IR 05000245/1982001
| ML20054H733 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 06/10/1982 |
| From: | Crocker H, Kantor F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20054H728 | List: |
| References | |
| 50-245-82-01, 50-336-82-01, NUDOCS 8206240375 | |
| Download: ML20054H733 (76) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION I
Report No. 50-245/82-01; 50-336/82-01 Docket No.- 50-245; 50-336 License No. DPR 21; DPR-65 Priority Category C
Licensee: Northeast Nuclear Energy Company P.O. Box 270-Hartford, Connecticut 06101 Facility Name: Millstone Nuclear Power Station, Unit Nos. I and 2 Inspection at: Waterford, Connecticut Inspection conducted: January 4-14, 1982 Inspector: q sh h /D N d Falk'Kantor, Ajiprapar Team Leader,
~ date signed DEP, HQ: IE Edward F.-Woltner, DEPOS, RI:IE Raymond H. Smith, DEPOS, RI:IE Sharyn K. Ecklund, DEP,.HQ: IE Leo H. Munson, Battelle PNL Bruce Pickett, Battelle PNL Joseph Levine, AEB, NRR Approved by:
M/CMA H. W. CrockhTT Chief, Emergency
dat( signed Preparedness Section, DEPOS, RI
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8206240375 820611 PDR ADOCK 05000245 O
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SUMMARY The appraisal of the onsite emergency preparedness at the Millstone Nuclear Power Station involved 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 Walk-throughs of Emergency Duties The Millstone Emergency Preparedness Program was developed by individuals in the licensee's corporate office as well as by individuals at the plant site.
The results of the appraisal indicated that the existing program contained a number of deficient areas.
The emergency organization description was found to be incomplete in that it failed to properly define the initial, intermediate and final phases of augmentation and did not for the most part include nonsupervisory elements.
An emergency preparedness training program was established; however, the program was deficient in that it did not align the various training courses with all of the critical functional areas and tasks of emergency activity.
Consequently, lesson plans had not been developed and training was not being accomplished in some functional areas of emergency activity.
The auditors found the concept of operations for the Technical Support Center (TSC) and Operations Support Center (OSC) to still be in a development stage and not adequately described in either the Emergency Plan or Emergency Plan Implementing Procedures. The TSC for Unit 2 was considered to be unacceptable while the TSC for Unit 1, while acceptable on an interim basis, did not appear to be adequately staffed by procedure.
A number of deficiencies were found in the procedures which implement the Emergency Plan, in particular the procedures related to post-accident sampling and laboratory analysis of samples containing high levels of radioactivity.
Coordi_ nation with offsite agencies for emergency response support training, and drills and exercises was satisfactory.
Observations and questioning of selected individuals during walk-t.hroughs of their emergency tasks and functions in the areas of emergency detection and classification, notification, and in plant and offsite monitoring indicated that the individuals were aware of their assignments and were able to perform effectively despite some procedural shortcomings.
The auditors concluded that some of the deficiencies identified in the appraisal could result in a potential degradation of the licensee'_s emergency response.
During the exit meeting, the auditors discussed a selected group of priority items and established with the licensee a schedule for corrective actions.
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1.0 ADMINISTRATION OF EMERGENCY PREPAREDNESS 1.1 Responsibility Assigned
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The responsibilities and authority for radiological emergency response planning and preparedness at the Millstone Nuclear Power Station (MNPS) were discussed in Section 8.0 of the Emergency Plan and addressed in more detail in Nuclear Engineering and Operations Procedure NE0 2.04, and Administrative Control Procedure ACP-1.15,
" Management Program for Maintaining Emergency Preparedness". The auditors reviewed these documents and interviewed licensee management personnel to determine the assignment of responsibilities and authority for emergency planning at the Millstone Station.
The Manager, Radiological Assessment Branch of the Corporate Headquarters staff in Berlin, Connecticut, was designated as the Corporate Nuclear Emergency Coordinator (CNEC). The Radiological Assessment Branch included an Emergency Preparedness Section with a supervisor and five assigned positions. The CNEC was responsible for coordinating the development and maintenance of the Corporate and Station emergency plans and procedures and for maintaining liaison with State agencies and local communities for emergency planning, agreements and response.
At the plant site, the Station Superintendent had the overall responsibility for the readiness of Millstone personnel and equip-ment to respond in an emergency situation and was responsible for the review and approval of all emergency plan procedures. The Station Services Superin endent was responsible to the Station Superintendent for the preparation and review of the Emergency Plan and Implementing Procedures, for the readiness of emergency equipment and facilities, and for the training of_ station personnel in the Emergency Plan Implementing Procedures.
The Radiological Services Supervisor was designated as the Millstone Emergency Planning Coordinator (EPC) and was responsible to the Station Services Superintendent for coordinating the preparation of all Emergency Plan Implementing Procedures and for coordinating the maintenance of all emergency equipment and facilities. Other Department Supervisors were responsible for supporting the emergency organization and maintaining on-call lists and certain emergency procedures.
The Station Services Superintendent stated that he had been actively involved in the development of the Millstone emergency organization and was the principal author of Procedure ACP - 1.15, the administrative procedure for maintaining emergency preparedness at the site. The EPC assignment was an additional duty for the Radiological Services Supervisor who in addition to his emergency planning duties was responsible for supervising the Chemistry, Health Physics, Radiation Protection and Station Medical departments.
The Radiological Services Supervisor estimated that emergency planning duties required about one-third of his time. Management personnel indicated that they recognized that the emergency planning position required an
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individual assigned on a full-time basis.
It was anticipated that an individual in the Corporate Radiological Assessment Branch would be assigned as the Millstone EPC on a full-time basis and would spend the majority of this time onsite.
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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Formally appoint a full-time Emergency Planning Coordinator for the Millstone Nuclear Power Station. The appointment should include the development of a position description clearly specifying the duties, responsibilities, and authority of the EPC.
(245/82-01-01; 336/82-01-01)
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Revise the Emergency Plan to fully reflect the assignment of responsibilities for maintaining emergency preparedness of
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Corporate and Station personnel including the Emergency Planning
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Coordinator.
(245/82-01-02; 336/82-01-02)
1.2 Authority Assigned responsibilities in the area of emergency preparedness were supported with sufficient authority and received management support where exercising this. authority.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
1.3 Coordination The Station Services Superintendent was a member of the Site Operations Review Committee (SORC).
The Radiological Services Supervisor was an alternate member.
Issues involving emergency planning and changes or revisions to Emergency Plan Implementing' Procedures were brought before the SORC by either the Station Services Superintendent or the Radiological Services Supervisor.
The Emergency Plan was written at the Corporate level under the direction of the Corporate Nuclear Emergency Coordinator. The Emergency Plan Implementing Procedures were developed primarily by the Station staff.
However, either organization could initiate changes or revisions to the Emergency Plan or Implementing Procedures.
The Station Emergency Planning Coordinator was assigned the responsi-bility in Procedure ACP - 1,15 for maintaining liaison with the Corporate staff on matters related to emergency planning.
Discussions with Corporate and Station emergency planning personnel indicated that there was satisfactory coordination between the organizations.
The Corporate Nuclear Emergency Coordinator was responsible for developing and maintaining contact with State and local governmental
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authorities, the news media, and the general public. The Station organization was responsible for providing training to local support organizations; however, this responsibility was not clearly specified.
Contact by the auditors with representatives of State and local response organizations indicated that there was adequate coordination in emergency planning activities between the licensee and offsite support agencies.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
1.4 Selection and Qualification A review of Corporate position descriptions indicated that responsibilities and duties regarding emergency preparedness were emphasized and selection criteria which reflected this were estab-lished for the Corporate personnel responsible for emergency planning.
A review of the position descriptions for key Station managers with emergency planning responsibilities indicated that there were no specific selection criteria other than normal position qualifications for Station emergency planning personnel.
The licensee did not have a formal program for providing professional development training for personnel with emergency planning responsibilities.
Individuals in the organization have the opportunity to request approval to attend professional development courses and seminars including those pertaining to emergency planning. None of the Station personnel with emergency planning responsibilities had attended any such courses.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be considered for improvement:
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Develop specific selection and qualification criteria for the Emergency Planning Coordinator and other Station personnel with emergency planning responsibilities.
(245/82-01-03; 336/82-01-03)
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Establish a professional development program for individuals who are assigned emergency planning responsibilities which will enable them to attain and maintain state-of-the-art knowledge in the field of emergency preparedness.
(245/82-01-04; 336/82-01-04)
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2.0 EMERGENCY ORGANIZATION 2.1 Onsite Organization The licensee's emergency organization was described in Section 5.2 of the MNPS Emergency Plan (Revision 7 dated July 15, 1981) and in Administrative Control Procedure ACP-1.15, " Management Program for Maintaining Emergency Preparedness," dated September 29, 1981. The auditors reviewed these documents and held dicussions with licensee personnel to evaluate the licensee's emergency organization.
The emergency organization progresses with time through three basic phases:
initial, intermediate and final augmentation. The initial phase of the emergency organization consists basically of the minimum shift crew operating the plant. The intermediate augmen-tation phase consists of the fully developed onsite emergency organization forming within a reasonable time frame (60 minutes).
The final phase of augmentation includes the first two and additional corporate and other offsite support agencies.
The final augmentation phase is discussed in Section 2.2 of this report.
The licensee's description of the initial phase of emergency response, with the exception of the Shift Supervisor's responsibility, was little more than a listing of emergency titles. The licensee did not adequately describe the organizational structure, the inter-relationships between the various elements of the organization, and the various functional areas of emergency activity to be performed by each element of the organization during the initial response to an emergency. The need for doing this is particularly important for responding to emergencies during off-shifts.
Several discrep-ancies and inconsistencies were also noted between the information concerning the initial emergency organization presented in Procedure ACP-1.15 with that contained in the Emergency Plan.
For example, the affected unit Shift Technical Advisor (STA) is designated in Procedure ACP-1.15 as the Manager of Technical Support until relieved by the Duty Officer and the nonaffected unit STA is designated as the Manager of External Communications until the on-call manager arrives at the Emergency Operations Facility.
Neither of these interim STA duties are described in the Emergency Plan.
In addition, the emergency role of the Shift Supervisor's Staff Assistant is not addressed in ACP-1.15.
The licensee's description of the intermediate phase of the emergency organization consisted primarily of a descripton of the managerial positions in the organization and did not extend down to lower supervisory and nonsupervisory levels.
Further, the specific emergency functions and tasks to be performed within each element of the organization were not well defined. As a result, several functional areas of emergency activity, such as decontamination, post-accident sampling and analysis, and search and rescue, were not described in the emergency organization. The responsibility
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for supervising these functions during an emergency was consequently not clear.
Lists of personnel assigned to certain functional areas of emergency
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response were maintained on several different station forms but not all required emergency functions were covered.
fne auditors found no means by which the Director of Station Emergency Operations and other key personnel could correlate the various functional areas of respon:.e and the tasks required to be performed during emergencies with individuals trained and qualified to perform these tasks.
The minimum number of personnel on-shift as shown in Table 5-1 of the Emergency Plan was 8 at the time of the appraisal with 2 others, a Plant Equipment Operator (equivalent to an Auxiliary Operator)
and a Chemistry Technician, scheduled to be on-shift by July 1, 1982. The total shift staff of 10 will meet the minimum shift staffing requirements of Table B-1 of NUREG-0654.
However, the licensee did not provide for any augmentation capability within 30 minutes. A total of 21 personnel were shown in the Emergency Plan as augmenting the shift staff within 60 minutes.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
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Revise the emergency organization to provide for all emergency functions needed during initial, intermediate and final phases of augmentation.
Revise the Emergency Plan to include a description of the emergency organization and update admini-strative and implementing procedures to be consistent with the revised 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 nonsupervisory elements.
(245/82-01-05; 336/82-01-05)
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Develop lists of personnel trained and qualified to perform the tasks associated with each functional area specified within the revised emergency organization.
These lists shall identify the current training status of each individual, and provisions to maintain the lists current shall be developed and implemented.
(245/82-01-06; 336/82-01-06)
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Pursuant to the requirements of the generic letter dated February 18, 1981 to all licensees from Mr. D. Eisenhut, NRR, regarding the minimum staffing requirements for nuclear power plant emergencies, perform a study to determine how the augmentation of the on-shift staff can be achieved within the
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30 and 60-minute goals of NUREG-0654, Table B-1, after the declaration of an emergency.
The results of this study will be documented and forwarded to the NRC Region I office for review and evaluation along with a description of compensatory
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mea;ures for any augmentation goals not met.
(245/82-01-07; 336/82-01-07)
2.2 Augmentation Organization The auditors reviewed the information on the corporate support organization in Section 5.3 of the Emergency Plan and in the Corporate Organization for Nuclear Incidents (CONI) Procedure Manual, Revision 2, dated October 1981.
The major functional areas of emergency activity in the Corporate organization were:
Emergency Direction and Control; Technical Support; Radiological Accident Assessment; Resources - Manpower and Logistics; and Public Information.
An on-call roster was maintained for each of the Corporate functional areas of emergency activity in which individuals in the organization were specified by name.
Key senior management and corporate emer-gency managers were notified of a nuclear incident or emergency situation through a radiopager call initiated by the plant staff upon activation of the emergency organization. Members of the Corporate on-call emergency organization were expected to report to the Emergency Operations Center at the Corporate offices in Berlin, Connecticut within 90 minutes. The Emergency Plan called for Corporate representatives to be dispatched to the State of Connecticut Emergency Operations Center and the Media Center.
It was noted that the CONI Procedure Manual was keyed throughout to the State of Connecticut emergency classification scheme rather than the NRC emergency classification scheme given in NUREG-0654, Appendix 1.
The use of the State emergency classification scheme is discussed further in Section 5.3 of this report.
The Emergency. Plan identified the local fire fighting, ambulance, and hospital organizations which were relied upon to support the onsite emergency organization.
Letters of agreement were included in the Emergency Plan which delineated the response support to be provided by each organization.
Letters of agreement also existed for support to be provided in an emergency by General Dynamics Corporation and UNC Naval Products, two private corporations which maintain radiological facilities in the State.
The Emergency Plan contained no information on the expected State role in an emergency situation and did not discuss the licensee -
State interactions in responding to an emergency with offsite consequences.
The lead State agencies or offices responsible for radiological emergency response were not identified in the Emergency Plan nor were the interfaces between the licensee's emergency organization and the State and other offsite response groups illustrated in an organization chart.
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Based on the above findings, this portion of.the licensee's program appears to be acceptable, but the following matters'should be considered for improvement:
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Describe in the Emergency Plan the State role in an emergency situation identifying the lead State agencies. -The interfaces between the onsite and Corporate emergency organizations and the-State of Connecticut and other offsite emergency response agencies should be included in the revised emergency organization description.
(245/82-01-08; 336/82-01-08)
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3.0 EMERGENCY PLAN TRAINING / RETRAINING 3.1 Program Establishment The licensee's program for training personnel assigned emergency response duties was discussed in Section 8.1 of the Emergency Plan.
Information on the functional areas of emergency activity which should be included in the Emergency Plan training program was contained in Section 5.2 of the Emergency Plan and in Administrative Control Procedure (ACP) 1.15, " Management Program for Maintaining Emergency Preparedness," dated July 15, 1981.
Procedure ACP 8.06, Revision 7, " Emergency Plan Training," dated July 15, 1981, established the various responsibilities for the training of the emergency organization.
