IR 05000335/1981013
| ML20054D816 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 12/08/1981 |
| From: | Gaitanis M, Jenkins G, Perrotti D, Stansberry W, Stransberry W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20054D801 | List: |
| References | |
| 50-335-81-13, NUDOCS 8204230411 | |
| Download: ML20054D816 (58) | |
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UNITED STATES E' % NUCLEAR REGULATORY COMMISSION t a REGION 11
e 101 MARIETTA ST., N.W., SulTE 3100 ATLANTA, GEORGIA 30303 o
Report No. 50-335/81-13 Licensee: Florida Power and Light Company P.O. Box 529100 Miami, Florida 33152 Facility Name: St. Lucie Nuclear Plant Docket No.: 50-335 License No: DPR-67 Appraisal at the St. Lucie site near Jensen Beach, Florida Inspectors: ph/'M r /2# g'/ D. J. Ferrotti (Team /eader) Date Signed khbb vl /2 4-5/ tl.~W. Staasberry / Date Signed kh/ l /z J' af/ M. J. Gaitanis / Fate Signed Accompanying Personnel: C.
orbit, J. Kenoyer, J. Fairobent, G. Gibson, alc n, K. Clark . ' h /N 9 /8l Approved By: - - G. R. Js W ns, Section Chief Date Signed EPOS p ision SUMMARY Ins,pection on June 8-19, 1981 Areas Inspected i This special, announced appraisal involved 507 inspector-hours onsite and offsite in the performance of an Emergency Preparedness Implementation Appraisal, including administration, emergency organization, training and retraining, emergency facilities and equipment, procedures, coordination with offsite groups, drills and exercises, and evaluation of the i Emergency Plan.
8204220 N
Results In the areas inspected, no violations or deviations were identified.
Appraisal deficiencies were identified the in following areas: in plant, onsite and offsite radiation surveys, paragraphs 4.2.1.1, 5.4.2.1, 5.4.2.12, 5.4.2.2 and 5.4.2.3; offsite dose assessment, paragraph 5.4.2; and public information system, paragraph 6.2.
. TABLE OF CONTENTS INTRODUCTION PART I DETAILS 1.0 Administration 2.0 Emergency Organization 2.1 Onsite Organization 2.2 Offsite Organization 3.0 Training / Retraining 3.1 Program Establishment 3.2 Program Implementation 4.0 Emergency Facilities and Equipment 4.1 Emergency Facilities 4.1.1 Assessment Facilities 4.1.1.1 Control Room 4.1.1.2 Technical Support Center (TSC) 4.1.1.3 Operations Support Center (OSC) 4.1.1.4 Emergency Operations Facility (EOF) 4.1.1.5-4.1.1.8 Post-Accident Sampling and Analysis (Included in Sections 5.4.2.4 - 5.4.2.9) 4.1.1.9 Offsite Laboratory Facilities 4.1.2 Protective Facilities 4.1.2.1 Assembly / Reassembly Areas 4.1.2.2 Medical Treatment Facilities 4.1.2.3 Decontamination Facilities 4.1.3 Expanded Support Facilities . 4.1.4 News Center 4.2 Emergency Equipment 4.2.1 Assessment 4.2.1.1 Emergency Kits and Portable Instrumentation 4.2.1.2 Area and Process Radiation Monitors 4.2.1.3 Nonradiation Process Monitors 4.2.1.4 Meteorological Instrumentation
TABLE OF CONTENTS (Continued) 4.2.2 Protective 4.2.2.1 Respiratory Protection 4.2.2.2 Protective Clothing 4.2.3 Communications 4.2.4 Corrective Action 4.2.5 Reserves 4.2.6 Transportation 5.0 Procedures 5.1 General Content and Format 5.2 Emergency, Alarm and Abnormal Occurrence Procedures 5.3 Implementing Instruction 5.4 Implementing Procedures 5.4.1 Notifications 5.4.1.1 Alert and Notification System 5.4.2 Assessment Actions 5.4.2.1 Offsite Radiological Surveys 5.4.2.2 Onsite (Out-of-Plant) Radiological Surveys 5.4.2.3 In-Plant Radiological Surveys 5.4.2.4-Post-Accident Sampling and Analysis 5.4.2.9 5.4.2.10 Liquid Effluent Sampling 5.4.2.11 Liquid Effluent Sample Analysis 5.4.2.12 Radiological Environmental Monitoring Program (REMP) 5.4.3 Protective Actions 5.4.3.1 Radiation Protection During Emergencies 5.4.3.2 Evacuation of Owner Controlled Areas 5.4.3.3 Personnel Accountability 5.4.3.4 Personnel Monitoring and Decontamination 5.4.3.5 Onsite First Aid / Search and Rescue 5.4.4 Security During Emergencies 5.4.5 Repair / Corrective Actions 5.4.6 Recovery 5.4.7 Public Information
TABLE OF CONTENTS (Continued) 5.5 Supplementary Procedures 5.5.1 Inventory, Operational Check and Calibration of Emergency Facilities and Equipment 5.5.2 Orills and Exercises 5.5.3 Review, Revision, and Distribution of Emergency Plan and Procedures 5.5.4 Audits of Emergency Preparedness 6.0 Coordination with Offsite Groups 6.1 Offsite Agencies 6.2 General Public 6.3 News Media 7.0 Drills, Exercises and Walk-Through 7.1 Drill and Exercise Program Implementation 7.2 Walk-Through Observation 8.0 Follow-up on Previously Identified Emergency Preparedness Items 9.0 Persons Contacted ATTACHMENT-EVALUATION OF THE ST. LUCIE EMERGENCY PLAN 1.0 Background 2.0 Emergency Plan Evaluation 3.0 Conclusions .
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- .. - INTRODUCTION , The purpose of this special appraisal was to perform a comprehensive evaluation of the licensee's emergency preparedness program. This appraisal included an evaluation of the adequacy and effectiveness of areas for which explicit regulatory requirements may not currently exist.
The appraisal effort was directed toward evaluating the licensee's
capability and performance rather than the identification of specific items of noncompliance.
The appraisal scope and findings were summarized on June 19, 1981, with those persons indicated in Section 9 of this report.
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1.0 ADMINISTRATION 1.1 - 1.4 Responsibility Assigned, Authority, Coordination, Selections, and ! , Qualifications
The overall responsibility for emergency response planning at St. Lucie has been i delegated to the Vice President, Power Resources.
The Vice President, Power
Resources is responsible for all FPL Offsite Emergency Organization activities, t , " including personnel assignments and communication arrangements.
The Emergency ! Plan Administrator is responsible for maintaining emergency preparedness, ,
including the planning, scheduling and coordinating of major emergency drills or ! exercises, conduct and documentation of initial training and retraining of FPL ! , Offsite Emergency Organization personnel, periodic reviews of the Radiological i Emcrgency Plan (REP), review and updating of letters of agreement, revisions to ! the REP, and distribution of the REP and revisions of the REP to offsite agencies ' and organizations. In addition to the Emergency Plan Administrator, the position ! . of Power Resources Supervisor of Radiological Emergency Planning has been
established by the Manager, Power Resources Nuclear Services, effective April 1, j 1981.
However, a description of the responsibilities and authority of the ! Radiological Emergency Planning Supervisor has not been included in the REP.
l The St. Lucie Plant Operations Superintendent is responsible for the planning, scheduling and coordination of all emergency drills or exercises involving the l Onsite Emergency Organization. This responsibility has been redelegated to the > Health Physics (HP) Supervisor, who has the overall responsibility for emergency ! . planning at the site. However, there is no individual at the site who has been ! l formally appointed to the position of Emergency Planning Coordinator.
i Discussions with the HP Supervisor indicate that a billet has been approved for l . this position. The Facility Review Group (FRG) reviews and approves all changes f I to the REP and Emergency Plan Implementing Procedures (EPIP). As a member of the ' FRG, the HP Supervisor provides direct input to emergency planning for the St. Lucie Facility.
! Discussions with those individuals responsible for the planning effort within the , licensee's organization indicated that the individuals possessed an understanding
. of the principles involved in developing plans and procedures, that these
individuals have been selected according to criteria established by the . licensee's management and that these individuals have been provided knowledge of I the emergency planning area through the individual's normal responsibilities, ! seminars and meetings held by various industry groups.
! Based on the above findings, this portion of the licensee's program appears to be acceptable. However, the following should be considered for improvement: , Appointing an individual to the position of Emergency Planning Coordinator ! at the site with no other additional duties. Consider also appointing this ' ! person should be appointed a member of the FRG. (50-335/81-13-01)
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2 I Including in the REP a description of the duties, responsibilites and authority of the Radiological Emergency Planning Supervisor and the Emergency Planning Coordinator. (50-335/81-13-02) 2.0 EMERGENCY ORGANIZATION 2.1 Onsite Organization A site Emergency Coordinator has been designated who is available at all times and has the authority and responsibility to initiate any emergency actions within the provisions of the REP including the exchange of information with authorities responsible for coordinating and implementing offsite emergency measures. The REP specifies the line of succession for the position of Emergency Coordinator.
There are adequate personnel onsite at all times to provide initial emergency response capability in all key functional areas.
The REP identifies the response capability as Interim Teams (initial response) and Primary Teams (augmented response) as follows: , Radiation Teams Fire Teams First Aid and Decontamination Teams Security Teams Assembly Order Supervisor Recovery and Restoration Teams (Primary only) Reentry Teams (Formed as required) However, the REP does not address the capability for augmenting the initial ' emergency response capability within 30 minutes and 60 minutes as delineated in the specific criteria of NUREG-0654, Section II.8, Table B-1, relating to the planning standard of 10 CFR 50.47(b)(2).
Discussions with the licensee indicated that the augmentation capability will be described in the next revision to the REP.
(See Attachment 1, Section 2.2 of this report for the evaluation of the REP.) The discussions indicated, however, that the augmentation capability would not meet the Table B-1 criteria, in that personnel called in to perform emergency response functions are expected to arrive at their designated emergency response facility within a 45-90 minute time ' frame (after notification from the plant). This was verified by review of a memo ~ from A. D. Schmidt to R. E. Uhrig, dated June 5, 1981. The authority responsi-bilities and duties of the individuals who will take charge in an emergency have j been described, d Discussions with licensee representatives indicate that plant staff members are familiar with the REP and EPIP and have an understanding of the general functional areas in which they would be expected to perform.
Based on the above findings, the following deficiency must be corrected to , achieve an acceptable program: Provide for the augmentation of the initial response capability, within 30 minutes and 60 minutes, in accordance with NUREG-0654, Section II.B, Table B-1.
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, ' 2.2 Offsite _ Organization The ontite organization is augmented by assigned personnel from the normal onsite
plant complement, as described in Section 2.1 above. Those additional personnel - are alerted by the Duty Call Supervisor, who is contacted by the Emergency Coordinator. Additional assistance in coping with an emergency is provided by
the FPL Offsite Emergency Organization. The REP describes the responsibilities and authorities of the key positions in the Offsite Emergency Organization.
Primary and alternates for key positions are identified for the following i positions: Emergency Control Officer (ECO).
, - Recovery Manager (RM) Emergency Information Manager (EIM) ' Emergency Security Manager (ESM) Emergency Technical Manager (ETM) Governmental Affairs Manager (GAM) Lines of succession for the ECO and Managers of the Offsite Emergency Organization are controlled by procedures and are maintained by the Emergency
, Plan Administrator.
Declaration of a Site Area or General Emergency will I initiate the establishment of the expanded response organization.
The FPL Offsite Emergency Organization will be notified and mobilized.
In an Alert, the FPL Offsite Emergency Organization is notified and placed in a standby mode.
The EC0 will report to the General Office Emergency Center and take charge of the ' overall FPL Offsite Emergency Organization activities. The Recovery Manager, who I will be responsible for directing the company's expanded response organization, can report to the General Office Emergency Center, the nearsite interim Emergency Operations Facility (EOF), or the onsite Interim Technical Support Center (TSC).
Additional staff support is available for the ECO and the Managers of the Offsite Emergency Organization to augment the onsite and offsite operating staff. The ECO will have access to this support through the offsite Emergency Roster (Offsite Emergency Organization Procedure 1301) maintained by the Emergency Plan Administrator.
Based on the above findings, this portion of the licensee's program appears to be dCCeptable.
3.0 EMERGENCY PLAN TRAINING / RETRAINING 3.1 ' Program Established For most employee tasks, the licensee has a formally documented and approved i emergency plan training / retraining program as demonstrated by procedures and
training records.
Employee training on emergencies begins with new employee i orientations. The qualification criteria for employees are directly related to the responsibilities a person would have during the course of an emergency event, should one occur.
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The. two areas not yet fully established are the Health Physics Department emergency and radiological accident assessment training procedures. The Health ' Physics Emergency Preparedness Procedure is in draft form with changes underway.
The radiological accident assessment training is also planned.
Once the procedures are in place, a few additional Health Physics Department training ! topics will be included. More intensive training for Nuclear Plant Supervisors i and Nuclear Watch Engineers on radiological assessment will be included. Added ' new training will include radiological and environmental surveillance and r j monitoring as part of the radiological accident and assessment training.
l , ' Training for offsite fire and ambulance support services, state and local l agencies is provided.
See Section 6.3 for news media training.
FP&L has had five annual exercises that involved state and local agencies that includes the Sheriff's Department. See Section 7.2 for walk-through findings on both offsite , and onsite training / exercises.
Lesson plans include outlines th" each qualified instructor uses. Audits of ! training records shows that each department maintains individual employee records , on training completed for each category and item.
Oral and written exams are
used on items of importance (i.e., reactor operator certification, Radiation
Protection Man instrument use, and emergency procedures for chemical technicians.)
There are plans to extend existing training to cover the post-accident radio-logical engineering studies that have been completed. This training will include estimates of radiological conditions in varying emergency situations with changing radionuclide compositions and dose rates.
' i Current,1y there appears to be no overa'l training on the emergency organization ! and the relationship of the various funt.tional areas to the entire organization.
l i Similarly, training in protective action decision-making and plant conditions is l not adequate. (See Section 5.4.2 for Post-LOCA events.)
e Individuals assigned to first aid teams have been trained in the Red Cross ! ' Standard First Aid - Multimedia course. Most training involves a combination of formal classroom training (i.e., lectures, films, etc.) and hands-on use of ! equipment, i Based on the above findings, this portion of the licensee's program appears to be , acceptable. However, the following should be considered for improvement: ! Expanding the existing radiological emergency training program for the ( Radiation Protection Man, to cover estimated dose rates that could occur on a location-by-location basis, under varying accident conditions, outside of the radiation controlled area. (50-335/81-13-04) Including in the training program for Nuclear Plant Supervisors and Nuclear
Watch Engineers emphasis on radiological assessment and protective action.
