ML20010F527
| ML20010F527 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 08/26/1981 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20010F528 | List: |
| References | |
| NUDOCS 8109100319 | |
| Download: ML20010F527 (20) | |
See also: IR 05000295/1981013
Text
_____ _ _ ___ _____________________________
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August 25, 1981
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Docket No. 50-295
Docket No. 50-3C4
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Commonwealth Edison Company
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ATTN:
Mr. Cordell Reed
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Vice-President
Post Office Box 767
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Chicago, IL 60690
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Gentlemen:
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Subject: EMERGENCY PREPAREDNESS APPRAISAL
To verify that licen:,ees hava attained an adequate state of onsite emergency
preparedness, the Office of Inspection and Enforcement is conducting special
appraisals of the emergency preparedness programs at all operating nuclear
p:;wer reactors. The objectives of these appraisals 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 requesting individual licenree action to
correct deficiencies and effect improvements, but also for effecting improve-
ments in NRC requirements and guidance.
During the period of June 29 - July 10, 19t?
and July 14, 1981, the hRC con-
ducted a special appraisal of the emergency preparedness program at the Zion
Nuclear Generating Station. This appraisal was performed in ' lieu of certain
routine inspections normally conducted in the area of emergency preparedness.
Areas exaaiined during this appraisal are described in the enclosed report
(50-295/81-13; 50-304/81-09).
Within these areas, the appraisal team rev;ewed
selected procedures and representative records, inspected emergency facilities
and equipment, observed work practices, and interviewed personnel.
The findings of this emergency preparedness appraisal indicate that several
significant deficiencies exist in your emergenci preparedness program. These
are discussed in Appendix A, "Significant Appraisal Deficiencies," and in
sucmary include:
a.
Inadequate content and format of Emergency Plan Implementing Procedures
and interface with Emergency Operating Procedures.
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b.
Ineffective coordinat ion witL offsite governmental and support agencies.
c.
Ineffective Radiation Protection (RP) program for emergencies, in that RP
procedures which ould be used in emergency situations are not inuicated
or referenced :.o ensure proper limitations and precautions for their use.
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Commonwealth Edison Company
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d.
Incomplete shift augmentation capability as per the regulatory positions
of Table B-1 of NUREG-0654.
e.
Upgrading of Emergency Action Levels in the Plan to be more specific and
include actual reliable and observable reactor and/or radiation process
monitor readings or rate of change of readings.
The findings of this appraisal also indicate that there are areas for improve-
ment in your emergency preparednese program. These are discussed in Appendix b,
" Appraisal Improvement Items."
In conjunction with the aforementioned appraisal, emergency plass for your
facility were reviewed. The results of this review indicate that certain de-
ficiencies exist in your Emergency Plan (GSEP) and the Zion Site Specific Annex.
These are discussed in Appendix C, " Emergency Preparedness Evalnation Report."
Several areas in your emergency preparedness program were not complete at the
time of this appraisal and therefore were not examined. These areas are
identified as Open Itens and are listed in the enclosed Appendix D.
These will
be examined by our staff upon complete implementation of the area insolved.
Please notify our office relevant to your completion schedule of these items
for re-examination by our staff.
We recognize that an explicit regulatory requirement pertaining to each item
identified in Appendices A, B, and C may not currently exist. Notwithstanding
this, you are requested to submit a written statement within thirty days of the
date of this letter, describing your planned actions for improving each of the
items identified in Appendix A and the results of your consideration of each of
the items in Appendix B.
This description is to include:
(1) steps which have
been taken; (2) steps which will be tsken; and (3) a schedule for completion of
actions for each item. This request is made pursuant to Section 50.54(f) of
Part 50, Title 10, Code of Federal Regulations. With regard to Appendix C,
within 90 days of the date of this letter you are requested to provide changes
to the emergency plan correcting each deficiency.
Copies of these changes are
to be submitted in accordance witL the procedures delineated in 10 CFR 50.54(q).
This is to inform you that should the deficiencies in Appendix A not be corrected
within four months of the date of this letter, the Ccmmission will determine
whether the reactors shall be shut down until such deficiencies are remedied or
whether other enforcement action is appropriate.
In accordance with 10 CFR 2.790 of the Commission's egulations, a copy -f 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 disclosure 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 your intention to file a request for with-
holding; and (b) submit within twenty-five (25) days from the date of this letter
a written application to this office to withhold such information.
