed after major modifications to the turbine building ventilation system have been completed.
The potential post-accident radioactivity levels for the augmented-off gas building sampling allow the use of the normal sampling equipment and no RGEMIS is required for this release point.
With regard to the present post-accident gas and particulate effluent sampling facilities, the normal sample collection facilities have not been shielded, and the licensee has not determined accessibility or potential inability to change out normal particulate and iodine samples due to radioactivity build-up from routine sample collection of post-accident effluents.
Such build-up r
could preclude particulate filter and iodine cartridges change out under the NUREG-0737, Table II.F.1-2, specified concentration and sampling time.
Also, with regard to present post-accident sampling capability, the licensee did not have necessary equipment such as air sample pumps, collection devices, sample location shielding, and shielded sample transport casks readily available for use during an emergency.
As noted in previous sections, 4.1.1.5 and 4.1.1.6, no analytical facilities beyond those available for routine sample analysis have been provided. -Provisions for handling and analysis of high activity samples have not been provided.
The licensee indicated samples having direct radiation levels greater than approximately 100 mR/hr have not been considered in determining analytical capabilities.
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~25 Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
Complete the installation and calibration of the new stack and turbine
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building vent radiological effluent gaseous monitoring systems.
(219-82-01-35)
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Develop an interim-type methodology to collect and analyze high activity post-accident gaseous, particulate, and iodine samples consistent with the activity levels identified in Table II.F.1-2 of NUREG-0737. Con:ideration should be given to any restrictions posed by direct radiation exposure from normal monitoring and sampling equipment which might have been operating under accident release conditions.
(219-82-01-36)
4.1.1.8 Post-Accident Liquid Effluent Sampling and Analysis The auditors reviewed the licensee's facilities for sampling and analysis of t
liquid effluents under post-accident conditions.
In addition, the licensee's capability for handling large volumes of contaminated water which might be generated as a result of accident conditions was also reviewed.
No special sampling or analysis facilities have been provided for post-accident condition use; normal facilities are utilized.
However, given the licensee's intent to not discharge liquids under accident conditions and the storage capability discussed below, the existing sampling facilities appeared adequate.
Analytical facilities, however, may be grossly affected by elevated background radiation resulting from shine from major radioactivity releases to containment, the reactor building, and the stack (see Section 5.4.2.11 for further discussion).
The licensee appeared to have adequate facilities for storage of contaminated
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water. -These included the torus and torus room within the reactor building (for relatively high activity water), and the following outside storage tanks for low activity water: a 10,000 gallon waste surge tank, two 30,000 gallon and two 12,000 gallon processed rad waste storage tanks, the 750,000 gallon torus water storage tank, and the 500,000 gallon augmented fire prevention water tank which is under construction. Under normal operating conditions, the waste surge tank and torus water storage tank would be available on relatively short notice. The augmented fire prevention water tank would be filled with radiologically clean water which could be dumped if the storage space were needed.
~ Based on the above findings, this portion of the licensee's program appeared acceptable.
4.1.1.9 Offsite Laboratory Facilities
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-The availability of offsite laboratory facilities and equipment to either assist the onsite laboratory or take its place was reviewed.
The three vans (one onsite and two offsite) equipped to monitor the atmospheric and terrestrial environments for radioactivity were also examined.
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During the discussion regarding offsite laboratories available to assist or take the place of the onsite laboratory, the licensee stated that the laboratory facilities at Three Mile Island and at the GPU Nuclear Environmental Assessment Command Center near Harrisburg, Pennsylvania, were available. Both fact 11 ties could adequately take over for, or assist, the onsite laboratory facilities.
However, both facilities are about 180 road miles away from the Oyster Creek'
j site. This is an appreciable distance to transport samples. Also, considerable time would be involved in transporting the samples.
Equipment for the vans include an air sampler, a gasoline generator, and the supplies in an emergency monitoring kit which is listed in Appendix C of the Emergency Plan. While examining the air sampling equipment, it was noted that the filter holders on the sampler were sized to hold a St _,tt filter rather than the Science Applications, Inc. silver zeolite filter cartridges. The air could bypass the filter, and a representative sample would not be taken.
This and other deficiencies in the vans and the equipment are discussed further in sections. 4.2.1.1 and 7.2 of this report.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for. improvement:
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Provide a mobile laboratory to perform reactor coolant and other pertinent
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analyses during emergencies. (219-82-01-37)
4.1.2 Protective Facilities l
4.1.2.1 Assembly / Reassembly Areas l
The auditors reviewed the Emergency Plan and the Emergency Plan Implementing Procedures concerning the assembly areas used as personnel protection facilities t
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during the accounting for personnel.
The auditors examined the facilities.
l The onsite assembly area for nonessential personnel located in the protected
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area but not in radiation work permit areas, is a designated location in the materials management warehouse. The assembly area in the radiation work permit areas located within the reactor building and the turbine building is the monitor and control area.
The remote assembly area for use during site evacuations is located at the Jersey Central Power and Light Berkeley Operations Headquarters.
The onsite facilities provide protective clothing, respiratory protection equipment, adequate lighting, and communications equipment.
Based on the-above findings, this portion of the licensee's program appears to be acceptable.
4.1.2.2 Medical Treatment Facilities Emergency first aid and medical treatment facilities provide treatment ranging from simple first aid to hospital care.
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Small first aid kits and stretchers are located throughout the plant.
These
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kits contain supplies for treating minor injuries.
The next level of medical treatment facility is the plant First Aid Station located at-the North Access Portal.
Supplies of potassium iodide for thyroid blocking of emergency workers are stored at the station.
The station was crowded with five persons.
Placement of equipment and supply storage was poorly organized.
The ststion is easily accessible by stretchers and ambulances.
A registered nurse is available at the First Aid Station during weekdays and is on call 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, seven days a week. An emergency medical technician serves as an alternate to the nurse.
Ambulance service is normally provided by the Lacey Township First Aid Squad.
The squad takes about 10 minutes to respond.
Bayville Township First Aid Squad may also provide ambulance service.
Community Memorial Hospital in Toms River, New Jersey, provides the hospital facilities.
The Community Memorial Hospital facilities were centered around the morgue, which has two operating tables for use. The facilities were readily isolated
from the rest of the hospital, and preparedness for handling injured and contaminated persons was readily apparent. Additional arrangements for hospital and medical services are provided by the Radiation Management Corporation.
The licensee has letters of agreement with the first aid squads, the hospital, and Radiation Management Corporation concerning their emergency support.
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Based on the above findings, this portion of the licensee's program appears acceptable, but the following matter should be considered for improvement:
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Provide more room in the First Aid Station for personnel and equipment and for storage of emergency supplies.
(219-82-01-38)
4.1.2.3 Decontamination Facilities The auditors reviewed Section 6.6.2, First Aid and Decontamination, of Emergency Plan and EPIP-21, Personnel Decontamination.
According to EPIP-21, the personnel decontamination areas were located at the Monitor and Control Area at the Oyster Creek site and Building 12 at the Forked River site.
At the Oyster Creek site, the decontamination area was in close proximity to the onsite medical facility. Adequate radiation survey instrumentation was available. The decontamination supplies and equipment were available as specified in the plan and implementing procedures.
There were provisions for proper disposal of contaminated solid and liquid waste. However, there were no provisions for replacement clothing.
At the Forked River site, the decontamination supplies and facilities were not adequate.
Licensee personel indicated that EPIP-21 was being revised to
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remove the Forked River Building 12 as a decontamination facility. This action will eliminate any decontamination facilities located offsite from the Oyster Creek Nuclear Generating Station site.
In addition, the licensee does not have decontamination facilities at their Remote Assembly Area located at their Berkeley Operating Headquarters.
EPIP-18, Activation of the Remote Assembly Area, calls for a fully qualified Radiological Control Technician with appropriate monitoring equipment to-be at the Remote Assembly Area. The action this Radiation Control Technician is to take to decontaminate personnel is not defined. -It is obvious that needed decontamination of personnel may not be possible.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be considered for improvement:
Provide decontamination facilities at the Berkeley Operating Headquarters
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Remote Assembly Area.
(219-82-01-39)
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Provide for replacement clothing in the decontamination facilities.
(219-82-01-40)
4.1.3 Expanded Support Facilities The inspector examined the Expanded Support Facilities. Office space is available for 32 persons in Building 12 and for 15 persons in movable trailers with office equipment and communications which are tied into the plant systems.
Additional space is available in Buildings #14 and #5 and the training building, if necessary.
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Plans for the near future are in process to have a 15-trailer complex to house 50 persons and a 17-trailer complex to house 80 persons.
These facilities will be located outside the protected area.
Based on the above findings, this portion of the licensee's program appears to be adequate.
4.1.4 News Center The Media Center has been established at the Toms River Elks Club in Toms River, New Jersey, in accordance with the Emergency Plan.
Equipment at the center includes telephone service (25 telephone jacks),
adequate power supply sources for media equipment, copying capability, public address system, and audio-visual equipment.
The Security Organization will provide crowd and access control support. The center was considered adequate to meet Emergency News Management needs.
i Based on the above findings, this portion of the licensee's program appears to be acceptable.
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4.2 Emergency Equipment 4.2.1 Assessment Equipment 4.2.1.1 Emergency Kits and Emergency Survey Instrumentation The auditors reviewed Section 6.5.3, Emergency Equipment Readiness, of the Emergen:y Plan, and Emergency Plan Administrative Procedure (EPAP)-05, Rev. O, Emergen y Equipment Inventory.
The auditors also examined the inventory of emergency supplies at most of the assigned locations.
The licensee had selectively pre positionea emergency supplies and radiation survey and air sampling eauipment at the Main Gate Processing Center, the Control Room / Group Shift Supervisor's Office, the Monitor and Control Area, the Office Building, the Auxiliary Office Building, the Technical Support-Center, the Operations Support Center, the Nearsite Emergency Operations Facility, and the Farsite Emergency Operations Facility.
Examination of the inventory of equipment in the emergency kits, the emergency instrument kits, and the lockers disclosed that the kits and lockers did not contain all the equipment and supplies specified in EPAP-05.
Licensee personnel stated that the missing material was on order through their inventory control system. This lack of supplies could hamper the effectiveness of emergency teams dependent upon the kits for supplies and equipment for use during an emergency.
The portable equipment available to survey teams included radiation detection instrumentation suitable for detecting beta and gamma radiation fields and for detecting beta and gamma radioactive contamination.
The instrumentation (Eberline PS-2) used for emergency environmental surveys have the capability-to detect and measure radioiodine concentrations in air of at least 1E-07 pCi/cc under field conditions in any kind of weather without regard to the presence of noble gases and background radiation.
During the observation of personnel performing walk-throughs of the offsite monitoring duties (section 7.2 of this report), the auditor observed deficiencies in the equipment supplied to the offsite teams.
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The scaler in one van was inoperable.
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There were no check sources for use in performing dose rate instrument response checks as required by EPIP-11.
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There was no power for operating the air sampler available in one van.
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The Science Application radioiodine filter cartridge was incompatible with the Scott air sampler filter chamber.
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The air sampler could not be moved away from the van and raised above ground level, if necessary, to obtain a representative air sample.
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There was in plant instrumentation for detecting airborne radiciodine in the presence of noble gases.
Instruments were properly maintained on a routine schedule; operability and calibration checks were performed quarterly or after each use with inoperable or malfunctioning instruments promptly repaired or replaced.
Radiological controls procedures, series 900, provides written procedures for calibration of emergency radiation instruments.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be considered for improvement:
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Provide emergency equipment and supplies in emergency kits n specified in procedure EPAP-05, Rev. O.
(219-82-01-41)
Provide proper operable equipment for the offsite monitoring teams by
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assuring that scalers are operable, check sources are available, power sources for air samplers are available, filter chambers on air samolers accommodate the filter cartridges, and air samplers can be placed to take a representative sample.
(219-82-01-42)
4.2.1.2 Area and Process Radiation Monitors The area radiation monitors (ARM's) and process radiation monitors (PRM's) in place,.except for those in the Radwaste Building and Radwaste Process, are basically original station equipment.
The range of the ARM's usually had an upper measurement level of 10' milliroentgen per hour (mR/hr).
