IR 05000244/1981022
| ML20053E909 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 05/04/1982 |
| From: | Crocker H, Terc N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20053E902 | List: |
| References | |
| 50-244-81-22, NUDOCS 8206100199 | |
| Download: ML20053E909 (56) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION Region I Repcrt No.
50-244/81-22 Docket No.
50-244 License No.
DPR-18 Priority Category C
Licensee:
Rochester Gas and Electric Corporation 39 East Avenue Rochester, New York 14649 Facility Name:
R. E. Ginna Nuclear Power Plant Appraisal at:
Ontario, New York Appraisal conduc 6 1:
Novemb r 2-13, 1981 b/U Team Members:
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Nemen M. Terc, Appraisal Team date signed Leader H. W. Crocker, Chief,-EPS, Region I E. F. Woltner, TIB, Region I B. Zalcman, DEP, HQ E. H. Carbaugh, Battelle NW Laboratories L. F. Garcia, Battelle NW Laboratories Approved by: '_'
M ['/f M H lbert W. Crocker, Chief date signed Emergency Preparedness Section B206100199 820520 PDR ADOCK 05000244 Q
i INDEX Page SUMMARY
1.0 ADMINISTRATION OF EMERGENCY PREPAREDNESS
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 Organization
3.0 TRAINING / RETRAINING
3.1 Program Establishment
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
4.1.1.2 Technical Support Center (TSC)
4.1.1.3 Operations Support Center (OSC)
4.1.1.4 Emergency Operations Facility (EOF)
4.1.1.5 Post-Accident Primary Coolant Sampling
and Analysis 4.1.1.6 Post-Accident Containment
Air Sampling and Analysis
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ii 4.1.1.7 Post-Accident Gaseous and Particulate Effluent Monitoring Sampling and Analysis
4.1.1.8 Transfer and Storage of Post-Accident
Liquid Waste 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
4.2 Emergency Equipment
4.2.1 Assessment
4.2.1.1 Emergency Kits and Portable
Instrumentation 4.2.1.2 Area and Process Radiation Monitors
4.2.1.3 Non-Radiation Process Monitors
4.2.1.4 Meteorological Instrumentation
4.2.2 Protective Equipment
4.2.2.1 Respiratory Protection
4.2.2.2 Protective Clothing
4.2.3 Communications
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4.2.4 Damage Control, Corrective Action and
Maintenance Equipment and Supplies 4.2.5 Reserves
4.2.6 Transportation
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I iii 5.0 PROCEDURES
5.1 General Content and Format
5.2 Emergency, Alarm and Abnormal Occurrence
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 Post-Accident Primary Coolant
Sampling 5.4.2.5 Post-Accident Primary Coolant Sample
Analysis 5.4.2.6 Post-Accident Containment Air Sampling
5.4.2.7 Post-Accident Containment Air Sample
Analysis 5.4.2.8 Plant Vent Effluent Sampling Procedure
5.4.2.9 Plant Vent Effluent Sample Analysis
5.4.2.10 Sampling of Post-Accident Liquid Wastes
5.4.2.11 Analysis of Post-Accident Liquid Wastes
5.4.2.12 Radiological Environmental Monitoring
Program (REMP)
5.4.3 Protective Actions
5.4.3.1 Radiation Protection During Emergencies
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iv 5.4.3.2 Evacuation of Owner Controlled Areas
5.4.3.3 Personnel Accountability
5.4.3.4 Personnel Monitoring and Decontamination
5.4.3.5 Onsite First-Aid / Rescue
5.4.4 Security During Emergencies
5.4.5 Repair and Corrective Actions
5.4.6 Recovery
5.4.7 Public Information
5.5 Supplementary Procedures
5.5.1 Inventory, Operation Check and Calibration
of Emergency Equipment, Facilities and Supplies 5.5.2 Drills and Exercises
5.5.3 Review, Revision, and Distribution of
Emergency Plan and Procedures 5.5.4 Audits of Emergency Preparedness
6.0 COORDINATION WITH OFFSITE GROUPS
6.1 Offsite Agencies
6.2 General Public
6.3 News Media
7.0 DRILLS, EXERCISES AND WALK THROUGHS
7.1 Drill and Exercise Program Implementation
7.2 Walk-Through Observation
7.2.1 Emergency Detection, EAL Recognition
and Emergency Classification
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v 7.2.2 Post-Accident Primary Coolant Sampling and
Analysis 7.2.3 Offsite Radiological Surveys
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Ginna SUMMARY The appraisal of the onsite emergency preparedness program at the R. E. Ginna Nuclear Power Plant, involsed seven general areas:
Administration of the Emergency Preparedness Program Emergency Organization Emergency Training Emergency Facilities and Equipment Procedures which implement the Emergency Plan Coordination with Offsite Agencies Walkthroughs of Emergency Duties The development of the Emergency Program was administered by individuals on the staff at the site.
The results of the appraisal indicated that the existing program contained a number of deficient areas.
A review of the licensee's emergency organization description sho,ied it was ill defined and that as a consequence personnel assignment to the various functional areas of emergency activity was unclear.
The emergency preparedness training program was incomplete and some personnel tested by the auditors lacked adequate know-how in the performance of their duties.
A number of deficiencies were noticed in the licensee's facilities and equipment.
Emergency implementing procedures were found inadequate, with unclear assignment of responsibilities, ambiguities, inconsistencies, errors, and lacking specific cross-references to other procedures.
The auditors concluded that the overall impact of the deficiencies identified could rasult in a potential degradation of the licensee's emergency response, but that their overall state of emergency preparedness would allow them to restend, manage and mitigate emergencies.
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1.0 ADMINISTRATION OF EMERGENCY PREPARCDNESS 1.1 Responsiblity Assigned Appendix A " Letters of Agreement", letter No. 10, " Designating Emergency Planning Coordinator (EPC)", of the Ginna Station Radiation Emergancy Plan (hereafter referred to as the Emergency Plan) assigned to the Superin-tendent of Nuclear Production, located in RG and G, headquarters office
in Rochester, New York, "the overall authority and responsibility for emergency response planning." An Energency Planning Coordinator on site was also assigned by the letter to assist with the development and updating of emergency plans, and to coordinate these plans with other responsible organizations. His " Position Analysis Questionaire," however, assigned him as Technical Assistant to the Plant Superintendent and referred to a sertes of duties which did not include Emergency Planning.
While apparently the EPC on site devoted most of his time to emergency planning functions, his corporate counterpart devoted only a small part of his time to emergency planning.
This assignment was a collateral duty in addition to ten basic functions described in his " Position Analysis Questionaire".
Deficiencies found in various areas of the emergency program (See Sections 3. 4. 5) suggested the need for assigning another person who devotes most of his time to assist the EPCs in the implementation of their numerous duties pertaining to emergency planning.
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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Assign another individual to assist the EPCs on their emergency planning duties (50-244/SI-22-01)
1.2 Authority Assigned responsibilities in the area of emergency preparedness were supported with sufficient authority and received management support when exercising the authority, with exception as noted in Section 1.1 above.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
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1.3 Coordination The EPCs were usually involved in management meetings and belonged to committees reviewing procedures which may have an impact on emergency planning.
Discussions with the EPCs indicated that there was some degree of coordination among site and corporate EPCs.
However, discussions with the various elements of the onsite emergency response group, and deficiencies in areas such as:
emergency organization, training and procedures (See i
Sections 2, 3 and 5) indicated that coordination between onsite groups was lacking.
The development of procedures and training for example, was performed in isolation, without vital feedback from other elements of the organization.
Based on the above findings, improvements in the following areas as required to achieve an acceptable program:
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Develop and implement administrative means to ensure adequate coordination between onsite emergency organizational elements.
(50-244/81-22-02)
1.4 Selection and Qualifications The auditors found that no selection critieria had been established for personnel responsible for emergency planning. Judging by their resumes, the auditors found that basically both EPCs would be qualified to perform in their present capacities, and that professional development training courses were made available to them.
For example, in August 1981 the onsite EPC attended INPO's Training Conference on Emergency Planning, which lasted 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />.
Based on the above findings, this portion cf the licensee's program appears to be acceptable, but the following matters should be considered for improvemont:
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Establish specific formal selection criteria for personnel responsible for emergency planning.
(50-244/82-22-03)
2.0 EMERGENCY ORGANIZATIL; 2.1 Onsite Organization The auditors reviewed the Emergency Plan and implementing procedures and held discussions with licensee persennel to evaluate his emergency organiza-tion.
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In performing this evaluation the auditors conceived the emergency organiza-tion as a system unfolding with time.
Three basic phases were considered:
initial, intermediate and final augmentation.
The initial phase consists basically of the minimum crew operating the plant.
The intermediate augmentation phase comprises the full fledged onsite emergency organization forming within a reasonably rapid time frame (60 minutes).
The final augmentation phase includes the first two, additional corporate and other support groups.
The final augmentation phase will be discussed in Section 2.2 below.
The licensee's emergency organization was referred to in Section 4 "Organi-zational Control of Radiation Emergency". The licensee's description of the initial phase of response was limited to describing, by title, the number of persons in the operating crew and the Health Physics Technician on shift.
The Shift Supervisor (SS) was assigned the responsibilities of the Emergency Coordinator until relieved, and thus the authority to classify and declare emergencies.
The licensee failed to address the hierarchy of command, the various functional areas of response, and the inter-relationships between elements during the initial response, required to clearly and unambigiously describe the emergency organization at this stage. The need for doing this is particularly important for responding to emergencies during offshifts.
The description of the intermediate phase of the emergency organization was limited to the subdivision into four major groups, namely:
survey evaluation, communications, Control Room Operator and Technical Support Center in addition to the Emergency Coordinator.
In addition, the licensee made reference to Tag Board Assignments, to be picked up in numerical sequence by individuals arriving at the Emergency Survey Center (ESC).
Some Implementing Procedures (e.g. SC-1.3B " Site Emergency Coordinator and Survey Center assignees) specifically addressed the use of Tag Board Assignments, and briefly outlined responsibilities for: Assistant Emergency Coordinator, Technical Support Manager, Emergency Survey Center, Dose Assessment, Technical Center Health Physicist, Communication Aide, Technical Support Personnel (e.g. Technical / Nuclear Engineer, Offsite Survey teams, Systems and Equipment Analysis, Instrument and Control Analyst, Data Processor) onsite survey teams, and decontamination teams.
Although some of the functional areas and tasks required during the intermediate response phase were addressed in this manner, the licensee neglected others (e.g., inplant surveys, post-accident sample collection and analysis, etc.').
Additionally, an overall description of the full fledged emergency organization during the intermediate response phase was lacking.
The auditor's found that inter-relationships among supervisory and non-supervisory elements needed for a coordinated response were left undefined. As a result, the overall logic of the system became blurred, and this condition was propogated to other areas of the licensee's emergency preparedness program such as Training and Procedures (Sections 3 and 5).
The auditors discussed the above discrepancies with the EPCs, Training
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Coordinator and the Plant Superintendent who acknowledged the need for clarifying each phase of the emergency organization.
Interviews with persons who would act as Emergency Coordinators and other members of the emergency organization's management staff indicated that each individual had a different idea about the emergency organization concerning its command structure and inter-relationships between organizational elements.
The auditors found no means by which the Emergency Director and other key personnel could correlate the various functional areas of response and the tasks required to be performed during emergencies with individuals trained and qualified to perform these tasks.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
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Establish an emergency organization which provides for all emergency functions needed during initial, intermediate and final phases of augmentation.
Revise the Emergency Plan to include a description of the organization, and update implementing procedures to be consistent with the organization. The description shall include sufficient detail to define the command hierarchy; specify its struct e, reporting chains and inter-relationships at any phase of a% ;entation; and include supervisory as well as non-supervisory elements.
(50-244/81-22-04)
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For each functional area specified within the emergency organization provide a list of personnel trained and qualified to perform the tasks associated with the area.
These lists shall identify the current status of each individual.
Provisions to maintain lists current shall be developed and implemented.
(50-244/81-22-05)
2.2 Augmentation Organization The auditors found the augmentation of the licensee's onsite emergency organization in Sections a.3 and 8 of the Emergency Plan.
Section 8, " Recovery", referred to an organization that would provide long term augmentation and consisted of corporate staff personnel.
The staff would operate from the Recovery Center, also designated an EOF, in the event of site or general emergencies. A brief statement of responsi-bilities was included for each of the six staff members and for the Recovery Manager, who would direct and coordinate the final augmentation phase.
The auditors noted that according to the Emergency Plan, the Recovery augmentation referred to a phase following the accident, when operational and offsite conditions had returned to normal.
Again, the auditors found that the description of the corporate augmentation during and after the accident was vague.
(This finding was included in Section 2.1.)