Sectica
2.790(b)(1) requires that any such application must be accocpanied by an
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Commonwealth Edison Company
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affidavit executed by the owner of the information which identifies the document
or part sought to be withheld, and which coatains a full statement of the
reasons on the basis which it is claimed
t...c the information should be with-
held from 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 from you in this regard
within the specified periods noted above, a copy of this letter, the enclosures,
and your respons? to this letter will be placed in the Public Document Room.
The reporting requirements contained in this letter affect fewer than ten persons
and therefc.re are not subject to Office of Management and Budget Clearance as
required by P.L.96-511.
Should you have any questions concerning this inspection, we will be pleased to
discuss them with you.
Should you have any questions concerning the items of
Appendix C, please contact Mr. W. L. Axelson, Emergency Preparedness Licensing
Branch at (312) 932-2535.
Sincerely,
.O.Gf
gM
es G. Keppler
Regional Director
Enclosures:
1.
Appendix A, Significant
Appraisal Deficiencies
2.
Appendix B, Appraisal
Improvement Items
3.
Appendix C, Emergency Prepared-
ness Evaluatiu Peport
4.
Appendix D, Open i Dms
5.
Office of Inspection and
Enforcement Inspection
Reports No. 50-295/81-13;
and No. 50-304/81-09
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Louis 0. DelGeorge, Director
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K. Graesser, Station
Superintendent
DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII
Mary Jo Murray, Office of
Assistant Attorney General
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Regional Director, FEMA Region V
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Appendix A
SIGNIFICANT APPRAISAL DEFICIENCIES
The following is a list of Significant Deficiencies regarding the Zion
Emergency Preparedness Appraisal. These deficiencies are categorized
according 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
reasonable assurance that adequate protective measures can and will be
taken in the event of a radiological cmergency.
1.
PLANNING STANDARD (b)(1)
Primary responsibilities for emergency response by the nuclear
facility licensee, and by State and local organizations within the
Emergency Planning Zones have been assigned, the emergency responsi-
.
bilities of the various supporting organizations have been specifically
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established, and each principal response organization has staff to
respond and to augment its initial response on a continuous basis.
DEFICIENCY
I
Contrary to the above,-the following deficiency was identified:
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Letters of agreement have not been made with those offsite
.
support and governmental agencies listed in Section 6.1.
Followup on the agreements, including management review, to
ensure that all agreements have been signed by both parties has
not been completed.
(Section 6.1).
(295/81-13-01; 304/81-09-01)
i
2.
PLANNING STANDARD (b)(2)
On-shif t facility licensee responsibilities for emergency response
are unambiguously defined, adequate stsffing to provide initial
facility accident response in key functional areas is maintained at
all times, timely augmentation of response capabilities is available,
and the interfaces among various onsite respotse activities and
offsite support and response activities are specified.
DEFICIENCIES
Contrary to the above, the following deficiencies were identified:
Emergency Plan Implementing Procedure EPIP-320-1 does not
.
include Rad / Chem Technicians (RCTs) in the call-out list, and
the call-out list is not prioritized to ensure augmented staffing
'
as per the regulatory position of Criteria II.B.5 of NUREG-0654
(Revisicu 1).
(Section 2.2.2) (295/81-13-02; 304/81-09-02)
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Appendix A
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With the exception of the Station Director's procedure, none of
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the Station Group Directors' procedures (e.g., EPIP-120-1 through
EPIP-180-1) are in the format specified by Zion Administrative
Procedure ZAP-5-51-5.
Further, these procedures are for the most
part ambiguous.
(Section 5.1) (295/81-13-03; 304/81-09-03)
The Station Director's procedura (EPIP-110-1) does not specify
.
or reference what protective action recommendations to offsite
agencies will be made depending on the event; and it does not
direct the RCT's to conduct appropriate surveys or sampling
until the arrival of the Rad / Chem Director. (Section 5.3)
(295/81-13-04; 304/81-09-04)
3.
PLANNING STANDARD (b)(5)
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 (EPZ) have been established.
DEFICIENCIES
Contrary to the above, the following deficiencies were identified:
The Emergency Operating Procedures (EOPs) and Abnormal Occurrence
.
Procedures (A0Ps) listed in Section 5.2 that describe emergency con-
ditions which warrent the classification of the event do not direct
the Reactor Operator to inform the Shift Engineer of a possible GSEP
condition.
