IR 05000282/1981020
| ML20039B274 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 12/16/1981 |
| From: | Axelson W, Paperiello C, Patterson J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20039B271 | List: |
| References | |
| 50-282-81-20, 50-306-81-22, NUDOCS 8112220482 | |
| Download: ML20039B274 (49) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-282/81-20; 50-306/81-22 Docket Nos. 50-282; 50-306 Licenses No. DPR-42; DPR-60 Licensee: Northern States Power Company 414 Nicollet Hall Minneapolis, MN 55401 Facility Name:
Prairie Island Nuclear Generating Plant Inpsection At:
Prairie Island Plant Site, Red Wing, MN Inspection Conducted: November 2-7 and 9-13, 1981
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Inspectors:
. L. Axelson Team Leader Ob [I/fN P. P t n
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/1 [/s- !P/
Approved By:
W.
e son, hief Emergenc Preparedness Section l
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.J Pa e lo, Chief f
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ergency Preparedness and Program Support Branch
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Inspection Summary Inspection on November 2-7 and 9-13, 1981 (Reports No. 50-282/81-20; 50-306/81-22)
Areas Inspected: Special announced appraisal of the state of onsite emergency preparedness at the Prairie Island Nuclear Generating Plant involving seven general areas: Administration of the Emergency Pre-pareduess Program; Emergency Organization; Training; Emergency Facilities and Equipment; Procedures Which Implement the Emergency Plan; Coordination with Offsite Agencies; and Exercises and Drills. The inspection involved 408 inspector hours onsite by two NRC inspectors and two consultants.
Results: No items of noncompliance or deviations were identified; however several significant findings were identified in the areas of prompt public
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notification, emergency implementing procedures, and meteorological equipment.
8112220482 811217 PDR ADOCK 05000282 O
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1.0 Administration of Emergency Plan (1.1, 1.2, 1.3 and 1.4)
At the site, the Plant Manager serves as the Emergency Director, and has the prime responsibility and authority during an emergency. He can immediately initiate any emergency actions including protective action recommendations to those responsible for implementing offsite emergency measures. His counterpart at the corporate level is the Emergency Manager.
A line of succession, by title, is established to succeed the Plant Manager including as first alternate, the Plant Superintendent, Engineering and
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Radiation Protection-The site Emergency Planning Coordinator (EPC) is the Superintendent, Radiation Protection. He delegates most of these functions, including the development and updating of the Prairie Island Emergency P3.an and implementing procedures, to the Senior Production Engineer. The Super-intendent, Radiation Protection, also serves as the Radiological Emergency Coordinator who functions as part of the Plant Emergency Response Organ-ization and reports to the Technical Support Center (TSC) when it is activated.
At the corporate level the Manager, Environmental Services, serves as the Emergency Planning Coordinator. His emergency organizational i
title is the Administrator-Emergency Preparedness. His authority for this function was delegated in a letter (March 1980) from the General Manager, Nuclear Plants, to all corporate level managers.
Plans and procedures at both the corporate and site level interface as the inspector's reviews indicated. Also, there are some jolnt training sessions held which involve both licensee entities. However, professional training courses have not been proviaed for corporate and site Emergency Planning Coordinators.
In previous drills and practice drills, parts of both the corporate Headquarters Emergency Center (HQEC) and the site's Technical Support Center (TSC) have been activated as well as other facilities at each location depending on the nature of the practice exercise or drill.
Selection criteria for emergency organization members are established largely by management decision and job qualifications. Through procedural reviews and direct interviews the inspectors determined that those chosen at the management and administrative levels are qualified.
Based upon the above findings, this portion of the licensee's program is adequate. However, the following item should be considered for improvement:
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i Professional training coarses should be provided for corporate and site
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Emergency Planning Coordinators.
1.5 Quality Assurance of the Emergency Preparedness Program The corporate administration has developed a surveillance program which includes procedures to assure that independent audits of emergency re-sponse facilities and procedures are made at specific intervals.
Individuals responsible for these audits from the corporate office report to corporate level management that is independent of those involved in j
emergency preparedness at either location.
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A formal Quality Assurance Program has not yet been established. A decision will be made by corporate management prior to the date for the first independent audit requirement, (April 1, 1982, 10 CFR 50.54(t))
whether to contract the audit out or perform it within the organization.
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When initiated this audit will be documented, reported to appropriate management, and retained for five years.
Based on the above findings, this portion of the licensee's program is adequate.
2.0 EMERGENCY ORGANIZATION
2.1 Onsite Organization The emergency onsite organization is described in Section 5.0 of the Plan which includes both a functional and an onsite emergency organization chart.
These two charts are attached to this report as Figure 1 and Figure 2.
Upon review the inspector concluded that the position descriptions and the organizational charts were adequate from both a management and a functional standpoint.
The Duty Shift Supervisor of the unaffected unit assumes the responsibility of the Emergency Director (ED) at the onset of any emergency condition.
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When the designated ED arrives, the Shift Supervisor is relieved of the ED responsibility. Through interviews and discussions with the Emergency Director, three Shift Supervisors, the Radiological Emergency Coordinator, two OSC Coordinators, two TSC Coordinators, t'e Shift Emergency Communicator n
and the Supervisor, Security and Services, the inspectors concluded that these emergency management personnel were qualified, knowledgeable and
competent in their assigned emergency response fractions.
The Emergency Plan Implementing Procedures (EPIP's) provide for the Emergency Director to serve as an overall emergency coordinator who is available onsite at all times. He is equipped with a radio pager. His authority and responsibility are passed down to the next individual in the line of succession, along with the radio pager, when he is unavailable.
However, certain types of responsibilities cannot be delegated to others by the Emergency Director. These include the recommendation of protective actions to State and local governmental units.
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Selection criteria are established for individuals who serve functional areas in the emergency organization on the basis of job description, qualifications, management designation and, for the Radiation Protection Specialists, by ANSI Standards.
Based on the above findings, this portion of the licensee's program is adequate.
2.2 Augmentation of Onsite Emergency Organization The following corporate emergency response personnel were interviewed by the inspection team:
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Emergency Manager (4)
Recovery Manager Administrator Emergency Preparedness Assistant Administrator Emergency Preparedness Environmental and Regulatory Activities Department (ERAD) Manager These individuals plus one E0F Coordinator interviewed at the training center demonstrated to the inspectors that they were competent, knew their functions and could perform as required in an actual plant emergency.
Both the corporate and the site plans include provisions for supplementing the radiation protection and monitoring. program if accident conditions con-tinue beyond 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Corporate authority to activate this support is through the Power Production Management, specifically the Senior Vice President, Power Supply. He relays corporate policy decisions through the Corporate Emergency Organization. The contractor, Westinghouse, is specified in the cornorate plan as being the prime vendor who could respond for assistance if requested by the Emergency Manager. Fluor Power Services as the architect engineers is also specified in Corporate EPIP 1.1.1.4, Revision 2.
Letters of Agreement have been completed with these vendors, a laboratory services organization, State and local governmental agencies, and five police and medical support organizations. One letter signed by Fluor Power Services, Inc., should be more specific in responsibilities and limits on actions by that organization in providing support services to the licensee.
To help assure notification of key emergency response personnel needed to augment shift staffing, a radio receiver has been placed in the homes of approximately 45-50 NSP employees. This is part of the Radio Alert System which includes a transmitter in the TSC which initiates the announcement.
The transmission system at the TSC consists of:
(1) Message recorder (2)
Message transmitter (3) Microphone (4) Telephone Answering Unit (5) Tele-phone (6) Code Selector. The receiver in the employees' homes includes a light which blinks when the message is not received directly by a person answering the call. A recorded message is given when the person activates the radic receiver.
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The licensee has demonstrated, through a drill using a telephone call system with documentation of time required for the person to reach the site, that minimum staffing can be accomplished as required by Table B-1 of NUREG-0654.
Currently, the licensee has the following minimum shift staffing:
two SR0s, one for each unit
three Control Room Operators
three Auxiliary Operators
one Dedicated Shift Emergency Communicator
one Radiation Protection Specialist
one STA This makes a total of eleven emergency response workers available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day for two unit operation. Another dedicated Health Physics trained individual for emergency inplant surveys is still needed. The current-4-
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emergency plan does not reflect this capability. Once the Emergency Plan is revised to reflect the above capability, and a dedicated, trained in-dividual for emergency inplant surveys is available, the inspector shall deem the minimum shift staffing as meeting the regulatory positions of Table B-1 of KUREG-0654.
The Plan has to be revised to specify that the EOF Coordinator is avail-able within one hour to partially activate the EOF which would include followup notifications to offsite agencies prior to the arrival of the Emergency Manager. The inspectors have confirmed that this position is
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available and will be utilized.
Based on the above findings this portion of the licensee's program is adequate. However, the following item should be considered for improvement:
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The letter of agreement for Fluor Power Service, Incorporated, should be
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changed to include more specific terminology regarding responsibilities.
3.0 TRAINING / RETRAINING 3.1 Program Establishment The licensee has a formally documented and approved emergency plan training /
retraining program. This program is specified in EPIP 1.2.1, Emergency Plan Training, and further described in an Emergency Plan Training Program document issued in October 1981. Criteria for instructor qualifications are defined.
The training / retraining schedule is specified on an annual basis. The emer-gency training categories are designed to address each emergency procedure.
Offsite support personnel (i.e., sheriff, fire department, and ambulance personnel) are invited annually by the licensee to participate in the onsite familiarization / training program.
In addition, other local and state agency personnel are invited to attend seminars'
News media are
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also invited to attend emergency preparedness seminars and participate in exercises. Approved formal lesson plans are established for each
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training category, have performance objectives, adequate records and specially designed viewgraphs for presentations. The training program l
includes classroom lectures and hands-on training for special instruments, kits and equipment.
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Radiological condition changes that might be encountered during postulated emergencies are given. Communications are described and practiced. Organ-ization, responsibilities and authorities are also covered in the emergency training program.
Red Cross Multi Media training is given by a Red Cross Instructor. Training for non-licensee augmentation personnel (e.g.
contractors, radiation techni-cians, vendors, etc.) would be given prior to their assignment of duties, or else they would be escorted continuously.
When changes are made to the emergency plan or procedures, a routing of such changes is made to all members of the emergency organization. They are asked to read and understand all changes, and acknowledge their understanding via-5-
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sign off on the routing slip. This interim training technique is used between the required annual training sessions to assure that members of the emergency organization are aware of all program changes.
Based upon the above findings, this portion of the emergency preparedness program is adequate.
3.2 Program Implementation The inspectors reviewed the training records and found that training and examinations had been completed as required. Walkthrough discussions were conducted with station emergency organization directors (and alternates),
security personnel, shif t supervisors, radiation / chemistry technicians, engineers and health physicists. These walkthroughs demonstrated that the licensee personnel had been provided emergency training and understood their emergency functions.
Based upon the above findings, this portion of the licensee's emergency preparedness program is adequate.
4.0 Emergency Facilities and Equipment 4.1 Emergency Facilities 4.1.1 Assessment Facilities 4.1.1.1 Control Roem The inspectors reviewed control room emergency preparedness. The control room had updated copies of the Emergency Plan and Implementing Procedures.
Emergency communication equipment consisted of a dedicated intercom system, portable radios, plant telephone and dedicated telephone systems. There is a common control room for both units. The control room contained sufficient instrumentation and equipment to permit evaluation of the magnitude and potential consequences of emergency situations with the exception of certain RG 1.97 parameters.
Based on the above findings, this portion of the licensee's program is adequate.
4.1.1.2 Technical Support Center (TSC)
The inspectors examined the TSC and associated equipment and procedures.
The TSC is in a state of near completion with the ventilation system and Safety Parameter Display System (SPDS) yet to be installed. The TSC is located on the fifth f1Bor of the Administration Building approximately 30 seconds walking time from the Control Room and OSC.
The TSC is equipped with dedicated telephones (including the HPN and ENS),
plant telephones, radios, an inplant intercom system, and a Radio Alert Communication system that is independent of telephone communications. The Radio Alert system provides prompt notification of NSP emergency response personnel via a recorded message broadcast to a receiver in their homes.
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The TSC is equipped for radiological monitoring and protection. Supplies included potassium iodide, G-M and ion chamber survey instruments, an area radiation monitor, a continuous air monitor, dosimeters, two Scott Air Packs, and anti-contamination clothing.
Plant Technical Specification, Emergency Plan and Implementing Procedures, Plant Operating Procedures, Schematics, maps, and Final Safety Analysis Report were available.