Emergency Plan training was found by the auditors to be fragmented among various departments with the supervisors of each department including the Station Superintendent responsible for training other supervisory personnel who are on call to perform the same emergency function. The Training Department only provided training for Emergency Monitoring Team members and Managers of External Communications. The training responsibilities were as follows:
Station Superintendent - Conducts semi-annual training for Directors of the Station Emergency Organization.
Operation Supervisors - Conducts semi-annual training for Managers l
of Control Room Operations.
Radiological Services Supervisor - Conducts semi-annual training for Managers of Radiological Consequences Assessment.
Engineering Supervisors - Conducts semi-annual training for Managers of the Technical Support Center.
Nuclear Records Supervisor - Conducts semi-annual training for Managers of Resources.
Security Supervisor - Conducts semi-annual training for Managers of Security.
Quality Assurance Supervisor - Conducts semi-annual training for Managers of Engineering Support.
Training Supervisor - Conducts semi-annual training for Managers of External Communications and also Emergency Monitoring Team members.
Senior Nuclear Information Supervisor - Conducts semi-annual training for Managers of Public Information.
Training records were maintained by the Training Department.
Documentation of emergency training consisted of an entry in the
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I individual's training folder which contained a program code keyed to a training class form, test grade where applicable, and the date of training. Determining the type and extent of emergency training an individual had taken was a tedious, time consuming process with some confusion over the meaning of the training program codes.
Record keeping was also complicaced because the training was performed by many departments other than the Training Department. A computer program was being developed to facilitate the retrieval of training record information. There were no provisions in the emergency plan training program for training members of the emergency organization in changes to procedures or equipment which occurred between scheduled training sessions.
General employee training in emergency plan procedures was described in Procedure ACP-8.01, " Millstone Station Training." First-aid training was provided to Security Shift Supervisors and other shift personnel.
The auditors examined the available lesson plans for the emergency plan training courses listed above. The lesson plans indicated the training objective and referenced applicable Administrative Control Procedures, Operating Procedures, and Emergency Plan Implementing Procedures. The training consisted of a review of the procedures, familiarization with the equipment, and a tour of the emergency response facilities. A written test was administered at the end of the instruction period. The instruction periods ranged from 45 minutes to 2 1/2 hours with the exception of the training for Emergency Monitoring Team members which ranged from 4 to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
Lesson plans were not developed for many of the functional areas of emergency activity such as emergency classification, protective action decision making, radiation protection during emergencies, decontamination, repair / corrective actions, search and rescue, radwaste operations, post-accident sampling and analysis of high-level samples.
There was also no training provided to members of the emergency organization other than the fire brigade in the use of self-contained breathing apparatus.
Procedure ACP-8.06 indicated that training for offsite support agencies was provided by Corporate personnel. Section 8.1.2 of the Emergency Plan indicated that the training for participating offsite agencies was conducted by both Corporate and Station personnel. A review of the training records and discussions with licensee personnel established that training for offsite response agencies was being conducted by Corporate and Station personnel but that the training effort was not well coordinated. No single document existed which spelled out the training responsibilities for each organization, the objectives of the training program, or the subject content of
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the offsite training courses.
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Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
Establish an integrated emergency plan training / retraining
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program to ensure that lesson plans are developed and training is accomplished for each functional area of emergency activit.y including radiation protection during emergencies, emergency repair / corrective actions, search and rescue, and radwaste operations.
(245/82-01-09; 336/82-01-09)
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Develop a procedural method to ensure that members of the emergency organization are trained in any pertinent changes to emergency procedures, facilities or equipment which occur between scheduled training sessions.
(245/82-01-10; 336/82-01-10)
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Develop a systematic method for documenting and maintaining records of emergency training and retraining. (245/82-01-11; 336/82-01-11)
In addition, the following matters should be considered for improvement:
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Align the training categories of the emergency plan training /
retraining program with the functional areas of emergency activity in the revised emergency organization and develop a procedure to implement the program.
(245/82-01-12; 336/82-01-12)
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Develop a training document which describes the program for training offsite support agencies and specifies the responsi-bilities for the different training courses, training. objectives, subject content of the courses, and means for documenting.the'
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(245/82-01-13; 336/82-01-13)
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3.2 Program Implementation The auditors reviewed training records and documents and interviewed members of the emergency response organization to assess the implementation of the emergency plan training program.
The training records were maintained-in the Training Department; however, only a part of the' emergency plan training program was.
conducted by the Training Department. Training records were forwarded
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The review of'the training records indicated that not all records were being forwarded in a timely manner.
There did not appear to be any administrative means by which the Training Department could ensure that all necessary emergency plan training was performed and documented.
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Procedure ACP 8.06 specified that emergency training was to be conducted on a semi-annual frequency. A memorandum from the Station Superintendent dated December 15, 1981, stated that the required semi-annual training for the current period was to be completed by January 29, 1982. At the. time of the appraisal (January 4-14, 1982), the training records indicated that the semi-annual training for the following emergency groups had not yet been completed:
Managers of Resources; Managers of Engineering Support; Managers of Security; Managers of Control Room Operations; Managers of Technical Support; and Managers of Public Information.
Interviews with members of the emergency organization confirmed that, in general, individuals were aware of their emergency role, knew where and who to report to, what their function would be, and who they would interact with. However, as discussed in Section 3.1 of this report, not all functional areas of emergency activity were covered in the licensee's emergency plan training program. Also, the interviews tended to indicate some uncertainty among supervisory members of the emergency organization in the use of protective action guides, protective action decision making, and. interaction with offsite authorities in the decision m'
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The training records documented that the licensee had provided response training to local offsite fire and ambulance groups. A tour of MNPS had been conducted on October 25, 1981, to familiarize representatives of local fire and rescue departments with the site and possible hazards that could be encountered in responding to an=
emergency onsite. A contractor retained by the licensee had provided emergency training for personnel of Lawrence and Memorial Hospitals, the local support hospitals.
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 means to ensure that all personnel assigned emergency response duties receive the required training in the emergency plan' training program.
(245/82-01-14; 336/82-01-14)
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Develop a training program for emergency managers which emphasizes the-protective action decision making process, protective action strategies, and the use of protective action guides.
(245/82-01-15; 336/82-01-15)
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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 Control Rooms for Units 1 and 2 which are located adjacent to each other separated by a sliding glass door.
The control rooms were found to have adequate space, shielding and air filtration capability to ensure their habitability under various accident conditions.
In addition, the auditors noted that instru-ments to detect and measure radiation levels and airborne contamination were available.
The control rooms contained the protective equipment, monitoring equipment, communications equipment and other emergency equipment specified in the Emergency Plan. There were no decisional aids referred to in the Emergency Plan for dose assessment.or plume projection, nor were any in evidence in either of the control rooms.
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There were no monitor readouts common to both Unit I and Unit 2 control rooms other than dual annunciators for the seismic instru-mentation. Meteorological data was available only in the Unit I control room. There was no readout in the Unit 2 control room for the Unit 1 stack monitors although the Unit 2 gaseous effluent is discharged via the Unit 1 stack in the event high activity levels are detected.
Copies of the Emergency Plan Implementing Procedures were available in the Unit 1 Shift Supervisor's office, which opens onto the Unit I control room, and in the Unit 2 control room. The Emergency Plan was available in the Unit 1 Shift Supervisor's office, but a
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copy of the Emergency Plan was not available in the Unit 2 control room.
Communication was provided between the Unit 1 and Unit 2 control rooms in the form of an intercom and the site telephone system.
Since the two control rooms were in close proximity, direct face-to-face communication was also possible.
The general. appearance and housekeeping of the Unit I control room was excellent. The Unit 2 control' room, despite being in the midst of an outage, was also satisfactory.
Based on the above findings, this portion of the licensee's program i
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4.1.1.2 Technical Support Center The licensee identified two distinct areas as the Technical Support Centers (TSC) for Units 1 and 2, respectively.
It was estimated that the walk up io the control room would be accomplished in about two minutes.
The TSC for Unit 1 was located in the computer room on the ground floor, two floors below the Unit 1 Control Room. The TSC for Unit 2 was located in the computer room entered through a doorway from the Unit 2 Control Room. Both TSCs were within the same habitability envelope as the control room.
There were radiation monitors in place and also a PING continuous air monitor in' the Unit 2 TSC.
The Unit 1 TSC proper was located in one end of the Unit 1 computer room.
It was estimated that there was space for a maximum of 8 to 10 persons in the TSC assuming that additional working space in the computer section of the room would be made available in an emergency.
The Unit 2 TSC had only standing room available since the room was almost completely occupied by computer equipment.
Communications in the TSCs included a TV monitor for a TV camera located in the control rooms, dedicated telephones, direct hot lines to the control rooms and a dial intercom between the control rooms, the two TSCs, and the Emergency Operations Facility.
In addition, there were regular commercial telephones and a public address intercom system in the TSCs.
The Unit 2 TSC contained copies of plant drawings, a microfiche reader, reference materials, plant technical specifications, plant operating procedures, and a copy of the Emergency Plan and Imple-menting Procedures. Drawings and reference materials for the Unit 2 TSC were to be obtained from the Unit 2 control room.
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In the licensee's concept of operations, only one person, the Duty Officer who becomes the Manager of Technical Support, reports to the TSC.
Then, depending on the nature of the emergency, the Manager calls in one or two additional persons for assistance as the emergency progresses. Primary reliance.for technical support during an emergency is placed on the technical staff in the Emergency Operations Center at Corporate headquarters in Berlin, Connecticut.
The Managers of Engineering Support and Resources in the Emergency
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Operations Facility were also considered to be available for backup
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support to the TSC.
The majority of NRC personnel reporting to the
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site in an emergency were expected to function in the EOF.
The licensee's concept of TSC operation was not discussed in the Emergency Plan nor in any other document. There was no procedure for activating and staffing the TSC other than to say that the TSC would be activated at an Alert or higher emergency classification.
Licensee personnel stated during interviews that the licensee was
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considering combining both TSCs into the Unit 1 TSC.
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Based on the above findings, improvements in the following areas
are required to achieve an acceptable program:
Establish a Technical Support Center (TSC) which provides on
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an interim basis, until a permanent TSC can be established which meets applicable regulatory criteria, adequate working space for assigned personnel and which alleviates potential crowding in the control room.
(245/82-01-16)
Describe in the Emergency Plan the division of technical
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support functions between the TSC, the Emergency Operations Facility, and the Corporate Emergency Operations Center for Units 1 and 2, and indicate the functional areas of emergency activity to be performed at each technical support function location.
(245/82-01-17; 336/82-01-17)
Develop an implementing procedure for activating and staffing
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the TSC and establishing the responsibilities and functional areas of emergency activity to be performed in the TSC.
(245/82-01-18; 336/82-01-18)
4.1.1.3 Operations Support Center i
The Operations Support Center (OSC) was stated in Section 7.1 of the Emergency Plan to be the Operations Assistants' offices next to the control rooms. The Operations Assistants' offices did not have sufficient space or adequate equipment and supplies for OSC emer-gency response personnel. According to licensee personnel onsite, the concept of operations was for on-call operators, electricians, mechanics and I&C technicians to report to the Operations Assistants'
offices for a briefing of the situation for an emergency during normal hours. All other operations support personnel report to the Condensate Polishing Facility (CPF) assembly area. During backshift hours, the response for operations support personnel within the protected area was the same; however, all other on-call and called-in personnel were to report to the EOF.
The Manager of On Site Resources was identified as the individual responsible for dispatching OSC personnel. The Manager of On Site Resources during backshifts reports to the EOF within 60 minutes.
In the interim, OSC personnel would be directed by operations personnel although this was not specified in any procedure and the individual in the control room responsible for this function was not identified.
The CPF and EOF areas had adequate space for OSC personnel to assemble. Some personal protective equipment and dosimetry supplies were available for use by OSC personnel in the CPF area and more
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was available in the E0F.
Provisions were made for an Emergency Monitoring Team to survey the CPF area.
However, it was not clear how work teams would form, be equipped, dispatched and controlled in an emergency.
There wa< minimal information on the OSC in the Emergency Plan and an implementing procedure for activating and staffing the OSC did not exist.
Based on the above findings improvements in the following areas are required to achieve an acceptable program:
Establish an Operations Support Center (OSC) with sufficient
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space for assigned emergency response personnel to assemble in the event of an emergency, and which includes communications, protective equipment and supplies needed for the performance of emergency activities that may be required of assigned personnel.
(245/82-01-19; 336/82-01-19)
Revise the Emergency Plan to describe the location of the OSC
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and the concept of operations for the OSC including how work teams will be formed, equipped, dispatched, and controlled in an emergency.
(245/82-01-20; 336/82-01-20)
Develop an implementing procedure for activating and staffing
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the OSC.
(245/82-01-21; 336/82-01-21)
4.1.1.4 Emergency Operations Facility The Emergency Operations Facility (EOF) is a hardened building located just off the site access road approximately one mile from the MNPS site.
The building was newly constructed and had approxi-mately fifteen offices, a large open central area and two decon-tamination rooms in addition to various storage rooms.
The facility would be staffed by the Director of Station Emergency Operations, licensee personnel from seven other emergency functional groups, NRC, and other Federal, State, and local officials and staffs.
The Emergency Operations Facility was equipped as stated in the Emergency Plan, Table E-4.
The equipment and supplies included emergency radiological monitoring equipment and supplies, protective clothing. respiratory protective devices and dose assessment supplies and procedures.
Communication equipment was in place in all the assigned offices and included dedicated telephone lines, base radios, NRC Emergency Notification System and Health Physics Network lines, dial intercoms and numerous telephones to cover all required onsite and offsite contacts and organizations.
The EOF was equipped with copies of the Station Emergency Plan and Implementing Procedures; other plant plans and procedures; site area maps; and necessary records and supplies. There was an emergency
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diesel generator in place for back-up power. The facility had an air lock door and a ventilation system with HEPA filters and four-inch
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deep charcoal filters capable of functioning in a recirculation
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mode if required.
Based on the above findings, this portio'n of the licensee's program appears to be acceptable.
4.1.1.5 Post-Accident Coolant Sampling and Analysis The auditors reviewed the licensee's post-accident coolant sampling and analytical facilities and the licensee's capability to obtain and analyze high activity reactor coolant samples during accident situations. The auditors inspected the sampling locations for Units 1 and 2, reviewed the sampling procedures (see Section 5.4.2.4)
and discussed post-accident coolant sampling with licensee personnel.
The auditors also inspected the new post-accident reactor coolant sampling system that was being installed.
In the sampling areas for Unit 1 and Unit 2, there was no shielding to reduce the exposure to personnel in these areas. Both of the sampling areas were monitored by area radiation monitors (ARM) that
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read out locally and in the control rooms.
Licensee representatives indicated that shielded sample containers would be availaole, but none were dedicated for emergencies.
Licensee chemistry personnel
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had no training with respect to reactor coolant sampling in an emergency. They also had not received any formal instruction in the use of self-contained breathing apparatus (see Section 3.1).
The sample analysis area was the plant chemistry laboratory.
It appeared that this area would be shielded from direct radiation during an emergency, since it was not in proximity to either con-tainment. The chemistry lab had several Ge(Li) detectors and counting systems available and a liquid scintillation detector for radiological analyses. An automated system was being installed to perform nonradiological (pH, boron and chloride) analyses of samples.
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Other equipment, such as micropipettes, syringes and other glassware were available in the chemistry lab.