(Section 5.2) (295/81-13-05; 304/81-09-05)
The licenaee has not demonstrated that administrative and physical
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means have been established for alerting and providing prompt
instructions to the public within the plume exposure pathway EPZ.
The licensee will be responsible for ensuring prompt alerting and
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notification of the public in accordance with the Commission's
,
regule.tions.
(Section 6.2.2) (295/81-13-06; 304/81-09-06)
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4.
PLANNING STANDARD (b)(6)
Provisions exist for prompt communications among principal response
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organizations to emergency personnel and to the public.
DEFICI2NCIES
Contrary to the above, the following deficiencies were identified:
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Appendix A
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The licensee has not established and implemented a program to
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test the ability to communicate between the facility and the
Wisconsin Division of Emergency Government in Madison, Wisconsin
on a monthly basis.
(Section 4.2.3) (295/81-13-07; 304/81-09-07)
The licensee has not installed a Nuclear Accident Report System
.
(NARS), or an equivalent backup communication system, such as
the National Warning System, between the facility and the
Wisconsin Division of Emergency Government in Madison, Wisconsin.
(Section 4.2.3) (295/81-13-08; 304/81-09-08)
5.
PLANNING STANDARD (b)(7)
Information is made available to the public on a periodic basis on
how they will be notified and what their initial actions should be
in an emergency (e.g., listening to a local broadcast station and
remaining indoors), the principal points of contact with the news
media for dissemination of information during an emergency (including
the physical location or locations) are established in advance, and
procedures for coordinated dissemination of information to the
public are established.
DEFICIENCIES
Contrary to the above, the following deficiencies were identified:
Public information pamphlets have not been distributed to areas
.
in Wisconsin where the transient adult population within the
ten mile EPZ may read a copy.
(Section 6.2.1) (295/81-13-09;
304/81-09-09)
Public information pamphlets or equivalent information have not
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been posted in public places, such as the Illinois Beach State
Park and adjacent campgrounds.
(Section 6.2.1) (295/81-13-10;
304/81-09-10)
6.
PI.ANNING STANDARD (b)(8)
A>sequate emergency facilities and equipment to support the emergency
response are provided and maintained.
DEFICIENCIES
Contrary to the above, the following deficiencies were identified:
Existing procedures for inventory, operational checks,
.
and calibrations of emergency equipment at the Station,
Technical Support Center (TSC), Operations Support Center
(OSC), Emergency Operations Facility (EOF), and onsite
first aid /decon facility do not:
(1) interface with each
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Appendix A
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other, (2) specify the minimum number of each inventoried item
required, and (3) include provisions for replacement of missing
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items. Procedures do not include provisions to test all emergency
equipment including telephones and radios, facilities and
instruments and to record all such tests.
(Section 5.5.1)
(295/81-13-11; 304/81-09-11)
Emergency equipment at the offsite hospital is inventoried quarterly
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by a licensee representative; however, there is no EPIP for inven-
torying these items.
(Section 6.1) (295/81-13-12; 304/81-09-12)
7.
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
Contrary to the above, the following deficiencies were identified:
There is no procedure for the field team's use which specifies
.
which instruments are to be used in various circumstances (such
as the instrument and means to determine whether or not the team
is inside a plume), what equipment is needed (e.g., respirators,
high range dosimeters, air sampling tripods, portable generator,
etc.), the means for documenting results, and what information
must be communicated to the EOF.
(Section 5.4.2.1) (295/81-13-13;
304/81-09-13)
Procedure RP-1740-4, operation of the Eberline SAM II, is
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deficient in the following areas:
(a) no specific assembly
(e.g., which counting shelf level, electrical hook-up, etc.) or
methods enucarated that are necessary to measure 10
uCi/cc
iodine in the presence of noble gases; (b) the numerical scaling
on the calibration graph of uCi (iodine) vs. counts per minute
was poorly labeled; (c) incorrect equation to determine iodine
concentration.
(Section 7.1) (295/81-13-14; 304/81-09-14)
The licensee has not demonstrated that the model for transport
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and diffusion used at the Zion site is reasonable considering
lake influence, especially for the assessment of effluent
trajectories.
(Section 4.2.1.4) (295/81-13-15; 304/81-09-15)
8.
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 Evergency Worker and Lifesaving Activity Protective Action Guides.
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Appendix A
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DEFICIENCIES
Contrary to the above, the following deficiencies were identified:
Several established radiation protection procedures that are
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routinely used and would also be used during an emergency are
not cross-referenced in EPIP-99-1, Reference Procedures.