! (See Section 5.4.2). (50-335/81-13-05)
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Establishing and/or finalizing the following items and incorporating into
the training program: HP emergency and radiological assessment procedures.
' Coverage of post-accident engineering studies, to include estimates of radiological conditions in varying emergency conditions with changing . radionuclide compositions and dose rates.
. Operational aspects of the emergency organization and the relationship of the various functional areas to the entire organization.
(50-335/81-13-06) ' i .t , 3.2 Program Implementation j Training records indicate that all required training has been completed in accordance with requirements. The training reviews with people on walk-throughs ' indicated that the training provided did take place as prescribed. All employees , questioned demonstrated an understanding of their duties.
! . Based on the above findings, this portion of the licensee's program appears to L2 i i acceptable.
t 4.0 FACILITIES AND EQUIPMENT 4.1 Emergency Facilities 4.1.1 Assessment Facilities 4.1.1.1 Control Room The Control Room for Unit 1 is located in the Reactor Auxiliary Building (RAB) - - adjacent to the Technical Support Center.
For any emergency, the Control Room serves as the initial point of control.
The Control Room is designated to be
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tenable under conditions described in the FSAR.
The air ventilation system ! includes HEPA and charcoal filters to remove airborne contamination.
Nuclear
plant instrumentation is provided to give early warning of a potential emergency ' , ' situation including area and process radiation monitoring instrumentation.
Habitability provisions and supplies, including self-contained breathing apparatus, self-reading dosimeters and chargers, and portable G-M tube monitors appear adequate.
Emergency Plans and Procedures are available in the control i room as well as in the Nuclear Plant Supervisor's office.
I Necessary communications equipment for notifying onsite and offsite authorities , in the event of an accident is available and includes: ' National Warning System (NAWAS) Local Government Radio (LGR)
Emergency Notification System (ENS) - Hot line to NRC (Bethesda) and NRC
, Region II
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Commercial Telephones FPL' Company Radio Systems Public Address System PAX Telephone System 'FM Radio System , Radio Paging System Portable Radio Sets i Direct commercial line from Control Room to EOF Direct commercial line from Control Room to TSC ' Based on the above findings, this portion of licensee's program appears to be acceptable.
4.1.1.2 Interim Technical Support Center (TSC) ., The TSC is located in the training classroom area adjacent to the Unit 1 Control l Room. The TSC, when activated by the Emergency Coordinator during an alert or more severe emergency classification, will be staffed in accordance with the REP.
. In the event that the REP is activated during normal day shift hours for the ! plant staff, the following department heads or their alternates will report to the TSC, in accordance with EPIP No. 3100032E: ! Health Physics Supervisor
Technical Supervisor Maintenance Superintendent , Quality Control Supervisor Chemistry Supervisor
Reactor Engineering Supervisor ' Others as necessary During off-duty hours, the TSC staff is chosen from shift personnel assigned to the plant and are known as " Interim Team Leaders."
The TSC communications , j network includes: Sound Power Phones Commercial Telephone Lines ' Plant Auxiliary Exchange (PAX) i Emergency Notification System (ENS) i +' Additional commercial telephone lines are to be installed by mid-July as the establishment of a permanent TSC approaches completion.
(See Section 4.2.3.,
Communications, of this report for further discussion on emergency communication i equipment.) Should all communications to the Control Room be lost, the close proximity of the two areas allows for continued effective emergency response management. This center meets the same habitabiIity requirements as the Unit 1
Control Room.
There. is sufficient space to accommodate up to 25 persons.
Currently, the licensee is in the process of installing auxiliary equipment such ! as status boards, computer systems for monitoring and recording of selected plant i parameter data, drawings and other reference materials, cabinets, and emergency
supplies.
Based on the above findings, this portion of the licensee's program appears to be l acceptable.
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4.1.1.3. Operations Support Center (OSC) The OSC is located in the first floor maintenance area of the Service Building, i Auxiliary operators, HP technicians, maintenance personnel and otFar essential plant shift personnel available to support the emergency response are to assemble in the OSC. The required staff will be assigned to appropriate activities by the Emergency Coordinator (EC). An estimated 100 persons can readily be accommodated in the OSC. PAX telephone communications are maintained between the OSC and the Control Room. In the event the OSC becomes untenable, the EC will designate an
alternate location.
Based on the above findings, this portion of the licensee's program appears to be acceptable. However, the following should be considered for improvement: Identifying the OSC supervisor and alternate. (50-335/81-13-07) Including in the OSC the communications system a dedicated telephone , extension to the Control Room and one to the TSC. (50-335/81-13-08)
Identifying a backup location in the event the primary facility becomes - untenable, and establishing procedures for evacuation of OSC personnel and a
how the relocated OSC will perform its function. (50-335/81-13-09) l 4.1.1.4 Interim Emergency Operations Facility (EOF)
The Interim EOF is located in the Unit #2 site construction office building.
Sufficient space is available to accommodate the licensee's response organization and representatives from the federal, state and local authorities, with a capa- ' city for 100 or more persons. The Emergency News Center (ENC) is also located with the Interim EOF.
(See Subsection 4.1.4 for additinnal information on the ENC.) If the EOF becomes untenable, the EOF will be relocated to FPL's Walton Transmission and - Distribution Substation, about 5 miles west of the plant.
Continuity of E0F functions during any transition between interim and alternate facilities will be maintained by the General Office Emergency Center and the TSC.
The EOF contains emergency radiological monitoring equipment and supplies,
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protective clothing, respiratory protection devices, essential precalculated emergency data and pertinent reports and drawings.
, ' The Interim EOF has an emergency communications network including LGR and commercial telephone lines.
Activation and staffing of the EOF will be under the direction of the ECO. The Recovery Manager will report to and manage the Interim EOF as specified in Offsite Emergency Procedure 1202.
i l Based on the above findings, this portion of the licensee's program appears to be i acceptable.
i 4.1.1.5 - 4.1.1.8 Post-accident Sampling and Analysis (Refer to Section 5.4.2.4 - 5.4.2.9.
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- 4.1.1.9 Offsite Laboratory Facilities FPL has primary and backup radiological facilities onsite. The backup facility is a normally cold lab augmented with counting equipment made portable from the primary facility.
Environmental sampling can be augmented by the State of Florida's Mobile Emergency Radiological Laboratory within three hours of notifi-cation. (See Section 5.4.2.1.)
If required, the laboratory facilities at FPL's Turkey Point Plant can be used.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.1.2 Protective Facilities 4.1.2.1 Assembly / Reassembly Areas Assembly / Reassembly Areas are designated depending on the classification of the evacuation. When a " Local Evacuation" is declared, all nonessential personnel in that particular area are to go to the designated assembly area for accountability and monitoring.
The designated " Local Evacuation" assembly area is announced during the evacuation notice. This area will vary depending on the location and nature of the declared emergency. When an "0wner Controlled Area Evacuation" is declared, the assembly area for nonessential personnel from the protected area is the Site Assembly Station,.5 miles north on Highway A1A. For personnel outside the Protected Area, the assembly area is the Jaycee Public Park, 7.8 miles north on Highway A1A.
Personnel are instructed to assemble by departments at the designated assembly areas., Essential personnel (Emergency Teams) are to assemble at the OSC in the Service Building.
The assembly area designated for protected area evacuated personnel appears to be too small to gather all personnel from within the protected area as defined in paragraph 1.2, page 1-5 of the REP: " Protected Area - The area (within the Owner Controlled Area) occupied by the two nuclear units and their associated equipment enclosed within the security perimeter fence."
Paragraph 5.2.2 of the REP, page 5-15, PERSONNEL ACCOUNTABILITY, TRANSPORTATION, AND EXIT ROUTES, indicates the maximum population within the Owner Controlled Area is approximately 3,050.
Most of the 3,050 are workers at the Unit 2 construction site within the protected area.
However, EPIP #3100026E, Rev. 5 provides assembly and evacuation guidance for Unit 1 only.
Based on the above findings, this portion of the program appears to be acceptable. However, the following should be considered for improvement: Providing a larger primary assembly area, and an alternative site for the evacuees from the Protected Area as defined in the REP. (50-335/81-13-10)
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- Providing assembly area and evacuation guidance for personnel working on
Unit 2~ side. (50-335/81-13-11)
4.1.2.2 Medical Treatment Facilities l The First Aid Room is located on the ground floor of the Reactor Auxiliary Building (RAB). The First Aid Room is provided with first aid supplies including , 2 - two kinds of stretchers.
In addition, standard 24-unit first aid kits are maintained at numerous locations throughout the St. Lucie Plant. A commercial first aid kit, containing the same type of supplies as the 24-unit kit, but in greater quantity, is maintained in the Site Assembly Station.
The medical supplies and first aid kits in the first aid station are checked at least every i two months and replenished as necessary by the Chemistry and Maintenance Departments.
A personnel decontamination washroom and shower room is provided on the ground floor of the RAB. Accepted decontamination practices are employed onsite. Life endangering injuries such as extensive burns, serious wounds or fractures shall , receive prompt attention in preference to decontamination.
Personnel with injuries involving radiation or radioactive contamination will be handled by REEF Associates, Inc. at the designated facilities at Mount Sinai Hospital, or by ' Radiology Associates, Inc. at the Lawnwood Medical Center, Fort Pierce, FL as i specified by EPIP 3100021, Rev. 9 - Medical Emergency Checklist.
The auditor reviewed the emergency kit located at the Lawnwood Medical Center and determined that the inventory was in accordance with Procedure HP-90.- (See < Subsection 5.5.1 of this report for details.) The medical center had provisions i for decontamination of patients and collection of the waste water.
However, there were no administrative controls over the drain arrangement in the decon-shower rooms.
Thus the hold-up tanks could be used for nonemergency showers.
Moreover, the medical center emergency plan had no provision for checking the tank level before and after emergency use.
The Medical Center Administrator stated that the plan would be revised to correct these weaknesses.
Based on the above findings, this portion of the licensee's program appears to be acceptable. However, the following should be considered for improvement: I Coordinating with the Lawnwood Medical Center in the revision of the emergency plan as described above, including the method of sampling the ' hold-up tanks for contaminated water and action levels for and method of disposition of. the waste water. (50-335/81-13-12)
4.1.2.3 Decontamination Facilities i Personnel decontamination washroem and showers with chemical decontamination l agents are provided on the ground floor of the RAB near the First Aid Room (see Section 4 ! 2.2).
The chemical decontamination agents available are mild soap and pot.us1am permanganate, if necessary.
Replacement clothing and waste disposal are provided.' However, decontamination provisions at each of the personnel assembly / reassembly areas are not specifically identified.
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Based on the above findings, this portion of the licensee's program appears to be acceptable. However, the following should be considered for improvement:
Providing and indicating specific decontamination equipment and provisions at each of the personnel assembly / reassembly areas. (50-335/81-13-13) 4.1.3 Expanded Support Facilities The Expanded Response Organization will be located in the General Office Emergency Center and/or the interim E0F.
These. areas contain communications equipment sufficient to accommodate a large number of persons, including corporate, contractor and nonlicensee augmentation personnel.
Additional facilities are available for 30 persons in the Training Center.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.1.4 News Center Provisions for an emergency news media center (ENC) require additional prepara-tion. The REP should be revised to clearly designate that the ENC on the site is located in the training trailer, adjacent to the interim E0F.
The ENC has adequate electrical supply to carry the added TV load, adequate copying services available, an adequate PA system and adequate audio-visual equipment. Telephone -
facilities for press use at the ENC are not adequate.
Four telephone jacks are available at present, with two additional telephones in adjacent offices.
' " Present telephone service requires routing calls through the plant switchboard and has no capability for direct long distance calls.
Plant security is adequate, but the information section of the REP should reflect specific plans for media badging and crowd control.
I The ENC on the site is not adequate for more than 20-30 media representatives or for a large television contingent. The alternate emergency news center, located , at the Jensen Beach Holiday Inn, about 8 miles from the site, is adequate in size. However, the present REP contains insufficient detail as to how adequate telephone service, copying, audio-visual equipment and security will be assured at that location.
Based on the above findings, this portion of the program appears to be acceptable. However, the following should be considered for improvement:
-Clearly identifying the ENC in the training trailer adjacent to the interim EOF.
. Improving the telephone facilities for the press with regard to number and capability for long distance calls.
Describing the provisions for media badging and crowd control.
i , Describing the support services provided at the alternate ENC (i.e., telephone service, copying, audio-visual equipment and security.)
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4.2 Emergency Equipment
4.2.1 Assessment 4.2.1.1 Emergen:y Kits and Emergency Survey Instrumentation The licensee reserves pre positioned supplies and survey instrumentation at specified locations in kits for use only during emergencies. These emergency kits are located at the Site Assembly area, the Control Room, the interim EOF, and the Lawnwood Medical Center. The location of these kits is specified in the emergency plan and in the Health Physics Operating Procedure HP-90.
Each emergency tea: provided for in the plan has ready availability to proper instrumentation, equipment and supplies.
The inventories. for each emergency kit were checked by the auditors and determined to be correct. The equipment was determined to be operable and was in calibration at the time of inspection.
The equipment to be used for teams reentering of tne facility or portions thereof include provisions for extremity monitoring and detection and measurement of beta and gamma radiation fields. The beta / gamma survey meters located in the approp-riate emergency kits include high level ratemeters and ion chambers.
Portable ion chamber instruments with beta / gamma distinguishing capability are
available for measuring whole-body dose rates in the plant.
Instrumentation for measuring plume exposure rates is not addressed in the emergency plan or present procedures. (Refer to Section 5.4.2.1. ) In the emergency kit located at the site assembly area, there are GM instruments with beta / gamma distinguishing capability used for detecting contamination on individuals.
Contents of the emergency kits provide sufficient numbers of instruments / supplies to equip the number of team members for its intended function.
Equipment and procedures are available for detecting in plant airborne iodine in the presence of noble gases.
Instrumentation is available for emergency environmental surveys with the cap-ability to detect and measure particulate activity in air of 10 ' pCi/cc (Cs-137 equivalent) without regard to the background radiation. However, procedures must be established and training conducted to demonstrate this capability. (Refer to Section 5.4.2.1.)
The instruments referred to are properly maintained on a regular schedule.
