ML20004F889
| ML20004F889 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 06/11/1981 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20004F890 | List: |
| References | |
| NUDOCS 8106260135 | |
| Download: ML20004F889 (16) | |
See also: IR 05000373/1981014
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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GLEN 8tLLYN, ILLINOIS 80137
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June 11, 1981
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Docket No. 50-373
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Docket No. 50-374
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Commonwealth Edison Company
ATTN:
Mr. Cordell Reed
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Vice President
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Post Office Box 767
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Chicago, IL 60690
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Gentlemen:
Subject: Emergency Preparedness Appraisal
To verify that licensees have attained an adequate state of onsite emergency
preparedness as required by 10 CFR 50.47(a)(1), the Office of Inspection and
Enforcement-is conducting special appraisals of the casite emergency pre-
paredness at each operating power reactor site. The objectives of the
appraisal at each facility are to evaluate the overall adequacy and
effectiveness of emergency preparedness and to identify areas of weakness
that need to be strengthened. We will use the findings from these appraisals
as a basis not only for findings against the provisions of 10 CFR 50.'J(a)
and (b)-and for requesting individual licensee action to correct deficiencies
but also for effecting improvements in NRC requirements and guidance.
During the period of April 20 - May 1,1981, the NRC conducted an appraisal
of the state of onsite emergency preparedness for the LaSalle Nuclear
Generating StatSca. Areas examined during this appraisal are described
in the enclosed report (50-373/81-14 and 50-374/81-09). Within these
. areas, the appraisal team reviewed selected procedures and representative
records, inspected emergency facilities and equipment, observed work
practices, and interviewed personnel.
The findings of the emergency preparedness appraisal at the LaSalle
Nuclear Generating Statica indicate that significant findings exist in
several. areas. These are addressed in the enclosed Appendix A.
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These findings are categorized in the form of the planning standards of
10 CFR 50.47(b). In addition.to these significant findings, the staff
found.several areas which need improvement and have indicated ~these in
'
the enclosed Appendix B.
These improvements are areas which we feel,
based on professional judgement, should be corrected. Although these
corrections are not required by.the rule, we strongly urge your staff to
. address them. We will examine your corrective actions on-these matters.
The enclosed Appendix C identifies Open Items relevant to Emergency.
Preparedness wLich will be -reexamined by our staff during subsequent
inspections pr!.or to fuel load.
The' appraisal team concluded that the licensee appeared to be capable of
responding to and managing emergencies of limited scope and duration, but
appropriate corrective action on-the significant findings in Appendix A
is necessary before the licensee could properly respond and manage broad
scope emergencies.
Accordingly, please submit to this office within'30, days of receipt of this
,
letter a committment to resolve and schedule for. correcting the significant
findings of Appendix A.
These findings must be adequately addressed prior
"to licensing. Further, please notify this office relevant to your schedule
,
for re-examination of these findings by our staff.
In'accordance with-10'CFR 2.790 of the Commission's' regulations, a copy.
of this letter, the enclosures, and your response to this letter will be
placed in the NRC's Public Document Room. If the enclosures contain any
information that you or your contractors believe to be. exempt from dis-
l
closure under 10 CFR 9.5(a)(4), it is necessary that you (a) notify this
'
office by telephone within seven (7) days from the date of this letter of
your2 intention to file a request for withholding; and (b) submit within
twenty-five (25) days from the date of this letter a written application
to this' office to withhold such information. Section 2.790(b)(1) requires
l
Ethat any such application must be accompanied by an affidavit executed by
. the: owner of the information which identifies the document or part sought
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to be withheld, and which contains a full statement of the reasons on the
basis which it is claimed that the information should be withheld from
_
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public disclosure. This section further requires the statement to address
with specificity the considerations listed in 10 CFR 2.790(b)(4). The
~information sought to be withheld shall be incorporated as far as possible
into a separate part of the affidavit.
If we do not hear fr>m you in this
- regard within the specified periods noted above, a copy of tais letter,
the enclosures, and your response to this letter will be plated in the
Public Document' Room.
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. We will gladly discuss any questions you have concerning this
-inspection.
Sincerely,
.