All other aspects of the TSC were adequate, except for the total amount of floor space available in the TSC. NUREG-0696 requires the TSC to provide at least 75 square feet per person for at least 25 people. The current TSC provides space for a maximum of 16 people according to this criterion.
Furthermore, the current allocation for NRC personnel is adequate for only-two people, instead of the required three. The licensee has no current plans for expanding the TSC. This matter was brought to the attention of the Emergency Preparedness Development Branch.
Based on the above findings, this portion of the licensee's program is an open item pending completion of the TSC in accordance with the position of NUREG-0696.
4.1.1.3 Operations Support Center (OSC)
The inspectors evaluated the licensee's OSC for compliance with NUREG-0654
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and NUREG-0696. The OSC is located immediately adjacent to the reactor I
control room and is equipped with two plant telephones and a dedicated inplant intercom system for communication. The licensee intends to install one additional plant telephone.
In an emergency situation, direct voice communication with the control room would be used to augment these tele-phone communication links. An emergency supply cabinet in the OSC contained adequate supplies of survey instrumentation, air sampling equipment, protective clothing, high range dosimeters, and first aid kits.
The locker also contained one battery powered flood light for emergency lighting purposes and a hand held portable radio. However, no fixed emergency lighting was provided in the OSC. The licensee has made adequate provision for evacuation of the OSC in the event of high radiation levels.
Based on the above findings, this portion of the licensee's program is adequate. However, the following item should be considered for improvement:
The OSC should be equipped with fixed permanent emergency lighting.
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4.1.1.4 Emergency Operation Facility (EOF)
The inspectors examined the interim nearsite E0F and reviewed the licensee's plans for a permanent nearsite EOF. The interim EOF is located approximately ten miles southeast of the plant site in a large basement room in the Sterling Motel in Red Wing.
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The interim EOF is equipped with dedicated telephone lines, (including the HPN and ENS), plant phones, several Minneapolis extensions, an inplant in-tercom that permits direct communication with the TSC, Control Room and OSC, and a radio base station for communications.with offsite survey teams.
Equipment for radiological monitoring and protection included an area radiation monitor, G-M and ion chamber survey instruments, a decontamination kit, dosimeters, air sampling equipment (including silver zeolite cartridges)
and a sealed offsite survey kit.
Documentation in the EOF included current copies of the Plant Emergency Plan and Implementing Procedures, site and local maps, State and local Emergency Plans and Implementing Procedures, and a copy of the plant's FSAR. A set of plant Technical Specifications, plant layout drawings, schematics, and diagrams is maintained in the Training / Construction Building and would be delivered to the EOF according to procedures.
The permanent nearsite EOF is under construction as part of a new training facility located approximately 1/2 mile northeast of containment. This facility is scheduled for completion in the summer of 1982. Plant data acquisition systeras for the permanent EOF, such as the Safety Paramenter Display System (SPDS) and other RG 1.97 parameters are still under development.
The Headquarters Emergency Center (HQEC) will serve as the backup EOF. The HQEC is located 20 miles from the plant site, but will be provided with i
duplicate plant data acquisition systems.
Based on the above findings, this portion of the licensee's program is an open item pending completion of the nearsite EOF.
4.1.1.5 Post Accident Coolant Sampling and Analysis The inspector examined the licensee's permanent post-accident primary coolant sampling facilities and equipment to determine if a representative pressurized and unpressurized sample could be obtained and analyzed within three hours as per NUREG-0737. The inspectors conducted a walkthrough with two Radiation Protection Specialists (RPS). Simulated accident conditions with significant core damaga were assumed.
Both RPS technicans followed appropriate health physics precautions. Actual pressurized and unpressrrized samples were collected and analyzed.
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The current permanent sampling facilities for unpressurized samples do not meet the regulatory positions in NUREG-0737. Unshielded primary coolant lines are located in the sampling fume hood. Dose rate calculations by the inspectors indicated levels greater than 20 rems per minute assuming a source term of 10 curies per gram as per NUREG-0737. Further, no provision for back flushing of these lines is provided.
The licensee used a much smaller source term (0.1 curies per gram) as the basis for their shielding calculations. The licensee believed they could take credit for dilution from a Safety Injection. This assumption is i-8-l
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incorrect because several accidents resulting in core damage can occur as
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a result of Icas of High Pressure Safety Injection (i.e., small break LOCA).
This matter was brought to the attention of NRR.
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As a result of this finding, the licensee is re-evaluating dose calcula-tions using the NUREG-0737 source term. They believe additional shielding and relocation of the primary coolant lines will be necessary. These modifications, including shielding, can be completed by January 1, 1982, in accordance with the post TMI schedule. The licensee will have available
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technical documentation indicating that these modifications will meet the criteria of NUREG-0737. This area is an open item.
The inspector's examination and observation of the pressurized sample collection equipment indicated that adequate facilities are in place.
The walkthrough of this system indicated that an adequate level of training in equipment use has been implemented. The systems consist (Units I and 2) of custom built Beckman Instruments. They provide for hydrogen analysis by thermal conductivity and the capability to obtain a gas grab sample for isotopic analysis. The gas grab sample can be diluted with a fixed volume of nitrogen. Back flushing of the system
is provided. All vents are directed to a treated fume hood exhaust.
All drains are directed to the RHR sump and pumped back into containment.
Isotopic analysis of the diluted gas sample can be conducted onsite or
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offsite in a trailer based mobile counting room.
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The interim post-accident unpressurized samples can be collected by using a specially made manipulator. However, the RPS's indicated that this system requires too much time in a high radiation field and in all likelihood, would not be used. Specially made reach rods would be used to obtain a
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sample instead of the manipulator. An area radiation monitor (ARM) is
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located in the sample area. However, the monitor can not be easily read in the sample area due to obstruction by overhead ventilation equipment.
Af ter collecting the unpressurized sample, it will be placed in a 1-1/2" lead shielded pot, which is capable of hand transport to a large shielded two wheel cart. The sample is then transported to a hot cell located in the lower level turbine building.
Sample dilution will take place in the hot cell. Provisions for pH, chloride and boron analysis are provided.
Based on the above findings, this portion of the licensee's program is adequate for limited core damage accidents.
Because full implementation i
of NUREG-0737 Catagory B items is not completed due to improper design assumptions, this area is an open item.
The following matter should be considered for improvement:
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Relocate the sampling area ARM for use during post-accident conditions
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to ensure that the sampling team can visually read the radiation levels.
Provisions for alarm silencing should also be provided for this ARM.
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4.1.1.6 Containment Air Sampling and Analysis The inspectors examined the post-accident containment air sampling and analysis equipment to determine if they meet the regulatory positiona of NUREG-0737. The systems (Units 1 and 2) consist of gas sampling of the exhaust of the installed Westinghouse Containment Gas Analyzer. The sample collection bomb has been relocated to a lead shielded enclosure in the sampling room. Hydrogen analysis of the containment gas is done with ac installed gas analyzer using thermal conductivity. Provisions have not been made to allow for purging of the sampling lines back into the affected containment or waste gas system. No inline monitoring capability to perform radioiodine or particulates exist for accident conditions. -The existing containment inline monitors isolate on con-tainment isolation. All containment accident monitoring is by gas grab sample collection and analysis. Noble gas determination can be estimated by use of the high range area radiation monitors, which will be installed inside containment by January 1, 1982.
No provisions currently exist for air particulate or radioiodine collection during accident conditions. To determine amounts of these radionuclides, the licensee will dilute the gas grab sample to reduce radiation levels.
Further, the offsite mobile lab has been calibrated with geometries up to 36 inches from the detector for counting high level samples.
Based on the above finding, this portion of the licensee's program is adequate for limited core dacage accident. Further modifications are necessary to meet the regulatory positions of NUREG-0737. This is an
open item.
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The following should be considered for improvement:
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The containment air sampling method must be modified, either pro-
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cedurally or structurally, to ensure that all samples obtained are representative of containment air. The modification must be
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accompained by a technical justification.
Capability for collection of radioiodine and particulate containment
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air samples with adequate shielding should be made.
4.1.1.7 Post-Accident Gas and Particulate Effluent Sampling and Analysis Post-accident sampling of the auxiliary and' refueling building exhaust can be made via the Auxiliary Building Special Ventilation System (ABSVS). Under accident conditions, the ABSVS automatically directs all auxiliary ventilation to the Shield Building annulus.
This. air is then treated and released at the top of each unit containment.
In addition, shie'1d building recirculation
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ventilation automatically starts creating a small negative pressure in the annulus area. This air is also treated and released through the common stack.
Final effluents, through the special' accident ventilation, are monitored prior to release. Each unit has a high range Victoreen Model 845 area sonitor which alarms and reads out in the Control Room and locally. Vital power is supplied
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to' ihe d' elector and sampling pump.
Isokinetic samples are drawn through a
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fl6ws to a large gas chamber which is monitored by the high range Victoreen ARM. This ARM is. shielded from the silver zeolite and particulate filters.
Sample flow is measured locally.
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The system has the capability of measuring IX10 uCi/cc noble gas concen--
tration.
A factor of ten dilution is credited by auxiliary building dilution.
Rackup measurements of noble gas effluent can be made by using portable dose rate instruments. Predetermined locations on the gas chamber have been designated and calibration curves are located in procedures.
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The inspectors calculated general field dose rates in the immediate vicinity e
of the sampling cubicle to be around 1-2 R/hr. No shielding has been provided
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for the sampling lines leading into the sampling cubicle. Further, sampling lines within the cubicle are not shielded. Although the system meets GDC 19 of, Appendix A of 10 CFR 50, ALARA considerations have been neglected.
Steam jet air ejector exhaust has been rerouted to the Shield Building stack and will be monitored by the above described system.
Secondary side steam relief radiation monitors have not been installed. This should 'ue comp'i'eted by January 1,1982.
Interim procedures have been written fcr determining the amount of radioactivity released by steam generator tube ruptures. This area is an open item.
Based on the above findings, this portion of the licensee's program is
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adequate. However, the following matter should be considered for improvement:
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Adequate levels of shielding for ALARA consideration should be provided
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for the sampling lines of the Shield Building exhaust monitoring and sampling station. Shielding should be limited to the immediate vicinity of those areas which will be occupied for sample collection.
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4.1.1.8 Post-Accident Liquid Effluent Sampling and Analysis
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Post-Accident liquid effluent sampling for thir, facility is limited to two major pathways. Tuese are the radwaste discharges and Steam Generator (S/G)
blowdown. Both pathways are monitored. During a S/G tube rupture, the blow-down ARM will isolate blowdown. Sampling of the blowdown lines can be accomplished in the normal nmple area. Special facilities and equipment are.
available for handling elevated radioactive liquid samples.
Sampling of radwaste is administratively controlled. Batch sampling of hold tanks will prevent accidental releases of radioactive liquids. Procedures for sampling and analyzing these samples are developed. No special equipment or facilities were developed. Radwaste systems are automatically isolated during an emergency.
If elevated radiation levels were experienced during sampling, primary coolant sampling equipment (shielded pot, reach rods and shield trans-port cart) could be utilized.
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Based on the above findings, this portion of the licensee's program is adequate.
4.1.1.9 Offsite Laboratory Facilities I
The licensee has a mobile laboratory facility for analysis of offsite
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monitoring samples. The lab has a dedicated 4k channel analyzer, with a high purity germanium crystal, which is maintained, calibrated, routinely checked, and promptly repaired as needed. A Radiation Protection Specialist (RPS) provided the inspectors a walkthrough of the mobile lab that included; how the lab would be transported, used, and results tabulated and reported.
Baaed upon the above findings, this portion of the licensee's program is j
adequate.
4.1.2 Protective Facilities 4.1.2.1 Assembly / Reassembly Area The inspectors examined the assembly / reassembly areas. The primary assembly area is the Training / Construction Building. The alternate assembly area is the onsite Screenhouse.
In the event of an evacuation alarm, procedures call for onsite' personnel to be directed to the proper assembly area via the plant public~ address system.
Both the primary and secondary assembly area have been equipped with protec-tive clothing, portable lighting, and communication equipment. Communication equipment consists of the plant public address system, radios and megaphones.
Both locations are adequate with respect to size, but the high noise level in the Screenhouse may hinder communications to large groups of people.
Based on the above findings, this portion of the licensee's program is adequate.
4.1.2.2 Medical Treatment The inspector reviewed the licensee's provisions for dealing with injured and/or contaminated victims of an accident. Radiation Protection Specialists are trained in a Red Cross Multi-Media equivalent first aid training program, first aid kits are located in emergency lockers and at various places through-out the plant. The Emergency Plan requires that injured persons, needing care beyond first aid, be transported to St. John's Hospital in Red Wing.