. Operability and calibration checks are periodically performed and these checks and calibrations appear to be accurate. The gamma-detecting survey instruments
are calibrated onsite using a calibration unit which is comparible with all of
the gamma detectors used.
If an instrument is considered inoperable, it is replaced with the same model instrument or with a compatible instrument. There i are written procedures for calibration of all the types of emergency radiation instruments.
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Based on the above findings, the following deficiency must be ccrrected to achieve an acceptable program: ' Provide the instrumentation to be used for emergency environmental surveys which have the capability to detect and measure radioiodine concentrations in air of at least 10 7 pCi/cc under field conditions. (50-335/81-13-15) The following matter should be considered for improvement of the program: Upgrade the emergency kit located at the Lawnwood Medical Center to incorpo-rate the following items: a.
Removir.g old implementing procedures from the emergency kit storage area, and, b.
Listing on the inventory sheet the large roll of blotter paper which is stored in the emergency ki t area for protection of the hospital corridor from contamination. (50-335/81-13-16) 4.2.1.2 Area and Process Radiation Monitors The area and process radiation monitors that are described in the plan and , procedures that are being relied upon for the emergency detection, classifica-tion, and assessment are in place and operable.
The readouts for all such monitors are located in the Control Room.
The monitors have the operating characteristics required to assess the accident conditions for which the plan is i designed to cope in terms of range, operating temperature, and humidity.
_ There exists the possibility that an elevated background radiation level could.
affect the reading of the post-LOCA monitors. (See Section 5.4.2.)
Calibrations of the area and process radiation monitors are performed across the entire response range.
The instruments appear to be maintained on a routine schedule. Operability and calibration checks are routinely performed; most of the instruments are calibrated once every 18 months and some more frequently.
These checks and cal'ibrations appear to be adequate.
Inoperable instruments appear to be repaired or replaced as needed. Written procedures are established for all of the monitors.
There is' redundant power supplied for all of the critical instruments.
The auditors could not determine that the detector efficiencies obtained for the monitors were correct; that is, that the conversion factors from readouts in the Control Room accurately represented radioactive concentrations / release rates.
The bases for conversion to dose rates were not clear; no reference to the source term was found. (See Section 5.4.2.)
Based on the above findings, this portion of the licensee's program appears to be acceptable.
t 4.2.1.3 Nonradiation Process Monitors Nonradiation ' process monitors such as chlorine, temperature, containment pressure, water level and flow monitors which are relied upon for emergency , , -- ,_,. -, , .-- - _ _. . ,. _., -
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detection, classification and assessment are in place and operable. Readouts for these monitors, except chlorine gas, are located in the Control Room and are readily observable. The chlorine gas storage area is monitored by an alarm that , would annunciate in the Control Room.
In addition, the air intake duct for the <- Control Room HVAC has an in-line chlorine monitor, which would isolate the
Control Room and place the HVAC in recirculation mode if the chlorine gas concentration in the intake air reached a predetermined level.
Based on the above findings, this portion of the licensee's program appears to be , acceptable.
4.2.1.4 Meteorological Instrumentation - , The bases for the auditors' review of the licensee's meteorological measurements program included Regulatory Guides 1.23 and 1.97 and the criteria set forth in NUREG-0654, -0696, and -0737.
' The licensee provided a description of their meteorological measurements system and the method for utilization of meteorological data in the REP and EPIP-3100022 (Rev. 8) and 3100033E (Rev.1).
The primary source of meteorological information is the onsite meteorological measurements program which provides the basic data of wind speed and wind direction (10m and 60m levels) and vertical temperature gradient (10m to 60m interval) as an indicator of atmospheric stability.
Onsite meteorological equipment is checked daily for operability and the system is calibrated semi- ! annually. Meteorological data are displayed on strip charts in the control room l behind the main instrument panels. Digital displays of instantaneous value's of ' wind speed, wind direction, and temperature for the 10m and 60m levels are also provided. The National Weather Service station at West Palm Beach, Florida, is the designated alternate source of meteorological information if onsite data are not available. The St. Lucie plant receives information regarding severe weather over the National Warning System (NAWAS).
The atmospheric dispersion model proposed by the licensee is a straightline trajectory model. The licensee should investigate the appropriater,ess of this i i model during sea breeze conditions or other local circulation patterns which may result in curved trajectories and/or airflow reversals within the plume exposure i EPZ. Due to the uncertainty in characterizing this effect, the scope and area for protective actions that may be recommended should be reconsidered.
! Based on the above findings this portion of the licensee's program appears to be
i acceptable. However, the following should be considered for improvement: Detailing the meteorological considerations used in the dose assessment procedure.
See Section 5.4.2 - for additional information.
A unique technical bases document supporting the assessment does not exist.
This document should address " sea breeze" effects discussed above.
(50-305/81-17-17) l l - _ , _.. - . _ _ _ .
- . - 14-Clarifying the meteorological data used in the dose assessment procedure,
e.g., data source (strip chart vs. LED), and data resolution (delta T ' scaling, stability grouping, wind speed stratification, and default values).
(50-335/81-13-18) -
' 4.2.2 Protective
4.2.2.1 Respiratory Protection Emergency equipment and supplies are located in the areas listed in the Procedure HP-90, Rev. 5.
Self-contained breathing apparatus (SCBA) are reserved for emergency use.
There are units in the appropriate emergency kits and additional units are located throughout the radiation-controlled area. Units are also reserved for emergency fire use. A minimum of 25 SCBA units are available f or emergency use. Capability for refilling the SCBA devices exists and this equipment is usable under conditions in which the internal areas of the plant have high airborne / direct levels of radiation.
, Based on the above findings, this portion of the licensee's program appears to be acceptable.
. 4.2.2.2 Protective Clothing Specific numbers of protective clothing are reserved for emergency use and are , stored with the emergency equipment at the locations listed in the Procedure ' HP-90. The auditors visited the storeroom and reviewed the procedures with the Stores Supervisor which insure that an adequate stock of protective clothing is available onsite at all times. Minimum stocking levels are maintained equal to , the stock levels considered adequate for a major outage.
Stock levels, a inventories and requisition of items are maintained by the Power Plant Stores j Office and were found to be up-to-date and acceptable. The minimum stock levels of protective clothing maintained should be sufficient for initial and continuing response to an accident. Clothing stocks are maintained outside the main plant building and should be accessible under emergency conditions.
q J Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.2.3 Communications The interim communications equipment specified in the emergency plan and implementing procedures were in place as specified. However, the licensee is in i the process of completing installation in the interim TSC of several additional communications systems which will satisfy the requirements of NUREG-0654 and NUREG-0696 for the final TSC.
The auditor examined the licensee's emergency communications system: plant public address system; plant UHF 2-way radio system; plant security radio system; plant private automated exchange (PAX) system; Control Room /TSC/ EOF dedicated j phone tie-line; Power Operated Portable Phones between the Control Room and
Technical Support Center; commercial telephones; NAWAS radio / telephone l
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--, - - -. , . ,,,, ,--, ,, .,----,,.7+,, -
circuits; LGR system; ENS and the Health Physics Network (HPN) to the NRC in h thesda and Atlanta; and FP&L FM radio system. The ENS system has vital power, and the plant PAX, NAWAS, LGR and FP&L FM radio systems have vital power on battery backup.
The auditor noted the interim TSC, which is being upgraded to be the final TSC, did not contain the requisite number of telephones per NUREG-0696. As previously stated in Section 4.1.1.2, the licensee will complete installation of TSC phones by mid-July.
Based on the above findings, this portion of the licensee's program appears to be acceptable. However, the following should be considered for improvement: Installing separate commercial lines, plant PAX and TSC/ EOF tie-lines for both licensee and NRC personnel in the TSC. (50-335/81-13-19) 4.2.4 Damage Control / Corrective Action and Maintenance Equipment and Supplies The REP states that repair and damage control will be assigned teams which may be composed of members from any of the emergency teams and may be augmented by non-FP&L support personnel. These teams would be under the direction of the Emergency Coordinator or his designee and would be used to mitigate the con-sequences of the accident and to help restore the normal operation of the plant.
Specific needs for onsite damage control, corrective action and maintenance equipment and supplies were not identified in the REP.
However, through discussion with the Mechanical Maintenance Supervisor it was indicated that equipment, supplies and personnel would be available to assist in the recovery from the emergency. The equipment used for normal plant operation is maintained such that it would be ready for emergency use and the reserves of supplies appear to be sufficient and should be available in emergencies.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.2.5 Reserve Emergency Supplies and Equipment The licensee relies upon the onsite inventory of supplies to support emergency operations. Adequate quantities of reserve supplies and equipment appeared to be available onsite or readily accessible from the onsite Power Plant Stores facility.
This facility maintained reserve supplies of protective clothing, respirators, smears and miscellaneous equipment (including spare parts for portable survey meters) with minimum stock levels identified.
If necessary, equipment from the Turkey Point Power Plant could be obtained for emergency use; this equipment would be compatible with the equipment now in use.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.2.6 Transportation The responsibility for transportation rests with the Security Manager. Transpor-tation of injured personnel associated with radiation or contamination will be
. .__,. _. _ _ _ ._ _ i
16 provided by Fort Pierce-St. Lucie County Fire District Rescue Service, when , called, to the Lawnwood Medical Center. Transportation of injured personnel not associated with radiation or contamination will be provided by the Rescue Service,.FPL Company (10 vehicles), or private individuals.
Additional trans-
portation may be provided by the specifically designated emergency vehicles of Unit 2 construction organizatiens or the Bechtel backfitting organization. No agreement has been indicated for using these emergency vehicles between these organizations and FPL.
t , There are no vehicles onsite designated by the licensee (Unit 1) for team " transportation.
There are no control provisions to insure availability of j licensee-owned vehicles to provide transportation for emergency purposes.
Based on the above findings, this portion of the licensee's program appears to be
acceptable. However, the following should be considered for improvement: ' Providing dedicated transportation for emergency team transportation.
! Providing controls to insure availability of licensee-owned vehicles for emergency transportation. (50-335/81-13-20) ! 5.0 EMERGENCY PROCEDURES 5.1 General Content and Format The auditors reviewed the procedures which implement the St. Lucie REP with i respect to their content and format and discussed procedures with licensee representatives. Overall, the implementing procedures were found to be adequate < ! regarding the assigned responsibilities for each area, prerequisites and conditions modifying specified actions, and guidelines for specific actions to be taken relative to the emergency levels and accident classification. Signoff of checklists have been included in those where they are applicable.
Except for those specific comments noted in each of the following sections, the form and.
content of the implementing procedures were found to be satisfactory, f Based on the above findings, this portion of.the licensee's program appears to be acceptable.
5.2 Emergency, Alarm and Abnormal Occurrence Procedures-The facility has annunciator response procedures, Emergency Operating Procedures.
(EOP), and Off-normal Operating Procedures (00P).
The annunciator responses, - according to Control Room personnel, were effectively not used for response to emergency alarm annunciators, but for the general panel alarms only. Operator guidance for emergency alarm annunciation is provided in the E0Ps and the 00Ps.
A review of selected E0Ps and OOPS showed references to the EPIP at some approp-riate locations.
A further review with Control Room procedures showed the following 00P/E0P should be interfaced with the EPIP since they fall in the . l -. - - - - -. -. ,. _ . -.. - - - . - -.,., - -., .
Unusual Event or Alert classifications: Number Revision Number Procedure Title 0030140
Blackout Operation 0030141
Control Room Inaccessibility 01200031
Excessive Reactor Coolant System Activity 01200032
Loss of Reactor Coolant Flow 0120041
Steam Generator Tube Leak Failure 0360040
Operational Requirements for Interim Ultimate Heat Sink 0810040
Main Steam Line Break 1300030
Loss of Containment Integrity--Off-Normal Operation 1600030
Accident Involving New or Spent Fuel Based on the above findings, this portion of the licensee's program appears acceptable. However, meshing the above ECPs and OOPS with the EPIP would improve this part of the licensee's program.
(50-335/81-13-21) 5.3 Implementing Instructions There are procedures for each class of emergency specified in the REP including an implementing procedure for onsite support centers. The St. Lucie Plant EPIP #3100022E provides the logic necessary to classify an emergency by the Emergency Coordinator (EC). The scope of the authority and responsibility vested in the EC is described in the REP including those responsibilities which may not be delegate.d to other elements of the emergency organization (see Section 5.4.1).
Each procedure describes the specification levels and planned response actions required to be considered in response to each class of emergency (e.g., staffing and activation of facilities and centers, initiation of assessment and protective action, etc.) The EALs were based on observable information readily available to the EC and others who are responsible for emergency detection, classification and assessment.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.4 Implementing Procedures 5.4.1 Notifications For each class of emergency, there is a sequence of notification of alert, mobilize or augment. The onsite emergency organization and supporting agencies'
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i immediate notifications, within 15 minutes of the declaration of an emergency, is i
the responsibility of the Emergency Coordinator. The equipment to be used in the ,
notification, such as ENS, HPN, and NAWAS are specified.
Planned messages, j
announcements and alarms are used for initial notifications.
Telephone numbers . are listed in the EPIP and Offsite Emergency Organization Procedure No.1301.
- The REP provides for authentication of messages between the Control Room and
Florida Bureau of Disaster Preparedness.
Based on the above findings, this portion of the licensee's program appears to be r
acceptable.
, 5.4.1.1 Public Alert and Notification System
L The auditor determined from discussions with licensee representatives that an , alert and notification system meeting the design objectives of Appendix 3 to ' NUREG-0654 has not been provided. Installation of sirens is expected to begin in . mid-July with completion sometime in December. FLP's response (April 28, 1981)
l to the staff's review comment on the subject matter indicated that the Emergency Plan would commit to such a system in the next revision (scheduled for August ' 1981), and that implementation of the system would be discussed under separate ! cover! ! . Based on these findings and due, in part, to the recently proposed changes to the regulation, the following matter has been identified as an unresolved item to be l reviewed during a subsequent inspection: An alert and notification system that meets the design objectives of , Appendix 3 to NUREG-0654. (50-335/81-13-22) ! ' , , 5.4.2 Assessment Actions j
Pursuant to 10 CFR Part 50.54 operating power reactors emergency response plans ' shal] be implemented by April 1, 1981, except as provided in Section IV, 0.3 of ! j Appendix E.