It was noted by the auditor, while the plant was not operating, that the radiation levels in some areas were in the upper part of the range of the ARM. A 10-fold increase in radiation level in the area probably could not be measurad because of this range limitation.
If this is the situation, it would require correction because an " Action Level Criteria" given in Table 4.1 of the Emergency Plan and an " Emergency Action Level" (EAL) given in Section 3.2 of EPIP-3 is a 10-fold increase in plant radiation levels.
According to Table 4.1 of the Emergency Plan, entitled, ACTION LEVEL CRITERIA FOR CLASSIFICATION OF EMERGENCY CONDITIONS, radiation levels above a given
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setting for four different ARM's could indicate a main steamlin_e break. The
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l Emergency Plan Implementing Procedures which are to be used in detecting and classifying emergency conditions do not address these emergency action levels
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for the radiation levels measured by these ARM's. Also, according to Table 4.1 of the Emergency Plan, the radiation levels measured by certain PRM's provide Action Level Criteria.
The PRM's mentioned are the stack gas monitors, offgas monitors, steamline radiation monitors, radwaste discherge monitors, vent #1/#2 radiation monitors, service water discharge monitor, and the Radwaste Building ventilation system monitor.
In this case, the Emergency Plan Implementing Procedures for detecting and classifying emergency conditions only provided Emergency Action levels for the stack gas monitors and offgas monitors.
(The offgas monitor EAL's only appear in EPIP-1).
The Emergency Plan Implementing Procedures for detecting and classifying emergency conditions must provide for the use of all pertinent area and process radiation data.
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It also appeared that the number of ARM's and the range of the ARM's would not be adequate for the mapping of post-accident radiation conditions to meet ANSI-N320.
The calibration of the PRM's was not performed across the entire range of the instruments. The licensee's auditing team found that the maintenance of the instruments to ensure their readability was deficient.
Based or. the above findings, improvements in the following areas are required to achieve an acceptable program:
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Incorporate all area and process radiation Emergency Action Levels given in the Emergency Plan into the Emergency Plan Implementing Procedures.
(219-82-01-43)
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Perform an engineering study of existing Area Radiation Monitors.(ARM's)
and Process Radiation Monitors (PRM's) to determine the upgrading necessary to the monitoring system to provide adequate cccident detection and classification and post-accident radiation mapping capabilities to meet ANSI-N320.
Incorporate the results of the study in the Emergency Plan and the Emergency Plan Implementing Procedures.
(219-82-01-44)
4.2.1.3 Non-Radiation Process Monitors
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The process monitors described in Table 4.3, INSTRUMENTS FOR ACCIDENT DETECTION, of the Emergency Plan measuring vital non-radiological parameters, such as pressure and temperature used for accident detection, classification, and assessment were found in place and operable. Monitor readouts were accessible in the control room and readily observable.
Based on the above findings, this portion of the licensee's program appeared to be acceptable.
4.2.1.4 Meteorological Instrumentation The review of the licensee's meteorological measurement program was based on guidance given in Regulatory Guides 1.23 and 1.97, as well as criteria found in NUREGs-0654, 0696, and 0737.
EPIP-9 and Section 7.6.1.1 of the Emergency Plan were reviewed and the meteorological system was examined.
The present onsite meteorological measurements are made using a primary 400-foot tower. Wind speeds and directions are measured at the 33, 150, and 380-foot levels. Vertical temperature difference is measured between 33 and 150 feet as a measure of atmospheric stability.
Redundant wind sensors are situated at
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the 33 and 380-foot levels.
Precipitation is measured at ground level near the tower.
The meteorological data is telemetered to strip chart recorders in the control room and the instrument shelter. The data is also telemetered to a computer in the shelter for storage of the 15-minute averaged data.
The data is also telemetered to the Digital Graphics, Inc. (DGI) computer facility in Rockville, I
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Maryland, and to the GPU Computer Center in Reading, Pennsylvania. The meteorogical data is orally transmitted from the control room to the TSC and NEOF for use in the manual dose calculation procedures.
During the observation of the instrument shelter and control room, the auditor noted the strip charts were not set to the correct clock time. The licensee
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attributed this to the unavailability of correct charts from the recorder supplier. A backorder for the charts had been placed and was to be filled as soon as possible.
Quarterly calibrations of the meteorological sensors were done by a contractor,
= weekly visits to the meteorology tower were done by a GPU technician, and checks of the readout were done by control room personnel to assure data recovery rates identified in Regulatory Guide 1.23.
There were neither redundant power supplies to the tower nor procedures to obtain meteorological data from other sources should electrical power to the tower or the tower itself be lost.
Should site meteorological data be lost, other meteorological data sources such as Lakehurst Naval Air Station, McGuire Air Force Base, and the National Weather Service at Atlantic City could be contacted via telephone.
A contract with Weather Services International (WSI) will provide routine and severe weather information through a telephone and computer terminal system.
The meteorological data system cannot be remotely interrogated by offsite
agencies to assess meteorological conditions. Access for remote interrogation
should be provided.
Since the 0yster Creek site is near the Atlantic Ocean and Barnegat Bay, the potential need is indicated for a supplementary meteorological tower or source of data to assess the possible effect of sea breeze circulation on effluent
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plume transport.
The auditors found that the measurement program provides acceptable information
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on wind speed, wind direction, and atmospheric stability for use in the class A assessment model.
Based upon the above findings, this portion of the licensee's program is acceptable, but the following matters should be considered for improvement:
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Provide either a redundant power supply to the meteorological tower or develop a procedure for obtaining representative meteorological data if the tower measurements are unavailable.
(219-82-01-45)
Establish a remote interrogation capability for the meteorological data
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for use by offsite agencies.
(219-82-01-46)
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Establish a supplementary meteorological tower or develop procedures to assess the possible effects of sea breeze circulations on the effluent plume transport.
(219-82-01-47)
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i 4.2.2 Protective Equipment 4.2.2.1 Respiratory protection
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The auditors reviewed the availability and amount of filtered and self-contained air masks. Of the filtered air masks, about 1000 are located in the Issue Trailer, and about 100 are located at different onsite points such as the
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Control Room, OSC, and radiation control points.
Approximately 60 self-contained breathing apparatus (SCBA) are available on the site with about 80 refillable bottles.
In an emergency, additional SCBA's are available from Three Mile Island.
Refilling of air bottles is presently done by Delaware Valley Safeguards, Inc., in Pennsylvania. The licensee is currently considering the establishment of a bottle refilling capability onsite.
Based upon the above findings, this portion of the licensee's program appears to be acceptable.
4.2.2.2 Protective Clothing The auditor reviewed the availability of protective clothing onsite'that would be used during an emergency.
There is an ample' supply of protective clothing which would be accessible during an emergency. About 25,000 pairs of blue coveralls are available, and about 22,500 yellow coveralls are on order to replace the blue ones. About 5,000 new coveralls are in the warehouse, the onsite assembly area. About 2000 pairs of disposable paper coveralls (one month's supply) are also available.
The coveralls, plus other protective clothing such as gloves, shoe covers, hoods, are available at several locations at the plant. Stores of protective
clothing in 55 gallon drums are located in trailers which can be moved to be readily accessible during an emergency.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.2.3 Emergency Communications Equipment The onsite and offsite communications system capabilities are listed in the table below. The acronyms used in the table are as follows:
CR - Control Room OSC - Operations Support Center TSC - Technical Support Center NEOF - Nearsite Emergency Operations Facility FEOF - Farsite Emergency Operations Facility RADCON - Radiological Control NRC - Nuclear Regulatory Commission
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HPN - Health Physics Network-ENS - Emergency Notification System ECC - Emergency Control Center N.J. - New Jersey BRP - Cureau of Radiation Protection GE - General Electric E0C - Emergency Operations Center SYSTEM IDENTIFICATION TYPE CONNECTING Operations Line Two Digit Rotary CR, CSC, TSC, Dialing NEOF**, FEOF Radiological Line Two Digit Rotary CR, TSC, OSC, Dialing RADCON, RADCON COUNTR00M, NEOF**,
FE0F NRC (HPN)
Two Digit Rotary CR, TSC, NEOF**,
Dialing FEOF, RADCON,
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NRC RESIDENT, NRC BETHESDA,
NRC REGIONAL OFFICE-NRC (ENS)
Direct CR, ECC, CONFERENCE Supervised ROOM, TSC, NRC RESIDENT, NEOF**,
NRC REGION, NRC BETHESDA N.J. State Notification /
CR, TSC, NEOF,-
Hotline Verification - Direct-STATE EMERGENCY Line (Dedicated)
COMMAND CENTER N.J. Bureau-Nctification/
CR,.TSC, NEOF, of Radiation Verification - Direct-BRP HQTRS, BRP Protection Line'(Dedicated)
EMER. OPS CENTER Tech. Functions Two Digit Rotary CR, TSC, NEOF**,
Line Dialing FEOF, GPU TECH.
CENTER News Line Two Digit Rotary CR, TSC, NEOF**,
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Dialing EMERGENCY NEWS CENTER, FEOF, MEDIA CTR.
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Emergency Dedicated / Direct CR, TSC, NE0F Directors - Hot Line
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SYSTEM IDENTIFICATION TYPE CONNECTING Emergency Two Digit Rotary CR, TSC, OSC, Directors Line Dialing NE0F**, FEOF, GPU CORP. HQTRS., GPU TECH. CENTER Plant Status Two Digit Rotary CR, TSC, OSC, Update Line Dialing NEOF**, FEOF Parsippany/
Two Digit Rotary CR, ECC, GPU
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General Elect. Line*
Dialing TECH. FUNCTIONS CENTER, GE EMER.
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SUPP. CENTER Ocean Co.
Dedicated / Direct SHERIFFS CENTER E0C Line Notification /
CR, TSC, NE0F Verification Lines i
" STATE" Two-way TSC, NEOF**,
Emergency.
Auto Ring.
STATE EOC
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Director's Line General Information Two Digit CR, TSC, OSC, Line Rotary Dialing NEOF**, FEOF Emergency Directors Automatic Dialing ACTIVATE SELECT
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Auto Dialer System *
EMERGENCY ORGANIZATION
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WHEN REQD N.J. Bell _ System Site Dimensions THROUGHOUT
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Conventional Phones LICENSEE-REALTY LOCATIONS Microwave Corporate Grid Net GRID LOCATIONS AND MOBILE UNITS-Radio Communications Security 2 Grid Radio SITE AND OTHER Mobile Units GPU LOCATIONS Plant Paging Telephone PERMANENT AND-System JACK LOCATIONS THROUGHOUT PLANT Maintenance and Sound Telephones
. JACK LOCATIONS Instrumentation Telephone System i
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SYSTEM IDENTIFICATION TYPE CONNECTING Station Security /
Two Digit CR, TSC, OSC, Accountability Line***
Rotary Dialing NEOF, MAIN GATE, NORTH GATE, SHERIFF,
-WARE-HOUSE BADGE AREA, WAREHOUSE ASSEMBLY AREA.
Not yet installed. Approved budget item.
Estimated installation summer
1982.
When offsite power at Forked River is lost, these systems in the NEOF
have no power.
Conventional telephones throughout the NE0F and other Forked River offices would still have power.
There are'about 75 conventional telephones on the Forked River site. The NRC ENS and HPN systems at the NE0F would also be left without power.
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In final phase of installation.
The licensee is considering the installation of another two-digit rotary dialing system for use by the Environmental Assessment Command Center (EACC)
to communicate with the CR, TSC, OSC, NEOF, FEOF, and the Environmental Meteor-
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ological Section. Currently, the EACC uses a security organization radio channel on a remote transmitter / receiver to communicate with the offsite monitoring teams. The licensee-is considering supplying the EACC with a-separate radio system with a-10 mile range capability for communication.with
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the offsite monitoring teams. The EACC is also to have a remote data link backup line with the meteorological tower.
A new site alarm system is currently being installed to support Emergency Plan Program needs. The old system will be used until the new system is operational.
The new alarms and their meanings are given below.
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Reactor Building Evacuation Alarm - a high pitched steady tone which means that all personnel in the Reactor Building must evacuate immediately.
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Site Evacuation Alarm - a warbling tone which means that the site is to be evacuated. All personnel will proceed to the Remote Assembly Area as directed.
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Site Accountability Alarm - a continuous wailing tone which indicates that personnel are to report to their assigned site emergency assembly-area or to their assigned emergency duty station.
