IR 05000409/1981013
| ML20011A927 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 10/28/1981 |
| From: | Axelson W, Bates E, Fairobent J, Grant W, Pagliaro J, Paperiello C, Psomas P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20011A913 | List: |
| References | |
| 50-409-81-13, NUDOCS 8111030364 | |
| Download: ML20011A927 (75) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-409/81-13 Docket No. 50-409 Licensee: Dairyland Power Cooperative 2615 East Avenue-South Lacrosse, WI 54601 Facility Name: Lacrosse Boiling Water Reactor Appraisai At:
Genoa, WI Appraisal Conducted:
ly 3-24, 1981 Inspectors:
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Approved by:
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Emergenc Preparedness Section
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Emergency reparedness and Program Support Branch Appraisa) 3ummary Appraisal on July 13-24, 1981 (Report No. 50-409/81-13)
Areas Appraised: The appraisal of the state of onsite emergancy pre-paredness at the Lacrosse Boiling Water Reactor involved seve val areas: Administration of the Emergency Preparedness Program; t.
icy Organization; Training; Emergency Facilities and Equipment; Proce.mures bk1030364 ADOCK Of0 h 9
which Implement the Emergency Plan; Coordination With Offsite Agencies; and Exercises and Drills. The Appraissi involved 551 man-hours onsite by seven inspectors.
Results: One apparent item of noncompliance nas identified regarding Technical Specification Requirement 6.8.1. (Level IV violation-failure to implement the emergency plan Section 90.
Significant deficencies were also identified in Appendix A which must be corrected within the provisions of 10 CFR 50.54(s)(2).
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1.0 Administration of Emergency Plan 1.1 Responsibility Assigned Overall authority and responsibility for radiological emergency response planning has not been formally assigned in the Emergency Plan. During appraisal interviews, Laccosse Boiling Water Reactor (LACBWR) personnel stated that emergency planning is part of the technical staff's normal duties.
Emergency p7anning and preparedness is accomplished by LACBWR per-sonnel only. The Corporate staff does not have input into the emergency planning process. The Corporate staff is involved in che administrative support role for emergency planning at LACBWR.
There are two individuals at the site responsible for emergency planning and coordination; however, the assignment is not formally specified.
Corporate management is aware of those personnel responsible for emergency planning at the site.
1.2 Authority Based on the Lacrosse Emergency Plan review and interviews with LACBWR management, personnt.1 assigned emergency functions are given the authority to perform assigned duties by the LACBWR Emergency Plan.
LACBWR management has stated they would support the individuals exercising the authority given them by the Emergency Plan. The two individi als responsible for the LACBWR Emergency Plan report directly
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to the Plant Manager.
1.3 Coordination During interviews, LACBWR management personnel stated that they are included in Operations Review Committee (0RC) meetings and budget input meetings involving emergency planning. However, coordination between the site and corporate individuals is lacking.
1.4 Selection and Qualification During interviews with LACBWR management, the inspectors were shown job selection criteria established for management personnel. The licensee meets these criteria as written. However, they do not specify selection and qualification criteria for individuals with
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emergency planning and preparedness functions and responsibilities.
The plan states that professional development training courses will be made available as needed. A training program for personnel responsible for emergency planning to naintain their state-of-the-art knowledge has not been established.
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Based on the above findings this portion of the licensee's progras is adequate; however, the following items should be corrected:
Specify formally the assigned responsibilities of LACBWR per-
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sonnel responsible for emergency planning and coordination.
Develop a formal document, describing the authority, respon-
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sibilities and interaction between site and corporate individuals regarding emergency preparedness.
Develop and formalize selection and qualification criteria for
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individuals with emergency preparedness responsibilities.
Establish and implement a training program for professional
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development of personnel responsible for emergency planning and coordination to ensure they maintain their state of the art knowledge in emergency preparedness.
2.0 Emergency Organization 2.1 Onsite Emergency Organization The inspectors reviewed the LACBWR emergency organization that is cur-rently in place. The following key emergency organization assignments were provided in EPP-2 "LACBWR Operation During Emergencies:"
Emergency Control Director Director of Ir. formation
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LACBWR Operations Supervisor LACBWR Assistant Superintendent LACBWR Radiation Protection Engineer LACBWR Quality Assurance Sapervisor These individuals were responsible for the following emergency operations or functions:
Emergency Control Director: overall direction of the response to an emergency condition; staff augmentation.
Director of'Information: operation of the Joint News Center, single spokesperson for LACBWR, arranging interviews, statements quoted in press releases, presiding at formal press conferences, coordinating information with counterparts from state, local and federal agencies.
LACBWR Operations Supervisor:
implementation of in plant recovery activities, supervising operating, mechanical and instrument / electrical maintenance staff and security personnel.
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LACBWR Assistant Superintendent:
long-term operation of the TSC;
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analysis of plant conditions; development of plans and procedures to directly support plant operations personnel; collection, retention, retrieval and transmittal of plant and local environmental parameters.
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LACBWR Radiation Protection Engineer:
control of radiation exposure; and development of plans and procedures to process and control radio-active liquid, gaseous and solid wastes.
LACBWR Quality Assurance Supervisor: Design and construction necessary to meet the requirements of re-entry and recovery operations.
The shift supervisor on duty acts as the Emergency Control Director (ECD) if the LACBWR Plant Superintendent, Assistant Superintendent, Operations Supervisor, or Health and Safety Supervisor / Radiation Protection Engineer are not available.
The Emergency Control Director (ECD) has the responsibility to initiate emergency actions including the exchange of information with authorities responsible for coordinating and implementing offsite emergency measures.
Once the EOF is activated, these responsibilities are transferred to the Emergency Control Director at the EOF in Lacrosse, about 20 miles from LACBWR. However, the method of transfer of the ECD responsibility from the LACBWR site to the EOF is unclear.
Interfaces between and among the identified onsite functional areas of emergency activity are clearly specified and understood by the individ-uals assigned to the emergency organization.
Based on the above findings, improvement in the following area is required to achieve an acceptable program:
Develop a procedure which s-
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Emergency Control Driector i sponsibilities from the LACBWR site to the EOF at the DPC Headquarters in Lacrosse.
2.2 Augmentation of Onsite Emergency Organization 2.2.2 Onsite Emergency Organization The Shift Supervisor initially augments the onsite organization by contacting LACBWR supervisors who then contact their personnel, however, a method or procedure for augmentation is not specified.
The licensee has indicated that they can not meet the minimum staffing or augmentation specified in NUREG-0654, Table B-1, but they have requested relief from this requirement in the letter to the NRC dated April 2, 1981.
LACBWR Present Normal Night Shift Table B-1 NUREG-0654 1 Shift Supervisor (SRO)
1 Shif t Supervisor (SRO)
4 Operators 1 SRO Forman 1 HP Tech 2 Contrcl Room Operators 1 STA 2 Auxillary Operators 1 HP Tech 1 Rad / Chem Tech 1 STA 1 Communicator Total
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The. Corporate Organization of Dairyland Power has one member who could provide technical support, all other support from Corporate will be of an aduinistrative nature. The plan states that the Corporate Environ-mental Affairs Department will supply trained monitors. According to Corporate personnel, these persons have not yet received the training.
needed to respond to an emergency at LACBWR. Functional areas of emergency response and augmentation are not clearly described in the plan.
Based on the above findings in Section 2.2.2, improvements in the following areas are required to achieve an acceptabic program:
Provide adequate compensatory measures for minimum shif t staffing
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and augmentation as specified in NUREG-0654, Table B-1 (Item B.5)
and provide an acceptable system for shift augmentation (duty officer system with pagers, prioritized call out procedures, off-hour drills, etc.).
Provide documentation delineating the authority, responsibilities
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and limits on actions of corporate management, and contractor organizations.
The following should be provided:
Provide an organizational chart specifying the interrelationships
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of each of the onsite functional areas of emergency response and augmentation groups.
3.0 Emergency Plan Training / Retraining 3.1 Program Established The inspectors determined that the licensee has established a formal training program for both the onsite and offsite emergency organizations.
Emergency Plan Procedure (EPP-14) defines the training requirements.
According to the procedures, training will be provided on an annual basis. The LACBWR Health and Safety Supervisor Radiation Protection Engineer and LACBWR Training Supervisor have concurrent responsibility for the administration and documentation of the training program for the onsite emergency organization.
The Emergency Plan training program for the onsite staff outlined in EPP-14 includes lectures, discussions and drills and requires specified training for all necessary plant personnel.
Emergency response training provided for offsite emergency organizations and groups who may be called to provide assistance is also outlined in EPP-14. Training and/or training drills are to be held annually.
Current copies of the Emergency Plan and all pertinent Emergency Plan Procedures are provided to each support group. Specialized training for particular agencies or groups (e.g., hospital emergency room per-sonnel, first aid and rescue squads and fire fighting personnel) has been provided with a commitment for periodic retraining.
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3.2 Program Implementation Training records indicate that there has been formal training in the Emergency Plan and Procedures for all onsite personnel. The training program given was as described in EPP-14, but it is incomplete (e.g.,
no lesson plans or performance objectives and limited hands on ex-perience).. Based on numerous interviews _with plant-personnel, it appears that control room personnel (SRO's, R0's and STA's) and Health Physics personnel understood the emergency procedure and their roles and resposibilities. However, in many cases they have not had enough hands-on training or experience with emergency equipment to operate effectively during an emergency.
Personnel at the Genoa-3 fossil fuel plant, which is located next to LACBWR, have not been trained in the emergency plan provisions for site evacuation.
Offsite emergency support agencies and groups who may be called upon in the event of an emergency at the plant were visited or contacted by telephone by the appraisal team. All of the agencies contacted (e.g.,
hospital, fire department, ambulance service, Sheriff and Coast Guard)
expressed satisfaction with the training equipment and procedures provided by the licensee. The primary suppart agencies (e.g., medical, fire, Sheriff and ambulance) have participated in drills and exercises with the licensee.
The LACBWR Emergency Plan, Section 5.3.1 Technical Support Group lists the Environmental Affairs Department Staff (Corporate Headquarters) as a supporting group with capabilities in environmental monitoring and dose assessment.
It is not clear whether the staff will perform these functions from Corporate Headquarters or from the plant site.
If Corporate Staff are to assist the emergency organization they should receive emergency plan training.
Based on the above findings in Sections 3.1 and 3.2, the following matters should be considered for improvement;
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i Upgrade the implementation of the training program to include
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student performance objectives and hands-on experience with equipment to be used in an emergency to ensure individuals understand and can perform assigned duties.
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Provide training in the provisions of the emergency plan and
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implementing procedures for corporate personnel who may assist the emergency organization and for all onsite personnel including personnel working at Genoa-3.
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4.0 Emergency Facilities and Equipment 4.1
_EA rgency Facilities 4.1.1 Assessment Facilities 4.1.1.1 Control Room
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The Control Room was examined by the inspectors several times during the appraisal.
It was n 'ed that current copies of the Emergency Plan and implementing procedures were available.
Nuclear Energy Services, Inc. conducted a habitability study for Class 9 accidents. The report, documenting this study, dated September 23, 1980, states, for fulltime occupancy, that the average integrated dose in the Control Room for two days is 8.2 rem and for 100 days is 9.2 rem.
The ventilation system for the Control Room does not have isolation capability for protracted periods of time. The Control Room ventilation system maybe isolated "by shutting the system down," however, at present there are no provisions for recirculation and filtration.
LACBWR is currently perform-ing a design study for ventilatior. system filtration for Control Rcom habitability. This study she.1/ be complete by August 15, 1981 according to LACBWR personnel.
Instrumentation related to emergency detection and accident assessment identified in the implementing procedures was in place and operable.
Based on the above findings, this portion of the licensee's program is adequate pending modification of the Control Room ventilation as per NUREG-0737, Task Item 111.D.3.4.
This is an open item.
4.1.1.2 Technical Support Center (TSC)
The Technical Support Center (TSC) is located on the third floor of the turbine building. Personnel can move between the TSC and Control Room in 20-30 seconds. There is adequate working space for those personnel assigned to the TSC. The TSC does not have data display and manipulative systems, nor does it meet habit-ability requirements because the facility is not on an isolatable ventilation system with appropriate filtration. This is an open item. According to the Nuclear Energy Services, Inc. study (September 23, 1980) dose rates in the TSC under a Class 9 accident would result in a total of 1.81E03 rem to an individual occupying the area for the first 30 minutes of the accident. There are no dedicated voice communication links between the 7SC and the Control Room nor does the TSC meet the NUREG-0696 communications guidelines and there are not sufficient number of telephones-8-
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available. The Health Physics Network extension is installed in the TSC. Portable radios will be used for communications between the TSC and field monitoring teams (see Section 4.2.3).
The TSC contains up-to-date records such as current plant technical specifications, plant operating procedures, etc.
Based on the above findings, improvement in the following area is required to achieve an acceptable program:
Dedicated voice communications links shall be installed
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between the Control Room and TSC.
Competion of the permanent TSC in accordance with NUREG-0696 is not completed. This is an open item.
4.1.1.3 Operations Support Center (OSC)
There are two Operations Support Centers (OSC). One is located in the lunch room adjacent to the LACBWR control room, the second is located in Genoa-1 electric generating facility, about 6.o hundred yards north of LACBWR.
The Operations Support Center next to the lunchroom has a habit-ability factor similar to the TSC. During a general emergency an individual occupying the area would receive approximately 210 rem in the first two days following a Class 9 accident. This facility would be used as the assembly point for those support personnel needed immediately, such as cxtra Rad / Chem Techs.
The OSC at Genoa-1 is large enough to accommodate all other individuals that may be onsite during an emergeacy.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.1.1.4 Emergency Operations Facility (EOF)
The Emergency Operations Facility (EOF) is located, as stated in the plan, in the city of Lacrosse at the Dairyland Power Coopera-tive corporate headquarters, approximately 18 miles north of the plant. There is sufficient space available in the facility to provide working space for assigned personnel.
The EOF contains adequate emergency equipment and supplies except for the following:
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Copies of the state and local plans 2.
Isopleths (dose projections for meteorological conditions as aids in decision making)
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As-built LACBWR plant lavout drawings 4.
Readout of the station mt.eorology 5.
Dedicated EOF to TSC communications
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The ENS is not installed because the NRC-is changing the system and has not yet installed this line; Based on the above findings, this portion of the licensee's i
program appears to be acceptable, but those items list above should be provided in the EOF.
4.1.1.5 Post-Accident Coolant Sampling and Analysis The inspectors reviewed the licensee's capabilities for post-
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accident coolant sampling analysis pursuant to the requirements of the NRC. This review was conducted to verify.that the licensee had the ability to sample and analyze high activity
reactor coolant samples during accident situations.
l The licensee has performed an operational review of the reactor
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coolant sampling system. This review and the requirements of Section II.B.3, NURZG-0737 has retalted in the design of a post-accident reactor coolcnt sampling system with a sampling station
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located in the turbine building that will be accessible during accident situaticas.
i This post-accident reactor coolant sampling system design-and i
concepts of operationr. includes; provisions for shielding the sanple line end collections station, monitoring of the sampling
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area with an area radiatica uonitor with an adequate range of operation, monitoring radistion levels from these coolant samples, and remote readout external of the sampling area.
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The concepts of operation includes the use of. aielded liquid sample containers, remote handling tools and a dolly mounted shielded transport container. The sampling station is located on the same floor level as the Health Physics Radiological
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Analysis Laboratory.
The inspector examiaed the sampling station area and reviewed the system design and installatier. dates with the licensee. The licensee stated that the post-accident reactor coolant sampling systems will be installed, and tested, and that operaticaal pro-
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cedures will be prepared, approved for use and implemented by_
January 1,1982. This is an cpen item.
The interim post-accident reactor coolant sampling procedure is to provide a method of sampling the primary coolant system.