The Red Wing Ambluance Service wi]1 provide transportation of injured individuals to St. John's Hospital Ambulance drivers and.str.endants are paramedic trained and have been provioad with self reading dosimeters.
The inspectors interviewed St. John' V>s;4tal personnel and found them to be adequately trained in technique f,
de aling with contaminated patients.
The hospital has been adequate'
c pu ' ed sith equipment and instruments for contamination control.
Ici, eat includes protective clothing, containers for liquid and soln was 4 sposal, and survey instrumentation.
In addition to the above provisions, the licensee maintains a first aid station in the Training / Construction Building. The station is staffed Monday through Friday during the day-shift by a Registered Nurse.
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Based on tb-above findings, this portion of the licensee's program is adequate.
4.1.2.3 Decontamination Facilities The inspectors examined the licensee's decontamination faci' ties and equipment. Routine decontamination of personnel and equipr ent is performed at Access Control on the second floor of the terbine building. A water supply, sink for disposal of liquid waste, r.ud decontamination supplies and procedures are available at Access Control.
ihis facility would also be used in emergency situations if available.
In addition, sealed itcontamination kits with plastic containers for disposal of liquid waste are positioned at both of the assembly areas. These kits are inventoried monthly per SP-1034 and would be used in conjuction with equipment stored in nearby emergency lockers.
Contaminated individuals would be treated according to standard operating procedures. No special decontamination limits far emergency situations are provided.
Contaminated persons would be issued anti-contamination clothing cut of the kits if replacement clothing were required.
Based on the above findings, this portion of the licensee's program is adequate.
4.1.3 Expanded Support Facilities The licensee has made provisions for corporate, vendor and consultant staff augmentation in the E0F. Once an emergency has terminated and recovery initiation has been announced, expanded provisions for offsite consultant /
vendors would be available in the training facility that is attached to the EOF.
Based upon the above findings, this portion of the licensee's program is scceptable.
4.1.4 News Center The inspectors examined the licensee's news center and discussed the liccasee's provision for dealing with the press in the event of an emergency. The licensee has established a media information facility (MIF)
in the basement of NSP's corporate office in Minneapolis.
In the event of an emergency, the MIF would be the sole interface between the press and the licensee's Communications Department. The licensee has made adequate pro-visions for space, telephone service, electrical supply, copying, audio-visual equipment, and security in the MIF.
The licensee's Emergency Plan calls for a limited amount of space in the nearsite EOF to be devoted to a press briefing area. However, no provision for such an area has been made in either the interim EOF or in the plans for a permanent EOF. The licensee does not acknowledge the need for a nearsite press interface and maintains that the MIF in Minneapolis will satisfy the requirements for dissemination of information to the news media.
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. Based on the above findings, this portion of the licensee's program is adequate. However, the following item should be-considered for improvement:
The licensee should establish a joint nearsite press briefing area for
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use in emergency situations by the State, local and licensee media personnel.
4.2 Emergency Equipment 4.2.1 Assessment 4.2.1.1 Kits and Survey Instruments The licensee has reserved pre positioned supplies and survey instruments at specified locations for emergency use.
Emergency equipment locations were as specified in individual procedures. Emergency kit and locker contents were specified in Surveillance Procedure 1034.
Emergency kit and locker contents varied from location to location depend-ing upon the intended use of the equipment. For example, two locations were provided with sealed kits containing specialized equipment for offsite radiological surveys; other locations were equipped with sealed decontamina-tion kits. The OSC emergency locker contained, among other things, high range self-reading dosimeters, finger-ring dosimeters and self-contained breathing apparatus for re-entry teams.
Protective clothing was included at appropriate locations. All kits contained air sampling equipment (including silver zeolite for iodine sampling) G-M and ion-chamber survey instruments, low and medium range dosimeters and portable radios. Kit contents were generally appropriate for each location.
Respiratory protection was generally not included in emergency kits or lockers, except in the OSC and TSC. During normal plant operation, respirators are available at Access Control and this pool of equipment would be drawn upon during an emergency. Howevee, the licensee has not addressed the possibility that emergency conditions may prevent access to respiratory protection at Access Control, especially for offsite emergency response groups arriving for offsite survey teams.
(see Sections 4.2.2.1 and 5.4.2.1).
The licensee conducts monthly inventory and operational checks of emergency kit and locker contents per SP-1034.
Instruments dedicated for emergency use are rotated out for calibration every six months. All instruments in emergency kits and lockers were operable and calibrated.
Based on the above findings, this portion of the licensee's program is adequate.
4.2.1.2 Area and Process Radiation Monitors The inspectors examined several Area Radiation Monitors (ARMS) and process monitors to determine operability in the event of an emergency.
Twelve ARMS per unit read out in the Control Room.
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Nine of these have a maximum range of 1 R/hr and the other three range up to 10 R/hr. ARMS are located in the Control Room, charging pump area, sample room, radiochemistry lab, spent fuel pool area, waste gas valve gallery, primary coolant letdown line, containment vessel area, and incore seal table area. The latter two are inside containment.
The high range (10 R/hr) containment dome monitor ARMS have not been installed. The licensee has committed to have these ARMS installed by Janua ry 1,1982. This is an open item.
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As per NUREG-0654, increase direct radiation levels (greater that 1000 times normal) indicate that an Alert emergency is in progress. The ARMS in the Control Room have low and high range alarms. However, these alarms do not necessarily mean an Alert is in progress. No signs or color coding
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indication are provided on the ARM instrument panel.
Based on the above findings, this portion of the licensee's program is adequate. However, the following items should be considered for improvement:
Provide labeling on the ARM panel located in the Control Room
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indicating that 1000 times normal levels of these instruments (ARMS)
is an Alert emergency or color code the instrument to aid the Reactor Operators or Radiation Protection Specialist in classifing the event.
Af ter the permanent high range dome ARMS are installed, the readout should be color coded for an Alert, Site Area Emergency, and General Emergency.
4.2.1.3 Non-Radiation Process Mpnitors The only significant onsite non-radioactive toxic gases are chlorine, ammonia, and hydrazine. Pressurized chlorine gas is used for circulating water treatment. The gas is located in the main screenhouse structure. A chlorine monitor with a local readout is provided. Further, a chlorine leak annunciator is located in the Control Room.
A chlorine emergency locker is located on the bottom lev-l of the turbine building. Adequate damage control equipment for responding to a chlorine leak is provided. However, no portable chlorine monitors are provided for the damage control teams or other operation personnel to measure toxic levels of chlorine. Further, EALs for entry of toxic levels of chlorine, amonia or hydrazine into vital plant areas (e.g., Control Room) are not indicated in procedures.
Based on the above findings, this portion of the licensee's program is adequate. However, the following item should be considered for improvement:
Provide portable chlorine monitoring kits (i.e.
Drager Kits) for
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measuring chlorine, ammonia and hydrazine levels for use during an emergency.
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4.2.1.4 Meteorological Instrumentation The basis for the inspectors review of the licensee's meteorological measurements programs included Regulatory Guides 1.23 and 1.97 and the criteria set fr,rch in NUREG-0654, -0696, and -0737.
The licensee provided a brief description of the meteorological measurements program in Section 7.3 of the Radiological Emergency Plan. The integration of meteorological data into the licensee's dose assessment scheme was found in Procedure F3-13.
The inspectors reviewed the licensee's procedures for surveillance and calibration of the system.
The inspectors determined that the licensee's meteorological capabilities address the requirements of NUREG-0737, TAP III.A.2 and the criteria set forth in NUREG-0654, Appendix 2 in adopting the interim compensating measures to milestene three.
The meteorological measurements system has the capability to provide the basic parameters (i.e., wind direction and speed, and an estimate of atmospheric stability) necessary to perform the dose assessment function.
Fifteen minute averaged meteorological conditions ara recorded in the control room /TSC vicinity.
The current primary system affords a temperature gradient over a 30 meter layer. The stability class gradations provided in Regulatory Guide 1.23 are generally applicable for a 50 meter layer. The smaller height dif-ferential tends to enhance the frequency of extremes due to specification limits of the instruments and scaling. As a result, the narrow range stability categories (e.g., Pasquill Class B or C) are unlikely deter-minable from the available equipment. Less refinement in stability categorization (e.g., four classes rather than seven) will provide reasonable assurance that the atmospheric stability will be realistically described.
All meteorological instrumentation appeared to be in operation. Provisions have been made for access to an alternate source of data in the event the primary system was out of service. Lock and Dam No. 3 can provide local wind conditions and the National Weather Service (NWS) in Minneapolis is accessible for supplemental data.
Information regarding severe weather conditions is forwarded to the control room staff by the load dispatcher; the NAWAS can provide direct access to the NWS and State and local agencies for transmitting or receiving meteorological information :qdates. The licensee has access to the NRC health physics network te provide the NRC with direct telephone access to the individual responsible for making offsite dose projections.
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The licensee's preventative maintenance and data reduction programs are insufficient to assure that qualified data will be available for use by the control room /TSC personnel with a high degree of reliability. The procedures governing surveillance and maintenance are uncontrolled and not subject to any degree of quality assurance. Preventative maintenance activities are limited to calibrations performed on an infrequent schedule with no operability checks (beyond recorder pens inking) between calibra-tions. Archived data appeared to be limited to those data obtained from
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digital systems without supplementation from analog systems available from recorders at the weather station. The systems providing retill of meteoro-logical conditions are uncontrolled and subject to system malfunctions; this results in a data base discontinuity.
No' retrieval system exists to assure a continuous data stream in the event the hard copy dr.' ice is not functioning.
The use of meteorological data in the dose calculational methodology does not
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provide a basis for considering potential terrain induced flow conditions.
The methodology used to consider transport and diffusion have no supporting technical bases. The automated and manual techniques consider transport and diffusion as a ground-level, straight-line steady-state, Gaussian-type assessment. The potential for valley induced flow conditions under low wind conditions may produce trajectories differing significantly from straight line flow.
Based on the above findings, improvements in the following area are required to achieve an adequate program.
The licensee shall improve the meteorological measurements program to
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assure that qualified data records are available for use by control room /TSC personnel with a high degree of reliability. This shall include installation of a RG 1.23 meteorology tower (i.e., 60 meter tower) with primary measurements at the 10 and 60 meter level.
4.2.2 Protective Equipment 4.2.2.1 Respiratory Protection The inspectors reviewed the-availability and amount of respiratory equipment that would be available in an emergency. Onsite supplies of both supplied air masks (two varieties) are adequate. Facilities are adequately available for rechorp'.ng the supplied air bottle.. Backup respiratory equipment for-emergency use would also be available from the Northern States Power's Monticello Nuclear Generating Plant in about two hours. Additional oxygen bottles could be provided from a supplier, along with additional masks, should that prove necessary.
Respiratory protection devices were found to be unbagged and unlabled for testing and inspection. Although sufficent numbers of respirators were available_at the reactor, the placement was inadequate because assembly and emergency response facilities and emergency kits were either insufficently stocked at levels for personnel at such locations, or not stocked at all.
Based on the above findings, this portion of the licensee's program is adequate. However, the following items should be considered for improvement:
The respiratory equipment required for emergency use should comply
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with ANSI Z 88.1 - 1980 standards.
Respiratory protection equipment should be available in all emergency
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kits, assembly areas, and emergency response facilities.
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4.2.2.2 Protective Clothing The inspectors reviewed the onsite and offsite availability of protective clothing available for use during an emergency. There was both an adequate supply and range of sizes of protective clothing that would be accessible
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Based upon the above findings, this portion of the licensee's emergency preparedness program is adequate.
4.2.3 Communications The inspectors examined onsite and offsite communications equipment at the following locations: Control Room (CR), OSC, TSC, EOF, Access Control, and Corporate Headquarters Emergency Center. All onsite emergency operating facilities have (1) portable or installed radios, (2) normal plant telephone communications, and (3) an intercom system.
Primary and backup communications are available onsite.
The CR has an NRC hotline and HPN line, two system dispatcher phones, portable radios including a six channel radio base system with capability to talk to the Goodhue Sheriff, plant security, radiation monitoring teams, and the EOF.
The TSC has an NRC hot line and HPN line, tua system dispatcher lines, Wisconsin NARAS, base station for field rad monitoring teams, and a dedicated hotline for the Minnesota Emergency Government.
Health Physics Access Control Point has a HPN extension, various plant phones, and a intercom system.
The Headquarters Emergency Center has several dedicated telephones for emergency use plus access to the System Dispatcher.
The onsite protective area has a plant evacuation and fire alarm consisting of 125 VDC operated siren, which is started from the CR.