The intepim assessment actions have been found, during the course of the emergency prepa_ redness appraisal, to be seriously deficient. 10 CFR Part 50, Appendix E, Part If, B, requires that "the means to be used for determining the , ! magnitude of and for continually assessing the impact of.he release of radio-l active materials shall be described, including emergency action levels that are
to be used as criteria for determining the need for notification and partici-
apation of_ local and State agencies."
This requirement has not yet been i adequately demonstrated, as is discussed in this section in accordance with - Appendix, E, Part IV.B.
There is no demonstrated overall procedure which orchestrates the implementation ! of the accident assessment scheme (operational and radiological) that will l provide for the collection and assimilation of information and data needed for decisions on: '(1) escalating or de-escalating onsite corrective / protective ' actions, and (2) recommending protective actions for emergency events and announcing termination of such events. Further, there is no procedure to cover , l { ' !
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the priority system and sources of information that would be used (i.e., area and < process monitor readings, in plant radiation teams, offsite radiation teams or i the radiological and environmental monitoring program).
i There are no demonstrated provisions to allow definition of the radionuclide source terms that could be released to the environment. The magnitude of environ-mental releases of radionuclides is not addressed in quantifiable terms.
, EPIP 3100021E, " Duties of the Emergency Coordinator," contains a specific
methodology using the post-LOCA monitor alarm for recommending offsite protective t .j actions for the population at two, five and ten miles.
If the post-LOCA monitor ! alarms at 1R/hr, (reading radiation exposure rates through the containment wall),
a General Emergency would be declared, and one of two actions would occur: ' First, assuming no containment failure, recommendations would be made to , government agencies to evacuate within 360 degrees around the reactor, for up to ,
5 miles. - However, should containment fail, the alternative action would involve
recommending evacuation of the population within a 90 degree sector (between 5
i and 10 miles) and complete evacuation within the 5-mile planning zone r l (360 degrees).
i EPIP 3100033E, issued in March of 1981, indicates that the Emergency Coordinator i would notify offsite authorities of: i 1.
Meteorological conditions, i 2.
Projected thyroid and whole-body dose at 1, 2, 5 and 10 miles, and 3.
Whether default values or actual measurements were used for dose estimates.
, Specific radiation levels measured by the post-LOCA radiation monitor on the ' r shield building wall would categorize, in accordance with EPIP 3100033E, the loss ' of coolant accidents A through D.
Determination of the meteorological stability class is then procedurized in i EPIP 3100033E. Walk-through discussion with shift operations personnel showed that meteorological data are readily accessible in the Control Room. The meteoro-logical readout selected by the Nuclear Watch Engineer was a digital readout that , updates the reading every 10 seconds. The strip chart recorder, which provides i j ready summation of differential temperature ( AT) for 3 or 4 hours was not used , because the procedure indicates SHOULD instead of SHALL for a fifteen-minute
period.
Section 8.1.5 of EPIP 3100033E states: " Determine the average wind direction
l-over at least the most recent fifteen minute period..." Section 8.1.4 of the same procedure states, " Determine the average wind speed over at least the most , ' recent fif teen-minute period..." Section 8.1.2 states "This value ( AT) should i be an average for at least a fifteen-minute period." Walk-through on each shift ! , demonstrated that the shift supervisors and nuclear watch engineers have not been ! taught the significance of error in this procedure.
, i With the existing program, a difference of one-tenth of a degree Farenheit ( F), can shif t the accident classification up or down from stability class A+B to C+D ' i (or vice versa), and change projected doses at five miles in five mile / hour winds
! by a factor of ten for a Class D LOCA (from 0.22 Rem to 3.42 Rems). Further, a i i !
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1.2 F difference can, with the same parameters, change projected doses for a Class D LOCA from 0.22 Rem to 20.4 Rems, about a factor of 100.
, The dose factor for LOCA Types (categories) B, C & D (i.e.,1, 6 and 60) were define'd by the NWE. The tables providing dose by time and distance were also ! demonstrated adequately by the NWE.
Thus, although EPIP 3100033E was explained adequately, in terms of the way it was written, the NWE made it clear that the.1R per hour post-LOCA monitor reading, following indications of loss of coolant, automatically initated a General Emergency, and evacuation would be recommended in accordance with the protective action table.
Walk-through investigations of the post-LOCA monitor locations showed that they were attached to the outside walls of the containment in the fan room. However, no mention was made of having portable dose rate measurements taken at that location to verify the readings, nor was there any procedure with instructions on what to do if these monitors were either offscale or not working.
No basis document was available to allow evaluation of whether or not the cmergency action levels prescribed in EPIP 3100033E were valid. No source term ! was defined to allow interpretation of the prescribed action levels. Instead the !. LOCAs were defined as Classes A, B, C, and D.
There are exhaust plenums in the vicinity of the post-LOCA monitors that could conceivably carry sufficiently high !
quantities of noble gases following a LOCA to cause the monitors to alarm at levels that would not cause true Site Area or General Emergency LOCA conditions.
Should a Class A LOCA somehow increase background dose rates at the post-LOCA
' monitor to IR/hr., (assuming the 1.2 F error described above), population doses would be estimated a factor of 7500 high.
l Provisions exist for determining the containment source term via four containment monitors that read out in the Control Room.
Plans exist to add a high range i containment monitor.
Provisions also exist for containment liquid and air sampling (See Section 5.4.2.4) along with monitoring of the plant vent and other , effluent streams.
I However, none of these sampling and monitoring provisions have currently been demonstrated as part of the radiological assessment function. Reliance is placed solely on the post-LOCA monitors.
l There is no demonstrated capability for radiological or environmental survey ' teams either in the plant, following a loss-of-coolant accident, in the plant environs, nor offsite. Thus, there is no demonstrated capability for making
initial dose projections in the event that control rcom instrumentation is either j offscale or inoperable, f There are adequate provisions for notification of offsite and onsite authorities ! and personnel within the allotted times specified in NUREG-0654.
However, ' although verification of the initial calls are specified, provisions for continuous updating of * assessment information on dose projections and/or
protective action recommendations are not defined.
, , ' s . __ . .. -,-.. -... _,. _ _ - -. _ .. . . _. -.
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t t i f !
i ! Currently, FP&L does have specific plans to upgrade the total radiological ! assessment capability 'to conform to 10CFR50, Appendix I.
However, since the .' planned upgrade is not now in place, it cannot be evaluated.
Thus, to comply ' with 10 CFR Part 50, Appendix E requirements, the following items must be completed to demonstrate an acceptable emergency assessment program: .
-
1.
An overall operational and radiological assessment procedure, . 2.
Definition of accident source terms in the emergency procedures, i 3.
Review, modification and clarification of EPIP 3100021E (or other procedure ! as desired) so as not to " override" the instructions of EPIP 3100033E.
'
i
4.
Modify EPIP 3100033E to more clearly reflect the licensee's intent to . ' provide meteorological accuracy within the limits of equipment error and ' ] provide training to all Emergency Coordinators on the use of the revised procedure. (50-335/81-13-23 for items 1 through 5)
5.
Provision for verification of radiation readings of the post-LOCA monitors.
[ L (Note: Items 2, 4 and 5 above are covered by the confirmation of action i letter dated June 30,1981.)
{ t' 6.
Make other program improvements specified in the section-by-section analysis below.
5.4.2.1 Offsite Radiological Surveys
The REP states that the Florida Department of Health and Rehabilitative Services ' maintains a system of 39 TLD stations in the vicinity of the plant. Stations are provided in each 22.5 degree sector at the 1-mile, 5-mile, and 10-mile
(approximate distances) radii.
The locations of the stations appear to be appropriate.
i ' The REP also states that analysis of offsite environmental samples will be i performed at the State's Mobile Emergency Radiological Laboratory (MERL). This mobile lab is now located in Criando, but can be in position near the site within
j three hours of notification and would serve as a central point for the receipt of all offsite field monitoring data and coordination of sample media.
No procedures were available which discussed emergency offsite radiological t surveys. Moreover, the REP does not describe the capability and resources for [ , ' field monitoring within the plume EPZ by onsite emergency radiation teams. This
matter is further addressed in Section 5.4.2.12 of this report.
! i Based on the above findings, the following deficiency must be resolved to achieve
- i an acceptable program: There are no emergency procedures and instructions for Health Physics [ personnel to define methods, and equipment for the detection of iodine concentrations in air down to 1E-07 pCi/cc under field conditions in the i presence of noble gases, communications, and radiation protection guidance i for emergency offsite radiological surveys. (50-335/81-13-24) ! !
! > I ! i ' ., - -_ . - - - -.,,.... _ _., - -,. - -, - - _.. - - -., _ - _ m--., -
- - . . .- __ -. -. . _.
I
(Note: This item is covered by the confirmation of action letter dated
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June 30,1981) The following should be considered for improvement: Providing emergency procedures and instructions for Health Physics personnel to define methods, and equipment for the detection of particulate activity ' in air of 1E-09 uCi/cc, communications, and radiation protection guidance for emergency offsite radiological surveys. (50-335/81-13-25) i 5.4.2.2 Onsite (Out-of plant) Radiological Surveys No procedures were available which discussed emergency onsite (out-of plant) radiological surveys.
, Based on the above findings, the following deficiency must be corrected to
achieve an acceptable program: There are no emergency procedures containing instructions for Health Physics < personnel to define methods, equipment, communications and radiation protection guidance for emergency onsite (out-of plant) radiological surveys. (50-335/81-13-26) ' 5.4.2.3 In-Plant Radiological Surveys
No procedures have yet been fully developed for emergency radiological surveys.
FP&L plans to develop such procedures.
! Based on the above findings, the following deficiency must be corrected to achieve an acceptable program: . There are no emergency procedures containing' instructions for Health J Physics personnel to define methods, equipment, communications, and-
radiation protection guidance for emergency in plant radiological surveys.
(50-335/81-13-27) } 5.4.2.4 - 5.4.2.9 Post-accident Sampling and Analysis (Includes
Sections 4.1.1. 5 - 4.1.1.8) .l ! These ten sections are discussed together as a unit. Primary coolant, contain-
ment ' air and stack effluent sampling and analysis for post-accident conditions
are addressed in the St. Lucie REP and are covered by emergency procedures.
Hereinafter these sampling and analysis items are referred to as the Post-Accident Sampling & Analysis Program (PASAP).
The interim sampling, analysis and calibration portions of the PASAP procedures ' were reviewed by the auditors, and evaluated during walk-throughs to determine j personnel familiarity with the procedures and procedural applicability.
Instructions and supplies for collecting and labeling samples, communications ? - systems and remote laboratory use were available. Data is recorded from each sample and the results are centrally collected in the OSC and then given to the , TSC staff.
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Personnel involved in the interim collection and analysis of the PASAP ware trained to use remote handling equipment to maintain personnel exposures below 3 rems.
They would be continuously monitored during this work by a Radiation Protection Man. Contamination control was adequately considered.
-Based upon the above findings, this portion of the licensee's emergency prepared-ness program appears to be acceptable.
However, the following should be considered for improvement: Within the remote (cold) laboratory, radioactive samples are not normally handled.
As a result, there is no predesignated, shielded or isolated location for ' storage of radioactive samples.
Consider making provisions for sample storage along with the capability for proper radiation area demarcation capability. (50-335/81-13-28) 5.4.2.10 and 5.4.2.11 Liquid Effluent Sampling and Analysis While no procedures exist for emergency sampling and analysis of the subject effluents, it is believed that the nonemergency sampling and analysis program is sufficient to cover both nonemergency and emergency needs.
Based on the above findings, this portion of the program appears to be acceptable. However, the following should be considered for improvement: Including in the present procedure specific instructions which could apply to emergency liquid effluent sampling or providing a separate emergency procedure. (50-335/81-13-29) 5.4.2.12 Radiological and Environmental Monitoring Program No procedures exist for the necessary radiological and environmental monitoring emergency program. The State of Florida maintains radiation monitoring stations within the plume EPZ. Support in this area is available from the State and the Department of Energy.
Based on the above findings, the following deficiency must be corrected to achieve an acceptable program: There has been no development of a coordinated, integrated radiological and environmental monitoring program including procedures which interface witn the offsite support in this area from the State of Florida and the respond-ing federal agencies. (50-335/81-13-30) 5.4.3 Protective Action 5.4.3.1 Radiation Protection During Emergencies Routine procedures will be used in emergencies with a few exceptions that are to be specified.
The use of routine procedures minimizes the potential for confusion during emergency events. HP 62 for example, provides the system for refilling air bottles.
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- , .There are ample provisions for expanding the respiratory protection program (see-Section 4.2.2.1). Constant air and area radiation monitors will be used to alert all workers to changing work environment radiological conditions. However, no work will be done in areas of rapidly changing radiation level unless a Radiation
Protection Man is available. Thus, emergency events will closely parallel normal operation conditions in terms of employee protection.
Procedures for. chemical sampling and analysis, first aid, rescue and decontami-nation, and maintenance require appropriate health physics coverage. Thus, items , . such as essential high dose rate sampling and analysis and first aid and decon-l tamination are defined by procedures.
i~ The licensee's program for radiological protective action appears to be acceptable except for the procedural deficiencies identified in Section 5.4.2, and minor adjustments in the training program described in Section 3.2.
. 5.4.3.2 Evacuation of Owner controlled Areas Section 5.2.2 of the REP and EPIP #3100026E, Rev. 5, provide guidance and policy on evacuation procedures. The REP indicates that alarms and/or the plant public address (PA) system will be used to announce evacuation orders. Depending on the nature of the emergency and the extent of the area affected, onsite evacuations will be classified as either a Local Evacuation or an Owner Controlled Area Evacuation.
' When a ' Local Evacuation is declared, all nonessential personnel in that particular area are to evacuate through the Radiation Control Point (RCP) in the , RAB for accountability and monitoring and report to the designated assembly area , announced over the PA system.
i Owner Controlled Area Evacuation will be declared in the event of a Site Area [ Emergency, General Emergency, or at any time the Emergency Coordinator determines j that evacuation is appropriate.
Evacuees are to report to the Assembly / Reassembly Areas described in Section 4.1.2.1.
The Security Force assists and controls the evacuation and conducts a sweep of the plant to verify that all personnel have' evacuated. The Security Force also ensures that adequate transportation is provided visitor evacuees.
There appears to be only a primary evacuation route north on Highway A1A as designated in the REP and EPIPs. A secondary route to the south appears not to
have been considered. This leaves no alternatives for the high traffic density - of the Unit 2 construction workers and backfit personnel evacuating north on l Highway A1A through residential areas to the Jaycee Park Assembly Area.