When the sampling stations inside conteinment are not accessible the
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licensee does not have a defined system or method for collecting a post-accident reactor coolant sample. This is a generic problem with all BWRs. Emergency Plan Procedure EPP-6 " Sample Collection and Analysis During Emergencies" is adequate for collecting a post-accident reactor coolant sample under emergency conditions requiring containment entry.
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4.1.1.6 Containment Air Sampling and Analysis The inspectors examined the licensee's capabilities for contsin-ment air sampling and analysis against the criteria specificd in NRC requirements. This review was conducted to determine t!e capability of the licensee to promptly obtain (less than one Sour)
a sample of containment atmosphere under accident conditions.
The license ^ has performed an operational review of the contain-ment air sampling system. This review and the requirements of Section II.
B. 3, NUREG-0737 has resulted in the design of a containment atmosphere sampling system with a sampling station located in the turbine building that will be accessible during accident conditions. This system is partially installed. The licensee experts to complete installation and develop operational implementing procedures by January 1, 1982.
For the interim period, pendinh full operational capability of the containment atmosphere sampling system, the licensee has addressed Containment building atmosphere sampling in Sections 7.0 and 5.0 of Emergency Plan Procedure EPP-6. The ability to perform containnunt air sampling and analysis under accident conditions is deper. dent upon the accessibility of containment for personnel entry. These procedures are adequate for limited emergency condi-tions enly.
Additionally, the licensee received a letter from NRR dated April 25,
'980, containing the Staff's evaluation of licensee's compliance with Category "A" Items of dRC Recommendations Resulting From TMI-2 Lessons Learned. This document in Section 2.1.8.a " Post-Accident Sampling" states that for the short term:
(1) the licensee has procedures to use the sampling stations (located inside contain-ment) during an accident when the stations are accessible; (2) if the stations are not accessible, the licensee can estimate the quantity of radioactivity released from the core by an area monitor located outside containment on a wall common to the containment; and (3) this_ monitor is in place and procedures have been written for its use.
Contrary to the information presented under Cover Letter Zienan to Linder, dated April 25, 1980, the inspectors findings from a review of this interim monitoring system is:
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There is no existing procedure or posted conversi:n factors or graphs for the use of this monitor to estimate the quantity of radioactivity relea;ed from the core.
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Based on the above findings, improvement in the following area is required to achieve an acceptable program:
Develop procedures and EALs for use of the ARM outside con-
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tainment to est imate the quantity of radioactivity released from the core.
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4.1.1.7 Post-Accident Gas and Particulate Effluent Sampling and Analysis The inspectors examined tF licensee's implementatt.on of recom-mendations specified in N REG-0578, Section 2.1.8, Paragraphs (a),
(b), and (c), to verify that the licensee has instrumentation to follow the course of an accident and the ability to sample and analyze high activity gas and particulate. effluents during accident situations.
The licensee identified eight (8) air monitors that would be used to follow the course of an accident in Section 7.3.1.1 of the Emergency Plan. These incluJe the following air monitors:
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Air Ejector Off-gas Monitor: Monitors off gas.
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Containment Building Ven'_ilation Exlaust Monitor: Monitors containment air for purges.
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Stack Effluent Monitor: Monitors final effluents.
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Mobile Containment Monitor: Monitors particulate activity at various locations in containment.
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Turbine Building Access Monitor: Monitors the turbine building air at various sampling points.
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Turbine Building Exhaust Monitor: Monitors the turbine building for airborne particulate activity as it is exhausted to the tunnel area.
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Leak Detector Monitor One: Monitors the air in the forced circulation pump cubicle ventilation duct.
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Leak Detector Monitor Two: Monitors the air in the upper or lower cavity.
In the event the fixed monitoring system and instrumentation intended for use in the determination of releases of gasous and particulate effluents are offscale or inoperable, the licensee described alternate approaches in Emergency Plan Procedure EPP-6.
These alternate approaches, described in EPP-6, Sections (4.0),
(5.0), (6.0), and (7.0), are dependent upon area accessibility
and off gas treatment operability.
Additionally, the licensee stated that if the activity in the Air Ejector Offgas System exceeds the allowable level at the holdur tank outlet, the monitor automatically re-routes these gases from the stack to the gas storage tank, and that both gas and particul-ate effluent samples could be collected from this system using the Health and Safety Department Procedurc HSP-06.16. This pathway automatical isolates with a main steam isolation.
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This sampling system and procedure for use as a post-accident gas and particulate effluent sampling and an. lysis system and/
or method is not described in the Emergency Plan Implementing Procedures. Also, Procedure HSP-06.16 does not provide for the use of remote handling tools, shielded sample containers or shielded syringes required for collection and analysis of high activity samples.
Long term post-accident high range noble gas, particulate and radioiodine effluent sampling system have not been installed as per NUREG-0737. This is an open item.
~ ~ 1.8 Post-Accident Liquid Effluent Sampling and Analysis Post-accident lignid effluent sampling and analysis are not addreased or described in either the Licensee's Emergency Plan or Emergency Plan Implementing Procedures.
The inspectors examined the liouid effluent system and sampling capabilities with a licensee representive. The liquid effluent system censists of two (2) separate systems for the retention and sampling effluents prior to release. One system consisting of two 6,000 gallon retention tanks located in containment and receives liquid waste from the primary water system and other reactor systems within containment. The second system consisting of two retention tanks of 3,000 and 4,500-gallons capacity which are located in the tunnel access near the turbine building. They receive liquid waste from the hot laundry, water treatment building sump, turbine building floor drains, and laboratory sinks.
These two liquid effluent systems can be connected from inside containment and liquid effluents from the containment retention tank could be transferred to one or both of the waste tanks located in the access tunnel from the turbine building. However, this is dependent upon accessibility to the containment building.
The only procedure for sampling liquid effluents is for routine sample'. taken to determine if the liquid effluents can be released.
This procedure is described in HSP 07.5 and does not provide for the sampling and analysis of elevated radioactive liquid effluents.
Based on the above findings, the following improvement is required to achieve an acceptable program:
Develop capability und procedures for post-accident sampling
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and analysis of samples from the liquid effluent system.
The following item should be considered to improve the program.
The liquid effluent system should be described in emergency
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facilities and equipment in the the Emergency Plan Procedurr.
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4.1.1.9 Offsite Laboratory Facilities The licensee has identified two offsite support laboratory.
facilities, one located at the University of Wisconsin-lac: osse Nuclear Radiation Center located in Cowley Hall and the Dairyland Power Cooperative Laboratory located in the Service Center.
Building on East Avenue in Lacrosse.
The inspectors met with the Director of the University of Wisconsin-Lacrosse Nuclear Radiation Center (WNRC).
WNRC does not have a copy of the LACBWR emergency plan and is limited in capability to analyzing samples in the millicurie range. This facility had the folloving equipment on hand at the time of the review:
8 Canberra GM counters 2 sodium iodide crystals 1 gccmanium, ultrapure crystal 2 analyzers (one 256 and one 1024 Nuclear Data Analyzer)
I spectrashield Nuclear Chicago gas flow proportional counter 1 alpha spectrometer model 5300 Harshaw 7 chemical hoods with HEPA filtration
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1 Nuclear Chicago Liquid Scintillation counter The inspectors interviewed corporate personnel regarding the Dairyland Corporate backup laboratory.
It was learned that there were no ctpabilities at corporate because the environ-mental laboratory is moving to new quarters. Further, the new laboratory will be limited in capabi?ity with only one gas proportional counter.
Based on the above findings, thic portion of the licensee's program appears to be acceptable, but the following matters should be considered for improvement.
Develop an agreement, with the University of Wisconsin-
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Lacrosse Nuclear Radiation Center, limiting samples that LACBWR will transport to the facility at U. of W. to millicurie quantities of activity per sample.
Expand the laboratory capability of the Dairyland Corporate
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backup laboratory.
4.1.2 Protective Facilities 4.1.2.1 Assembly / Reassembly Areas The licensee has designated an assembly area at the Genoa-1 oil-fired power plant north of LACBWR. This power plant is normally in shutdown status and provideds adequate space for all personnel from LACBWR and Genoa-3. There is no special shielding or ventilation provided at the assembly area. There are two
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emergency kits kept at the assembly area and each kit contains ten sets of protective clothing. The buildings are lighted and heated and there were telephones for the site telephone system and the NRC-HP Network. There is no portable lighting equipment (i.e., flashlights) available in the buildings or emergency kits.
There are no other desi aated onsite or offsite assembly areas t
in the event that Genoa-1 is uninhabitable.
Based on the $bove findings, improvements in the following areas are required to achieve an acceptable program:
Provide an additional assembly area offsite equipped for
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sheltering of site evacuees and outfitting of survey teams.
4.1.2.2 Medical Treatment Facilities The inspectors examined the onsite medical treatment facilities.
These facilities were consistent with the description in the LA;BWR Emergency Plan (Section 6.5.2) and Implementing Procedures (EPP-11).
The treatment facility is in the change room located in the turbine building, one floor below the Control Room. Access to this room by two individuals carrying a stretcher is possible, but it appears that it would be somewhat difficult due to the room dimensions.
First aid equipment and supplies are located across the hall in a storage room and are readily accessible. Operable, calibrated personnel contamination survey instrumentation and a telephone is readily available.
Procedures for treatment of the injured were not available, but decontamination procedures were.
LACBWR relies primarily on the Health Physics personnel who are experienced and trained to administer first aid. About 80% of LACBWR personnel have received multi-media training.
LACBWR management has decided not to make Potassium lodide available at this facility.
Based on the above findings, this portion of the licensee's program appears to be adequate.
4.1.2.3 Decontamination Facilities and Assemble Areas The inspectors examined the decontamination facilities specified in the LACBUR Emergency Plan, Section 6.5.2, and implementing Procedure EPP-11. These facilities were as described. The decon-tamination facility for the plant is a multipurpose, change room and first aid room and decontamination area.
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Since the change room and first aid room area is used to gain access to areas of the plant whica are potentially cestaufnated, provisions for decontamination and monitoring are available The turbine building lunch room has been designated as the onsite assembly / reassembly area. The lunch room is located next to the Control Room on the floor above the change room I
decontemination facility, providing easy access for assembly.
The other assembly / reassembly area io }ocated in Genos-1. There is a shower in that facility, as described in the plan, and two emergency kits which contain instrumentation for monitoring.
Decontamination procedures were not readily available at either locatic.
Some decontamination supplies listed in the plan were not avilable at the Genoa-1, assembly area, which included hair clippers and extra decontamination solutions.
Contaminated water from the LACBWR turbine building showers drains into the waste storage facilities, but the water from the shower at Genoa-1 is not controlled. However, this water can be collected prior to release. There were no waste disposal containers at either location for the collection of solid and liquid waste. The LACPWR turbine building facility had some replacement protective clothing, but the Genoa-1 assembly f cility had none.
Based on the above finaings, this portion of the licensee's program appears to acceptable, but the following matters should be considered for improvement:
Provide copies of decontamination procedures for the Genoa-1
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assembly area and the LACBWR turbine Building facility.
Replace the missing decontamination suppliea in the turbine
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building facility Genoa-1.
Make provisions at the Gen,4-1 facility for collecting solid
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and liquid wastes.
Provide a supply of replacemer.t clothing at the Genoa-1
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assembly area and the LACBWR turbine Building Facility.
4.1.3 Expanded Support Facilities The inspectors discussed the need for expanded support facilities with LACBWR personnel.
LACBWR personnel stated that if expanded facilities were needed the Technical Support Center (TSC) would be expanded to utilize all the office space on the third floor of the Turbine Building. This expanded area would be used for individuals performing functions requiring close plant proximity.
For those functions not requiring close proximity, such as meetings and planning, the Corporate Headquarters building would be used as needed.
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Based on the above findings, this portion of the licensee's program appears to be adequate.
4.1.4 News Center The inspectors interviewed the Dairyland Power Cooperative (DPC)
Public Information Director regarding DPC's pl.-aning for news dissemination during an emergency.
iecording to the news director, the Stoddard Elementary School gyrmstum will be used as the Joint Press and Information Center (JPIC).
There is a verbal under-standing between Dairyland Power and Wisconsin State Personnel that once State personnel arrive they will assume control of the JPIC. During an emergency, the Public Information Director and his alternate will be called to assume roles at JPIC and corporate.
It is estimated that 20-30 members of the news media will be ac-commodated at DPC Headquarters in Lacrosse and up to 300 members of the media will be accommodated at the JPIC.
The JPIC is a gymnasium that does not have support capability.
After an emergency is declared telephone service, copying equipment, PA systems, and audio visual equipment will be rented locally and installed in the gymnasium within hours. DPC has not yet explored which telephone coepany will supply lines and equipw:nt to the gymnasium.
It is proposed within DPC that telephones will be installed outside the gymnasium. Provisions for security at the media center and E0C have not been considered.
The 'T11owing matters should be considered for improvement:
Develop a letter of agreement with the State of Wisconsin
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stating concepts of eperation, limits of authority and re-sponsibility for the JPIC.
Develop agreements with:
the telephone company that specifies
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the number of telephone units to be supplied; and the vendor for copy vachine rental specifying the number of copying machines to be supplied; the vendor from whom the P.A. System will be rented; and the vendor from whom the audio-visual equipment will be rented.
Develop procedure which specifies: who of DPC staff is
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assigned to JPIC and who to Corporate; how media will be contacted; who is responsible for contacting the media and the order in which they are to be contacted; media telephone numbers; format and content of message given to the media; delineation of authority and responsibility between Dairyland Power Cooperative and the State of Wisconsin; and security for JPIC and EOF
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4.2 Emergency Equipment 4.2.1 Assessment 4.2.1.1 Egprgency Kits and Emergency Survey Instrumentation The licensee has reserved supplies of protective equipment in emergency equipment boxes at the assembly area at Genoa-1 and at the DPC corporate headquarters in Lacrosse. Two kits are at Genoa-1 and one at the DPC corporate headquarters. Each of these kits contained sufficient protective clothing for ten people.
Each kit has two self-contained breathing apparatus' units with a spare air bottle for each. There were five full-face respirators in each box, but only enough filter canisters for three respirators.
There are four 0-10 R dosimeters and ten TLD's in the kits. Other dosis.eters are to be in the kits, but had been removed for cali-bration. The LACBWR Emergency Plan calls for replacing the dosimeters during calibrations, but this was not done. Each kit contain one beta / gamma dose rate instrument and one survey monitor.
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There is a portable a.c. powered high volume air scmpler with 4" particulate filters and a portable a.c. powered low volume air sampler with charcoal filters. There is no portable generator or other means of supplying power to these samplers under field conditions.
There was sufficient paper and pencils for recording survey data, but no detailed maps of the area for sur rey teams. There is ne portable lighting or communications equipaent in the kits.
Each kit contain decontamination and first aid kits and copies of the T.ACBWR emergency plan, emergency plan procedures, safety analysis report and operations manual.
Based on the above findings, improvement in the fallowing area is required t, achieve an acceptable program.
Assure that survey teams will have air sampling equipment
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that can be used in the field (i.e., battery powered or a.c. powered wit! a portable a.c. power supply) and provide detailed maps, portable lighting, and portable communications equipment in the e mergency kits for the survey teams in the emergency kits.
4.2.1.2 Area and Process fadiation Monitors The inspectors reviewed the licenset's onsite monitoring systems that would be used to initiate emergency measures and conducting radiolcgical assessment.
The radiological process monitors consist of liquid monitors, air monitors, high range radiation dome monitors, and area radiation monitors. These monitors have their readouts, clarms, and controls 18 -
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located in the reactor Control Room with the exception of the turbine building access monitor which has its readout at the instrument and the recorder chart in the change room.
The area radiation monitoring system consists of 15 monitoring channels with their detectors located throughout the plant and monitor radiation levels in occupied or accessible areas. These monitors also have readouts and alarms at the detector location and alarms when radiation levels exceed a predetermined setpoint.