James G. Keppler
Director
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Enclosures:
1. ' Appendix A
'2.
Appendix B
3.
Appendix C-
4.-
IE Inspection Reports
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No. 50-373/81-14 and
No. 50-374/81-09
cc w/encls:
J. S. Abel, Director
of Nuclear Licensing -
L.~ J. Burke, Site
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Construction Superintecdent
T. E. Quaka, Quality
Assurance Supervisor
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R. H. Holyoak, Station
Superintendent
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B. B. Stephenson
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Project Manager
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DNB/ Document Control Desk (RIDS)
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Resident Inspector, RIII
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Mary Jo Murray, Office of-
Assistant Attorney General
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Appendix A
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The.following is a list of Significant Findings regarding the LaSalle
Emergency Preparedness Appraisal. These findings are arranged according
to the planning standards of 10 CFR 50.47(b). These fir. dings must be
resolved prior to licensing of the LaSalle Nuclear Station in order for
the onsite ' state of emergency preparedness to provide reasonable assurance
that appropriate protective measures can and will' be taken in the event
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of a radiological emergency.
11.
Planning Standard (b)(2)
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On-Shift facility licensee responsibilities for emergency preparedness-
are unambiguously defined, adequate staffing to provide initial facility
,
accident response in key functional areas is maintained at all times,
timely augmentation of response capability is'available, and the inter .
' face among various.onsite response activities and offsite support
activities are specified.
Deficiencies
Contrary to the above, the following ' eficienci
aere identified:
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Onsite staf' augmentation procedures must be prioritized to
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assure timely staffing of the Technical ~ Support Center (TSC)
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(Section 5.4.1).(373/81-14-01; 374/81-09-01).
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Procedura LZP-1110-1 must'specify the following:
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.(a)' What actions'the Acting' Station Director cannot delegate,
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(b)- evacuation of non-essential personnel for a Site Area or
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General Emergency,
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(c) ' completion of the NARS form prior to notifying System
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Load Dispatcher, and
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-(d) direct Rad / Chem Technicians to conduct appropriate surveys
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and samples (Section 5.3) (373/81-14-02; 374/81-09-02).
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- 2.
-Planning Standa'rd (b)(4)
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A standard emergency classification and act on level scheme, the bases
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of which include facility system and effluent parameters, is in use by
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the nuclear facility licensee, and State and local response plans call
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for reliance on information provided by facility licensees for deter-
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minations of minimum initial offsite response measures.
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Appendix A
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Deficiency
Contrary to the above, proposed LGA-3 (containment control procedure)
does not require-the. reactor' operator, as a subsequent action, to
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~ monitor the containment high range radiation monitor. reading. .' Correction
of this deficiency will ensure that the Shift Engineer is cognisant of
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the source term.in containment and can re-evaluate any changes needed
in recommendations to offsite agencies (Section 5.2) (373/81-14-03;.
374/81-0,9-03).
3.
Planning Standard (b)(5)
Procedures have been established for notification, by the licensee,lof
State and local response organizations and for notification of emergency
personnel. by all response organizations; the content of initial and
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followup sessages to response organizations and the public has been
established; and means to provide early notification and clear instruc-
tion to the populace within the plume exposure pathway Emergency
Planning Zone (EPZ).have been established.
Deficiencies
.
Contrary to the above, the following deficiencies were identified:
Various-LOAs (abnormal operating procedures) do not interface
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with t_e Generating Stations Emergency Plan (GSEP) and thus do
not ensure that the Acting Station Director will classify the
emergency and make appropriate notifications. Thes'e LOAs are
listed in Section 5.2 of the enclosed report (373/81-14-04;
374/81-09-04).
All fire preplan procedures do not interface with the GSEP.
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These preplans must include stater.ent to request the Shift
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Engineer to classify the fire in accordance with LZP-1200-1
(Section 5.4.8) (373/81-14-05; 374/81-09-05).
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4.
Planning Standard (b)(8)
Adequate emergency facilities and equipment to support the emergency
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response are provided and maintained.
Deficiencies
Contrary to the above, the following deficiencies were identified:
Emergency lighting, portable air sampling capability, high
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range personnel dosimeters, and a high range (0-1000 R/hr)
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portable gamma monitor need to be installed in the Operations
Support Center (Section 4.1.1.3) (373/81-14-06; 374/81-09-06).
