IR 05000237/1981027
| ML20039A608 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 12/14/1981 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20039A609 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 NUDOCS 8112180512 | |
| Download: ML20039A608 (12) | |
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(DEC 141981.
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Docket No. 50-10 Docket No. 50-237
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Docket No. 50-249 Q
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Commonwealth Edison Company
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ATTN:
Mr. Cordell Reed
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Vice President
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Post Office Box 767 O
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Chicago, IL 60690 D
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I Gentlemen:
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Subject: Emergency Preparedness Appraisal To verify that licensees have attained an adequate state of onsite emer-gency preparedness, the Office of Inspection and Enforcement is conducting special appraisals of the emergency preparedness programs at all operating nuclear power reactors. The objectives of these appraisals are to evaluate the overall adequacy and effectiveness of emergency preparedness and to
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identify areas of weakness that need to be strengthened. We will use the findings from these appraisals as a basis not only for requesting individual licensee action to correct deficiencies and effect improvements, but also for effecting improvements in NRC requirements and guidance.
During the period of November 2-10, 1981, the NRC conducted a special appraisal of the emergency preparedness program at the Dresden Nuclear Generating Station. This appraisal was performed in lieu of certain routine inspections normally conducted in the area of emergency prepared-ness. Areas examined during this appraisal are discussed in the e. closed reports (50-10/81-16; 50-237/81-27; and 50-249/81-20). Within these areas, the appraisal team reviewed selected procedures and representative records,
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inspected emergency facilities and equipment, observed work practices, and
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interviewed personnel.
I Significant deficiencies for which you have made acceptable commitments to i
resolve are discussed in the Confirmation of Action Letter dated November 13, l
1981, enclosed as Appendix A.
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The findings of this appraisal also indicate that there are areas for improvement in your emergency preparedness program.
These are discussed in Appendix B, " Preparedness Improvement Items."
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Commonwealth Edison Company-2-In conjunction with the aforementioned appraisal, emergency plans fot your facility were reviewed. The results of this ' review indicate that cercain deficiencies exist in your Emergency Plan (GSEP) and the Dresden Site Specific Annex. These are discussed in Appendix C, " Emergency Preparedness Evaluation Report."
Several areas in your emergency preparedness program were not complete at the time of this appraisal and therefore were not examined. These items are identified as Open Items and are listed in the enclosed Appendix D.
These will be examined by our staff upon complete implementation of the area involved.
Please notify our office relevant to your completion schedule for these items for re-examination by our staff.
We recognize that an explicit regulatory requirement pertaining to each item identified in Appendices A, B, and C may not currently exist.
Notwithstanding this, you are requested to submit a written statement within thirty days of the date of this letter describing your planned actions for improving each of the items identified in Appendix A and the results of your consideration of each of the items in Appendix B.
This description is to include:
(1) steps which have been taken; (2) steps which will be taken; and (3) a schedule for completion of actions for each item. This request is made pursuant to Section 50.54(f) of Part 50, Title 10, Code of Federal Regulations. With regard to Appendix C, within 90 days of the date of this letter, you are requested to provide changes to the emergency plan correcting each deficiency. Copies of these changes are to be submitted in accordance with the procedures delineated in 10 CFR 50.54(q).
This is to inform you that shouid the deficiencies addressed in the Confirmation of Action Letter of November 13, 1981, not be corrected by the commitment dates provided, the Commission will determine whether the reactors shall be shut down until such deficiencies are remedied or whether other enforcement action is appropriate.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of-this letter, the enclosures, and your response to this letter will be placed in the NRC's Public Document Room.
If this report contains any information that you (or your contractors) believe to be exempt from disclosure under 10 CFR 9.5(a)(4), it is necessary that you (a) notify this office by tele-phone within ten (10) days from the date of this letter of your intention to file a request for withholding; and (b) submit within twenty-five (25)
days from the date of this letter a written application to this office to withhold such information.
If your receipt of this letter has been delayed such that less than seven (7) days are available for your review, please notify this office promptly so that a new due date may be estab-lished. Consistent with Section 2.790(b)(1), any such application must be accompanied by an affidavit executed by the owner of the information which identifies the document or part sought to be withheld, and which contains a full statement of the reasons which are the bases for the
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Commonwealth Edison Company-3-claim that the information should be withheld from public disclosure. This section further requires the statement to address with specificity the con-siderations listed in 10 CFR 2.790(b)(4). The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit.