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The extension of the capabilities provided by local services (e.g. ambulance, medical, hospital, firefighting) were specified in the plan but the organizational elements corresponding to these activities had not been delineated, and their inter-relationships, with other organizational elements were not described.
(This finding was included in Section 2.1.)
3.0 TRAINING / RETRAINING 3.1 Program Establishment The licensee's training program was described in Saction 7.1 of the Emergency Plan, with detailed information described in A-102.11 " Emergency Plan Training Program".
The auditor inte viewed Training Coordinators responsible for emergency training, assistants, and instructors, and reviewed pertinent documents.
The following emergency training categories were provided:
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Emergency Plan Indoctrination
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Ginna Station General Employee Emergency Plan Review
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Emergency Coordinator
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Control Room Operator
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Security Force
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Local Service Support
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Manning the Technical Support Center Training for the Emergency Operations Facility (EOF) personnel was provided through the Assistant to the Superintendent of Nuclear Operations who was assigned as Corporate Training Officer.
The auditors conducted interviews and reviewed the corporate training program.
Training appeared to be informal in nature.
Training subjects listed in inter-office correspondence included: a review of the site, county, and State Emergency Plans, recovery center facilities, Dose Assessment, accident analysis, Recovery Plans, implementing procedures and check-lists, offsite teams, and recovery center assignments.
The auditors noted that written criteria for qualifying instructors was lacking.
Training instructors were selected on the basis of their technical competence, experience, and their ability to teach.
Emergency training sessions were usually four hours long. The auditors reviewed the lesson plans in the Nuclear Training Section and determined that lesson plans with stated objectives existed for all the various emergency training categories, and were also provided for security personnel and local agencies.
The major part of training onsite was conducted by the Nuclear Training Section.
Security and fire control training was performed under their respective divisions.
Recovery Center (EOF) personnel training was conducted by the Corporate Training Officer and training for offsite support agencies by consultants.
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The auditors noted that training had been documented, including: name of attendees, date, training category and instructor.
Records were forwarded to the Records Center for filing.
Written tests to ascertain whether individuals had attained a minimum level of proficiency in their emergency tasks were lackir.g. The instructor's judged whether individuals could perform the required tasks based on hands-on training results.
No formal testing was used. While most individuals that would respond during emergencies had received training in the above categories these were not aligned to an emergency organization.
(See Section 2.1)
Based on the above findings, improvements in the following area is required to achieve an acceptable program:
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Realign the emergency plan training program to be consistent with the functional areas, requirements, and structure of the emergency organization.
(S0-244/81-22-06)
3.2 Program Implementation The auditors reviewed the following training categories records stored in the Control Records Center:
Training Type 1981 Training Date Emergency Coordinators January Control Room Operations October Monitoring Teams October
Response Teams July, October First Aid July, October Security Force October, November Fire Brigade February, June, August, November Technical Support Center January On-Site Support Center October Local Support Agency September, October The auditors interviewed four members of management and ten other individuals to verify that they had received emergency training and found that they had been trained.
Individuals selected for interviews represented a sample from the various training categories.
The auditors found that although emergency training was in fact given to a substantial number of individuals, formal means to ensure that individuals were adequately qualified to perform their emergency duties were lacking (e.g. written and oral evaluations based on established critieria).
In some cases and in particular for middle management positions a lack of a description of the onsite emergency organization, complicated matters even further, since specific tasks and responsibilities were uadefined.
(See Section 2.1)
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Results of walk-through performed by the auditors confirmed that, in some cases, employees had not attained proficiency in vital tasks.
For example, offshift Shift Supervisors and Health Physics technicians failed to adequately recognize Emergency Action levels, classify emergencies, interpret, analyze results, or take proper radiological precautions.
(See Section 7.2)
The auditors review of the licensee training records confirmed that employees generally were not given tests to verify that they had attained a minimum level of proficiency to perform their assigned emergency dutics.
While training walk-throughs done by the licensee were instructive, there were no means to test the proficiency of the persons involved.
Based on the above findings, improvement in the following area is required to achieve an acceptable program:
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Develop means to verify that all individuals with emergency duties have been trained and have attained a minimum leve'
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proficiency.
This shall include, but not be limited t,
.Js-on training and walk-throughs.
(50-244/81-22-07)
4.0 EMERGENCY FACILITIES AND EQUIPMENT 4.1 Emergency Facilities 4.1.1 Assessment Facilities 4.1.1.1 Control Room The auditors toured the R. E. Ginna Control Room.
This tour included an audit of emergency kits, documentation (e.g. emergency plan and procedures, plant drawings) readouts of area and process monitors, communications equipment, and meteorological instrumentation.
The content of the emergency kit was as specified in SC-1.15, " Inspection of Emergency Equipment" The licensee maintained a complete set of relevant plant drawings and procedures in the control room.
The auditor examined 65 procedures related to emergency preparedness to verify current revisions were in place.
Included in this audit were the Emergency Plan (SC-1) as well as procedures in each of the following categories:
alarm response, emergency system operation, health physics, and site contingency.
The auditors found one outdated procedure.
(See Section 5.5.3 of this report).
Readouts for instrumen-tation to be used in accident assessment and emergency classification appeared to be adequate and reasonably accessible for timely interpreta-tion.
There was no readout in the control room for the seismic accelerograph, but the auditors concluded that existing procedures would allow determination of seismic activity.
Equipment for sampling and monitoring the radioactive airborne concentrations in the control room was not being maintained in the control room,
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Preposition sampling and monitoring equipment to detect and measure airborne and particulate radioactivity in the control room.
(50-244/81-22-08)
4.1.1.2 Technical Support Center (TSC)
The TSC was located adjacent to the main building in a structure specially designed and built to serve as the TSC.
The TSC consists of a central space surrounded by the NRC resident inspector office, a conference room, a document roon, and another room currently used for computer operations. One end of the central space has mobile partitions enclosing an area used for routine operations.
The TSC is directly accessible from the outside through one door. Wall ing time from the TSC to the control room (CR) through any of two doors communicating to the turbine building was less than one minute.
There were no area monitors to indicate radiation levels in routes between the TSC and the CR.
The licensee estimated that the maximum dose received by a person walking from the CR to the TSC during a design basis accident would be less than 5 rem.
The auditors found no provisions for closed circuit TV that would facilitate face to face interaction between personnel located in the CR and TSC and that could be used to retrieve information not available in the TSC data system.
The TSC was currently in the procurement-design stage.
Its complete set-up was scheduled for mid-1983.
The working space in the TSC (2400 sq. ft.), would allow 32 persons.
An off-site dose-assessment map mounted on a mobile frame, was located in the TSC, including a set of plastic isopleths.
It was not divided into the 22 1/2 - degree sectors, as specified in NUREG-0654, and was limited to 20 miles from the plant site.
Display-size " plant status" printed forms were available in the TSC, but not plant operating records.
The auditors found that data communications were not complete at the time of the appraisal, but a hard copy from the plant computer was obtainable at two locations within the TSC.
The structure of the TSC provided shielding equal to about two feet of concrete.
Should radiation levels exceed specified habitability criteria, current plans called for evacuation of selected TSC personnel to the C The ventilation system of the TSC was in place but not fully operational.
Farticulate (HEPA) and caarcoal filters were installed but had not been activated.
Dedicated individual voice links between the TSC and the CR, Emergency Operations Facility (EOF), and NRC were:
from the TSC to the CR (telephone, intercom, and radio), from the TSC to tne EOF (none),
TSC links with NRC, ENS extension in the main TSC area, and ENS, HPN extensiens in the NRC resident's office.
In additier., there were two commercial telephones for NRC use.
There were no dedicated telephona links between the TSC and the State and Counties (New York State; Wayne and Monroe Counties).
Hot lines to those agencies were expected to be set up by mid-December 1981.
Two outside telephone lines were availa >1e for communications with onsite and offsite certers and agencies.
The TSC had no radio facilities for communicating with field monitoring teams.
Noise was controlled by accoustical tile ceiling and carpeted floor, doors between separate rooms, and flashing lights to identify ringing telephones.
The Document Room (260 sq. ft.) contained up-te-date records (e.g.
Technical Specifications, Plant Operating Procedures, Emergency Operating Procedures, Final Safety Analysis Report, and updated drawings, schematics, and diagrams).
The room had table-top space for working.
Emergency-kit items and Emergency Survey Instrumentation (see item 4.2.1.1 below) were found in this location. Additional NRC individuals were allocated a private office (450 sq. ft.) within the same TSC building.
The TSC has a kitchen, with stove-sink; refrigerator with freezer, and restroom with shower.
The auditors found that current provisions for monitoring equipment for immediate awareness of airborne radioactivity were inadequate.
This is of particular importance because the ventilation system must be initiated manually.
Based on the above findings, inprovements in the following areas are required to achieve an acceptable program:
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Complete the installation and testing of equipment in the TSC to ensure that it will be habitable and functional and able to perform its intended use during accident conditions.
(50-244/81-22-09)
4.1.1.3 Operations Support Center (OSC)
The OSC was located adjacent to the TSC, in an area having 450 square feet, normally used for auxiliary operators. Although within the same building complex the OSC was not protected by the shielded covering, or the ventilation system of the TSC.
The OSC is accessible froir the TSC via a short hallway and has an access door to the turbine building.
The primary communication link between the OSC and the CR and the TSC was through portable radios.
If the OSC becomes uninhabitable, personnel would evacuate to the computer room in the TSC.
Emergency equipment at the OSC consisted of 6 full face masks with charcoal cartridges; 2 portable flood lights; and 6 sets anti-contami-nation clothing.
Potassium iodide tablets, were not included.
Dosimeters and radiation monitoring equipment were lacking.
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 radiation monitoring and radiation protection equipment and supplies in the OSC.
(50-244/81-22-10)
4.1.1.4 Emergency Operations Facility (EOF)
The EOF, or " Recovery Center," was located at RG&E's corporate headquarters, in downtown Rochester, 18 miles WSW of the Ginna plant.
The auditors toured various areas within the building designated as the EOF and noted that the facilities were scattered through the building.
The ' main' EOF was a 1900 sq. ft. room on the seventh floor, while the Engineering Staff would occupy regular office spaces located on the sixth floor.
The Dose Assessment area would be located on a separate floor from the ' main' EOF.
Readout of the station meteorology could be obtained via CRT terminal, TI 700 terminal, and by telephone communication with CR and TSC.
The main EOF had work spaces for the Recovery Manager and his staff, communications, and outside agencies (including NRC). The auditor noted sufficient work space for 5 NRC persons and a separate office for NRC use across the hallway from the main EOF.
The main EOF contained:
work tables, identification signs, telephones, emergency plans and procedures, applicable parts of the FSAR and ER, an assignment board for main EOF activities, and plant flow diagrams.
The auditors noted a total absence of radiation protection equipment and supplies (e.g. radiation survey meters, dosimeters, check sources, sample counting equipment, air samplers); site map divided into 22
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1/2 degree-sectors, clock, radio, and direct-line communication system. There were no first-aid kits and decontamination supplies in the EOF.
There wc: e no dedicated communications equipment from the main EOF-to the TSC and CR, except for one dedicated telephone line and a radio transceiver located in the Recovery Manager's office. Non-deritcated voice communication links with the NRC, and federal, state, and local agencies consisted of 27 centrex telaphones.
Based on the above findings, improvements in the following treas are required to achieve an acceptable program:
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Provisions for an Emergency Operations Facility (EOF)
having sufficient and appropriate equipment to enable the direction, coordination, and evaluation of licensee's activities as demanded by the emergency organization.
(50-244/81-22-11)
4.1.1.5 Post Accident Primary Coolant Sampling and Analysis The auditors inspected the sampling location and equipment, reviewed the sampling precedure (See Section 5.4.2.4), and discussed design
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parameters with members of the plant chemistry and health physics staff.
The auditors noted that routine primary coolant sampling and analysis facilities were used for interim post-accident sampling, with modifica-tions such as:
reduced volume (14 ml) sample collection bomb and shielded sample transport.
The coolant sample is extracted frcm the B-loop and piped to the Nuclear Sample Room in the controlled access side of the Intermediate Building.
Two alternate sample locations were available for routine uses:
the A-loop sample station inside containment and the containment A Sump in the Auxiliary Building basement.
These, however, would not be accessible during certain accident scenarios.
In the event of a LOCA, the former would be inaccessible due to containment isolation, and the latter due to high radiation levels in the Auxiliary Building basement.
The sample room did not contain added shielding around the sample lines or valving.
Emphasis was placed on reducing time of exposure in the sample room rather than in shielding for reducing dose rate.
Two area monitors were located in the Nuclear Sample Room.
The installed plant area monitor had local and control room readout and alarm capability, and a maximui range of 10 R/hr.