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Emergency lighting and portable radiation monitoring is needed
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in the assemble /relocetion area (Section 4.1.2) (373/81-14-07;
374/81-09-07).
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Wind direction and speed must be monitored at the 10 meter
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elevation which will not be affected by man-made obstructions
(Section 4.2.1.4) (373/81-14-ud; 374/81-09-08).
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Chart recorders of primary meteorological measurements 'aust be
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read out in the Control Room (Section 4.2.1.4) (373/81-14-09;
374/81-09-09).
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A backup metro system or equivalent to the primary system must
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be installed if the Dresden Station metro program is determined
to be non-representative for LaSalle (Section 4.2.1.4)
373/81-14-10; 374/81-09-10).
5.
Planning Standard (b)(9)
"
Adequate methods,_ systems and equipment for assessing and monitoring
actual or potential offsite consequences of a radiological emergency
condition are in use.
Deficiencies
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Contrary to the above, the following deficiencies were identified:
No' procedure exists for the field team's useoto specify what
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" instruments are to be used in various circumstances, what
equipment and supplies are necessary for documenting results
and what and how information is to be communicated to the
Emergency Operations Facility (EOF) (Section 5.4.2.1)
(373/81-14-11; 374/81-09-11).
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Procedure L2P-1220-4 must be corrected to direct the Shift
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- Engineer to specify the Rad / Chem Technician (RCT) to collect
liquid effluent samples froe; the drain lint of the alarming
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process radiation monitor (Section 5.4.2.10) (373/81-14-12;
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374/81-09-12).
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Procedure LZP-1180-1 (Rad / Chem Director) does not specify when
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and in what order of priority post-accident reactor coolant,
containment air or station vent samples should be collected
(Section 5.4.2) (373/81-14-13; 374/81-09-13).
6.
Planning Standard (b)(11)
Means for controlling radiological exposures, in an emergency, are
established >for emergency workers. The means for controlling radio-
-logical exposures shall include exposure guidelines consistent with
' EPA Emergency Worker and Lifesaving Activity Protective Action Guides.
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Deficiencies
Ccatrary to the above,'the following deficiencies were identified:
Procedure .LZP-1350-1 must be revised to ensure a RCT or equiv-
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alent persons be directed to the assembly ares for personnel
monitoring when the assemble alarm is sounded (Section 5.4.3.2)
(373/81-14-14; 374/81-09-14).
Procedures for radiation protection during an emergency must
.
.be developed and provisions must be included to prevent a
repeat exposure to any overexposed (greater than three rems)
individual (Section 5.4.3.1) (373/81-14-15; 374/81-09-15).
Procedures for in plant radiation surveys during ' accident condi-
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tions must be developed (Section 5.4.2.3) (373/81-14-16;
374/81-09-16).
'
7.
Planning Standard (b)(15)
~ Radiological emergency response training is provided to those who may
be called on to assist in an emergency.
' Deficiencies
Contrary to the above, the following deficiencies were identified:
A specific training program for RCTs regarding their role during
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an emergency must be developed (Section 3.2) (373/81-14-17;
374/31-09-17).
A specific formal training program for all ccting Station
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Directors (SR0s) must be developed-(Section 3.2) (373/81-14-18;
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374/81-09-18).
'The scope and depth of the existing GSEP training program must
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be reevaluated -to ensure and verify that an adequate level of
training has been achieved (373/81-14-19; 374/81-09-19).
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Appendix B
APPRAISAL IMPROVEMENT ITEMS
Based on the results of the NRC's appraisal of the LaSalle Nuclear Station
Emergency Preparedness Program coeducted April 20 - May 1, 1981, the
following items should be considered for improvement:
Note: These items are prioritized in' order of importance.
' Develop a QA program to determine the effectiveness of the. training
.1.
program.
2.
The Technical Director and Rad / Chem Director, in addition to the
Operations Director, shoulc La on a duty call system.
3.
Conduct an off-hours shift augmentation drill within one year.after fuel
load.
4.