If we do not hear from you in this regard within the specified periods noted above, a copy of this letter, the enclosures, and your response to this letter will be placed in the Public Document Room.
The responses directed by this letter and the accompanying appendices are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork P. eduction Act of 1980, (PL 96-511).
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Should you have any questions concerning the items of Appendix C, please contact Mr. M. P. Phillips, Emergency Preparedness Section at (312)932-2530.
Sincerely, original signed by Jcoas G. Kepplet-James G. Keppler Regional Administrator Enclosures:
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Appendix A, Confirmation of Action Letter dtd 11/13/81 2.
Appendix B, Preparedness Improvement Items 3.
Appendix C, Emergency Preparedness Evaluation Report 4.
Appendix D, Open Items 5.
Inspection Reports No. 50-10/81-16; No. 50-237/81-27; and No. 50-249/81-20 cc w/encls:
Louis 0. DelGeorge, Director of Nuclear Licensing D. J. Scott, Station Superintendent DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII Mary Jo Murray, Office of Assistant Attorney General Regional Director, FEMA Region V Al Kenneke, OPE Q
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Appendix A CONFIRMATION OF ACTION LETTER Docket-No. 50-10 Docket No. 50-237 Docket No. 50-249 Commonwealth Edison Company ATTN:
Mr. Cordell Reed Vice President
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Post Office Box 767 Chicago, IL 60690 Gentlemen:
This letter is to confirm agreements reached between Mr. D. Scott, Dresden Station Superintendent, and others of your staff, and Dr. C. Paperiello and other members of the NRC staff on November 10,-1981, during the management exit interview following the NRC Emergency Preparedness Appraisal and to a telephone conversation with Mr. W. Brenner of your staff with the same NRC staff on November 12, 1981.
-Immediate corrective actions are required for significant Appraisal Findings.
The exact nature of the required actions, as well as the agreed upon dates for such actions, are as follows:
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The licensee shall incorporate.the revised protective action recom-mendations table (Table 6.3-1) into the Generating Stations Emergency Plan (GSEP) and appropriate Dresden Station Emergency Plan Implementing Procedures (EPIPs). All Station Directors and Acting Station Directors shall be trained on the use of this table for protective action recom-mendations decision making.
(Section 7.2) (10/81-16-01; 237/81-27-01; and 249/81-20-01).
This shall be completed by February 1,1982.
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2.
The licensee shall prioritize the Notification Phone List such that augmentation capabilities defined in Criterion II.B.5 of NUREG-0654, Revision 1, will be met.
(Section 5.4.1) (10/81-16-02; 237/81-27-02; and 249/81-20-02).
This shall be completed by December 7, 1981.
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Appendix A-2-3.
The Corporate Command Center Director's call list shall be prioritized such that a Recovery Manager will be at the nearsite Emergency Opera-tions Facility (EOF) within 60 minutes of determining that the EOF must be activated.
(Section 5.4.1) (10/81-16-03; 237/81-27-03; and 249/81-20-03).
This shall be completed by February 1, 1982.
4.
EPIP 500-7 shall be revised to ensure that the communication checks with the NRC as required in 10 CFR 50, Appendix E,Section IV.E.9.d are conducted.
(Section 5.5.1) (10/81-16-04; 237/81-27-04; and 249/81-20-04).
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This shall be completed by February 1, 1982.
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The licensee shall submit a description of the prompt notification system including enough information to ensure that the design objec-tives of Appendix 3 in NUREG-0654, Revision 1, are met.
This description shall clearly indicate when the system will be fully operational.
(Section 6.2.2) (10/81-16-05; 237/81-27-05; and 249/81-20-05).
This shall be completed by February 1, 1982.
If our understanding of your planned actions described above is not in ac-cordance 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 />. Further, please inform this office, in writing, upon completion of all the above action items.