This monitor could be off scale in a major accident situation.
A portable digital area monitor (local readout and alarm only) was installed over the
sample hood.
This monitor was set to alarm at 10 mR/hr, suitable for annunciating normal operation deviations, but of little value for accident situations.
A 550 lb. lead shielded sample transport cask mounted on a cart, was stored in the Nuclear Sample Room.
Equivalent to a minimum of two inches lead shielding, this cask would make a significant contribution toward dase reduction from sample transport. The auditors noted that a small pin used to attach the handle to the cart could be susceptible to bending or breaking if torque was applied by twisting the handle while pulling the cask.
In addition to the cask, remote sample bandling tongs (vise grips mounted on a pole) are kept in the hot lab.
These tongs would be effective in dose reduction by placing distance between the technician and the source (sample container)
during transport.
The design of the tongs, however, would not be useful for remote valve manipulation (i.e. the_ vise grips had to be operated by direct contact rather than from the opposite end of the pole).
Semple analysis facilities included the hot lab and counting room.
The hot lab had a sample hood, and a portable digital readout area monitor set to alarm at 10 mR/hr.
Lead bricks were in place as a temporary shield for the sample and a lead glass portable personnel shield was available.
Other materials raquired for analysis (pipettes, gas collection bottles, etc) were readily available.
Since the counting room, is contiguous to the Nuclear Sample Room, and separated only by a wall, it could be subject to higher radiation levels during major accidents, which would render its Ge(Li), Nal, GM and proportional counter systems, useless. Alternate counting facilities were available in the environmental lab, located a consider-able distance away, in a trailer behind the training bcilding.
The possibility of transporting the sample to a remote location had not been considered. The licensee indicated that current plans called for addition of lead shielding on the counting room side of the wall separating the counting room from the nuclear sample room.
The coolant sanpling technique aimed at a representative sample.
Sample lines are flushed for five minutes prior to collection. A sample sink drain bypass line to a shielded (2 inches of lead) 15 gallon cask had been installed to collect sample spillage from the sink.
This cask would not receive the~ total flushing volume, which would be flushed to the CVCS tank, only that spilled during the
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sampling process.
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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Evaluate need for additional permanent shielding in the counting room and Nuclear Sample Room.
(50-244/81-22-12)
Develop 1mproved remote sample handling equipment.
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(50-244/81-22-13)
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4.1.1.6 Post-Accident Containment Air Sampling and Analysis s
The licensee has identified three containment penetrations from which post-accident containment air can be sampled.
These are penetration 124 on the intermediate floor of the Auxiliary Building, penetration 203 near the Nuclear Sample Room on the controlled
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access side of the Intermediate Building, and penetration 305 on the
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radiologically clean side of the Interrediate Building basement.
Only penetration 305 was actually set up with equipment for~a~ir sampling. A shielding study performed by a licensee contractor and reviewed by the auditors indicated that, in the event of a major accident, penetration 305 wouid have' the lowest dose rate of the three possible points, and, therefore, would be the preferred sampling location.
High dose rates during initial accident phases could preclude access to penetrations 124 and 203.
(See Section 5.4.2.6 for further discussion).
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Area radiation monitoring was not available at penetration 305, and '
area monitors in the general vicinity of penetrations 124 and 203 would be inadequate to assess dose rates at the penetrations due to
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distance from the penetration. ' Additionally, a relatively low (10 R/hr) maximum range could be exceeded during certa'.n' accident scenarios.
Equipment available for air sample collection at penetration 305 d
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included a sample pump, 47 mm particulate filter, packed silver zeolite column for iodine collection, and a 35 cc gas sample collection glass bulb.
Flow measurement and control was provided by a rotometer and adjusting valve.
The auditors noted that the sampling apparatus was not permanently connected to the penetration isolation valves, although this would reduce the time (and dose) required for sample collection in the event of a major accident.
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A shielded cask (one inch of lead) and remote handling tongs consisting of locking pliers at the end of a rod were provided to aid in dose reduction during sample transport.
These were normally stored in the health physics lab area although no specific storage locations were defined, which could result in time delays in. locating the shielding cask.
Laboratory analytical equipment including syringes, septum bottles,
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hood, shielding, and analyzers were comparable to that previously described in Section 4.1.1.5 and appeared adequate.
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Based on the above findings, improvements in the following areas are required to achieve,and acceptable program:
Provideco(tainmentatmospheresamplingequipmentat i
penetrations 124 and 203; consider the need to maintain this equipment permanently connected to the penetration isolation valves;'and evaluate the need for additional
. area ~monitcring. equipment at the sample stations.
(50-244/81-22-14)
4.1.1.7 Post-Acciden.t Gas and Particulate Effluent Monitoring Sampling and Analysis
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The auditors noted that the licensee's plant vent monitoring capability had been upgraded on an interim basis in response to NUREG-0578 by locating a high range ion chamber detector one foot from the plant vent duct on the operating floor of the Intermediate Building. The detector was shielded on five sides by four inches of lead; the open l
side dir'ectly facing.the plant vent duct.
During an accident, a dedicated survey meter would be connected to a remote lead approximately 70 feet from the detector, and read by a technician. The calibration of this instrument was performed using
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calibration procedures which appeared to meet ANSI N323-1978 " Radiation
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,t Protection Instrumentation Test and Calibration Criteria."
Interim monitor readings from approximately 1 mR/hr to 1000 R/hr were related to effluent.concentr5tions of'0.001 pCi/cc to 1000 pCi/cc by a series of grapfs, derived using a calculational study of dose rates.
from a noble gas and hal' ogen mixture at several post accident times.
The model used wa.s.a cylindrical volumetric gamma source with the detector at one foot' from the source.
(See Section 5.4.2.9 for
additional comments). The auditors concluded, after a review, that the methodology used was acceptable.
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The normal plant' vent gas monitor (R-14) had a maximum reading of
10' cpm corresponding to approximately 0.1 pCi/cc xenon-133 gas
concentration.
This provided a two decade overlap between the normal and interim post-accident vent monitors, and appeared acceptable.
The auditors reviewed dhe licensee's capability for collecting samples of noble gases, radiciodines, and particulates from the plant vent. The only provision for emergency plant vent sampling beyond the particulate and iodine (charcoal-cartridge) system used
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for routine sampling was thenuse of a hand held probe manually
inserted and positioned through a hole drilled through the plant vent duct..
While the probe might be suitable for collection of representathe-gas samples, its adequacy for collecting representative
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particulates per ANSI N13.1-1969, " Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities," is doubtful.
Contamination control for the vent hole consisted of a piece of duct tape. Normal particulate and iodine sampling provisions would be inadequate during emergencies due to radioactivity buildup (NUREG-0737 specified source terms are 100 pCi/cc of radiciodine and particulates and a 30 minute sample time).
Such buildup would preclude normal filter or cartridge changeout, during severe accidents.
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The facilities for sample analysis consisted of those described in section 4.1.1.5 and included GM, proportional, Ge(Li), and Nal detector and analyzer capability.
Backup facilities were also available.
Based on the above findings, improvement in the following area is required to achieve an acceptable program:
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Evaluate current post-accident plant vent sampling facilities to assure a representative sample can be collected, transported, and analyzed such that whole body and extremity doses
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would be as low as reasonably achievable.
(50-244/81-22-15)
4.1.1.8 Transfer and Storage of Post-Accident Liquid Waste The licensee had not conducted a study to determine the need for:
retention, transfer, storage, sampling and analysis of post-accident liquid wastes that may be generated as a consequence of certain accident scenarios.
Based on the above finding improdements in the following areas are required to achieve an acceptable program:
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Make an evaluation of the need for:
retention, transfer, storage, sampling and analysis of highly radioactive liquid wastes that could be generated as a result of severe accidents.
(50-244/81-22-16)
4.1.1.9 Offsite Laboratory Facilities The auditors tourec the laboratory-trailer normally used only for environmental assays, and noted that during emergencies this facility could be used as a backup for their primary counting laboratory.
The trailer was located west of the plant, within the security fence, and had sample preparation equipment, a liquid scintillation detector, a low beta counter, and a Ge-Li detector with a computer-based multi-channel analyzer.
The auditors noted that the laboratory-trailer would not be functional during a power outage, so that the licensee would have to rely on its contractors, or other facilities.
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Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.1.2 Protective Facilities i
4.1.2.1 Assembly / Reassembly Areas The Emergency Plan identified the Information Center as the primary assembly / reassembly area.
The auditors toured the Information Center to determine the size, location and the types and quantities of emergency protective equipment
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available.
The assembly area was found located in close proximity to the reactor building and did not have adequate shielding and ventilation.
The area appeared to have sufficient space to accommodate the number of personnel expected.
The auditorium seats approximately 150 people
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in addition to other rooms and the basement of the building.
The only dedicated form of communication with other emergency facilities was in the form of telepher.es with direct paging features.
(See Section 4.2.3) The audicors found a lack of dedicated radiation instrumentation (e.g. air samplers, frisker, dose rate detectors) to i
determine habitability of the primary assembly area.
(See Section
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4.2.1.1).
There were no provisions for re-assembling personnel in the event the major assembly area became uninhabitable.
Based on the above findings, this portion of the licensee's program appeared to be accaptable, but the following matter should be considered
for improvement:
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Provide means for re-assembling personnel in alternate assembly areas.
(50-244/81-22-17)
4.1.2.2 Medical Treatment Facilities The auditors verified that the licensee maintained onsite provisions and facilities for the treatment of individuals who may be injured or contaminated.
The dispensary was maintained under electronic lock when the nurse was not on duty.
Rapid entry was made possible by the use of key-cards.
Access by two individuals carrying a stretcher would not present a problem. The facility was equipped with first aid equipment and supplies adequate to perform personnel decontamination. Communications were available from the dispensary and procedures for treatment and decontamination of individuals were available.
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Additional assistance for the treatment of injured and contaminated individuals was available from the Rochester General Hospital and the Radiation Management Corporation.
Based on the above findings, this portion of the licensee's program appeared to be acceptable.
4.1.2.3 Decontamination Facilities The licensee maintained onsite provisions for decontamination near the Radiation Control Area and at the Dispensary.
The auditors toured these facilities and determined that supplies and equipment were available to decontaminate a limited number of individuals.
Decontamination shower and washroom were found adjacent i
to the Access Control Point. The Dispensary contained a body tray l
for wash down of individuals and a large carboy for the collection i
of potentially contaminated water, cotton swabs and various other decontamination supplies.
Provisions for decontamination were available at the Emergency Survey Center including:
one shower, containers for radioactive waste and replacement clothing.
Based on the above findings, this portion of the licensee's program appeared to be acceptable.
4.1.3 Expanded Support Facilities The licensee's program for support facilities was outlined in a brochure dated November 3, 1981 titled " Nuclear Emergency Offsite Response", issued by their Facilities and Personnel Division (FPD),
the FPD provides administrative and logistic support during emergencies.
Examples of support services include lodging, craftsmen, trailers, tents, toilet facilities, food, water, communications, vehicles and additional electrical power. Arrangements havo been made with suppliers of the above services to obtain prompt procurement of the items.
i Based on the above findings, this position of the licensee's program appears to be acceptable.
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4.1.4 News Center A description of the News Center was found in Section 6.1.7 of the Emergency Plan and Figure 6-2 of the Offsite Response Procedures.
The auditor interviewed the manager of Public Relations, regarding the news center arrangement and equipment, and visited the premises of the Joint Emergency Information Center.
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A total area of approximately 4700 ft.2, including a 2000 ft.2 press conference section (250 person capacity), 1200 ft.2 news media work j
area, and 600 ft.2 of office space were available for Federal, State and the local public.
There were 28 kw of electrical power available j
for camera crew use, suitable audio / visual display equipment, PA system, copying equipment and telephones.
A security guard was
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routinely available for badging visitors and other personnel entering the building.
During accident situations, additional security personnel would be assigned to all entrances to the news center.
This would ensure that only authorized news media, Federal, State, and local officials would be allowed access ta the area.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.2 Emergency Equipment 4.2.1 Assessment 4.2.1.1 Emergency Kits and Portable Instrumentation The auditors inspected emergency kits and emergency survey instrumenta-tion in the Emergency Survey Center (ESC), Technical Support Center (TSC), Operations Support Center (OSC), and Control Room. These items were reserved and prepositioned as specified in SC-1.15, Inspection of Emergency Equipment (See Section 5.5.1).
The auditors noted that dose-rate instruments (e.g. ionization chambers) were not provided for the offsite survey teams. Count-rate instruments were considered inadequate for their intended use, due to the need for converting counts into dose-rate, and because the energy dependency of the instruments could translate into significant errors.