The licensee's design review of the MNPS post-accident sampling systems, expressed in a letter to the NRC dated December 31, 1979
on "TMI-2 Short Term Lessons Learned Implementation," indicated
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that (1) post-accident primary coolant samples could not be obtained with the present sampling system and (2) post-accident radioactivity and chemical analyses could be completed as required with present laboratory equipment and only minor procedural changes. The licensee had committed to install new post-accident sampling systems.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
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Expedite the development of procedures and training on the
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post-accident sampling systems presently being installed to ensure that the systems are fully operational in the minimum amount of time.
Provide a status report for these activities to the NRC Region I office.
(245/82-01-22; 336/82-01-22)
Perform a radiological analysis which demonstrates that liquid
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and gaseous effluent samples can be obtained under postulated accident conditions.
(245/82-01-23; 336/82-01-23)
Develop specific detailed procedures and training for obtaining
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liquid and gaseous effluent samples under postulated accident conditions.
(245/82-01-24; 336/82-01-24)
4.1.1.6 Post-Accident Containment Air Sampling and Analysis The auditors reviewed the licensee's capability to sample and analyze high activity containment air samples during accident situations. The auditors inspected the sampling locations for Unit I and Unit 2, reviewed the sampling procedures (see Section 5.4.2.4) and discussed post-accident containment atmosphere sampling with licensee personnel.
The auditors also inspected the new post-accident containment atmosphere sampling systems that were being installed.
There was no shielding.in the sampling areas for Unit 1 and Unit 2 that would restrict the exposure to personnel in the areas.
Licensee representatives indicated that shielded sample containers would be available, but none were dedicated for emergencies.
Licensee chemistry personnel had had no training with respect to containment atmosphere sampling in an emergency.
In discussions with licensee representatives, there was some confusion as to which group, Chemistry or Health Physics, had the responsibility to perform the sampling and analysis of containment atmosphere.
This responsibility was not assigned in the procedures.
Sample analysis could be performed in the chemistry or health physics labs. There were Ge(L1) detectors and counting systems available in_the analysis areas. Other equipment, such as gas marinelli flasks, filters and handling equipment such as tongs and tweezers were available in the chemistry lab.
The licensee's design review of the post-accident sampling systems, expressed in a letter to the NRC dated December 31, 1979, on "TMI-2 Short Term Lessons Learned Implementation," indicated that:
(1) post-accident containment atmosphere samples could not be obtained with the present sampling system, and (2) post-accident radioactivity
'
and chemical analyses could be completed as required with present laboratory equipment and only minor procedure changes. The licensee had committed to install new post-accident sampling systems.
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Based on the above findings, improvements in the following area are required to achieve an acceptable program:
(See items 245/82-01-22, 23, 24 and 336/82-01-22, 23, 24 of
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this report)
4.1.1.7 post-Accident Gaseous and Particulate Effluent Sampling and Analysis The auditors reviewed the licensee's capability to sample and analyze high activity gaseous and particulate effluents during accident situations. The auditors inspected the sampling locations for the Unit 1 stack and Unit 2 auxiliary vent, reviewed the sampling
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procedures and discussed post-accident stack and vent sampling with licensee personnel.
The sampling location for the Unit I gaseous effluent stack was in the sampling room at the base of the Unit 1 main stack. The loca-tion of the sampling point for the Unit 2 Auxiliary Building vent was in the east penetration area of the Unit 2 enclosure building.
The Unit 2 auxiliary vent was unfiltered. The Unit 2_ control operators had the option of switching the containment ventilation effluent from the auxiliary vent to the Unit 1 main stack, which had HEPA and charcoal bed filtration.
There was no shielding available in either the Unit 1 stack sampling room or the Unit 2 auxiliary vent sampling area. The Unit 1 area was monitored by an ARM which read out locally and in the Unit 1 i
control room.
This ARM was the same instrument that was being used as the Unit 1 interim high range stack monitor. The Unit 2 area was unmonitored except for an ion chamber that was being used as the Unit 2 interim high range stack monitor and which read out only locally.
Licensee representatives indicated that shielded sample containers would be available, but none was dedicated for emer-gencies.
Licensee chemistry personnel had no training with respect to gaseous and particulate sampling in an emergency or in the use of self-contained breathing apparatus (SCBA).
The sample analysis area was the plant chemistry laboratory. The chemistry lab had several GI(Li) detectors and counting systems available for radiological analyses. Other equipment such as sample flasks, filters and handling equipment were available in the chemistry lab.
Licensee representatives indicated that a new stack monitoring and sampling system was being installed at the Unit 1 stack sample room, but exact details of its operating capabilities or the completion date were not available.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
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(Seeitems 245/82-01-22, 23, 24 and 336/82-01-22, 23, 24 of
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this report)
4.1.1.8 Post-Accident Liquid Effluent Sampling and Analysis The auditors observed the locations for liquid effluent sampling.
The licensee's representatives indicated that these sampling locations would be accessible during accident conditions; however, an engineering study to confirm these statements had not been performed.
Procedure EPIP 4202, " Post Accident Sampling," provided guidance to health physics personnel, under the supervision of the Manager of Radiological Consequence Assessment, for determining the habitability of the sample routes and sampling areas.
The analytical lab was the plant chemistry laboratory. This analytical facility appeared to be accessible during accident conditions based on the licensee's shielding design review.
Shielded sample containers and remote handling tools for transporting samples were available.
Other equipment and tools (e.g., micropipettes, syringes, shielding, etc.) were available for use by the chemistry personnel.
Instruments and detectors for analysis described in the relevant procedures were in place.
Procedures CP 809A, " Liquid Waste Discharge," and CP 2809B, " Liquid Waste Discharge," described, for Units 1 and 2 respectively, the sampling technique to assure a representative sample. Based on a review of procedures and discussions with licensee personnel, liquid effluent sampling and analysis could be performed within three (3) hours.
Based on the above findings, improvements in the following areas ara required to achieve an acceptable program:
(See items 245/82-01-22, 23, 24 and 336/82-01-22, 23, 24 of
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this report)
4.1.1.9 Offsite Laboratory Facilities Alternate laboratory facilities for use by the licensee in emergency situations were available at the Haddam Neck plant, approximately 40 miles away. Additional facilities were available from commercial vendors, and letters of agreement covering these arrangements were in Appendix B of the Emergency Plan.
The licensee had on order additional equipment for monitoring and analysis. This equipment will be installed at facilities provided in the hardened EOF approximately one mile from the plant.
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Based on the above findings, this portion of the licensee's program appears to be acceptable,
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4.1.2 Protective Facilities 4.1.2.1 Assembly / Reassembly Areas The Emergency Plan identified two assembly areas for accountability of persornel as follows:
Condensate Polishing Facility (CPF) Area Northwest Assembly Area The CPF appeared to have sufficient space to accommodate the expected number of personnel. The licensee had stocked a large number of paper coveralls, respirators with canisters, and cloth and rubber gloves in the CPF.
Portable air samples, friskers and a gamma radiation monitor with a high radiation alarm were available in the general area. There was a room available for first-aid treatment along with first-aid kits.
The Northwest Assembly Area is an outdoor area.
Emergency Monitoring Team (EMT) personnel are directed by procedure to determine the i
radiation and airborne activity levels at both the CPF and Northwest l
Assembly Areas.
EMT personnel also monitor personnel in the assembly j
area for radioactive contamination.
No offsite assembly areas had been designated in the event a site evacuation was ordered.
Licensee personnel stated the Director of Station Emergency Operations would determine the location of offsite assembly areas if necessary during an emergency.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered j
for improvement:
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Designate an offsite location or locations where site personnel l
could reassemble in the event of a site evacuation.
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(245/82-01-25; 336/82-01-25)
4.1.2.2 Medical Treatment Facilities The first aid facility was lccated on the fourteen and one-half foot elevation within the Unit 1 turbine building. This was considered a " clean area";
i.e., contaminated ambulatory injured would be f
taken to the Health Physics decontamination facility prior to being escorted to the first aid station.
For badly injured, contaminated individuals, the nurse could transport a trauma kit to the victim within three to five minutes. The nurse would be accompanied by a Health Physics technician who would have radiation survey instrument-ation.
Emergency first aid would be given, and then the individual would be prepared for transport to Lawrence & Memorial Hospitals.
The ambulance service would take approximately ten minutes to arrive onsite.
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For definitive medical care not available at Lawrence & Memorial Hospitals, the licensee had an agreement with Radiation Management Corporation and the University of Pennsylvania.
The first aid and HP decontamination facilities were not readily accessible to severly injured personnel on stretchers; however, provisions have been made to remove the railing on the landing adjacent to the first aid station entrance and install a ramp to bypass the stairs.
Emergency dosimetry was available at the HP dosimetry trailer and at the security access points. There were only two bottles of potassium iodide (KI) onsite (approximately 1,000 tablets of 130 mg.
each) in the first-aid station.
The distribution of this drug to onsite and offsite emergency workers will be at the discretion of the Emergency Medical Director and the Director of Station Emergency Operations. As for back-shift medical capabilities, the Security Shift Supervisors are trained in first-aid procedures.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.1.2.3 Decontamination Facilities The licensee had established personnel decontamination facilities at two locations, the Millstone Unit 1 and Unit 2 Health Physics Control Point (HPCP) and the Emergency Operations Facility (EOF).
Both decontamination facilities were located near medical facilities.
The HPCP and the EOF had shower facilities, survey instruments and decontamination supplies. However, there were no decontaminants specifically for radiciodine in any of the personnel decontamination kits.
Procedure EPIP 4208, " Aid to Affected Pesonnel," in the personnel decontamination instructions, identified decontaminants which would be suitable for radioiodine contamination removal but specific reference to radiciodine decontamination was not made.
The procedure required approval by the Manager of Radiological Consequence or the Medical Director for use of any personnel decontaminants other than detergent.
(See Section 5.4.3.4)
A personnel decontamination kit was provided at the Condensate Polishing Facility (CPF) assembly area. However, no provision had been made for water supplies or radioactive waste disposal. Tap water and plastic bags for absorbed liquids or solid wastes were-available. No provisions for personnel decontamination were provided at the Northwest Assembly Area. However, the Emergency Plan specified that contaminated personnel were to be sent to the HPCP or the EOF for decontamination. The procedure also specified the'Haddam Neck Plant as backup if onsite areas were not usable.
No personnel decontamination supplies were located in the reactor control rooms.
Personnel survey instruments were available in the
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i control rooms and in the EMT #1 kits located in the control rooms.
However, Procedure EPIP 4203, "EMT #1 - In Plant Radiological Sampling and Monitoring", did not instruct personnel to perform contamination surveys of personnel reporting to this location.
The HPCP shower facilities were capable of handling two persons at a time; the EOF shower facilities coulo handle several persons at a time and were separate for men and women.
Liquid waste from the HPCP discharged to the plant radioactive waste system and from the E0F to a 10,000 gallon hold-up tank. Solid waste disposal was provided at both locations.
Replacement clothing was available at the HPCP and the EOF.
Decontamination procedures were not available at the EOF and were
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not included in Procedure EPIP 4603, " Emergency Radiological Equipment
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Maintenance and Inspection," which contained the inventory lists for the decontamination facilities.
l Based on the above f'ndings, this portion of the licensee's program l
appears to be acceptable, but the following matter should be considered for improvement:
Provide personnel decontamination procedures at the Emergency
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Operations Facility personnel decontamination facility and in t
the decontamination kit located in the Condensate Polishing l
Facility assembly area. (245/82-01-26; 336/82-01-26)
4.1.3 Expanded Support Facilities Section 5.0 of the Emergency Plan stated that offsite support would (
be available from the Corporate emergency organization. Additional support services would be obtained from the Nuclear Steam Supply System manufacturer and the Architect / Engineer. Also support
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l resources were available from Electric Boat, UNC Naval Products, I
Haddam Neck Nuclear Power Station and other vendors as specified in letters of agreement. Discussions with licensee management indicated that work facilities, in addition to the E0F, would be determined on an as needed basis.
Based on the above findings, this portion of the licensee's program appears to be acceptable; however, the following matter should be considered for improvement:
Describe how work facilities and other resources in the vicinity
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of the site would be made available for Corporate, contractor and other personnel in the event of a large, prolonged response.
(245/82-01-27; 336/82-01-27)
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4.1.4 News Center The Emergency Plan and the Corporate Organization for Nucleae Incidents Procedure Manual identified the Connecticut State Armory in Hartford, Connecticut as the Media Center.
The auditors discussed the Media Center with licensee representatives and the Governor's Press Secretary, and toured the facility.
The main drill floor of the Armory is designated as the Media l
Center.
The Media Center is a State facility and its activation and operation is under the control of the Governor. The licensee would dispatch a Corporate representative to the Media center in the event of an emergency.
No provisions have been made by the licensee to provide media briefings at a location closer to the site.
The Media Center is located in close proximity to the State Emergency Operations Center which is also in the Armory. The drill floor is very spacious and there would be no difficulty in accommodating a large number of media personnel once the drill floor is cleared of temporary tennis courts which occupied the space.
Security and crowd control should not be a particular problem considering that the Media Center is located within the State Armory.
Some telephone lines and a limited amount of audio-visual equipment were available in the Armory which could be utilized by media personnel. The State has made provisions with utility companies to install banks of telephones and electrical service lines on a priority basis in the event of a serious emergency which attracts a large number of media personnel.
The Governor's Press Secretary stated that the Connecticut media could be accommodated on very short notice with existing facilities and that the Media Center could be made ready in approximately six hours to handle the national media which would take several hours to arrive on the scene.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.2 Emergency Equipment 4.2.1 Assessment Equipment 4.2.1.1 Emergency Kits and Portable Instrumentation The licensee had pre positioned emergency supplies and survey instrumentation at specified locations in the Control Rooms, Technical Support Center (TSC), Condensate Polishing Facility (CPF), and Emergency Operations Facility (EOF).
Emergency kits and supplies were inventoried by the auditors.
Supplies were found in place and equipment appeared to be operable and within calibration specifications.
However, during the inventory one kit was found without a security
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seal.
Several items were found missing from the kit and the licensee representative stated that when kits were found without a security seal, immediate action was implemented to secure any items missing and provide the kit with a full complement of supplies as designated in Procedure EPIP 4603, " Emergency Radiological Equipment Maintenance and Inspection." Also during a walk-through with the licensee, it was apparent that an instrument designated in the procedures was not available for use by EMT #1 (see Section 5.4.2.3).
The licensee's inventory records indicated that the emergency supplies and equipment were inventoried and equipment operationally checked on a monthly basis. However, the emergency procedures did not specify a frequency for inventory of supplies nor. operational checks for equipment (see Section 5.5.1 of this report).
Emergency instrumentation was checked for calibration in accordance with Health Physics (900/2900 Series) Overall Procedures and inoperable instruments appeared to have been replaced or repaired in a prompt manner. Operability and calibration checks appeared to be adequate.
However, the licensee stated that instruments in the EMT kits that need to be recalibrated may be removed for calibration for up to one-half day without replacement.
Each emergency team assigned had ready access to all instrumentation, equipment and supplies described in the procedures applicable to their emergency duties.
Equipment to be used by teams re-entering the facility included provisions for the detection ar.d measurement of beta / gamma radiation fields, but there were no provisions for extremity monitoring.
Portable ion chamber instruments with beta /
gamma distinguishing capability were available for use in the detection and measurement of whole body dose rates -in plant and out of plant. GM instruments with beta / gamma distinguishing capability were available for use in detecting contamination on individuals and in the environment.