Sincerely, James G. Keppler Regional Administrator
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Appendix B PREPAREDNESS IMPROVEMENT ITEMS Based on the results of the NRC's appraisal of the Dresden Nuclear Station Emergency Preparedness Program conducted November 2-10,_1981, the following items should be considered for improvement:
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An overall emergency radiation protection procedure should be developed which covers precautions to be taken, respiratory protection, and radia-tion exposure controls during emergencies.
(Section 5.4.3.1).
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Instructions should be included in an emergency procedure which define
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how-to make a radiation survey during an emergency. These instructions should include appropriate precautions, such as noble gas interference with ion chamber readings, and Kr-88 decay to Rb-88 (gas to particulate).
Techniques for determining the source of the radiation levels measured l
should also be included; i.e., external source vs inside an airborne source.
(Section 5.4.2.3)
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The licensee should revise EPIP 100-C1 to direct the RCTs under the direction of the Shift Engineer to conduct appropriate surveys or -
collect appropriate samples until the arrival of -the Rad / Chem Director.
(Section 5.3)
4.
The licensee should conduct an offshift augmentation drill to ensure that the regulatory position of Criterion II.B.5 of NUREG-0654, Revision 1, will'be met. This drill should be documented, conducted on a quarterly basis, and identified deficiencies corrected.
(Section 2.2.2)
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EG-3, (Revision 1), should be revised to identify the means by which a field team can determine whether they are 'inside or beneath a radiological plume (i.e., if open window readings are significantly higher than closed window readings, the team is submerged in the plume). This will also ensure that air samples collected will be representative of the plume.
(Section 5.4.2.1)
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A copy of the Fire Hazards Analysis Report should be placed in the Control Room to assist the Shift Engineer in determining whether equipment has been degraded to the point that a Limiting Condition for Operation (LCO) requires shutdown.
(Section 5.4.8)
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The licensee should develop a Quality Assurance (QA) procedure to ensure-that all areas of Emergency Preparedness as~specified in the GSEP and EPIPs are audited. This should be done when major GSEP revisions have been completed.
(Section 1.5)
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Appendix B-2-
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The licensee should prepare.an emergency kit which contains the required
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radiation detection equipment and which could easily be' transported to the interim EOF when it is activated..(Section'4.1.1.4)-
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A precaution should be included in the appropriate EG procedures indicat-
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-ing that Cutie Pie survey instruments should be hagged to prevent -noble
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. gases from entering the ' ionization chamber and giving false readings.
'(Sections 5.4.2.1~and 5.4.2.2)
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EUF-3 and ED-1 should be revised to specify the means for updating Federal and State radiological assessment personnel at least every 15 minutes.
(Section 5.4.2)
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The licensee should document with a formal Letter of Agreement the s
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' arrangements to.use Drake's Farm Restaurant as a back-up Emergency F56 ;.
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Center. -(Section 4.1.4)
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Meteorological chart recorders in the Control. Room should be equipped with chart paper.which matches the scale of the instruments and indicates a
the rate of speed of the recorder (i.e., time marked).
(Section 4.2.1.4)
13.
Liquid effluent sampling and analysis procedures should be revised to
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contain precautionary statements that warn the user of possible high'
sample activity in post-accident samples. '(Section 5.4.2.10)
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Appendix C EMERGENCY PREPAREDNESS EVALUATION REPORT The following is a list of deficiencies identified in the Dresden Emergency Plan Site Specific Annex. These deficiencies are categorized as per the planning standards of 10 CFR 50.47(b). These deficiencies as well as those listed in Appendix A must be corrected in accordance with the provisions of 10 CFR 50.54(s)(2):
PLANNING STANDARD 50.47(b)(2) (ONSITE EMERGENCY ORGANIZATION) (10/81-16-06; 237/81-27-06; and 249/81-20-06)
The GSEP does not adequately describe' shift augmentation as per the
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regulatory position of Criterion II.B.5 of NUREG-0654, Revision 1.
Enclosure 9 of CECO's submittal dated December 31, 1980, indicates the current capability of the Dresden Station to provide emergency support within 30 minutes. This capability consists of approximately three times the number of personnel needed. The Dresden Annex does not include this 30 minute shift augmentation capability. The Annex does not clearly indicate what kind of duty officer system is being used to ensure that this augmentation capability can be met.