(Section 5.4.2.3) (295/81-13-16; 304/81-09/16)
Radiation Protection procedures that will be used in an emergency
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and are not listed in EPIP-099-1 (e.g., 1350-12 and 13, RP-1190,
RP-1250, and RP-1740-4) have not been reviewed to determine their
precautions and limitations and actions for use during an emergency.
Several RP procedures that are used only for emergencies are not
in EPIPs.
(Section 5.4.2.3) (295/81-13-17; 304/81-09-17)
The exposure guidelines specified in the Environmental Protection
.
Agency's Protective Action Guides (EPA-520/8-75/001) and GSEP
for emergency workers are not included in the Emergency Plan
Implementing Procedures.
(Section 5.4.3.5) (295/81-13-18;
304/81-09-18)
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Appendix B
APPRAISAL IMPROVEMENT ITEMS
Based on the results of the NRC's appraisal of the Zion Nuclear Station
Emergency Preparedness Program conducted June 29 - July 10, 1981, and
,
July 14, 1981, the following items should be considered for improvement:
Note: These items are prioritized in order of importance.
1.
The licensee should develop an EPIP for activation of the entire EOF
building, utilizing sufficient working space to adequately support all
licensee and other personnel required to be present.
(Section 4.1.1.4)
2.
An interim procedure that uses sampling techniques and/or portable dose
rate instrumentation to quantify and verify gaseous releases from the
steam generator safety / relief valve pathway should be developed.
(Section 5.4.2.2)
3.
Specify elevated radiation levels which would require relocation of
laboratory capability and specify relocation area.
(Section 5.4.2.5)
4.
Correct T measurements for the Zion tower (i.e.,
T measurement
between 10 and 60 m) to be in reasonable agreement with the position
in RG 1.23.
ED procedures should be revised to incorporate this
change.
(Section 4.2.1.4)
5.
Specify action levels (e.g., anticipated loss of laboratory capability)
which warrant charging porta 51e intrinsic germanium dewars with liquid
nitrogen to assure timely operability.
(Section 5.4.2.5)
6.
The licensee should include in fire preplans a statement to request
the Shift Engineer to classify a fire emergency in accordance with
EPIP-330-1.
(Section 5.4.8)
7.
Expand the Environs Group (EG) procedures to include sample / survey
data collection forms and a description of their use, instrumentation
needed and protective clothing requirements.
(Section 5.4.2.12)
8.
Include diagrams of evacuation routes from the site in EPIP-360-1.
(Section 5.4.3.2)
,
9.
Coordinate with FEMA and the states of Wisconsin and Illinois to ensure
that both the Milwaukee and Chicago U.S. Coast Guard Stations will be
supplied with radiation detection instruments, film badges, dosimeters,
and any other related protective equipment.
(Section 6.1)
10.
Install an analog recording system consisting of RG 1.97 meteorological
parameters in the Control Room in accordance with the implementation
schedule provided in Task Item III.A.2 of NUREG-0737.
In addition,
the wind speed _and direction indicators from the mast on top of
Unit 1 Containment should be removed.
(Section 4.2.1.4)
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Appendix B
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11.
The Waukegen Generating Station Shif t Engineer (s) and other cognizant
personnel having responsibilities for accommodation of Zion Station
evacuees, should be properly informed and trained.
(Section 6.1)
12.
Training for dispatchers / communicators at the Lake County Sheriff's
Office saould be given by the licensee regarding initial notification /
recommendation from the facility.
(Section 6.1)
13.
P ocedures should contain a provision to immediately signal when an
EAL has been reached based on sample results.
(Section 5.4.2.5)
14.
OSC emergency personnel should have immediate access to c.dditional
radiological monitoring equipment, portable transceivers, and radiation
signs.
(Section 4.1.1.3)
15.
Include in the routine liquid effluent sampling procedure precautions
and limitation for use of this procedure during accident conditions.
(Section 5.4.2.10)
16.
The Station Group Directors should be familiar with the EOF procedures
describing comparable positions in the EOF Organization.
(Section 2.1)
17.
Protective Action Tables in the GSEP should be incorporated and re-
ferenced in the Corporate Command Center (CCC) Director's procedure
(CC-1).
(Section 5.4.1)
18.
The licensee should consider elimination of the Zion Station EPIP-330-3,
and modification of EG-1 and/or EG-2 to include the general street map
locations used in EPIP-330-3.