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Site Alert Alarm - An oscillating hi-lo tone which notifies site personnel to be alert for an announcement which will follow on the PA system.
Such an announcement may include personnel injuries, declaration of plant emergency status, or other emergency situation.
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Site Fire Alarm - a repeating chime tone which indicates a fire on site.
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Members of the Fire Brigade will proceed to their stations as directed.
It was noted during the appraisal that the licensee was educating onsite personnel on the new system.
Visible light alarms will be installed in high noise areas to supplement the audible alarms.
There were no organized procedures which assured the testing and maintenance of the communications systems and provided operating instru::tions.
Responsibility
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for maintaining these systems was not assigned.
There is a 24-hour per day capability via commercial and NRC ENS and HPN lines to notify the NRC of any emergency conditien. The auditor observed such notification being accomplished -on January 9, 1982 during a fire emergency affecting the Reactor Building.
Redundant power source capability for offsite NEOF, Media Center, and FEOF dial rotary systems was not available. The licensee was studying this problem at the time of this appraisal.
Back-up power for onsite alarm systems is supplied by the diesel generators off the vital bus.
It was noted during a licensee drill on January 7, 1982, that personnel assigned to communicator positions could not effectively communicate plant parameter
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information.
This hampered the exchange of technical data throughout the Emergency Organization.
It was also noted in QA Audit Report S-0C-81-19 that
" Emergency tasks to be performed by... communicators have not been defined".
It was also noted in another GPU Sponsored Audit, EP-196-81, that "No communications / telephone logbooks, or legsheets were found in this facility".
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be considered for improvement:
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Develop procedures that assure the testing and maintenance of communications equipment and provide instructions for the use of all communications systems and equipment.
(219-82-01-48)
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Identify communicators with regard to technical background, and train and qualify the communicators prior to assignment to the emergency organization.
(219-82-01-49)
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Provide back-up power supply system for all communications equipment identified for usage during an emergency.
(219-82-01-50)
4.2.4 Damage Control / Corrective Action and Maintenance-Equipment and Supplies The auditors reviewed Section 7.9, Damage Control, of the Emergency Plans and-the Emergency Plan Implementing Procedure, EPIP-14, Damage Control.
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The licensee relies upon the normal onsite inventory of supplies, of survey instruments,-dosimeters, protective clothing, and equipment to adequately support any emergency operations. These supplies were readily available; however, neither the Emergency Plan nor the procedure (EPIP-14) specifically designated where damage control / corrective action and maintenance equipment and supplies could be obtained.
The auditors noted that the licensee maintained routine stocks of equipment, supplies, and spare parts; however, the licensee had not identified such items
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i specifically for damage control purposes.
Licensee personnel stated that the equipment which would be needed to support damage control / corrective action activities had been evaluated, and such needed equipment is included and maintained in the routine inventory level of stocks.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
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Designate in the procedure (EPIP-14) where damage control teams would acquire specific equipment required to perform their function.
(219-82-01-51)
4.2.5 Reserve Emergency Supplies'and Equipment
The licensee relies upon the normal onsite inventory of supplies of survey
instruments, dosimeters, protective clothing, and equipment to adequately support any emergency-operations.
Reserve emergency supplies are stocked in the Radiological Controls Department offices and a site warehouse where minimum stock inventory levels are maintained.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.2.6 Transportation The auditor reviewed the appropriate sections of the Emergency Plan and the pertinent Emergency Plan Implementing Procedures (EPIP's) concerning emergency-type transportation, and the auditor interviewed appropriate licensee personnel i
concerning the availability of vehicles for use during various emergency situations.
According to the licensee, they have three vans available for use by the onsite and offsite monitoring teams. The van available to the onsite monitoring team was controlled by the Radiological Control (RADCON) organization. The
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two vans available to the offsite monitoring teams were controlled by the Emergency Planning organization at Building 12 on the Forked River site, the location of both the Environmental Assessment Command Center and the Nearsite Emergency Operations Facility.
The keys to the vehicles are controlled by the concerned organization and available to the monitoring teams on a 24-hour per day, 7 day per week basis. The Security organization also has keys to all licensee vehicles, and these keys may be used if needed.
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There was a lack of agreement with the foregoing transportation arrangements in the EPIP's for the monitoring teams.
EPIP-10, EMERGENCY RADIOLOGICAL SURVEYS, ONSITE, and EPIP-11, EMERGENCY RADIOLOGICAL SURVEYS, OFFSITE, state that transportation shall be acquired from the Security organization.
The licensee should review this situation and revise the EPIP's as necessary to reflect the arrangements made for transportation of the monitoring teams.
Also concerning the transportation for the offsite monitoring teams during a January 1982 drill, the teams found that their assigned vans had flat tires.
This points out a need for a preventative maintenance program for these vehicles.
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With regard to ambulance service, the Lacey Township First Aid Squad has four ambulances available, and the Bayville First Aid Squad has three ambulances which could be used to transport injured personnel from the site to the nearest available hospital.
According to the licensee, helicopter support has been available upon need from the New Jersey State Police and from the Keystone Company in Philadelphia, Pennsylvania, on a contract basis.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
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Formalize responsibility for the control of vehicles designated for emergency use, revise the Emergency Plan Implementing Procedures to reflect this vehicle control, and assure the vehicles are maintained in a state of readiness for emergency use.
(219-82-01-52)
5.0 EMERGENCY IMPLEMENTING PROCEDURES The licensee has established 10 Emergency Plan Administrative Procedures (EPAP's) and 26 Emergency Plan Implementing Procedures (EPIP's). The auditors reviewed the Emergency Plan and these procedures. The auditors examined these procedures and other pertinent operating procedures and interviewed licensee personnel.
Licensee Emergency Preparedness management indicated that they were presently performing a comprehensive review, revision, and expansion of their EPIP's and EPAP's.
5.1 General Content and Format The EPAP's have subjects pertaining to the taking of the inventory of emergency equipment; the training of emergency response personnel; the preparation, revision, and approval of the EPAP's and EPIP's; and the maintenance of emergency preparedness.
The format of the EPAP's include these sections: Documentation, Introduction, and Procedur ;
The EPIP's address the definition and classification of emergency conditions; the implementation of the appropriate actions depending upon the emergency classification; the actions to be taken for personnel injury, fire, damage control, toxic / flammable gas release, radioactive liquid release, and persennel decontamination; offsite dose assessment; onsite and offsite enargency radiological surveys; personnel evacuation; accounting for personnel; search and rescue operations; thyroid blocking; activiation of the different emergency facilities; and recovery operations.
Two different formats are used in the EPIP's depending on their subjects.
First, EPIP's 1 - 5 address the definition and classification of emergency conditions and the implementation of appropriate actions depending upon the emergency classification. These EPIP's have five sections entitled: Purpose, Attachments, Emergency Action Levels, Emergency Actions, and Final Conditions.
Second, EPIP's 7 - 29 address the actions to be taken for different specific emergencies such as personnel injury, fire, etc., and the rest of the procedures mentioned in the preceding paragraph.
The format for these procedures includes four sections: Documentation, Action Level References, Precautions, Procedures.
The EPAP's and EPIP's specify the individual or organizational element responsible for performing the tasks covered by the procedure.
The Emergency Action Levels (EAL's) and modified Protective Action Guides are specified in the associated EPIP's, and the appropriate emergency actions or protective actions to be taken are given in the EPIP's. The inadequacy of the Emergency Action levels given in the EPIP's for radiation levels was previously discussed in Section 4.2.1.2 of this report.
Not all EPIP's describe the prerequisites and conditions that must exist before specified actions are performed and the precautions and limitations that must be observed while performing emergency actions.
For example, EPIP-11, EMERGENCY RADIOLOGICAL SURVEYS, OFFSITE, does not discuss precautions in the use of the power generator and reading samples in high background, and EPIP-10, EMERGENCY RADIOLOGICAL SURVEYS, ONSITE, does not address conditions that might make buildings inaccessible.
The EPIP's do not always specify guidelines for each area in which personnel must exercise judgment in the implementation of specific actions.
For example, no guidelines are provided in the implementing procedure for wearing respirators, staying inside plumes for measurement purposes, moving to lower background for counting samples, and entering building during emergencies.
In general, EPIP's do not refer the user to other procedures already in existence which are required to complete the detailed emergency actions.
References are not always readily available to the user.
(See Section 7.2)
Based on the above findings, improvement in the following area is required to achieve an acceptable program.
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Include in the Emergency Plan Implementing Procedure appropriate judgment guidelines, precautions, limitations, and references to other procedures used in the completion of the emergency response tasks.
(219-82-01-53)
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5.2 Emergency, Alarm, and Abnormal Occurrence Procedures The licensee's Alarm and Emergency Operating Procedures were contained in the 500 Series Procedures.
These procedures were reviewed to determine if they provided a logical progression to appropriate Emergency Plan Implementing i
Procedures.
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The 500 Series Procedures appeared to provide the means for identifying the initial response to off-standard operating conditions.
Important to this was Procedure 501, Annunciators and Alarms, which identified the initial operator response to a control panel annunciator alarm.
Each control room annunciator appeared to be included in the procedure, along with a statement of alarm set point, possible initiating conditions, statement of automatic actions initiated by the alarm, and instructions for immediate operator response with reference to other specific 500 Series emergency operating procedures for follow up action.
Further review of numerous 500 Series Procedures indicated that references to Emergency Action Levels and references to the appropriate Emergency Plan Implementing Procedures had not been incorporated into the procedures.
Discussions with licensee control room and other operations personnel and emergency planning personnel confirmed this. While not all emergency operating procedures would necessarily result in Emergency Plan implementation, many would. Without references in the 500 Series Procedures to the Emergency Plan Implementing Procedures, heavy reliance is placed in the Group Shift Supervisor (GSS) to recognize the need to evaluate plant conditions with regard to the Emergency Action Levels included in EPIP-1, Classification of Emergency Conditions.
Such reliance places an unnecessary burden on the GSS.
Based on the above findings, improvement in the following area is required to achieve an acceptable program:
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Incorporate appropriate references to the Emergency Plan Implementing Procedures in your 500 Series Procedures.
(219-82-01-54)
5.3 Implementing Instruction Five EPIP's pertain to the detection and classification of the emergency conditions and appropriate action.
EPIP-1 provides overall instructions for the classification of emergency-conditions into the four emergency classes.
EPIP-2 provides instructions for an Unusual Event.
EPIP-3 provides instructions for an Alert.
EPIP-4 provides instructions for Site Emergency.
EPIP-5 provides instructions for General Emergency.
Each EPIP describes the specific EAL's and planned responses for its class of emergency.
Implementing instructions for the Emergency Director are contained in several EPIP's. The EPIP's contain the authority and responsibility of the Emergency Director; the EPIP's state which responsibilities cannot be delegated.
The EPIP's do not refer the user to normal operations procedures which must be
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used in'the performance of the emergency actions. Also, the normal operations
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procedures used in conjunction with the EPIP's do not address the limitations and restrictions on their use under emergency conditions.
It was noted that there was no EPIP covering the duties and responsibilities of the In plant Monitoring Team.
It was noted that some of the EAL's were not based on observable information that is readily available to the individuals responsible for emergency detection, classification, and assessment.
For example, the EAL for Radiological Effluent-Release Rate is " Tech Spec Limits Exceeded" and for natural phenomena is
" Earthquake -SSE Levels 0.22g".
It is of interest that the Emergency Plan in Table 4.1 called for the EPIP's to provide the stack gas monitor reading which represented the Technical Specification Limit, and the EPIP's didn't provide these readings.
Based on the above findings, improvement in the following area is required to achieve an acceptable program.
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Complete the revision and expansion of your Emergency Plan Implementing _
Procedures so that personnel are specifically directed in the completion of all required emergency response tasks.
(219-82-01-55)
s In addition to the above findings, the following matters should be considered for improvement:
Re-examine all EAL's to determine if the information is readily available-
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to control room personnel.
(219-82-01-56)
Address the limitations on the use of normal operating procedures under
-
emergency conditions in the normal operating procedures.
(219-82-01-57)
5.4 Implementing Procedures
,
.