The contents of emergency kits provided sufficient numbers of instruments and supplies, except for extremity monitoring, to equip the team members for their intended function.
There was an in plant capability for detecting airborne iodine in the presence of noble gases. Available eq'..pment was adequate in number for all intended uses, e.g., assembly area monitoring, decontam Nation, in plant surveys, etc.
The licensee's emergency radiciodine and particulate sampling methods used a silver loaded silicon gel cartridge and glass fiber filter paper. The radioiodine sampling cartridges, due to sus-ceptibility to moisture absorbtion, were stored in sealed metal cans.
The can contained a chemical moisture indicator showing if cartridges were suitable for use when removed. At least twelve cartridges were available in each emergency sampling kit and more than one hundred reserve cartridges were stored at the EOF.
Studies
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I and tests performed by the licensee demonstrated that the defined method was capable of the detection and measurement of radioiodine concentrations in air of 1.0 E-08 uCi/cc under field conditions and of particulate activity in air of 1.0 E-09 uCi/cc.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters snould be considered for improvement:
Develop a system to ensure that the integrity of the emergency
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monitoring kits is maintained and replacements are provided for instruments taken out of the emergency monitoring kits for calibration until the original instruments are returned.
(245/82-01-28; 336/82-01-28)
Include provisions for extremity monitoring in emergency kits.
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(245/82-01-29; 336/82-01-29)
4.2.1.2 Area and Process Radiation Monitors The area and process monitors described in Table 7-2 of the Emergency Plan were available and operable. The readouts for_these monitors were in the control rooms of their respective reactor units, with the exception of the Unit 2 Interim High Range Stack Monitor, which.
was located on the fourteen foot level of the Unit 2 Reactor Building near the spent fuel pool. This location was deemed to be accessible under most accident conditions.
Typical ARMS at the two units had maximum detection limits of 10 R/hr. Others such as the Unit 2 Containment Post Accident Area Monitor had a limit of 100 R/hr; some such as the bait I refueling floor and stack sample room ARMS had limits of 1000 R/hr. Alarm set points for the ARMS ranged between 1 mR/hr for the Unit 1 Control Room to 4 R/hr for the Unit 1 TIP Cubicle ARM.
The alarm set points were posted near the monitor readout locations. ARM readings and alarms were referenced in the Emergency Action Levels (EAls).
The ARMS were calibrated on an eighteen month schedule. The ARMS inside containment were done every outage. The licensee had the capability to calibrate the instruments onsite with a Cesium-137 source that produced exposure rates up to 800 R/hr.
The licensee had 39 process radiation monitors (PRMs) for the two reactor units which measured liquid, gaseous, or particulate activities within various systems and effluent pathways.
Selected PRMs were equipped with recorders in addition to the monitor readouts. These monitors were checked monthly and calibrated quarterly.
The readouts for various ARMS and PRMs were not duplicated in each control room, but rather each control room had its own independent
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monitoring network.
The readouts for the main stack n;onitor and interim high range monitor were located only in the Unit I control room.
Since, at times, Unit 2 may release effluent through this point, it may be advantageous to duplicate the readmit of these monitors in the Unit 2 control room.
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:
Duplicate the readouts for the main stack effluent monitors in -
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the Unit 2 control room.
(245/82-01-30; 336/82-01-30)
4.2.1.3 Non-Radiation Process Monitors Non-radiation process monitors were not listed in the Emergency Plan or Implementing Procedures. The process monitors which measured vital parameters that were relied upon in the Emergency Action Levels (EAls) for emergency detection, classification and assessment such as reactor coolant system pressure, temperatures, levels and flow rates, and containment pressures and temperatures were in place and operable. All monitor readouts were accessible in the control rooms and were readily observable.
Annunciators in both control rooms indicated seismic events.
These annunciators were activated by a seismic trigger on the Unit 2 containment slab.
Seismic recording instruments were available in the Unit 2 control room.
The magnetic tapes for these recorders could be removed and analyzed onsite to determine the intensity of a seismic event and the results then reported to the two control rooms.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.2.1.4 Meteorological Instrumentation The meteorology program as described in the Emergency Plan relies on data from the primary 450-foot (137 m) meteorological tower at the site. Data from the tower includes three levels of delta-temperature (10-43 m,10-114 m, and 10-136 m) for stability determination and four levels of wind speed and wind direction (10, 43, 114, and 136 m). Those data provide the necessary information that is combined in the class A gaussian model to calculate offsite doses.
The observations measured by the sensors are transmitted to strip chart recorders in the tower instrument shelter and the control room and also stored on magnetic tape and in computer memory at the site and in Northeast utilities (NU) headquarters in Berlin, Ct.
During the inspection of the meteorological instrumentation, the auditor noted that the time marks on the strip.
charts did not correspond to the actual clock time. This was pointed out to licensee representatives who took corrective actions.
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The instrumentation was provided with redundant power supplies and was checked daily from Corporate headquarters via remote interroga-tion. Quality assurance evaluation was performed by NU meteorolo-gists and technicians at Corporate headquarters.
Prompt maintenance was available in the event problems were identified. Calibrations were performed quarterly to ensure acceptable data recovery rates.
The licensee had not committed to provide a btckup tower. Data from other sources such as the Maromas tower in Middletown, CT or a tower in Waterbury, CT were proposed by the licensee as alternative sources of data. The use of either of these two towers was judged by the auditor to not be acceptable to represent site conditions.
In addition, the proximity to Long Island Sound, with its summer season onshore sea breezes, indicated the need for additional measurements to assess the sea breeze effect on the transport of effluents on shore.
Meteorological forecasts were available from the Travelers Weather Service and severe weather warnings were provided through WSI, a private meteorological service.
Based on the above findings, this portion of the licensees program appears to be acceptable, but, the following matters should be considered for improvement:
Install a supplementary meteorological tower to better
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characterize air flow and effluent transport at the site.
(245/82-01-31; 336/82-01-31)
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Develop procedures to ensure that meteorological strip charts are properly timed and checked at an appropriate surveillance frequency.
(245/v2-01-32; 336/82-01-32)
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Provide information on a nearby source of offsite or onsite meteorological data that can be used as backup in the event of loss of the primary tower, rather than the two proposed locations, Middletown and Waterbury, CT.
(245/82-01-33; 336/82-01-33).
4.2.2 Protective Equipment 4.2.2.1 Respiratory protection The licensee had self-contained breathing apparatus (SCBA) reserved for emergency use in the control rooms for Units 1 and 2 as well as at the EOF. Each control room was equipped with two SCBA units and one spare bottle.
In addition, a plant supplied air outlet distri-bution manifold, hoses and respirators were located in each control room. The EOF supply of SCBAs consisted of 12 units with 50 extra bottles. Additionally, the licensee possessed 50 MSA fullface
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respirators at the E0F. All units were NIOSH approved. There were no SCBAs dedicated to the Technical Support Center (TSC).
The licensee had the capability for refilling SCBA bottles using a four-bottle cascade refilling system.
In addition, the licensee had an agreement with a local vendor to supply bottled air during an emergency. The vendor provided a breathing air quality certifi-cation (Grade D or better). The onsite refilling system was tested on an annual basis by an outside vendor.
The licensee indicated that future certification of breathing air quality would be performed by plant personnel.
Because the onsite refilling system was located in the environmental building some distance apart from the main area, it should remain accessible even though internal areas of the plant might have high airborne or direct radiation levels.
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:
Provide dedicated self-contained breathing apparatus in the
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TSC.
(245/82-01-34; 336/82-01-34)
4.2.2.2 Protective Clothing The licensee had stores of protective clothing reserved for emergency use.
Protective clothing inventories were located at two onsite warehouses and one offsite warehouse.
Inventories were maintained at or above minimum stocking levels based on. outage usage.
Stores of protective clothing would be accessible under most emergency conditions.
In addition, backup supplies of protective clothing would be available from the Haddam Neck nuclear facility.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.2.3 Emergency Communications Equipment The auditors verified that the communications equipment specified in the licensee's Emergency Plan and Implementing Procedure was available and operable including alarms located throughout the facility which had specific personnel notification functions.
Voice communication equipment consisted of commercial telephone lines, dedicated telephone lines to specific locations including the Control Rooms, TSC, E0F, Corporate E0C and law enforcement agencies; two-way radios for Security, Tri-Town, State Police and Waterford Police; the Millstone radiopager system for alerting key licensee and offsite personnel; and the Intercom - PA system. The Control Rooms, TSC and EOF had 24-hour per day capability to notify
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the NRC, State and local authorities with dedicated and back-up equipment in place.
Provisions for routine checks of the emergency communications equipment were included in the 4600 series of EPIPs.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.2.4 Damage Control, Corrective Action and Maintenance Equipment and Supplies The auditors reviewed Section 6.3.2 of the Emergency Plan and verified that equipment and supplies necessary to perform repair and corrective actions of plant equipment were available. The licensee stated that equipment and supplies needed to support damage control and corrective action activities were included and maintained in the routine level of reserve supplies.
In addition to maintaining certain equipment (e.g., air compressors, recharging equipment, cranes and fork lifts), the licensee had a standing purchase order with an onsite contractor, Stone and Webster, for goods and services.
Supplies and equipment to support damage control and corrective actions could also be obtained from Corporate resources, the Haddam Neck Nuclear Facility, and private nuclear industries in the area.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.2.5 Reserve Emergency Supplies and Equipment Section 8.4 of the Emergency Plan identified locations of emergency equipment and supplies located throughout the Station and these were observed by the auditors during walk-throughs of the Station.
Detailed lists of emergency supplies and equipment were provided in Appendix E of the Emergency Plan.
The licensee relied upon the onsite inventory for certain supplies and equipment such as survey instruments, dosimetry, and protective clothing to support emergency operations. The licensee also had a 17,000 sq. ft. warehouse in New London stocked with approximately 10 to 15% of the routine level of required health physics materials.
These levels were based on the minimum - maximum stocking level system and were maintained and inventoried on a continuing basis.
Additional emergency supplies of equipment and personnel were available under memorandum of understanding with General Dynamics, Groton, Ct.; UNC Naval Products, Uncasville, Ct.; and the Haddam Neck Nuclear Facility.
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 had four vehicles dedicated for emergency response operations including offsite monitoring requirements. These vehicles were located at the E0F and were controlled by -the Manager of Radiological Consequence Assessment.
l The dedicated vehicles included a 1981 van and three well used i
automobiles: one 1973 compact model and two 1974 c.ompact models.
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The appearance, age and size of the vehicles led the auditors to question the reliability and effectiveness of their use for plume tracking.
It also appeared that Emergency Monitoring Team members
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would have difficulty in getting equipment into and out of the
compact cars.
The licensee also had three vehicles onsite which could be used as replacement vehicles for the above.
Two sets of keys were controlled by Security at two locations during off-shift hours for the emergency vehicles.
In addition to company vehicles, employee personal 4 -
vehicles were relied upon for transporting Emergency Monitoring Teams offsite. The licensee had no special provisions for transportation over rough terrain or during periods of heavy snow, ice or rain.
Ambulance service would be provided by an offsite supporting agency as indicated in a letter of agreement.
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:
Provide' reliable' emergency vehicles for use by Emergency
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Monitoring Teams for plume tracking capable of transporting required equipment and personnel off road and in adverse weather. (245/82-01-35; 33/82-01-35)
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5.0 PROCE0VRES 5.1 General Content and Format The auditors reviewed the content and format of the licensee's Emergency Plan Implementing Procedures (EPIPs) for Units 1 and 2.
These procedures specifiec the assigned responsibilities for each emergency response positicn or functional area, the conditions which would alter specified actions, and the basis for specific actions taken relative to emergency action levels (EALs) and the corresponding accident classification. A separate section contained app 1 N oie sign-off sheets and checklists to indicate the actions taken by individuals within the emergency response organization.
The form and content of the EPIPs were in general found to be satisfactory except for specific comments which are noted in the following sections.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.2 Emergency, Alarm and Abnormal Oce;rrence Procedures The licensee had operating pro udures which were referred to as Emergency Operating Procedures and Alarm Set Point Procedures.
These procedures are used for protection of the reactor core and plant systems and for responding to abnormalities and transients.
The auditors reviewed a sampling of the emergency operations and alarm set point procedures and found that the majority of them contained a step in the "immediate action section," which directed the operators to the appropriate EPIP or the basic operating proce-dures used to classify emergencies (i.e., Procedures OP 501 and OP 2501) which in turn directed the user to the appropriate EPIP.
Based on the above findings, this portion of the licensee's program appears to be adequate.
5.3 Implementing Instructions The auditors reviewed Procedures OP 501 and OP 2501, " Incident Assessment and Classification," and EPIPs 4101 thru 4104 classification procedures for Unit 1 and Unit 2, respectively, and which comprised the implementing instructions for responses to the four classes of emergencies: Notification of Unusual Event, Alert, Site Area Emergency and General Emergency.
Procedures OP 501 and OP 2501 also contained references to the-State of Connecticut emergency classification scheme. The State of Connecticut employs a unique emergency classification scheme which classifies reactor incidents according to escalating severity into one of the following categories:
Echo, Delta, Charlie-One, Charlie-Two, Bravo and Alpha. The Connecticut accident categories are
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analogous but not identical to the NRC emergency classification scheme given in NUREG-0654, Appendix 1.
The Shift Supervisor is initially the Director of Station Emergency Operations and is responsible for.the initial classification of the event and making the proper initial notifications and recommenda-tions.
The emergency classification is made based on observable information obtained from control room instrumentation. However, the emergency action levels (EALs) for several conditions in the classification procedures for both Units 1 and 2 were not addressed and clarification of several EALs-is required.
The following changes should be considered in OP 501:
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(a)
In Item V under Unusual Event, relevant sections or pertinent values from the Technical Specifications should be listed.
(b)
In Item V under Alert concerning loss of functions needed for plant cold shutdown, the pertinent systems and instrumentation should be listed.
(c)
In Item V under Site Area Emergency concerning loss of all alarms, "significant abnormal transients" should be defined and compared with the intent of item #9 on page 1-13 of NUREG-0654.
(d)
In Item VI under Unusual Event concerning the release of radiological effluents exceeding Technical Specifications,
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" Technical Specifications" should be changed to " Environmental
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Technical Specifications."
l (e)
In Item VII under Unusual Event concerning loss of containment integrity,'"significant" should be deleted from the initiating condition and the relevant sections or pertinent l
values from the Technical Specifications should be listed.
( f) Under Item VII, Unusual Event, concerning a leak rate exceeding Technical Specification limits, leaks outside of primary containment should also be addressed; e.g.,
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leaks from the reactor water cleanup system.
(g) Under Item VII, Site Area Emergency, concerning a degraded core with possible loss of coolable geometry, an EAL for gap activity in the steam or primary coolant should be added.
The following changes should be considered in OP 2501:
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In Item II under Unusual Event concerning a fire lasting more than 10 minutes, the phrase "in an area that has
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some potential to adversely affect systems important to safety" should be replaced with "within the plant." Also under Alert, "high" should be deleted.
(b)
In Item V under Alert concerning the loss of all alarms, the phrase "for greater than 15 minutes" should be deleted.
(c)
In Item V under Alert concerning loss of functions required for plant cold shutdown, the pertinent systems and instrumentation should be listed.