Thirteen (13) detectors have a range from 0.01 mr/hr to 10 r/hr and two (2) detectors have a range from 0.1 mr/hr to 100 r/hr.
The monitoring system is calibrated annually or following maintenance and repair of any individual monitoring channel.
There are three (3)-liquid monitors which monitor the component cooling water, liquid waste discharge, and the turbine condenser cooling water discharge. These three (3) monitors are keyed to emergency action ievels and are calibrated on an annual basis.
The air monitoring system consists of eight (8) air monitors which monitors both particulate and gaseous radioactivities of various plant locations, stack and reactor systems. These monitors are keyed to emergency action levels.and are calibrated annually or immediately following any maintenance or repair and before the monP.o-ing channel is approved for operational use.
Additionally, the licensee has installed an Eberline Model SPING 4 monitor for monitoring the stack gaseous and particulate activity. This is a nine (9) channel monitoring system which
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measures particulates, radioiodine and noble gas concentration and direct radiation levels. - This system has not been calibrated.
This is an open item.
The installation and use of this monitoring system should provide the licensee with significantly more information in accident situations.
The licensee has installed two (2) high range radiation dome monitors in the containment building. There monitors lave ranges to 1.0 E+06 R/nr for gamma radiations and are capable ( f monitoring radiation levels in post accident situations involving a LOCA.
These monitors meet the criteria of NUREG-0578.
The monitors will be approved for use by DPC pending the development of operational procedures and approval of detector leads 'sr high temperatures.
This is an open item.
Based on the above findings, this portion of the-licensee's program appears to be acceptable.
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4.2.1.3 Non-Radiation Process Monitors The non-radiation process monitors described in the Emergency Plan used during emergency situations are in place and operable.
Meteorological monitors and fire detection devices are keyed to emergency action levels for the initiation, classification and continued assessments of the emergency conditions. All read-outs and alarms are in the Control Room.
Additionally, Lock and Das N. 8 located approximately one (1)
mile north of the plant has hydrologic and meteorological equip-ment which provides backup information to tne licensee on these pa ramete rs.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.2.1.4 Meteorological Instrumentation The inspectors reviewed the current meteorological measurements program at the Lacrosse Boiling Water Reactor (LACBWR). A general description of this program is provided in Section 7.3, " Assessment Facilities," of the LACBWR Emergency Plan. A complete, detailed description of the program, including location and orientation of sensors, sensor specifications, calibration and maintenance pro-cedures, and data reduction techniques is needed.
The LACBWR site is small and congested, dominated by a large coal-fired power plant in addition to the nuclear facility. A small oil-fir 2d power plant, now used infrequently for emergency
generating capacity, is also located at the site. Because of the numerous structures at the site and other obstacles (e.g., a large coal pile), locating conventional meteorological towers that are not influenced by structures and other obstacles to airflow is not possible.
Local terrain and security problems preclude siting meteorological towers near the site.
Routine releases of radioactive effluent to the atmosphere are vented through a 106 m (350-ft) stack. The current meteoro-logical measurement program reflects the emphasis on elevated releases. The primary wind speed and wind direction measurements are obtained from sensors mounted at the top of the stack, on a boom on the west side of the stack. Only winds from the east should be perturbed by the presence of the stack, and winds from this direction are infrequent because primary airflow is along the river valley. Vertical temperature difference is determined by one sensor at the top of the stack and one located on a 10 meter (m) light pole located some distance away adjacent to the parking lot.
These primary meteorological measurements (i.e.,
wind speed, wind direction, and atmospheric stability) are appropriate for evaluating the consequences of releases through the stack but. are not appropriate for releases near ground level.
Analog records (strip charts) of wind speed and wind direction
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from the 106 m level are available in the Control Room, but not in the Technical Support Center or Emergency Operations Facility at this time.
Instantaneous measurements of temperature difference are displayed digitally in the Control Room, as are instantaneous readings of wind speed and direction from an old aerovane located on the turbine building.
Instantaneous values of meteorological parameters are not acceptable. At the time of the inspectors review, the temperature difference display was not operable and the projected return-to-sc vice date was uncertain.
Calibration of the meteorological measurements program is performed twice per year, although the frequence of calibra-tion does not appear to be regular. Operability checks and maintenaace procedures are not described; however, wind speed and direction records appear to be monitored routinely by control room operators for use in support of the coal-fired power plant at the site.
Because the sensors are located at the top of a 106 m stack, maintenance and repair are difficult, as evidenced by the history of poor data recovery from the LACBWR program.
Additional wind speed and wind direction measurements are made at the site from sensors mounted atop the 10 m light pole described previously. These measurements are influenced by the presence of a nearby building, particularly during winds from the southwest. Sigma-theta (standard deviations of fluctuations of horizontal wind direction) is computed for the 10 m level, although the current method of computation does not conform to NRC guidance of Revision 1 to Regulatory Guide 1.23.
Data from the 10 m light pole are recorded in the building containing the Resident Inspector's office.
Offsite meteorological data can be obtained from Lacrosse Airport through either the National Weather Service (NWS) or the Federal Aviation Administration Flight Service Station although the NWS station may not be in operation 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. Wind direction at the airport will likely be different from that observed at the plant, because of a different valley orientation; wind speed measurements at the airport are made near the surface and are not representative of conditions at the t.op of the LACBWR stack. The procedures for obtaining and utilizing offsite meteorological measurements to replace missing primary measurements are not clear.
The National Warning System (NAWAS) circuit is available to control room operators to provide information about severe weather events.
Several years ago plant technical specifications were developed to require monitoring of NOAA Weather Radio for information on tornado occurrences in the vicinity of the plant.
If these technical specifications were implemented, this additional source of severe weather information should be incorporated into the emergency plan.
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Based ca the above findings, the current program to provide metco.ological information for use in emergency conditions at LACLdR contains a number of significant deficiencies and is not acceptable. The following information and modifications to the program are necessary for acceptance:
Provide a complete description of the onsite meteorological
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measurements program to be used in the emergency plan.
Include the location and orientation of all sensors, sensor specifications, calibrat.on and maintenance procedures, operability checks, data reduction techniques, and data displays.
Provide displays in the control room of meteorological data
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appropriate for releases near ground-level. These displays should permit easy determination of 15-minute averages of wind speed, wind direction, and an indicator of atmosperic stability.
Data recorders for these parameters could replace the dials currently recording wind speed and direction from the acrovane on the turbine building.
Replace the digital display in the control room of instan-
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taneous value of temperature difference with a display which will allow determination of a 15-minute average.
Relocate 10 m sensors. Although no location on the LACBWR t
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site is completely satisfactory for locating a 10 m tower, the tower can be sited to reduce the building influences at the present location.
Provide revisions to current plant procedures for obtaining
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meteorological data if primary measurements are not available.
Techniques for obtaining and utilizing back-up information should be described in detail for both elevated and ground level-releases.
Identification and utilization of back-up data should be consistent in all plant emergency procedures.
Develop improved written procedures for calibration, oper-
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ability checks, and maintenance of the onsite meteorological acasurements program. Illstorical data recovery and quality of data at the LACBWR site does not meet current criteria and design objectives.
As the licensee proceeds to upgrade the meteorological measurement program for emergency planning purposes, an alternativa to vertical temperatures difference as a stability indicator for mievated releases should be considered. Vertical temperature difference is a good indicator for stable conditions and low wind speeds but is not a good indicator for unstable conditions. Elevated releases are brought to the ground more quickly during unstable conditions.
Use of almost a 100 m separation for temperature difference as a stability indicator for ground level releases is questionable because the large separation masks occurrences of low-Icvel inversions.
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4.2.2 Protective 4.2.2.1 Respiratory Protection The licensee has nine self contained breathing apparatus' units (SCBA's) and seven spare air cylinders located in the LACBWR on the turbine deck, in the maintenance shop and in the change room.
In addition, there were two SCBA's and two spare air cyliaders with each of the two emergency kits at the Genoa-1 assembly point.
LACBWR has the capability to refill the SCBA's from a cascade system in the warehouse. Each of these large tanks, when full, has the capacity to completely recharge approximately two of the SCBA tanks to 1800 psi. The licensee's policy was to keep a minimum of twelve of these large tanks on hand at any time.
The licensee's supplier of compressed air keeps a minimum supply of twenty-five large air cylinders on hand and these could be delivered to LACBWR within two hours.
Based on the above findings, this portion of the licensee's program appears acceptable.
4.2.2.2 Protective Clothing The licensee has approximately 24 full sets of protective clothing (coveralls, hoods, gloves and booties) available in the change room, 12 sets stored in the warehouse and 10 sets in each of the emergency kits.
The change room has the same habitability as the Control Room and the TSC and would therefore be accessible.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.2.3 Emergency Communications Equipment During the review, the inspectors interviewed LACBWR personnel regarding the emergency communications equipment. The onsite and offsite communications equipment specified in the plan and pro-cedures were located as stated. On July 17, 1981, as part of the e
appraisal, a test was conducted of the siren and public address systems. The siren could be heard by six of seven individuals who were strategically stationed throughout the site. The siren alarm was faint in the equipment penetration room. The licensee repaired and retested the siren on July 19, 1981, with positive results. All personnel in the test stated the voice announcement was garbled and could not be understood in containment and outside
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of the buildings. The site emergency warning system is checked anmially.
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I.ACBkR personnel stated they conduct radio checks with the Vernon County Sheriff on the back shift and that there is a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day capability to notify NRC, state and local authorities.
Each communications net has at least one backup. Handi-talkies are capable of transmitting up to one mile exterior to the plant.
Two of the three DPC trucks assigned to LACBkR are equipped with fixed radios that can transmit at least 40 miles.
The available in plant communications include NRC telephones, dedicated phone lines to the EOF, backup microwave telephone system, FM radios, and NA*JAS On July 20, 1981, an in plant communications test was performed using the handi-talkies (FM radio). Generally, the communications links between the Shift Supervisor'r office and the mobile radio, and between the Shift Supervisor's office and the change room was good and clear. However, the communication link between the mobile radio and the change room was poor or non-existent during the time the radio was taken into the containment building, but was good in the turbine building. This type of communications check is not required by procedure and therefore is not performed routinely.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
Upgrade the a Public Address system to ensure that it can
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be heard and understood in all areas.
- The following should be corrected:
Establish a communications check procedure for portable FM
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radios at various locations in the turbine building and the containment building.
4.2.4 Damage Control / Corrective Action and Maintenance Equipment and Supplies During the review the inspectors discussed damage control and corrective action and maintenance equipment and supplies with LACBkB personnel. The LACBWR Emergency Plan states that. heavy equipment will be supplied by the Alma Dock Corporation and Dairyland Power Cooperative. During a discussion with LACBWR personnel, it was learned that the LACBkB No. I warehouse contains spare parts for the LACBkT facility.
There are no procedures written discu;. sing where supplies and equipment can be obtained nor the methods for obtaining.the equipment during emergency conditions.
Based on the above findings this portion of the licensee's program appears to be adequate, but the following matter should be con-sidered for improvement:
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Procedures should be written astablishing methods for
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obtaining equipment during an emergency.
4.2.5 Reserve Emergency Supplies and Equipment The inspectors discussed reserve emergency supplies and equipment with LACBVR personnel. This topic is not specifically addressed in the LACBWR Emergency Plan nor the implementing procedures.
The licensee believes there are sufficient supplies and equipment onsite except for TLD's which they obtain from the Eberline Corpora tion. However, during discussions with LACBWR personnel it was determined that:
The warehouse has a threshold level established to initiate reordering of supplies.
The (threshold) minimum supply action levels are not always adequate to the supply needs for normal operations.
Based on the above findings, this portion of the licensee's program appears adequate; however, the following matter should be con-sidered for improvement:
Establish minimum stock levels to insure that adequate reserves
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of supplies are available to handle emergency situations.
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4.2.6 Transportation The inspectors determined that there are no vehicles set aside for use in supporting the emergency response effort. There are no provisions to insure availability of a vehicle when needed during an emergency. During backshift heurs, there are no provisions for ensuring vehicle keys are accessible during an emergency. The vehicles that would be used during an emergency are pick-up trucks.
During inclement weather, emergency equipment required for monitoring team use may become wet, due to exposure to the elements.
Based on the abcve findings, this portion of the licensee's program appears adequate; however the following should be considered for
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Develop control provisions for emergency vehicles and keep to
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insure availubility durin: an emergency.
Provide a means of protecting emergency equipment on the
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emergency vehicle from the elements during inclement weather.
5.0 Procedures 5.1 General Content and Format The inspectors reviewed the emergency plan implementing procedures. All procedures were not arranged in the same general format. Most of the
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procedures had the following general headings:
(1) Purpose, (2)
References, (3) Procedure, and (4) Actions.
Procedures were written to cover all ' unctions of the Emergency' Plan.
The procedures usually specified the individual or organizatlan having authority and responsibility for emergency actions.
The review found the procedures format to be inconsistent and the
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i content to be weak. The procedures are too general fu many cases and some procedures de not implement the current plan.
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Based on the above findings, improvements in the content of proced.ures
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are regi' ired to achieve an acceptable program. Therecommended improve-ments are contained in appropriate sections of the report.
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5.2 Emergency, Alarm and Abnormal Occurence Procedures
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The licensee has provided non-routine and emergency procedures in Section 3 of Volume I of the LACBWR Operating Manual.
These procedures refer to the Emergen.y Plan Procedures in only one instance. All other procedures reviewed do not direct the Control Room operator to inform the shift supervisor to classify the emergency in accordance with the Emergency Plan. There were no other references to the EPP's which would activate the Emerger y Plan.
Based on the above findings, improvements in the following areas are.
required to achieve an acceptable program:
The LACBWR Operating Manual, Ncn-routine and Emergency Operating
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Procedures shall reference the EPP's and activation of the Emergency Plan.
5.3 Implementing Instructions The procedures for each class of emergency specified in the Emergency Plan were contained in EPP-2.
These procedures were written for use by the Emergency Control Director and the authority and responsibilly vested in the ECD was specified. The responsibilities which could not be delegated by the ECD were specified in EPP-2.
These procedures orchestrated the implementation of other, more specific procedures
which were developed to support implementation of the Emergency Plan.
Initiating conditions for the EPP's were specified in EPP-1, but these were not tied to emergency action levels based on observable informa-tion (e.g., readings of specific intrumentation)..idditionally, in EPP-1, issued, page 18, for the initiating condition of a General Emergency, " Loss of 2 of 3 fission product barriers with a potential loss of 3rd barrier (e.g., loss of primary coolant boundary, clad _
failures, and high potential for loss of containment) indicated by very high containment pressurc 50 psig and rising," is confusi'ng in that it gives the impression that the potential loss of the third -
barrier will always be indicated by high containment pressure. No -
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y j credit is given to other st.enerlos where the order of the loss of the
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co31 ant boundary simultaneously with loss of containment. Considera-
tion needa to be given for loss of any 2 of 3 fission product barriers
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with potential loss of the third.
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The degree of conservatism associated with an action level of contain-ment pressure of' greater thari 50 psig is questionable. The containment.
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bu11 ding is tested to 52 psig with a leak rate of 0.1% per day. Con-s, tafument was designed t.o contahi a maximum internal pressure of 52 psig.
c The declaration i;,f 'a General '..nergency for the above conditions should of cur.at a threshbld less than 50 psig, e.g., greater than 30 psig and
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rising.
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Based on the above findings, improvements in the following areas are
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required to achieve an acceptabic program:
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Modify UP 1 to )ase initiating conditions for emergency action
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levels of readings on specific instrumentation which provides sufficient emergency l; detail to categorize ar. incident at the appropriate evel and provide for loss of any 2 of 3 fission product barricra with potential loss of the third as an initiating conditinn for a Genezal Emergency in this procedure.