5.4.1 Notifications
EPIP's 1 - 5, the Emergency Implementing Procedures which address the detection and classification of emergency conditions and the emergency actions, provide for the notification of local, State, and Federal offsite agencies of the
!
emergency situation. These EPIP's also provide for the activation and augmentation of the emergency response organizations.
The notifications to emergency _ response personnel are made primarily by the licensee's security organization. The security organization uses a pre programmed
" touch-a-matic" pager system to accomplish this task. Use of conventional phones and a phone list was an alternate method for notifying emergency response personnel.
Discussions with personnel and observation of a drill on January 6,1981 indicated that notifications were completed about-30 minutes after
.
declaration of an event.
With regard to the EPIP's providing for the proper notifications to be made at the various classes of emergency conditions, EPIP-2 provides for notifications at the Unusual Event class; EPIP-3 provides for notifications at the Alert
.
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4 class; EPIP-4 provides for notifications at the Site Emergency class; and EPIP-5 provides for notifications at the General Emergency class.
The notifications at the various emergency classes appear to be consistent with 10 CFR 50.72 and Appendix 1 of NUREG-0654. The EPIP's provide the formats of the notification messages to assure that the appropriate necessary information is provided.
The licensee's notification system includes a listing of all personnel assigned i
to the emergency organizations and their telephone numbers.
Dedicated automatic telephone ring instruments which directly conaect the licensee to USNRC, New Jersey State Police, New Jersey Bureau sf Radiation Protection, and the Ocean County Communications Center are used in the applicable
procedures. All include a verification / authorization call-back feature on automatic ring circuits.
Discussions with operations staff personnel disclosed that they felt that the notification procedures given in EPIP's 1 - 5 were difficult to implement because they were complicated and redundant. Also, lack of training in and familiarity with the EPIP's were given as reasons for operation staff personnel feeling uncomfortable concerning the EPIP's.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be considered for improvement:
-
Simplify and consolidate the notification requirements in EPIP's 1 - 5.
(219-82-01-58)
5.4.2.
Assessment Actions The auditors reviewed the licensee's procedures for assessing accident consequences, including the bases used for onsite and offsite protective actions.
EPIP-9, OFFSITE DOSE ASSESSMENT, has been established by the licensee to be used for dose projections based on measured effluent releases. This procedure was found to include six dose assessment methodologies: four for specific accidents analyzed in the FSAR, one for assessing allowable planned release rate, and one for generic release dose assessment methodology for use with any type of release (liquid or airborne). The four FSAR-based accidents provided for correction of the FSAR-derived offsite doses for actual meteorological condition at the time of release.
Licensee personnel indicated that these release scenarios had been included in the procedure for use in the event that such an accident actually occurred. The generic release scenario was intended to be used for virtually all unplanned releases.
The decision for which methodology to use would be made by the Emergency Director.
The methodologies given in EPIP-9 all appear to be based on whole body dose from a passing cloud. The procedure neither identified the critical age group (child - adult) nor described a methodology for calculating thyroid dose rate or time-integrated dose to the thyroid in addition to whole body dose. The procedure also did not include or reference EPA protective action guides.
!
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Emergency action levels (EAL's) for offsite dose assessments were not specifically included in EPIP-9; however, identification of the EPIP's in which the EAL's could be located were included in the reference section of the procedure.
The individuals or groups responsible for performing the offsite dose assessment during the course of an escalating emergency were not clearly stated in EPIP-9;
however, it was implied that the Emergency Director was responsible for performing the initial dose assessment.
Licensee personnel indicated that the on-duty shift RadCon technician would perform the initial assessments at the direction of the Emergency Director. Upon the activation of the TSC, the Radiological Assessment Coordinator would take over dose assessment coordination, including direction of the Offsite Monitoring teams. Ultimately, however, the dose assessment and direction of the Offsite Monitoring teams would be the respons-ibility of the Environmental Assessment Coordinator located at the Environmental Assessment Control Center in Building 12 of the Forked River site.
Discussions with licensee personnel indicated that persons responsible for making dose projections were capable of executing the procedure.
Some problems had been experienced in past drills with misinterpreting wind direction and consequently sending offsite survey teams in the wrong direction.
The procedure appeared to properly address plume direction.
It was noted, however, that at least one shift RadCon technician erroneously believed the wind direction meter indicated downwind direction.
The licensee had developed computerized dose assessment capability, using a mini-computer. This system had been implemented at the NEOF; however, the system has not been implemented at the TSC or the control room. The licensee indicated that they planned to implement the system in these locations.
The procedure for using the computer was not given in EPIP-9. Manual dose assessment capability, as well as computer capability, should be maintained and individuals trained in both computer and manual methods.
Based on the above findings, improvement in the following area is required to achieve an acceptable program.
-
Develop a method to determine offsite doses to the thyroid based on measured and projected radiciodine concentrations.
The method should document the assumptions used, incorporate appropriate EPA-520 or ICRP models, and be made consistent with the method used by the appropriate offsite agencies.
(219-82-01-59)
In addition to the above finding, the following matters should be considered for improvement.
-
Define the responsibility for dose assessment in the procedure.
(219-82-01-60)
Provide additional training in dose assessment.
(219-82-01-61)
-
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-
Implement computer analysis for dose assessment at the TSC and control room.
(219-82-01-62)
5.4.2.1 Offsite Radiological Surveys Provisions have been made to totally outfit only two offsite monitoring teams.
The licensee indicated that more teams could be formed and equipped using existing resources. Members of the teams are selected from non-bargaining unit personnel whose normal jobs do not require them to conduct surveys.
There is currently no adequate selection criteria or qualification requirements
.
defined for members of the team. Most team members interviewed during the walk-through cor,sidered their level of training to be inadequate to provide and maintain a reasonable level of proficiency in offsite monitoring.
(See Sections 3.1, 3.2, Training, and 7.2, Walk-Through, for further details.)
e EPIP-11 covers offsite monitoring.
This procedure does not contain all methods to be used to perform offsite dose measurements such as plume chasing, identifying the plume centerline, and determining if tha surveyor is in the plume.
It is not descriptive enough to direct personnel in the operation of the air sampler and supporting equipment and in the calculation of airborne concentrations of radioactive materials.
Further, it does not refer to other
!
procedures where the required information or directions may be found.
(See Section 5.3, Implementing Instructions.) The procedure also does not specify the use of dosimeters.
Pre-designated survey points have been identified on a map.
Provisions have been made for the recording of field data and the transmission of the data to dose assessment personnel via radio.
No central storage and processing point has been designated for the collection of all environmental samples.
Based on discussions with licensee personnel, inadequate radiation protection guidance has been provided to Offsite Monitoring team members.-
(See Section 7.2, Walk-Through.)
Based on the above findings, improvement in the following area is required to achieve an acceptable program:
-
Include all methods to be used in the performance of the offsite radiological surveys in Emergency Plan Implementing Procedures.
(219-82-01-63)
In addition to the above finding, the following matters should be considered for improvement:
Develop qualification requirements for Offsite Monitoring Team members.
-
(219-82-01-64)
-
Define a central collection and storage location for environmental samples.
(219-82-01-65)
'
-
-.
..
.
'
5.4.2.2 Onsite (Out-of-Plant) Radiological Surveys
,
Onsite monitoring teams have been identified on the September 19, 1981, emergency roster to provide onsite surveillance during an emergency. Members of the
-
team are selected from non-bargaining unit personnel whose jobs do not normally require them to conduct surveys. As was the case for Offsite Monitoring Team me,nbers, there is currently no selection criteria or qualification requirements defined for team members. Most team members interviewed during the walk-through considered their level of training to be inadeyaate to provide and maintain a reasonable leYel of proficiency in conducting onsite surveys.
(See Section 3.1, 3.2, Training, and 7.2, Walk-Through.)
The licensee indicated that_they are attempting to expand their Radiological Controls group and.have additional Radiological Control Technicians assigned to each shift. These technicians would perform the onsite monitoring activities.
This concept was illustrated in the licensee's January 11, 1982, emergency response roster, which stated that there would be a minimum of three bargaining unit / contractor Rad Con Techs on each shift available to serve as Radiological Control monitors. As stated in Section 3.1 of this report, the Rad Con Techs have not received sufficient specific emergency preparedness training.
EPIP-10 covers the operation of the Onsite Monitoring teams.
The procedure is not descriptive enough to direct personnel in the operation of the air samplers and supporting equipment and the calculation of airborne' concentrations of radioactive materials under emergency conditions.
Further, it-does_not' refer to other procedures where the required information or directions may be found.
(See Section 5.3, Implementing Instructions.) The procedure also does not specify the possible use of protective clothing, dosimeters, or respiratory protection.
(See Section 5.4.3.1, Radiation Protection During an Emergency.)
EPIP-10 assigns the responsibility for conducting onsite surveys to the Onsite Monitoring Team, and EPIP-9 states that an equipment operator will be' dispatched to perform perimeter surveys. There is no indication that " equipment operators" have been trained to conduct onsite surveys under emergency conditions.
Based on discussions with licensee personnel, insufficient radiation protective guidance has been provided to Onsite Monitoring Team members.
(See Section 7.2,' Walk-Through.)
No central storage and processing point has been designated for the collection of all onsite samples.
Based on the above findings, improvement in the following area is required to achieve an acceptable program:
Include all methods to be used in the performance of the onsite radiological
-
surveys in the Emergency Plan Implementing Procedure.
(219-82-01-66)
In addition to the above finding, the following matter should be considered for improvement:
.
,
, _.
_
.
.-
,
-
._ _
_
._
Develop qualification requirements for Onsite Monitoring Team members.
-
(219-82-01-67)
5.4.2.3 In-Plant Radiological Surveys The personnel identified to perform Onsite Radiological Surveys evidently also provide the in plant radiological surveys; however, this was not clearly stated in the Emergency Plan or Emergency Plan. Implementing Procedures. As
-
stated in the previous section, members of the team are selected from non--
bargaining unit personnel whose jobs do not normally require them to conduct surveys or provide radiological support to other emergency teams.
There are currently no adequate selection criteria or qualification requirements defined for team members.
Most team members interviewea during the walk-through considered their degree
'
of training, including respiratory protection, to be inadequate to provide and maintain a reasonable level of proficiency in conducting surveys in support of in plant emergency operations such as post-accident sampling and analysis, search and rescue, damage control and repair, and handling of contaminated injured personnel.
(See Sections 3.1, 3.2, Training, and 7.2, Walk-Through.)
The team members indicated that radiation technicians would support them during an emergency.
Radiation technicians have not been provided sufficient, specific emergency preparedness training. The Training Department plans to provide such training in the near future.
(See Section 3.1, 3.2, Training.)
There is no Emergency Plan Implementing Procedure which addresses the actions and responsibilities of the In-Plant Monitoring Team. The procedure could provide plant maps identifying potentially high. radiological hazard areas.
Based on the above findings, improvement in the following area is required to achieve an acceptable program:
-
Include the procedures to be followed for in plant radiological control under emergency situations in the Emergency Plan Implementing Procedures.
(219-82-01-68)
In addition to the above finding, the following matters should be considered for improvement:
-
Define the emergency organization responsible for providing in plant radiological control, including in plant radiological surveys, during emergencies.
(219-82-01-69)
-
Develop qualification requirements for In-Plant Monitoring Team members.
These requirements should include respiratory protection training and a respirator fit test.
(219-82-01-70)
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5.4.2.4 Primary Coolant Sampling
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As was stated in Section 4.1.1.5, the auditors reviewed the 11ce9see's
'
Implementation of NUREG-0578 and NUREG-0737 to assess the licensee's abilitym.
"
i to collect and analyze high activity reactor coolant samples under post-accideat
-
conditions. The auditors inspected the sampling location and, equipment and the sampling procedures, and the auditors discussed these itims.with meabers 5 i of the licensee's staff.
k The procedure for the post-accident sampling of the primary reactor coolant
-
was found to be Procedure 803.49, Post-Accident Sampling of Primary Coolant,
]
Revision 1.
The sampling procedure appeared to be essentially the same as for normal coolant sampling with some added provisions for radiation protection,
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notably the use of remote handling tools for valve operation and sample handling /..
-
'
and the use of a shielded cask for sample transport.
The review of this
.
procedure revealed the following inconsistencies and. inadequacies:
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Health Physics Dek etment designated to determineLreactor building l'
-
accessibility, and there is no department with that title.
