ML19323J090
| ML19323J090 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 04/18/1980 |
| From: | Moore G FLORIDA POWER CORP. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19312E843 | List: |
| References | |
| CS-80-118, NUDOCS 8006170760 | |
| Download: ML19323J090 (3) | |
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Power CO R Po n a i tone 18 April 1980 3-0-3-a-2 CS-80-118 Mr. J. P. O'Reilly, Director Docket No. 50-302 Office of Inspection & Enforcement License No. DPR-72 U.S. Nuclear Regulatory Conmission Reg:
RII:DRQ 101 Marietta St., Suite 3100 50-302/80-14 Atlanta, GA 30303 D' ear Mr. O'Reilly:
We offer the following response to the apparent Item of Noncom-pliance in the referenced inspection report.
NOTICE OF VIOLATION Technical Specification 6.8.1.e states " Written procedures shall be established, implemented and maintained covering the activities referenced below... Emergency Plan Implementa-tion":
Emergency Prou:hre EM-207, Section 7.2.2 states
" Notification for a Class "B"
emergency... Call the State Duty Warning Officer via National Warning System (NAWAS) at
" State Warning Point Tallahassee" and notify him of the in-cident, utilizing Appendix "A" (enclosure) and the attached Radiological Accident Reporting Form".
Emergency Procedure EM-206, Sections 3.1 and 3.2 state "Each Section Head will inform the Nuclear Plant Manager's secretary within one (1) week of known changes in his personnel when such changes affect the Emergency Plan personnel or telephone numbers.
These changes will be made as " housekeeping changes" and will be distributed within five (5) working days of their receipt by the secretary to holders of " working" copies of EM-206".
Contrary to the above:
1.
On February 26, at 3:17 p.m., the plant manager did not follow EM-207 and notify the State of Florida of the Class "B" emergency by NAWAS.
8006170 M r6 e m General Office 3201 inirty-fourtn street soutn. P O Box 14042. st Petersburg. Fionda 33733 e513'--866-5151
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Notice of Violation Ref: RII:DRQ Page 2 2.
On February 26, and March 6, the Control Room working copy of EM-206 did not list Mr. Dan Poole, Plant Man-ager and his telephone number, although he had been plant manager for over two (2) months.
Response: 1)
The conditions in the Control Center during the transient of 26 February 1980 were not conducive tc establishing and maintaining a clear, cpen comunica-tion link with State agencies via NAWAS.
To resolve this concern, an extension of NAWAS wt11 be installed in the temporary Technical Support Center.
It is believed that the installaticn of this extension will help to avoid any possible confusion and congestion during emergency situations and that it will permit clear and concise reporting to appropriate agencies.
Installation of this extension will be completed prior to plant entry into Mode 3.
Response
2)
Emergency Plan Roster and Notification Procedure, EM-206, has been updated to reflect the present status of plant personnei.
As an added measure to maintain effective updated personnel status and to preclude recurrence, a revision to EM-206 will require quarterly review of the roster by appropriate plant supervision.
Implementation of the revision will be prior to 1 May 1980.
With regard to your request to review our Emergency Plan and Pro-cedures, and your concern about the time interval ("2:34 p.m.
when LOCA conditions existed at the Crystal River plant, the Class "B"
emergency was not declared until approximately 3:05 p.m.
and no environmental surveys were performed until 13pproximately 3:40 p.m.")
1.
Florida Power Corporation has performed an extensive review of our Emergency Plan in preparation of our Draft Emergency Plan submitted to NRR for SER on 7 March 1980. This draft was prepared pursuant to Reg.
Guide 1.101, NUREG 0610 and NUREG 0654. The draft sub-mitted contains significant changes in the areas of classification, notification and actions to be taken for plant conditions. When the Emergency Plan has been reviewed and approved, appropriate changes will be made to the Emergency Plan Implementing Procedures.
A com-mitment date for completion of this activity cannot be given due to uncertainties associated with the approval of our submittal by NRR and FEMA's concurrence with the upgraded State and local plans.
i I
t Notice of Violation Ref: RII:DRQ Page 3 2.
While the time intervals stated in your inspection report appear to be excessive from the time LOCA conditions existed until the time of declaration for
" Class B" emergency, the actual conditions required by EM-203, " Classification of Emergencies and Criteria for Evacuation" were never met.
However, after careful consideration of the existing conditions, and those actions which needed to be initiated by the plant staff, the decision was made to declare a " Class B" as an expedient and conservative approach.
The proposed modifications to the Crystal River Unit #3 Emergency Plan referenced in 1) above will provide better clarification of accident conditions and action guidelines to quicken the plant staff response.
3.
The apparent delay in dispatching the Radiation
' y-Monitoring Team stems partly from the disparity in the
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times at which the " Class B" emergency was declared.
Disregarding this disparity between these times for the actual declaration: by 2:30 p.m. continuous monitoring of installed process and area monitoring was being perfomed to assess any potential for, or indication of, leakage from the Reactor Building; at 2:45 p.m.
additional surveys were being perfonned by the Radiation Monitoring Teams inside the Auxiliary Building; at 3:03 p.m.
instructions were given to initiate Reactor Building post LOCA sampling; at 3:17 p.m.
the Environmental Survey Team left the Security Building to conduct environmental surveys; and at 3:50 p.m.
the initial environmental results were reported to the Health / Physics Supervisor.
It is Florida Power Corporation's belief that the time sequences set forth above are both accurate and fully meet the intent of the phrase, "ininediately dispatch Radiation Monitoring Teams...".
Should there be further questions, please contact us.
Very truly yours, FLOR POWER CORPORATION dto. PuA 7
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Oe Nuclear Plant Manager Vice President Power Production GCMemhF04D70 Attach: N/A J