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/ 5.4 Img1pmenting Procedures
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5.4.1 Notifications
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Eacl/ e'. ass'of emergency is specified in both the Emergency Plan C
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and imN'the onsite emergency organization and supporting agencies end uting' procedures. The sequence to alert, mobilize or
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is specified in E.PP-Z.
The Shift Supervisor is responsible for
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J immediate no 'fications,until relieved by the Emergency Control
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DirectGr'(EC Each' classification of event is ident.ified and
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i I specifies who id to be.ptified.
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cations are'not specified in detail. There are no examples of
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messages that will be isrued. The emergency procedures contain
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listings of persons to be contacted and telephone numbers.
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The plan and procedures do not contain a method for offsite
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7j agencies to verify, me.cy,es received from I.ACBWR.
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Based on the above findings, this portion of the licensee's plan f;e appenrs to be acceptabic, but the following matters should be (
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considered for improvement:
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The emergency procedures should contain examples of the
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messages 'and annoucements that will be used during an
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emergency.
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A method for verifyinr, messages from LACBWR to offsite
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agencies should be included in the emergency procedures.
5.4.2 Aysessment Actions
The licensee utilized EPP-5, " Estimate of Offsite Exposure," EPP-8,
"Otisite Radiological Survey," and EPP-9, " Evaluation of Foodstuff Contamination and Control of the Distribution of Affected Agricul-tural Products," as part of assessment aci. ions in an emergency.
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These procedures are ' inadequate for performing the associated
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assessent accions, for the following reasons:
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EPP-5 Estimate of Offsite Exposure m
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Section 7.0 eatitled " Estimation of Release Rate" does not cortsider the pm::ibility of both elevated and ground level
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releases.
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Table 1, of EPP-5 which describes stability classification
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by ten.perature difference, does not include an extremely
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stable (Pasquill Type "G") category. Likewise, Class "G"
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Provisions for obtaining meteorological information to
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follow-up the initial assessment are not considered in the
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To facilitate the manual corputation of X/Q, the sigma y and
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sigma-z curves contained in Figures 1 and 2 should be combined y
into a single figure containing the product of sigma-y aud
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sigma-z.
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EPP-8 does not characterize releases as gr.und.or elevated.
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The procedures sere weak for obtaining and utilizing back-up data. The technical bases for utilizing back-up data ia not
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EPP-9 does not provide for the identification of radionurlides for asri'gning conversion factors.
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The procedures EPP-5, EPP-8, and EPP-9, do not identify pro-
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vicions for obtaining and utilizing meterological information
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for the long term, beyond the initial dose assessment.
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Data Sheets 1 and 2 reference Figure 3 of EPP-5 as does 5R Section-7.6 which contains two Figure 3's, one on page 9
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and one on page 15.
This could lead to confusion.
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Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
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Revise the meteorological procedures (EPP-5 and EPP-8) to
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consider both elevated and ground level releases.
Revise the metcorological procedures for obtaining and
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utilizing back-up data. Provide the technical base; for utilizing back-up data in a document separate from the procedure.
Identify provisions for obtaining and utilizing meterorological
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information beyound that used in an initial does assessment.
Revise Data Sheets Nos. I and 2 (EPP-5) to characte:-ize
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release, consider 15-minute average meteorological conditions, and to contain provisions for obtaining and utilizing back-up meteorological data. These provisions should be consistent with EPP-8 as revised.
5.4.2.1, 5.4.2.2, &
5.4.2.3 Offsite Radiological Surveys The licensee's procedures specifies the equipment to be used by the offsite, onsite and inplant survey teams, but does not indicate where equipment, such as FM radios, are to be obtained.
The locations for the initial survey points are determined by rough calculations of the maximum plume concentrations based on available meteorological data. Traverses across the suspected plume area are to be performed. Once the maximum plume concentration was located laterally across the plume and reported to the ECD, the survey team is directed to the locations to perform surveys.
There are no provisions in the offsite radiological survey pro-cedures for th< sarvey teams to take environmental samples.
Equipment is to be available for air and environmental samples, but the precedures only call for making dose rate measurements and taking smears of the area.
There is no specification of types of samples (smear, air or environmental) to be taken for collection and analysis.
Onsite teams perform surveys (nsite or in affected buildings.
Smears of floors and surfaces are taken in buildings and retained for analysis. Analysis of the samples are performed in the Waste Treatment Buildicg Change Room or in the Annex Environmental Laboratory depetiing on habitability.
EPP-1 contains provisions for survey results to be recorded and communicated to the ECD. However, there are no standardized survey forms nor provisions for supplying written survey records to those responsible for assessment actions.
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There were no detailed maps for survey teams co determine sampling locations.
Survey results are to be radioed to the ECD and/or Control Room, but there are no provisions for providing the emergency organiza-tion with the original data sheets.
The survey teams use a plant vehicle, equipped with a radio, for transportation and communication. The procv ires provided for protective clothing, respiratory protection, dosimetry and monitoring for the survey teams.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
Provide environmental sampling procedures for survey teams.
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Other findings are given in Section 4.2.1.1.
In addition to the above findings, the following matters should be considered for improvement:
Provide for using pre printed survey forms for survey teams.
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Provble for supplying survey reports to the emergency
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organization performing assessment actions.
5.4.2.4 &
5.4.2.5 Primary Coolant Sampling and Analysis The inspectors reviewed the Emergency Plan Procedure EPP-6 " Sample Collection and Analysis During Emergencies" with the licensee's representative to evaluate the licensee's capability to sample reactor coolant within one hour under accident conditions and t)
analyze high concentration radioactivity reactor coolant samples as specified in NUREG-0737.
Emergency Plan Procedure EPP-6 does not adequately address or provide the necessary instructions for obtaining a sample of reactor coolant under accident conditions, sample preparation, or analytical measurements of high activity primary coolant samples. See Section 4.1.1.5 for conclusions to these findings.
This is an open item.
5.4.2.6 &
5.4.2.7 Containment Air Sampling and Analysis The inspectors reviewed the licensee's capability to collect and analyze high activity containment air samples under accident conditions. For the long term (interim) period, there are no procedures for sampling the containment atmosphere when the present sampling stations are not accessible under accident conditions. This is an open item.
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Emergency Plan Procedure EPP-6 does not provide adequate instructions for analytical measurements of high activity samples of containment atmosphere under emergency conditions.
See Section 4.1.1.6 f or conclusions.
5.4.2.8 Stack Effluent Sampling The inspector reviewed the licensee's implementation of recom-mendations specified in NUREG-0578, Section 2.1.8, Paragraphs (a),
(b), and (c), to verify that the licensee has the interim cap-ability to obtain samples of high activity gas and particulate effluents under accident conditions.
The licensee does not have an adequate emergency plan implementing procedure for collecting a sample of high activity gas and particu'-
ate effluents in accident situations.
Based upon the above findings, the following improvements are required to achieve an acceptable program:
Develop procedures for sample retrieval and r3 placement of
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stack effluents under accident conditions.
Upgrade Emergency Plan Procedures for sample preparation to
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determine radioisotope identification and concentration; e.g.,
dilution criteria or sample fractioning should be related to pre-determined radiation levels indicating that 10% dead time of the multi-channel-analyzer-system for fixed geometries will not be exceeded.
5.4.2.9 Stack Effluent Sampling Analysis The inspectors reviewed the licensee's capabilities to perform analysis of stack effluents samples during emergency situations.
Sections 5.0 and 6.0 of Emergency Plan Precedure EPP-6 Address
"In-plant Airborne Sample Collection and Analysis During Accidents" and " Radioactive Effluent Sample Collection and Analysis During Accidents" respectively. The implementation of these sections of EPP-6 do not adequately address or provide necessary instructions for performing analvtical measurements of high activity samples during accident conditions.
Based upon the above findings, the following improvements are required to achieve an acceptable program:
Upgrade Emergency Plan Procedure EPP-6 to adequately cover
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sample preparation and analysis of high activity samples under accident conditions by providing instructions for performing analytical measurements of high activity samples.
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5.4.2.10 &
~5.4.2.11 Liquid Effluent Sampling The licensee does not have procedures for liquid effluent sampling nor for performing analytical measurements of high activity liquid effluent samples under accident conditions.
Based on the above finding, the following improvement is required to achieve an acceptable program.
Develop a procedure for sampling and analysis of liquid
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effluents under emergency conditions.
5.4.2.12 Radiological and Environmental Monitoring Program There are provisions in the Emergency Plan Procedures for radio-logical and environmental monitoring. The procedure provides for collection samples of foodstuff and agricultural products and for airborne radioiodine sampling and analysis. All other environmental monitoring is to be performed according to standard Health and Safety Department (HSD) procedures. The HSD procedures called for taking environmental samples at the standard, preselected locaticns, rather than determining sampling locations from meteorological data.
Replacement TLD's are not kept onsite for the environmental TLD stations, and che EPP's do not provide for retrieval of the TLD's under emergency conditions.
The licensee has adequate equipment onsite in the hot lab and the environmental lab to analyze the environmental samples depending on habitability.
Samples are to be taken to the University of Wisconsin-Lacrosse
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for analysis if the hot lab or the environmental lab are not available.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
,
Provide procedures for preparation and analyr.is of environ-
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mental samples and assign responsibility of who will perform preparations and analysis of environmental samples and include provisions for recovery and replacement of environmental TLDs.
5.4.3 Protective Actions 5.4.3.1 Radiation Protection During Emergencies The licensee's Emergency Plan Procedures do not contain an overall procedure governing the implementation of the radiation protection program.
Instead, the normal health physics procedures contained in Volume X of the LACBWR Operating Manual are to be used in an emergency with certain EPP's providing additienal precautions to be used regarding radiation protection.
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Radiation protection procedures which are expanded on in the EPP's include: personnel dosimetry, access controlc, instructions to emergency workers and dose assessment.
The procedures dc describe who is to perform the health physics procedures emergency situations (e.g., inplant, onsite and offsite surverys, emergency sampling and dose assessment).
Radiation protection terminology is not always consistent or correct throughout the EPP's.
For example, EPP-2, in Section 4.3.11 states:
"Any indication that dose rates or contamination rates may exceed 1 rem whole body or 5' rem to the thyroid shall cause the ECD to escalate the emergency status...."
The numbers expressed here, I rem and 5 rem are dose equivalents, not dose rates or contamination rates.
Based or. the above findings, improvements in the following areas are required to achieve an receptable program:
Provide an emergency plan procedure which orchestrates all
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aspects of the radiation protection program during an emergency.
The following area should be considered for improvement:
Assure that terminology is correct throughout the emergency
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plan implementing procedures and radiation protection procedures.
5.4.3.2 Evacuation of Owner Controlled Areas The inspectors interviewed the Director of Security, security personnel and members of the plant staff regarding evacuation of owner controlled areas.
Section 6.4.1 of the LACBWR Emergency Plan, " Protective Cover, Evacuation, Personnel Accountability,"
provides a general discussion of this subject.
EPP-2, Section 4.3.3 of the LACBWR Procedures provides a more detailed discussion of the actions to be taken for evacuation during an emergency.
Section 4.3.3., " Site Emergency," states " evacuate all onsite personnel except operational crew, Health and Safety Technician and Shift Technical Advisor to the Operational Support Center (OSC) at Genoa-1 (G1) or the OSC in the lunch room by the Control Room."
There are primary and secondary evacuation routes, however, they are not clearly marked with conspicously posted arrows, signs, floor markings or other readily visible means.
A check of the siren warning and oral annoucement systems was made by the auditing team.
It was determined that most areas could clearly hear the siren
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There are no means specified in the LACBWR Emergency Plan or Procedures to verify that all individuals onsite and in owner controlled areas have been warned. other than personnel account-ability. Section 4.2.3 provides corrective measures regarding the warning sirens.
The following matters should be considered for improvement:
Mark evacuation routes clearly to permit rapid and safe, egress.
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5.4.3.3 Personnel Accountability The inspectors interviewed the Security Director and some members of the security force regarding personnel accountability.
Personnel accountability is addressed in the LACBWR Emergency Plan in Section 6.4.1.1.
This section described how the " check in" boards are used by personnel at the turbine and containment building entrances; and who is responsible for the accountability of personnel, including contract and construction personnel and visitors.
EPP-2,
" Operation During Emergencies," Sections 4.3.3 and 4.4.3 describe the actions that are to be taken by the Security Force regarding personnel accountability and that they are to report to the Emergc cy Control Director (ECD) with their results.
Those individuals interviewed stated that they had practiced the accountability procedures during drills and could determine who was missing within 30 minutes. The procedures do no specify what action each security force member must take in the event of an emergency, although all security personnel interviewei knew what action to take.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be con-sidered for improvement:
EPP-2 should be modified to state specifically the respon-
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sibilities of each security force member in an emergency.
5.4.3.4 Personnel Monitoring and Decontamination Section 6.4.1 of the Emergency Plan discusses the monitoring and decontamination of individuals. EPP-12, " Personnel Decontamination Procedure," discusses the decontamination of personnel. Ilowever, there are no EPP's providing for the monitoring of all individuals leaving restricted areas, at assembly areas and at reassembly areas.
Because there are no procedures for personnel monitoring during an emergency, these are no provisions for:
recording the names of individuals surveyed,
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recording the extent an individual is contaminated,
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instrumentation to be used for survey,
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action levels for decontamination, and
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providing collec;*d data to the individual or organizational
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element responsible for the radiation program during emergencies.
Based on the above finding, improvements in the following areas are required to achieve an acceptable program:
Develop a procedure for monitoring of all individua1r leaving restricted areas, at assembly areas and at reassembly areas, which includes; a.
Recording the names of individuals surveyed.
b.
Recording the extent an individual is contaminated.
c.
Describing the instrumentation to be used for personnel monitoring.
d.
Action levels for decontamination.
5.4.3.5 Onsite First Aid / Rescue Onsite first aid and medical treatment are addressed in Sections 5.3.2.2, 5.3.2.4 and 7.2.1.4 of the LACBWR Emergency Plan and EPP-11, " Emergency First Aid and Medical Assistance - Contamin-ated Patient," of the LACBWR Emergency Procedures. Section 6.5.1 of the LACBWR Emergency Plan discusses Emergency Personnel Exposure.
The emergency plan and procedures do not address decision making parameters used to for emergency rescue.
EPP-11 generally discusses the method for receiving, transporting and handling injured persons who may also be contaminated. This procedure also describes the interface and criteria for using offsite medical treatment facilities. Attachment A of EPP-11 states that the LACBWR Health and Safety personnel will be responsible for monitoring exposure to those individuals treating the coni oinated individual, but does not discuss the limiting of personnet exposure.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be con-sidered for improvement:
Upgrade EPP-11; " Emergency First Aid and Medical Assistant -
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Contaminated Patient," to contain information for decision making regarding when offsite medical treatment facilities will be used.
Modify EPP-11, " Emergency First Aid and Medical Assistant -
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Contaminated Patient," Attachment A to state that LACBWR Health and Safety personnel will be responsible for limiting the exposure of hospital personnel and describe those methods to be used for limiting personnel exposure.
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Establish decision making parameters for emergency rescue.
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5.4.4 Security During Emergencies The inspectors intet riewed the Security Director and six security personnel.
It was determined that security personnel were not aware of the 30 minute personnel accountability criteria specified in Section J.5 of NUREG-0654, nor is the 30 minute criteria addressed in the plans and procedures. However, personnel accountability are generally described in the plan and procedures.
Security personnel stated that during drills the 30 minute criteria has been met.
However, no records were provided verifying this.
(See Section 5.4.3.3).
Procedures describing security personnel actions have been written, (EPP-2), but they do not specify what actions the personnel at each security post should take during an emer3ency. Security personnel stated that the emergency procedures involving the security force should be more detailed.
Security personnel are also members of the fire brigade during an emergency.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be con-sidered for improvement.
Procedures should be developed which specify the respon-
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sibilities of members of the Security force during an emergency.