.-
Referencemadetoanon-existentprocedure, Procedure 804._38,hst-Accfd$nt
-
Sampling.
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Sample bottles, including size of bottles, not listed in equipment I st.d f
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Size of sample not prescribed.
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Sample labeling instructions not given.
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Range of personnel dosimeters to be used not designated.
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Responsibility for predetermining path of travel to sample locition not
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designated.
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s Radiation dosage allowed or radiation limits not designated.
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-
Precaution alerting personnel to retreat to lower exposure area's whaneier
'
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-
.
,
possible not given.
As was discussed in Section 4.1.1.5 of this report, the sampling system does
[
not contain the coolant during sampling, and there is no ventilation syst+m to s
contain the gases released from the coolant during the sampling of the coolant.
x The procedure calls for a 15-minute flush of the sample lines at a 100 - 500-milliliter per minute flow rate. This could result in substantial quarRit'ies of fission product gases being released to the reactor building during the
',
flushing and sampling process and the subsequent exposure _of~ sampling and -
other personnel. Personnel could not sample reactor coolant with-10 curie per gram activity using the present equipment and procedures without exceeding
'
personnel radiation exposure limits. The licensee had not evaluated and determined the radioactivity levels of the reactor coolant which could be sampled by personnel without having their radiation exposure exceed whole body
or extremity exposure limits. Also, the licensee had not determined the point in the procedure where the sampling effort could be safely terminated because
of radiation considerations.
A further potential problem was noted with this procedure. The sample valve
- <
has normally been left in the open position with approximately 500 ml/ min flow
s inte the 7 ample sins drain maintained per vendor recommendations.
Isolation
of the sample line is a possible occurrence during an emergency reactor shutdown.
ThJ procedure refers to another plant procedure which might be required and
-
.
-' war:1d override the isolation signal.
If the isolation signal was overridden
!
and; sainple flow to the open sink drain was restored, unintended releases to
-the ieactor building could result, prior to overriding the isolation signal, s
'
it might be desireable that sample sink flow be manually valved off.
It was found that technical personnel were generally not aware of the procedure for post-accident sampling of reactor coolant and were not trained in the procedure.
The need to define and predetermine conditions under which reactor building accessioility for interim coolant sampling can be reasonably expected or precluded was addressed in Section 4.1.1.5 of this report. Also, the need to determine reactor coolant radioactivity levels which can be sampled using interim facilities without exceeding appropriate NRC exposure criteria or EPA protective action guides was addressed in Section 4.1.1.5 of this report.
The need to train personnel in post-accident sampling procedures was addressed in Section 3.1 of this report.
' Based on the above findings, improvements in the following area is required to
.
cachieve an acceptable program.
'
Revise your procedures for performing post-accident reactor coolant
-
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.; g sampling using interim-type equipment.
This revision should include, but not be limited to, consideration of the following: personnel radiation g
-
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expoture limits, dosimeters to be used by personnel, radiation level of
'
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coolant that may be sampled, points where sampling should be terminated due to radiation levels, determination of path of travel to and from s
sample location, sample size, and sample labeling.
(219-82-01-71)
~
5.4;2.5 Primary Coolant Sample Analysis The auditor reviewed the licensee's procedures for post-accident primary coolant sample analysis and discussed the procedures with Chemistry Department personnel to eva'Jate compliance with Section 2.1.8.a of NUREG-0578 and Section II.B.3 of NUREG-0737. These sections specify that the licensee shall be capable of analyzing coolant samples with two hours of collection for boron and radionuclides (e.g., noble gases, radiciodines, cesiums, nonvolatiles) and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for chloride.
No procedures other than routine, normal activity level procedures have been developed for post-accident coolant sample analysis.
Radiation protection provisions included in normal activity analytical procedures did not appear to
_
_
i
adequately address high activity samples consistent with the NUREG-0737 Section II.B.3 criteria of 10 curies / gram.
Licensee personnel were found to have had no special training in the handling or analysis of such high activity samples.
Based on the above appraisal, improvements in the following areas are required to achieve an acceptable program:
Develop procedures to address the analysis of high activity coolant
-
samples ccnsistent with criteria detailed in Section II.B.3 of NUREG-0737.
Such procedures should include specific radiation protecton provisions to assure personnel whole body and extremity limits are not exceeded, should
provide for use of adequate shielding from elevated post-accident background direct radiation exposure rates, and should identify proper disposition of samples following analysis.
(219-82-01-72)
'
5.4.2.6 Containment Air Sampling
l l
The auditors reviewed the licensee's plant procedure for post-accident containment I
air sampling and discussed the procedures with licensee personnel to evaluate conformance with NUREG-0578 and NUREG 0737.
l The procedure for the post-accident sampling of containment air was Procedure l
803.50, post-Accident Sampling of Drywell Atmosphere, Revision 1.
The review I
of the procedure revealed the following inconsistencies and inadequacies:
Health Physics Supervisor designated to authorize post-accident sampling,
-
and there is no individual with this title.
Reference made to a nonexistent procedure, Procedure 804.38, Post-Accident
-
Sampling.
-
Proper techniques for taking samples of highly radioactive gases not identified and described.
Responsibility for the planning associated with procedure performance not
-
specified.
Sketch of the sampling location and sampling equipment arrangement not
-
given.
Techniques for using remote handling equipment and shielded sample containers
-
not described.
-'
Dilution of initial sample not called for if initial sample had radiation levels greater than 50 mR/hr.
(Procedure appeared to call for collecting a smaller sample.)
Collection of particulates and radiciodines using a filter and silver
-
zeolite cartridge, respectively, not called for.
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l Chemistry Department personnel (technicians and professional) were found to lack training in this procedure.
This lack of training was indicated by a i
lack of knowledge of the procedure's existence, lack of knowledge of the
'
sampling point location, and general lack of knowledge in how to handle very high activity samples.
l Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
i
Develop a procedure for performing post-accident containment air sampling
-
i consistent with NUREG-0737 Section II.B.3 criteria. The procedure should include specific provisions for collecting particulate, iodine and gas
,
.
i samples, specific instructions for the safe handling of highly radioactive samples, a sketch of the sampling location and equipment, and assignment of responsibility for performance of planning activities consistent with
positions defined in the Emergency Plan organization.
(219-82-01-73)
5.4.2.7 Containment Air Sample Analysis The auditor reviewed the licensee's procedures for analyzing post-accident containment air samples and discussed the procedures with Chemistry Department personnel to evaluate compliance with NUREG-0737.
As was the case with post-accident coolant samples, no procedures other than routine procedures have been developed for analyzing containment air samples containing high radiation level air. The procedures for analyzing routine radiation level samples did not address the special dilution, fractionation,
j counting, or other analytical techniques which could easily be required for containment air samples in the event of fuel failure accidents. Also, the
'
procedures did not include specific personnel radiation protection precautions appropriate for handling high activity samples.
Data sheets were not included or referred to in the procedures. Analytical equipment had not been calibrated
!
for high activity samples.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
-
Develnn procedures for analyzing containment air samples under the post-acci;ent conditions specified by NUREG-0737 Section II.B.3. and Table II.F.1-1.
Such procedures should incorporate specific personnel radiation protection requirements.
(219-82-01-74)
I 5.4.2.8 Stack Effluent Sampling The auditor reviewed the licensee's procedures 'ar sampling stack and airborne effluents to evaluate compliance under the post-cident conditions defined in NUREG-0737, Table II.F.1-2.
These procedures included the following:
'
803.46 Collection of Stack Gas Sample for Analysis of Noble Gases.
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i 1207.11 Post-Accident Stack Effluent Monitor Filter Replacement.
1213.6 Post-Accident New Radwaste Vent Duct Monitor Filter Change.
1213.7 Post-Accident Augmented Offgas Vent Duct Monitor Filter Change.
1213.10 Post-Accident Procurement of New Radwaste/ Augmented Offgas Vent Duct Gas Sample for Analysis of Noble Gas and Estimation of Releases.
1213.14 Post-Accident Pro:urement of a Gas Sample from the Turbine
'
Building Vents for Estimation of Noble Gas Releases.
1213.15 Post-Accident Procurement of Particulate and Charcoal Filter Samples from the Turbine Building Vents for Estimation of Releases.
,
These procedures included only minimal personnel radiation protection guidance, and they did not address the possibility that very high activity levels (nominally
>
'
180 curies) might be associated with the sampling under the NUREG-0737, Table
,
II.F.1-2 conditions. Procedures did not include data' sheets, and in some i
cases '(e.g., Procedures 1207.11, and 803.46), did not include either data sheets or specific identification of data to be recorded with sample collection.
Sketches of equipment location and setup were not included in the procedures,
"
and all procedures referenced a nonexistent procedure, 804.38 Post-Accident Sampling.
,
Based on the above findings, improvement in the following area is required to t
achieve an acceptable program:
Review and upgrade airborne effluent sampling procedures incorporating
-
specific radiation protection provisions appropriate for sampling effluent i
streams using the design basis criteria of NUREG-0737, Table II.F.1-2.
(219-82-01-75)
In addition to the above findings, the following matters should be considered for improvement:
Incorporate sketches of sampling facility location and equipment set up
-
in the sampling procedures.
(219-82-01-76)
-
Delete the references to the nonexistent procedure 804.38, Post-Accident Sampling, or develop such a procedure.
(219-82-01-77)
.5.4.2.9 Stack Effluent Sample Analysis
The auditor reviewed the licensee's procedures for analyzing post-accident stack and airborne effluent samples to evaluate compliance with the criteria i
of NUREG-0737.
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The licensee's procedures for routine, normal samples were the only procedures available for performing analyses, even post-accident sample analyses.
These procedures did not incorporate provisions for personnel radiation protection (shielding, dosimetry, etc.), which might not be a serious concern under normal conditions, but could be extremely important for handling high activity
,
post-accidenc samples.
The impact of elevated post-accident background at the counting lab had neither been factored into the procedures nor considered in determining analysis capability. Such an elevated background could result from fuel failure accidents with major releases to the drywell and reactor building.
The stack could also be a significant source of direct radiation.
Methods for reducing the activity level of samples by means of dilution or reduction of sample size were not addressed in the procedure.
The charcoal cartridge (iodine) analysis procedure called for opening the counting shield halfway through the count and inverting the cartridge. Under accident conditions, opening this shield could expose the detector to a significantly higher background, causing erroneous analysis results.
Based on the above findings, improvement in the following area is required to achieve an acceptable program:
Develop procedures for the analysis of high activity airborne stack
-
effluent samples under post-accident conditions. Procedures must address
,
analysis of radiolodines and particulates as a minimum and meet the criteria of NUREG-0737, Table II.F.1-2.
Specific radiation protection concerns applicable to high activity sample analysis shall be incorporated into the procedures.
(219-82-01-78)
5.4.2.10 Liquid Effluent Sampling The licensee indicated that under post-accident conditions they would continue to abide by their technical specifications limits and NRC regulations pertaining to the storage of radioactive liquids and the discharge of liquid effluents to the environment. The auditor reviewed the handling, storage, and sampling of
,
radioactive liquid considering the licensee's position.
Since the licensee does not intend to discharge liquid effluents with high levels of radioactivity, the licensee's normal liquid effluent sampling procedures are adequate, even under post-accident conditions.
The licensee indicated that the amount of radioactive material stored in outside tankage would be limited to their technical specification limit of 10 curies. Highly contaminated water, which could not be stored in outside tankage, would be dumped into the torus.
Should the capacity of the torus be exceeded, the torus room inside the reactor building would be flooded. No procedure or plan documented the method for handling and storing large volumes of contaminated water.
I
As long as the licensee abides by the 10 curie radioactive material limit in the large outside storage tank, the concentration of the radioactivity in the water would pose no problem to sampling personnel.
Therefore, any radiological hazard to sampling personnel would be related to the radiation fields at the sampling location, and appropriate personnel protection precautions would be required.
Sampling of the water in the torus under post-accident conditions might be necessary or desirable. Since this war.er might be highly contaminated, special provisions would probably be required, especially since personnel entry into the reactor building basement would be required.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be considered for improvement:
-
Develop a procedure or plan documenting methods and a philosophy for the storage and handling of large volumes of contaminated water.