The tone is trans-mitted over the plant PA system. This system is periodically tested.
Several telephones are located in the EOF including the NRC,-HPN, and ENS.
The System Dispatcher telephone is also located in the EOF. Dedicated plant extension telephone are also provided. A base station radio is provided with communication capability to the field monitoring teams, TSC, and CR.
An intercom system will be installed in the near future.
As a result of a recent exercise held onsite, the licensee determined that additional telephones are needed for certain emergency response facilities.
Corrective measures are being implemented.
Based on the above findings, this portion of the licensee's program is adequate.
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4.2.4 Damage Control / Corrective Action and Maintenance Equipment and Supplies The licensee maintains routine maintenance equipment and supplies at the reactor site. Similar backup equipment and supplies would be available from the Monticello plant, approximately two hours from the Prairie Island plant.
The onif special damage control equipment and supplies is the chlorine cylinder repair kit.
Based upon the above findings, this portion of the emergency preparedness program is adequate.
4.2.5 Reserve Emergency Supplies and Equipment The licensee has onsite stocks of protective clothing, respiratory protec-tion, dosimeters, radiation protection instruments, communications, first aid supplies, and environmental monitoring supplies. These stocks are found in various locations at the Prairie Island Plant, and at the Monticello Plant.
These stocks are maintained at specified levels, and some are dedicated for emergency events.
In addition, backup stocks could be procured from vendors should they be needed.
Dedicated emergency reserve supplies are specified in SP-1034, and these supplies are checked monthly. Further, as described in Section 4.2.1.1, vital effsite monitoring kits are maintained sealed both in Red Wing District Service Center and at the site.
Based upon the above findings, this portion of the licensee's emergency preparedness program is adequate.
4.2.6 Transportation The licensee maintains a motor pool of 4-5 plant vehicles that are available for emergency use.
Vehicle keys are kept in the guardhouse. The vehicle motor pool includes one four-wheel drive vehicle.
In addition, the licensee has an mphibious vehicle that could be used in flood situations. This vehicle receives yearly maintenance and inspection.
In addition to the vehicle pool described above, the licensee maintains three to four vehicles that are dedicated to the area inside of the cecurity perimeter.
These vehicles would also be available for use during emergency situations.
Based on the above findings, this portion of the licensee's program is adequate.
5.0 Emergency Implementing Procedures 5.1 General Format Content There are twenty-four Emergency Plan Implementing Procedures. All procedures are functionally orientated. No position / titles procedures have been developed nor are check-off lists provided to ensure that all functions are fully implemented.
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Administrative Control Directive (ACD) 1.5, of the licensee's procedures, requires that procedures include chec k-off lists and references of other-pertinent procedures. Not all EPIPs have these.
Review of F3-2 (Emergency Classification) indicated that several EALs based on observable and reliable indicators were not included. These are summarized below:
(1) Provide containment radiation level EALs for a primary coolant leak greater than 50 GPM.
(2) Provide containment radiation level EALs for a loss of 2 of 3 fission product barriers.
(3) Provide steam line radiation monitor reading for a 50 GPM primary to secondary leak with and without fuel damage indication.
.(4) Provide EALs for IR-50, 2R-50, 1R-22 and-2R-22 Shield Building Vent Exhaust for an Alert, Site Area, and General Emergency.
(5) Change 100 R/hr to 1000 R/hr (EALs) for an Alert indicating a severe degradation in control of radioactive materials and remove airborne levels greater than 10 CFR 20 limits as an Alert EAL.
(6) Remove loss of both turbine generators an an Unusual Event and keep loss of both diesel generators as the EAL for Loss of Onsite AC Power Capability.
(7) Provide EALs for R 11/12, R-7, and R-2 for a fuel handling accident at the Alert Level and provide EALs for R-13, R-25, R-5 and R-28 at the Site Area level.
(8) Correct typographical error for Condition No. 13 from Ci/cc to uCi/cc (primary coolant results).
(9) Develop EALs for chlorine, ammonia, and hydrazine releases onsite including the Control Room, Administration Area, and Auxiliary Building.
The EPIPs refer the user to other procedures necessary to implement the emergency plan. Action steps are clearly displayed in a step-by-step sequence. Each procedure specifies the individual (s) having the authority and responsibility for performing the tasks covered by the procedure.
Based on the above findings, the following actions must be taken to achieve an acceptable program:
Develop check-off lists for key members of the Emergency Response
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Organization to ensure all tasks are performed in the proper sequence in order to prevent reliance on memory.
Develop observable and reliable EALs for those accident conditions
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listed above.
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5.2 Emergency.
A. irm and Abnormal Occurence The inspectors examined several Emergency Operating Procedures, Abnormal Operating Procedures and Ar.nunciator Procedures to determine if they adequately interfaced with the Emergency Plan Implementing Procedures.
Westinghouse Owners Group Symptomatic Emergency Operating Procedures have not been implemented at Prairie Island.
The following Emergency Operating Procedures adequately interfaced with the Emergency Plan Impi.cruenting Procedures:
AB-1, Safety Injection AB-3, Earthquakes AB-2, Tornadoes AB-4, Floods The following additional Emergency Operating Procedures do not adequately interface with che Emergency Plan Implementing Procedures:
C19.7, Loss of Containment Integrity D5.7, Fuel Handling Accident E40, High Radioactivity in the Secondary Coolant E21, High Reactor Coolant Radioactivity E17, Loss of Shutdown Capability C4, 3.5, Reactor Coolant Leak C5, Rod Control Drop or Withdrawal Emergency C15, Loss of RHR System DS, 7.0, Abnormal Procedure For Handling Damage Fuel C20.9, Loss of One Train of Vital DC Power F5, Fire Emergency F6, Toxic Chemical Releases Onsite In addition to the above, the Annunciator Correction Action procedure does not adequately interface with the EPIPs as necessary. These Annunciator procedures are currently being revised.
Based on the above findings, the following action must be taken to achieve an acceptable program:
Review and revise, as necessary, all plant abnormal operating procedures,
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emergency instruction, and annunciator procedures which do not contain, as a subsequent operator action, a statement to direct the Reactor Operator or user to notify the Shift Supervisor to classify the emergency in accordance with the Emergency Plan Implementing Procedures. This review shall also pertain to the new Westinghouse Owners Group Symptomatic Emergency Operating Procedures when and if they are adopted.
5.3 Implementing Instructions The inspector examined the following Emergency Plan Implementing Instruc-tions: F3-1 (Onsite Emergency Organization), F3-2 (Classification of Emergency), F3-4 (Responsibility During a Notification of Unusual Event),
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F3-4 (Responsibilities During an Alert, Site Area, or General Emergency).
The inspector found F3-1 procedure to be adequate. Deficiencies noted in l
.F3-2 are noted.in Section 5.2 of this report.
F3-4 11sts the actions to be-taken by various members of the onsite energency.
response organization. During the initial stage of the emergency, the Shift
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Supervisor of the unaffected unit becames the acting Emergency Director and as such is in charge of.the emergency. 'His first duty is to classify the event and implement appropriate plant a-tions. Three major and critical
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actions are missing in this section of tce procedure. They are:
(1) the
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Shift Supervisor must initiate (within the first hour) direct onsite and inplant radiation surveys as necessary, (2) he must direct radiochemistry personnel to'take appropriate samples (primary coolant, containment air or station effluent).and (3) he must make initial recommendations to offsite
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agencies for any General Emergency that will include activation of public notification systems and recommendation for sheltering for a two mile radius.
around the plant.
If the duty Emergency Director arrives prior to the e action statements, then these actions should be implemented by the Emergency
Director.
The TSC and OSC coordinators action statements listed in Procedure F3-4 do not direct them to establish communications with other Emergency Response Facilities (i.e., Control Room and EOF). This.should be added to their d
responsibilities.
i The Radiation Emergency Coordinator (REC) procedure does not provide guidance for determining priority for Post-Accident Sampling. Consideration should be given to determine when and in what order to:
collect pressurized versus unpressurized primary coolant samples; inplant, onsite, and offsite surveys
for unmonitored releases; auxiliary building surveys for operations and
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maintenance personnel; and station effluent sampling.
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Based on the above findings, the following action must be taken to achieve an acceptable program.
Revise F3-4 to ensure that the Acting Emergency Director (Unaffected
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Unit Shift Supervisor) will implement the above mentioned three critical actions within the initial stages of an emergency.
The following items should be considered for improvement:
Revise F3-4 to ensure that the TSC and OSC coordinators establish
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communications with the other Emergency Response Facilities.
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Revise F3-4 to ensure that the REC is provided guidance relevant to
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determining priorities for post-accident sampling and inplant/onsite radiation surveys.
5.4 Implementing Procedures 5.4.1 Notifications i
The licensee's Emergency Plan Implementing Procedures (EPIP) for emergencies
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is defined in EPIP F3-5 and EPIP 1.1.14 (Corporate). EPIP F3-5' delineates
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the notification procedures to be used during emergency situations, defines the primary and backup plant emergency communications systems, and provides operating instructiona for the notification system.
The Shift Emergency Communicator (SEC) has been specially designated by the licensee to assist the Emergency Director in completing the Emergency Wotifi-cation Report form and making the proper notifications. These notifications include federal, State, local, and NSP personnel. The procedure calls for initial contacts with State and local authorities within 15 minutes following declaration of an emergency. Further, it requires verification of call receipt and periodic updating of all required calls.
Augmentation of the plant emergency organization is required by EPIP F3-5.
For a Notification of Unusual Event, augmentation is based upon judgment of the Shift Supervisor, and for an Alert, Site Area or General Emergency, augmentation is based upon a pre-established Emergency Organization Call List. Once the TSC is activated, backup communicators will be used by the Duty SEC as required, and communications with the Westinghouse Emergency
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Response Team will be established.
In addition, the Radiological Emergency Coordinator will maintain contact with the States and the NRC.
EPIP F3-5 provides 12 pages of pre-defined notifications with appropriate messages.
"Hotlines," radio low band paging, radio alert and normal tele-phone systems are employed. Operating instructions for these systems are included in the EPIP, along with telephone numbers, and generic message cassette recording and live microphone transmissions for the radio alert system.
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The communications portion of the emergency preparedness program is discussed in Section 4.2.3 above.
Based upon the above findings, this portion of the licensee's program is adequate.
5.4.2 Dose Assessment Actions The inspector examined the licensee's dose assessment EPIPs titled F3-8 (Recommendation for Protective Actions), F3-13 (Offsite Dose Calculation),
and F3-20 (Manual Determination of Release Concentrations). F3-20 is used to determine the concentrations and flow rates of radionuclides being released via: Steam headers, Air Ejectors or Shield Building Vent Stack.
The procedures provide source term information if the instruments are operable, inoperable, or offscale. F3-13 is used to determine offsite dose calculations by two methods:
(1) Computer or (2) hand calculation method when the computer is unavailable. F3-8 is used to provide guidelines to establish the basis upon which protective action recommendations are to be made to offsite agencies.
F3-20 provides calibration curves for 1/2 R-22 monitors (low range Shield Building Vent) to determine uCi/cc stack concentration from the CPM reading of the instrument. This monitor will peg at luci/cc Xe-133 stack concen-tration. Accordingly,highrange(1/gR-50)instrumentswereinstalledto measure stack concentrations up to 10 uCi/cc. Calibration curves are pro-vided in the procedure.
If either of these instruments fail, precalibrated
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portable meter locations have been determined to estimate noble gas con-centrations. The same methodology has been provided for the air ejector and steam header pathway.
Air particulate and silver zeolite filter media are provided for tha Shield Building Vent Pathway.
Backup calibration curves for a RM-14, 2" GM pancake probe reading of a silver zeolite sample have been developed. Dose rate vs total iodine-131 activity is provi tel on the graph. Dose correction as a function of time after reactor shutdown for iodine-132, 133, 134, and 135 has not been considered. Accordingly, the licensee could overestimate iodine doses by as much as a factor of two during the early stages of an emergency.
However, this method of determining offsite iodine doses would only be used if both onsite and offsite laboratories were lost as a result of the emergency.
F3-13 is used to determine offsite doses by either using the computer or hand calculation methodn. The computer program is a basic straight line X/Q estimate of dose rates offsite. No dose assessment methodology is provided for plumes traveling perpendicular to the river bluffs. Dose rates are calculated at various distances from the site boundry out to ten miles. RG1.145 plume meander factors are considered. A ground level release is always assumed. Xe-133 equivalent dose rates and total iodine inhalation thyroid dose are calculated.