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(d)
In Item VI under Alert concerning release of radiological effluents which exceed Technical Specification by a factor of ten, " Technical Specification" should be changed to " Environmental Technical Specification." Also a revision should be made to indicate that readings would be reflected on Unit l's stack radiation monitor.
(e)
In Item VI under Site Area Emergency concerning the results of atmospheric steam dump measurements, the EAL should reflect that results are obtained via onsite surveys and not a direct readout in the control room.
(f)
In Item VI under Alert concerning high radiation levels or high airborne contamination, pertinent radiation levels and instrumentation should be indicated.
(g)
In Item VII under Site Area Emergency, air ejector radiation alarms are used in conjunction with the letdown radiation monitor alarm to indicate a steam line break with primary to secondary leakage.
Consideration should be given to the possibility that contaminated steam may not reach the air ejector after a steam line break.
(h)
In Item VIII under Unusual Event concerning the possibility of exceeding the primary to secondary leak rate, the word
" suddenly" should be deleted. Under Alert, the containment atmosphere radiation level alarm EAL should be reconsidered in view of the fact that these radiation monitors will not detect a primary to secondary leak.
(i)
In Item VIII under Alert concerning the rapid failure of many steam generator tubes, the third EAL should be reconsidered in that the low level alarm in the Volume Control Tank may not lead to a sufficiently rapid response.
(j) Under Item VIII, Unusual Event, concerning abnormal coolant temperature and/or pressure, an EAL for unacceptable subcooling margin should be added.
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(k) Under Item VIII, Alert, concerning severe loss of fuel cladding with greater than 1% fuel failure, an EAL based upon rate at which fuel is failing should be added.
(1)
In l u.: VIII, Site Area Emergency, concerning degraded core with possible loss of coolable geometry, EALs for gap activity in the primary coolant and for an uncovered core should be added.
(m)
Items 5d and 5e on page 1-18 of NUREG-0654 should be addressed in the EALs.
Also, Shif t Supervisors stated during walk-throughs that a fault-tree format or more training in the present procedure would make implementation and usability easier (see Section 7.2 of this report).
The Shift Supervisor also indicated that the need to use both a State and an NRC system for classifying emergencies was cumbersome.
Each of the above EPIPs described the planned response actions required to be considered in response to each emergency class (i.e., staffing and activation of facilities, initiation of assessment and protective actions, etc.).
Based on the above findings, improvement in the following area is required to achieve an acceptable program:
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Propose a plan of action to establish consistency between the emergency classification and action level schemes of the licensee and State and local emergency response organizations in accordance with the guidance of NUREG-0654, Appendix 1.
(245/82-01-36; 336/82-01-36)
In addition, the following matters should be considered for improvement:
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Develop a more usable format for the EALs in Procedures OP 501 and OP 2501 and provide additional training for Shift Supervisors and other Directors of Station Emergency Operations in classifying emergencies.
(245/82-01-37; 336/82-01-37)
Changes should be made as indicated in Section 5.3 of this
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report to the emergency action levels for Unit 1 and Unit 2 in Procedures OP-501 and OP 2502 respectively.
(245/82-01-38; 336/82-01-38)
5.4 Implementing Procedures 5.4.1 Notifications Procedures EPIP 4101 through 4104 indicated that the non-affected Unit Shift Technical Advisor or the Shift Supervisor's Staff Assistant
(STA/SSSA) would report an incident within 15 minutes of its
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classification by initiating the radiopager and telephone call-back system to the following State and local officials; the Governor's Office; Office of Civil Preparedness; Department of Environmental Protection; State Police; and the Chief Executive Officers of the towns within the ten-mile Emergency Planning Zone.
Form SF 127 (Incident Report For;a) would be completed by the Shift Supervisor or the Shift Technical Assistant and would then be recorded and transmitted by the SSSA. The SSSA would then verify that given individuals and agencies had received the message and called back.
If local agencies had not responded, the SSSA would l
call the communities and if unsuccessful in alerting officials, the SSSA would contact appropriate State Police barracks to pursue notification.
In given situations, the Shift Supervisor of the non-affected unit would be directed to assist the SSSA/STA in notifying and calling in EMTs and Corporate emergency organization managers and directors who were not on call.
The SSSA would notify the NRC within one hour of the occurrence of an incident and maintain open communications during the incident.
Federal support would be coordinated through the State EOC in Hartford.
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:
Perform a drill to verify the adequacy of the alert, call-in,
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and augmentation capabilities of the emergency response
organization.
(245/82-01-39; 336/82-01-39)
5.4.2 Assessment Actions
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Procedures OP 501 and OP 2501, " Incident Assessment and Classification,"
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contain procedural steps and emergency action levels (EALs) which will be used by the Shift Supervisor in classifying an emergency situation. Upon classifying the event, these procedures direct the Shift Supervisor to Emergency Plan Implementing Procedures (EPIPs)
4101, 4102, 4103 or 4104, which contain the implementing instructions for each class of emergency and indicate the criteria for escalating or de-escalating an event as well as subsequent actions to be taken.
These decisions will be based on data obtained from effluent monitor readings, area radiation monitor readings and onsite and offsite environmental surveys.
The EALs included stack monitor readings which are related to specific site boundary doses based on assumed activity release rates and meteorology. Other than this, there were no means or personnel within the licensee's emergency organization to perform
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dose calculations on back shifts until the arrival of radiological consequence assessment personnel in the EOF 60 minutes after declara-tion of the emergency (see Section 2.1 of this report).
However, protective actions were built into the emergency classification scheme used by State and local agencies.
When the EOF is operational, radiological assessment personnel use Procedure EPIP 4201, " Radiological Dose Assessment," and NUSCO's draft procedure on containment high-range monitor readings to calculate offsite doses.
These procedures indicated the methods that would be used to determine a source term by correlating a high range containment monitoring reading to the appropriate drywell/
containment activity concentration, estimate the fraction of failed fuel, determine the release rates of noble gases and iodints, and estimate the resultant offsite whole body and thyroid radiological doses.
Within Procedure EPIP 4201, there were provisions for assessing offsite radiological consequences should all plant effluent monitors become inoperable.
These provisions consisted of predetermined values for assumed release rates from either the Unit 1 or Unit 2 stack for a LOCA or stream generator tube rupture, predetermined values for a continuous release of unknown duration, and predetermined iodine / noble gas ratios based on a given type of accident.
EPIP 4201 also mentioned the possible use of post-accident grab samples and offsite monitoring data; however, the method used to factor this data into dose assessment calculations was not addressed.
Once dose calculations had been obtained, the Manager of Radiological Consequence Assessment was to report the results to the Director of Station Emergency Operations; however, the method and responsible individual through whom the State and local agencies would receive prompt dose assessment notification were not specified.
Furthermore dose assessment procedures did not appear to contain clear provisions for trend analyses of assessment data or specify a continuous update of assessment information to appropriate offsite agencies involved in implementing protective actions.
Based on the above findings, this portion of the licensee's program I
appears to be acceptable, but the following matters should be considered for improvement:
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Implement the procedure used to ascertain the containment source term based on containment high range monitor readings and provide training on its use to dose assessment personnel.
(245/82-01-40; 336/82-01-40)
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Provide action steps in Procedure EPIP 4201 for the prompt transmission and continuous update of assessment information to State and local agencies responsible for protective action decision making.
(245/82-01-41; 336/82-01-41)
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Develop provisions for trend analyses of assessment data.
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(245/82-01-42; 336/82-01-42)
Develop the methodology to utilize in plant sampling results
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and offsite environmental survey data in the radiological consequence assessment program.
(245/82-01-43; 336/82-01-43)
5.4.2.1 Offsite Radiological Surveys Procedure EPIP 4206, "EMT #4, #5 - Offsite Radiological Sampling and Monitoring," specified the methods and equipment to be used to perform emergency offsite radiological surveys. The procedure was clear and could be easily followed by the Emergency Monitoring Team (EMT) members performing the surveys. The procedures provided a means for the offsite monitoring team members to record all pertinent information about the survey to include such items as background readings, instruments used, time and date of survey, ctc. Detailed maps, with the monitoring points marked on them, were provided to the offsite monitoring teams as described in the procedures. These prepositioned survey points were used to determine the precise locations where measurements were to be made within the plume exposure EPZ.
Each collected environmental sample was to be uniquely labeled for later identification. The procedure discussed the means by which collected data, including the original data sheets, were to be provided to the organizational element responsible for emergency assessment functions. The central collection point for all environmental samples collected by the offsite survey teams was to be the EOF or a location determined by the Manager of Radiological Consequence Assessment.
The procedure described the communication method to be used during an emergency, and backup communications were available. Trans-portation for the offsite survey teams would be provided, as necessary, by the Manager of Onsite Resources.
General radiation protection guidance was provided in the emergency procedure to include such items as exposure control, protective clothing, equipment, etc.
The emergency procedure controls to be implemented during an accident appeared to be consistent with the State and local offsite monitoring requirements.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.4.2.2 Onsite (Out-of plant) Radiological Surveys The licensee's procedure EPIP 4205, "EMT #3 Site Boundary Radiological Sampling / Monitoring," discussed the methods and equipment to be used to perform emergency radiological surveys.
The procedure was
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clear and could be readily followed by Emergency Monitoring Team members.
Emergency Monitoring Team #3 members were to take air sample and waist level beta and gamma readings.
The initial sample point and sampling route was to be established by the Manager of Radiological Consequence Assessment. Communication from EMT #3 back to the EOF was by two-way radio; several back up two-way radio units were ava'lable at the EOF.
The means for recording all pertinent data on survey sheets was provided for in the emergency procedures.
Each individual sample was to be attached to the associated data sheet for later identification. The procedure specified that all completed survey forms with their attached samples were to be turned in to the Manager of Radiological Consequence Assessment or to an alternate central location as designated by.
General radiation protection guidance was provided in the emergency procedures including exposure allowed, protective clothing and sources of further guidance.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.4.2.3 In-plant Radiological Surveys The methods and equipment to be used to perform emergency radiological surveys were specified in the emergency procedures.
Procedure EPIP 4203, "EMT #1 In plant Radiological Sampling and Monitoring,"
specified that Procedure EPIP 4207, " Radiological Sampling During an Emergency," was to be used when the Control Room constant air l
monitor was not operational; however, Procedure EPIP 4207 referred to instrumentation for analysis of iodine cartridges that was not
I available in the EMT #1 kit. The procedures were clear and could be followed by persons responsible for performing the surveys.
Data sheets that included entry of all important information were provided for in the emergency procedures.
The procedures instructed emergency monitoring personnel as to the labeling of collected samples for later identification. The procedures specified that the collected data with samples attached were to be delivered to the Manager of Radiological Consequence Assessment at the EOF or some other central collection point as designated by the Manager.
General radiation protection guidance was provided in the emergency procedures. This guidance included such items as exposure control considerations, need for protective clothing, equipment needs, etc.
However, extremity monitoring was not addressed in the general radiation protection guidance.
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q 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:
Ensure that instrumentation specified in the emergency monitoring
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and sampling procedures 4 s available for use-by Emergency Monitoring Team members; include guidance for self-extremity monitoring in the procedures.
(245/82-01-44; 336/82-01-44)
5.4.2.4 Post-Accident Primary Coolant Sampling In response to the requirements of NUREG-0578 and the Commission letters _to all operating nuclear power plants dated September 13, 1979, and October 30, 1979, the licensee developed and implemented Procedure EPIP 4202, " Post Accident Sampling," on an interim basis
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to sample and analyze reactor coolant utilizing the current sampling systems.
The auditors reviewed Procedure EPIP 4202 and Surveillance
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Procedures 838, 2830, 2831, and 2834 which dealt w'ith the routine
, samplings' of the reactor coolant post-accident sampling systems was and analysis of reactor coolant for both reactors. The
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operation discussed with licensee personnel, and the auditors observed the in place post-accident coolant sampling systems and the new post-accident coolant sampling systems that were bein'g installed.
Procedure EPIP 4202, the procedure applicable to post-accident sampling, did not provide detailed instructions for the operation
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of the coolant sampling equipment and facilities for each reactor under accident conditions.
Licensee representatives indicated that routine chemistry and surveillance procedures would form the basis for collecting and analyzing coolant samples. These routine procedures did not take into account any extraordinary conditions that might be expected during an emergency such as high dose rates, high activity samples og airborne contamination.
'N The EPIP made provisions to limit exposure to sampling personnel by 3 stating that the Manager of Radiological Consequence Assessment and
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. Health Physics personnel would determine the protective measures
' prior to obtaining a sample at the time of the accident and that a radiation work permit (RWP) would be written for the specific
\\ sampling to be done. There was no statement in the procedures y
which indicated maxmimum allowable exposures or exposure rates, or
.what protective measures might be taken. There was no provision t
for the installation of shielding in the sampling areas.
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The EPIP did not identify the location of coolant sampling points for either reactor. Surveillance Procedure #838 indicated that the sampling sink for Unit 1 was located on the third floor of the Reactor Building. The surveillance procedures did not specify the location of the sampling point for Unit 2.
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The EPIP indicated that for liquid coolant, an " adequate sample in a sample container" would be collected. The amount of the sample, the size and type of the container, and the detailed means of collection were not specified. The surveillance procedures indicated that for routine samples, "approximately one liter of reactor coolant in a plastic bottle" was to be collected.
The EPIP and the surveillance procedures did not specify any specialized equipment such as remote hardling equipment, shielding, protective clothing, respiratory protection, or dosimetry for the whole body or extremities.
The EPIP stated that a portable sample shield or pig would be set up to transport a sample, but did not specify where this would be obtained.
There were no data sheets provided for the collected samples other than routine data sheets and there were no provisions for labeling samples for later identification.
The auditors reviewed all procedures that were pertinent to sampling reactor coolant and concluded that the licensee's current system is unworkable under accident conditions.
The licensee had committed to install a new sampling system dedicated for post-accident reactor coolant sampling.
This sytem was being installed at the time of the appraisal.
Licensee representatives indicated that these new systems would be completed by early 1982, and that the development of appropriate procedures and training of personnel would be completed by June 1, 1982.
Based on the above findings, improvement in the following area is required to achieve an acceptable program:
(See items 245/82-01-22., 23, 24; 336/82-01-22, 23, 24 of this
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5.4.2.5 Primary Coolant Sample Analysis The auditors reviewed Procedure EPIP 4202, " Post Accident Sampling,"
Surveillance Procedure 838, " Analysis of Reactor Coolant for Radio-activity," SP 2831, " Reactor Coolant Gross Activity Determination,"
Chemistry Procedure 801/2801N, " Computer Radioisotope Analysis System," and CP 806/2806T, " Multi-Channel Analyzer Counting" and held discussions with licensee chemistry personnel on the analyses of coolant samples.
Procedures for the dilution and analysis of high level samples were mentioned in EPIP 4202, but specific details were not provided.
The chemistry procedures described the calibration of the counting equipment with respect to Figh level samples, and this was supported in the EPIP.
No specific ouidance was provided for the protection of laboratory personnel working with high-lev.1 samples or the protection of the laboratory fram contamination.
Procedure EPIP 4202 required that
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the Manager of Radiological Consequence Assessment and Health Physics personnel establish radiation protection requirements prior to the sampling and analysis operations.
In the event of high backgrounds in the primary counting area, samples could be counted on the equipment in the Health Physics lab or, when it is installed, on the equipment in the EOF, but this was not identified in the procedures.
There were no data sheets for high level or emergency samples.