In addition, the response range was in the order of 20 mr/hr (for intermediate energies) so that measurements taken near the centerline of the radioactive plume, could exceed the maximum response level of the instrument.
This, in turn, would translate in the absence of offsite team data for making dose projection estimates.
The auditor's noted that self contained breathing apparatus (SCBAs)
and extremity dosimeters were not kept at the ESC, although inplant surveys originated there.
In addition, survey instruments with beta / gamma distinguishing capability included GM types, but failed to include ion chambers.
Carbon cartridges, used for training purposes, were not clearly marked, nor had other provisions been taken to prevent confusing them with silver zeolite cartridges. As a result, the auditors found charcoal cartridges installed in air sampling equipment.
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There were no radiation instruments dedicated to the ESC for determining its habitability conditions (See Section 4.1.2.1)
Emergency instrumentation detectors such as frisking (HP-190) probes in the ESC and 7~C were not provided with shielding, to reduce the background radiaGon and thus increase the minimum levels of detect-ability of the instrument.
The range of direct reading pocket dosimeters in the ESC were too low (maximum SR) for them to be consistent with the amount of radiation expected to be received in some of the emergency response tasks
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during severe accident conditions.
Based on the above findings, improvement in the following areas are required to achieve an acceptable program:
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Re-evaluate portable instrumentation to rapidly and accurately measure radiation levels and radioactive contamination according to the needs of the various functional area of response during emergencies.
(50-244/81-22-18)
4.2.1.2 Area and Process Radiation Monitors The auditors found that area and process radiation monitors described in sections 6.3.1, 6.3.2, and 6.3.3 of the Emergency Plan were available and operable.
Readouts and chart recording of all units except the interim high range vent monitor were provided in the control room (CR). Alarm set points were posted adjacent to the control room readouts.
The plant area radiation monitoring (ARM) system consisted of eight detectors, with local and CR readout and alarms. Alarm set points ranged from 2 to 100 mR/hr.
The purpose of these monitors was to alert station personnel to higher than normal radiation conditions and to identify a plant radiation emergency as defined in SC-1.2 The auditors judged that the area monitor system would be of nominal value during accidents involving major fission products release, due to their 10 R/hr range.
(An upper detection limit of 10' R/hr was recommended by ANSI N320-1979 " Performance Specifications for Reactor Emergency Radiological Monitoring Instrumentation.") Calibration of the ARM system was performed annually during refueling outages, in accordance with STAT procedures.
The most recent (April 1980)
calibration of the ARM system was reviewed by the auditors and found acceptable.
Post-accident containment monitoring was based on area monitors (R-2 and R-7) which are limited by a maximum range of 10 R/hr. The auditors noted that two permanent post-accident high range containment monitors were being installed.
The licensee expects to meet the
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NUREG-0737 required completion date or January 1, 1982 for their operation.
Evaluation of these monitors to NUREG-0737 criteria will be made in a subsequent inspection.
The process radiation monitoring (PRM) system consisted of 14 detectors including containment, plant vent, and service water monitors. With the exception of the in.erim post-accident hiqh range plant vent monitor discussed in sections 4.1.1.7 and 5.4.2.8 of this report, all units had control room readouts and strip chart recording.
Alarm set points were posted adjacent to the control room readouts.
The auditors reviewed the most recent (April 1981) calibration of the R-14 plant vent gas monitor.
Calibration included plotting the GM tube plateau, setting detector voltage, and fluid calibration using low and high activity krypton-85 gas corrected for decay.
Detector efficiency for Xenon-133 was also determined using laboratory analysis of containment air as a standard. Maximum reading of the vent monitor was 10' cpm which corresponded to approximately 0.1
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pCi/cc for Xenon-133.
Overlap between the normal and interim post-accident high range vent monitor is discussed in section 4.1.1.7 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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Perform a study to determine the number of detectors (ARMS) with sufficient high range to provide in plant post-accident radiation measurements useful to accurately detect and classify emergency conditions.
(50-244/81-22-19)
4.2.1.3 Non-Radiation Process Monitors The auditors inspected the process monitors described in section 6.3.6 of the Emergency Plan.
Primary system parameters included pressurizer level and pressure, steam generator level, and average reactor coolant temperature.
Secondary system parameters for each steam generator included steam flow and feedwater flow. Containment monitoring parameters included pressure, sump level for both the A and B containment sumps, fan cooler condensate level, and dew point temperature.
The auditors verified that all above instruments were readily observable and had control room readout and annunciators, except those which were located in the Intermediate Building.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.2.1.4 Meteorological Instrumentation The auditors found a brief description of the licensee's meteorological-measurements program in Section 6.3.8 of the Emergency Plan. The integration of meteorological information into the licensee dose
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assessment scheme was found in procedures:
SC 1.13, PC-23, and SC-1.3.
Surveillance and maintenance of the measurements program was found in RD-14.
The auditors determined that meteorological capabilities addressed the requirements of NUREG-0737, TAP III.A.2 and the criteria set forth in NUREG-0654, Appendix 2.
i The metecrological measurements system had the capability to provide the basic parameters (i.e. wind direction and speed, and an estimate of atmospheric stability) necessary to perform dose assessments. A portion of these data were recorded in the control room (CR) (i.e.
10 meter wind conditions).
Instantaneous values of wind and temperature values were available in the CR on the plant process computer and LEDs; but the time history of these data, other than the 10 meter winds was not available there.
The auditors determined that dispatching an individual to obtain that information on a continuing basis was not acceptable.
All measurement systems were in operation and calibrated by the contractor.
Recent modifications to measurement and recording systems were not described accurately in the plan.
The emergency plan should reflect current capabilities instead of proposed improvements.
Provisions to obtain meteorological information from an alternate data source (station 13A control building), consisted of dispatching an individual to the location.
During severe weather conditions affecting the site, CR personnel
would be advised by the load dispatcher. Access to the NRC health physics network would be used on an interim basis to provide the NRC with direct telephone access for making offsite dose projection.
The preventative maintenance program consisted of a multi-tiered operational program.
The primary system was checked on a three time per week basis and the Station 13A wind sensors on a once/ week basis.
Surveillances were reviewed on a weekly basis to assure the operability of the systems.
Calibrations were performed on a semi-annual basis by a contractor.
The procedure for surveillance activities did not reflect the current configuration of the system, (e.g. recent modifications to the primary system and location of recorders). The auditors noted that, with a semi-annual calibration frequency, additional surveillance activities need to be performed in order to evaluate the electronic response of the equipment (e.g.
zero/ span checks), and to review strip chart records for system malfunction (e.g. threshold response with bad bearings).
In the event of system malfunction, the I&C staff was notified to perform corrective maintenance on the system.
Procedures did not reflect the current instrumentation.
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The methodology for using transport and diffusion characteristics did not consider terrain induced effects. Methodologies in use were not supported with a technical basis document for either the meteor-ological or radiological aspects.
The model used for transport and diffusion was a ground-level, straight-line, steady-state, Gaussian-distribution.
SC-1.13 took into account real-time meteorological information but the auditors noted various difficulties with this procedure.
(See Section 5.4.2)
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
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Include in the Emergency Plan the current means used fer determining the magnitude of release, and for continuous dose assessment.
(50-244/81-22-20)
In addition, the following areas should be considered for improvement:
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Establish a mechanism to assure that a continuous record of meteorological information is available in the CR, the TSC and EOF.
Include, as a minimum, a hard copy listing of 15 minute averaged values or a continuous trace of wind direction and speed and an estimate of atmosphere stability.
(50-244/81-22-21)
Revise the Einergency Plan, and procedures (e.g. RD-14 and
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CP-250) to ensure they are consistent with the equipment currently in place.
(50-244/81-22-22)
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Identify an alternate source of meteorological data.
(50-244/81-22-23)
4.2.2 Protective Equipment 4.2.2.1 Respiratory Protection The auditor verified stocks of full-face respirators with charcoal filters, reserved in accordance with SC-1.9, " Inspections of Emergency Equipment," for emergency use.
The need for additional numbers of full-face respirators and SCBAs in the ESC, and CR for use by the offsite survey teams, was pointed out in Section 4.2.1.1.
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The licensee had two facilities for refilling SCBA air cylinders.
One used compressed air, and would not be useable if ambient air became contaminated, but the other was a cascade system consisting of bottled air, located in the basement of the Service Building.
There were no other provisions, to use as backup, in the event this location became inaccessible during severe accidents.
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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Evaluate present SCBA refilling air facilities te ensure that SCBA refilling capabilities will be available under the most severe accident scenarios.
(50-244/81-22-24)
4.2.2.2 Protective Clothing The licensee had pre positioned emergency supplies at various strategic locations throughout the facility.
In addition, extra sets of protective clothing were stored in the warehouse.
The auditors concluded that routine stores could provide sufficient protective clothing to support accident response needs.
Based on the above findings, this portion of the licensee program appears to be acceptable.
4.2.3 Communications The auditors verified that communications equipment specified in the licensee's Emeegency Plan and Implementing Procedures was available.
There were three alarms throughout the facility which had distinct sound and meanings.
These were fire, intrusion and evacuation.
In addition, a public address system was used in conjunction with the alarms to provide instructions to plant personnel. Whenever oral alarms would be inaudible, visual alarms, in the form of red warning lights, were provided.
Voice communications equipment consisted of portable radios, fixed station radios, dedicated telephones, and beepers. The licensee had provisions for routinely checking the operability of emergency communication devices and equipment, such as, alarms, portable radios, base radios, intercom A and D, direct outside lines with Rochester and Ontario, hot line with the state and county, NRC ENS and HPN phones.
The auditors reviewed and observed various check logs and operation of the emergency communication devices and equipment.
The licensee had dedicated communication among the Control Room, Technical Support Center, Operation Support Center and Emergency furvey Center including radios, PA and telephones.
The EOF communications
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equipment was limited to commercial telephone lines with the site (See Section 4.1.1.4)
Based on the findings in the above area the following improvement is required to achieve an acceptable program:
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Install state and county hot lines from the TSC and complete installation of communications equipment within the E0F.
(50-244/81-22-25)
4.2.4 Damage Control, Corrective Action and Maintenance Equipment and Supplies The auditors determined that the licensee did not maintain dedicated reserves of parts, supplies, or equipment to be used for damage control, repair and corrective actions, or replacement of equipment but depended upon routine stocks of these materials.
The auditors determined that the licensee had not developed a specific method to identify materials and equipment that would most likely be used during the varicus accident scenarios.
Orsite truck and snow moving equipment were available for use.
Based on the above findings, improvement:. in the following area are required to achieve an acceptable program:
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Evaluate the need for maintaining a supply of selected damage control, and corrective action equipment and supplies, and for positioning the same so that it will be accessible for use during emergencies.
(50-244/81-22-26)
4.2.5 Reserves The auditors noted that the licensee maintained dedicated stocks of certain supplies, material and equipment for use during an emergency; radiological survey equipment, dosimetry supplies for personnel and environmental radiation monitoring, protective clothing, respiratory protection equipment, radios and decontamination supplies.
Reserve supplies and equipment were distributed in the various locations:
ESC, CR, TSC, and Health Physics Control Point.
These were also means for the periodic verification of items and for reordering of supplies.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
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4.2.6 Transportation The licensee does not have vehicles dedicated to emergency response'
operations.
There were five company owned vehicles available on site, including two 4-wheel drive vehicles.
The use of personal vehicles is allowed by the company for off site monitoring teams.
The vehicles had no radio communication systems and would have to depend on hand held radios obtained from the ESC. Ambulance service is available with off site service.
Based on the above findings, this portion of the licensee's program appeared to be acceptable, but the following matters should be considered for improvement:
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Provide means to ensure that at least one emergency vehicle would be available to perform offsite monitoring functions under severe weather conditions.
(50-244/81-22-27)
5.0 PROCEDURES 5.1 General Content and Format The auditors found emergency procedures consisted of three main sections:
purpose; references; and instructions.
Procedures included a cover sheet which documented its number, revision rumber, revision PORC review date, approved date, title, and notation of t,tal pages contained.
Each page of the procedure was numbered, but these pages contained no revision number nor identified the final procedure page.
Without the cover sheet the revision number or the total pages could not be identified. Procedures frequently made general references (e.g. to the Emergency Plan) which were of no practical value to the user.
Procedure instructions were not specific enough to enable the user to perform the task required (as an example, SC-1.38.3, TAG TC-1-Technical Operation Manager in step B required a survey of radiation levels along the path to the TSC, but did not specify what radiation detection instrument to use or where to get the instrument.
In step A the person should report to the Health Physicist for guidance on protective actions, although such emergency title was not identified.) SC-1.3D " Manning the Technical Support Center" contained two general references but failed to give references to specific procedures that outline detailed techniques required to perform the various tasks.