Iodine ground deposition is not calculated in the program. Only Xenen, Krypton and Iodine dose factors are in the program. Dose factors for cesium-134 and 137, ruthenium-106, and tellurium-132 are missing. These radionuclides contribute significant whole body and lung exposures and must be considered.
The computer model does not automatically calculate high range noble gas concentrations from the IR/2R-50 instrument readings. This must be manually determined from a graph. Also, the computer does not automatically calculate a containment source term from the high range dome monitors and project offsite dose rates.
Shield Building ventilation flow rates can not be measured directly. Flow rates have been determined by Pitot tube measurements of the Auxiliary Building Special and Spent Fuel Fool Special ventilation flow. Both of these safety related ventilation systems automatically discharge into the Shield Building vent stack. Steam dump, air ejector, and S/G safecies flow rates have been manually calculated.
F3-8 is used to make recommendations to offsite agencies based on results from Procedures F3-13 and F3-20.
The recommendations follow the guidance of the EPA. Sheltering and evacuation are the two protective action options.
Actual or potential releases are considered as part of the recommendations.
Action levels for ground contamination are also considered. The Prairie Island evacuation time estimate study is part of this procedure. However, the evacuation time estimates do not accurately reflect worst case sector evacuation, for example, those sectors which will effect the City of Red Wing. Section F and G out to ten miles include greater than 50% of the ten mile EPZ. Ac.cordingly, evacuation time estimates should be calculated for Sectors E, F, G and H.
Also, plant predominent wind direction is towards these sectors.
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Page 4 of F3-8 requires the user to evaluate the potential for a wind shift, however, the procedure does not tell the user how to accomplish the evaluation.
Further, the evaluation is not an action step in the procedure, but, rather, a NOTE statement. This statement should be a procedure step.
Based on the above findings, this portion of the licensee's program is adequate for short term Class A dose assessment. However, the following items should be considered for improvement:
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Include dose factors for cesium-134 and 137, ruthenium-106, and te11erium-132 in the dose assessment computer for whole body and lung doses.
Remove the RG1.145 plume meander factor from the dose assessment computet
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program.
Program 1R-50, 2R-50, 1R-22 and 2R-22 instrument readings to stack
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concentration in the dose assessment computer program.
Program the high-eange dome monitor readings into the dose assessment
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computer program.
Determine evacuation time estimates for worst case sectors (E, F, G and
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out to ten miles and include these estimates in the procedures.
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Program ground deposition for radioiodines and particulate releases, in-
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the dose assessment computer.
Include in F3-9 a statement indicating to the user that plume diversion
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is likely to occur if the plume is traveling toward the bluffs and consider this as part of the plume monitoring methodalogy (i.e., team locations). This methodology should also identify the techniques to be incorporated into the dose calculations to compensate for potential uncertainties associated with plume trajectories.
Provide information in F3-8 for the user to determine meteorological
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forecasting.
5.4.2.1 Offsite Radiological surveys Three Emergency Plan Implementing Procedures (EPIPs) are used by the licensee for offsite surveys. The offsite EPIPs are F3-15, F3-16, and 1.1.10 (corporate). EPIP F3-15 describes the " Responsibilities of the Radiation Survey Teams During a Radioactive Airborne Release." EPIP F3-16 describes the " Responsibilities of the Radiation Survey Teams During a Radioactive Liquid Release." EPIP 1.1.10, the corporate p cocedure, describes the Corporate offsite monitoring backup role.
The Prairie Island offsite monitoring capability includes the dispatch of three teams of four Radiation Protection Specialists in 30 to 60 minutes.
The Corporate offsite monitoring capability includes the dispatch of two additional teams from the Monticello plant. These teams would consist of two persons per team, one of which must be a Radiation Protection Specialist.
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While the initial direction for the offsite monitoring teams will come from the Emergency Director in the reactor control room, offsite monitoring would continue under the direction of the Emergency Manager at the nearsite EOF.
The inspectors reviewed the procedures and equipment for offsite surveys, and conducted walkthroughs with the Radiation Protection Specialists (RPS)
to determine the adequacy of the offsite surveillance program. Emergency kits, two at the Prairie Island Training Center and two at the offsite service center in Red Wing, contained all of the needed equipment and supplies except respiratory protection for RPS team members who could be involved in plume monitoring.
The offsite surveillance procedures describe the duties for the offsite monitoring teams and provides the survey record forms that would be filled out during surveillance activities. Although the record forms do provide information pertinent to plume monitoring, no specific instructions for plume surveillance and sampling is provided in the procedure. Thus, the procedures address specific offsite sampling locations, and the plume may not reach the sample points; rather the-plume may travel parallel to sample locations. Accordingly, plume search techniques should be incorporated into this procedure.
Based upon the above findings, this portion of the licensee's emergency program is acceptable. However, the following item should be considered for improvement:
The offsite radiation survey procedures should address plume monitoring
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technignes.
5.4.2.2 &
5.4.2.3 Onsite (Out-of-Plant and Inplant) Radiological Surveys The F3-15 and 16 EPIPs described above also provide for initiation of onsite monitoring.
In addition, EPIP F3-14 further describes onsite monitoring.
The onsite monitoring teams are responsible for controlling all onsite radiation exposures and, if necessary, establishing secondary access points as described in F3-21, and onsite sampling and monitoring analysis. Habit-ability of the TSC, OSC, Control Room and EOF are covered by procedures for those facilitir.s.
The methods and equipment that would be used for onsite monitoring were found to be in-place and available. Walkthroughs were conducted with Radiation Protection Specialists to determine the adequacy cf the onsite monitoring program, including inplant and out-of plant surveillance. Provisions for surveillance of personnel exposure, contamination control, respiratory protection for workers, and food and water control are provided.
Based upon the above findings, this portion of the licensee's emergency preparedaess program is acceptable.
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5.4.2.4 &
5.4.2.5 Primary Coolant Sampling and Analysis The inspector reviewed Emergency Plan Implementing Procedure F3-23 (Emergency Sampling) which is applicable to all Radiation Protection group personnel.
This procedure delineates the steps to be taken prior to obtaining a liquid reactor coolant sample or containment air sample. Adequate precautions are listed in the procedure including exposure controls. The procedure adequately interfaces with C39.1 (Reactor Coolant Sample Collection and Analysis) and C39.4 (Containment Gas Sample Collection and Analysis).
The procedure does not provide prcvisions to estimate the sample activity and dose rates. That is, the containment dome monitor reading should be utilized to estimate containment activity prior to sample collection.
Further, the R-9 letdown monitor reading, when on scale, could be used to estimate primary coolant activity. Graphs relating sample activity vs sample dose rates vs area radiation monitor readings (R-9 and dome monitor) should be included in this procedure.
Procedure C39.1 (Reactor Sampling System) provides means to collect pressurized and unpressurized reactor liquid samples. Section 5.7 provides Post-Accident hydrogen, radioactive gases and liquid samples. Procedure format and content is adequate. This procedure is currently being revised as a result of sampling equipment modifications. Sample modifications were necessary as a result of miscalculations relevant to post-accident dose rates. The licensee indicated this procedure will be revised as necessary after sampling modifications are nade.
Primary coolant sample analysis and sample preparation is performed in a hot cell located at the lower level turbine building. The Prairie Island Chemistry Manual, Section D, Post-Accident Analysis was reviewed by the inspectors.
Analysis capabilities for pH, chloride, boron, gamma count sample preparation, hydrogen, radioactive gases, liquid sampling, and waste disposal are covered in the. chemistry manual. Hydrogen ion concentration (pH) is measured by using the Orion pH probe; chloride is performed by the Hach Turbidimeter technique and boron is performed by the post-accident carminic acid method which was developed by Westinghouse.
Post-accident hydrogen is automatically deter-mined by the Westinghouse Beckman sampling unit. The inspector judged these procedures to be adequate.
Based on the above findings, this portion of the licensee's program is adequate.
5.4.2.6 &
5.4.2.7 Containment Air Sampling and Analysis Procedure F3-23 (Emergency Sampling) delineates steps to take prior to obtaining a containment air sample. Procedure C39.4 (Gas Analyzer),
Section 7.0 is used for collection and analysis of containment air samples.
Both procedures adequately interface with each other. The procedure provides two methods of obtaining the gas semple, with or without the gas analyzer in se rvice. The preferred method is with the Gas Analyzer. The sample is pro-vided through the post-LOCA hydrogen control panel.
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A three minute sample purge is provided for prior to sample collection. The sample purge is diverted to the waste gas treatment system.
H, and 0 C^"
automatically be measured by the installed inline monitor. After purging, a syringed sample (Ice to 5cc) is obtained from the shielded bomb and trans-ferred into a shielded glass vial.
Maximum source strengths for a RG 1.4 source term have been calculated to be 12 mci /cc. Maximum calibration distances for the portable Ge (HP)
detector have been made up to twelve feet. This would provide a dose rate at the detector of less than 1.0 mr/hr Zar the worst case sample.
The inspect.
recommended radioiodine and particulate sampling capability be added to this system. See Section 4.1.1.6.
Based on the above findings, this portion of the licensee's program is adequate. However, the following item should be considered for improvement:
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Develop a graph for F3-23 EPIP to calculate expected sample dose rates from the dome monitor radiation levels, that will aid in deciding sample size.
5.4.2.8 &
5.4.2.9 Stack Effluent Sampling and Analysis The licensee has developed Emergency Plan Implementing Procedure F3-20 (Manual Determination of Release Concentration) for use by the Radiation Protection group to determine the concentration and flow rate of radio-nuclides being released via the following effluent pathways:
Steam Release Headers
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Air Ejectors
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Shield Building Vent Stack
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Adequate precautions are covered in the procedure including proper exy osure control, and protective measures. The procedure adequately references other pertinent EPIPs.
The procedure has calibration curves for the low and high range noble gas effluent monitors. Monitoring points on the shield buildings stack gas chamber and air ejector discharge pipe are provided. Steam release activity is determined by Teletector readings on. predetermined steam lines. Dose rate conversion factors are determined from one of three graphs depending upon time after reactor shutdown. Steam flow rates have been predetermined from FSAR review.
Analysis of camples collected would be conducted by the normal means.
If the onsite laboratory is lost, the offsite laboratory can be utilized for counting.
Based on the above findings, this portion of the licensee's program is adequate.
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5.4.2.10 Liquid Effluent Sampling The inspector reviewed the licensee's procedures for liquid effluent sampling in F-23.
The licensee has made provisions for sampling of both steam generator blowdown and radwaste liquid effluents through sampling lines in the Auxiliary Building sampling hood and hot laboratory. Procedures for liquid affluent sampling are essentially identical to those used for primary coolant sampling, and are adequate for emergency situations. The team conducted a walkthrough of post-accident primary coolant sampling to determine the adequacy of the procedure. The findings of this walkthrough are discussed in Section 4.1.1.5.
Based on the above findings, this portion of the licensee's program is adequate.
5.4.2.11 Liquid Effluent Sampling Analysis The inspector reviewed the licensee's procedures for analysis of liquid effluent samples. Procedures are given in Section 5 of the Count Room Manual and in F3-23 of the Implementing Procedures. As indicated in 5.4.2.10, liquid effluent sample analysis procedures are essentially identical to tmst-accident primary coolant sample analysis procedures, except that the potential for very high levels of radiation is significantly reduced. See Section 5.4.2.5 for.a discussion of sample analysis procedures.
Based on the above findings, this portion of the licensee's program is adequate.
5.4.2.12 Radiological Environmental Monitoring Program (REMP)
The REMP program is defined in the licensee's Corporate EPIP 1.1.12.
Initiation of this program would be triggered by an emergency condition re-quiring offsite response at the Prairie Island plant. The Emergency Manager would notify the Administrator REMP or his alternate that special environmental sampling is needed. Radiation Protection Specialist, who work on the routine REMP program, would then be deployed to the areas around the reactor, where the pre-established REMP stations are located. A full spectrum of air, land, water, milk, vegetation and TLD samples can be collected and analyzed. _The two qualified REMP Radiation Protection Specialists would take parallel actions with the State and/or federal environmental teams as required, or in the absence of other teams conduct the necessary surveillance. They would contact the offsite REMP laboratory (Hazelton Environmental Services) to obtain new sets of dosimeters and alert the laboratory of special samples which require forwarding.
Based upon the above findings, this portion of the licensee's emergency preparedness program is adequate. However, the following item should be considered for improvement:
Although the size of the existing REMP manahement and surveillance
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teams are adequate if they are available, the number of persons capable of providing this service should be expanded to assure availability for emergency events.