Further, the Plan does not describe the administrative means, (e.g., studies and/or drills) imple-mented to ensure that the design objectives of shift augmentation are met as described in either Criterion II.B.5 of NUREG-0654, Revision 1, or Enclosure 9 of CECO's December 31, 1980, submittal.
The Plan does not indicate which responsibilities of the Acting Station
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Director may not be delegated (such as the protective action recommenda-tions to offsite authorities).
PLANNING STANDARD 50.47(b)(4) (EMERGENCY CLASSIFICATIONS SYSTEM) (237/81-27-07 and 249/81-20-07)
The Dresden Annex does not adequately provide Emergency Action Levels
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(EALs) as per Appendix 1 of NUREG-0654, Revision 1, in the following areas:
UNUSUAL EVENT a.
Condition No. 1 must also include transportation of any contaminated injured individual to an offsite medical facility as an Ucusual Event.
(As stated in Table 5.0-2, C.14 of the generic GSEP)
b.
Condition No. 8 does not define any earthquake detected on station seismic instrumentation or felt in-plant as an Unusual Event.
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Appendix C-2-c.
The Annex does not address train derailment onsite. This is an Unusual Event.
d.
Condition No. 4 does not address either loss of offsite power or loss of onsite AC power capability as an Unusual Event.
e.
Condition No. 10 does not address exceeding a primary system leak rate technical specification limit as an Unusual Event.
f.
The Annex does not address a significant loss of assessment or com-munication capability for equipment other than that requiring plant shutdown (e.g., plant computer, Safety Parameter Display System, all meteorological instrumentation). These are all Unusual Events.
g.
Condition No. 11 does not address high coolant activity sample (e.g.,
exceeding coolant technical specifications for iodine spike) as an Unusual Event.
h.
The Annex does not address high offgas activity at the air ejector monitor (greater than 500,000 uCi/sec or an increase of 100,000 uCi/sec within a 30-minute time period).
If the technical specification trip setting is to be used, this value must be less than the above and the value specified in the annex.
ALERT a.
Condition No. 11 does not address high offgas activity at the air ejector monitor as an Alert (greater than 5 Ci/sec; corresponding to 16 isotopes decayed 30 minutes).
b.
The Annex does not address the loss of most or all annunciators as an Alert.
c.
Condition No. 10 does not address a Main Steam Isolation Valve (MSIV)
malfunction causing leakage as an Alert.
d.
Area Radiation Monitor (ARM) reading EALs are not provided in Table DA 5-1 which indicate a severe degridation in the control of radio-active materials (e.g., increases by factor of 1000 in direct ARM reading within the facility).
e.
Condition No. 4 should specify that the complete loss of all AC power (onsite and offsite) is an Alert.
f.
Condition No. 5 should specify that the complete loss of all onsite DC power is an Alert.
g.
Condition No. 6 inadequately addresses a fire potentially affecting safety systems.
This condition is an Alert, rather than an actual degraded system being an Unusual Event.
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Condition No. 8 does not address an earthquake greater than Operating Basis Earthquake as an Alert.
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The Annex does not address turbine failure with casing penetration as an Alert.
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EALs for anticipated evacuation of the Control Room have not been included in the Plan (e.g., radiation levels, toxic gas concentrations approaching hazardous levels, and fires). These should also be included for the Site Emergency (see Condition No. 13).
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Condition No. 18 does not address other plant conditions that warrant precautionary activation of the Technical Support Center (TSC) and placing the nearsite Emergency Operations Facility (EOF) snd other key emergency personnel on standby.
SITE AREA EMERGENCY a
Condition No. 18 does not address other plant conditions that warrant activation of emergency centers and monitoring teams or a precautionary-notification to the public near the site as a Site Emergency.
b.
Toxic gas sampling results (EALs) which are hazardous have not been indicated in the Plan. This must be done for an Unusual Event and Alert as well as the Site Area Emergency.
c.
Condition No. 2 does not address entry of uncontrolled flammable gases for the Unusual Event, Alert, and Site Area Emergency. These would be the same EALs as for toxic gases.
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d.
The Annex does not address the loss of most or all annunciators and a plant transient initiated or in progress as a Site Area Emergency.