(Section 5.4.2.1)
19.
Incorporate planned messages in EPIP-320-1 to include as a minimu=
the emergency classification and the location where these personnel
should report.
(Section 5.4.1)
20.
EPIP-700-1 and EPIP-320-1 should be revised to incorporate the names
of personnel currently filling the positions of the Rad / Chem Director
and the Environs Director.
(Section 5.4.1)
21.
Attachment B (Major Nuclear Incident Plan Public Information) to
procedures E0F-4 and CC-4 should be revised to describe the current
location of the Zion Emergency News Center.
(Section 5.4.7)
22.
The licensee should obtain a wound monitor probe for the first aid /
decontamination room.
(Section 4.1.2.3)
23.
Technical support personnel should be listed in the GSEP telephone direc-
tory for each of the various technical disciplines.
(Section 5.4.1)
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Appendix B
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24.
Acquire a dedicated vehicle or establish and implement a system to
ensure one or both of the station pickup trucks will be immediately
available for use by tne field wonitoring teams.
(Section 4.2.6)
25.
The licensee should develop a QA procedure to ensure all areas of
Emergency Preparedness as specitied in the GSEP and EPIPs are audited
(Section 1.5)
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Appendix C
EMERGENCY PREPAREDNESS EVALUATION REPORT
The following is a list of sign.ficant defictencies identified in the
e
Zion Emergen(y Plan Site Specific Annex. Taese deficiencies are categorized
as per the planning standards of 10 CFR 50.47(b). These deficieacies as
well as those listed in Appendix A must be corrected in accordance with
the provisions of 10 CFR 50.54(s)(2):
Planning Standard B (Onsite Emergency Organization) (295/81-13-19; 304/81-09-19
The Plan does not adequately describe shift augmentation as per the
.
regulatory position of Table B-1 of NUREG-0654. Enclosure 9, of CECO's
letter dated December 31, 1980, indicates the current capabilities
of the Zion Station to provide emergency support within 30 minutes.
Specifically, no senior Health Physics Expertise will be available
within 30 minutes. However, two senior HPs will be available in 60
minutes. The 60 minute commitment is an adequate compensatory measure,
but this deficiency must be fully removed by July 1, 1982.
As a result of the Emergency Preparedness Apprai .1,
shift augmentation
procedures yere determined to be unacceptable (Section 2.2).
The Zion
Annex does not include 30, 45, and 60 minute shift augmentation capability.
The Plan does not clearly indicate what kind of duty officer system is
being used to ensure that these capabilities can be met.
Further, the
Plan does not describe the administrative means, (e.g., studies, and/or
drills) implemented to ensure that the design objectives of shift augmen-
tation are met as described in Enclosure 9 of CEC 0's December 31, 1980,
letter.
Planning Standard D (Emergency Classification System) (295/81-13-20; 304/81-09-20)
The Plan does not adequately provide Emergency Action Levels (EALs) as
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per Appendix 1 of NUREG-0654 in the following areas:
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UNUSUAL EVENT
(a) Fuel damage indication (loss of fission product barrier)
are not provided in Table ZA 5-1.
Failed fuel monitor
readings on the letdown line must be calculated for a 0.1%
equivalent fuel failures over a 30 minute period.
Primary
coolant sample analysis should be included as a backup to
this EAL.
(b) Abnormal coolant temperature or abnormal fuel temperature
readings are not provided in Table ZA 5-1
(e.g., subcooling
meter reading and incore thermocouple readings).
(c) Transportation of contaminated injured individual (s) from
site to offsite hospital is not covered in Table ZA 5-1.
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Appendix C
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(d) Radiological effluent readings (or alarms) of the Station
Vent and Auxiliary Vent monitors are not included to indicate
effluents greater than Technical Specification (TS).
ALERT
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(a) Area Radiation Monitor (ARM) reading EALs re not provided
in Table ZA 5-1 which indicate a severe degradation in the
control of radioactive materials (e.g., increases by factor
of 1000 in direct ARM reading within facility).
(b) Radiological effluent readings of the Station Vent and
Auxiliary Vent monitors are not included to indicate
effluents greater than 10 times TS or equivalent to 1 mr
dose if averaged over a two hour period. These readings
shall be indicated in the Plan.
(c) EALs for anticipated evacuation of the control room have
not been included in the Plan (e.g., radiation level, toxic
gas concentrations approaching hazardous levels, and fires).