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5.4.3 Protective Action 5.4.3.1 Radiation Protection During Emergencies
.EPIP F3-12, Emergency Exposure Control, addresses personnel. exposure limits, control, and precautions under emergency conditions. For saving human _ life, for example, up to 75 rems of whole body dose can be voluntarily received.
EPIP F3-25, Re-Entry, would be used to brief individuals on the expected radiation levels. Should dose rates be greater than 10 R/hr, two dose rate meters are required for the rescue team composed of two persons.
EPIP F3-25 provides 20 figures of the Prairie Island Nuclear Generation Plant that specify expected design basis accident dose rates (RG 1.4) immediately following an event.
In addition, two graphic figures have been developed for dose rate decay time versus percent of dose rate expected, out to one year.
Thus, expected dose rates may be quickly derived prior to entry. The training
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program for Radiation Protection Specialists covers this information.
" Record Keeping During An Emergency" is specified in EPIP F3-24.
Access control is specified in F3-25, "Re-Entry," and F3-21, " Secondary Access Control." Offsite Dose Calculations, both computerized and manual, are covered in F3-13.
The use of " Thyroid Iodine Blocking Agent (KI)" is described in F3-18.
EPIP F3-14, "Onsite Radiological Monitoring," defines the normal and emergency contamination level guidelines that are and would be used, respectively. F3-14 also describes the respiratory protection program (Section 4.3) that would be employed during an emergency situation.
Routine radiation protection procedures in a few cases, such as analytical counting equipment, are made applicable by defining emergency conditions such as elevated dose rate and contamination levels.
The application of the procedure to brief emergeacy worker volunteers for life-saving and re-entry purposes is comprehensive. Figure 2, EPIP F3-12, provides a two page record form for emergency exposure authorizations.
The form requirements include four approval signatures, a briefing on the effects of acute exposure, and extensive information on each employee involved. Completion of all informa'. ion required on the form could prevent timely rescue of injured employees in high dose rate areas should the reactor (s) come under the press of a real emergency event. However, if necessary, the Emergency Director may verbally authorize emergency exposure when time is a limiting factor and documentation shall be completed as a followup.
Based upon the above findings, this portion of the licensee's emergency preparedness program is adequate.
5.4.3.2 Evacuation of Owner Controlled Areas The inspector reviewed the licensee's procedures for evacuation of owner controlled areas. F3-9 assigns responsibility for decisions on evacuation to the Emergency Director. The Emergency Director bases his decision on
"the best information available," but no criteria for evacuation are given
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for areas other than emergency response facilities. Action levels for the TSC and OSC are given in F3-6 and F3-7, respectively.
Evacuation routes from plant areas are adequately marked. There is only one possible site-evacuation route. Assembly area locations are specified and consistent with the locations in the Emergency Plan.
Evacuation of personnel from plant areas is verified by a brief search of the evacuated area. Thereafter, access to the evacuated area is controlled by the radiation protection group.
Site-wide evacuation is verified per F3-10.
Personnel are notified of the need for evacuation via the plant public-address system.
Based on the above findings, this portion of the licencee's program is adequate.
5.4.3.3 Personnel Accountability The inspectors reviewed the licensee's procedures for accounting for personnel during an emergency.
Procedure F3-10 requires the Plant Security Force to assume principle responsibility for personnel accountability.
When the evacuation alarm sounds, the Security Force will immediately obtain a computer printout of the names of all onsite personnel. At the assembly area, the Security Force will collect ID badges from evacuated personnel, and check the badges against the computer listing. Each Emergency Response Coordinator will produce a listing of personnel present in his respective facility and forward the list to the Security Force. The Security Force will then supply a list of missing persons to the Emergency Director.
Search and Rescue operation may then be initiated per F3-11, " Search and Rescue." Accountability check will be performed every eight hours thereafter until the emergency situation is resolved.
If the computer listing of onsite personnel becomes unavailable, the Security Force will perform a manual check of the security credentials, checking the board in the guardhouse for missing badges.
Based on the above findings, this portion of the licensee's program is adequate.
5.4.3.4 Personnel Monitoring and Decontamination The inspectors reviewed the licensee's procedures for personnel monitoring and decontamination during an emergency. During routine operation, all personnel leaving the Auxiliary Building are monitored by a scintillation-type portal monitor at Access Control. This would also be the case during an emergency situation unless the access control point had to be relocated.
In the event of a site evacuation, the Radiation Protection Group is respon-sible for contamination monitoring of evacuated personnel at the assembly area. This function would be performed by radiation protection personnel arriving from offsite if the emergency were to occur during a backshift.
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Release limits for contaminated personnel and equipment.are given in F3-19.
These limits are consistent with the limits given in corporate EPIP 1.1.16.
Positive results of personnel and equipment surveys at the assembly areas are recorded on a Radiation Occurrence form and forwarded to the Supervisor,
. Radiation Protection, for evaluation..This individual is authorized to establish-release criteria that are different from those in F3-19 if'necessary.
Based on the above findings, this portion of the licensee's program is
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adequate.
5.4.3.5 Onsite First Aid / Rescue
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The inspector reviewed the licensee's procedures for recovery and treatment
of injured individuals. F3-11 gives procedures for Search and Rescue teams to use in locating missing personnel. This procedure provides radiation protection guidance for the teams.
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-Transportation to the offsite medical treatment facility at St. John's Hospital and instructions for handling of contaminated patients are adequately addressed-(see Section 4.1.2.2).
Onsite medical treatment (First Aid) will be provided by plant personnel j
trained in a Red-Cross -Multi-Media equivalent program.
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Based on the above findings, this portion of the licensce's program is
. adequate.
5.4.4 Security During Emergencies The inspectors reviewed the licensee's procedures. for security during plant emergencies. F3-29 and SWI-GF-13 delineate security procedures for emergency
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situations. All members of the Security Force will report to the guardhouse during an emergency. The Security Supervisor will then-direct their actions-according to instructions from the Emergency Director.
The Security Force
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will assist members of the Radiation Protection Group in ' establishing a secondary access control point if necessary. The procedures include provision
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for establishing a road-block at the site -boundry. to prevent.non-NSP personnel from entering hazardous areas.
Based on the atave findings, this portion of the. licensee's program is adequate.
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5.4.5 Repair / Corrective Actions
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i As described in Section 5.4.3.1, repair or corrective actions requiring emergency exposure levels and personnel. briefing to prevent significant i
offsite exposures are covered in EPIP F3-12.
Further, F3-15, "Re-Entry,"
specifies the requirements on the formation and safeguards that must be
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employed. The re-entry procedures (F3-25) contain expected dose rates for postulated accidents, procedures for assuring that repair work or
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corrective actions are properly monitored, and provisions for respiratory
protection.
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Based upon the above findings, this portion of the licensee's emergency preparedness program is adequate.
5.4.6 Recovery Section 9.0 of the Emergency Plan divides recovery from emergencies into two types; short and long term.
Short term recovery does not include events having core damage or significant releases of radionuclides. The plant organization would be responsible for short term recovery and the Recovery Organization, long term.
Criteria for transition from the emergency to the recovery phase are iden-tified in the emergency plan. The criteria include:
(1) assurance that the problem is solved and will not recur; (2) general occupancy areas are free of significant contamination; (3) radiation areas and high radiation areas are defined, and (4) airborne radioactivity is eliminated or controlled.
Written procedures for recovery will be developed, and will be approved by the Operation's committee prior to use.
Short term recovery is covered in EPIP 1.1.15 (Corporate).
The long term recovery organization is shown in Section 9 of the Emergency Plan, and the major responsibilities are defined in EPIP 1.1.15.
EPIP 1.1.15 requires that Power Production Management make the decision when an emergency should be declared, terminated, and recovery initiated.
As part of the emergency organization turnover to the recovery organization are the responsibilities of the Administration and Logistics Superintendent, the Logistics Coordinator, and the Communications Coordinator. However, the EPIPs do not specify that either the emergency or recovery organizations will assure that the various individuals and agencies will be informed prior to initiation of recovery actions.
A draft of the NSP Corporate Emergency Response Plan was reviewed by the inspector. This draft contained information on recovery. This document, when finalized, will become part of the liceusee's emergency preparedness submission to the NRC.
Based upon the above findings, this portion of the licensee's program is acceptable. However, the following item should be considered for improvement:
The EPIPs should clearly state that the emergency organization will
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promptly notify all appropriate individuals and agencies that the emergency has been terminated and recovery actions will be initiated.
5.4.7 Public Information Corporate EPIP 1.1.8 delineates the licensee's provisions for dissemination of information to the news media during an emergency. The procedure iden-tifies the licensee's Communication Department as the organization responsible for this function, with two " media representatives" designated as the primary contacts for the news media. The procedure adequately defines the organiza-tional structure of the Communications group during an emergency, and specifies lines of communication and authority.
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Checklists for key' personnel, telephone lists and pre-written sample news releases are also provided in the procedure.
-The licensee's corporate News Center in Minneapolis is designated as the only authorized interface between the news media and the licensee.
Rased on the above findings, this portion of the licensee's program is adequate.
5.4.8 Fire Protection Notification c f a fire within the reactor could arise via employee observa-tion and/or atarm.
Should an employee, in the absence of an alarm, report the fire, he wauld call the control room, report the location and give particulars about the fire.
Should awareness of fire occur via control room annunciation, the reactor operator, Shift Technical Advisor or the Shift Supervisor would go to the fire location alarm panel. This panel has location definition, a Technical Specification number (if vital equipment is involved) and a location number.
In order to classify an emergency, a fire that could affect a vital system must be defined properly. Using the fire panel nomenclature from the alarming panel, the control room personnel can use the Fire Strategy notebook (F-5 Appendix A), and rapidly locate the fire preplan. The information under the location number consists of pictorial drawings of the affected locations that shows fire protection systems in color-coded circles, triangles, etc.,
and printed information on the facing page. The printed information includes fire loading, personnel hazards, communication, fire equipment, equipment control, special instructions, and a summary. The beginning of the Fire Strategy appendix includes definition of the color code and a pull out chart that identifies where the fire probably originated.
Following use of the information obtained from the fire strategy document, the Shift Supervisor would then classify the emergency.
Based on tne above findings, this portion of the licensee's program is adequate.
5.5 Supplemental Procedures 5.5.1 Inventory, Operation Check and Calibration of Emergency Equipment, Facilities and Supplies The inspectors reviewed the licensee's procedures for maintaining emergency
. equipment and facilities in an operable and' useable state.
In addition to periodic plant-wide emergency drills, the licensee conducts monthly inventory and operational checks of equipment reserved for ' emergency use.
Instruments reserved for emergencies are rotated every six months for calibration. The Radiation Protection Group is responsible for conducting the monthly inven-tories and rotating instruments for calibration.
Based on the above findings, this portion of the licensee's program is ddequate.
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5.5.2 Drills and Exercises The Manager, Nuclear Environmental Services, is responsible for planning and organizing drills and exercises. The Manager. Production Training (training is Corpo..t function) is responsible for conducting drills and exercises.
The Prairie Island Plant Assistant Administrator, Emergency Preparedress, assists in conductine; drills and exercises. Each drill / exercise is conducted using a documented scenario.
EPIP 1.2.2 covers the overall plan for exercises and drills, and the Nuclear Engineering Planned Drill / Exercise Program document, issued in July 1981, further describes this portion of the NSP training for postulated emergency events. The exercise / drill program frequencies vary from monthly and quarterly communications drills to annual exercises. Provisions for handling
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news media coverage will be covered in the annual exercises. State and County organizations, along with ambulance and fire department personnel, are provided opportunity for walkthroughs and training annually.
There are provisions for backshift drills and exercises.
EPIP F3-26 provides guidance on the conduct, observations and critique of Emergency Plan drills.
The inspectors reviewed past drill critiques and found that discrepancies in procedures and/or equipment use were noted, studied, and/or corrected as required.
Recent site medical drills were found to have been conducted and video-taped by a consulting firm. Fire drills are conducted in accordance with the Northern States Power Fire Protection outline. Responsibilities and dead-lines for corrective actions following a critique of an exercise or drill are addressed in Corporate EPIP 1.2.4, Surveillance.
Based upon the above findings, this portion of the licensee's emergency preparedness program is acceptable.
5.5.3 Review, Revision and Distribution Telephone numbers for those with emergency response assignments are updated at least quarterly as stipulated in Plant EPIP F3-28.
Procedures which implement the plan are annually updated as needed, and reviewed to assure that they are current. The updates include changes made as a result of critiques following drills and exercises.
(Reference EPIP, No. F3-28).
The schedule for these various procedure reviews is programmed into the licensee computer. Regular computer printouts of scheduled events prompts a review of the specific procedure and designates the individual assigned as a reviewer.