5.4.5 Repair and Corrective Action Repair and corrective action is not addressed in a specific Implementing Procedure. The LACBWR Emergency Plans specifies that repair and corrective action will be directed by the Quality Assurance Supervisor Maintenance Superintendent. There is no procedure which specifically addresses safety considerations for repair or corrective action teams. The information should include the radiation safety and dosimetry aspects of each test and give attention to ALARA in the planning.
The responsibility for this is generally assigned to the Radiation Protection Engineer.
Based on the above finding, this portion of the licensee's program is adequate; however, the following matter should be considered for improvement:
Establish procedures which specify the repair and/or correc-
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Live action, organization to whom the team reports and steps to assure that individuals are properly briefed in radiological conditions prior to working.
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5.4.6 Rec,very Based on the inspectors review of the licensee's Emergency Plan, Section 9 of the LACBWR Plan, titled " Recovery and Re-entry" the authority and responsibility for those positions listed below is specified and appears to be adequately described:
Emergency Control Director LACBWR Operations Supervisor LACBWR Assistant Superintendent LACBWR Radiation Protection Engineer LACBWR Quality Amaurance Supervisor However, the recovery and re-entry phase of the LACBWR facility after an accident is not addressed in a specific implementing procedure.
Responsibility for initiating the recovery and re-entry phase has
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not been defined. According to the Plan, the LACBWR Assistant Superintendent will prepare the procedures for the recovery and re-entry of the plant and the Operations Review Committee and Emergency Control Director will review and approve them. Fro-visions have not been established for evaluating plant operating conditions nor have provisions been established for in plant and out of plant radiological conditions to be used for decision making purposes. No provisions have been described for notifying individuals and agencies that a recovery and re-entry mode has been initiated.
Based on the above findings, this portion of the licensee's program appears adequate; however, the following item should be corrected:
Develop a procedure for recovery and re-entry which:
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Specifies duties and responsibilities of personnel involved in recovery and re-entry as indicated in the Emergency Plan.
b.
Provides the criteria for initiation of the recovery and re-entry phase.
c.
Provides information on radiological conditions-inside and outside of the plant to aid in decision making.
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d.
Initiates notification of appropriate organizations and supporting agencies that the recovery and re-entry phase has been initiated.
5.4.7 Public Information The licensee, with the assistance of Wisconsin Division of Emergency Government, has compiled an~ information brochure for the LACBWR facility. The brochure is entitled "Just in Case What You Should Know In The Event Of An Incident At A Nuclear Power
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Plant." The pamphlet gives a short explanation of radiation and what it is and also describes precautions to be taken in the event of a " stay indoors" or an." Evacuation" notification. The generic part of the brochure also describes special provisions mode for disabled persons. General advice for any emergency situation (Tornado, chemical release) which could require evacuation is also given.
'he second part of the brochure contains plant specific information on: evacuation routes, including maps; addresses and phone numbers of Local Emergency 6m,ernment/ Civil Defense offices; instructions for local residents who may be disabled; identification of local radio and TV stations; a Dairyland Power Cooperative (DPC) information phone number; and a local State Division of Emergency Government (DEG) telephone number. Mailing addresses of DPC and DEG are also provided.
The Public Information Director stated that the brochure would be disseminated in the plume emergency planning zone (EPZ) by August 15, 1981.
Emergency Plan Procedure-16 (EPP-16) identifies organizations involved in dissemination, their location and ways of contacting them.
The Public Information Director and/or the Director of Information and Marketing are designated as official company spokespersons and appear to understand their functions and responsibilities. However, procedures have not been developed outlining all of these duties and functions.
Provisions have been made for providing response to inquiries from private citizens, from the news media and for rumor control. However, written procedures have not been developed which designate who is responsible.
No procedures exist regarding activities of the JPIC, personnel duties and responsibilities, message content for public dissemina-tion, backup personnel for the two public information individuals.
Based on the above findings, improvements in the followir,q area is required to achieve an acceptable program:
No procedures exist regarding activities of the JPIC, personnel
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duties and responsibilities, message content for public dis-semination, back-up personnel for the two public information individuals.
The following matter should be considered for improvement:
Procedures should be written defining the functions and
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responsibilities of the spokesperson with regard to the news media, inquiries from private citizens, and rumor control.
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5.5.1 Inventory, Operational Check and Calibration of Emergency Equipment and Supplies The licensee's Emergency Plan, Section 8.4, states: all emergency equipment and supplies are to be inspected on a quarterly basis by the Health and Safety Department; the various first aid and medical equipment kits, personnel decontamination supplies, emergency egaipment boxes and portable radiation monitoring equipment are to be inspected after each use; equipment is to be inspected for both quality and condition and readiness for use; and equipment removed for calibration are replaced by spares during calibration.
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The aspectors determined there were no formal procedures 'for regular operational checks of emergency equipment and supplies.
Therefore, Section 8.4 of the Emergency Plan does not have an implementing procedures.
Based on the above findings, improvement in the following area is required to achieve an acceptable program:
Develop procedures to assure emergency equipment and supplies are operationally checked and inventoried to ensure availability.
5.5.2 Drills and Exercises The inspectors reviewed the Emergency Plan Procedure (EPP-17) which describes action that will be taken during emergency plan drills and exercise.
Communication drills have been held monthly. All other drills and exercises are scheduled.
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Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.5.3 Review, Revision and Distribution The LACBWR Emergency Plan specifies that the LACBWR Health and Safety Supervisor is responsible for keeping the Emergency Plan up-to-date and is designated the Emergency Planning Coordinator (EPC). A review of the entire plan will be completed every two years instead of annually as required by NUREG-0654, Criteria P-4.
Telephone numbers in the EPP's are to be updated quarterly.
Pro-posed changes to the plan must be reviewed by the LACBWR Operations Review Committee and approved by the Plant Superintendent prior to implementation.
Changes in the Emergency Plan and Preparedness Frocedures are furnished to groups and individuals assigned respcasibilities for implementing of the plans and procedures.
EPP-15 Emergency Preparedness Review and Updating addresses the review, revision and distribution of the plan. This procedure states that distribution of the plan will be in accordance with reference 2.3-ACP-7.1, " Review, Approval and Issuance of LACBWR Controlling Documents." The LACBWR Emergency Plan and Procedures are on controlled distribution.
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Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be con-sidered for improvement.
Modify the provision for updating of the emergency plan to an
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annual requirement.
5.5.4 Audit The audit of the Emergency Preparedness Program is specified in EPP-15 and in ACP-19.0.
EPP-15 requires an annual independent audit of the entire Emergency Preparedness Program as specified in NUREG-0654. The emergency plan dated March 31, 1981, and implementing procedures have not been audited to date.
Based on the above findings, this portion of the-licensee's program appears to be acceptable.
6.1 Offsite Support Agencies
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L_aCrosse Lutheran Hospital On July 16, 1981, the inspector met with the Nursing Coordinator of the Lacrosse Lutheran Hospital and discussed the responsibilities of the Emergency Medical and Trauma Center (EMTC) in the event of a nuclear accident at the LACBWR facility. The procedures the hospital and EMTC personnel would follow in handling and treating a radioactively con-taminated LACBWR employee were described. Their decontamination room can accommodate one patient at a time, although they can adequately manage two to three individuals involved in a nuclear accident.
The licensee has presented radiation training seminars at the hospital for those personnel whose duties might entail the treatment of a radio-actively contaminated patient. The licensee has offered support to individuals for specific training courses conducted at the Oak Ridge National Laboratory, Oak Ridge, Tennessee.
The inspectors reviewed a copy of the h, spital's Nuclear Emergency Medical Plan which contains the guidelines for the care of patients involved. in a nuclear accident. This plan was dated August 28, 1980, and was approved by the Hospital Administrator, Administration Head and the Nursing Coordinator. Emergency equipment is located in a locked metal cabinet in the decontamination room. A LACBWR Rad / Chem Technician has the key. The current policy of LACBWR provides that a Rad / Chem Technician shall accompany the radioactively contaminated employee to the hospital and be present when the EMTC personnel take over. The LACBWR representative unlocks the equipment c: binet when the patient is to be admitted to the decontamination room. Verifi-cation that the emergency equipment was present in the cabinet was not performed during this appraisal.
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The most recent letter of agreement is dated December 14, 1979. This agreement letter should be updated. The hospital participates in yearly emergency exercises with LACBWR.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the follovicg matter should be considered for improvement.
Update the letter of aggreement with Lacrosse Lutheran Hospital.
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Tri-State Ambulance Service The inspector visited this organization on July 16, 1981, and spoke to the attendants regarding their functions as a support agency to LACBWR in the event of a nuclear accident. Those on duty stated they had not personally participated in any drill or exercise with the licensee. The auditor learned later by telephone inquiry that the most recent drill conducted was in the summer of 1980, prior to the employment of these particular ambulance attendants. The letter of agreement was signed on April 14, 1977. The owner, contacted by telephone, stated that he felt training was adequate and that a good working relations _ip exists between the licensee and the ambulance s2rvice. The current plan calls for a yearly drill involving this agency with the Lacrosse Lutheran Hospital.
A Rad / Chem Technicina rides in the ambulance ;hile the patient is beir.g transported from the site to the hospital.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement.
Update the letter of agreement with Tri-State Ambulance Service.
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Vernon County Sheriff's Department, Viroqua, Wisconsin On July 16, 1981, the inspector interviewed the Deputy Sheriff who was on duty at the time and was also serving as Dispatcher. He was familiar with the NAWAS phone and knew how to utilize it properly. He showed the inspector a two page procedure to follow if an emergency was declared at the site and the Sheriff's Department was asked for help. He stated all Sheriff's Department personnel and Police were cognizant of the NAWAS phone and instructed on the procedure just described.
This emergency procedurc used by the Sheriff's Department personnel included other offsite agencies to contact once the Vernon County Sheriff's Department receives the original telephone call.
The inspectors concluded that this offsite agency had adequate procedures to follow in the event of a nuclear emergency at the LACBWR facility and was knowledgeable of them.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
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Mississippi River-Lock and Dam No. 8, Army Corps of Engineers On July 17, 1981, the inspector interviewed the Lockmaster at Lock and Dam No. 8, which is approximately \\ mile north of the reactor site. He is aware of his responsibility in regulating river traffic and also contacting the lock and dam on either side of this location in the event of a nuclear accident. Ship and-boat control is the Lockmaster's prime responsibility. Their letter of agreement was signed on January 4, 1980 by an executive of the Army Corps of Engineers. This lock and dam site has a total cowpliment of 12 people. The inspector concluded that this offsite support agency is knowledgeable of its responsibilities in the event of a nuclear accident.
Based on the above findings, this pcrtion of the licensee's program appears to be acceptable.
U.S. Coast Guard, Twin Cities District Office, St. Paul, Minnesota The inspector contacted this offsite support agency by telephone on July 17, 1981. He spoke with the Chief Warrant Officer (CWO) wb; was aware of their function in the event of a nuclear emergency at the reactor site. They have a contingency plan to follow, but have practically no emergency radioactive measuring equipment. The CWO stated their personnel have dosimeters, but no film badges or other related equipment. He was not familiar with the letter of agreement.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
Provide basic radioactivity measuring devices as well as film
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badges to the U.S. Coast Guard, Twin Cities District Offite, St. Paul, Minnesota.
6.2 General Public The licensee has developed an information brochure for the LACBWR facility. This pamphlet was compiled and written in with the Wisconsin Divirion of Emergency Government and all of the Wisconsin Nuclear Plants.
The brochure is described in Section 5.4.7 of this report.
The Public Information Director stated that the brochure is being printed and will be distributed to the resident and transient population of the plume exposure EPZ.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
Distribute the Public Information Brochure to inform the resident
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and transient adult population of the plume exposure EPZ of what to do in the event of an emergency. The brochure shall be updated and diseminated annually.
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6.3 News Media The licensee held a news media briefing on November 20, 1980. The media toured the plant and received information on normal plant operations, refueling operations and basic radiation protection. The media was invited on an annual tour of the facility.
Based on the above finding, this portion of the licensee's program appears adequate.
7.0 Drills and Exercises 7.1 Program Implementation The licensee's Emergency Plan Section, 8.2, addresses drills and exercises.
Emergency Plan Procedure (EPP-17) implements that section of the plan.
Section 8.2 of the plan and the procedure comply with the requirement of NUREG-0654 Planning Standard N.
Drills and exercises have been conducted as required in acccedance with EPP-17.
Based on the above findings, this portion of *.he licensee's program appears to be acceptable.
7.2 Walk-Through Observation 7.2.1 Emergency Detection, 7.2.2 Emergency Classification, and 7.2.3 Notification The inspectors conducted walk-through observations with seven of the thirteen Licensed Senior Operators (LS0) at LACBWR. The Licensed Senior Operators observed were either assigned as Shift Supervisors or might be assigned as relief Shift Supervisors.
The Shif t Supervisors were observed in the role of Emergency Control Director (ECD).
By Procedure EPP-2 they would assume responsibilities at the onset of an emergency during the time in which the Plant Superintendent'or his Assistant would not be available. The ECD role would be assumed by the Plant Superintendent when he would arrive at the EOF for Site Area and General Emergencies; for notification of Unusual Events and Alert categories, the Shift Supervisor would remain the ECD for the duration of the emergency.
During the walk-throughs, involving various hypothetical initiating events, the ECD's demonstrated the basic skill to assess and categorize the event, recognize the need to augment staff, notify appropriate offsite agencies and perform mitigating actions to control the offnormal plant condition. The Licensed Senior Operators, who assume the ECD role, stated they had
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received minimal formal training in the Emergency Plan and Emergency Plan Procedures the training received was'on the order of less than an hour to three hours of formal training in the past six months. This was evidenced by the faltering use of the EPP's, failure to recognize EPP-1 and EPP-2 as the basic pro-cedures for categorizing the event, and initiati'g appropriate emergency response.
The ECD's were questioned regarding post accident sampling of containment air and primary coolant. Because no procedures have been developed for interim post accident sampling, the ECD's formulated extemporaneous unacceptable methods for collecting these samples without giving thought to tne consequences of their actions.
Based on the above finding, the following improvaments are required to achieve an acceptable program:
Upgrade the emergency plan and procedures training program to
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include specific training in the contents of EPP-1.
Emergency Conditions and Response, and EPP-2, operation during emergencies; and the physical use of the EPP's.
The following matter should be considered for imnrovement of the training program.
Institute a program of training followup to include a periodic
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walkthrough use of the EPP's for Hypothetical Emergency Condi-tions (scenarios) to maintain proficiency in use of the EPP's.
Walkthroughs 7.2.4 Post Accident Sampling and Analysis 7.2.5 Containment Air Sampling and Analysis 7.2.6 In-Plant Sampling and Analysis 7.2.7 Offsite Environmental Sampling and Analysis Walkthroughs for these sections were not conducted during this appraisal because no Emergency Plan Implementing Procedures were in place for use as evaluating criteria. This is an open item.
8.0 Persons Contacted DPC Lacrosse Boiling Water Reactor R. Brimer. Electrical Engineer (LACBWR)
D. Croonquist, Licensed Senior Operator (LACBWR)
L. Goodman, Operations Engineer (LACBWR)
R. Hackner, Engineering Aide (LACBWR)
- G. Joseph, Security Director (LACBWR)
S. Kaldunski, Engineering Aide (LACBWR)
R. Marose, Public Information Director (DPC)
L. Nelson, Health Physics Technician (LACBWR)
- J. Parkyn, Asst. Plant Superintendent and Security Manager (LACBWR)
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P D. Rybarik, Mechanical Engineer (LACBWR)
F. Schroeder, Health Physics Technician (LACBWR)
- P. Shafer, Radiation Protection Engineer (LACBWR)
- T.