Titles used in the procedures were not consistent with an emergency organization but corresponded to the normal organization.
Based on the above findings improvements in the following areas are required to achieve an acceptable program:
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Revise the emergency implementation procedures to:
provide specific guidance (who, when, where, how, etc.); incorporate useful references to other procedures in the action steps; label procedure pages indicating procedure number, revision and final page.
(50-244/81-22-28)
Specific findings relating to various procedures will be discussed in subsequent sections of this report.
5.2 Emergency, Alarm, and Abnormal Occurrence Procedures The auditors reviewed alarm respo,se (AR) and emergency (E) procedures for use in identifying and classifying abnormal plant conditions and to initiate actions to return the plant to normal or stable conditions.
The AR procedures were used to link specific control panel alarm annunciators to a set of Emergency Operating Procedures (EOPs).
The auditors verified that E0Ps were available for each accident condition listed in Regulatory Guide 1.33.
Each E0P included a list of symptoms requiring procedure execution, defined immediate and followup operator actions, and, where applicable, a list of automatically initiated actions.
The E0Ps provided Emergency action levels (EALs) and cross-references to appropriate emergency plan implementing instructions.
In some cases (e.g., E-16.1, "High Activity-Radiation Monitoring System," Section 2.6.3) the EALs were readily keyed to emergency classifications by a table.
In other cases, the relationship between EALs and emergency plan classification, although present, required a review and cross-references to numerous steps and procedures.
The excessive use of cross-references could result in sub-stantial delays in classifying emergencies. The auditors noted that in some cases instructions were not concise and oriented toward the user's immediate needs.
Shift supervisors, for example, need a clear and concise linkage of plant status indicators to emergency plan classifications via emergency action levels.
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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Review E0Ps to incorporate clear and concise instructions for the user to link emergency action levels and emergency classifi-cations.
(50-244/81-22-29)
5.3 Implementing !nstructions Implementing Instructions are overall procedures, usually one for each emergency class written for use by the person coordinating and directing the emergency respor.se effort.
Such procedures should orchestrate the implementation of other, more specific procedures (e.g., offsite surveys, personnel accountability, etc.) to be used in response to the various
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classes of emergencie The auditors reviewed implementing instructions for the folicsing emergency classes:
SC-1.2A Unusual Event, SC-1.2B Alert, SC-1.3A, 3B and 3C Site Emergency and SC-1.4 General Emergency. An additional emergency classifica-tion was defined in SC-1.2 as Plant Radiation Emergency.
This classification pertained to response to events of relatively minor radiological significance, and known to have no offsite consequences.
Implementing instructions indicated that the shift supervisor would act as Emergency Coordinator until relieved.
Emergency coordinator responsi-bilities were defined within the steps of each implementing instruction, with " Emergency Coordinator Checklists" included.
Planned responses (notifications, TSC activat;un, orchestration of other procedures) were addressed for plant radiation, unusual event, alert, and site emergency categories.
The guidance provided in the general emergency implementing instruction may be adequate for gradually worsening emergency conditions (e.g. site to general emergency) but, if there was a sudden need to declare a general emergency, or a quick intensification of conditions from Alert to General Emergency, the guidance provided in the Site emergency procedure would be insufficient.
EALs were included in the implementing instructions for Plant Radiation emergency and Site Emergency.
Implementing instructions for Unusual Event, Alert and General Emergency classifications refered to SC-1.1A, "Ginna Station Event Evaluation and Classification",
for action levels.
The Unusual Event Implementing Instruction refered to a table (step 3.1.1) for event classification.
This table, however, had been deleted.
EALs provided for the site emergency classification included two specific radiation detector readings and a table of general conditions, but failed to identify specific plant instrumentation reflecting emergency conditions.
The auditors review of SC-1.1A, "Ginna Station Event Evaluation and Classification", revealed that paragraph 3.14.3 classified a number of abnormal conditions, (e.g. a reactor trip or malfunction of pressured heaters or s~ pray valves as an alert level); paragraph 3.15.1 did not describe the electrical transient following loss of offsite power; contra-dictory statements we:e noted in paragraph 3.8.1 where it stated that a plant radiation emergency would be declared for a vent monitor alarm occuring simultaneously with a 1 R/hr reading on an area radiation monitor.
This is dif ferent from the criteria given in SC-1.2, which stated that an emergency would be declared for any area monitor alarm (area monitor alarms were typically set at 100 mR/nr); Paragraph 3.8.6 called for a general emergency on the basis of offsite survey measurements rather than projected doses calculated from measured affluent releases and other inplant parameters.
(See Section 5.4.2).
Technical guidance in SC-1.1A was redundant to other sources cf information, such as Technical Specifications, and E0Ps and, in addition, difficult to use.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
-_. -
-
Review general emergency implementing instructions to assure adequate guidance and necessary detail are provided for the emergency coordinator.
(50-244/81-22-30)
-
Re-evaluate EALs to assure that initiating conditions are defined as far as practicable in terms of speci,'ic, observable parameters (e.g. measured effluent release rates) which are readily available in the control room.
(50-244/81-22-31)
5.4 Implementing Procedures 5.4.1 Notifications The auditors noted that instructions for initial notification of offsite agencies and plant personnel were contained in the implementing instructions for each emergency class.
The shift supervisor, who would be onsite at all times was made responsible for notifications but, these were routinely delegated to a designated auxiliary operator.
Unusual event and alert notifications were defined by cross-reference to procedure 0-9.3, "NRC Immediate Notification", which also included state and local agency notifications. Message content was not explicit but a sample information sheet identified information to be given to offsite agencies.
Explicit instructions were provided in SC-1.3A for making site emergency notifications.
The designated auxiliary operator uses an Immediate Call List to notify station personnel. A second designated auxiliary operator would complete a status report form and will notify state and local agencies.
The notification message included site emergency status, name of individual making the report, verifi-cation phone number, meteorology, fa.ility status, and an estimate of the radioactive release.
The form indicated that while the preceding information was given to the State agency, the local agencies (e.g. counties) would not be given this information but would be directed to wait further instructions from the state. The auditors noted that offsite dose estimates or recommended protective actions based on EPA protective action guides were not included in the init'.al notifications.
A step in SC-1.4 requested General Emergency status notifications, but the level of detail given was scantier than the one for site emergencies.
In addition, there were no status forms for summarizing message content, nor were specific organizations and phone numbers identified.
The emergency coordinator maintains two additional call lists: A Station Call List (SC-1.128) with home phone numbers for all plant personnel, and a Specialized Call List (SC-1.12C) with phone numbers
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for offsite personnel, police, ambulance, fire, consultants, etc.
The auditors noted that both, names and phone numbers, had been deleted from TSC, Control Room, and plant library copies of SC-1.12C.
Notifications were made through the Immediata Call List (SC-1.12A)
for emergency class notifications and other plant administrative procedures in case of medical and fire emergencies.
Based en the above findings, improvements in the following area are required to achieve an acceptable program:
-
Review and upgrade of SC-1.4 to ensure notification of NRC, state, and local authorities, including information as to plant status, releases, offsite dose projections, and where applicable, recommended protective actions.
(50-244/81-22-32)
i In addition to the above findings, the following matters shou'd be considered for improvement:
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Provide augmented notifications to local authorities comparable to that given the state authorities.
(50-244/81-22-33)
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Provide offsite dose projections for abnormal releases.
(50-244/81-22-34)
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Link offsite dose projections to EPA recommended protective action guides.
(50-244/81-22-35)
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Rectify the Specialized Call List (SC-1.12C) distribution error.
(50-244/S1-22-36)
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Develop means to minimize distribution errors in emergency procedures, and to verify that vital lists would be readily available to the elements responsible for making the notification.
,
(50-244/81-22-37)
5.4.2 Assessment Actions The auditors reviewed the methodology used for offsite dose projections and the basis for recommending protective actions.
Two procedures
'
addressed offsite dose projections; SC-1.3.A, " Site Emergency (Shift Supervisor and Control Room)," and SC-1.13, " Estimating Off-Site Doses."
The guidance in SC-1.3.A provided the initial dose estimate for the New York State Bureau of Radiological Health (NYBRH).
The dose estimates contained in Attachment II consisted of FSAR design safety evaluation calculational results.
Contrary to the intent of NUREG 0654, no consideration of actual releases or meteorology were indicated for initial dose projections.
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The auditors noted that SC-1.13 was used for projecting offsite doses based on real-time meteorological and release data.
The procedure lacked responsibility assignments for actions to be performed during the different phases of the emergency as the onsite organization became activated.
Appendix A to SC-1.13 contained dose factors for converting air concentrations into thyroid dose projections.
The method used by the licensee was based on NRC Regulatory Guide 1.109, and provided thyroid dose estimates that were more conservative than those derived by EPA 520/1-75-001 " Manual of Protective Actions." For thyroid doses, the licensee used the adult critical age group whereas EPA 520 identified the child's.
Calcolated air activity that would give for example, a 5 rem dose to the thyroid, was approximately twice as conservative using the licensee method.
Comparing adult thyroid doses, the licensee's was approximately five times more conservative than EPA 52C.
The discrepancies appeared to be primarily attributed to licensee e;sumptions of a single isotope source (iodine-131) and light work ac*.ivity breathing rate for adults, whereas the EPA-520 method consicered a mixture of radiciodines and a lower (24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> average) adult breathing rate.
The licensee should re-evaluate its dose assessment assumptions to assure that they are consistent with those used by offsite agencies responsible for carrying out protective actions.
Other difficulties noted with SC-1.13 included the following:
1)
Failure to consider rapid changes in source or meteoro-logical parameters.
2)
Cumbersome method to estimate, categorize and report the stability class.
3)
Improper selection of AT related information (e.g. obtaining a 15 minute average AT and converting it to a stability class).
4)
Use of deficient techniques (e.g. wind direction fluctuation technique to establish stability.)
5)
Unclear assignment of responsibilities (e.g. responsibil-ity for estimating off-site doses using the X/Q overlap and 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> dose isopleths).
6)
Contradictions (e.g. General Radiation Emergency Criterion (paragraph 3.3.9) versus that in paragraph 3.8.3.
7)
Errata (e.g. 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> correction factor given as 3.7 x 208)
8)
Failure to consider the effects of a ground level release in the diffusion model (e.g. maximum concentrations at site boundaries for all stabilities)
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9)
Failure to provide the basis for "the site boundary effect" (3.8.1, 3.8.2 and 3.8.3)
10) Protective action recommendations based on EPA 520, " Manual of Protective Actions," were not defined, nor was specific reference provided to those listed in Table 5.1 of SC-1,
" Radiation Emergency Plan."
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
Include
'.n the Emergency Plan, the method to be used for
-
determining the magnitude of and for continually assessing the impact of the. release of radioactive materials.
(50-244/81-22-38)
Develop a technique for making protective action recommendations
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based on a method which considers: source, elevation, and buildings in the vicinity of the release; the real-time characteristics of the release and actual meteorological information.
(50-244/81-22-39)
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Identify techniques to compensate for potential uncertainties associated with plume trajectories, and include the technical basis as an appendix to the emergency plan.
(50-244/81-22-40)
5.4.2.1 Offsite Radiological Surveys
.The auditors reviewed procedures prepared as reference for field survey teams, namely:
SC-1.78, "Dete mination of Iodine or Particulate,"
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SC-1.78, " Monitoring Site Radiation Level by TLD," SC-170, " Emergency Radiation Monitoring Off-Site Survey Team".
Procedures were burdened by the inclucion of notes and technical materials. The auditors noted that some of these notes were not essential and could result in confusing the users.
For example, attachment I to SC-1.7D, included field calculations for low and high volume air samplers although low volume samplers were not part of the offsite survey equipment.
Offsite monitoring would be conducted in two stages.
The first one was intended to allow monitoring teams into the field for collection of initial data at predetermined locations. Specific directions for this response stage were detailed in the procedures and included equipment inventory and checks prior to leaving the survey center.
The first stage survey would provide a total field placement of eight TLD's and collection of three air samples at predetermined locations. Two alternate second stage surveys were defined depending
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on wind direction.
These would provide additional TLD placement and one additional air sample. A substantial effort was made to determine sample locations before plume information was made available to the teams.
The emphasis was on placing TLD's rather than in collecting air samples and direct radiation readings. Attachment I to SC-1.70 made reference to five offsite air sample stations which would be the first air samples collected.
This was not consistent with procedure steps.
In addition, although two locked environmental air sample stations were specified in SC-1.7, instructions for locating them were not included in the procedure.
The method used for monitoring the plume consisted of open air count rate measurements using a cylindrical thin-end window GM probe.
Using this method the user will be unable to determine whether the measured count rate was due to gamma radiation only (Indicating exposure from an overhead plume) or a combination of beta and gamma radiation (indicating immersion in the plume). An ion chamber dose rate instrument having a beta window would allow estimating plume exposura versus immersion assessments and provide a direct dose rate.