Corporate EPIP 1.2.3, specifies the methods used to maintain NSP Corporate and Plant Emergency Plans and EPIPs.
It also provides for periodic reviews of plans and procedures as well as an administrative program that supports the emergency planning effort. One of the procedural reviews listed is to be performed by someone independent of emergency planning.
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Distribution of the Corporate Plan and its EPIPs is controlled by the Assistant Administrator, Emergency Preparedness.
Current copies are assigned by alphanumeric identities to individuals listed by name as part of the Corporate EPIPs. Distribution of the site plan and related EPIPs is controlled.
Based on the above findings, this portion of the licensee's program is adequate.
5.5.4 Audit The inspectors reviewed the licensee's onsite quality assurance program with respect to the Emergency Plan and Implementing Procedures. The licensee conducts a yearly administrative audit of the Plan and Procedures according to Audit Plan 10.2.
This audit includes inventory checks of emergency equipment lockers and kits. See Section 1.5 for information concerning the licensee's plan to hire an outside consultant to perform an independent technical audit.
Based on the above findings, this portion of the licensee's program is adequate.
6.0 Coordination with Offsite Groups 6.1 Offsite Agencies Offsite agencies were contacted by the inspectors to determine the adequacy of support they would provide to the Prairie Island Plant in the event of a nuclear emergency. Agencies contacted are discussed below individually.
6.1.1 Goodhue County (Mn) Sheriff's Department and Civil Defense Director The Goodhue County Sheriff and the Civil Defense Director for the county were interviewed by the inspectors. Observed communications equipment included telephones, two-way radios, and intercommunications equipment between the Sheriff's dispatcher and the County E.O.C. facilities.
A dedicated (red) telephone, connected via radio transmitter, is used by the Sheriff's office to receive emergency calls from the Prairie Island Plant. A two-way radio, in the dispatcher's office, is connected to the plant guard-house for communications with the plant security force on traffic control and evacuation plans. One of the two-way radio sets was checked for transmission and receipt of messages by the inspectors and was found to be adequate.
The County EOC was also visited and equipment observed. The difference between the County EOC and the Sheriff's communications equipment was that the County EOC has only one two-way radio set to communicate to the plant.
Intercommunication messages have to be hand carried between floors of the E0C from the Sheriff's Department to the County EOC.
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Radiological safety training has been provided by representatives of the Minnesota State Department of Health for the Sheriff's Department.
Imple-mentation of the. emergency response plan would be in accord with Section VI of the Minnesota Nuclear Power Plant Emergency Plan. Other training for the duty officers covers responsibilities, notifications and basic radiation protection principles, and is provided through NSP corporate staff members.
Brochures for evacuation plans of the Prairie Island Plant were prepared and distributed by the Goodhue County Civil Defense Department.
Based upon the above findings, this portion of the licensee's program is adequate.
6.1.2 Pierce County (Wisconsin) Sheriff's Department and Civil Defense Director The Pierce County Sheriff and Civil Defense Director were interviewed by the inspector. The Sheriff can dispatch 10 patrol cars to assist in setting up road blocks and check points that might be required for an emergency event.
Communications equipment in both the Sheriff's dispatcher office and the couray E0C was observed.
Direct-dial telephones, two-way radios and the State of Wisconsin's NAWAS telephones along with the telephones between the Sheriff's dispatcher and the County E0C office constitute the key emergency response communications equipment. The two-way radio reception was tested between the Plant TSC, the Sheriff's dispatcher and Civil Defense dispatcher offices. The inspector concluded that the reception at each location was loud and clear.
Pierce County participated in an exercise in October 1980. Training, provided by the NSP Corporate staff, has covered notification procedures, duty officer activities, communications equipment, and basic radiation protection principles.
An ERAD respresentative and a private consultant were used as part of the NSP training team. Brochures for evacuation plans of the Prairie Islar.d Plant were prepared and distributed by the Pierce County Civil Defense Department. The Civil Defense Director expressed a concern about the lack of funds for salaries and equipment necessary for participation in exercises and drills.
Based upon the above findings, this portion of the licensee's program is adequate.
6.1.3 Lock and Dam No. 3 - Army Corps of Engineers, Red Wing, Minnesota The lockmaster was interviewed by the inspector to determine the respon-sibility and capability of this agency to respond. The lockmaster indicated that under orders from the US Coast Guard Command at St.
Paul, Minnesota, he could stop water traffic at the dam before it proceeded by the plant upstream. Also, as specified in the Letter of Agreement, air monitoring and wind speed and direction can be provided from meteorology data generated at the dam. Radiation monitoring training is being provided by the Army Corps of Engineers, not from the plant. The Lockmaster did express an interest in having his crew tour the Prairie Island Plant to get better acquainted with
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the plant and meet with key emergency preparedness personnel. They have a telephone and a radio transceiver installed to receive notifications from the plant.
Based on the above findings, this portion of the licensee's program is adequate.
6.1.4 Fire Department - Red Wing, Minnesota The inspector interviewed the fire Chief and 'the Assistant Fire Chief to assess the fire department's capabilities for responding as the primary offsite agency for fire fighting at the plant.
Both were knowledgeable of their responsibilities and the interface required with plant personnel.
The department ambulance has been dispatched as part of a medical drill within the last year.
Training sessions in plant facilities and familiarization with equipment relating to possible fires have been held within the last year. Also basic-radiation protection information has been provided by plant personnel. The fire department can equip eight fire-fighters with self-contained breathing apparatus units for up to one hour's use.
Five more such units are available as backup at the fire department facility. A program has been implemented for the Red Wing Fire Department to examine and test the adequacy of the plant's fire hose. Through joint efforts, the fire hydrants outside the plant's protected fence area are being flushed periodically to prevent sediment buildup. Earlier only those hydrants inside the fenced area were flushed.
The inspector considered this important preventative maintenance.
Communications by two-way radio and telephone are available in the fire station. Also there is an EPZ map and other area maps for guidance to the personnel. The Assistant Fire Chief reviewed with the inspector a checklist type of procedure to be followed by fire personnel on duty when an emergency situation is declared at the plant.
It is color-coded, simplified, short explicit instruction notebook that seemed to be efficent. A copy of both the corporate and the plant emergency plan is available for use and information purposes.
Based on the above findings, this portion of the licensee's program is adequate.
6.1.5 St. John's Hospital, Red Wing, Minnesota The licensee relies on St. John's Hospital in Red Wing for medical treatment of contaminated patients. The inspectors interviewed the hospital's Chief Administrator and Assistant Nursing Supervisor with respect to training, facilities, and the hospital's relationship with the licensee. The Chief Administrator expressed confidence that his staff was able to provide adequate medical service to the licensee in the event of an emergency. He also indicated that he wr.; satisified with the licensee's efforts to train his staff and udequately equip the hospital with instruments and radio-logical protection supplies. No deficiencies were found in either equipment or training at St. John's Hospital.
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The Hospital's Emergency Procedures contained a section which incorporated recommendations from the licensee's EPIP F4-9.
This EPIP covers the proper methods for handling contaminated patierts.
6.1.6 Other Support Agencies Telephone contacts were made with the following agencies and information received was considered satisfactory regarding emergency response capability:
U.S. Coast Guard Office, St. Paul, Minnesota Burlington Northern Railroad - Dispatcher, Fridley, Minnesota Chicago, Milwaukee, St. Paul and Pacific Railroad Company - Chief Dispatcher, Milwaukee, Wisconsin 6.1.7 Letters of Agreement The inspector's review of the licensee s files confirmed that all Letters of Agreement issued are current, one year or less, and have been signed by a responsible management representative of the support agency. However, as indicated in Section 2.2 the Letter of Agreement with Fluor Power Services, Incorporated should be modified as indicated in Section 2.2 when a new letter is initiated. Other reply letters from the Office of Sheriff of Pierce County, Wisconsin; Office of Civil Defense of Pierce County; Red Wing Fire Department and the Westinghouse Electric Corporation should be clarified and revised to be more explicit as to acknowledgement that they have a copy of both the corporate and site emergency plans. Also these letters should be more specific as to what areas of emergency response they will carry out, more descriptive, i.e.,
better delineation of authority.
The Assistant Administrator Emergency Preparedness informed.the inspector that a complete review and updating of these letters of agreement would be made as part of the annual review of the Emergency Preparedness Program. This review
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is tentatively scheduled prior to April 1, 1982.
Based on the above findings this portion of the licensee's program is adequate.
However, the following u ems should be considered for improvement.
.The following Letters of Agreement should be revised as suggested in
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the above paragraph; 1.
Office of Sheriff of Pierce County, Wisconsin
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Office of Civil Defense of Pierce County, Wisconsin 3.
Fire Department, City of Red Wing, Minnesota
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Westinghouse Electric Corporation 6.'2 Genecal Public The inspectors reviewed the licensee's provisions for ensuring that the general public is adequately informed about emergency procedures with respect to the Prairie Island' Nuclear Plant. This review included an interview with the Supervisor of Media Information, as well as a review of information distributed
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The licensee distributes emergency planning information to the population within a ten mile radius of the plant on a yearly basis. This information is contained in a set of 'two brochures; one of which focuses on civil defense related matters, the other relates to general aspects of radiation protection.
The brochures include information on emergency notification, appropriate actions in the event of an emergency, basic facts about radiation, and a contact for further information.
Distribution of the above information is accomplished by mailing of the brochures to all residents in the area.
County civil defense authorities have been provided with additional copies. The inspectors discussed the licensee's provisions for informing the transient adult population in the vicinity of the plant. Although the licensee has plans to dist.lbute copies of the information brochures to local hotels and motels, no provisions have been made for informing users of local picnic and camping areas.
The licensee is currently upgrading the public information brochure.
Based on the above findings, this portion of the licensee's program is adequate.
However, the following item should be considered for improvement:
The licensee should provide distribution of information on emergency
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measures to local parks and other public use areas, in the form of postings, to ensure that the transient adult population is adequately info rmed.
6.3 Public Alerting and Notification System The warning siren sys*em as the main mechanism used to alert the ger.eral public, within the ten mile EPZ, was scheduled for initial installation on November 6, 1981. A contract has been awarded. A total of 63 sirens will be installed at key locations within the 10 mile EPZ. Twenty-seven of these have 125 decibel rating; 36 have 115 decibel rating.
Sound level requirements were determined by the licensee's contractor, Wiley Laboratories. Some Civil Defense sirens (yellow) are already installed in some locations in the EPZ.
The licensee's sirens (grey) will be integrated into the existing Civil Defense siren system.
Bids were opened on November 6, 1981, for the tone alert radios. These radios, approximately 150, will be distributed to hospitals, large office buildings, public gathering building and wherever large number of people would normally congregate. The Civil Defense Agencies of Dakota, Goodhue and Pierce County (Wisconsin) will determine where to locate these radios.
Radio alert system radio receivers are already placed in the homes of the Prairie Island Plant Emergency Orgainization personnel living within the radios receiving range. Civil Defense people and those local residents within the immediate vicinity of the plant also have these radio receivers.
The initial activation of the radio system comes as an announcement from the plant TSC.
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This information was gathered by the inspectors from a meeting with corporate staff engineers at the NSP Headquarters. Separate discussions were also held with the corporate level Emergency Planning Coordinator and his assistant.
Based on the above findings, the following action must be taken to achieve an acceptable program:
Documentation must be provided to the NRC which technically supports
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whether the prompt public notification system meets the design objectives of Append'.x 3 of NUREG-0654. The licensee's submittal shall clearly indicate when the system will be fully operational.
J 6.4 News Medi.
The inspector reviewed the licensee's program for familiarizing the news media with emergency procedures.
The licensee conducts a yearly seminar to which members of the press are invited. The seminar covers emergency plans, points of contact for release of public Information, information about biological effects of radiation, acciderir aequences, normal plant operating characteristics, and the licensee's news center. This seminar has been conducted at least once in the past, and was well attended by the Minneapolis news media. The licensee indicated that the local news media in the vicinity of the plant has generally not attended the seminar, but would be encouraged to do so in the future.
Based on the above findings, this portion of the licensee's program is adequate.
7.0 Walkthrough Observation 7.0.1 Site Assembly / Evacuation Alarm Test
,
On November 7,1981, at 1:30 p.m. the Site Assembly Evacuation Alarm was tested, for a 30 second time duration. Four inspectors were stationed at following locations, Training Center Building approximately 150 yards from the protected fence area, second level Turbine building, third level Turbine building near the feedwater pumps, and the Auxiliary Building in the vicinity of the charging pump. The latter three areas are considered high noise areas.