(219-82-01-79)
-
Determine the need and, if required, develop a procedure for post-accident sampling of torus water, incorporating specific radiation protection criteria.
(219-82-01-80)
5.4.2.11 Liquid Effluent Sample Analysis As indicated in the foregoing section, the post-accident liquid effluent samples should not have high concentrations of radioactivity.
Therefore, post-accident samples of liquids intended for discharge should not require any special procedures due to high concentration of radioactivity.
The normal procedures might not be adequate for the analysis of torus water under post-accident conditions.
The procedures to be developed for analysis of reactor coolant water under post-accident conditions, as discussed in section 5.4.2.5 of this report, might be used for analysis of this torus water.
There has been no evaluation of the possible impact of post-accident elevated radiation background on existing analytical laboratory procedures.
The elevated background in the laboratory could result from the radiation from the stack or reactor building.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
-
Assess the impact of elevated background radiation levels which could result from direct radiation from the reactor building or stack under major release conditions on the normal analytical laboratory procedures.
Based on the assessment results, either revise the normal rocedures or develop new procedures.
(219-82-01-81)
-
-
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-
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i
55 5.4.2.12 Radiological and Environmental Monitoring Program i
The auditors reviewed the Emergency Plan and Emergency Plan Implementing
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Procedures and interviewed licensee personnel concerning the licensee's Radio-logical Environmental Monitoring Program (REMP) procedures.
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The licensee has established a REMP and has it in operation. The procedures
for the collection and analysis of environmental samples, i.e., vegetation, l
soil, fish, clams, etc., and the use of TLD's and film badges are provided in the Oyster Creek Generating Station 1200 series Procedures.
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During an emergency, the REMP is the responsibility of the Environmental Assessment Coordinator and his staff located at the Environmental Assessment Command Center (EACC) in Building 12 on the Forked River site.
EPIP-11, Emergency Radiological Surveys Offsite, provides the procedures for the Offsite Monitoring Teams in obtaining samples of the environment.
The REMP samples are sent to Radiation Management Corporation Laboratories located in Philadelphia, Pennsylvania, for analysis.
The Rad Con Laboratory is also available for performing analysis.
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Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.4.3 Protective Action
The auditors reviewed the Emergency Plan and Emergency Plan Implementing Procedures, and the auditors interviewed appropriate licensee personnel during the appraisal of the licensee's proce.dures for protective actions for personnel during emergencies.
5.4.3.1 Radiation Protection During Emergencies The subject of " Radiation Protection" has been a consideration in nearly all of the preceding sections of this report. As pointed out in these previous sections, the licensee must consider " radiation protection" of the licensee employees and/or the rest of the public in the Emergency Plan.and in the Emergency Plan Implementing Procedures.
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The review of the documents disclosed that their emergency exposure criteria for emergency workers given in Table 6.2 of their Emergency Plan were based on recommendations of the National Council on Radiation Protection, rather than i
being based on the EPA Emergency Worker and Lifesaving Activity Protective Action Guides, as stated in 10 CFR 50.47(b)(11).
The only point of inconsistency was the criteria for whole body exposure for lifesaving actions. Their criteria was 100 Rem, and the EPA criteria given in EPA-520/1-75-001 is 75 Rem projected whole body gamma dose.
EPIP's include the statement that the Emergency Director may not delegate the responsibility for the authorization for emergency workers to exceed 10 CFR 20 i
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radiation exposure limits. The EPIP's also state that the radiation exposure to individuals exceeding 10 CFR 20 limits is restricted to limits which are presented in tabular form. These limits are those given in Table 6.2 of the Emergency Plan, which were discussed above.
EPIP-19, Emergency Dosimetry, describes the method used to issue personnel dosimeters during emergencies when the primary dosimetry issue facility (North Gate) is not available for use.
The dosimeters are located at the Nearsite Emergency Operations Facility on the Forked River site.
EPIP-23, Thyroid Blocking, describes the licensee's procedure for the issuance and use of potassium iodide thyroid blocking tablets. The tablets are administered to specific individuals only upon direction of the Emergency Director after evaluation of the exposure of the individual to radioactive iodine.
The Health Services Department ensures that medical surveillance is performed on peronnel who have taken the potassium iodide tablets.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
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Make the emergency exposure criteria for emergency workers consistent with the EPA Emergency Worker and Lifesaving Activity Protective Action Guides given in EPA-520/1-75-001.
(219-82-01-82)
5.4.3.2 Evacuation of Owner Controlled Areas Action levels that require evacuation of specified areas, buildings, and the site complex are given in Emergency Plan Implementing Procedures EPIP-2, Unusual Event; EPIP-3, Alert; EPIP-4, Site Emergency; and EPIP-5, General-Emergency, which were all issued and dated 2/23/81. The procedures for Alert, Site Emergency, and General Emergency all call for the implementation of EPIP-12, Personnel Accountability.
EPIP-12 calls for nonessential personnel to report to the appropriate onsite emergency assembly areas. According to the procedures, the Emergency Director determines the necessity for onsite evacuation of nonessential personnel based on the potential of radiological exposure.
If evacuation is ordered, the procedures for Alert, Site Emergency, and General Emergency call for the implementation of EPIP-18, Activation of Remote Assembly Area, and implementation of EPIP-13, Site Evacuation and Personnel Accounting After Site Evacuation.
Evacuation routes within the plant buildings are marked with arrows to aid personnel during evacuation.
The assembly area for personnel in the protected area of the Oyster Creek Nuclear Generating Station site are the Materials Management Warehouse for personnel outside Radiation Work Permit Areas and the Monitor and Control Area for personnel inside Radiation Work Permit Areas.
Personnel en the Oyster Creek Nuclear Generating Station site outside the protected area, personnel on the Forked River site, and personnel in the Energy Spectrum (visitor's center)
must be accounted for according to EPIP-12.
The exact assembly points for these various areas and buildings have not been defined in the EPI.
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The Remote Assembly Area is the Berkeley Operating Headquarters, which is approximately eight miles northwest of the site. The licensee has a sufficient supply of maps to be issued to efacuees by the security organization as they depart from the site.
The EPIP's provide concise, oral announcements to be made over the plant's public address system concerning the evacuation of nonessential personnel.
The EPIP's provide for the accounting for personnel, including search and rescue if needed; the verification that personnel have evacuated upon the order to evacuate; the survey of personnel and vehicles for radioactive con-tamination; and the decontamination of personnel and vehicles as required.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.4.3.3 Personnel Accountability EPIP-12, Personnel Accountability, provides for the accounting of personnel when no site evacuation has been ordered.
EPIP-13, Site Evacuation and Personnel Accountability After Site Evacuation, provides for the accounting of personnel
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under the various circumstances which could arise when the site evacuation is ordered before the onsite accounting for personnel has been completed.
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personnel have demonstrated that they can account for personnel within 30 minutes of the order to implement the accounting procedures by the performance of drills. The auditor observed the accounting for personnel on January 7, 1982, and the licensee demonstrated the capability to account for all personnel within 30 minutes.
Results of the personnel accounting effort are reported to the Emergency Director.
If all personnel are not accounted for, the Emergency Director will use EPIP-22, Search and Rescue, to locate the unaccounted-for person and take appropriate rescue action, if needed.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.4.3.4 Personnel Monitoring and Decontamination The auditors reviewed Section 6.6.2 of the Emergency Plan, First Aid and Decontamination, and EPIP-12, Personnel Accountability, EPIP-13, Site Evacuation and Personnel Accountability After Site Evacuation, and EPIP-21, Personnel Decontamination, during this portion of the appraisal.
The Manager of Rad Con-Field Operations was also interviewed.
EPIP-12 does not specifically call for potentially-contaminated personnel who had been working inside Radiation Work Permit Areas of the facility to be monitored and decontaminated as necessary upon assembling at the Monitor and Control Area.
EPIP-13 does not call for these same potentially-contaminated personnel to be monitored and decontaminated as necessary prior to leaving the Radiation Work Permit Areas, evacuating the site, and reporting to the Remote
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Assembly Area.
EPIP-13 and EPIP-21 call for the monitoring to be performed at the Remote Assembly Area at the Berkeley Operating Headquarters. As was pointed out in Section 4.1.2.3 of this report, the licensee does not have a decontamination facility at the Remote Assembly Area.
EPIP-21 provided a means for recording the names of individuals to be decon-taminated, the levels of contamination, the survey instrument used, and the agents and methods used for decontamination.
The procedure did not call for the listing of all personnel surveyed for radioactive contamination and found to be free of contamination.
EPIP-21 required that personnel skin decontamiration be performed when personnel were found to have skin contamination above 100 counts per minute (cpm).
This procedure provides a method for the decontamination of the skin using soap and wate.
If the use of soap and water is not successful in reducing the skin
contamination level below 100 cpm, the Radiation Protection Coordinator must evaluate the need for further decontamination efforts and specify further actions, as necessary.
EPIP-21 does not specify any monitoring techniques, such as nasal smears, to detect possible inhalation of particulate radioactivity. Also, the procedure does not specify any contamination levels at which whole body counting or bioassay techniques might be appropriate to assess internal radiological exposure deposition. As stated previously, the procedure does place the i
responsibility for the performance of further and followup assessment of the extent of contamination and the performance of appropriate decontamination on the Radiation Protection Coordinator.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be considered for improvement.
Require the monitoring and decontamination of personnel assembled at the
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Monitor and Control Area prior to evacuation, if possible.
(219-82-01-83)
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Specify action levels which require further assessment of personnel radiation exposure and/or contamination and define the assessment techniques to be used.
(219-82-01-84)
5.4.3.5 Onsite First-Aid / Rescue
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EPIP-7, Personnel Injury, provides for the prompt medical care of injured persons with contaminated minor injuries.
EPIP-22, Search and Rescue, provides for the rescue of personnel. This procedure calls for use of EPIP-7 in conjunction with EPIP-22, if the person being rescued is injured.
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EPIP-7 addresses the methods for handling and treating contaminated injured persons, considering both medical treatment and contamination control. The well-being of the injured person is given primary consideration, and medical attention always takes precedence over decontamination efforts. Methods for maintaining contamination control are addressed in the procedure.
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EPIP-7 addresses the transport of contaminated, injured personnel to the offsite medical facilities. Qualified Radiological Controls Technicians accompany the transported injured persons.
EPIP-7 addresses the personnel
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radiation protection and contamination control measures to be taken in the ambulance and in the hospital.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.4.4 Security During Emergencies The auditor reviewed the licensee's Emergency Plan, Modified Amended Security Plan, Safeguards Contingency Plan, and Emergency Plan Implementing Procedures j
and interviewed members of the Security organization.
The auditor noted that the Security organization is responsible for performing portions of many Emergency Plan Implementing Procedures (EPIP's).
Better assurance that the Security organization performs its duties during emergencies might be obtained.by developing specific procedures or checklists which cor.solidate the Security organization duties.
The auditor noted that there was no EPIP for Security to follow should they be ordered to evacuate from the site.
This procedure should address such things as the securing of the access control system, the positioning of barriers or gates, and the relocation of emergency personnel access control.
Based on the above findings, this portion of the licensee's. program appears to be acceptable, but the following matters should be considered for improvement:
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Develop specific security procedures and/or checklists which consolidate the Security organization emergency duties.
(219-82-01-85)
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Develop a procedure for the Security organization which addresses the manner in which the security system should be left should the security force be ordered to evacuate.
(219-82-01-86)
5.4.5 Repair / Corrective Actions l
The auditor reviewed Section 6.4 of the Emergency Plan, Corrective Actions,
and EPIP's 2 - 5, Unusual Event, Alert, Site Emergency, and General Emergency, respectively, and held discussions with licensee personnel.
J The auditer determined that the Emergency Plan and the EPIP's generally addressed the concept of repair and corrective actions. However, they did not specifically address the criteria used to select repair and corrective action personnel; the types of skills and training required of the selected personnel; the location and contents of specific instruments and other equipment to be used; communications means; and radiological and other safety precautions to be employed.
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Address emergency repair / corrective actions in the Emergency Plan and the
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Develop appropriate EPIP's which address repair and corrective actions under emergency conditions.
These EPIP's.should specify the location of tools, radiation detection instruments, and communications equipment, and should address personnel radiological protection.