Modify LRP-1310-9 (Recharging Scott Air 'acs) to Linclude a precaution
statement to prevent overpressurization or t+e offsite fire department
SCBA tanks. This should be in bold print.
5.
Provide' additional public information pamphlets to the transient
population locations.
6.
-Establish formal 1 training program for dedicated communicators.
7.
Make provisions for an alternate area to perform necessary sample
dilution for cases where the chemistry lab will be unavailable due
to high radiation.
8.
A specific person, by title, should be designated as'being in charge
at the assemble area.
9.
' Include EG ' series procedures with the dedicated Environs Teams
equipment.
,
10.
Delete LZP-1450-2.
11.
Incorporate LZP-1450-1 with LZP-1550-9 for surveillance-of TLDs.
12. ~ LZP should be developed for sampling high level liquid effluent
samples, including means for collection, transport and dilution.
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It should include precautions and limitations.
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Appendix B
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13.
Specify"in appropriate procedures the use of KI prior to actual
exposure af calculated exposures will exceed ten rems..
' 14. . Include' limitation / precaution in appropriate procedures that XI
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should not be taken by persons allergic to iodide.
15. Specify in procedures when protective clothing and respiratory
equipment will be used,li.e., action levelr..
16. -Expand EG procedures'to include sample /scrvey data collection forms
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and a description of their use, instrumentation needed and protective.
clothing requirements.
' 17. Ten mile.EPZ map (laminated in plastic) in Standard. A thru P sector
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nomenclature should be available in the Control Room.
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18.
The instrument for measuring core damage assessment (containment
high. range. radiation monitor) should be color-coded to aid the user
in determining which emergency class he may be approaching.
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'19.
. Critical LZP's and LOA's should be tabbed in red for quick access.
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LOA's which direct the Shift Engineer to classify emergencies should
also be tabbed.
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20.
Station group directors should be familiar with EOF procedures
involving offsite Directors performing similar functions. This
should be added to GSEP Director training.
21. A directional shielded probe should be available for decontamination
monitoring in'the first. aid room.
22.-
Protective action Tables 6.3-1, 6.3-2, and 6.3-3 from GSEP should
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be incorporated in the CCC Director's procedere (CC-1).
23. EOF-3 and ED-1 procedures should be revised to specify the means for
updating Federal and State radiological assessment personnel at
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. least every 15 minutes.
(
24.
Procedure L2P 1200-3 should be revised to include block sections on
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the attached graph indicating various emergency classifications.
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15 . Direction arrows to direct personnel to the emergency assemble area
sho;'.d be placed in critical hallways and corridors.
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46.
Recommend revision of let ers of agreement between LaSalle Station
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and Dresden Station using St. Joseph's Hospital and St. Mary's
Hospital. as primary and backup and visa versa.
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27. ' Additional training of St. Mary's Hospital personnel in radiation
monitoring should be provided.
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28. Grand Ridge Fire Department should be given procedures (LZP-1370
series) and a copy of the GSEP.
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29. The site training department should be notified of all planned
exercises and drills so they may attend.
30. Radiation Management Corporation tudits, critiques, and training
records submitted to corporate office should be made available to
the onsite training department.
31. The station telephone directories (LZP-1700-1, 2, and 3) should be
revised to agree with requirements and lists in the current April
'1981, GSEP.
^
32. Technical support personnel should be listed in the GSEP telephone
directory for each of the various -technical disciplines.
33. LZP-1550-1, 5, 6, and 9 should'specify the provisions by which
missing equipment and supplies are replaced.
34. Procedure LZP-1550-7 should specify that monthly surveillance should
be performed monthly regardless of whether the facility has been
activated.
35. LZP-l'330-6 should be revised to incorporate the correct dose factors,
as shown in ED-16, and should be routinely reviewed by the supervisor
of the emergency planning group at corporate headquarters.
36. Environs response group should have a third walkie-talkie radio as a
backup and portable roof mounted antennas.
37. Future emergency vehicles purchased should be equipped with 4-wheel
drive.
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Appendix C
The following is a list' of Open Items identified in the area of Emergency
Preparedness which must be re-examined or completed prior to fuel load, full
power authorization, or in accordance with schedules set forth in NUREG-0737:
1.