Routine data sheets were available, but these were not keyed to
EALs; nor were there means for providing the data sheet:: or the information contained within to the emergency organizational element responsible for the assessment function.
The disposition of samples was not identified.
It was estimated that the analysis of samples could be completed within two hours. This was reflected in a letter from the licensee to the NRC dated June 10, 1981.
Based on the above findings, improvement in the following a'rea is required to achieve an acceptable program:
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Develop specific detailed procedures and training for chemistry personnel for the analysis in the chemistry laboratory of high-level primary coolant, containment air, and liquid and gaseous effluent samples in the chemistry laboratory.
(245/82-01-45; 336/82-01-45)
In addition, the following matter should be considered for improvement:
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Provide emergency data sheets for each sample and establish a method for providing the information to personnel in the emergency organization responsible for assessment decisions.
(245/82-01-46; 336/82-01-46)
5.4.2.6 Post-Accident Containment Air Sampling The auditors reviewed Procedure EPIP 4202, " Post Accident Sampling,"
and discussed post-accident containment atmosphere sampling for Unit I and Unit 2 with licensee personnel.
The EPIP did not contain a detailed checklist for the operation of the emergency sampling equipment, nor did it define who would be responsible for taking a containment atmosphere sample in an emergency.
Station Chemistry personnel indicated that, for normal operations, Health Physics personnel were responsible for sampling containment air and would, therefore, be the ones who would be responsible for
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the sampling in an emergency.
Station Health Physics personnel indicated that all post-accident sampling was the responsibility of Chemistry personnel.
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The EPIP indicated that Health Physics personnel would monitor the sampling and that an RWP would be written for the specific sampling to be done. Prior to sampling, the Manager of Rcdiological Conse-quence Assessment.and Health Physics personnel was to determine the health physics requirements needed to keep individuals within allowable exposure limits and control the spread of radioactive materials.
The sampling point locations for containment atmosphere and the sampling equipment to be used were not specified in the procedure.
The EPIP did not address the matter of uniquely labeling samples for later identification, and appropriate data sheets for each sample were not included. The EPIP indicated that a portable sample shield or pig would be set up to transport samples, but the source of the shield or pig was not identified.
Discussions with licensee personnel indicated that the new post-accident containment atmosphere sampling systems would be operational by early 1982 and that appropriate sampling procedures and the training of personnel in their use would be completed by June 1982.
Based on the above findings, improvement in the following area is required to achieve an acceptable program:
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(See items 245/82-01-22, 23, 24; 336/82-01-22, 23, 24 of this report)
5.4.2.7 Post-Accident Containment Air Sample Analysis The auditors reviewed EPIP 4202, " Post Accident Sampling," Chemistry Procedure 801/2801N, " Computer Radioisotope Analysis System" and CP 806/2806T, " Multi-Channel Analyzer Counting" and held discussions with licensee Chemistry and Health Physics personnel on analysis of containment atmosphere samples.
The findings and recommendations for this portion of the licensee's program are expressed in Section 5.4.2.5, " Primary Coolant Sample Analysis," of this report.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
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(See items 245/82-01-45, 46; 336/82-01-45, 46 of this report)
5.4.2.8 Post-Accident Gaseous and Particulate Effluent Sampling The auditors inspected the installed equipment and sampling locations, discussed post-accident gaseous and particulate effluent sampling with licensee personnel, and reviewed Procedures EPIP 4202, " Post-Accident Sampling." Chemistry Procedure 806/2806J, " Stack Gas Sampling and Counting," and Surveillance Procedure 2843, " Unit #2
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Enclosure Building Roof Vent Menthly Sampling and Analysis for Principle Gamma Emitters and Tritium."
Procedure EPIP 4202 did not provide detailed instructions for the operation of the stack effluent sampling equipment and facilities for each reactor under accident conditions.
Licensee representatives indicated that routine chemistry and surveillance procedures would form the basis for collecting and analyzing stack effluent samples.
These routine procedures provided a fairly detailed description of the sampling process, but did not take into account any extraordinary conditions that might be expected in an emergency such as high dose rates, high activity samples or airborne contamination.
The EPIP made provisions to limit exposure to sampling personnel by stating that the Manager of Radiological Consequence Assessment and Health Physics personnel would determine the protective measures prior to obtaining a sample and that an RWP would be written for the specific sampling to be done. The EPIP did not identify specific-sampling locations or equipment; however, these were identified in the surveillance procedures. The labeling of samples for future identification and appropriate data sheets for each sample were not addressed. The EPIP indicated that a portable sample shield or pig would be set up to transport samples, but the source of the shield or pig was not identified.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
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(See items 245/82-01-22, 23, 24; 336/82-01-22, 23, 24 of this report)
5.4.2.9 Stack Effluent Sampling Analysis The auditors reviewed Procedure EPIP 4202, " Post Accident Sampling,"
Surveillance Procedure 2843, " Unit #2 Enclosure Building Roof Vent Monthly Sampling and Analysis for Principle Gamma Emitters and Tritium," Chemistry Procedure 806/2806J, " Stack Gas Sampling and Counting," CP 801/2801N, " Computer Radioisotope Analysis System" and CP 806/2806T, " Multi-Channel Analyzer Counting" and held discussions with licensee chemistry personnel on the analysis of stack and vent effluent samples.
The findings and recommendations for this portion of the licensee's program are expressed in Section 5.4.2.5 " Primary Coolant Sample Analysis," of this report.
Based on the above findings, improvements in the following areas
are required to achieve an acceptable program:
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(See items 245/82-01-45, 46; 336/82-01-45, 46 of this report)
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5.4.2.10 Liquid Effluent Sampling Samp1'ng point locations were specified for Unit 2 in Procedure CP 28098, " Liquid Waste Discharge," but were not specified for Unit 1.
Routine operating procedures provided a detailed check list for the operation of the emergency sampling equipment. The cperating procedures discussed the sampling media and special equipment to be used.
Data sheets for each sample were specified in the operating procedures; however, data sheets for emergency high level samples were not available. Samples were uniquely labeled for later identification.
Consideration had been given to the transport of samples to the sampling analysis area and equipment was available.
Procedure EPIP 4202, " Post Accident Sampling," generally described procedures to limit exposure to sampling personnel and to verify habitability in the areas occupied by sampling personnel.
Based on discussions with the licensee's representative and a walk-through observation with chemistry personnel, the auditors determined that sampling could be completed within two hours.
Discussions with the licensee's personnel indicated that the Unit 2 liquid effluent sampling area was also the area where reactor coolant was sampled.
The licensee had not determined the accessibility of this area during an emergency.
Procedure EPIP 4202 specified the particular sampling locations for reactor coolant, containment air, and stack and vent gaseous effluent samples.
For other post-accident sampling locations, licensee personnel indicated that routine operating procedures would be
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used. Discussions with the licensee indicated that Procedure EPIP 4202 would be. relied upon for general guidance in obtaining liquid effluent samples however, no special emergency procedures for liquid effluent samples were available.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
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(See items 245/82-01-22, 23, 24; 336/82-01-22, 23, 24 of this report)
In-addition to the above findings, the following matters should be-considered for improvement:
Reference in emergency sampling procedures any routine procedures
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(245/82-01-47; 336/82-01-47)
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5.4.2.11 Liquid Effluent Sample Analysis The auditors reviewed Procedure EPIP 4202, " Post Accident Sampling,"
Chemistry Procedure 801/2801N, " Computer Radioisotope Analysis System" and CP 806/2806T, " Multi-Channel Analyzer Counting," and held discussions with licensee chemistry personnel on analysis of liquid effluent samples.
The findings and recommendations for this portion of the licensee's-program'are expressed in Section 5.4.2.5, " Primary Coolant Sample Analysis."
Based on the above findings, improvements in the following area is required to achieve an acceptable program:
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(See items 245/82-01-45, 46; 336/82-01-45, 46 of this report)
5.4.2.12 Radiological and Environmental Monitoring Program The auditors discussed the radiological and environmental monitoring program (REMP) with licensee personnel onsite and at the Northeast Utilities Service Company (NUSCO) corporate headquarters in Berlin,
.Ct.
The REMP was administered from the NUSCO Corporate offices.
In an emergency where environmental monitoring was required, the Manager, Radiological Assessment Branch at the NUSCO offices would notify the Productions Operations Services Laboratory (POSL) at Middletown, Ct., to call in the sampling technicians and send them to the Millstone site. The technicians could arrive at the site within.
75 minutes of receiving the call to respond. The technicians would pick up the emergency kit from the Niantic Information Center. The environmental teams would collect soil, water, vegetation and foodstuff samples and replace the environmental TLDs. The TLDs would be processed and analyzed at POSL and other samples would be sent to the Chemical Waste Mana,iement (Interex) laboratory at Natick, Ma. The licensee also had the laboratory facilities at the Haddam Neck nuclear' facility as a backup.
Based on the above findings, this portion of the licensee's program appeared to be acceptable.
5.4.3 Protective Actions 5.4.3.1 Radiation Protection During Emergencies The auditors reviewed the licensee's Emergency Plan and Implementing Procedures. There was not an overall procedure governing the implementation of the radiation protection program during emergencies.
However, radiation protection was generally discussed in the Emergency Plan and specific emergency procedures were available that discussed
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particular areas of radiation protection.
Licensee personnel stated that certain routine radiation protection procedures would be used during an emergency; however, these procedures were not specifically referenced in the emergency procedures.
Licensee personnel stated that during an emergency, an exposure control system would be established and implemented from the EOF.
Persennel dosimetry, exposure records, and positive access controls would be handled by the control system.
Exposure control was generally discussed in Procedure EPIP 4209, " Emergency Operations Re-entry"; however, the program indicated by the licensee personnel was not defined.
The Emergency Plan Implementation Procedures did not specifically address personnel dosimetry; exposure records; exposure controls and preventing overexposures; distribution, identification and collection of emergency dosimeters for all personnel; or guidance to emergency personnel in changing or unusual conditions.
Based on the above findings, improvement in the following area is required to achieve an acceptable program:
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Develop detailed organization and procedural methods for implementing a radiation protection program for emergency response personnel which provides for the continuity of critical radiation protection procedures and functions during accident conditions.
(245/82-01-48; 336/82-01-48)
5.4.3.2 Evacuation of Owner Controlled Area The licensee did not have a specific implementing procedure for site evacuation. Rather, the basic implementing procedures for the Alert, Site Area and General Emergencies (EPIPs 4102, 4103 and 4104) contained identical action statements for the evacuation of various categories of station personnel. The procedures called for the Shift Supervisor to sound the evacuation siren and make an announcement over the plant PA system. There were no prepared announcements to describe the immediate actions of nonessential personnel.
The assembly areas were identified in the procedures as the Condensate Polishing Facility (CPF) and Northwest Assembly Area. Only the CPF area was identified as an assembly area in the Emergency Plan, Section 7.1.
The evacuation routes in the plant were marked by posted signs and arrows-No offsite assembly areas were identified in the Emergency Plao or Implementing Procedures.
If site evacuation becomes necessary, tne procedures state that the Director of Station Emergency Operations will designate evacuation routes.
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The procedures contained some provisions for the handling of con-taminated personnel but it was not specified who would be responsible for carrying out these actions. The procedures for site evacuation did not include references to the procedures for accountability and personnel monitoring and decontamination.
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 specific procedure for site evacuation specifying the emergency position or individual in the emergency organi-zation responsible for each action and including references to other pertinent procedures.
(245/82-01-49; 336/82-01-49)
5.4.3.3 Personnel Accountability The auditors reviewed the procedures covering personnel accountability and discussed the subject with licensee personnel.
The procedures for personnel accountability were. included in the basic implementing procedures for the Alert, Site Area and General Emergencies (EPIPs 4102, 4103 and 4104) and in a restricted Security Procedure. The licensee did not have a separate EPIP developed exclusively for personnel
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accountability. The procedures identified the Manager of Security as the person within the emergency organization responsible for the personnel accountability function.
The licensee had a computer system for badge ccatrol and accountability.
By generating a plant and protected area roll call printout, obtaining the manual listing of badge numbers of personnel offsite from the three security guard gates (Primary Access Point, Alternate Access Point, and Condensate Polishing Facility), and physically comparing the on-duty and accounted-for personnel rosters obtained from the Manager of Control Room Operations of the non-affected unit, a personnel accountability list could be developed for the Manager of Security.
The Manager of Security would then assist'the Manager of On-Site Resources in determining the-location of all personnel in the protected area. The Manager of On-Site Resources would provide the completed personnel accountability list to the Director of Station Emergency Operations who would initiate search and rescue parties as required according to Procedure EPIP 4208.
The accountability
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Procedures.
The Security procedure provided for the continuous accountability of all individuals on site by reissuing badges or by manual logging of individuals re-entering the plant.
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The licensee conducted a drill during September, 1981, which required 15 minutes for approximately 475 individuals to exit through the CPF gate and complete the key card reader activity. An additional 45 minutes was required to complete the personnel accountability.
The licensee had installed a second key card reader since the drill.
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 personnel accountability procedure whch lists each step in the' accountability process, identifies the responsible individual, and provides for a full accounting of plant personnel within 30 minutes from the declaration of an emergency.
(245/82-01-50; 336/82-01-50)
5.4.3.4 Personnel Monitoring and Decontamination Procedures reviewed by the auditors did not appear to provide for i
the monitoring of all individuals during an emergency.
Persons leaving restricted areas or other areas known or suspected to be contaminated were surveyed in accordance with Procedure SHP 4909,
" Personnel Monitoring and Decontamination," before proceeding to assembly areas. Procedure EPIP 4204, "EMT #2 - Protective Actions for Onsite Personnel", provided for personnel contamination surveys and decontamination actions at the Condensate Polishing Facility and Northwest Assembly Areas. However, the procedures for the emergency monitoring team (EMT) responding to the control room,
EPIP 4203, "EMT #1 - In-Plant Radiological Sampling and Monitoring,"
did not provide for personnel monitoring and decontamination.
In addition, although the emergency procedures specified that the Director of Station Emergency Operations will determine the location of alternate assembly areas if necessary, they did not indicate how personnel monitoring and decontamination would be accomplished at the alternate assembly areas.
Procedure EPIP 4204 provided for recording the names of individuals found to be contaminated, the level of contamination, the survey instrument used, and the methods used for decontamination.
However, the procedure did not provide for a listing of personnel frisked and found not to be contaminated. The means for providing the responsible organizational element with personnel monitoring data during an emergency were described in the procedure.
Contamination levels that required decontamination (100 CPM above background at h inch) and the decontamination actions were provided in Procedure EPIP 4208, "Ald to Affected Personnel." However, special considerations for skin contaminated with radioiodine were not addressed.
Problem contamination cases were to be handled by the Manager of Radiological Consequence Assessment at the EOF.
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Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be considered for improvement:
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Revise the appropriate procedures to provide for the monitoring and decontamination of personnel in the control room and at all assembly area locations.
(245/82-01-51; 336/82-01-51)
Develop decontamination procedures for skin contaminated with
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radioiodine.
(245/82-01-52; 336/82-01-52)
5.4.3.5 Onsite First-Aid / Rescue The auditors reviewed Procedure EPIP 4208, " Aid to Affected Personnel" and held discussions with licensee personnel to verify that provisions for recovering, handling, and transporting injured personnel were adequate. The procedure specified that team members will be qualified in administering first aid and should also be knowledgeable of the station layout and systems and be familiar with the radiological consequences of accidents.