The auditors reviewed provisions for detecting airborne radiciodine, and noted that the licensee had silver zeolite cartridges and RADEC0 H-809C air samplers for sample collection; and used unshielded cylindrical GM tubes and count rate meters for counting the cartridges.
Minimum sensitivity based on licensee measurements was approximately 3 x 10 ' pCi/cc assuming a 10 cubic foot sample and counting the sample in a low (less than 200 cpm) background. A dose rate instrument and the method described in EPA 520/1-75-001, " Manual of Protective Action Guides," would allow initial plume concentration measuremenis to be made without relocating to a low background area, The auditors reviewed the licensee's instrument calibration and iodine retention determinations, and found them acceptable.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
I
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Re, evaluate provisions to rapidly and accurately detect and measure airbo-ne radioiodine under field condition, in the presence of noble gases and develop a method for field determination of plume immersion as opposed to overhead expcsure.
(50-244/81-22-41)
Provide for early assessment of plume pathway so that
-
instructions about the location of the plume will be given to offsite survey teams.
(50-244/81-22-42)
In addition to the above findings, the following matters should be considered for improvement:
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Provide instructions for obtaining keys for air sample stations.
(50-244/81-22-43)
Reconsider the value of TLD placement against plume tracking
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by air sampling and direct radiation measurements.
(50-244/81-22-44)
5.4.2.2 Onsite (Out-of-Plant) Radiological Surveys The auditors reviewed SC-1.7E and SC-1.7G for onsite (blue and yellow) radiological survey teams.
The procedure failed to specify the element responsible for activating and directing onsite surveys; radiological precautions for team members (e.g. exposure limits, high range dosimeters, protective clothing etc.); ALARA considerations and instrumentation.
The procedures lacked detailed instructions for removing and handling air monitoring cartridges and for measuring their radioactive contents.
The procedures failed to instruct the user to which element of the emergency organization results should be given.
There was no locatien designated as sample collection point, where cartridges and particulate filters would be stored for further evaluation.
The procedure was lacking clear guidelines for the user on when and where to make specific computations or which instrument mode should be used to determine dose rates (e.g. open versus closed window readings) and how these should be recorded.
The procedure did not specify whether portable high volume air or lapel samplers would be used.
In addition, the auditors noted that measurements taken in these surveys were not consistent with those needed for Dose Assessment and that no guidelines were available for the user to determine whether the team was under the radioactive cloud or immersed in it.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
-
Revise procedures SC-1.7E and 1.7G to specify:
responsiblities, radiological precautions, techniques for measuring radioacti-vity, information flow, records and sample disposition, guidelines for plume detection, air sampling equipment etc.
(50-244/81-22-45)
5.4.2.3 In-Plant Radiological Surveys The auditor reviewed SC-1.9, "In-Plant Radiation Monitoring," and noted the procedure failed to specify duties and responsibilities for directing in plant surveys, and did nat indicate who would
i
authorize radiation exposures greater than usual limits, or what guidelines would be used to ascertain dose allowances during accidents.
In addition, the number of individuals forming in plant survey teams and their qualifications were not addressed in the procedure.
The procedure failed to outline the number, types, and ranges of the survey meters and personnel dosimeters to be used, nor the means for recording open and closed-window readings.
The procedure made no reference to clipboards and floor plans that would be needed to accurately and rapidly record data. There were no instructions on how to maintain and relay communications during the survey.
Emphasis on action steps was on "what to do" rather than on "how to".
The licensee's reliance on equipment and instrumen-tation used routinely and kept within the Health Physics Office should be evaluated to ensure availability and accessibility of instrumentation and SCBA and other equipment at all times and under severe scenarios.
The procedure did not address the duration of air supply on SCBAs as part of the precautions on using this equipment.
Additionally, it didn't address the means for recording exposures of individuals performing the surveys.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
-
Revise procedure SC-1.9 to specify: responsibilities, radiological precautions, instrumentation, techniques for measuring radioactivity, record keeping and information flow.
(50-244/81-22-46)
5.4.2.4 Post-Accident Primary Coolant Sampling The auditors noted that section II.B.3.1-2 (page 3-67) of NUREG-0737 specified that licensees should be able to sample and analyze primary coolant water within three hours from the time a decision is made to take a sample, while keeping personnel doses ALARA, and without incurring a radiation exposure to any individual exceeding 5-rem whole body or 75 rem extremities.
This guidance superseded ur clarified that contained in NUREG-0578.
The auditors reviewed plant procedures and held discussions with the radiochemist, supervisor chemistry and health physics, and other licensee personnel to evaluate conformance to NUREG-0737 guidance.
The auditors reviewed PC-23.1 " Emergency Sampling of Primary Coolant, which included a checklist of materials and equipment needed to perform the task, and a sketch of the liquid sample degassing set up.
The auditors noted that precautions and instructions for task performance were satisfactory for routine low level coolant samples but not when concentrations approach accident source terms (10
.
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C1/g).
Under such conditions the 14.5 ml sample collection bomb would contain approximately 150 curies of activity and would constitute an 85 R/hr (1.4 R/ min) source.
The auditors noted that improvements were needed as follows:
clarify use of and range for high range dosimetry (e.g. 0-10 R pocket dosimeters for whole body and 0-100 R pocket dosimeters taped to hands or wrist); Include high range instrumentation (e.g. ion chambers) and high range dosimeters to equipment checklist; modify 6.2.1 to assure that dose rate criteria reflects the capability of installed instrumentation (i.e., the 20
'
R/hr criteria specified in the procedure exceeded the R-9 nuclear
'
sample room area monitor maximum reading of 10 R/hr) and include coolant activity concentrations (and corresponding area and sample dose rates) as guides for planning.
"
Based on the above findings, improvements in the following area are needed to achieve an acceptable program:
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Revise procedure PC-23.1 to include radiological precautions for collecting coolant samples up to 10 Ci/g.
(50-244/81-22-47)
5.4.2.5 Post-Accident P-imary Coolant Sample Analysis The auditors reviewed post-accident primary coolant sampling and analysis procedure PC-23.1, and noted that Sections 6.6, 6.7, 6.8, and 6.12 addressed dissolved gas analysis, radiogas determination, liquid sample analysis and chlorida analysis.
Cross reference was made to other procedures for equipment operation and calculation sheets. The auditors concluded that procedural steps for analysis were correct, but that improvements were needed.
For example, personnel dosimetry was inadequate (See Section 5.4.2.4); draining of the 14.5 ml depressurized primary coolant sample was into an open beaker rather than into a closed one; liquid sample disposition was not addressed.
Storage of 150 curies of activity would preclude further use of the lab, particularly if the open beaker were spilled or the gas collection bottle broken.
Based on the above findings, improvements in the following area is needed to achieve an acceptable program:
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Revise procedure PC-23.1 to include prerequisites, and radiological precautions, for analysis, and disposition of high activity (10 C1/g) primary coolant samples.
(50-244/81-22-48)
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5.4.2.6 Post-Accident Containment Air Sampling The auditors reviewed PC-23.2 " Containment Atmosphere Sampling and Analysis During Containment Isolation, which included a checklist of needed equipment and a list of precautions. While the procedure
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i addressed the need for proper dosimetry (whole body and extremities),
a dosimeter range was not provided.
In addition, the procedure failed to include additional dose rates due to airborne concentrations.
Step 6.1.1 called for obtaining a containment gas radiation monitor (R-12) reading from the control room but the interpretation was not correlated to a gas concentration.
Although, three alternative
<
locations for sampling were identified, no selection criteria was given. As noted before (section 4.1.1.6) equipment was set up only i
J in one of the three locations mentioned in the procedure.
Additionally, the procedure failed to address flow rate measurements or adjustments and did not give instructions for recording data.
Remote handling of samples was mentioned as a means to reduce dose.
'
Based on the above findings, improvements are required to achieve an acceptable program:
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Provide means for ubtaining gas concentration readings from R-12; criteria for selecting containment air sampling location; and incorporate data sheets in the procedure.
(50-244/81-22-49)
5.4.2.7 Post-Accident Containment Air Sample Analysis The auditors reviewed provisions for containment air sample analysis according to PC-23.2, which addressed gas particulate and radioiodine analysis The auditors noted that the procedure lacked instructions for instrument use but that allowable maximum dead time was stated.
References to data sheets and methods from other procedures were found lacking precautions for large concentrations of radioactivity and high radiation associated with samples containing 100 pCi/cc of iodine and particulates.
Sanpling for 5 minutes at I cfm would result in the collection of 2.8 curies of radiciodine.
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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Review the sample analysis areas of PC-23.2 to upgrade radiation protection guidance consistent with activity levels and source terms specified in NUREG-0737.
(50-244/81-22-50)
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5.4.2.8 Plant Vent Effluent Sampling Procedure The auditors reviewed PC-23.3, " Estimation of Noble Gas Release Rate from the Plant Vent During Accident Conditions," used to perform post-accident plant vent sampling and noted that in this procedure dose rates were measured using a dedicated portable survey meter and a remote ion chamber probe positioned in a shielded cave adjacent to the plant vent duct. Dose rates were converted to vent gas activity concentration using graphs available for six different post-accident times.
Conversion factors were based on calculations for mixed noble gas and halogen atmospheres from a volumetric gamma source.
Section 6.2 of this procedure dealt with supplementing the high range plant vent monitor by vent sampling.
The procedure step for post-accident vent sampling consisted of one statement, ".. sample the vent." No explanations of special sampling equipment, location, technique, or radiation protection provisions to observe during sampling were given, and no reference to any other procedure was provided. The auditors noted that the procedure addressed sampling for noble gases but had no instructions for sampling of iodines and particulates in order to obtain the extent of each contributing isotope. Discussions with licensee personnel showed that routine vent sampling equipment and procedure, RD-3, " Plant Vent Iodine and Particulate Releases Sampling and Analysis," would be used.
The auditors reviewed radiological precautions in RD-3 and found that because of the continued operation of routine sampling during high activity releases (100 pCi/cc iodine) a buildup of-t least 60 curies could be accumulated in the sampling media. Under such conditions routinely used sampling equipment would not be useful.
f A second method identified for vent sampling was the use of a hand held probe inserted through a hole in the vent duct.
The auditors noted that radiation protection precautions, sampling equipment, and flow rate for isokinetic sampling were not addressed in the procedure and that high radioactivity concentrations in the plant vent would require contamination control, respiratory protection, and high range extremity dosimetry.
The auditors noted that procedures prov:ded failed to address the resconsible element that would determine the need for sampling or the criteria for initiating and repeating sampling.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
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Review post-accident plant vent sampling procedures to incorporate means for collecting and handling samples having large concentrations of radioactivity during accident
.
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conditions using the source terms defined in NUREG-0737.
(50-244/81-22-51)
5.4.2.9 Plant Vent Effluent Sample Analysis The auditors reviewed PC-23.3, and noted that specific instructions or precautions for laboratory analysis of effluent samples were not addressed.
During discussions with the auditors the licensee indicated that other procedures, such as HP 11.2 " Iodine in Air-Charcoal Silver Zeolite Cartridge Method;" RD-3, " Plant Vent Iodine and Particulate Releases Sampling and Analysis," and HP-11.11, " Gas Sampling and Analysis Utilizing a 35 cc Glass Bulb" would be used for analysis.
The auditors review showed that such procedures were adequate for samples having low levels of radioactivity but not for high level effluent samples.
Precautions given in HP-11.2 and RD-3 were relevant to sample transport'only.
The auditors noted that with a 1 cfm flow using source terms in NUREG 0737, the activity collected on particulate and iodine collection devices could exceed 60 curies, which would render che aforementioned procedures inadequate.
The licensee failed to identify methods and techniques that would be used for maintaining personnel doses below 5 rem to the whole body and 75 rems to their extremities and the maximum activity and radiation levels that would result from the analysis of post-accident particulate and gaseous effluent samples.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
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Revise plant-vent effluent sample analysis procedures to incorporate radiological protection methods and counting techniques for the analysis of highly radioactive effluent samples, using the source terms of NUREG-0737 (50-244/81-22-52)
5.4.2.10 Sampling Post-Accident Liquid Wastes The auditors found that the licensee had not considered post-accident liquid wastes that could result from some accidents (See Section 4.1.1.8) and therefore would only depend on routine procedures for sampling radioactive liquid wastes.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
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Develop a procedure for sampling highly radioactive post-accident liquid wastes that may be generatcd from certain accident scenarios.
(50-244/81-22-53)
,
5.4.2.11 Analysis of Post-Accident Liquid Wastes The auditors found that the licensee had not considered means for analyzing highly radioactive liquid wastes that could be generatad during some accidents (See Section 4.1.18 and 5.4.2.10).