High range station vent and Standby Gas Treatment System monitors need
to be installed, calibrated and training performed regarding their use
(Sectionu,.1.1.7) (373/81-14-20; 374/81-09-20).
'
2.
Installation of all needed communications, radiological and assessment
equipment and the Safety Parameter Display System must be completed in
the permanent Technical Support Center (Section 4.1.1.2) (373/81-14-21;
374/81-09-21).
3.
Installation and testing of the high range sampling system (HRSS) and
completion of required shielding for the sampling lines is required
.(Section 4.1.1.5) (373/81-14-22; 374/81-09-22).
4.
Installation of first aid kits, stretchers, and blankets around the
site as per LZP's is necessary (Section 4.1.2.2) (373/81-14-23;
374/81-09-23).
5.
Area and process radiation monitors need to be installed and calibrated
.(Section 4.2.1.2) (373/81-14-24; 374/81-09-24).
6.
Installation and testing of the microwave voice channel communication
system is necessary (Section 4.2.3) (373/81-14-25; 374/81-09-25).
,
7.
Determination of calibration factors for LZP-1200-2 (Noble Gas) and
LZP-1220-4 (liquid effluents) relevant to releases during an emergency
needs to be completed (Section 5.4.2) (373/81-14-26; 374/81-09-26).
8.
Installation and operation of a Class A meteorological dose assessment
program is necessary (Section 4.2.1.4) (373/81-14-27; 374/81-09-27).
9.
Development of procedures covering sampling and analysis for all post
accident sampling systems (i.e., HRSS and General Atomic Skid) and
development of procedures for the portable Multi Channel Analyzer
system are required (Section 5.4.2 and 4.1.1.8) (373/81-14-28;
374/81-09-28).
10.
Implementation of the Security Plan relating to emergency preparedness
<
is required (Section 5.4.3 and 5.4.4) (373/81-14-29; 374/81-09-29).
11. Acquire a SAM-2 (Eberline) or equivalent portable field radioiodine
sampling capability for the emergency kits (Section 4.2.1.1)
(373/81-14-30; 374/81-09-30).
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Appendix C '
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12., Installation of the PING-3 -(Eberlir.e) or equivalent realtime monitor to
measure direct radiation, particulate, radioiodine, and. noble gas concen-
,
tration in the Emergency Operation Facility (EOF) is necessary
.
(Section 4.1.1.4) (373/81-14-31; 374/81-09-31).
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CONTENTS
PAGE
- 1.0 ADMINISTRATION OF EMERGENCY PLAN
2
2.0 EMERGENCY ORGANIZATION
4
2.1. Onsite Emergency Organization
4
2.2 Augmentation of the Emergency Otganization
5
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2.2.1
Offsite Emergency organization
5
2.2.2
Onsite Emergency Organization
6
' 3.0 -TRAINING / RETRAINING
6
3.1 Program Establishment
6
3.2 Program Implementation
7
4.0 EMERGENCY FACILITIES AND EQUIPMENT
9
~4.1
Emergency Facilities
9
4.1.1
Assessment Facilities
9
4.1.1.1
Control Room
9
4.1.1.2
Technical Support Center (TSC)
9
4.1.1.3
Operations Support Center (OSC)
10
4.1.1.4
Emergency Operations Facilt.ty (EOF)
11
4.1.1.5
Post-accident Coolant Sampling and
Analysis
12
4.1.1.6
Post-accident Containment Air Samplina
and Analysis
12
L
4.1.1.7
Post-accident Gas, Particulate, and
Iodine Effluent Sampling and Analysis
13
i
s
4.:.1.8
Post-accident Liquid Effluent Samplina
-
and Analysis
13
4.1.1.9
offsite Laboratories
13
i
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. - _ . .
- . . - - , - . . - , - . . - - . _ _ . . - . _ . .
..
~
.
.
.
.
a
..
4.1.2
Prrtective Facilities
14
4.1.2 1 Assembly / Reassembly Areas
14
.