(219-82-01-88)
5.4.6 Recovery
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The auditor reviewed Section 9.0 of the Emergency Plan, Recovery, and EPIP-29, Recovery Operations.
The Emergency Plan and the EPIP states that the Emergency Director and Emergency Support Director have the joint responsibility for determining and declaring when an emergency situation is stable and the recovery phase has been initiated.
The guidelines which must be met to enter the recovery phase are given in the
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j Emergency Plan and the EPIP. These guidelines include provisions for r.onsideration-of the control over plant operating conditions, radiation levels, and control
of radiation being released to the environment.
The Emergency Director is required to provide notification to all applicable individuals and agencies that the plant is in a recovery phase.
The licensee has defined key positions of the recovery organization in Section 5.7 of the Emergency Plan, which is entitled, Long Term Recovery Organization, and in Section 4.5 of the EPIP, which is entitled, Recovery Organization.
This organization includes the President of GPU Nuclear Corporation and his entire vice presidential staff.
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Based on the above findings, this portion of the licensee's program appears to
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be acceptable.
5.4.7 Public Information i
The auditor reviewed Appendix I of the Emergency Plan, Emergency Public Information Plan, other pertinent sections and tables of the Emergency Plan, and the Emergency Plan Implementing Procedures.
The auditors also interviewed licensee personnel.
The review disclosed that the Emergency Public Information Plan is a separate entity which is not well integrated with the Emergency Plan and the Emergency Plan Implementing Procedures. The area of organizational positions and authorities discussed below demonstrates this lack of integration.
l According to the Emergency Plan, there is a " Media Affairs Representative" position on the Initial Response (onsite) Emergency Organization, and the Emergency Public Information Plan does not mention such a position or give the
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duties of such a position. Conversely, the Emergency Public Information Plan i
indicates that the Manager, Communications Services, is the primary person in the conduct of the Emergency Public Information Plan activities, and the Emergency Plan does not mention this position or give the duties of this
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position. The licensee should integrate the Emergency Public Information Plan into the Emergency Plan and make the public information operation a part of the overall emergency operation.
The Emergency Plan Implementing Procedures (EPIP's) do not include any procedures relating to public information.
For instance, the activation and operation of the Media Center is not included in the EPIP's. After the licensee has integrated the Emergency Public Information Plan into the Emergency Plan, the licensee should prepare appropriate EPIP's to accomplish the proper implementation of j,
the Emergency Plan.
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GPU Nuclear has a Vice President of Communications who reports to the Office of the President and a Manager of Public Information who reports to this Vice President.
In addition, the licensee has a Manager of Communications Services and a Senior Public Affairs Representative at the Oyster Creek site. The licensee also has Communications personnel at their Three Mile Island site.
The licensee needs to define how these personnel will be organized, where they will be located, and how they will function during an emergency at the Oyster Creek Nuclear Generating Station. Training of personnel in the public information operations during an emergency should also be performed.
i Based on the above findings, this portion of the licensee's program appears to l
be acceptable, but the following matters should be considered for improvement:
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Integrate the Emergency Public Information Plan into the Emergency Plan
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and prepare and include appropriate public information procedures in the Emergency Plan Implementing Procedures.
Include the Communications personnel in the appropriate Emergency Response organizations and train the personnel in their emergency response functions.
(219-82-01-89)
5.5 Supplementary Procedures
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5.5.1 Inventory, Operational Check and Calibration of Emergency Equipment, Facilities and Supplies i
The auditors reviewed Section 6.5.3, Emergency Equipment Readiness, and Section 8.3, Maintenance and Inventory of Emergency Equipment and Supplies, of the Emergency Plan and EPAP-5, Emergency Equipment Inventory.
Procedure EPAP-5 provided a specific inventory listing of all equipment reserved for use during emergencies and specified the location of the equipment.
Section 8.3 of the Emergency Plan and Section 3.1 of the procedure specified that this equipment was to be inventoried, operationally checked and/ or calibrated quarterly. The designated inventory of properly operational equipment was required to be maintained.
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1 The procedure designated the Manager of Radiological Controls as responsible for the performance of emergency equipment readiness checks, for the taking of inventories, and for correcting any noted deficiencies.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.5.2 Drills and Exercises l
The auditor reviewed Section 8.1.2, Drills and Exercises, of the Emergency Plan and Emergency Plan Administrative Procedure No. 16 (EPAP-16), Maintaining
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Emergency Preparedness, and held discussions with licensee personnel.
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According to the aforementioned documents, the Supervisor, Emergency Preparedness is responsible for the planning, scheduling, and coordinating of all drills and exercises related to the emergency plan.
Each drill or exercise is to be conducted in accord with a scenario developed in advance, and the Emergency Preparedness organization is responsible for the preparation of these scenarios.
Evaluations and critiques of each drill or exercise are performed by the observers and participants.
The Supervisor of Emergency Preparedness is responsible for coordinating the achievement of appropriate corrective actions for problems disclosed by the drill or exercise. When necessary, the Plant Operating Review Committee assigns the corrective action to departments or individuals for completion and determines a schedule for the actions to be completed. A file is maintained which identifies each corrective action and the individual or department responsible for completion of the corrective action.
The licensee does not consider responses to an actual event as a substitute for the drills and exercises required in the procedure.
Section 8.1.2 of the Emergency Plan calls for all major elements of the plan and response organization to be exercised within'a five year period.
It also
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calls for an exercise to be started between 6 P.M. and midnight and another to be started between midnight and 6 A.M.
However, at the time of the appraisal, no provisions had been made for conducting drills and exercises on the backshift, nor had a mechanism been developed for ensuring that all personnel participate in drills or exercises, i
According to the licensee, EPAP-16 is currently being revised, and provisions for routinely inviting offsite agency participation in and news media coverage of exercises and drills are being included in the revised procedure.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for treatment:
Develop a mechanism to assure that all emergency response personnel
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(219-82-01-90)
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5.5.3 Review, Revision, and Distribution The auditors reviewed Section 8.2, Review and Update Emergency Plan and Implementing Procedures, of the Emergency Plan and EPAP-13, Emergency Plan, Gergency Plan Implementing Procedure / Administrative Procedure Comment,
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Feedback and Evaluation Procedure; EPAP-14, Emergency Plan Implementing Procedure / Administrative Procedure Review / Revision Procedure; and EPAP-15, Emergency Response Mobilization.
The auditors also interviewed licensee personnel.
Procedure EPAP-15 assigns the responsibility of administering the emergency duty roster and the telephone number listing to the Director, Oyster Creek Operations.
However, none of the aforementioned documents requires a quarterly review and updating of the telephone numbers of personnel on the emergency
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organization. Also, none of the documents require a quarterly review and updating of the telephone numbers of the other parties that must be contacted during an emergency.
The Emergency Plan states that an annual review and update of the plan and the EPIP's are the responsibility of the Supervisor, Emergency Preparedness.
EPAP-13 states that an independent review of the Emergency Preparedness Program will be conducted annually.
The review includes the Emergency Plan and the Emergency Plan Implementing / Administrative Procedures. The changes resulting from exercises or drills are included in the review and update process.
The licensee indicated to the auditors that their review of the Emergency Plan Implementing / Administrative Procedures had disclosed the need for major revisions to these procedures, and they were in the process of revising the procedures.
The responsibility for the distribution of the documents is assigned to the Document Control Center (DCC) in the Emergency Plan.
The DCC.also manages the system that verifies changes have been made in official copies of the documents.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
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Establish the quarterly review and updating of telephone numbers used in the Emergency Plan Implementing Procedures.
(219-82-01-91)
5.5.4 Audit The auditor reviewed Section 8.2, Review and Update Emergency Plan and Implementing Procedures, of the Emergency Plan; EPAP-13, Emergency Plan, Emergency Plan Implementing Procedure / Administrative Procedure Comment, Feedback, and Evaluation Procedure; and Technical Specification 6.5.3.5, Audits.
The auditor also interviewed licensee personnel.
The Emergency Plan did not address the subject of audits of the Emergency Plan and Emergency Plan Implementing Procedures.
EPAP-13 requires in Section 3.3.2 that an independent review (audit) of the Emergency Preparedness Program will be conducted annually.
The independent review is to be conducted by any
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competent organization, either internal or external to the GPU Nuclear Corporation, not immediately responsible for the Emergency Program. The review shall include the Emergency Plan and Emergency Plan Implementing / Administrative Procedures, practices, training, readiness testing, equipment, and interface with state and local governmental agencies.
Technical Specification 6.5.3.50.
requires an audit of the Emergency Plan and Emergency Plan Implementing Procedures performed under the cognizance of the Vice President, Nuclear Assurance, be accomplished at least once per two years.
The Site Audit Management conducted an audit of the Emergency Preparedness Programs in late 1981. Tha audit included the observation of a drill and associated activities on November 19, 1981.
The audit involved discussions with per sonnel and inspection of equipment, as well as a review of documents.
Based cn the above findings, this portion of the licensee's program appears to be acc3ptable.
6.0 COORDINATION WITH OFFSITE GROUPS 6.1 Offsite Agencies The auditors reviewed Section 5.10, Local Services Support; Section 5.11, Coordination With Governmental Agencies; and Appendix G, Letters of Agreement, of the Emergency Plan. Also, an auditor visited three offsite agencies providing emergency support to the licensee and interviewed offsite agency personnel.
A review of the aforementioned sections of the Emergency Plan disclosed that the licensee has not addressed emergency actions to be taken concerning that portion of the 10 mile radius area surrounding the Oyster Creek Nuclear Generating Station that is comprised by the Atlantic Ocean.
In this regard, the licensee should address these emergency actions in their Emergency Plan and Emergency Plan Implementing Procedures.
In particular, the licensee should consider the U. S. Coast Guard as a potential supplier of emergency support, and the licensee should reach an agreement with the Coast Guard for their support during an emergency.
The offsite agencies visited by the auditor were: Lacey Township First Aid Squad, Inc., Forked River, New Jersey; Forked River Volunteer Fire Company of Lacey Township, Forked River, New Jersey; and Community Memorial Hospital, Toms River, New Jersey. Adequate equipment and capability was readily noted during the visits.
The hospital staff was well trained in the preparation of the facility to accept and treat contaminated injured persons. As to the Fire Department and the First Aid Squad, each had enough vehicles, including four-wheel drive vehicles, to accomplish their tasks.
Each of the agencies visited had a Letter of Agreement with the licensee which described the support the agency will provide to the licensee.
The letters also addressed the specific training which will be offered by the licensee to the concerned agency, including annual retraining.
Personnel in each of the visited agencies had attended training and participated in drills conducted by the license.
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4 Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
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Address emergency actions to be taken concerning that portion of the 10 mile radius surrounding the Oyster Creek Nuclear Generating Station comprised by the Atlantic Ocean.
In particular, reach an agreement with
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the U. S. Coast Guard for their support during an emergency.
(219-82-01-92)
6.2 General Public The auditor reviewed the pamphlet to be distributed to the general public by the licensee and held discussions with the Oyster Creek Manager of Communication Services.
The Oyster Creek Manager of Communication Services is responsible for the public information program. An information pamphlet, which is to be distributed to utility customers within a 10 - 12 mile radius of the Oyster Creek Nuclear Generating Station in the near future, will supply the information needed by the public concerning an emergency at the_0yster Creek facility. The pamphlet
will be sent to the utility customers with their bills. The licensee will
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also supply the pamphlets to state, county, and local officials and to the local business community to achieve distribution of the pamphlets to the transient population.
Since the licensee has not as yet distributed the'
j pamphlet, the licensee should expedite the_ final preparation, printing, and i
distribution of the pamphlet.
The auditor examined the pamphlet, which was yet to be printed in quantity, and found that it contained information to the public as to how they will be notified and what their actions should be in the event of an emergency.
The pamphlet also explained the operation of a nuclear power plant and provided
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comprehensible information on radiation.
According to the Manager of Communication Services, he has also been implementing the public information program by speaking to public groups ar.d by appearing
on television programs and local radio talk shows.
Such an appearance was performed on January 10, 1982, with state, county, and local officials on a radio station which serves the local area.
The auditor viewed a tape of a television news feature involving a simulator at the plant which was used for public information.
This spot feature was done by a Philadelphia, Pennsylvania, television station and was aired to the Delaware Valley television public on December 8, 1981.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
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Expedite the final preparation, printing, and distribution of the emergency information pamphlet to the public.