Steele, Director of Environmental Affairs (DPC)
- J. Taylor, Assistant General Manager-Power (DPC)
H. Towsley, Director of Quality Assurance (DPC).
- B. Zibund, Health and Safety Supervisor (LACBWR)
R. Cota, Shift Supervisor, Licensed Senior Operator D. Croonquist, Licensed Senior Operator J. Gallaher, Shift Supervisor, Licensed Senior Operacor R. Ganser, Shift Supervisor, Licensed Senior Operator L. Goodman, Shift Supervisor, Licensed Senior Operator Shift Technical Advisor Operations Engineer L. Kelley, Shift Supervisor, Licensed Senior Operator Training Supervisor, Assistant Operations Superintendent M. Polsean, Shift Supervi.or, Licensed Senior Operator
- Denotes those present at the exit interviews.
Non DPC Employees M. Anderson, Nursing Coordinator, Lacrosse Lutheran Hospital J. Boge, Radiological Safety Officer, Lacrosse Lutheran Hospital S. Bussian, Security Post Commander-LACBWR, BISSI B. Christianson, Senior Guard-LACBWR, BISSI E. Cox, Deputy Sheriff, Vernon County, Wisconsin G. Egbert, Radiation Physicist, University of Wisconsin-Lacrosse W. Gardiner, Owner, Tri-State Ambulance Service T. Giese, Security Guard-LACBWR, BISSI K. Gobel, Firemen, Stoddard Fire Department T. Haag, Security Guard-LACBWR, BISSI L. McClellan, Senior Guard-LACBWR, BISSI R. McLees, Lockmaster, Army Corp. of Engineers, Lock and Dam No. 8 W. Nieckarz, Radiochemist, University of Wisconsin-Lacrosse R. Peterson, Chief Warrent Officer, U.S. Coast Guard, Twin Cities Dist.
Office, St. Paul, Minnesota R. Phillips, Chief, Genoa Fire Department D. Umberger, Senior Guard-LACBWR, BISSI BISSI= Burns International Security Services, Inc.
9.0 Followup on Immediate Action Letter Dated August 15, 1981 The licensee informed this office by letter (LAC-7455) dated April 6, 1981, that they would not be able to implement their Emergency Plan by April 1, 1981, in accordance with the requirements of 10 CFR 50.54(s)(2).
This is an item of noncompliance. Accordingly, an Immediate Action Letter was sent to the licensee on April 15, 1981, which required them to implement the Plan by May 1, 1981. The licensee agreed with this date.
This is a Severity Level IV violat'on.
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During this Emergency Plan Appraisal, the inspection verified that'the IAL had been implemented. The inspectors have no further questions regarding this item.
J-10.
Exit Interview -
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The inspectors and senior management from NRC headquarters and the region
~
met with licensee representatives (denoted in Paragraph 8) at 6he con-
!
clusion of the appraisal on July.24, 1981. The inspectors summarized the scope and findings of the appraisal. 'A detailed technical exit was also-g-conducted at the conclusion of the appraisal with licensee representatives
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of those technical areas which needed improvement.
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Appendix A SIGNIFICANT APPRAISAL DEFICIENCIES The following is a list of Significant Deficiencies regarding the Lacrosse Emergency Preparedness Appraisal. These deficiencies are categorized ac-cording to the planning standards of 10 CFR 50.47(b). These deficiencies must be resolved in accordance with the provisions of 10 CFR 50.54(s)(2)
in order for the onsite state of emergency preparedness to provide reason-able assurance that adequate protective measures can and will be taken in the event of a radiological emergency.
1.
Planning Standard 50.47(b)(1) (Assignment of Responsibility)
Deficiency The following deficiency was identified:
Documentation delineating the authority, responsibilities and
.
limits on actions of corporate management, site emergency response organizations, and contractor organizations have not been provided. Further, the method of transferring the Emergency Control Director Responsibility from the onsite emergency opera-tion to the EOF at the DPC Headquarters in Lacrosse has not been specified.
(Sections 1.0 and 2.0) (409/81-13-01)
2.
Planning Standard 50.47(b)(2) (Onsite Emergency Organization)
Deficiency The following deficiency was identified:
Adequate compensatory measures for minimum shift staffing,
.
augmentation, as specified in NUREG-0654, and Table B-1 have not been addressed nor has an acceptable shift augmentation system been developed or tested.
(Section 2.2) (409/81-13-02)
3.
Planning Standard 50.47(b)(4) (Emergency Classification System)
Deficiency The following deficiencies were identified:
The LACBWR Operating Manual, Non-Routine and Emergency Operating
.
Procedures did not reference the EPP's and activation of the Emergency Plan.
(Section 5.2) (409/81-13-03)
Appendix A-2-Initiating Conditions in EPP-1 for emergency action levels based
.
on specific readings and on specific instrumentation are not sufficiently detailed to categorize an incident at the appropriate emergency level; nor do they provide for loss of any two of three fission product barriers as an initiating condition for a General Emergencv; nor is there sufficient conservatism in the containment pressure condition for loss of a fissicn product barrier, i.e.,
declaration of a General Emergency for two of three fission product barriers and a potential loss of the third should be indicated by very high containment pressure greater than 30 psig and rising rather than " greater than 50 psig and rising." (Section 5.3) (409/81-13-04).
4.
Planning Standard 50.47(b)(5) (Notification Methods and Procedures)
Deficiencies The following deficiencies were identified:
The onsite warning siren and public address system at the LACBWR
.
facility could not be clearly heard in all areas of the plant and needs upgrading.
(Sections 5.4.3.2 and 4.2.3) (409/81-13-05)
The licensee has not demonstrated that administrative and physical
.
means have been established for alerting and providing prompt in-structions to the public within the plume exposure pathway EPZ.
The licensee will be responsible for ensuring prompt alerting and notification of the public in accordance with the Commission's regulations.
(409/81-13-06) (409/81-13-06)
5.
Planning Standard 50.47(b)(6) (Emergency Communicationsl Deficiencies The following deficiencies were identified:
Communications check procedures for portable FM radios at various
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locations in the turbine building and the containment building were not established.
(Section 4.2.3) (409/81-13-07)
Dedicated voice communication links <ere not installed between the
.
Control Room and TSC.
(Section 4.1.1.2) (409/81-13-08)
6.
Planning Standard 50.47(b)(7) (Public Education and Information)
Deficiencies The following deficiencies were identified:
Procedures were not established specifying DPC staff assignments
.
to the Joint Public Information Center and to the Corporate staff,
Appendix A-3-how media personnel will be contacted, staff responsible for con-tacting the media and the order in which they are to be contacted.
(Section 5.4.7) (409/81-13-09)
Distribution of the Public Information Brochure to inform the
.
resident and transient population of the plume exposure EPZ of what to do in the event of an emergency had not been accomplished.
There were no provisions for annual update and dissemination of the brochure.
(Section 6.2) (409/81-13-10)
7.
Planning Standard 50.47(b)(8) (Emergency Facilities and Equipment)
Deficiencies The following deficiencies werc identified:
An inventory procedure has not been provided for emergency kits
.
to assure that the correct inventory is maintained to include:
detailed maps for survey teams to report survey locations, re-placement of dosimeters during calibrations, portable li hting, P
(e.g., flashlights) and portable communications equipment.
(Sections 4.2.1.1 and 5.5.1) (409/81-13-11)
The survey teams do not have portable air sampling equipment that
.
can be used in the field i.e., battery powered or a.c. powered with a portable a.c. power supply.
(Section 4.2.1.1) (409/81-13-12)
8.
Planning Standard 50.47(b)(9) (Accident Assessment)
Deficiencies The following deficiencies were identified:
The licensee has not developed a definitive Emergency Plan Procedure
.
for sample preparation and analysis of high activity samples under accident conditions.
(Section 5.4.2.9) (409/81-13-13)
No procedure or EALs for use of the Area Radiation Monitor out-
.
side containment have been developed to determine quantity of radioactivity released into containment.
(Section 4.1.1.6)
(409/81-14-014)
The licensee has not developed the capability and procedures for
.
post-accident sampling and analysis of samples from the liquid effluent system.
(Sections 4.1.1.8 and 5.4.2.10) (409/81-13-15)
Procedures to obtair samples of stack effluent under accident con-
.
ditions have not been developed.
(Section 5.4.2.8) (409/81-13-16)
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Appendix A-4-
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Displays in the control room of meteorological data appropriate
.
for releases near ground level permitting easy determination of 15-minute averages of wind speed, wind direction, and an indicator of atmospheric stability have not been provided.
(Section 4.2.1.4)
(409/81-13-17)
The digital display in the control room of instantaneous value of
.
temperature difference will not allow determination of a 15-minute average.
(Section 4.2.1.4) (409/81-13-18)
The 10 meter sensors have not been properly sited. Although no
.
location on the LACBWR site is completely satisfactory for locating a 10 meter tower, the tower can be sited to reduce the building wake influence et. the present locatian.
(Section 4.2.1.4) (409/81-13-19)
Procedures for preparation and analysis of emergency environmental
.
sample = and assignment of responsibility of who will pecform sample analysis and preparations have not been provided including the recovery and replacement of environmental TLD's.
(Section 5.4.2.12)
(409/81-13-20)
Emergency Plan Procedures for sample preparation for radioisotope
.
identification and concentration do not cover dilution criteria or sample fractioning related to pre-determined radiation levels in-dicating that 10% dead time of the multichannel analyzer system for fixed geometries will not be exceeded.
(Section 5.4.2.8)
(409/81-13-21)
Procedures for obtaining meteorological data if primary measure-
.
ments are not available have not been provided. Techniques for obtaining and utilizing backup information should be described in detail for both elevated and ground level-releases.
Ident-
!
ification and uti!ization of backup data should be consistent in all plant emergency procedures.
(Section 4.2.1.4) (409/81-13-22)
Written procedures for calibration, operability checks, and main-
.
tenance of the onsite meteorological measurements program are not adequate.
(Section 4.2.1.4) (409/81-13-23)
The meteorological procedures (EPP-5 and EPP-8) do not consider
.
both elevated and ground level releases and the meteorological procedures do not include provisions for obtaining and utilizing backup data. The technical basis for utilizing back-up data should be provided in a document separate from the procedures.
(Section 5.4.2) (409/81-13-24)
Provisions for obtaining and utilizing meteorological informa-
.
tion beyond that used in an initial dose assessment have not been identified. Further, data sheets Nos. I and ?_ (EPP-5) do not
q Appendix A-5-characterize release mode, nor consider 15-minute average meteoro-logical conditions. These provisions should be consistent with EPP-8 as revised. The use of two Figure 3's in EPP-5 on Pages 9 and 15 leads to confusion in which one to use in performing calculations.
(Section 5.4.2) (409/81-13-25)
9.
Planning Standard 50.47(b)(11) (Radiological Exposure Control)
Deficiencies The following deficiencies were identified:
An alternate assembly area offsite equipped for sheltering of site
.
evacuees and outfitting of survey teams has not been provided.
(Section 4.1.2.1) (409/81-13-26)
Precedures have not been provided for monitoring of all individuals
.
leaving restricted areas at assembly areas and at reassembly areas, 5Nich includes:
a.
action levels for decontamination; b.
a description of the instrumentation to be used for personnel monitoring; c.
provisions for recording the extent an individual is contamin-ated, and d.
provisions for recording the names of individuals surveyed.
(Section 5.4.3.4) (409/81-13-27)
An emergency plan procedure that orchestrates all aspects of the
.
radiation protection program during an emergency was not provided.
including a method far determing individual doses in a timely manner and providing this information to responsible persons for control radiation exposures.
(Section 5.4.3.1) (409/81-13-22)
10.
Planning Standard 50.47(b)(15) (Radiological Emergency Response Tr'ining)
Deficiencies Contrary to the above, the following deficiency was identified:
.
The Emergency Plan and Procedures training program do not include specific training in the contents of EPP-1, " Emergency Conditions and Response," and EPP-2, " Operation During Emergencies;" and the physical use of the EPP's.
(Section 7.2) (409/81-13-29)
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Appendix B NOTICE OF VIOLATION Dairyland Power Cooperative -
Decket No. 50-409 As a result of the inspection conducted on July 13-24, 1981, and in accordance with the Interim Enforcement Policy, 45 66754 (October 7,1980), the following violation was identified-10 CFR 50.54(s)(2) states in part that licensee, State, and_ local emergency response plans shall be implemented by' April 1, 1981.
Contrary to the above, the licensee failed to implement their Emergency Plan by Apri1~1,'1981. The licensee's letter (LAC-7455) dated April 6, 1981, ad -
vised this office that they would not adhere to April 1, 1981, date.
This is a Severity Level IV violation (Supplement IV).
The inspection showed that action had been taken to correct the identified item (s) of nracompliance and to prevent recurrence.
Consequently, no reply to this (thest) item (s) of noncompliance is required and we have no further questions regarding this matter.
Dated James G. Keppler Director i
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Appendix C APPRAISAL IMPROVEMENT ITEMS Based on the results of the NRC's Appraisal of Lacrosse Boiling Water Reactor Emergency Preparedness Program conducted July 13-24, 1981, the following items should be considered for improvement.
1.
Provide an organizational chart specifying the interrelationships of each of the onsite functional areas of emerge.ncy response and augmentation groups.
(Section 2.2.2)
2.
Provide emergency plan and procedures training for corporate personnel who may assist the emergency organization and for all onsite personnel including personnel working at Genoa-3.
(Section 3.2)
3.
The Emergency Operations Facility should contain the following:
Copies of State and local plans.
.
Isopleths (dose projections for various meteorological conditions as
.
aids in decision making).
As-build LACBWR plant layout drawings.
.
Readout for station meteorology.
.
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Dedicated EOF to TSC communications.
(Section 4.1.1.4)
4.
Provide minimum stock levels of emergency equipment and supplies to ensure an adequate reserve of normal supplies is maintained.
(Section 4.2.5)
5.
The liquid effluent pathways to the environment should be described in the Emergency Plan Procedures.
(Section 4.1.1.8)
6.
An agreement, between LACBWR and the University of Wisconsin - Lacrosse Nuclear Radiation Center, should be reached limiting transport of samples to the facility to millicurie quantities per sample.
(Section 4.1.1.9)
7.
Establish procedures which specify the repair and/or corrective actions, organization to whom the team reports and steps to assure that individ-uals are properly briefed in radiological conditions prior to working.
(Section 5.4.6)
8.
Provide copies of decontamination procedures for the Genoa-1 assembly area and the LACBWR Turbine Building Facility.
(Section 4.1.2.3)
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Appendix C-2-
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9.
Replace the missing decontamination supplies in tlie gurbine building'
facility and supply Genoa-1 with the needed equipment. - (Section 4.1,.2.'3)
10.
Make provisions at the Genoa-1 facility for collecting solid aad liquid wastes.
(Section 4.1.2.3)
c 11.
Develop a QA program far maintenance and operability checks df emeraency '
communications equipment and associated supplies such as batteries and antennas.
(Section 4.2.3)
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12.
Provide a cupply of replacement protective clothing at. the Genoa-1 assembly area and the LACBWR Turbine Building Facility.
(Section 4.1.2.3)
13.
A letter of agr:eoent ebould be developed with the State of Wisconsin stating concept of operations, limits of authority _and responsibility of the Joint Public Information Center.
(Section 4.1.4)'
14.
Letters of agreement should be developed with:
the telephone company,that
'
supplies the telephone units at the JPIC; the vendor which supplies the copying machines at the JPIC; the vendor from whom the P.A. system will be s
rented; and the vendor from whom the audio-visual equipment will be rented.
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(Section 4.1.4)
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15.
Provide a dedicated transportation system for survey teams and a
[
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control system to ensure availabiltiy of emergency vehicle keys.
]
(Section 4.2.6)
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Procedures should be written establishing methods for obtaining additional
'c equipment during an emergency.
(Section 4.2.4)
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17.
Provide a means of protecting emergency equipment on the emergenc'y~
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j-vehicle from the elements during inclement weather.