Sirens in these three areas were heard. The inspection team concluded that the siren tests, including the announcement, were carried out successfully.
Based on the above findings, this portion of the licensee's program is adequate.
7.0.2 Offsite Radiological Survey Walkthrough The inspectors conducted walkthroughs with two RPS members on offsite radiological surveys. The RPS's started the simulated survey situation in the OSC, their " normal" emergency point of departure.
Complete explanations were given on protective apparel, dosimeters, emergency kits, transporta-tion, communications, how to conduct surveys, and how to determine if the RPS members were inside of a radioactive plume.
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Based upon the findings of this walkthrough, this portion of the licensee's program is adequate.
7.0.3 Offsite Laboratory Walkthrough The inspectors conducted walkthroughs with two RPS members on set-up, movement, use and data reporting. The RPS's started the simulated use of the mobile laboratory at the location of the trailer-mounted 4k channel analyzer laboratory. Complete explanations were given on protective apparel, dosimeters, emergency kits, transportation and location, communications
.and methods employed to handle elevated samples.
Based upon the findings of this walkthrough, this portion of the licensee's program is adequate.
7.0.4 Onsite Radiological Survey Walkthrough The inspectors conducted walkthroughs with two RPS members on onsite (inplant and out-of plant) surveys. The RPS's began their simulated surveys from the OSC, their " normal" emerger.cy point of departure.
Complete explanation were given on habitability, food, water, use of ARMS, and personnel surveillance.
Based upon the findings of this walkthrough, this portion of the licensee's program is adequate.
7.J.5 Post-Accident Primary Coolant Sampling and Analysis Walkthrough The inspectors conducted a walkthrough of post-accident primary coolant sampling and analysis. Two RPS were examined under simulated accident conditions. The walkthrough started from the OSC where the RPS's would normally be dispatched.
Both RPS's followed Health Physics (HP) and sampling procedures. Adequate protective equipment, dosimetry, HP instrumentation and communications were used.
Both an adequate pressurized and unpressurized coolant sample were collected. Dissolved gases including hydrogen and oxygen were collected and analyzed. Unpressurized liquid samples were collected for radionuclide analysis, boron, pH, and chloride. Samples were collected, shielded and transported to the turbine building hot cell.
.
It took approximately 25 minutes to collect the pressurized samples. This
'
was the actual time from start of the sampling procedure to backflushing and securing the system. Adequate additional shielding is being provided for the pressurized sampling facilities.
Ten milliliters of unpressurized coolant was collected in a 50 ml. glass vial.
The vial was then placed in a 1-1/2 inch shielded hand pot.
This pot is then placed in a two inch shielded cart for transport to the hot cell.
It took 20 seconds to collect this sample.
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Based on the above findings, this portion of the licensee's program is adequate.
7.0.6 Post-Accident Containment Air Sampling Walkthrough The inspectors conducted a walkthrough of the post-accident containment air sampling and analysis. Two RPS were examined under simulated accident con-ditions. The walkthrough began in the OSC where the P.PS personnel would be assembled following notification of an emergency event.
The RPS's followed proper health physics and sampling procedures. Adequate protective equipment, clothing and communications were employed.
Based upon the above findings, this portion of the licensee's program is adequate.
f 7.0.7 Inplant Sampling and Analysis The inspector walked-through post-accident sampling of the final station effluent (Shield Building Exahust) to determine if the RPS have been adquately trained. Simulated accident conditions were given to the RP s.
TheRPS'sweretoldthattheeffluentmonitor(1R-50)wasreading2X10('mR/hr and the upper level turbine building air concentration was at normal levels with no surface contamination.
Both RPS's started their walkthrough from the OSC.
Proper HP sampling procedures were followed. Adequate protective equipment and radiation instrumentation were used. A radioiodine and particulate sample was collected and placed in a portable shielded cart. ALARA procedures were followed.
The sample label sticker used did not provide all necessary pertinent information.
fhe date, type of sample, location, and person taking the sample were not indicated on the sticker. However, a sample record sheet does have this information. Both the sample record sheet and sample label sticker should have the same information. The licensee agreed to correct this item.
Based on the above, this portion of the licensee's program is adequate.
7.0.8 Field Radio Communication Walkthrough The inspectors cbserved a test of the portable radio system used for com-munications between the TSC and the offsite survey teams. ladio reception was tested from several locations around the plant. Distances from the plant were 10 - 20 miles, and one location was in a valley which represented the worst condition for radio reception. Radio reception at all locations
was loud and clear.
The inspectors observed a test of the inplant capabilities of the portable radio communications system. A Reactor Operator (RO) attempted to contact the Control Room base-station form the north side of the first floor of the Auxiliary Building. Although the base station was able to receive the RO's
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transmission, the RO was unable to receive the base station's transmission.
This deficiency was made known to the Assistant Radiation Protection Super-visor. Communications were successful from all other plant locations.
Based on the above findings, this is an open item pending resolution of the above problem.
7.0.9 Emergency Detection Walkthrough Several post TMI instruments had not been installed at the time of the appraisal. These included:
(1) high range ARM in containment, (2) steam line monitors, (3) wide range containment pressure and temperature and other.
RG 1.97 parameters. Accordingly, walkthroughs relevant to the meaning of these readings were not conducted.
This is an open item.
7.0.10 Emergency Classification Walkthrough The inspector interviewed several Shift Supervisors and Emergency Directors to ensure that they understood F3-2, Classification of Emergencies.
Selected scenarios were given to the user.
In each case, the user was capable of properly classifying the emergency, however Action Step 5.5 which references the user to the F3-3 and F3-4 (Actions to take for an Unusual Event, Alert, Site Area, and General Emergency) was not always followed. This matter further indicates that check-of f sheets are necessary to ensure actions are taken in the proper sequence.
(see Section 5.1)
Based on the above findings, this portion of the licensee's program is adequate.
7.0.11 Dose Calculation Walkthrough The inspectors conducted walkthroughs of several Radiation Emergency Coordinators (REC).
Scenarios were given to each REC which involved significant releases through the Shield Building Stack. Each REC was asked to calculate offsite dose rates and determine what protective measures would
be necessary. Those REC's examined followed their procedures and made timely and accurate recommendations for protective measures. Some problem areas were discovered. During the walkthroughs, instrument conversion factors had to be determined from reading a graph.
In some cases, the wrong value was chosen.
As part of protective measures recommendation, the REC had to determine the potential for a wind shift; however, the telephone number for the National Weather Service was unavailable. This matter was corrected while the inspectors were still onsite. Other impediments discovered are discussed in Section 5.4.2.
It was learned during the walkthroughs, that only the REC are adequately qualified to determine offsite dose calculations. Shift Supervisors and the Radiation Portection Specialist have not received training in this area.
Based on the above findings, this portion of the licensee's program is adequate. However, the following item should be considered for improvement:
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All RPS should have training relevant to determining offsite dose
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calculations (i.e., F3-13 and F3-8) by means of the computer. The training should be a limited scope program concentrating on the first hour of an emergency.
7.0.12 Back Shift Emergency Inplant Surveys Walkthrough In order to determine the licensee's ability to perform inplant radiological surveys during back shifts (when only one Radiation Protection Specialist is on duty), the inspectors conducted walkthrough exercises with three licensed Reactor Operators (RO's). According to the Emergency Plan, the licensee will rely on R0's to provide this capability.
The RO's were requested to make several exposure rate measurements and to collect an air sample for airborne particulates and iodines.
In general, the inspectors found that R0's were not sufficiently trained to provide this crucial function. Two of the R0's indicated they had received no specific training on radiation survey techniques. None of the R0's were able to make simple interpretations of the measurements.
These findings were made known to the Assistant Radiation Protection Super-visor who indicated that the licensee intends to conduct a more extensive training program for R0's.
This program will include basic training in survey techniques and periodic refresher training. This deficiency in the licensee's minimum shift staffing capability must be fully removed by July 1, 1982.
Based on the above findings, this portion of the licensee's program is an open item pending completion of more extensive training-for Reactor Operators on emergency inplant survey techniques.
7.0.13 Protective Action Decision Making Walkthrough Several Shift Supervisors and Emergency Directors were interviewed by the inspectors. Walkthroughs with predetermined scenarios were used to verify if the Emergency Directors can adequately determine appropriate protective measures. For Unusual Events, Alerts or Site Area Emergencies, the Shift Supervisors interviewed were able to indicate to the inspector what actions were necessary to implement the Emergency Plan. Most Shift Supervisors did not follow the procedures step-by-step directing them to the action to be taken in the proper sequence.
Those Shif t Supervisors interviewed indicated to the inspector that a check-
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off list would be helpful in leading them chrough their many responsibilities outlined in the Emergency Plan Implementing Procedures. This finding is discussed in Section 5.3.
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8.0 Persons Contacted NSP EMPLOYEES
- D. Gilberts, Senior Vice President, Power Supply
- L. Eliason, General Manager, Nuclear Plants
- F. Tierney, Plant Superintendent K. Albrecht, Superintendent for Quality Engineering D. Althaus, Supervisor of Plant Services L. Anderson, Production Engineer
- T. Bushee, Media Services B. Clark, Administrator, Radiological and Environmental Monitoring R. Conklin, Supervisor, Security D. Cragoe, Shif t Supervisor K. Delong, Radiation Protection Supervisor J. Early, Radiation Protection Specialist
- L. Finholm, Simulator Supervisor
- W.
Frederick, Sr.
Consultant, Regulatory Liaison (Corporate)
W. Gauger, I & E Supervisor
- G. Goering, Gen Sup't, Nuclear Technical Services
- J. Goldsmith, Sup't Nuclear Technical Services (Corporate)
- J. Gonyeau, Manager, Production Training (Corporate)
R. Held, Shift Supervisor J. Heubner, Reactor Operator
- G. Hudson, Ass't Administrator, Emergency Preparedness W. Irvin, Reactor Operator J. Joachim, Radiation Protection Specialist
- A. Johnson, Radiation Protection Supervisor D. Johnson, Reactor Operator G. Kolle, Instructor, Radiation Protection
- D. Larimer, Radiochemistry Supervisor J. Lemmerman, Radiation Protection Specialist R. Lindsey, Superintendent of Operations
- S. London, Supervisor, Media Services (Corporate)
D. Ludwig, Radiation Protection Specialist J. Lyons, Chief Electrician J. Maurer, Radiation Protection Specialist G. Mathiasen, Emergency Planning Coordinator, Monticello Nuclear Plant L. Mayer, Manager, Nuclear Support Services (Corporate)
D. Mendele, Sup't Operations Engineering R. Meyers, Reactor Operator M. Mulhauser, Maintenance Supervisor J. Nelson, Sup't Maintenance J. Payton, Radiation Protection Specialist 4D. Schuelke, Sup't Radiation Protection
- R. Stenroos, Senior Production Engineer Site Emergency Planning Coordinator C. Tice, General Monger, Plant Engineering and Construction P. Voltaks, Shift Supervisor D. Walker, Shift Supervisor
- E. Watzl, Plant Superintendent, Engineering and Radiation Protection
- E. Ward, Manager, Nuclear Environmental Services (Corporate)
R. Warren, Plant Office Manager
- Denotes,b"se present at the exit interview.
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NON-NSP EMPLOYEES S. Christiansen, Pierce-County Sheriff J. Collins, Consultant R. Kosec, Chief, Red Wing Fire Department D. Felmlee, Ass't Chief, Red Wing Fire Dept.
D.-Grote, Sheriff, Goodhue County B. Kanter, M.D., Interstate Medical Center, Red Wing
'R. Miller,' Pierce County Civil Defense Director E. Schuppel, Lockmaster, Lock and Dam No. 3, Army Corps of Engineers H. Watsor, Goodhue County Emergency Coordinator 9.0 Previous Inspection Findings a.
(282/79-06-01; 306/79-06-01): Missing Portable Radio
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The inspectors examined the Northern States Power garage in Red Wing and determined that adequate supplies of portable radios are in place. This item is considered closed.
b.
(282/79-06-02; 306/79-06-02): Rezero of Dosimeters The inspectors examined all of the emergency equipment and facilities provided at the St. John's Hospital and determined that dosimeters.have been rezerced.
Inventory procedures adequately described means to ensure that dosimeters are operational. This item is-considered closed.
10.0 Exit Interview The inspectors and senior management from the region met with licensee representatives -(denoted in Paragraph 8) at the cocclusion of the appraisal on November 13, 1981. The inspectors summarized the scope and findings of the appraisal. A detailed technical exit interview was also conducted at the conclusion of the appraisal with licensee representatives of those technical areas which needed improvement.
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