(219-82-01-93)
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6.3 News Media The auditor examined Appendix I, Emergency Public Information Plan, to the Emergency Plan during this portion of the appraisal.
The auditor.also interviewed licensee personnel during this portion of the appraisal and reviewed the information supplied to him by these persons.
According to the Responsibilities and Action section of the Emergency Public Information Plan, at least annually the Emergency Public Information Plan Coordinator shall conduct a program to acquaint the news media with the Emergency Public Information Plan, information concerning radiation, and points of contact for release of public information in the event of an emergency. Such a program was held on January 12, 1982.
Twenty-five news media representatives were provided with information on the licensee's plans and procedures for coping with emergencies and providing information to the news media and public.
The program included a tour of the Oyster Creek facilities and discussion of its operation by the Manager of Communications Services and other members of management.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
7.0 DRILLS, EXERCISES, AND WALK-THROUGH 7.1 Program Implementation The auditor reviewed the licensee's records concerning drills and exercises, the Emergency Plan, especially Table 8.2, Exercises and Drills and EPAP-16, Maintaining Emergency Preparedness, and held discussions with licensee personnel during this portion of the appraisal.
The licensee has been conducting "large scale" drills on a monthly basis since June 1981.
The scenarios for these drills have caused the simultaneous exercise of different portions of the emergency response organization.
The review of the documentation for drills conducted during 1981, which was required by section 3.4 of EPAP-16, disclosed that none of the drill scenarios
. satisfied the description of a semi-annual radiological controls drill as given in Table 8.2 of the Emergency Plan. Also, this documentation did not indicate that April and May 1981 monthly communications drills were conducted as required by Table 8.2.
The licensee should assure that they perform the exercised and drills in accord with the Emergency Plan.
The review of the documentation of the drills disclosed that many of the
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improvement items identified during the critiques of the drills have not been accomplished. The licensee indicated that they are attempting to expedite the accomplishment of needed improvements.
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As was pointed out in section 5.5.2 of this report, the licensee should assure that all emergency response personnel are given the opportunity to participate in drills and exercises.
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Based on.the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be considered for improvement:
Perform the exercises and drills in accord with the program described in
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the Emergency Plan, especially Table 8.2, and EPAP-16.
(219-82-01-94)
Expedite the accomplishment of needed improvements in emergency preparedness
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as indicated by the critiques of the drills and exercises.
(219-82-01-95)
7.2 Walk-Through Observations
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l Auditors observed the following during this portion of the appraisal: 1)
offsite, onsite, and in plant radiation monitoring teams performing walk-throughs
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i of their emergency duties; 2) Communication Services' personnel providing press releases during an exercise; 3) security personnel performing walk-through of the notification of emergency response personnel; and 4) shift personnel
reacting to an actual emergency situation.
The auditors found the performance of assigned emergency response procedural tasks by the offsite, onsite, and in plant radiological monitoring teams, deficient. The auditor also found deficiencies in the equipment. The following deficiencies pertaining to personnel performance were noted.
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Personnel were unfamiliar with the operation of the scaler used to measure the concentration of radionuclides in air samples.
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Personnel had not received sufficient hand-on type training.
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Personnel had not received sufficient respiratory protection training and had not been tested for respirator fit.
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The following deficiencies were found in the equipment supplied for offsite monitoring:
The scaler in one van was inoperable.
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There were no check sources for use in performing dose rate instrument response checks as required by EPIP-11.
There was no power available in one van for operating the air sampler.
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The Science Application radioiodine filter cartridge was incompatible with the Scott air sampler filter chambers.
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The air sampler could not be moved away from the van and raised above ground level if necessary to obtain a representative air sample.
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With regard to the preparation and handling of press releases observed on
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January 7, 1982, the auditor found the information in the press releases to be j
accurate and the flow of the information to be timely.
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' With regard to the security personnel notifying emergency organization personnel of an emergency situation, the individual demonstrated that he could satistuctorily
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perform the procedure for calling emergency response personnel.
With regard to the observation of the actual emergency event, the auditor made
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the following observations. A fire was reported in the reactor building at i
about 9:58 a.m. on January 9, 1982. The Group Shift Supervisor became the
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Emergency Director and implemented EPIP-1, Classification of Emergency Conditions,
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and EPIP-2, Unusual Event. The Emergency Director appointed a communicator, who made the notifications required by EPIP-2. This was accomplished within
30 minutes after the. fire was reported. A team of shift personnel found the source of the fire on the 51 foot level of the reactor building to be an
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overheated electric motor on a pump which had seized.
The automatic fire suppression system operated as designed and suppressed the fire. The licensee l
undertook appropriate recovery actions to dispose of the fire suppression water.
The problems in the training of radiation monitoring personnel and in providing proper survey equipment were addressed in Sections 3.1 and 4.2.1.1 of this
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report.
Based on the above findings, this portion of the licensee's program appears to
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be acceptable.
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TJUCLEAR REGULATORY COMMISSION I
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Docket No. 50-219 CAL 82-03 GPU Nuclear Corporation ATTN:
Mr. Philip R. Clark Vice President - Nuclear 100 Interpace Parkway Parsippany, New Jersey 07054 Gentlemen:
This letter refers to the meeting with you and members of your staff, Mr.
J. M. Allan and other members of the NRC Region I staff, Mr. C. R. Van Niel of the Office of Inspection and Enforcement; and Mr. J. J. Lombardo of the Office of Nuclear Reactor Regulation; which was held on January 28, 1982, in the Region I office. The meeting concerned the actions you are going to take regarding the significant findings of the NRC Emergency Preparedness Implementation Appraisal Team which were made during their appraisal of your Oyster Creek Nuclear Generating Station on January 4 through January 15, 1982.
These significant findings and your corrective actions were also discussed among Mr.
P. B. Fiedler, Vice President Oyster Creek, and other members of his staff and Mr. W. W. Kinney, Appraisal Team Leader, and members of the Emergency Preparedness Implementation Appraisal Team on January 15, 1982.
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With regard to the matters discussed at the meetings, we understand that you will undertake and complete the following actions.
1.
Improve the Emergency Response Facilities as follows:
a.
Relocate the Emergency Control Center (ECC) so that it is out of the Control Room and is completely contained in the Group Supervisor's Office.
Since the Group Supervisor's Office is not large enough, this will require either a reduction in the number of emergency response organization members working in the ECC, or expansion of the size of the Group Supervisor's Office, or a combination of the two options.
A schedule will be provided to the NRC Region I office no later than February 20, 1982.
b.
In regard to the Technical Support Center (TSC):
(1) Upgrade the present Technical Support Center with:
a ventilation system providing adequately filtered air; instrumentation to detect direct radiation and airborne contamination; a more comprehensive set of plant drawings; a more comprehensive set
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GPU Nuclear Corporation
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of plant parameter data from the computer terminal; more space for the occupants; and better spacing of the telephones. Also, provide a copy of the results of the TSC shielding study to Region I of the NRC.
(2) Because you are not providing a permanent Technical Support Center as described in your September 11, 1981, letter to the
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Director of the Office of Nuclear Reactor Regulation by October 1, 1982, resubmit conceptual design information for a suitable TSC which meets the requirements of the Office of Nuclear
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Reactor Regulation, February 18, 1981, Generic Letter 81-10 concerning " Post-TMI Requirements for the Emergency Doerations Facility." Also include a schedule showing milestones and the date when the facility will be operational.
Provide a copy of your complete submittal to the NRC Region I office.
These actions shall be completed no later than April 1, 1982.
c.
Locate and equip the Operational Support Center as described in the Emergency Plan and in your September 11, 1981, letter to the Director of the Office of Nuclear Reactor Regulation.
This shall be completed no later than October 1, 1982.
d.
Upgrade the Nearsite Emergency Operations facility located in Building 12 of the Forked River site with equipment and supplies to allow management and technical personnel to perform emergency functions as described in your September 11, 1981, letter to the Director of the Office of Nuclear Reactor Regulation.
This shall be accomplished no later than March 16, 1982.
e.
Provide a Farsite Emergency Operation Facility which has the same capabilities as the Nearsite Emergency Operations Facility as called for in your Emergency Plan and in your September 11, 1981, letter to the Director of the Office of Nuclear Reactor Regulation.
This shall be completed no later than October 1,1982.
2.
Improve Post-Accident Sampling Capability as follows:
a.
Complete the installation and calibration of your new stack effluent monitoring system.
Develop procedures to collect and analyze post-accident gaseous, particulate and iodine samples containing high levels of radioactivity consistent with the activity levels identified in Table II.F.l-2 of NUREG-0737.
This shall be act.omplished prior to resumption of reactor operations after your 1982/1983 refueling / maintenance outage.
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GPU Nuclear Corporation
FEB 181982
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b.
Until you have installed your equipment capable of sampling reactor coolant and containment atmosphere under post-accident conditions per NUREG-0737 and have it operational, evaluate and define the post-accident conditions under which reactor building accessibility for such sampling can be reasonably expected and determine radiation levels of the reactor coolant which can be sampled without exceeding appropriate NRC personnel. exposure criteria or EPA action guides.
Also, during this interim, define and procure necessary sampling and laboratory equipment and prepare procedures for sampling and analyzing high activity samples including reactor coolant, containment air, and airborne effluents.
Provide the schedule for the expedited procurement of equipment to the NRC Region I office.
The above actions, except for the procurement of the necessary sampling and laboratory equipment, will be completed no later than March 1, 1982.
3.
Complete the development of and establishment of a more comprehensive training / retraining program for all emergency response personnel which is consistent with your new Emergency Plan and Emergency Plan Implementing Procedures. Complete the training of all members of the newly defined onsite and offsite emergency organizations.
In particular, complete the training of offsite monitoring teams; sampling teams taking high activity samples; and analytical chemistry personnel analyzing high activity samples using hands-on type training.
The more comprehensive training / retraining program will'be developed and established no later than June 1, 1982. The licensee reports that the upgraded training has been initiated and will continue on an expedited basis, and that the offsite monitoring teams were trained prior to January 21, 1982.
The sampling teams and analytical chemistry personnel will be trained no later than one month after the expeditious procurement of the sampling and laboratory equipment previously addressed in item 2.b.
4.
Improve your precedures as follows:
a.
Incorporate appropriate references to the Emergency Plan Implementing Procedures in your operating procedures.
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This shall be comp.leted prior to resumption of reactor operations after your 1982/1983 refueling / maintenance outage.
b.
Complete the revision and expansion of your Emergency Plan Implementing Procedures so that personnel are specifically directed in the completion of all required emergency response tasks. Also include in these procedures:
appropriate judgment guidelines, precautions, limitations, and references to other procedures used in completing the emergency response task.
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GPU Nuclear Corporation
FEB 181982 This shall be completed no later than June 1, 1982.
c.
As backup to computer based methodology, establish a manual procedure to be used to determine offsite doses to the thyroid based on measured and projected radiciodine concentrations.
The procedure should document assumptions used; incorporate appropriate EPA-520 or ICRP models; and be made consistent with the procedures used by the appropriate offsite agencies.
This shall be completed no later than June 1, 1982.
5.
Perform an engineering study of existing Area Radiation Monitors (ARM's)
and Process Radiation Monitors (PRM's) to determine the upgrading necessary to the monitoring system to provide adequate accident detection and classification and post-accident radiation mapping capabilities to meet ANSI-N320.
Provide a schedule to the NRC for the upgrading of the monitoring system as determined by the study.
The study shall be completed no later than June 1, 1982.
The schedule for upgrading the monitoring system will be provided shortly thereafter.
Another significant finding regarding your lack of installed equipment capable of sampling reactor coolant and containment atmosphere under post-accident conditions per NUREG-0737 was not listed because you have made two requests to the Office of Nuclear Reactor Regulation to allow the postponement of this installation. As soon as we resolve the status of your requests, we will inform you when this sampling equipment must be installed.
If our understanding of your planned actions, described above, is not in accordance with the actual plans and actions being implemented, please contact this office by telephone and in writing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Your cooperation in this matter is appreciated.
Sincerely, N.
aid C. Haynes Regional Administrator cc:
M. Laggart. Licensing Supervisor J. Knubel, BWR Licensing Manager Public Document Room (POR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of New Jersey