ML17319A552

Transmits Concerns & Questions Re Intent & Use of Health Physics Network.Nrc Will Receive Info from Plant Members W/O Knowledge of Plant Mgt.Questions How NRC Intends to Test Network to Ensure Reliability & Functionability

ML17319A552
Person / Time
Site:	Cook
Issue date:	07/23/1980
From:	Hunter R INDIANA MICHIGAN POWER CO.
To:	Davis A, Essig T, James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML17319A551	List: ML17319A552
References
AEP:NRC:0393B, AEP:NRC:393B, NUDOCS 8008270246
Download: ML17319A552 (4)

Text

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INDIANA 5 MICHIGAN ELECTRIC CONPANY P. O. BOX 18 BO WLIN G GR E EN STATION NEW YORK, N. Y. 10004 July 23, 1980 AEP:NRC:0393B Donald C. Cook. Nuclear Plant Unit Nos. 1 and'2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 Mr. J. G. Keppler, Regional Director U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II'I 799 Roosevelt Road Glen Ellyn, Illinois 60137 Ref: Region III Letters to AEPSC dated: May 22, 1979 June 22, 1979 March 20, 1980 April 18, 1980 Attention: T. Essig and A. B. Davis

Dear Mr. Keppler:

This letter serves to transmit to you our concerns and questions regarding the intent and use of the Health Physics Network (HPN) during an emergency at the Donald C. Cook Nuclear Plant. Our concerns are:

1. The purpose and use of the HPN in the above-referenced letters is contradictory. The NRC, through its communication with us, has not established specific and consistent procedures for the use of this network. We suggest that you consolidate these letters into one procedure after you have reviewed the remainder of our comments.

2. How the NRC intends to confirm that accurate information is being relayed has not been established or communicated to AEP. If this concern is not resolved, it appears that this second emergency communications network could serve as a point of confusion if conflicting information is given over this network versus the Emergency Notification System (ENS). Operating on a duplicate mode such as this could very well cause confusion.

60OSRV92 JULY 81s80

Mr. J. G. Keppler AEP'NRC;0393B

3. Your letter of February 20, 1980, states that the HPN is to be used during "an abnormal occurrence" as well as for the "routine transmission of information requested by the NRC".

It is our concern that the NRC will be getting information from Plant members without the knowledge of the Plant Management. This is quite plausible, since the HPN has extensions presently located in the Radiation Protection Supervisor's office, in the Emergency Assembly area in the basement of the office building and one in the NRC Resident Inspector's office.

The same holds true during the routine transmission of information between the NRC and the Plant. There is again, the possibility that information from the NRC may be transmitted without Management being aware of jt. While we can take steps on'our part to prevent this unauthorized communication, this concern once again shows that a clari-fying procedure is needed from you, so that all parties are aware of the proper usage of,these telephones.

4. In your letter of April 18, 1980, itwill was stated that activate the "in the event of a site emergency, the NRC HPN...

The HPN is a restricted'network and may not"be used by non-government employees at any time unless;.. a significant event and both the'ENS and commercial telephone lines are out of service". 'Your letter of March 20, 1980 transmitted to us a System Description'which contained information contrary to these directions. Clarification as to who is permitted to activate the HPN is therefore needed.

5. The locations of the Health Physics Network at any facility and the specific requirements for our facility are not clear. The NRC should consider integrating the HPN with the emergency'operating centers (TSC, EOF, etc.}.

"6. How does the NRC intend to test the HPN to ensure its reliability and functionability?

7. If the primary function of the HP telephone is to support it is Health Physics operations during a nuclear incident, our opinion that the telephones should not be used for the routine transmission"of information requested by the Commission or facsimile traffic.

Very truly yours, cc; Attached'. S. Hunter Vice President

Nr. J. G. Keppler AEP;NRC;03938 l

CC: R. C. Callen G. Charnoff R. W. Jurgensen D. V. Shaller - Bridgman John E. Dolan

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