There also appears to be an insufficient amount of evacuation arrows, signs, ,~ . floor markings or other readily visible means indicating evacuation routes on and off site to the ' designated assembly areas. Evacuation route signs were found only in the Radiation Control Area (RCA).
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Based on the above findings, this portion of the licencee's program in this area
appears to be acceptable.
However, the following should be considered for improvement: Designating a primary and secondary evacuation route. Use of alternative I routes may prevent a potential high density traf fic problem on Hutchinson Island. (50-335/81-13-31) I Establishing evacuation route signs at the intersections of the plant egress i roads and Highway A1A and to the designated assembly areas.
(50-335/81-13-32) 5.4.3.3 Personnel Accountability j When an evacuation is declared, all personnel are to go to their designated assembly areas as discussed in Sections 4.1.2.1 and 5.4.3.?. The Security Guard , i Force has the initial responsibility to account for personnel during a protected area evacuation. This is done by a visual inspection of the access control badge i rack and by a print-out log from the Access Control Computer of the cavJ key , l entries.
! The department supervisors and foremen account for their personnel at the ! assembly areas with the assistance of the Security Force personnel present. The i Assembly Area Supervisor is responsible for personnel accounting at assembly areas and reports to the Emergency Coordinator.
! Based on the above findings, this portion of the licensee's program appears to be j acceptable. However the following improvement should be considered: Developing and implementing specific procedures for Security Guard Force personnel on what specific actions will be taken by specific guard personnel during radiological emergency conditions involving personnel accountability.
< { (50-335/81-13-33) 5.4.3.4 Personnel Monitoring and Decontamination Personnel monitoring and decontamination procedures are provided for in the St. Lucie Operating Procedures or the Health Physics Procedures. The procedures provide for recording of names of individuals surveyed, the extent of any contami- ' l nation found, instruments used, methods employed, and results of any l decontamination efforts.
The procedures contain contamination levels that ] require decontamination actions. Contamination and/or radiation levels that are l unexpectedly high are required, by procedure, to be reported to the NPS.
l
Based on the above findings, this portion of the licensee' program appears to be acceptable.
I [ 5.4.3.5 Onsite First Aid / Rescue l , i Procedure HP-70, Revision 2, covers the methods for decontamination (decon) of i the human body (hair, eyes, skin, nose, etc. ). In the event of an injury,
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EPIP #3100021, Revision 9, covers the caring for, recovering and handling of all injured persons, who may also be contaminated, and tran.;portation to the Lawnwood Medical Center. Pescue operations are conducted by the First Aid /Decon Teams and the Radiation Team, activated and instructed by the EC.
Entry into potentially hazardous areas are made only under direction of the Radiation Team.
The First Aid /Decon Team Leader is the Chemistry Supervisor or his representative trained in first aid and personnel decontamination. The Radiation Team Leader is the Health Physics Supervisor or his representative.
Based on the above findings, this portion of the licensee's program appears to bc acceptable.
5.4.4 Security During Emergencies The security emergency teams are trained in Emergency Plan Familiarization, Personnel Accountability Procedures, Site Ingress and Egress Control Procedures, and Deployment of Security Personnel.
The Security Guard Force assists in Evacuation (see Section 5.4.3.2), Vehicle Traffic Control (see Section 5.4.3.2) and Personnel Accountability (see Section 5.4.3.3) at the Radiation Control Point of the RAB, Main Gate and the Assembly Areas. They provide assistance in trans-porting visitors to the Assembly Area. The Security Force conducts a sweep of the plant site to verify accountability and that all personnel have evacuated.
Discussions with Security Guard personnel indicate that supervisory personnel were knowledgeable of what to do during a radiological emergency in the areas of evacuation and accountability.
However, nonsupervisory personnel basic instructions were to secure their posts and await further instruction.
Based on the above findings, this portion of the licensee's program appears to be acceptable. However, the following improvement should be considered: Developing and implementing specific procedures for Security Guard Force personnel under emergency conditions. (50-335/81-13-34) 5.4.5 Repair / Corrective Actions The REP describes the make-up and, in general, the responsibilities of the Repair and Damage Control Team.
The teams, composed of members from the other emergency teams, are under the direction of the Emergency Coordinator. However, procedures are not available that describe the concept of the operations for repair or corrective activities. The steps to assure that individuals are properly briefed as to the radiological conditions, stay times, etc., prior to , the conduct of the operation have not been identified in finalized procedures.
Based on the above findings, this portion of the licensee's program appears to be acceptable. However, the following should be considered for improvement.
Providing emergency procedures and instructions defining repair / corrective actions. (50-335/81-13-35)
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f 5.4.6 Recovery
The REP specifies the organizational authority for declaring that a recovery phase is to be entered. Provisions exist in the plan for an evaluation of plant ' ! operating conditions as well as the in plant and out-of plant radiological conditions. Notifications are to be made to various individuals and agencies , that must be completed before a recovery mode may be assumed. Key positions in j the recovery organization are identified.
Based on the above findings, this portion of the licensee's emergency program
appears to be acceptable.
> 5.4.7 Public Information Procedures identify both company and outside organizations involved in news dissemination. Additional specification of some state and county officials is needed to complete the notification lists.
Methods for coordinating internal dissemination of information to the various locations and individuals are specified, along with interim provisions for initial dissemination of information to the news media prior to establishment of the licensee's news center.
The utility spokesman is identified, along with sources of information to be used.
! Provisions for coordinating information among the various spokesmen of the i various organizations and groups presently contain insufficient detail as to how the company will accomplish this task.
Provisions for rumor control have not been developed. The company is discussing i a joint FPL-St. Lucie County rumor control center with county officials. If this
does not rapidly materialize, FPL should set forth procedures to see that the I company has its own plan.
. Based on the above findings, this portion of the program appears to be accept-able. However, the following should be considered for improvement: ! j ) Providing additional specification of some State and County officials in order to complete the notification lists.
Clarifying plans for coordinating information among the various spokesmen of the various organizations and groups.
Finalizing the plans for rumor control. (50-335/81-13-36) 't 5.5 Supplementary Procedures 5.5.1 Inventory, Operational Check and Calibration of Emergency Equipment, Facilities and Supplies t Procedure-HP-90 discusses the inventory of emergency equipment and supplies and establishes periodic cal _ibration and operational checks of the emergency radiation monitoring equipnient. Procedures discussing the operational checks and , ' calibration of specific radiation monitoring equipment are established and appear to be complete and up-to-date.
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, j' HP-90 provides a specific inventory listing of all equipment reserved for use
during emergencies and specifies the location of the equipment. This procedure states that an emergency kit shall not be below the recommended quantity of an ,
item for more than 4 days unless written authorization from the H.P. Supervisor extends this period. The item should be immediately replaced without provisions
for waiver of this requirement.
The frequency at which emergency equipnent is to be inventoried and operationally checked is specified in the procedure as once each quarter. Records showed that in ' practice the equipment has been checked on the average of once each month.
- The equipment is calibrated onsite at specified intervals.
The responsibility for the performance of the emergency equipment readiness checks and for
correcting any noted deficiencies is delineated.
The following should be considered for improvement: Revising the procedure for inventory of emergency equipment and supplies i such that if a major piece of emergency equipment is removed that item will be replaced immediately in order to maintain a complete up-to-date kit at all times. (50-335/81-13-37) Changing the reference in HP-90 in item 8.10 from "4.5" to "4.4" and add ! another column to the inventory sheets titled " operability check" to assist in the operation check of the equipment.
Including in the proper emergency kits: 1) stop watches, 2) appropriate H.P. procedures, and 3) higher-range dosimeters to allow monitoring of the radiation doses associated with life-saving and other emergency corrective actions. (50-335/81-13-38) 5.5.2 Drills and Exercises '
The FPL Emergency Plan Administrator is responsible for the planning, scheduling, and coordination of major emergency drills or exercises involving offsite agencies. The St.Lucie Plant Operations Superintendent has the same responsi-bility for all onsite emergency drills. There appears to be no Emergency Plan Administrator / Coordinator designated in the REP or EPIP 3100050E.
This is - discussed in Section 1.1 of this Appraisal.
The Plant Manager and Sperations > Superintendent, depending on the type of drill or exercise, are responsible to , ensure that deficiencies which are identified are addressed with.orrective measures. All drills and exercises, are conducted as required in NVIEG-0654 and designated in the. REP.
The NAWAS and LGR are exercised daily; how.ver, there
i appears to be no documentation of these tests with the agencies indicated in ' EPIP 3100050E, Section 8.lf.
l Based on the above findings, this portion of the licensee's program appears to be acceptable. However, the following should be considered for improvement: Documenting communication tests when conducted. (50-335/81-13-39) { . % ~. ..-- -_ -,_ __.- - - . --. _ -
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5.5.3 Review, Revision and Distribution Section 7.3.1 of the REP requires a quarterly review of the telephone call lists and an annual review of the REP. These are conducted in accordance with NUREG-0654.
Section 7.3.1, pages 7-12 of the REP indicates procedures are subject to continuing review and are changed as necessary.
Criterion P.9 of NUREG-0654 requires reviews of EPIPs at least every 12 months. However, EPIPs 3100024E,16 Oct.1979, Natural Emergencies, and 3100031E, 12 Sept. 1978, Oil Spill Emergencies, were found without documentation of an annual review.
, Based on the above findings, this portion of the licensee's program appears to be acceptable. However, the following should be considered for improvement: Changing Section 7.3.1 of the REP to require EPIPs to be reviewed at least every 12 months.
Documenting the review of EPIPs 24E and 31E.
(50-335/81-13-40) 5.5.4 Audit Section 7.3.4 of the REP indicates that TPL Quality Assurance (QA) Department will conduct an independent audit of emergency preparedness at least once every two years. Criterion P.9 of NUREG-0654 requires reviews of the emergency preparedness program at least every 12 months. The auditor determined that, in practice, QA Audits are conducted annually. Guidance is provided in FPL's OA Manual on how the audits will be conducted.
Plant management, the Emergency Plan Administrator and the Manager-Power Resources Nuclear evaluate audit findings and recommend corrective actions to the Vice President--Power Resources.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
However, the following should be considered for improvement: Changing Section 7.3.4 of the REP to require audits of the emergency preparedness program at least every 12 months.
(50-33b/81-13-41) 6.0 C0 ORDINATION WITH 0FFSITE GROUPS 6.1 Offsite Support Agencies The auditor discussed offsite support agencies with licensee representatives and reviewed recently upgraded agreement letters with offsite support agencies identified in the REP. Training has been provided for all offsite support groups and plant orientation tours have been held to familiarize these individuals who may need to respond to the site, with the general plant layout and access procedures.
In general, all offsite groups responding to the site will be accompanied by Security Force personnel while inside the protected area boundary.
On June 12, 1981, the auditor and licensee representatives met with representa-
tives from the St. Lucie County Sheriff's Office, Lawnwood Medical Center, St. Lucie-Fort Pierce Fire Department and St. Lucie County Civil Defense Office, ,
identified in Section 9.1 of this report, to discuss emergency response to an ' accident at the St. Lucie site. The individuals contacted at each agency were ' f I . _ _ _ _ __ ...... .,,
cognizant of their role in an emergency, had been provided training relative to their respective roles in emergency resporse and were satisfied that adequate contact and interface between their organizations and FPL have been provided.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
6.2 General Public FPL has act completed provisions for dissemination of emergency planning infor-mation to the public within the plume exposure EPZ.
FPL information office representatives state that they are awaiting action by the State of Florida's decision as to what form this information will take, how it will be packaged and how it will be distributed. Emergency action information coordination with State and local agencies has not been completed. There is no procedure to designate how it will continue to be updated and disseminated annually.
Based on the above findings, the following deficiencies must be corrected to achieve an acceptable program: Provisions for updating and disseminating emergency planning information to the public within the plume EPZ on an an..aal basis must be established.
+ Provide for establishment and distribution of the information package.
Establish a coordinated public information program. (50-335/81-13-42) 6.3 News Media The Vice President, Corporate Communications, designated as the Emergency Information Manager, serves as the principal spokesman for FPL and is responsible for disseminating information to the news media and for coordination with State and local news media ' representatives regarding news releases.
However, FPL does not presently have a specific program for familiarizing news media with emergency plans and associated details Such a program has not, to date, . been conducted and no specific provision has been made to do so on an annual basis.
Based on the above findings, this portion of the licensee's program appears to be acceptable. However, the following should be considered for improvement.
Developing a specific program for familiarizing the news media with emergency plans and associated details.
Conducting the initial program and providing for a repeat on an annual basis. (50-335/81-13-43) 7.0 DRILLS AND EXERCISES
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., . 7.1 Program Impleme.ntation l For the most part drills have been completed as per schedule. One auditor found 'that one drill was not completed on schedule; however, it was completed following i the audit.
Five full-scale exercises invciving state and local agency personnel
have been conducted by FP&L. These exercises have also involved support groups.
! Changes were made following exercise critiques, to insure more effective future } exercises. The critiques involved all participating agencies and the press.
t
In 1979, a hurricane required evacuation of Hutchinson Island.
The trained ! forces evacuated the island in one hour.
t I On June 17, 1981, the auditors observed a fire orill on site. The simulated fire l was postulated to start in the cable spreading room of the RAB. _ The cable , , spreading room is located underneath the control room. The fire was reported by , an employee to the NPS who, in turn, called the Fire Team to deal with the fire, i The team, with proper protective apparel and equipment, arrived and described its ! precise location (in the cable tray around the core controller) to the NPS, who ! promptly placed the reactor in simulated hot shutdown. The fire was put out in i 20 minutes.
The decision to restart the reactor or place it in cold standby would have been made after a damage report had been received.
i Based on the above findings, this portion of the licensee's program appears to be acceptable, i i 7.2 Walk-through Observations l
Walk-through observations showed that FP&L has the capability to notify [
responsible State and local governmental agencies within 15 minutes of the L [ discovery of initiating events. All of the shifts were visited over four days of l walk-through, and all discussions with supervisors and other employees demon-
strated that their basic skills and knowledge was adequate to perform all
assigned emergency tasks.
Equipment and facilities specified in procedures to accomplish tasks were avail-able, operable and adequate. Those procedures that were written were understand- ' able, up-to-date and complete, with the exceptions noted in other Sections of i this report.
> Walk-throughs were performed with the NPSs and NWEs covering the spectrum of potential accident initiating conditions covered in the REP. All members of all
shifts understood their responsibilities and the systems to classify and i implement actions relating to all four classes of emergencies.