As a consequence means for analyzing the same had not been considered.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
-
Develop a procedure for analyzing highly radioactive post-accident liquid wastes.
(50-244/81-22-54)
5.4.2.12 Radiological and Environ;aental Monitoring Program (REMP)
This portion of the licensee's program was not reviewed by the auditors during the present appraisal and will be subject to a future inspection.
5.4.3 Protective Actions 5.4.3.1 Radiation Protection During Emergencies The auditors reviewed emergency procedures and found that a procedure governing radiation protection during emergencies was lacking.
Individual precedures failed to specify exposure limits for individuals, applicable criteria to differentiate limits to be used during emergency conditions, and ALARA considerations.
The auditors noted a need for instructions governing the issuance of dosimetric devices, frequency of reading, and record keeping.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
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Write a procedure which governs the implementation of a radiation protection program to serve as a reference and provide guidance and technique for other emergency procedures.
This procedure shall include:
personnel dosimetry, exposure records, instructions to emergency workers, special controls to prevent re-exposure of individuals, respiratory protection, and general radiation protection techniques including ALARA considerations.
(50-244/81-22-55)
5.4.3.2 Evacuation of Owner Controlled Areas The auditors reviewed SC-1.5 " Evacuation Procedure" and found that it provided guidelines for evacuation during local and site radiation emergencies.
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e The procedure included instructions for sounding the containment evacuation alarm, as well as announcements made over the plant P.A.
system.
.
The auditors noted that locations of assembly areas were consistent with thosa delineated in the Emergency Plan.
SC-1.5 indicated that HP personnel would establish control points for decontamination, and instruct essential personnel to r.eport to certain areas while the -
remaining would await further instructions from their supervisor.
Based on the above findings,'this~ portion of the licensee's program
,
appeared to be acceptable.
5.4.3.3 Personnel Accountability
'
The auditors reviewed SC-1.13, " Accountability of Personnel;" GS-10.0,
" Security Personnel Av. ions During a Radiation Emergency" and,GS-17.0,
" Accountability of Personnel During Emergency Conditions" and found that actions to init41te accountability were specified. A computer system, used to aid in personn'el accountability was also located in
~
the security guard house. There were 771 active Photo I.D. key cards under computer control.
The auditors requested a demonstration of procedures for verifying personnel accountability using the
,
computer listings and noted that retrietal of names of 60 individ;als
- .-
was completed within five minutes. After the computer run, security
'
personnel would verify names using the' Employee Onsite List for all s
,
personnel within the protected area.
The status o h*
accounted for would be determined by checking with,f, personnel not the CR, TSC and
>
'
ESC.
t
,
Based on the above finc.ings, this portion of the licensee's program appears to be acceptab e.
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5.4.3.4 Personnel Monitoring and Decontamination
\\
The auditors reviewed SC-1.5 " Evacuation Pr'opedure," Sk l.38 " Site Radiation Emergency," and HP-6.3 Personnel Decontamination, and
,
noted that instructions for monitoring and deccntamination of personnel referred to routine techniquas ard did not address large numbers of i
individuals assembling in the assembly /reassedly areas.
The routine decontamination procedure H.P.-6.3 included means to record personnel contamination data including linits for decontamination, type of
'
equipment and decontamination supplies,' cecontamination regard and follow-up, and provided guidance for dahntamination of injcred
-
personnel.
Instructions were lacging for radiciodine decontamination,
-
and follow-up bicassays to confirmiinternal contamination.
Based on the above findings, improvemen"ts in the fo31owing are n are required to achieve an acceptable program:
ll
s; t
t g
y
,
s
_
,
k (
+
$
g
...
,e.
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Prepare a procedure governing monitoring and decontamination of persons and vehicles at assembly and reassembly, areas, addressing specific conditions which may occur during accident situations (e.g. large groups of individuals, radiciodine decontamination, followup / bioassays, etc.).
(50-244/81-22-36) -
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5.4.3.5 On Site First-Aid / Rescue
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TheauditorsreviewedSC-1.148"SearchandRescueOperNIion",SC-1.11A
"Immediate Re-Entry", and H.P.-6.3 " Personnel Decontamination" for search, rescue and treatment of injured persons who may be contaminated, and interfacing with offsite medical treatment grocos. The auditors noted that the procedures failed to define responsibilities and to specify when, where and how individuals would perform search, recovery, handling and transportation of injured persons who may be contaminated.
Instructions to the user did not provide, in some cases, the information
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needed to implement certain actions.
For example, Procedure SC-1.11A, section 3.2 stated " Contact shall be made with control room and information affecting immediate re-entry shall be given to the immediate re-entry tea:n" but failed to specify who will do this, what information will,be given and for what.urpose.
The radiation protection guidance made general reference ~i instrumentation but
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failed to identify specific radiation instr : aents.
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Based on the above findings,-improvements in the following areas are required to achieve an acceptable program:
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Revise existing procedure SC 1.14B to include specific ani detailed instructions for establishing the. rescue' team, communica-tions, radiation protection equipment, and interface witn
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offsite medical treatment facilities.
(50-244/81-22-57)
5.4.4 Security During Emergencies The auditors reviewed Security Proced;res and found that action steps in the procedures gave adequate instructions for establishing and implementing security measures during emergencies.
Based on the above findings, this portion of the licensee's program
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appears to be acceptable.
5.4.5 Repair and Corrective Actions The auditors reviewed SC-1.11A, "Immediate Re-Entry," and noted that it was brief, and omitted a number of important elements.
For example, it failed to specify the need for team members to wear protective clothing and respiratory equipment (e.g. SCBAs).
Radiological precautions and exposure limits were not considered, nor was the need to maintain communication with the CR or TSC.
The auditors
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noted that instructions for team members returning from their duties inplant were lacking. Other omissions were noted (See Section 5.4.2.3).
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
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Revise repair and corrective action procedures to include communications and radiological guidance.
(50-244/81-22-58)
5.4.6 Recovery s
The auditors reviewed SC-1.11, " Post-Acciderst Re-Entry and Recovery
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Plan," and concluded that it was acceptable, as a general plan, but it needs to be supplemented by detailed' procedures.
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Based on the~above findings improvements in the following areas are
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Develop detailed procedures to supplement SC-1.11 to support recovery operations.
(50-244/81-22-59)
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5.4.7 Public Information
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The auditors reviewed the Emergency Information Plan (EIP), and noted that it specified duties and responsibilities of the Manager of Public Relations (MPR), who would act as the Corporate Technical Spokesperson. reporting to the Recovery Manager and who serves as the sole source of. news releases and plant status within the Joint Emergency Information Support Center (JEISC). The EIP specified emergency notifications chain which is his responsibility during an alarm condition. The activation of the JEISC is the responsibility of the MPR. The auditors' review disclosed that specific individuals were assigned as primary and alternate officials for the key functions in the JEISC and that personnel were also specifically assigned to positions within.the JEISC.
These persons would respond upon activation
of the JEISC.
Emergency notification contacts would be made to state, local,'and federal authorities, TV stations, radio stations, UPI,~and major' newspapers. The plan included provisions for dissemena-tion of information, rumor control and response to public inquiries.
Approximately ten training sessions were conducted during August to Nov' ember, 1981 on the functions of the Emergency Information Plan
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and included a tour of the JEISC.
The auditor reviewed records of-training attendance, the schedule of continuing training, licensee's letters to news madia, state and_ local authorities, inviting them to
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attend the next emergency exercise.
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The public information personnel would be stationed at the JISC during emergency conditions.
Information of ficers will not be stationed onsite.
To compensate for this, escorts for news media personnel would be provided to an observation point near the site.
Based on the above findings, this portion of the lices.see's program appears to be acceptable.
5.5 Supplementary Procedures 5.5.1 Inventory, Operation Check, and Calibration of Emergency Equipment, Facilities and Supplies The auditors reviewed SC-1.15, " Inspection of Emergency Equipment,"
and noted that inventory lists, failed to specify the type, model, and range of instruments used to detect radiation.
In addition, direct reading dosimeter listings did not specify their numbers and range.
The number, and types of filter media (e.g. silver zeolite cartridges) were not specified in equipment inventories.
Based on the above findings, improvements in this area are required to achieve an acceptable program:
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Review procedure SC-1.15 to specify the type, model and range of radiation instruments, and the nun,ber and types of filter media expected to be used during emergencies.
(50-244/81-22-60)
5.5.2 Drills and Exercises Section 7.1.5 of the Radiation Emergency Plan required drills for medical emergency, emergency plan, and fire.
Procedure A-102 " Emergency Plan Training Progra ", specified annual drills for the emergency plan and medical emergencies, and quarterly fire emergency drills.
The auditor interviewed the Training Coordinator and his assistant,
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and reviewed documentation for an unannounced emergency plan drill conducted in February 1981, including: the scenario, tag assignments, notifications records, comments by drill observers, drill critique, and licensee's follow up actions. A medical drill was prepared by a contractor and included hospital, ambulance and rescue support
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groups.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.5.3 Review, Revision and Distributian of Emergency Plan and Procedures Section 7.2 of the Radiation Emergency Plan specified that the emergency plan and procedures would be reviewed annually by the
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Plant Operations Review Committee (PORC). The distribution of the procedures was specified by A-602, " Plant Procedure Distribution".
The auditors reviewed emergency procedures and noted that PORC reviews were, in fact, made on an annual basis. A review of selected procedures showed that revised procedures had been distributed in accordance with A-602.
The responsibility for reviews was recorded on the " Procedure change notice distribution and review sheet."
The auditors examined 65 procedures in the control room and TSC, and found the following deficiencies:
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Procedure E30.1 " Partial Loss of Condenser Vacuum", Rev. 3 was in use in the control room while the TSC index listed Rev. 4 as the currently valid procedure.
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Procedure HP-4.1 " Controlled Area Entry" Rev. 5 was in use in the control room while the TSC index and filed procedure was Rev. 4.
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Health physics Procedure PC23.2, " Containment Atmosphere dampling and Analysis During Containment Isolation", Rev. 5, was in use while the TSC index indicated Rev. 5 to be the proper revision but the copy filed in the TSC was Rev. 4.
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Two copies of page 5 of the TSC index were filed in the binder.
One was dated July 27, 1981 and the other dated August 13, 1981.
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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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Develop a method to ensure that only currently authorized procedures are present in the procedure binders.
(50-244/81-22-61)
5.5.4 Audits of Emergency Preparedness Section 7.4 of the Radiation Emergency Plan indicated that emergency plan equipment, training and procedures would be audited according to the frequency required by Plant Technical Specifications. QA audits of the emergency procedure, equipment and training were accomplished prior to the annual drill, in February,1981.
The auditors interviewed one of the QA auditors and reviewed the audit of the February 18, 1981 emergency drill, post audit debriefings, the audit report, and follow up.
Twenty items were listed for improvement, and then evaluated by management.
Items warranting improvements were corrected and resulting changes incorporated into the procedure Based on the above findings, this portion of the licensee's program appears to be acceptable.
6.0 COORDINATION WITH OFFSITE GROUPS 6.1 Offsite Agencies The auditors contacted Rochester General Hospital; Ontario, N.Y. Volunteer Emergency Squad; Ontario, N.Y. Fire Company; Wayne County Emergency Operations Center; Monroe County Emergency Preparedness Office; U.S.
Coast Guard; Port of Buffalo, N.Y.; and Wayne County Sheriff's Office, and verified the extent of licensee's coordination with these offsite support agencies. The local emergency rescue squad, fire departments, and county emergency personnel participated in an exercise in February and in off-site training courses conducted in September and October.
In addition, the hospital and other local agencies participated in a drill in October which included the handling and treatment of a simulated contaminated and injured person. A fire training drill, held in November, included the Ginna Fire Brigade and the Ontario Fire Company.
A licensee's contractor conducted an emergency training program during September-October,1981, in seven different locations in the two counties located in the EPZ.
The offsite agencies contacted by the auditors had a good understanding of their responsibilities during emergencies, and interactions with other agencies.
Although letters of agreement with offsite agencies, were dated 1980, representatives contacted indicated that agreements were still in effect.
The auditors discussed procedures concerning licensee /NRC interface during emergencies, and found them adequate.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered
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Provide administrative means to ensure that letters of agreement with offsite agencies are updated on an annual basis.
(50-244/81-22-62)
6.2 General Public Section 5.7 of the Radiation Emergency Plan described the licensee's public education and information program.
The auditors interviewed the i
manager of Public Relations, who was made responsible for disseminating
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emergency information to the public, and reviewed an information brochure,
"R. E. Ginna Nuclear Power Plant Emergency Information" According to the licensee, the brochure prepared in conjunction with State and local
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authorities, contained information describing sources of radiation, method for informing the public, courses of action in case of emergency (taking cover in residences, evacuation from the emergency planning zone (EPZ), public and school shelter areas, etc.)