Rescue teams consist of at least two stretcher bearers and one person responsible for radiation protection. The team will be equipped with radios, high-range dosimeters, TLDs, high-range survey instruments, keys or access cards, first-aid kit, and specialty gear required to aid in the rescue.
The maximum allowable planned exposure for team members will be determined oy the Manager of Radiological Consequence Assessment and will be controlled to less than 75 rem for life-saving actions.
The authorization for a search and rescue entry will come from the Director of Station Emergency Operations as will the approval for team members to exceed administrative exposure limits. The procedure, however, did not clearly specify who in the emergency organization would be responsible for supervising the rescue teams.
Ambulatory injured will be instructed on the evacuation route to follow.
Injured / contaminated individuals will be evaluated first for their medical injuries and first aid will be administered as necessary.
If circumstances are such that first aid cannot be given at the accident scene, injured personnel will be evacuated to the station first-aid room, E0F, or nearby hospital.
Blankets and stretchers were situated at various locations throughout the plant. Decontamination supplies (soap and water) were available in the first aid /HP area of the CPF Assembly Area. The EOF also had decontamination supplies and showers.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the followng matters should be considered for improvement:
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Specify in Procedure EPIP 4208 the emergency position or individual within the emergency organization responsible for organizing, controlling and supervising the search and rescue effort.
(245/82-01-53; 336/82-01-53)
5.4.4 Security During Emergencies The security measures to be placed in effect during emergencies were specified in Security Procedure SEP 1231 and in EPIPs 4102, 4103 and 4104, the Lasic implementing procedures for the Alert, Site Area and General Emergencies, respectively. The action steps in the security procedures provided a means for security and accountability during emergencies.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.4.5 Repair and Corrective Actions The auditors reviewed Procedure EPIP 4209, " Emergency.0perations Re-Entry," and determined that it addressed the concept of operations for repair and corrective action activities but did not refer to criteria to select team members, specific disciplines required, location of emergency equipment or the communications to be used.
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In addiion, the procedure did not clearly specify the emergency j
position or individual in the emergency organization responsible for supervising the repair and corrective action teams.
An emergency operations re entry team of " trained volunteers" would be established by the Director of Station Emergency Operations.
Most of the responsibility in the procedure for briefings, instruc-tions and precautions was placed on the individual in charge of the team who would be designated by the Director of Station Emergency Operations at the time the team is established.
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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Specify in Procedure EPIP 4209 the emergency position or individual within the emergency organization responsible for organizing, controlling and supervising the repair and corrective action effort.
Include in the procedure the criteria for team selection, location of emergency equipment and means for communicating.
(245/82-01-54; 336/82-01-54)
5.4.6 Recovery The auditors reviewed the information in Section 9.0 of the Emergency Plan and Procedure EPIP 4210 relating to Emergency Recovery.
The procedure merely stated that based on an evaluation of plant para-
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meters, the Director of Corporate Emergency Operations would activate the Recovery Organization.
Licensoe personnel indicated that a Recovery Operation would be handled similar to other types of project assignments in that a project number would be assigned to this phase of operations accompanied with a description of the engineering work requested, the expertise needed, and the designated I
engineering branch and personnel. A Corporate procedure addressing the Recovery Organization was said to be under development.
Based on the above findings, the 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 procedure to implement the transition from an emergency classification to a recovery mode, including specific criteria
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l upon which the emergency classes will be downgraded and provisions for notifying Federal, State and local officials prior to entering a recovery mode.
(245/82-01-55; 336/82-01-55)
5.4.7 Public Information l
The licensee's procedures for disseminating information to the news media were included in Procedures EPIPs 4102, 4103 and 4104, the basic implementing procedures for the Alert, Site Area and General Emergencies.
The licensee did not have a separate procedure addressing the subject area of public information. The procedures were in the -
form of general action statements for the Manager of Public Infor-mation which were identical in each of the EPIPs. No provisions were made in the procedures for the dissemination of information for a Notification of Unusual Event emergency.
Based on a review of corporate documents and discussions with licensee personnel, the auditors determined that the licensee's concept of operations for disseminating public information is for all contact with the news media to take place through c Corporate representative at the State Media Center in Hartford.
There are no provisions in the Station procedures for briefing news media at the local level.
The Manager of Public Information is responsible for establishing communications with the Corporate representative at the Media Center. The Manager of Public Information works with the Manager of External Communications and other Station emergency managers to prepare and update information for transmission to the Corporate EOC for review and transmission to the Corporate representative at the Media Center.
The procedures did not provide for the initial dissemination of information to the news media prior to the establishment of the Media Center or for responding to public inquiries separate from the news media at the local level.
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a 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:
Develop a specific procedure for disseminating public information
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which describes the information flow process and provides for the initial period o1 time prior to the establishment of the Media Center and for public inquiries separate from the news media.
(245/82-01-56; 336/82-01-56)
5.5 Supplementary Procedures 5.5.1 Inventory, Operational Check and Calibration of the Emergency Equipment, Facilities and Supplies The licensee's procedure, EPIP 4603, " Emergency Radiological Maintenance and Inspection," provided a specific inventory listing of all equipment reserved for use during emergencies and specified the location of this equipment. The frequency at which emergency equipment was to be calibrated was specified in Health Physics (900/2900 Series) Overall Procedures.
The responsibility for the performance of calibration of radiation protection instrumentation was specified in the procedures. The frequency at which emergency equipment was to be inventoried and operationally checked was not specified in the_ procedures. Discussions with licensee personnel revealed that inventories and operational checks of equipment were performed on a monthly basis.
Extra batteries and batteries for lanterns were on a change-out schedule of every six months, however, the batteries were not dated when placed in emergency inventories.
Inventories and operational checks included items other than radiation protection equipment such as calculators, communications equipment, procedures, and miscellaneous supplies.
Responsibility for the performance of emergency equipment inventories and operational equipment readiness checks was not specified in the emergency procedures.
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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Revise Procedure EPIP 4603 to include provisions to specify frequency of inventories and operational checks of emergency equipment; responsibility for the performance of emergency equipment inventories, operational checks, and calibration; and change-out and replacement schedules for items having limited shelf life.
(245/82-01-57; 336/82-01-57)
5.5.2 Drills and Exercises Section 8.2 of The Emergency Plan and Administrative Control Procedures (ACP) 8.02, " Fire Fighting Training Program," ACP 8.06, " Emergency
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Plan Training," and ACP 8.12, " Emergency Plan Drills," specified that drills and exercises would be conducted. The NUSCO Chief, Radiological Assessment Branch was responsible for coordinating the full scale exercise. The Training Supervisor was responsible:for conducting the remaining exercises and drills except for an annual orientation drill of the EOF, which was to be conducted by each Director of Station Emergency Operations.
The proceduras provided for scenario development in advance of the drill, emergency plan training, review of the scenarios, assignment of observers, guidelines for conducting the drills and exercises, critiques, and forwarding the critique items to the Station Services Superintendent for his disposition.
Section 8.3 of the Emergency Plan specified that critique items of drill and exercise deficiencies involving State and local communities will be resolved by the NUSCO Chief, Radiological Assessment Branch.
The Emergency Plan and Procedures ACP 8.02, 8.06, and 8.12 specified the drill and exercise schedules as follows:
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Communications Drill (Monthly with Station and NUSCO Duty Officers, Station emergency organization personnel, towns within the plume exposure pathway EPZ, and State agencies.)
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Fire Drill (quarterly)
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There were also provisions for routinely inviting Federal, State, and local offsite agcncies and groups to participate in the drills and exercises. There were provisions for handling news media coverage of the drills and exercises using the news media facilities, equipment, and procedures that would be used during an emergency.
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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Consolidate into one Emergency Plan Implementing Procedure all
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(245/82-01-58; 336/82-01-58)
5.5.3 Review, Revision, and Distribution Section 8.3 of the Emergency Plan described how the Emergency Plan and Implementing Procedures were reviewed and updated.
Procedure ACP-QA 3.02, " Station Procedures and Forms," described the review, revision, and distribution of the Emergency Plan Implementing Procedures.
Procedure ACP 1.15, " Management Program for Maintaining Emergency Preparedness," specified that the Station Services Superintendent was responsible for the preparation and review of site emergency procedures.
Procedure ACP-QA 3.02 specified a review of implementing procedures at least once every two years, and Procedure ACP 8.12, " Emergency Plan Drills," described how deficiencies observed in drills were provided to the Station Services Superintendent for resolution.
The procedures had been reviewed, approved, and updated as required.
Changes had been distributed in accordance with the approved distribution list.
Telephone numbers had been reviewed at least once every quarter. Names, titles, and telephone numbers in the implementing procedures were correct except for certain minor discrepancies.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.5.4 Audits of Emergency Preparedness The auditors reviewed Section 8.3 of the Emergency Plan and interviewed Corporate personnel responsible for performing emergency preparedness audits. The Technical Specifications require an audit of the Emergency Plan and Implementing Procedures by the Nuclear Review Board (NRB) at least once every two years. This audit is performed for the NRB by the Corporate Quality Assurance Department.
An audit of the MNPS Emergency Plan had been completed in November 1981.
Documents on file showed that the audit included discussions with site personnel as well as inspection of equipment and facilities.
A list of questions had been developed for the audit from the Emergency Plan. Audit findings were documented along with corrective actions taken to close out the findings.
The rule on emergency planning, in 10 CFR 50.54(5), requires a review of the emergency preparedness program at least every 12 months.
The Emergency Plan stated that in addition to the NRB audit, audits are also performed by an independent section of the corporate Radiological Assessment Branch (RAB) at least every 12 months. A review of available records and discussions with licensee personnel l
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indicated that no audits had yet been performed by RAB.
Discussions on audit responsibility and frequency between the QA Department and
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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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Revise the Technical Sp'ecifications to be consistent with the requirements in 10 CFR 50.54(t) that an audit of the emergency preparedness program be done at least every 12 months.
(245/82-01-59; 336/82-01-59)
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6.0 C0 ORDINATION WITH OFFSITE GROUPS 6.1 Offsite Agencies The auditors reviewed the licensee's coordination with State and local response agencies including fire, police, ambulance, and-medical and hospitai organizations. Representatives of those agencies were contacted and letters of agreement in the Emergency Plan, which were dated from July through December 1980, were reviewed.
The auditors verified that the licensee had contacted the appropriate agencies for the purposes of drills, exercises and training and that these agencies had participated in these activities with the licensee. The agency representatives expressed satisfaction with the licensee's support.
The auditors met with the local officials who would be involved in protective action decision making in the early stages of an accident.
The officials indicated that upon receiving the radiopager alert message, depending upon the classification of the emergency, they were prepared to initiate prompt protective action decision-making to include evacuation if necessary.
Waterford, East Lyme and New London have developed and implemented a tri-town emergency plan with Waterford taking the lead and the other two towns providing support. These towns, Waterford in particular, have been upgrading their level of emergency prepared-ness and training their personnel since 1974. The auditors were favorably impressed by the attention to detail and dedication of the local emergency response officials.
Discussions with representatives of the State agencies with the most significant responsibilities in a radiological emergency, i.e., the Office of Civil Preparedness and Department of Environ-mental Protection, and a review of the applicable sections of the State and local emergency plans indicated that the licensee's preplanned protective action recommendations were consistent with those of the State and local response agencies.
However, the auditors noted the potential problems associated with the dual Federal and State emergency classification schemes in use on Connecticut (see Section 5.3 of this report).
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
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Develop a procedure to ensure that letters of agreement with offsite support agencies are reviewed and updated on an annual basis.
(245/82-01-60; 336/82-01-60)
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6.2 General Public The auditors discussed the licensee's public information program with site and Corporate public information personnel.
The licensee maintained an Energy Information Center nearby at which a number of publications were available for the public.
The licensee had prepared a 16 page booklet with a card insert for distribution ta residences within the plume exposure pathway Emergency Planning Zone (EPZ) by means of a mass mail distribution agency.
l The booklet entitled, "What To Do In An Emergency," covers steps to I
be taken in case of a nuclear power plant emergency, means of notification, and protective actions that may be necessary. The i
booklet also contained information on what to do in other types of emergencies such as a fire, tornado, flood, and winter storm.
The card insert was different for each community within the plume exposure EPZ and included information on notification, Emergency Broadcast System stations, evacuation routes, and telephone numbers for assistance and additional information. The booklet provided only minimal information on radiation and did not include a map showing the plume exposure Emergency Planning Zone (EPZ) and evacuation
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routes.
The booklet had not yet been distributed to the public.
Licensee representatives stated that the distribution of the booklet including information for transient populations was to coincide with the installation of the siren system which was expected to be operational by June 1982.
The licensee also planned to send representatives to public meetings within the plume exposure EPZ to present emergency planning information.
The auditors viewed a slide program on emergency planning and the new siren system which the licensee had prepared as part of the public information program.
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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Disseminate emergency planning information to the public including transient populations within the plume exposure pathway Emergency Planning Zone.
(245/82-01-61; 336/82-01-61)
6.3 News Media The auditors discussed the licensee's program for familiarizing the news media with emergency planning with site and Corporate personnel.
The Emergency Plan contained very little information on this subject.
The licensee had prepared a package of information which had been distributed to members of the news media. The auditors reviewed this literature and found that it included information on emergency planning, points of contact for release of public information,
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information about radiation, normal plant operation, and possible accident sequences.
In addition, the licensee had an established program for briefing media personnel and providing them nuclear plant tours during refueling outages and at other times..The-licensee had given a briefing to representatives of the news media in November 1981.
Based on the'above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
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Revise the Emergency Plan to include, or make reference to, the media education and familiarization program including a description of the program and program-responsibility.
(245/82-01-62; 336/82-01-62)
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7.0 DRILLS, EXERCISE AND WALK-THROUGHS 7.1 Drill and Exercises Program Implementation Licensee personnel provided the auditors with records of drills and exercises that had been conducted during 1981. The auditors reviewed the records and noted that the following required drills and exer-cises (see Section 5.5.2 of this report) had not been conducted:
Health Physics Drill, Radiological Monitoring Drill, Post Incident Sampling Drill, and three of the EOF Orientation Drills. A Training Coordinator stated that the portion of the Emergency Monitoring Team training in which the trainees demonstrated the field use of radiation monitoring instruments and air sample equipment had been considered as meeting the requirements for Health Physics and Radiological Monitoring Drills. The Training Coordinator also stated that only air samples had been obtained during the training.
A review of the records for the drills that had been conducted showed that critique sheets and drill descriptions had been prepared.
The critiques identified items requiring improvement and, according to memorandums and licensee representatives, the identified defi-ciencies had been addressed.
Licensee representatives stated that the Post-Incident Sampling Drills were not conducted due to the lack of a sampling system. The auditors concluded that the deft-ciency. evident in the administration of the licensee's drill program was related to the lack of an integrated emergency plan training program with a central administrator (see Section 3.1 of this report).
Based on the above findings, improvement in the following area is required to achieve an acceptable program:
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Improve management controls to ensure that all required drills and exercises are performed and properly documented as speci-ficd in the Emergency Plan and Implementing Procedures.
(245/82-01-63,336/82-01-63)
7.2 Walk-Through Observations 7.2.1 Emergency Detection (EAL Recognition) and Emergency Classification The auditors conducted walk-throughs in both Unit 1 and Unit 2 Control Rooms with Shift Supervisors on several different shifts including back shifts. The Shift Supervisors have the responsibility and authority to initially function as the Director of the Station Emergency Operations until relieved by the on-call Director of SEO.