(Section 4.2.6).'
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18.
Theemergencyplanimplementingproceduresshouldcontainexbmplesof
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messages and announcements that will be used during an emergency.
(Section 5.4.1)
19.
A method for verifying messages from LACBWR to offsite agencies should,
.,
be included in the emergency procedures.
(Section 5.4.1)
20.
Develop pre printed survey forms for offsite, onsite and inplant radig
.
logical surveys to assist survey teams and provide recorded data for the
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organizational element performing assessment.
(Sections 5.4.2.1, 5.4.2.2 -
and 5.4.2.3).
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Evacuation routes from the site should be clearly marked to permit rapia '
s and safe facility egress.
(Sectio. 5.4.3.2).
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EPP-2'4houli!'beaodified to state specifically the responsibilities of
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the sde'urity,fo'ree' y5bgr during an emergency.
(Section 5.4.3.3)
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5 23.' ' U[ grade hhe trairycg progrcm to include student performance objectives as d hsMs ;on expel nce with equipment to be used in en emergency.
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[* ( 24.\\(d.'coltaminationleve IUP-L slpuld h' modified,to. incorporate:
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I tht require decontamination for both personnel
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z, aA equipment.
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b. ) J.iction levels that require further assessment.
s
@ ho is responsible for perfonning followup.
w (Section 5.4.3.3)
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25. Upgrade.EFP-11,e" Emergency First Aid.and Medical Assistance - Contaminated
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Patienty to contain information for decisica making regarding when offsite
treatmntragitieswillbeused.
(Section 5,.4.3.5)
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ModiIy5.P(-i>,;YEmergencyFirstAidandMedicalAssistance-Contaminated (, win be. e portsibleihdwnent \\[9 state that LACBWR Health and Safety pers Pa nent,"
or ligiting the exposure of hospital personnel and
,
desgig1,ivosemethodstob{usedforlimitingpersonnelexposure.
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Establieh' decision makihg pa'cometers for emergency rescue.
(Section 5.4.3.5).
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13., %<.eddces.should be arktten ddfining,the functions and responsibilities
[,' ',br +G spokesperson with regard te the nus medic, inquiries from private
. [\\ 4 f ahd rumor centro;!' ' (Sectic.n 5 < 4.7).
)
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(. 29. 'tforifd the provision ' fir qdating the emergency plan to an annual require-i s
E;,
r.,enp:
/.Sec'. for 5.5.3). E
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'!JC,, Pro 7depasicradioactivityn,essu-3g devices as well as film badges and f
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'q dasimeters to the U.S. Coast Juard, Tvin Cities District Office, St. Paul,
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Minwsota.
(Section 6.1).
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' ' s 31. ' instituty progra'm of training followup to include a periodic, (e.g.,
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, weekly) waihtbrough use of the EPP's for hypothetical emergency conditions ((scenarios). to mgintain proficiency in use of the EPP's.
(Section 7.2).
32.
Spec l.fy 'formdily the assigned responsibilities of LACBWR personnel respoipible for emergency planning and c6 ordination.
(Section 1.0)
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33; Dpveloli 4 'f omledocument, describing the authority, responsibilities and interaction \\between site and corporate-individuals regarding
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emergency' prep redness.
(Section 1.0)
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Appendix C-4-g-
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34.
"
Develop and ; formalize selection and qualification criteria for in-dividuals with emergency preparedness responsibilities.
(Section 1.0)
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35. Establish and implement a training program for prefeasional develop-annt of personnel responsible for emergency planning and (oordination t'o ensure they maintain their state of the art knowledge in emergency preparedness.
(Section 1.0)
36. Develop recovery and re-entry procedures ensuing that the following tasks are addressed; duties and responsiblities of personnel involved are defined, criteria established for recovery and re-entry are developed, and notification of appropriate organization are conducted.
37.
Establish selection and qualification criteria for an Emergency Preparedness Coordinator und ensure that this individual is properly trained.
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i Appendix D The following findings are given as a re.sult of a review of the Lacrosse Boiling Water Reactor Emergency Plan, dated March 31, 1981.
LACROSSE
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ASSIGNMENT OF RESPONSIBILITY (0RGANI g QC E L CONTROL)
Planning Standard Primary responsibilities for emergency response by the nuelear facility licensee, and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically estat-lished, and each principal response organization has staff to respond and to auFeent its initial response on a 00utinuous basis.
Synopsis:
The Federal, State, local and private sector organizations that are
.
intended to be part of the overall response organization for Emergency Planning Zones are identified. The roles of the States of Wisccasin, Minnesota and Iowa are described, and references are made to the re-spective State plans. The rssponsibilities of local Vernon County, Wisconsin agencies are sucaadzed. Federal support from the U.S. Army
Corps of Engineers, the U.S. Coast Guard and NRC is described. Worticg relationships with other organizations are listed, iucluding Nuclear
Energy Services, Inc., Southwest Research Institute, Wyle Laboratories, Inc., Dames & Moore, Inc., and the University of Wisconsin.
The interrelationships among emergency organizations are illustrated in
.
.
a block diagram (Figure 5.2).
The Emergency Control Director (Shift Supervisor until relieved by the
.
Plant Superintendent) is identified as the individual who shall be in charge of the emergency response.
24-hour per day emergency response, including 24-hour per day manning of
.
communications links, is provided.
Evaluation: The plan does not satisfy Planning Scandard A; problem areas are noted.
(409/81-13-41)
Criterion 1: The licensee's concept of operations is not fully and clearly specified.
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Appendix D-2-A.
ASSIGNMENT OF RESPONSIBILITY (ORGANIZATION CONTROL)-(Cont.)
p Criterion 3: No written agreements are appended to the plan. The contents of
those agreements therefore cannot be evaluated.
As. indicated in the plan, ogreements are currently being revised and updated letters of agreement wt31 be included in the plan at a later date.
Criteriog_d: No indiv Na1 responsible for assuring continuity of resources iu specitied.
i B.
ONSITE EMERGENCY ORGANIZATION Planning Standard i
On-shift facility licensee responsibilities for emergency response are un-ambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is ruintained at all times, timely augmentation of response capabilities is availabir, and the interfaces among various onsite response activities and offsite support and response activities are specified.
'
Synopsis:
The Emergency Control Director is designated as the individual with the
.
authority to direct and coordinate emergency actions.
A line of sucession for the Emergency Control Director is identified.
.
The functional responsibilities arsigned to the Emergency Control Director
.
are established. The Emergency Control Director may not delegate his re-sponsibility for recommending protective actions to outside agencies.
,
The interfaces between and among the onsite functional areas of emergency
.
activity, licensee headquarters support, local services support, and State and local government response organizations are specified (Figures 3.1 and 5.2).
The corporate management, administrative and technical support personnel
.
who will augment the plant staff in the areas of logistical and technical support are given.
.
Several organizations are listed that may be request.cd to providr technical
.
assistance to and augmentation of the emergency organization, iceluding Nuclear Energy Services, fr.c., Sordhwest Research Institute, ' yle Labora-w
,
tories, Inc., Dames and Moore, Jnc., and.he University of Wisconsin.
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Appendix D-3-B.
ONSITE EMERGENCY ORGANIZATION (Cont.)
The services to be provided by local agencies for handling emergencies,
.
including fire-fighting and medical services, are identified.
Evaluation:
The plan does not satisfy Planning Standard B; problem areas are noted.
(409/81-13-42)
Criterion 1:
the relations between all shifts of normal staff and the emergency orga mi ation are not specified.
Criterion 3: Th.: 3pecific conditions under which higher level officials will assume the position of Emergency Control Director are not specified.
Criterion 5: The staffirg levels described by the licensee [Iable 5.1) bear little relation to those required (Table B-1).
Reasons for the discrepancies are provided by the licensee in the cover letter dated April 2,1981.
Criterion 9:
Copies of the arrangements and agreements reached with contractor, private and local support agencies are not appended to the plan. Thergfore, no eva'.uation can be made.
C.
EMERGENCY RESPONSE SUPPORT AND RESOURCES
Planning 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 capable of augmenting the planned response have been identified.
Synopsis:
The Emergency Control Director is authorized to request Federal assistance.
.
The Federal Government can supply a Radiological Response Team to the EOF
.
within two hours of notification.
The Emergency Operations Facility is provided by the licensee to support
.
the Federal response.
The Emergency Control Director shall dec'.gnate any dispatch of requested
.
individuals to support government emergency response facilitie Appendix D-4-C.
EMERGENCY RESPONSE SUPPORT AND RESOURCES (Cont.)
Radiological laboratories, their general capabilities and expected avail-
.
ability are identified at the University of Wisconsin-IaCrosse Nuclear Radiation Center and at the Dairyland Power Cooperative Service Center Building in Lacrosse.
Organizations which can be relied upon in an emergency to provide
.
assistance, including fire-fighting, medical and radiation management capabilities, are identified.
'
Evaluation: The plan satisfies the planning standard except as noted.
(409/81-13-43)
Criterion 4: No letters of agreement are appended to the plan.
.
D.
EMERGENCY CLASSIFICATION SYSTEM Planning 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.
Synopsis:
An emergency c!nssification systes and action level scheme compatible with
.
that in Appendix 1, NUREG-0654 Revision 1 has been established.
Parameter values and/or equipment status is identified for each emergency
.
class.
Example initiating conditions except as noted have have been addressed.
.
Evaluation: The plan satisfies the planning standard except as noted.
(400/81-13-44)
Criterion 1: The plan fails to indicate if specific instruments, parameters on equipment status used to establish each emergency class are in the plant emergency procedures.
.
Criterion 2-The postulated accidents in the plant FSAR are not discussed. The example initiating conditions in Appendix 1, NUREG-0654 Revision I have been addressed except as follows:
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Appendix D-5-D.
EMERGENCY CLASSIFICAT10N SYSTEM (Cont.)
Unusual Event:
13 b and 1 Alert:
9 and 19 Site Area:
6 and 17 General Emergency: 4 and 6a, c, d.
Licensee Actions for Notification of Unusual Events do not contain
.
provisions for prompt notification of state and local authorities nor are there provisions for close out of the condition.
Licensee Actions for the Alert Conditions does not include the specific
.
time interval for updating information to offsite agencies.
The licensee actions do not provide for an individual dedicated to provide
.
plant status updates to offsite authorities and periodic press briefings in either Site Area or General Emergency actions.
E.
NOTIFICATION METHODS AND PROCEDURES Planning Standard Procedures 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 instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established.
Synopsis:
Procedures are established which describe mutually agreeable bases for
.
notification of response organizations consistent with the emergency classification and action IcVel scheme.
Evaluation: For Criteria 1, 2, 3, 4, 6 and 7, the plan does not satisfy Planning Standard E; problem areas are noted.
(409/81-13-45)
Criterion 1: Means for verification of messages are not provided.
Criterion 2: Procedures for alerting, notifying and mobilizing emergency response personnel are not described.
Criterion 3: The contents of initial emergency messages to be sent from the plant are nct describe Appendix D-6-E.
NOTIFICATION METHODS AND PROCEDURES (Cont.)
Criterion 4: The contents of followup messages from the facility to offsite authorities are not described.
Criterion 6: The plan does not indicate that an Early Warning System meeting the design objectives of Appendix 3 of the criteria has been developed. The p'on should address the administrative and physical means, and the time required t promptly notify the public of an emergency. The plan should commit to the establishment of sucn a system and indicate when the system will be implemented.
Criterion 7: The plan does not provide predetermined written messages intended for the public which are consistent with the operator's classification scheme.
These messages should provide clear instructions to the public with regard to specific protective actions to be taken (e.g., sheltering, evacuation, or thyroid blocking).
F.
EMERGENCY COMMUNICATIONS Planning Standard Provisions exist for prompt communications among principal response organizations to emergency personnel and to the public.
Synopsis:
The organizationel titles and alternates for both ends of the communication
.
links are included in the plan's implementing procedures.
24-hour notification to and activation of the State / local emergency response
.
network are provided.
Communications with contiguous State / local governments within the EPZ's are
.
provided.
/
Communications as needed with Federal Emergency response organizations are
.
provided.
Communications between the nuclear facility and the EOF, State and Iceal
.
E0C's and radiological monitoring teams are provided.
Alerting or activating of emergency personnel is provided.
.
Communication by licensee with NRC Headquarters and NRC Regional Office
.
E0C's is provide Appendix D-7-F.
EMERGENCY COMMUNICATIONS (Cont.)
A coordinated link for fixed and mobile medical support facilities exists.
.
Periodic testing of communications systems are provided.
.
Evaluation: The plan satisfies Planning Standard F.
G.
PUBLIC EDUCATION AND INFORMATION Planning 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 informa-tion during an emergency (including the physical location or locations) are established in advance, and procedures for coordinated dissemination of information to the public are established.
Synopsis:
A public information brochure containing the required information will be
.
distributed annually.
The public information program provides the permanent and transient adult
.
population within the plume exposure EPZ an adequate opportunity to become aware of the information annually.
Points of contact and physical locations for use by news media during an
.
emergency are designated.
The EOF will accomiaodate approximately 20 members of a press pool.
.
,
The designated spokespersons are the director of information and marketing
.
and the public information director.
Arrangements for timely exchange of information among designated spokes-
.
persons are under development.
Coordinated arrangements for dealing with rumors are established,
.
Annual information program designed to acquaint the news media with
,
.
emergency plans and procedures has been initiated.
Evaluation: The plan satisfies Planning Standard G.
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Appendix D-8-
'
H.
EMERGENCY FACILITIES AND EQUIPMENT Planning Standard Adequate emergency facilities and equipment to support the emergency response are provided and maintained.
Synopsis A Technical Support Center (TSC) has been established in the office area
.
adjacent to the control room. Drawings, procedures and safety anaysis reports are accessibic.
The plan infers that an Operational Support Center (OSC) is to be
.
established at the Genoa-1 office and lunch room area.
An Emergency Operations Facility (EOF) will be established at the company
.
office at Lacrosse and will be provided with up-to-date procedures and emergency planning material. Field monitoring results will also be coordinated through this facility.
The use of onsite radiologica.! monitors such as process, area, emergency,
.
effluent, portable and sampling systems; and fire and combustion detectors are discussed.
Arrangements have been made with the University of Wisconsin-Lacrosse for
.
offsite laboratory facilities.
In addition, the company facilities at Lacrosse will also be available.
Instruments / equipment are inspected, inventoried and operationally checked
.
on a quarterly basis and after each use.
Calibrations are performed at supplier recommended intervals.
Onsite meteorological systems including barometric pressure, temperature,
.
wind speed and direction and relative humidity have been established.
Arrangements have been made to obtain offsite meterological and hydrologic
.
,
data from Lock and Dam Number 8 about one mile north of the plant site.
Meteorological data can also be obtained from the U.S. Weather Bureau at
'
the Lacrosse airport about 20 miles north of the plant.
Evaluation: The plan fails to satisfy the planning standard for the following reasons:
(409/81-13-46)
The plan infers that an OSC is to be established out fails to inditate if
.
a temporary OSC is currently in place.
In addition, the licensee does not state when the permanent facility will be available, if it will have sufficient capacity to handle onsite emergency workers and if it will comply with the design criteria expressed in NUREG-0696.
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Appendix D-9-H.
EMERGENCY FACILITIES AND EQUIPMENT (Cont.)
The plan does not indicate if the TSC meets the design criteria expressed
.
in NUREG-0696.
The plan states that an EOF will be established but fails to state if a
.
temporary EOF is currently in place.
In addition, the licensee does not indicate when the permanent EOF will be available, the location of the EOF in relation to the plant site (i.e., distance and direction) and if the facility will meet the design criteria expressed in NUREG-0696.
Sections 4.1 and 4.2 infer that emergency facilities will be activated
.
and staffed in a timely manner. However, there is no indication of how soon this will be accomplished.