Walk-throughs were performed with the Chemistry Supervisor and Chemistry Technicians to observe their knowledge of and familiarity with the proper procedures for obtaining and analyzing specific samples.
Radiation Protection
Men were also involved.in similar walk-throughs demonstrating their knowledge of i potential " hot-spots" in the plant and use of the proper detection equipment.
l The auditors did not observe any impediments to timely and effective performance ! of the following areas: 1) post-accident coolant sampling and analysis-2) containment air sampling and analysis; 3) stack effluent sampling and ! . l .. t -- t , ! . ! ! . -.., , , _, -. -. --. --... -. - - -- - ,. ., --.
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!' analysis; 4) liquid effluent sampling - and analysis; 5) in plant sampling and-analysis. The chemistry technicians were familiar with the procedures necessary to obtain a representative sample and the proper techniques and procedures for the_ sample analysis. The Radiation Protection Men that were walked through the sampling areas had been well-trained and were familiar with the possible
" hot-spots" and the operation of the proper radiation protection equipment to be
used.
They were also able to estimate the radiation levels which could be present at specific areas within the radiation-controlled area for different accident scenarios.
Procedures for offsite environmental sampling and analysis are not available.
Walk-throughs in this area were not performed.
(See Sections 5.4.2.1 and 5.4.2.12.)
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Procedures are available for protective action decision-making and walk-throughs demonstrated that the personnel responsible for this action were capable of '
performing them. Procedural deficiencies are addressed om Section 5.4.2 of this ! report.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
! 8.0 FOLLOW-UP DN PREVIOUSLY IDENTIFIED ITEMS RELATED TO EMERGENCY PREPAREDNESS j (CLOSED) 50-335/80-19-01--Procedure HP-90 has been changed to correct the weakness stated in IE Rpt. No. 50-335/80-19.
] (CLOSED.) 50-335/78-BF-02--Silver zeolite cartridges have been purchased and are stored onsite.
Onsite counting equipment for determination of the amount of iodine present appears to be adequate.
, (CLOSED) 50-335/79-FI-07--No portable survey meters on or offsite have ranges greater than 1000 R/Hr; however, one such instrument is on order.
There are instruments available which have an upper range of 1000 R/Hr.
(OPEN) 50-335/79-23-04--IE Bulletin 79-18: Equipment will be ordered to
install volume boosters on existing Gaitronics speakers in the Service ' Building (20 locations), plant areas (24 locations) and the RAB ) (11 locations).
The equipment will be delivered on or about July 15, and installation is expected to begin in those areas with the greatest audibility problems.
Licensee management is committed to have the l installation completed by August 31, 1981.
] Auditors observed a test of the site evacuation alarm on June 12. The areas found by the auditors to have audibility problems are included in the lists of the locations described above and found in PWO-5682.
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. 9.0 PERSONS CONTACTED ! 9.1 Licensee Personnel
- C. Wethy, Plant Manager
! J. Barrow, Operations Superintendent j
- H. Buchanan, Health Physics Supervisor
- H. Johnson, Emergency Planning Supervisor, Power Resources M. Craig, Electrical Maintenance Supervisor
,. ' G. Longhouser, Assistant Plant Security Supervisor i J. West, Plant Security Supervisor i
- N. Roos, Quality Centrcl Supervisor
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- R. Jennings, Technical Supervisor
- A. Bailey, Quality Assurance Operations Supervisor
. D. Newberry, Maintenance Supervisor C. ' Wilson, Maintenance Supervisor F. Davis, Nuclear Plant Supervisor . i 0. Hayes, Nuclear Plant Supervisor
D. Oliver, Plant Stores Supervisor-T. Dillard, Mechanical Maintenance Supervisor ! B. Escue, Site Manager, Unit 2 '
- R. Frechette, Chemistry Supervisor D. West, Nuclear Plant Supervisor
- H. Mercer, Assistant Health Physics Supervisor i
C. Davis, Nuclear Plant Supervisor .
- K. Harris, Assistant Manager, Power Resources, Nuclear I
Other licensee employees contacted included 18 technicians 3 Nuclear Watch , i Engineers, 8 Security Force Members, 3 Maintenance - personnel, 2 Construction Personnel and 5 Office Personnel.
j .9.2 Other Organizations ' ' ' C. L. Norvell, Sheriff, St. Lucie County - B. King,- Administrator, Lawnwood Medical Center i Dr. Theodorou, Chief of Staff, Lawnwood Medical Center R. E. Rogers, Chief, St. Lucie County - Fort PiFire Department
P. Rodi, Disaster Preparedness Coordinator, St. Lucie County.
. l 9.3 NRC I ' *S. Elrod, Senior Resident Inspector
! H. Bibb,' Resident Inspector ' i
- J. P. Stohr, Acting Director, EPOS Division, RII
- F. G. Pagano, Chief, ELB, OIE
- Attended the exit interview on June 19, 1981.
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~ ATTACHMENT I EVALUATI0N OF THE ST. LUCIE EMERGENCY PLAN 1.0 BACKGROUND Evaluation by the Nuclear Regulatory Commission (NRC) of the state of emergency preparedness associated with the St. Lucie Nuclear Station (site) involves review of Florida Power and Light Company's (FP&L) eme gency preparedness and the Federal Emergency Management Agency's (FEMA) findings on State and local radio-logical emergency preparedness.
This evaluation addresses FP&L's emergency preparedness.
Supplement (s) to this evaluation will address the findings and determinations of FEMA on the adequacy of the State and local emergency response plans and the NRC staff's overall conclusions on the status of emergency preparedness associated with the St. Lucie site and related Emergency Planning Zones.
FP&L filed, by letter dated December 30, 1980, a comprehensive revision to the St. Lucie Unit 1 Radiological Emergency plan (Unit 1 Plan), Revision 7, dated January 2, 1981, in accordance with the new emergency planning rule which became effective November 3, 1980.
Since the submittal of Revision 7, FP&L has responded to NRC staff comments on Revision 7 and has submitted to the NRC: 1) Revision 8 (minor revision, April 1, 1981), 2) Revision 9 (major revision, August 1, 1981), and, 3) by letter dated September 1, 1981, a revision to the Unit 2 FSAR which included a revised St. Lucie Plant Radiological Emergency Plan that incorporated Unit 2.
On June 8-19, 1981, the Emergency Preparedness Licensing Branch (EPLB) conducted an Emergency Preparedness Implementation Appraisal (EPIA) at St. Lucie Unit 1.
Revision 9 to the Unit 1 Plan provided partial resolution for those plan deficiencies identified during the EPIA.
On September 24, 1981, Mr. Ken Harris, Assistant Manager, Power Resources Nuclear, and other members of the FP&L staff met with Mr. Frank Pagano, Chief, Emergency Preparedness Licensing Branch and other members of the NRC staff to discuss the open items associated with the St. Lucie Emergency Plan. During the meeting, FP&L addressed all of the open items and made certain commitments which were confirmed in writing on September 24, 1981. These commitments, described in Section 2 of this report, will require a substantial revision of the plan. FP&L has committed to submit a revised Plan by January 15, 1982.
This Emergency Preparedness Evaluation Report applies to the St. Lucie Plant (Units 1 and 2) Radiological Emergency Plan (hereinafter referred to as the Plan), as submitted by FP&L on September 1,1981, as a change to the Unit 2 FSAR, and FP&L's commitments submitted on September 24, 1981.
The Plan was reviewed against the requirements of 10 CFR Part 50.47(b),10 CFR Part 50, Appendix E, and the criteria of the 16 Planning Standards in Part II of the " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," NUP:6-0654/ FEMA-REP-1, dated November 1980.
Section 2 of this report lists each standard followed by a synopsis of applicable portions of the Plan as they apply principally to the standard and those items
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for which resolution is required. Section 3 of this report provides our review conclusions.
, 2.0 PLAN EVALVATION 2.1 Assignment of Responsibility (Organizational Control) Standard Primary responsibilities for emergency response by the nuclear facility licensee, and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of_ the various supporting organiza-tions have been specifically established, and each principal response organiza- , tion has staff to respond and to augment its initial response on a continuous basis.
Emergency Plan Esaluation The Plan describes the functions and responsibilities of the State and local , organizations that are part of the overall response organization for Emergency Planning Zones.
The Plan illustrates the overall State of Florida Emergency Response Organization.
- The State of Fiorida Bureau of Disaster Preparedness (BDP) is the State agency authorizea to receive initial notification from FP&L and is responsible for ' mobilizing the State and county emergency response agencies in accordance with the Florida Radiological Emergency Plan for Nuclear Power Facilities (State Plan, REP). This plan appears in Appendix A to the St. Lucie Plan and includes the St. Luc.ie and Martin County plans. However, the State of Florida REP, submitted under correspondence dated December 30, 1980, has undergone substantial changes and must be re-submitted.
I The State of Florida Department of Health and Rehabilitative Services (DHRS), Radiological Health Services, is the State agency authorized to provide the BDP with technical support and expertise in radiological matters.
The Plan identifies the counties within the plume EPZ and those within the ingestion pathway EPZ, and, in general, the responsibilities of these local organizations.
. Alerting, warning, and evacuation of populations, and hosting responsibilities,
! including shelter location and operation, and evacuee registration, monitoring, ' and decontamination are described in the State Plan.
Responsibility for direction and control rests with the Chairman, Board of County Commissioners. The County Disaster Preparedness Directors, who report to the
Boards of County Commissioners, are responsible for actual plan development and updating.
i Updated written agreements have been executed with the Federal, State, and local i agencies and organizations identified in the Plan as providing radiological support, hospital support and transportation, fire protection, traffic control on i -. ,
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land and waterways, and law enforcement during an emergency. Appendix A, State of Florida REP, contains a draft agreement to be signed by FP&L, State and county officials.
Letters of agreement involving emergency support by offsite support agencies / organizations are discussed further in Section 2.2, below.
An agreement letter between FP&L and the Department of Energy (formerly ERDA) Savannah River Operations Office (DOE-SR00), dated April 12, 1977, that was included in Revision 8 to the Unit 1 Plan has been deleted from the Plan.
FP&L has committed to provide an updated agreement letter with DOE-SR00, and to submit an updated State plan when the revised plan is available.
2.2 Onsite Emergency Organization Standard Onshift facility licensee responsibilities for emergency response are unambig-uously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available, and the interfaces among various onsite response activities, and offsite support and response activities are specified.
. Emergency Plan Evaluation The Nuclear Plant Supervisor (NPS), designated as the Emergency Coordinator, has the responsibility and authority to implement the Plan and initiate any necessary emergency actions. The Emergency Coordinator operates from the Control Room of the affected unit, and will not delegate the responsibility for the decision to notify and make protective action recommendations to offsite authorities.
The Plan identifies a line of succession, up to the Plant Manager, for the position of Emergency Coordinator.
S'tation staff emergency assignments have been made and the relationship between the emergency organization and normal staff complement are specified and illustrated in the Plan.
Positions and/or titles of shift and plant staff personnel, both onsite and offsite, assigned emergency functional duties are listed.
The shift staffing specified in the Plan does not meet the specific staffing recommendations expressed in Table B-1 of NUREG-0654. Clarification is needed in Table 2-2a of the Plan with regard to the position of the individual on shif t assigned the task of notification and maintaining communications, and the identi-fication of two Nuclear Plant Supervisors and two Shift Technical Advisors (STA) on each shift. Additionally, Table 2-2a indicates that changes in the number of Nuclear Watch Engineers (from 1 to 2), Nuclear Control Center Operators, SR0 and R0 (from 2 to 4), Nuclear Operators (from 1 to 2) and Nuclear Turbine Operators (from 1 to 2) are pending NRC/FP&L negotiation.
' The response time for augmentation capability does not meet the specific staffing recommendations at 30 and 60 minutes expressed in Table B-1 of NUREG-0654 in any
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37 position. Table 2-2a of the Plan indicates a capability for additions within 45-90 minutes after notification.
When an off-normal. condition is detected, it is the responsibility of the NPS to implement the - emergency classification procedure.
There is 24-hour per-day communication linkage capability between the St. Lucie site and Federal, State, and local response agencies and organizations.
The authority, responsibility, and duties of the plant staff personnel for coping with emergencies are defined for both the normal operating staff, and the augmented staff.
The Plan describes the functions of the onsite emergency , organization, licensee headquarters support, and State and local government support groups, and illustrates the interface between and among these groups and
the onsite Technical Support Center (TSC), Operations Support Center (OSC), and near-site Emergency Operations Facility (EOF).
The Plan describes the expanded response phase initiated by the Emergency Coordinator. His notification mobilizes the FP&L Offsite Emergency Organization as well as local, State, and Federal emergency response organizations.
The Emergency Control Officer (ECO), a designated corporate officer, has the authority to establish policy and expend the funds necessary to cope with any emergency situations that may arise.
The Recovery Manager (RM), a designated corporate officer, has the responsibility for directing FP&L's expanded emergency response organization. The RM can report to the General Office Emergency Center, the near-site EOF or the onsite TSC depending on his assessment of the situation.
' The Expanded Response Organization is described and illustrated in the Plan.
Additional staff support can be provided to augment the operating staff onsite and offsite.
Lines of succession for the ECO and Managers of the Offsite Emergency Organi-zation are controlled by procedures maintained by the EPS.
The Plan identifies the Institute for Nuclear Power Operations (INPO) and Combustion Engineering Company (CE) as possible sources of additional technical, personnel, and material support. The Plan also identifies Radiology Associates, Inc. as providing medical support at the Lawnwood Medical Center.
Written agreements, however, are not provided for INPO, CE or Radiology Associates, Inc.
In addition, the written agreements involving the Mt. Sinai Radiation Emergency Evaluation Facility (REEF), the Department of Energy (00E), the Radiation Emergency Assistance Center Training Site (REACTS), and the REEF Medical Plan are on the order of 3-5 years old and require updating. The REEF Medical Plan also requires a signature page.
The letters of agreement with offsite police, ambulance, hospital, and fire support identify the emergency measures to be provided. However, the letters do not delineate the limits on the actions of the support groups, the mutually acceptable criteria for their implementation, or the arrangements for exchange of information.
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FP&L has committed to clarify Table 2-2a of the Plan with regard to the position of the individual assigned the tasks of notification / communication; the two NPSs ! dnd two STAS on each shift; and shift staffing for the other positions discussed above.