GENERAL EMERGENCY a.
Loss of two out of three fission product barriers with a potential loss of a third barrier is not adequately addressed. Table DA 5-1 is too conservative by classifying a General Emergency using only
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the high range containment radiation monitor. This must be changed to indicate loss of two out of three fission product barriers with a potential loss of containment. Therefore, high radiation level in containment and (not or) indication of potential loss of containment should be used to classify this event.
b.
EALs have not been calculated for those BWR sequences which could lead to a core melt and likely failure of containment.
(See page=1-18 of Appendix 1 in NUREG-0654, Revision 1).
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Appendix C-4-For all EALs in the Plan, the specific value corresponding to the
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parameter must also be included in the Plan (e.g., hazardous and toxic gas concentration levels).
PLANNING STANDARD 50.47(b)(5) (NOTIFICATION METHODS AND PROCEDURES)
(10/81-16-07; 237/81-27-08; and 249/81-20-08)
The Dresden Annex does not describe the administrative or physical
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means and time required for notifying and providing prompt instructions to the public. A description of the prompt notification system for the ten mile EPZ similar to CECO's April 27, 1981, submittal for LaSalle, must be provided for Dresden. A summary of this must also be included in the Annex.
PLANNING STANDARD 50.47(b)(8) (EMERGENCY FACILITIES AND EQUIPMENT)
(10/81-16-08; 237/81-27-09; and 249/81-20-09)
When commitments are fully implemented as stated in the Plan, then
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the Plan must be revised to reflect these changes; i.e.,
installation of post-accident monitoring and sampling systems, process monitors, TSC aad EOF as built diagrams, etc.
The Plan makes no reference to the existence of equipment designed to
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measure hydrological and seismic parameters from offsite sources, nor hydrological parameters from onsite sources.
The Plan does not provide for timely activation and staffing of the
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E0F.
Specifically, no mention is made of how the E0F will become functional within one hour of the decision to activate as specified in Criterion 4.3 of NUREG-0696.
PLANNING STANDARD 50.47(b)(14) (EXERCISES AND DRILLS) (10/81-16-09; 237/81-27-10; and 249/81-20-10)
The Dresden Annex does not specify that communications drills with
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States within the ingestion pathway (Indiana) shall be tested quarterly.
The GSEP does not address the requirement to test communications with
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the NRC Headquarters and Region III Operations Centers from the TSC, EOF, and Control Room on a monthly basis. This is required by 10 CFR 50, Appendix E,Section IV.E.9.d.
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Appendix D OPEN ITEMS The following is a list of Open Items identified in the area of Emergency Preparedness which must be re-examined and completed:
1.
Installation of all needed radiological and assessment equipment and supplies should be completed in the permanent TSC to conform to NUREG-0696.
(Section 4.1.1.2) (10/81-16-10; 237/81-27-11; and 249/81-20-11)
2.
The Operational Support Center (OSC) must be relocated to the Radio-chemistry Foreman's office.
(Section 4.1.1.3) (10/81-16-11; 237/81-27-12; and 249/81-20-12)
3.
Installation, testing, and development of procedures covering sampling and analysis using the Sentry High Range Sampling System (HRSS) must be completed.
(Sections 4.1.1.5, 4.1.1.6, 4.1.1.8, 5.4.2.4, 5.4.2.5, 5.4.2.6 and 5.4.2.7) (237/81-27-13; 249/81-20-13)
4.
Installation, testing, and development of procedures covering sampling and analysis using the SPING and Victoreen post-accident stack effluent systems must be completed.
(Sections 4.1.1.7,15.4.2.8 and 5.4.2.9)
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(237/81-27-14; 249/81-20-14)
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Installation and calibration of the high range containment radiation monitor is required.
(Section 4.2.1.2) (237/81-27-15; 249/81-20-15)
6.
The licensee must issue Revision 9 to DAP 7-1 (Operations Department Organization) and train Shift Control Room Engineers (SCREs) in their new responsibilities.
(Section 5.2) (237/81-27-16; 249/81-20-16)
7.
The licensee must issue Revision 2 to EPIP 300-3.
(Section 5.4.3.3)
(10/81-16-12; 237/81-27-17; and 249/81-20-17)
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