Onsite hydrologic and scismic equipment, radiological monitor
'or wounds
.
and process monitors in general are not discussed.
There is no indication if arrangements have been made to secure seismic
.
data from offsite sources.
Although offsite radiological monitors including ratemeters and sampling
.
devices are discussed, the plan does not indicate if the dosimetry provided meets, as a minimum, the NRC Radiological Assessment Branch Technical Position for the Environmental Radiological Monitoring Program.
There appears to be some confusion regarding provision for offsite radio-
.
logical monitoring in the vicinity of the facility. The licensee in Section 7.3.2.1 describes the offsite radiological monitoring program instead of indicating that emergency radiological monitoring equipment, available to field monitoring teams is available at a location in the vicinity of the plant (c.f., Criterion 7).
The licensee in Section 7.6 discusses release dose. assessment capability
~
.
indicating that equipment to provide this capability is being installed using data from ensite sources (i.e., the facility stack and 10 meter tower) and the 27 meter tower located 1.95 miles ESE of the plant. The licensee fails to state when installation will be completed, when data will be available and if these data and accompanying procedures will satisfy the criteria in Appendix 2, NUREG-0654 Revision 1.
Section 7.1.3 states that personnel assigned to the OSC will be issued
.
protective equipment prior to entering the facility and that no equipment will be stored at the OSC.
It would be helpful if the licensee indicated where emergency and protective equipment is located and/or stored in relation to the OSC. The locations should be reasonably accessible to the OS.
Appendix D
- 10 -
H.
EMERGENCY FACILITIES AND EQUIPMENT (Cont.)
The plan appendix does not contain a list giving the identification of
.
emergency kits by general category.
The plaa does not indicate that the EOF will receive and analyze all
.
field monitoring data.
I.
ACCIDENT ASSESSMENT Planning Standard Adequate methods, systems and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in u;e.
Synopsis _
The licensee identifies plant system and effluent parameter values
.
characteristic of off normal conditons and identifies parameter values or plant status corresponding to example initiating conditions in Appendix 1, NUREG-0654 Revision 1.
Onsite capability and resources to provide initial value and continuing
.
assessment including radiation and effluent monitors and containment radiation monitoring in accordance with NUREG-0578 is briefly discussed.
The licensee currently has the capability to assess potential releases
.
using manual calculations based on meteorological data available in the control room from the stack instrumentation and the source term.
The licensee indicates that a computer calculational model as being
.
developed using meteorological data from available sources to calculate plume EPZ exposures.
ThecapabilityandresourcesforprovidingfieldmonitorjnginthePlume
.
EPZ and the ability to measure radioiodine as low as 10 Ci/cc under field conditions is discussed.
Evaluation: The plan fails to satisfy the planning standard for the following reasons:
(409/81-13-47)
Although the plan identifies plant system and effluent parameter values
.
characteristic of off normal conditions there is no indication that parameter values and corresponding emergency class is included in the facility emergency procedures. Neither is there indication that the emergency procedures.will specify the kinds of instrument used and their capabilities.
,
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.
.
.
Appendix D
- 11 -
I.
ACCIDENT ASSESSMENT (Cont.)
The capability and resources to provide initial values and provide
.
continuing assessment of in plant radiciodine is not addressed.
The plan states that determination will be made of the source term for.
.
releases of radioactive materials within plant systems, and the magnitude of the release of radioactive materials. However, the plan fails to address ; methods and techniques used for making such determinations and strtes only that they are in the emergency plan procedures.
The plan fails to discuss the relationship between effluent monitor
.
readings and onsite and offsite exposures and contamination for various meteorological conditions, stating only that relationship is provided in the emergency plan procedures.
The plan infers that the plant does not currently have the capability to
.
provide meteorological data to the TSC, EOF, NRC/ state and local agencies, but will have as soon as computer services are installed. No installation date is given.
The plan does not indicate how the release rate / projected dose will be
.
determined if assessment instrumentation is inoperable or off scale. The plan states only that alternate approaches are contained in the emergency plan procedures.
The plan fails to discuss the methods, equipment and expertise required to
.
make r.ipid assessment of actual or potential effluent releases, including activation, notification means, field team compostion, tranportation, communication, monitoring equipment and estimated deployment times.
The plan fails to specifically establish the means for relating various
.
measured parameters to dose rates for the key isotopes listed in Table 3, page 18, KUREG-0654 Revision 1.
.
The plan does not address provisions for estimating in.tegrated dose from projected and actual dose rates and for comparing the estimates with protective action guides, or indicate if detailed provisions are described in separate procedures.
'
J.
PROTECTIVE RESPONSE Planning 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 protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective
_
Appendix D
- 12 -
>
J.
PROTECTIVE RESPONSE (Cont.)
actions for the ingestion exposure pathway EPZ appropriate to the locale have been developed.
Synopsis The licensee has established the means to warn onsite individuals of an
.
emergency and provides evacuation routes to offsite locations including alternatives for inclement weather.
,
Evacuation of onsite non-essential personnel is provided in case of a Site
.
Area of General Emergency. Radiological monitoring for contamination and decontamination is available at the essembly area.
Thyroid blocking agents are available for distribution to onsite emergency
.
workers if required.
Time estimates for evacuation within the Plume EPZ are given in Table 6.1.
.
The plan includes maps showing onsite evacuation and offsite evacuation
.
routes (Figure 6.1 and 6.3); radiological sampling and monitoring points (Figure 6.4) including designators; and a map showing population dis-tribution around the plant site (Figure 6.2).
Local protection afforded in residential units or other shelters for direct
.
and inhalation exposure (i.e., shielding factors) are shown in Tables 6.4, 6.5 and 6.6.
The recommended protective actions to reduce whole body and thyroid dose
.
from exposure to a gaseous plume is shown in Table 6.3.
Evaluation: The plan satisfies the planning standard except as noted.
(409/81-13-48)
Criterion 1: The time required to warn or advise onsite individuals is not addressed.
Criterion Id: The means used to and time necessary to warn or advise persons who may be within the licensee's controlled area but outside the protected are not addressed.
Criterion 4: The plan does not indicate if the licensee has transportation.
available to evacuate onsite individuals who have no other means of transporta-tion. The plan does not adequately cover assembly area, in that an alternate assembly area to Genoa-1 will be needed for adverse wind directions.
Criterion 5: The plan does not indicate if personnel accountability can be accomplished within the 30 minute time limit.
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Appendix D
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J.
PROTECTIVE RESPONSE (Cont.)
Criteria 6a, b and_c: Adequate description of provisions for individual re-spiratory protection, use of protective clothing, and radioprotective drugs is not given in the plan.
Criterion 7: The plan does not adequately discuss the subject matter required by Criteria 7, specifically, prompt notification of population within the five mile EPZ is not covered.
Criterion 10a: The plan does not provide maps showing evacuation routes, sectors, relocation centers in host areas, hospitals and other medical facilities. These maps should follow the format of Table 2-1 of the criteria.
Criterion 10b: Figure 6.2 does not indicate evacuation with designated sector fo rma t.
Criterion 10c: The plan does not provide a means for notifying all segments of the transient and resident population.
.
K.
RADIOLOGICAL EXPOSURE CONTROL Planning Standard Means for controlling radiological exposures, in an emergency, are estublished for emergency workers. The means for controlling radiological exposures shall include exposure guidelines consistent with EPA Emergency Worker and Lifesaving
,
Activity Protective Action Guides.
Synopsis
Onsite exposure guidelines consistent with EPA Protective Actions Guides
.
(520/1.75/001) have been established for lifesaving activities, corrective and assessment actions, first aid, ambulance and medical services and personnel decontamination.
The plan identifies the plant superintendent / emergency director as having
.
the non-deiegatable responsibility for approving radiation exposure to emergency volunteer workers in excess of 10 CFR 20 exposure limits.
The means necessary to provide radiological decontamination of emergency
.
personnel, supplies, instruments and equipment and for waste disposal have been establishe.--. -.. - -.
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Appendix D
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K.
RADIOLOGICAL EXPOSURE CONTROL (Cont.)
Onsite contamination measure for area access control, drinking water and
.
food supplies have been established.
The capability to decontaminate relocated onsite personnel, including
.
provisions for extra clothing has been provided.
Evaluation: The plan satisfies the planning standard except as noted.
(409/81-13-49)
Criterion 3a and b: The plan fails to indicate if the licensee has the capability to issue dosimeters to emergency workers and determine the doses received by them on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day basis. The plan also does not indicate if dosimeters will be read at appropriate frequencies (e.g., each shift) or if provisions have been made to maintain dose records for emergency workers on a continuing basis.
Criterion Sa: The plan does not specify the action levels for determining when decontamination is required.
Criterion Sb: The plan does not adequately address the means for decontamina-tion of emergency personnel wounds, supplies,- instrements and equipment, and for waste disposal.
Criterion 6a: The plan does not adequately address onsite contamination control measures namely, area access control, drinking water and food supplies, and criteria for permitting return of areas and items to normal use.
L.
MEDICAL AND PUBLIC HEALTH SUPPORT Planning Standard Arrangements are made for medical services for contaminated injured individnals.
Synopsis:
Arrangements for hospital and medical services have been made with the
.
Lacrosse Lutheran Hospital and St. Francis Hospital in Lacrosse.
.
Onsite first aid capability is provided.
Arrangements have been made with the Tri-State Ambulance Service of LaCrnsse for transporting victims of radiological accidents to medical support facilities.
Evaluation: The plan satisfies the planning ctandard except as noted.
(409/81-13-50)
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Appendix n
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L.
HEDICAL AND PUBLIC HEALTH SUPPORT Criterion 1 and Criterion 4: No letter of agreement describing the facilities and capabilities is appended for Lacrosse Lutheran Hospital, St. Francis Hospital or Tri-State Ambulance Service. The adequacy of the medical support thus cannot.
be evaluated.
M.
RECOVER AND RE-Mjp!Y PLANNING AND POST-ACCIDENT OPERATIONS Planning Standard General plans for recovery and reentry are developed.
Synopsis:
General plans and procedures icr reentry and recevery are developed and
.
the means are described by waich decisions to relax protect'.ve measures are reached.
The structure, functions and membership of the facility recovery
.
organization are described.
A method for periodically estimating total population exposure is
.
established.
Evaluation: The plan satisfies the planning standard except as noted.
(409/81-13-51)
Criterion 3: No means for informing nembers of response organizations that a recovery operation is to be initiated are specified.
N.
EXERCISES AND DRILIS Planning 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.
Synopsis:
The annual emergency preparedness exercise si.all simulate an emergency that
.
would require response by offsite authorities.
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Appendix D
- 16 -
f{.
EXERCISES AND DRILLS (Con _tj A joint exercise to involve mobilization of state and local personnel and
.
resources is provided.
The scent.rios of the exercises are varied from year to year such that
.
all major elements fof the Emergency Response Plan are elevated every five 3 ears. Additionally, exercises are conde ted under various weather conditions, at differing tines of day, and some are unannounced.
Required comeanication drills are provided.
.
Fire drills shall be conducted in accordan:e with ACP-21.4.
.
Required medical drills are provided.
.
Required radiological monitoring dtills are provided.
-
.
Semi-annual health physics drills whcih involve response to, and analysis
.
of, simulated elevated airborne and liquid samples and direct radiation measurements in the environment will be conducted.
The scenarios for use in exercises and drills include the required information.
A critique by government observers, resulting in a formal evaluation, is
.
provided.
Evaluation: The plan satisfies the planning standard except as noted.
(409/81-13-52)
Criterion 2: No provision is made for analysis of inplant liquid samples including use of the pott-accident sampling system.
Criterion 5: No means are established for utilizing the results of the exercise critique.
O.
RADIOLOGICtL ErfERGENCY RESPONSE TRAINING Planning Standard Radiological emergeprv response training is provided to those uho may be l
called or. te -ssist is an emergency.
Synopsis:
Training for specific offsite response organizations who will be called
.
upon for assistance (i.e., police, fire, ambulance / rescue) will be provided.
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Appendix D
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O.
RADIOLOGICAL EMERGENCY RESPONSE TRAINING Training of members of the onsite emergency organizations will consist of
.
lectu.es, discussions and practical drills. Erroneous performance during drills will be corrected on the spot.
Individuals trained in first aid will have the training equal or equivalent
.
to the Red Cross Multi-Media course.
Training programs lor instructing and qualifying personnel who will
.
implement radiological emergency response training plans have been established, including initial and annual re-training of personnel with emergency response responsibilities.
Evaluation: The plan satifies the planning standard except as noted.
(409/81-13-53)
Criterion 1: The plan does not indicate if training, for those response organizations who will enter the site, will include site access procedures and the identity, by title and position, of the individual in the onsite organization who will control the support organization activities.
P.
RESPONSIBILITY.FOR THE PLANNING EFFORT:
DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION 02 EMERGENCY PLANS Planning Standard Responsibilities for plan development and review and for distribution of emergency plans are established, and planners are properly trained.
Synopsis:
I The Emergency Planning Coordinator shall receive training in plan
.
i-development as required.
The Health and Safety Supervisor will be responsible for keeping the Emer-
.
gency Plan up-to-date and is designated the Emergeacy Planning Coordinator.
If review indicates that changes are required to the Emergency Plan,
.
procedures set forth in the Emcagency Plan Proedures will be followed.
Changes to the Emergency Plan and Preparedness Procedures will be furnished
.
to groups and individuals assigned responsibilities for ieplementation of the plans and procedures. Revised pages shall be dated and marked by a line in the right-hand margin to show where changes have been made.
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Appendix D 18 -
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P.
RESPONSIBILITY FOR THE PLANNING EFFORT:
DEVELOPMENT, PERTODIC RrVIEW AND DISTRIBUTION OF EMERGENCY PLAN (Cont.)
Support plans are listed.
.
Emergency Plan Procedures are listed.
.
A table of contents is provided.
.
An independent audit of the emergency preparedness prograis will be conducted
.
at least every 12 months.
The telephone numbers in the Emergency Plan Procedures will be updated
.
quarterly.
Evaluation: The plan satisfies the planning standard except as noted.
(409/81-13-54)
Criterion 2: No individual with overall authority and responsibility for radiclogical emergency response planning is identified.
Criterion 7: The Emergency Plan Procedures list does not include the section(s)
of the p'.an to be implemented by each procedure.
Criterion 8: The plan's cross-reference to NUREG-0654 is inaccurate and should be revised.
._
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Appendix E OPEN ITEMS LIST 1.
Adequate commui.ications and ventilation controls were not available in the TSC in accordance with NUREG-0696. This is to be accomplished by October 1, 1982.
(Section 4.1.1.2) (409/81-13-30)
2.
Data display (SPDS and A.her RG 1.97 parameters) were not made availabic to TSC personnel.
(Section 4.1.1.2) (409/81-13-31)
3.
A complete description of the onsite meteorological measurements program to be used in the facility including the location and orienhtion of all sensors, sensor specifications, calibration and maintenance procedures, operability checks, dat a reduction techniques, and data displays has not been provided.
(Section 4.2.1.4) (409/8!-13-32)
4.
The Control Room ventilation system has not been modified to permit Control Room habitability under accident conditions.
(Section 4.1.1.1)
(409/81-13-33)
5.
A complete post-accident primary coolant and containment air sampling system needs to be ins.alled, tested and procedurcs developed by January 1, 1982.
(Section 4.1.1.5 and 4.1.1.6) (409/81-13-34)
p 6.
A complete post-accident effluent analyses and sampling system needs to be installed, tasted and procedures devele. ped as per NUREG-0737.
(Section 4.1.1.8) (409/81-13-38)
7.
Operation and calabration of the SPING-4 monitors has not been completed.
(Section 4.2.1.3) (409/81-13-39)
8.
Operational procedures for the high range containment radiation monitors
,
have not been completed.
(Section 4.2.1.3) (409/81-13-40)