- , FP&L has committed to provide letters of agreement for INPO, CE (when available), and Radiology Associates, Inc.; to update the letter of agreement with REEF, and the REEF Medical Plan (which includes letters with DOE and REACTS); and to provide additional specification in the letters of agreement with the St. Lucie County and Martin County Sheriffs, Lawnwood Medical Center, and the St. Lucie County - Fort Pierce Fire District as discussed above.
! ' The following item requires resolution: . . (1) Provide an onsite shift staff and augmentation capability that meets the ' specific staffing recommendations expressed in Table B-1 of NUREG-0654.
(Note: On November 5,1981, a meeting was held between Mr. C. O. Woody, Manager, Power Resources Nuclear and other members of FP&L and members of the NRC staff to discuss the shift staffing and augmentation time for the St. Lucie site. Curing the meeting FP&L committed to submit to the NRC, by November 23, 1981, an alter-
native to the specific staf fing recommendations expressed in Table B-1 of
NUREG-0654.)
2.3 Emergency Response Support and Resources
Standard
Arrangements for requesting and effectively using assistance resources have been made, arrangements to accommodate State and local staff at the licensee's near-site Emergency Operations Facility have been made, and other organizations I capable of augmenting the planned response have been identified.
' Emergency Plan Evaluation . ! Request for support under the Federal Radiological Monitoring and Assessment Plan . (formerly Radiological Assistance Plan (RAP) and Interagency Radiological Assistance Plan (IRAP)) will be coordinated through BDP, DHRS.
The Emergency l Coordinator has the responsibility to notify Federal, State, and local officials,
as appropriate, upon declaration of an emergency.
FP&L has provided facilities for representatives from Federal, State, and local ' government organizations and groups at the EOF.
The Plan, however, does not provide information concerning specific licensee, State, and local resources , available to support Federal response or the expected arrival times of Federal i , assistance at the site.
The Plan states that FP&L will dispatch a representative to the St. Lucie County EOC which has been identified as the primary EOC for an emergency at St. Lucie.
In addition to the St. Lucie site primary and backup radiological laboratories, the Plan identifies a hot lab backup at the site using portable equipment, the i , -
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State's Mobile Emergency Radiological Laboratory (MERL) available within three hours of notification, and laboratory facilities at FP&L's Turkey Point Plant which can be used.
FP&L has committed to specify the procedures for accommodating NRC and FEMA , personnel at the EOF, and provide additional specification regaraing specific licensee, State and local resources available to support the Federal response,
and the expected arrival times of Federal assistance at the site.
2.4 Emergency Classification System Standard A standard emergency classification and action level scheme, the bases of which
include facility system and effluent parameters, is in use by the nuclear
facility licensee, and State and local response plans call for reliance on ' information provided by facility licensees for determinations of minimum initial offsite response measures.
! Emergency Plan Evaluation she four standard emergency classes (i.e., Unusual Event, Alert, Site Area , ! Emergency, and General Emergency) have been established by the applicant.
Observable and measurable emergency action levels (EALs) which, if exceeded, will ' initiate each emergency class, consistent with the criteria of Appendix 1 of i NUREG-0654, have been established.
EALs are provided using specific instru- ' mentation, parameters, and equipment status.
Emergency Plan Implementing Procedures (EPIP) contain specific information and guidance for determining the , appropriate EAL and properly classifying the emergency condition, as well as the appropriate actions to be taken.
An upgraded Emergency Classification System, contained in Section 3 of the Plan submitted by FP&L on September 1,1981, incorporates Unit 2 into the emergency preparedness program. This upgrade is currently under review by the staff. A supplement to this report will provide the staff's conclusions as to the adequacy of the Emergency Classification System for the St. Lucie site.
2.5 Notification Methods and Procedures Standard Pracedures have been established for notification, by the licensee, of State and local response organizations and for notification of emergency personnel by all response organizations; the content of initial and followup messages to response organizations and the public has been established; and means to provide early
notification and clear instructions to the populace within the plume exposure pathway Emergency Planning Zone have been established.
Emergency Plan Evaluation ' The Plan is activated with the declaration of an emergency.
The NPS will continue as the Emergency Coordinator until properly relieved by the Plant . _. _ __ . -..,_ -. =_.
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' Manager. or his designated alternate.
The Plan and associated procedures , establish and describe a notification and verification system which provides for i rapid notification of the FP&L onsite and offsite 'mergency Organizations, Florida Bureau of Disaster Preparedness State War
- Point Tallahasse (SWPT),
St. Lucie County E0C, Martin County E0C, and tht naC Operations Center.
The essential communication links are manned continuously and will be periodically tested to assure availability.
The information to be reported to the offsite agencies in the event of an emergency has been predetermined in accordance with the recommendations in NUREG-0654 and the format of the initial notification message is included in the . ] Plan. The Plan specifies that follow-up messages will be made by the Emergency Coordinator to BDP, however, the format and content of follow-up messages is not specified.
The initial message format could be used for follow-up messages
provided additional information that is recommended in NUREG-0654 is supplied.
) The Plan specifies that FP&L has committed to purchase and install an alert (stren) system. The Plan, however, does not indicate that the system will meet i the recommended criteria set forth in Appendix 3 to NUREG-0654. The Plan speci-fies that the State Plan provides information on warning of the public and discusses warning procedures in St. Lucie and Martin counties.
The State Plan also provides the guidance for keeping the public informed about the potential , hazards, emergency response, and protective measures that can be taken to min-
imize or avoid public health affects.
The Plan, however, does not address , ] written messages intended for the public.
FP&L has committed to provide a followup message format from the facility to ' offsite authorities, to provide a general description of the Alert and Nctifi-cation System, and to provide a description of written messages intended for the
public, consistent with the St. Lucie emergency classification scheme.
( 2.6 Emergency Communications i Standard
i , i Provisions exists for prompt communications _ among principal response
organizations to emergency personnel and to the public.
Emergency Plan Evaluation
Primary and backup communication links which include provisions for 24-hour- , per-day notification are provided with the Federal, State, and local emergency i response organizations within the 10-mile EPZ. The Plan includes organizational
' titles and alternates for both ends of the communication links.
The offsite communication systems include the NAWAS, commercial telephone,
' l dedicated telephone lines, company radio and Local Government Radio (LGR).
The Plan provides for periodic testing of the entire communication system.
j ! The Plan describes the communications between the State and local EOC, radio- ' i logical monitoring teams, NRC headquarters, NRC Regional E0C, interim E0F, and interim TSC.
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41 The Plan describes the arrangements for offsite medical support and a coordinated communication link for fixed and mobile medical support facilities.
' 2.7 Public Education and Information Standard information is made available to the public on a periodic basis on how they will . be notified and what their initial actions should be in an emergency (e.g.
listening to a local broadcast station and remaining indoors), the principal points of contact with the news media for dissemination of information during an , , emergency (including physical location or locations) are established in advance j and procedures for coordinated dissemination of information to the public are j established.
Emergency Plan Evaluation
The Plan specifies that the State of Florida BDP and St. Lucie County and Martin
County Disaster Preparedness Agencies have the responsibility for conducting the t public information program with FP&L providing financial and technical support.
This program will include information on radiation, respiratory protection, ,
sheltering, evacuation procedures, warning and notification systems, and who to ! contact for additional information.
The State Plan contains discussion on evacuation of "special needs" population.
Transient and permanent population ! will be provided an opportunity to become aware of the information. While the Plan indicates that the information will be disseminated periodically, it does ' not specify that the program will be updated and disseminated on an annual basis.
. FP&L wi,ll conduct an annual program for personnel of the news media which will acquaint these persons with the Plan, provide information concerning radiation, and provide points of contact for release of public information during an
emergency.
! FP&L has established an Emergency News Center near the interim EOF.
The
Emergency Information Manager (EIM) is responsible for disseminating information ' to the public via the media. The EIM will work with the NRC, State and local news media representatives and will assure that the exchange of information among > designated spokespersons is accomplished in a timely manner. The Plan indicates that this timely exchange of information will aid in responding to rumors; however, the Plan does not address coordinated arrangements for dealing with , rumors.
i FP&L has committed to include in the public information program provisions for i annual dissemination of information to the public and to provide a draft of this ' material for review, and to provide a reference to the State Plan which describes coordinated communication arrangements between FP&L and the State and county that
are used as the means for rumor control.
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2.8 Emergency Facilities and Equipment Standard Adequate eme'rgency facilities and equipment to support the emergency response are provided and maintained.
Emergency Plan Evaluation Emergency facilities to support an emergency response have been established as
i follows: (1) Control Rooms The Control Rooms contain those controls, instruments and communications equipment necessary for operation of the plant under both normal and emergency i conditions.
The ventilation system, shielding, and structural integrity are designed and built to permit continuous occupancy during postulated accidents.
For any emergency response, the Control Room of the affected unit serves as the initial point of control.
(2) Technical Support Center (TSC).
The interim TSC is located adjacent to the Unit 1 Control Room. The role of the TSC is to provide command and control functions, provide dose assessment, and provide technical assistance to the Control Room and EOF staffs.
The TSC Supervisor and his staff will be located at the TSC. Activation of the interim TSC will be initiated by the Emergency Coordinator in the event of an Alert, Site Area Entergency, or General Emergency. Arrangements will be made to staff the interim.TSC in a timely manner.
(3) Operational Support Center (OSC) , , The OSC provides an area for operations, maintenance, health physics, and chemistry personnel to assemble and be assigned to duties in support of the ,
emergency response. The OSC is located in the first floor maintenance area of ! the Service Building.
PAX communications are maintained between the OSC and Control Rooms.
Activation of the OSC will be initiated by the Emergency - Coordinator for Alert, Site Area Emergency and General Emergency. Arrangements will be made to staff the OSC in a timely manner. In the event the OSC becomes untenable, the Emergency Coordinator will designate an alternate location.
(4) Emergency Operations Facility (EOF) l The interim E0F is designated as the Unit 2 site construction office building.
i The interim EOF provides the central point from which evaluation and coordination of all FP&L activities related to an emergency can be carried out and from which - ' FP&L can provide information to Federal, State, and local authorities.
The interim EOF contains emergency radiological monitoring equipment and
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supplies, communications network including LGR, radiological health services (DHRS) radio, and commercial telephone lines, essential precalculated emergency { i- . , ,,~-r ,, -, - - - .-n - - - -, - -- - -. .- - -, - - - - - - - - -. - ,.,..... - .
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, data and reports, and plant drawings. Activation of the interim EOF will be 4' , initiated by the EC0 dur:ng a Site Area Emergency or General Emergency. Arrange-
l ments will be made to staff the interim EOF in a timely manner.
An alternate EOF is maintained at FP&L's Walton Tra >smission and Distribution ' Substation, approximately 5 miles west of the plant. This facility will be used if the interim EOF becomes untenable.
Continuity of EOF functions during any transition between the interim and alternate facilities will be maintained by the General Office Emergency Center and interim TSC.
On June 8, 1981, FP&L submitted the conceptual design for the Emergency Response
Facilities (ERF), which includes the TSC, OSC and EOF.
The ERF is currently ' under review by the staff.
In correspondence dated October 1, 1981, FP&L committed to provide additional information on the EOF.
Following a review of all information submitted by the FP&L, a supplement to this report will provide l the staff's conclusions as to the adequacy of the ERF.
F , . (5) General Office Emergency Center ! i , The General Office Emergency Center is an area within the Power Resources Manage- ! , ment area at the FP&L General Office in Miami, Florida.
It is equipped with a dedicated telephone to the Plant Manager's office. The ECO and his staff will man the center to direct the Offsite Emergency Organization and to provide support and resources to the onsite organization until the EC0 directs the organization to staff the interim EOF.
' The Plan describes, in general, radiation monitoring systems portable radio-logical sampling and analysis equipment, and a meteorological measure system, including an offsite backup source of data. However, additional' gents speci-
fication of the Area and Process Radiation Monitoring systems is required
including type of detector, location, range of measurement and alarm setpoint.
The Plan does.not describe other onsite monitoring systems that would be used to !
initiate emergency measures, including hydrologic and seismic monitors, and
process monitors (e.g., liquid levels, flow rates or line-up of equipment com- - ponents).
FP&L is in the process of upgrading the onsite meteorological measurements program in accordance with Appendix 2 to NUREG-0654. At a later date a supple-ment to this report will provide the staff's evaluation and conclusions on the adequacy of the upgraded system.
The Florida DHRS maintains a system of 39 TLD stations in the vicinity of St. Lucie.
Stations are provided in each 22 sector at approximately the 1 mile, 5 mile, and 10 mile radii.
Laboratory facilities are provided as discussed in Section 2.3, above.
The l plant's onsite laboratory serves as the primary facility with backup provided by ! portable equipment. Analysis of offsi.te environmental samples will be performed at the State's MERL.
This mobile lab can be in position near the site within three hours of notification and serves as the central point for the receipt of l all offsite-field monitoring data and coordination of sample media. The Plan ' i + " , ,... - . -. . -, - - -. c.
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' specifies that the State Plan describes field monitoring teams including team composition, transportation, communications, equipment and estimated deployment times.
The Plan specifies that plant procedures provide for activation of emergency field monitoring teams; however, there is no description in the Plan of
a - coordinated program for Environmental Radiological Monitoring, including provisions to acquire data from or for emergency access to offsite monitoring and analysis equipment.
Designated emergency equipment that is maintained at key locations throughout the ! plant' will be inventoried, operationally checked and inspected at least once each calendar quarter and following each use.
The Plan provides general emergency equipment lists for the Control Room, OSC, and the interim EOF.
t r FP&L has committed to include in the Plan, from FSAR Table 11.5-1, a listing of
the Area and Process Monitoring Systems, including type of detector, location, , range of measurement and typical alarm setpoint, and other onsite monitoring systems that are specifically relied upon in the emergency classification scheme, and to describe the Environmental Radiological Monitoring Program, which illustrates a coordinated program with the offsite support from the State of Florida and that the coordination with DOE will be provided by the State of . Florida.
, l 2.9 Accident Assessment Standard , ' Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use, j Emergen'cy Plan Evaluation - The Plan identifies specific instrument readings and other observable and measurable parameters which, if exceeded, will indicate an emergency a's discussed in Section 2.4 of this evaluation. General descriptions are given for effluent monitors, area radiation monitors, grab sampling equipment and containment monitors. Specifications of instrumentation utilized for accident assessment and postaccident sampling capabilities are also described in procedures.
However, the Plan does not address the methods and techniques (procedures) to be used for determining the source term of potential releases of radioactive material.
The Plan does not indicate whether the plant radiation monitoring systems meet the upgraded requirements of NUREG-0737.