Thus, the Shift Supervisors hold a critical position in the emergency organization.
The auditors presented various postulated accident scenarios to the Shift Supervisors of each unit. The following scenario is an example of one of the scenarios presented during the walk-throughs:
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Assume that an-event has occured at 4 a.m. with minimum shift complement. The reactor vessel level is holding and the containment isolated except for one backup valve indicating
'that it had failed open. Control Room personnel were instructed that they had the following parameters:
(1) containment radiation level:
500-1000 R/hr, (2)
incore thermocouple:
700 F, (3) SBGTS working and station vents isolated, (4) the SBGTS vent monitor is reading 100 cpm, (5) containment pressure:
42 psig, and increasing, (6) containment spray working, (7) containment temperature:
180 F, (8) -suppression pool level normal; suppression pool temperature increasing, and (9) there appeared to be a mechanical malfunction problem with essential service water cooling pumps.
The Shift Supervisors assessed the situation and, after discussing their response to the operational requirements of the plant, went to the appropriate operating procedure for classifying an emergency; i.e., OP 501, " Incident Assessment and Classification - Unit 1,"
and OP 2501, " Incident Assessment and Classification - Unit 2."
In the licensee's procedural arrangement, the EALs for classifying emergencies are contained in the aforementioned ops which are considered part of the Emergency Plan Implementing Procedures.
ops 501 and 2501 refer to EPIPs 4101 through 4104 for implementing i
instructions for each of the emergency classes.
In general, the Shift Supervisors demonstrated that they were proficient in using the EALs to classify the postulated events. A primary reason for this is that the EALs were developed by persons experienced in control room operations.
The auditors had some comments on the EALs (see Section 5.3 of this report).
Several of the Shift Supervisors thought the procedures could be improved by presenting the EALs in a one page flow chart format rather than in several pages of tables.
One Shift Supervisor had difficulty with the dual NRC and Connecticut emergency classification schemes incorporated in ops 501 and 2501.
Other Shift Supervisors indicated that the use of a single emergency classification scheme would be an improvement.
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7.2.2 Notifications The radiopager system in the MNPS control room is the principal means for notifying local and State officials and key licensee personnel of an emergency at the plant. The system is operated by the Shift Supervisor's Staff Assistant (SSSA) in an emergency. At the request of the auditors, a special demonstration of the radio-
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pager notification system was arranged by licensee personnel. A test message was put out by the SSSA on a back shift to the Connecticut Department of Environmental Protection and the Town of Waterford.
The call backs to the plant came within one minute of transmitting the message over the radiopager system.
The on-call DEP duty officer indicated that within 15 minutes of being notified, their organization could be activated and ready to initiate protective action decisions.
The dispatcher for Waterford indicated that upon receiving the alert, he would notify the First Selectman and standby to implement his instructions. This would take but a matter of minutes and would possibly be initiated prior to State notification of local officials.
7.2.3 In plant and Site Boundary Monitoring The auditors conducted practical drills in two areas: activation and performance of Emergency Monitoring Team 1 (EMT 1) and activa-tion and performance of Emergency Monitoring Team 3 (EMT 3).
EMT 1 was responsible for the assessment of control room habitability, initial in plant monitoring, and search and rescue.
EMT 3 was responsible for the determination of radiological conditions at the site boundary. Both drills included the team's verification of emergency kit contents and equipment operability, assessment of ambient radiological conditions, and reporting of data to the appropriate responsible authorities.
The practical drill for EMT 1, conducted on a back shift, was initiated by selecting two Health Physics technicians designated as qualified EMT members and establishing a scenario (Unit I had declared a Site Emergency and the evacuation alarm had sounded.
It was on the back shift and tl;e HP technicians were assigned to Unit 1 and to Unit 2 respectively. What do you do?) Both EMT members proceeded immediately to the Unit 1 Control-Room and opened the EMT.1 emergency kits located there. The kit was stocked as indicated in the Emergency Plan. The EMT members removed the EMT 1 procedure from the kit (EPIP 4203) and proceeded to follow it step by step. Record forms were removed from the kit and documentation of the team activities commenced.
Instrumentation was removed and functionally tested. Communication radio was procured and a radio check completed.
Since the control room PING continuous air monitor was not operational, particulate and radioiodine air sampling was initiated using the portable equipment from the emergency kit as prescribed by the EMT 1 procedure.
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The EMT 1 procedure instructed the team to " perform the air sample in accordance with Procedure EPIP 4207, " Radiological Sampling During an Emergency." This referenced procedure, however, instructed the team to evaluate the air sample using a single channel analyzer (PS 2-2) counting instrument, which was not available in the emergency
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This discrepancy caused some confusion to the team until they decided to evaluate-the air sample using the count rate' instrument available in the kit.
The team members were familiar with the instruments and procedure and appeared competent to perform their assigned emergency.respone duties. Ambient radiological conditions were assessed and information prepared for presentation to the Control Room Shift Supervisor. The team members stated that-they would then be ready for assignment to other emergency activities as required by the Shift Supervisor.
The practical drill for EMT 3, conducted on a Saturday, was also
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initiated by selecting two Health Physics technicians designated as qualified EMT members and establishing a scenario (Unit I had declared a site emergency, you were on call, assigned to EMT 3 and had been notified to report. What would you do?) Both EMT members left the site immediately, took one of their personal. vehicles and reported to the EOF.
Simulating the direction of the Manager of-Radiological Consequence Assessment, the team members opened the emergency cabinets and the EMT 3 kit. The kit contents were as indicated in the Emergency Plan. The team members removed the EMT 3 procedure (EPIP 4205) and proceeded to follow it step by step.
Contents of the kit was verified, instrumentation was func-tionally checked, and a two-way radio and spare battery were procured and checked for operation.
The team then' loaded the kit into their personal car and proceeded to a predesignated site boundary location.
In transit, ambie.nt dose rates were measured. At the site boundary, a particulate and.radiciodine air sample was then taken'using a battery operated portable air sample.
Upon completion of the sampling, data was simulated as being communicated to the Manager of Radiological Consequence Assessment at the EOF as required by procedure. The air sample filter and cartridge were then stapled to the data sheet for return to the EOF.
The air sample data prepared for transmission to the EOF _was in corrected counts per minute (gross sample CPM minus background), not an air activity concentration.
The team members indicated that this method was as required by the procedure and precluded field errors in calculations.
The EMT members were familiar with the instrumentation and procedure and appeared competent to perform their assigned emergency response duties.
7.2.4 Post-Accident Liquid Effluent Sampling The auditors conducted a walk-through of the licensee's liquid effluent sampling system for Unit 2.
A scenario was established and given to one of the on-call chemistry technicians. The auditors accompanied the individual, made observations, posed questions and discussed the procedures.
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.The individual was provided dosimetry and a hand-held dose rate instrument.
Protective clothing was used while the sample was taken. The chemistry technician allowed the sample line to drain with a distilled water line flushing the liquid effluent down a drain. A one milliliter sample was collected for later dilution in the analysis facility. The technician indicated to the auditors that special consideration such as self-contained breathing apparatus were not. general knowledge. Based on the observations during the walk-through, it was evident that the chemistry technician was well trained for liquid effluent sampling except for self-contained breathing apparatus training.
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Individuals Contacted L. Bettencourt, First Selectman, Waterford P. Blasio11*, Licensing Engineer (Corporate)
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J. Bohan,' Security Shift Supervisor R. Brisco*, Supervisor, Radiological Protection Section (Corporate)
T. Burns, Chemistry Technician l
D. Butter, Building Services Supervisor T. Calzetta, Electrician (EMT Member)
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K. Carlson, Health Physics Technician L'. Chambers, Health Physics Technician A. Cheatham*, Radiological Services Supervisor
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l D. Clark, Shift Supervisor
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C. Conklin, Station Technician J. Corbett, Health Physics Technician
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R. Crandall, Supervisor, Radiological Engineering Section (Corporate)-
L. Crocker, Security Shift Supervisor J. Currier, Health Physics Technician B. Darr, Health Physics Technician T. Dembeck, Civil Preparedness Director, Waterford L. Donovan, Health Physics Technician G. Doughty, System Manager, Nuclear Information and Media Services (Corporate)
E. Farrell*, Station Services Superintendent M. Gelinas, Security Shift Supervisor C. Gilbert, Training Supervisor B. Granados, Health Physics Supervisor R. Griswold, Supervisor Stores R. Haynes, Training Coordinator J. Heg, Operations Assistant
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R. Herbert, Superintendent Unit 1 A. Heubner, Department Environmental Protection C. Hill, Nuclear Information Supervisor M. Hyde, Health Physics Technician J. Kangley*, Chemistry Supervisor J. Kelley*, Superintendent Unit 2 W. Kerr, Mechanic (EMT Member)
E. Laine*, Health Physicist R. Langer, Chemistry Foreman E. Lambert, Officer Supervisor R. Lougee, First Selectman, Easc Lyme L. Loomis, Shift Supervisor Staff Assistant M. Machado, Station Nurse F. Matovic, Health Physics Technician D. Miller, Radiation Program Engineer (Corporate)
K. McCarthy, Department of Environmental Protection
'E. Mroczka*, Station Superintendent D. Nordquist,' Supervisor-Design & Operation QA (Corporate)
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Denotes those also present at exit meeting.
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J. Opeka*, Vice President, Nuclear Operations (Corporate)
A. Olechnowicz, Supervising Control Operator D. Peabody, Fire Marsnall, Waterford J. Perkins, Chief of Police, Waterford P. Prizekop, Senior Engineer R. Reading, Health Physics Technician
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T. Ricketts, Health Physics Technician R. Rodgers, Manager Radiological Assessment Branch (Corporate)
W. Romberg, Operations Supervisor, Unit 1 S. Scace, Operations Supervisor, Unit 2-R. Schleicher, Assistant I&C. Supervisor R. Schmidtknecht, Shift Supervisor D. Stump, Training Coordinator R. Walker, Shift Supervisor R. Welzant, Training Coordinator A. Weber, Shift Supervisor D. Wilkens, Chemistry Foreman D. Wright, Shift Supervisor G. Zitka, Supervising Control Operator i
Denotes those also present-at exit meeting.
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- ?p* '84 UNITED STATES
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NUCLEAR REGULATORY COMMISSION j
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nine or esiussia. nennsvi.vAme A is es
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FEB 4 1982
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Docket Nos. 50-245
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50-336 CAL 82-02
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Northeast Nuclear Energy Company ATTN: Mr. W. G. Council Senior Vice President
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P. O. Box 270 Hartford, Connecticut 06101 Gentlemen:
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This lotter refers *a a meeting between Mr. J. F. Opeka, Vice President Nuclear Operations, and otSe.s of your staff, and Mr. F. Kantor, Headquarters NRC, and other members of the NRC Emergency Preparedness Appraisal Team which was held at the Millstone Nuclear Power Station on January 14, 1982, and to a telephone conversation between Mr. E. C. Farrell, Station Services Superintendent and Mr. Gary L. Snyder, Chief, Emergency Preparedness and Program Support Branch, on February 1,1982. With regard to the matters relating to emergency preparedness discussed, we understand that you will undertake and complete the following actions:
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1.
Revise your emergency organization to provide 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 revised l
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.
This will be accomplished no later than March 1, 1982.
2.
As a collateral effort to Item 1, develop lists of personnel trained and t
qualified to perform the tasks associated with each functional area specified within the revised emergency organization.
These lists shall identify *.he current training status of each individual, and provisions to maintain the lists current shall be develo;,d and implemented.
This will be accomplished no later than March 1, 1982.
3.
Pursuant to the requirements of the generic letter dated February 18, 1981 to all licensees from Mr. D. Eisenhut, NRR, regarding the minimum staffing requirements for nuclear power plant emergencies, a study shall be performed to determine how the augmentation of the onshift staff can be achieved within the 30 and 60 minute goals of NUREG 0654, Table B-1, after the declaration of an emergency.
The results of this study will be documented and forwarded to the NRC Region I office for review and evaluation along with a description of compensatory measures for any augmentation goals not met.
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FEB 4 1982
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This will be accomplished no later than March 1, 1982.
4.
Estabitsh an integrated emergency plan training / retraining program to ensure that:
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Lesson plans are developed and training is accomplished for each functional area of emergency activity, including emergency repair /
corrective actions, search and rescue, radiation protection during emergencies, and radwaste operations.
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Members of the emergency organization are trained in any pertinent changes to procedures or equipment which occur between scheduled training sessions.
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Training is documented and records are properly maintained in a systematic manner.
This will be accomplished no 1ater than April 1, 1982.
5.
Establish a Technical Support Center (TSC) for Unit 2, which provides on an interim basis until a permanent TSC can be established which meets applicable regulatory criteria, adequate working space for assigned personnel and which alleviates potential crowding in the control room.
Describe in the Emergency Plan the division of technical support functions between the TSC and Emergency Operations Facility (EOF) for Units 1 and 2, and indicate the functional areas of emergency activity to be performed at each technical support function location.
Develop implementing procedures for activating and staffing the TSC.
This will be accomplished no later than March 1, 1982.
6.
Establish an Operational Support Center (OSC) with sufficient space for assigned emergency response perstonel to assemble in the event of an emergency, anet which includes communications, protective equipment and supplies needed for the performance of emergency activities that may be required of personnel gathered in the OSC.
Describe the location of the OSC in the Emergency Plan and develop implementing procedures for activating and staffing the OSC.
This will be accomplished no later than March 1, 1982.
7.
Expedite the development of procedures and training on the post-accident j
sampling systems presently being installed to ensure that the systems l
are fully operational in the minimum amount of time.
Provide a status report and schedule for these activities to the NRC Region I office.
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This will be accomplished no later than March 1, 1982.
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FEB 4 1982 8.
Perform a radiological analysis which demonstrates that liquid and gaseous effluent samples can be obtained under postulated accident conditions and develop specific detailed procedures for obtaining such samples.
This will be accomplished no later than March 1, 1982.
9.
Develop specific detailed procedures anci training for chemistry personnel foe the analysis of primary coolant containing high levels of radio-activity, containment air, and liquid and gaseous effluent samples in the chemistry laboratory.
The procedures will be completed no later than March 1, 1982~.
Training will be accomplished no later than April 1, 1982.
10.
Develop detailed organization and procedural methods for implementing a radiation protection program for emergency response personnel which provides for the continuity of critical radiation protection procedures and functions during postulated accident conditions.
This will be accomplished no later than March 1, 1982.
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Improve management controls to ensure that all required drills and l
exercises are performed and properly documented as specified in the l
Emergency Plan and implementing procedures.
This will be accomplished no later than April 1,1982.
12.
Propose a plan of action to establish consistency between your emergency classification and emergency action level scheme, and those of local and State emergency response organizations, in accordance with the criteria of NUREG-0654, Appendix 1.
This will be accomplished no later than February 3, 1982.
In addition to the above action, please inform this office in writing when 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 H. W. Crocker of 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 />.
Your cooperation with us on this matter is appreciated.
Sincerely,
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nald C. Haynes egional Administrator
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FEB 4 1982 cc:
J. F. Opeka, Vice President, Nuclear Operations E. J. Mroczka, Station Superintendent D. G. Diedrick, Manager of Quality Assurance R. T. Laudenat, Manager, Generation Facilities Licensing Public Document Room (POR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of Connecticut bec:
Region I Docket Room (with concurrences)
Brian K. Grimes, Director, EP, IE I
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