'
4.I'.2.2
Medical Treatment Facilities
14
4.1.2.3
Decontamination Facilities
-14
4.1.3'
Expanded. Support Facilities
14
4.1.4
News Center
15
4.2 Emergency Equipment'
15
4.2.1
Assessment
15
4.2.1.1
Emergency Kits and Emergency Survey-
Instrumentation
15
-
4.2.1.2
Area and Process Radiation Monitors
16
4.2.1.3_
'Non-Radiation Process Monitors
16
'4.2.1.4
Meteorological Instrumentation
17
4.2.2
Protective Equipment'
18
f
4.2.2.1
Respiratory Protection
18
'
4.2.2.2
Protective Clothing
18
4.2.3
Emergency Communications
18
4.2.4
Damage Control / Corrective Action and
Maintenance Equipment and Stpplies
19
4.2.5
Reserve Emergency Supplies and Equipment
19
-4.2.6
Transportation
19
5.0 PROCEDURES
20
'
5..
Ceneral-Content and Format
20
- 5.2 Emergency, Alarm, and Abnormal Occurrence' Procedures
20
5.3 Implementing Instructions
22
'5.4
Implementing Procedures
24
5.4.1-
Notifications
24
l
11
.,
..
.
-
,
-
.-
5.4.2
Assessment Actions
'26
i-
5.4.2.1
Offsite Radiological Surveys
28
5.4.2.2
Onsite Radiological Surveys
28
5.4.2.3
In-plant Radiological Surveys
29
5.4.2.4
Post-accident Primary Coolant Sampling
30
5.4.2.5
Post-accident Primary Coolant
Analysis-
30'
5.4.2.6
Post-accident Containment Air Sampling
- 30-
5.4.2.7
Post-accident-Containment-Air
. Analysis
30-
5.4.2.8
Post-accident Stack Effluent Sampling
30
5.4.2.9
Post-accident' Stack Effluent Analysis
30
.
5.4.2.10 ~ Liquid Effluent Sampling
31
5.4.2.11
Liquid Effluent Analysis
30
5.4.2.12 Radiological Environmental Monitoring
Program (REMP)
31
5.4.3
Protective Actions
32
.5.4.3.1
Radiation Protection During
Emergencies-
32
5.4.3.2-
Evacuation of Owner-controlled Areas
33
.
5.4.3.3
Personnel Accountability
34
5.4.3.4
Fersonnel Monitoring and
.
Decentamination
34
5.4.3.5
-Onsite First' Aid / Rescue
34
5.4.4
Security During Emergencies
35
5.4.5
Repair / Corrective Actions
35
5.4.6
Recovery
35
5.4.7
Public Information
36
5.4.8-
Fire Protection
36
..
iii
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. ..
.
.
.
- - . . .
. .
. . _ _ _ - _ . . . . , . .
.
. , .
. .
. _ . . . , _ -.
_ . -
_ _.
.
_ _
-
-
- '
.
.
6
%m
5.5 Supplemental Procedures'
37
15.5.1
Inventory, Operational 1 Check and Calibration -
of Emergency Facilities and Supplies.
37
5.5.2
- Drills and Exercises
38
5.5.3
Review, Revision, and Distribution of Emergency ~
,
Plan and Procedures-
38
5.5.4
L Audits of Licensee Emergency Preparedness Program
39
'
5.6 Human Factors Engineering-
-40
f6.0 - COORDINATION WITH OFFSITE' GROUPS
40
6.1 Offsite Agencies-
40
6.2 ~ General Public and Transient Populations
42
6.3 ' News Media
43
I
6.4 Contractors and Vendors-
43
~ 7.0 DRILLS ~AND EXERCISES
44
7.1 Onsite/Offsite Drill During Appraisal
44
8.0 LICENSEE ACTION-ON PREVIOUS IDENTIFIED ITEMS'RELATED TO
EMERGENCY PREPAREDNESS-(IE INSPECTION REPORTS NO.~ 50-373/80-47;
,
50-374/80-29; 50-373/80-53)
45
9.0 PERSONS CONTACTED
,
45
10.0 EXIT' INTERVIEW
-47
-
-ANNEX A - FIGURES
21 GSEP Station Group Organization
.2.2
Limited Response Offsite GSEP Organization
2.3 Full Response Offsite GSEP Organization
5.4 Simplified Emergency Notification Scheme
iv
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