It also contained maps describing the EPZ's.
The brochures were mailed to all residents within the ten mile EPZ's in September, 1981.
In addition, 4,000 copies were sent to the major industrial company located withis. the EPZ's for distribution to their employees who work within the EPZ, but live outside the area.
The brochure included a form for individuals with special needs, and the addresses of the counties EOCs.
The licensee had not addressed any other means of public information (e.g. posters in public places, media announcements, notices in the Yellow Pages of the Telephone Director, etc.).
Based on the above findings, this portion of the licensee's program to be i
I acceptable, but the following matters should be considered for improvement:
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Implement means of public information other than the dissemination of brochures (e.g. posters in public places, media announcements, notices in the Yellow Pages of the Telephone Director, etc.).
(50-244/81-22-63)
6.3 News Media Section 5.7 of the Radiatien Emergency Plan specified that annual briefings and training sessions will be held to familiarize the news media with the emergency plan.
The auditor intervie,.ed the Manager of Public Relations, who was responsible for making contact with the news media, and noted that an informal meeting with news media representatives took place in May, 19S1.
During the meeting, information was given on nuclear radiation and other issues of interest to them.
The auditor reviewed letters to the news media informing them about the scheduled exercise.
The letter roquested names of newspersons planning to attend.
The licensee had held no formal meetings to familiarize the news media with specific information on the exercise.
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 annual training for news media representatives, to familiarize them with emergency plans, radiation, points of contact for release of public information, locations and equipment to be used during emergencies.
(50-244/81-22-64)
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7.0 DRILLS, EXERCISES AND WALK-THROUGHS 7.1 Drill and Exercise Program Implementation The auditors' review indicated that an emergency drill was conducted on February 18, 1981; a medical drill on October 27, 1981; fire brigade training drills were conducted quarterly, the most recent one on November 8, 1981.
The auditors reviewed records for varices drills and noted that descriptions and critiques following each drill were prepared by QA.
In addition, follow-up actions were taken on items identified needing improvement (See Section 5.5.4).
Based on the above findings, this portion of the licensee's program appears to be acceptable.
7.2 Walk-Through Observation 7.2.1 Emergency Detection, EAL Recognition, and Emergency Classification The auditors walked two Shift Supervisors (who would function as Emergency Coordinators during the initial phases of emergency response)
through EAL recognition and event classification.
Individuals were informed that the RMS Operation Monitor High Activity annunciator was alarming, the plant vent monitor was reading full scale, and additional plant parameters were such as to indicate a plant accident had occurred.
They were asked to demonstrate and talk through their response.
In addition, one Shift Health Physics Technician was walked through his role in the plant vent release accident assessment scenario. Walk-throughs corroborated deficiencies in procedures and training.
(See Sections 3 and 5)
In the first walk-through, the individual correctly classified the postulated release as a site emergency, but did not folicw SC-1.1A,
" Event Evaluation and Classification".
Instead, he usea an unapproved reference developed as a tr aining aid.
The individual indicated that this reference was clearer and was more concise and thus better for quick assessment and classification of conditions during the initial phase of an emergency.
The shift supervisor identified SC-1.3A, was the implementing instruction, and referred to Attachment II for the initial offsite dose projection.
The individual was aware of the interim plant vent monitor and knew about the existence of a procedure for calculating projected offsite doses. He indicated that such determinations were not part of the init'al projection and would be performed by the Health Physics Techniciac The second shift supervisor walked-through a similar scenario experienced great difficulties in finding procedures with relevant information and was unable to classify the emergency condition.
His initial
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response was correct (to locate AR-E-16, "RMS Operation Monitor High Activity,").
He then requested Health Physics assistance and again tried to class!fy the event.
The individual indicated frustration in his attempt to classify the event and stated his primary concern would be with controlling the plant.
In summary, this portion of the walk-through confirmed that emergency response, operating, and classification procedures were cumbersome, contained numerous extraneous items, and were not suited for a timely execution.
The shift Health Physics Technician contacted during the second walk-through indicated that his response to the shift supervisor's request for assistance would be to take a reading from a monitor and collect particulate filter and iodine cartridge. When demonstrating his actions, the technician selected the proper instrument from the storage locker and proceeded to the Intermediate Building. At the entrance to the Intnrrediate Building, he took a reading from the remote connection to the interim high range vent monitor, but interpreted the reading erroneously believing it to be the steam line vent monitor. When questioned as to what his response to a high reading would be, he indicated that a very high reading would preclude him from reaching the vent sample monitor since he would be required to pass by the steam lines.
Prompted by the auditors he traced the detector lead, and realized that he had actually read the interim high range plant vent monitor.
He then stated that he would report the vent reading, without interpretation, to the shift supervisor.
The technician seemed unaware of his responsibility to calculate vent concentration and release rate according to procedure PC-23.3, Estimation of Noble Gas Release Rate from the Plant Vent Durir.g Accident Conditions. At no time, did the technician reference or indicate cognizance of the procedure.
Regarding the vent monitor filter and cartridge, the technician indicated tnat ne would count it using a Ge(li) detector, even if the sample media read as high as 500 mR/hr.
The auditors concluded that these deficiencies reflected those found in the licensee's training program.
(See Section 3)
The findings summarized above were evaluated as part of the findings in Section 5.1, 5.2, 5.3, 5.4.2, 5.4.2.8, and 5.4.2.9 of this report.
7.2.2 Post-Accident Primary Coolant Sampling and Analysis The auditors conducted a primary coolant sampling and analysis walk-through with chemistry and radiation protection personnel to simultaneously evaluate organizational factors, equipment, facilities, procedures, and training.
The walk-through used PC-23.1 " Emergency Sampling of Primary Coolant," as a basis.
Specific simulated radiolog-ical conditions were described by the auditor Two Chemistry and Health Physics Technicians performed the walk-through, which required use of self contained breathing apparatus (SCBA), and the need for a heavy sample transport shielding cask. Minor difficulty with telephone communication to the control room was noted, due to the lack of microphones in the face masks.
Procedures for valve lineup, flushing, and sample collection were adequately followed. Actual sample collection occured in about one minute with another minute required to meet procedural requirements of sample sink wash down and valve closure.
Valves were noted to be clearly labeled and referenced by procedure text, but lacked a sample layout sketch.
Some radiation protection requiremerts were included in the procedure, and the technicians showed satisfactory awareness of radiation protection concerns while performing the procedure.
Improvements highlighted during the walk-through, were:
(1) need to specify high range and extremity dosimetry. (2) need to add a caution note en the maximum range of area radiation monitors and the need for adequate inplant surveys prior to sample collection, and (3) lack of a dose rate survey instrument in the equipment check list.
The technicians used 0-1R and 0-10R dosimeters for supplemental whole body monitoring, and finger ring TLD's for extremity monitoring.
Due to the potential of 85 R/hr (1.5R/ min) dosa rates estimated by the licensee from the 14.5 m1 sample bomb, the range of dosimetry was inadequate.
Procedure step 6.2 required obtaining the sample room ARM reading from the control room.
This value was simulated by the auditors as 10 R/hr.
The technicians were unaware that this represented a full scale reading, and consequently were surprised by a much higher reading simulated in the sample room.
Had the technicians realized this possiblility existed prior to entering the sample room to collect a sample, alternate sampling collection procedures or constraints may have been devised.
In addition, the technicians were unaware that the radiation level specified in step 6.2.1 as a decision point for additional guidance was beyond the capability of the sample room ARM. A dose rate survey instrument was not specified in the procedure equipment check list, and as a result, was not taken into the Inter-mediate Building when the technicians entered. As a result, surveys on approach, and prior to entering the sample room, were not made.
The findings summarized above were evaluated as part of the findings in Sections 5.1, 5.4.2.4, and 5.4..2.3 Offsite Radiological Surveys The auditors conducted a walk-through of an of fsite radiological sur.ey by a team of two individuals.
The scenario presented to them consisted of being called in to perform offsite monitoring.
On the whole, the auditors noted that individuals showed the basic skills necessary to perform their assigned tasks, and had a working familiarity with procedures.
Equipment and facilities were used and in accordance with procedures.
Deficiencies observed were associated with equipment and procedures (e.g. inadequate instrumentation, and lacking instructions on how to determine whether the plume was overhead or the user was immersed in it.) (See Sections 4.2.1.1 and 5.4.2.1)
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15 DEC 1931 Docket No. 50-244 Rochester Gas and Electric Corporation ATTN:
Mr. John E. Maier Vice President Electric and Steam Production 89 East Avenue Rochester, New York 14649 Gentlemen:
This letter refers to a meeting between Mr. John E. Maier, Vice President and member of his staff, and Mr. Nemen M. Terc, Appraisal Team Leader, and other members of the NRC Emergency Preparedness Implementation Appraisal Team, which was held at the R. E. Ginna Nuclear Power Plant on November 13, 1981, and to a telephone conversation between Mr. L. Lang of your staff and Messrs. G.L. Snyder and N.M. Terc of my staff on December 1, 7 and 9, 1981.
With regard to the matters discussed at the meeting we understand that you will undertake and complete the following actions:
1.
Establish an emergency organization which provides for all emergency functions needed during initial, intermediate and final phases of augmentation.
Revise the Emergency Plan to include a description of the organization, and upd' ate implementing procedures to be consistent with the organization.
The description shall include sufficient detail to define the command hierarchy; specify its structure, reporting chains and interrelationships at any phase of augmentation; and include supervisory as well as non-supervisory elements.
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Updating of implementing procedures will be accomplished no later than December 18, 1981.
Revision of the Emergency Plan will be accomplished by March 15, 1982.
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For each functional area specified within the emergency organization referred to in item 1, provide a list of personnel trained and qualified to perform the tasks associated with the area.
These lists shall identify the current status of each individual.
Provisions to maintain lists current shall be developed and implemented.
This will be accomplished no later than December 18, 1981.
3.
Realign the emergency plan training program to be consistent with the functional areas,. requirements, and structure of the emergency organi:-
ation.
This will be accomplished no later than January 15, 1982.
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Rochester Gas and Electric Corporation 2 15 DEC EB1 4.
Develop and implement means to verify that all individuals with emergency duties have been trained and have attained a minimum level of proficiency.
This shall include but not be limited to hands-on training and walk-throughs.
This will be accomplished no later than January 15, 1982.
5.
Complete the interim installation and testing of equipment in the Technical Support Center to ensure that it will be habitable and functional and able to perform its intended use during the various accident conditions.
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This will be accomplished no later than January 15, 1982.
6.
Re-evaluate provisions to rapidly and accurately detect and measure
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radiciodine concentration under field conditions in the presence of noble gases,(including equipment and procedures-needed to ascertain the location and characteristics of the plume relative to the sampling locations)
Provide a written report of the results of your evaluation to the NRC Region I Office and include a schedule for any planned actions.
This will be accomplished no later than January 15, 1982.
7.
Re-evaluate interim facilities, equipment and procedures for post-accident sampling and analysis of the contaminent atmosphere to determine maximum concentrations that could be handled and analyzed during accident conditions.
Provide a written report of the results of your evaluation to the NRC Region I Office and include a schedule for any planned actions.
This will be accomplished no later thah January 15, 1982.
8.
Undertake and complete a review of all emergency plan implementing procedures and make appropriate revisions to:
a)
Clarify required actions, and eliminate existing ambiguities, inconsistencies and errors.
b)
Clarify duties and responsibilities cf personnel involved in the various actions.
c)
Provide specific cross-references to other procedures in the action steps as needed to detail and clarify further actions.
The above revision shall be performed in accordance with a schedule as follows:
Procedures SC-1.2A, SC-1.28, SC-1.3A, SC-1.38, SC-1.3C, SC-1.3D, SC-1.3E, SC-1.4, SC-1.7B, SC-1.70, SC-1.7F, SC-1.7H, SC-1.13 to be revised no later than January 15, 1982.
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Rochester Gas and Electric Corporation 3 15 c.p; '90 Other procedures will be revised no later than March 15, 1982.
In addition to the above action, please inform this office in writing when each of the aforementioned actions have been completed.
If our understanding of your planned actions described above is not in accordance with your actual plans and actions being implemented, please contact this office by telephone (215) 337-5000, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
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Your cooperation with us on this matter is appreciated.
Sincerely,
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g w 77l. (Q Yl w onald C. Haynes, Regional Administrator l
cc w/ encl:
Lee Lang, RG&EC Harry H. Voigt, Esquire Central Records (3 copies)
Public Document Room (PDR)
local Public Document Room (LPOR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of New York
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