A plant procedure provides the details on the method for estimating initial doses i using current meteorological data, process monitor data and post-LOCA radiation monitors. Dose calculations will be updated periodically during the course of an ! accident and the results will be provided to State and county authorities.
{ Default values, using conservative estimates of release rates, can be utilized if I assessment instrumentation is not available (offscale or inoperable) and field sample analysis has not yet been completed.
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The Plan specifies that meteorological data displays are available in the Control Room. It is not clear, however, if Unit 2 Control Room has meteorological data displays.
Communication systems between the Control Room, the interim TSC, interim E0F and State E0C provide access to meteorological data.
The Plan describes, in general terms, the capability for field monitoring by plant personnel during the period from the declaration of an emergency to the time required for State monitoring teams to get in position in the vicinity of St. Lucie (estimated to be approximately 3 hours).
Additional information regarding the capability for offsite monitoring by plant personnel is needed, including field team composition, activation, notification means, monitoring equipment and deployment times.
In addition, the capability to detect and measure radioiodine concentrations in air, in the plume exposure pathway EPZ, as low as E-07 microcuries per cubic centimeter, under field conditions, has not been addressed in the Plan.
The Plan compares the estimated integrated doses with the protective action guides. However, it is not clear that the means have been established for relating the various measured parameters to dose rates for key isotopes and for estimating integrated dose from the projected and actual dose rates.
FP&L has committed to: (1) Identify the specific procedures which describe the methods and techniques to be used for determining the source term of potential releases of radio-active material, (2) Include in the commitment expressed in Section 2.8 above the plant radiation monitoring systems that meet the requirements of NUREG-0737, (3) Specify that Unit 2 Control Room has meteorological data displays, (4) Identify the specific procedures which provide information on the offsite monitoring capability by plant personnel, including those elements described above, (5) Identify the specific procedures that provide the capability for detection and measurement of radiciodine concentrations in air, in the plume EPZ, as low as E-07 microcuries per cubic centimeter, under field conditions, and (6) Identify the specific procedures that describe the means for relating the various measured parameters to dose rates for key isotopes and for estimating integrated dose from projected and actual dose rates.
2.10 Protective Response Standard A range of protective actions have been developed for the plume exposure pathway EPZ for emergency workers and the public. Guidelines for the choice of
i l
l protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been developed.
Emergency Plan Evaluation The Plan establishes guides for determining when protective actions are required onsite.
The actuation of fire alarms, radiation alarms, evacuation alarms, telephone calls, and public address announcements, as applicable, will immediately alert employees, visitors, contractors, and other onsite personnel to hazardous conditions and actions they must take.
The Plan describes the monitoring and decontamination of onsite personnel during a local evacuation; however, it is not clear that the monitoring capability exists at the designated offsite assembly areas specified in the Plan. Nor is it clear what decontamination capability is provided at the offsite assembly areas.
The Plan describes and illustrates the evacuation route to the offsite assembly areas; however, it does not include alternatives for high density traffic and specific radiological conditions.
The Plan specifies that an onsite " reaction time" (time measured from the time of an accident until the initiation of evacuation) should not exceed 30 minutes.
The Plan, however, does not describe the capability for 30 minute accountability and for accountability of all onsite personnel continuously thereaf ter.
The Plan provides for recommending offsite protective measures to State and local authorities for the population-at-risk in the plume EPZ depending on the projected dose to the environs. However, the Plan does not contain the bases for the choice of recommended protective actions from the plume exposure pathway during emergency conditions.
The Plan does not contain evacuation time estimates.
The Plan refers to the State Plan regarding plans to implement protective measures for the plume EPZ, including evacuation maps, population distribution maps, and means for notifying all segments of the population, including those whose mobility may be impaired. The Plan specifies that control of radioactive contamination ar.d public safety in offsite areas are the responsibility of the respective County Disaster Preparedness Departments, DHRS, and BDP.
Upgraded evacuation time estimates, currently under review by the staff, must satisfy the criteria of Appendix 4 to NUREG-0654. A supplement to this report will provide the staff's conclusions as to the acceptability of the methodology used to determine the evacuation time estimates.
FP&L has committed to: (1) Expand the description of the monitoring and decontamination capability at the offsite assembly areas identified on page 5-16 of the Plan, including reference to applicable procedures.
(2) Include in Figure 5-1 of the Plan, " Site Evacuation Routes", alternates for high density traffic and specific radiological condition (3) Provide for accountability of all onsite individuals within 30 minutes of the declaration of an emergency and for all onsite individuals continuously thereafter.
(4) Provide, in the Plan and appropriate EPIPs, a summary of the evacuation time estimates.
(5) Expand the current description of recommended offsite protective actions to include the EPA Protective Action Guides.
2.11 Radiological Exposure Control Standard s Means for controlling radiological exposures, in an emergency, are established / for emergency workers. The means for controlling radiological exposures shall ' include exposure guidelines consistent with EPA Emergency Workers and Lifesaving Activity Protective Action Guides.
Emergency Plan Evaluation FP&L has established a radiation protection program for controlling radiological exposures in the event of an emergency.
With the exception of individuals providing ambulance service and medical treatment services, emergency exposure guidelines have been provided for the various categories of radiation workers.
These guidelines are consistent with the EPA Emergency Worker and Lifesaving Activity Protective Action Guides.
It is not clear, however, that emergency procedures shall be worked out in advance for permitting onsite volunteers to receive radiation exposures in the course of lifesaving and other emergency activities.
The Plan provides for 24-hour per-day determination of doses received by onsite workers and offsite response personnel and for appropriate record keeping.
The Plan provides for personnel decontamination facilities. Onsite contamination control measures for personnel, equipment, and access control are provided.
Clarification is needed in regard to action levels for determining the need for decontamination of personnel during an emergency condition.
In addition, the Plan has not clearly established provisions for onsite contamination control measures for drinking water and food supplies, and criteria for permitting return of areas and items tu normal use during an emergency / recovery condition.
. The Plan addresses the handling of contaminated waste, including special circum-stances, during an emergency condition.
FP&L has committed to: (1) Provide emergency exposure guidelines for those individuals providing ambulance service and medical treatment service in accordance with 10 CFR Part 20.
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(2) Identify the procedures that shall be followed for permitting onsite volunteers to receive radiation exposure in the course of emergency activities.
(3) Clarify action levels for determining the need for decontamination of , . personnel during emergencies.
(4) Clarify contamination control measures with regard to driaking water and food supplies and criteria for permitting return of areas to normal use during an emergency / recovery conditon.
2.12 Medical and Public Health Support Standard Arrangements are made for medical services for contaminated and injured individuals.
Emergency Plan Evaluation FP&L has made arrangements, confirmed in writing, with a qualified hospital located in the vicinity of the site for receiving and treating contaminated or exposed persons.
This hospital will be available 24 hours per day and shall maintain the capability and facilities to provide decontamination, first aid, and emergency medical treatment to injured or ill persons from the site. Arrangements for back-up hospital and medical center equipped for the definitive evaluation and treatment of radiation injuries have also been confirmed in writing. Letters of agreement with these hospitals are discussed in Section 2.2 of this report.
The Plan provides for onsite first aid capability.
FP&L has made arrangements, confirmed in writing, for ambulance service for transporting persons from the site to the primary hospital in the event of a radiological as well as a nonradiological accident.
2.13 Recovery and Reentry Planning and Postaccident Operations Standard General plans for recovery and reentry are developed.
Emergency Plan Evaluation The Plan describes the general plans for recovery and reentry.
It is the responsibility of the Recovery Manager (Manager, Power Resources-Nuclear) to determine when an emergency situation is stable and has entered the recovery phase. As the Recovery Manager, he is responsible for the overall aspects of the recovery operation.
The Plan establishes criteria that must be met before recovery operations can begin. The Plan specifies that all applicable Federal, State and local agencies will be informed that the emergency has shifted to a recovery phase.
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The Plan describes the Expanded Response Organization which includes key personnel in the areas of public relations and information, command and control, technical services, engineering support, security, and logistics.
The Plan specifies that the State Plan provides the process for periodically estimating population exposure.
' 2.14 Exercises and Drills Standard Periodic exercises are (will be) conducted to evaluate major portions of emergency response capabilities, periodic drills are (will be) conducted to develop and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected.
Emergency Plan Evaluation The Plan ensures that a major exercise will be conducted on an annual basis that will involve participation of of fsite emergency support personnel within the county and State emergency organizations. This exercise will be conducted as a Site Area Emergency or General Emergency. The scenario will be varied such that all plans and preparedness organizations are tested within a 5 year period. One exercise will start between midnight and 6:00 a.m. and another between 6:00 p.m.
and midnight once every 6 years. The Plan does not provide for exercises to be conducted under various weather conditions or for unannounced exercises as recommended by NUREG-0654.
The Power Resources Emergency Planning Supervisor is responsible for the planning, scheduling, and coordinating of drills and exercises involving offsite agencies. The site Health Physics Supervisor has the same responsibility for all onsite emergency drills.
All drills and exercises involving the plant are approved by the Plant Manager.
Each drill and exercise is conducted to test the state of emergency preparedness and is designed to meet a list of specific objectives which are specified in the Plan.
The Emergency Planning Supervisor and Health Physics Supervisor will coordinate and implement Plan revisions and required corrective actions resulting from the drills and exercises.
Drills are supervised instruction periods aimed at testing, developing, and maintaining skills in the following areas and frequencies: Radiological monitoring drills - annually.
Health Physics drills - semiannually.
Medical emergency drills - annually Fire drills - in accordance with Technical Specifications.
Communication links and notification procedures are tested at least semiannually.
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Communication drills - communication with State and county governments will [ be tested monthly; communications with Federal response agencies and States
. within the 50-mile EPZ will be tested quarterly, and communications between
! the site, State E0C, St. Lucie County EOC, Martin County EOC, State and , field assessment teams will be tested annually.
t ! i h
The Plan has not incorporated communication tests for the plant offsite monitor-l ing teams into the radiological monitoring drills. In addition, the description E
of the communication drills does not include the aspect of understanding the I content of messages.
! i Following an exercise, the Emergency Planning Supervisor, plant management, FP&L [ observers, and principal participants in the exercise will meet to discuss and ! evaluate the exercise. Plant management will be responsible for any necessary < changes in the Emergency Procedures and for recommending changes in the Plan to ! the Emergency Planning Supervisor.
j FP&L has committed to provide for unannounced drills, and to include in the drill program communication tests with the plant offsite monitoring teams, including [ the aspect of understanding the content of messages for all the communication
tests.
j r l 2.15 Radiological Emergency Response Trainin_g [ i i Standard i
i I
Radiological emergency response training is provided to those who may be called [ upon to assist in an emergency.
l t Emergency Plan Evaluation ! The Plan provides for training and retraining of personnel on the emergency tasks for which they are responsible as specified in the Plan.
The St. Lucie Plant , Training Supervisor is responsible for the conduct and documentation of initial > training and periodic retraining programs for on-site FP&L emergency organization personnel, except Emergency Teams.
Emergency Team Leaders are responsible for ! i training team members and reporting the conduct of such training to the Training l , Supervisor.
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. Tha Plan describes specialized training and retraining for personnel assigned to i ! the emergency organization, including the Emergency Coordinator, TSC staff, first ! aid and rescue team, fire brigade, security team, radiological monitoring team, i , l Shif t Technical Advisor, Onsite Emergency Organization, and Offsite Emergency l t Support Organization.
l FP&L will provide training and annual retraining for those offsite organizations l
whose services may be required in an emergency, such as fire, police, medical
' support, local disaster preparedness officials, and rescue personnel.
The ' ( training will be consistent with the organization's emergency functions, i ! ' ,
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2.16 Responsibility for the Planning Effort: Development, Periodic Review, and Distribution of Emergency Plans Standard Responsibilities for plan development and review and for distribution of emergency plans are established, and planners are properly trained.
Emergency Plan Evaluation The Emergency Planning Supervisor has the majority of the responsibilities associated with the emergency planning effort. These responsibilities include, but are not limited to, ensuring changes are made in the Plan after approval by the Vice President - Power Resources; coordinating periodic reviews of the Plan; coordinating drills and exercises involving o'fsite agencies; and ensuring that all elements of the total emergency organhations (FP&L, State, local) are informed of revisions to the Plan.
Other emergency planning responsibilities have been assigned to other onsite and offsite FP&L personnel.
The Plan does not identify, by title, the individual with the overall authority and responsibility for radiological emergency response planning.
The Plan and letters of agreement will be reviewed and updated, as necessary, at least every year.
The Facility Review Group will conduct periodic reviews of Emergency Plan Implementing Procedures.
The Plan contains supporting plans and agreements, a specific table of contents and a listing of procedures required to implement the Plan.
' An independent audit of emergency preparedness will be performed by the FP&L Quality Assurance Department at least annually. Audits will verify compliance with Federal regulations and Technical Specifications provisions. Plant manage-ment, the Emergency Planning Supervisor, and the Manager, Power Resources - Nuclear will evaluate the audit findings and recommend corrective actions to the Vice President - Power Resources.
Revisions to the Emergency Plan and Emergency Plan Implementing Procedures will be distributed in accordance with plant proceaures.
Notification lists and rosters will be updated quarterly.
FP&L has committed to identify, by title, the individual with the overall authority and responsibility for radiological emergency response planning.
3.0 CONCLUSIONS Based on the NRC review against the criteria in " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," NUREG-0654, Revision 1, November 1980, the staff concludes that the St. Lucie Nuclear Station Radiation Emergency Plan, upon i satisfactory correction of those items requiring resolution as identified in l
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Section 2 of this evaluation, and those plan deficiencies identified during the EPIA (referred to in Section 1.0 to this Report), and upon satisfactory completion of tho;e items for which FPAL has made commitments, will provide an adequate planning basis for an acceptable state of emergency preparedness and will meet the requirements of 10 CFR Part 50 and Appendix E thereto.
After receiving the findings and determinations made by (EfA on State and local energency response plans, and af ter reviewing the revision (s) to the Plan, a supplement to this report will provide the staff's overall conclusions as to whether the plans provide reasonable assurance that adequate protective measures can and will be taken in the event of an emergency.
The final NRC assessment of the state of emergency preparedness for the St. Lucie Nuclear Station will be made following implementation of the revised emergency plans to include revision / development of procedures, training and qualifying of personnel, installation of equipment and facilities, and a joint exercise involving participation of the response organizations (site, State, and local), l - l 1 }}