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(d) Additional fuel damage indicators for an Alert condition are
not included in Table ZA 3-1.
The Fail Fuel monitor reading
on the letdown line must be calculated for greater than 1%
fuel failures within 30 minutes or 5% total fuel failures.
. e) The EALs indicated in the Plan for a Steam Generator (S/G)
(
tube rupture accident are inadequate. Steamline monitor
readings (when installed) and blowdown monitor readings
must be calculated for a rapid failure of one S/G tube.
This accident in conjunction with loss of offsite power is
an Alert. Further, EALs for rapid failures of several S/G
tubes (e.g. , several hundred gallons per minute) must be
calculated using the same radiological instrumentation.
(f) Main Steam line break accident in Table ZA 5-1 for an Alert
is inadequate. EALs for a 10 GPM primary to secondary leak
using installed radiological instrumentation must be calcu-
lated. This leak in conjunction with a main steam line break
is an Alert. No failed fuel is assumed.
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SITE AREA EMERGENCY
<
(a) A loss of coolant accident greater than makeup pump capacity
is not adequately addressed in Table ZA 5-1.
A leak greater
than 50 GPM over a four hour period is indicated to be classi-
fied as a Site Area Emergency. This is probably a typographical
error and must be corrected.
I
_
- .- -
-_~ _
-
-
- - - . - . -. ..-
-.
.
.
~
FILE COPY
'
.
Appendix C
-3-
(b) EALs for a degraded core with possible loss of coolable geometry
are not addressed.
Incore thermocouple readings (or rate of
change) and subcooling meter reading to detect inadequate core
cooling must be calculated and indicated in the Plan.
(c) EALs for rapid failure of several S/G tubes with a loss of
offsite power have not been calculated.
(d) Steam line break accident with greater than 50 GPM primary
to secondary leakage and indication of fuel damage ( 0.1%)
j
has not been addressed. EAI.s must be calculated for this
a
event.
l
(e) Radiological effluent readings of the Station Vent and
Auxiliary Vent monitor have not been calculated for levels
corresponding to greater than 50 mr/hr 'or 1/2 hour or
greater than 500 mr/hr W.B. for two rina es (five times
these levels for the thyroid).
,
(f) The Plan does not address an anticipated transient without
a scram (no core damage immediately evident).
(g) EALs for low water levels in Lake Michigan which could
,
i
cause a loss of essential service water cooling have not
been calculated and indicated in the Plan (e.g. , forebay
water level indication or alarms).
'
(h) Toxic gas sampling results (EALs) which are hazardous have
not been indicated in the Plan. This should be done for an
s
Unusual Event and Alert as well as the Site Ares Emergency.
-
GENERAL EMERGENCY
,
(a) Radiological effluent monitor readings which detect levels
corresponding to I rem /hr have not been calculated and
,
indicated in the Plan (use average meteorology).
,
(b) Loss of two out of three fission product barriers with a
potential loss of a third barrier is 'not adequately addressed.
Table ZA 5-1 is too conservative by classifying a General
l
Emergency using only the high range containment radiation
monitor. This should be changed to indicate loss of two
out of three fission product bariers with a potential loss
of containment. Therefore, high radiation level in contain-
ment and (not or) indication of potential loss of containment
should be used to classify this event.
.
!
(c) EALs have not been calculated for those PWR sequences which
!
could lead to a core melt and likely failure of containment.
l
(See Pages 1-18 of Appendix 1 of NUREG-0654).
l
.
-
.
.
.
. -
-
-
.
- .-
'
LIE COPY
_
Appendix C
-4-
l
PLANNING STANDARD E (Notification Methods and Procedures) (293/81-13-21;
304/81-09-21)
The Zion Annex does not describe the administrative or physical means
.
i
and time required for notifying and providing prompt instructions
l
to the public. A description of the prompt notification system for
the ten mile EPZ similar to Ceco's April 27, 1981, submittal for
>
LaSalle, must be provided for Zion. This must also be included in
the Plan. Survey, equipment bids, equipment ordered or received and
equipment installation schedules must be provided.
l
PLANNING STANDARD F (Emergency Facilities and Equipment) (295/81-13-22;
304/81-09-22)
When commitments are fully implemented as stated in the Plan, then
.
the Plan must be revised to reflect these changes,
i.e.,
installation
i
of post-accident monitoring and sampling, process monitors, TSC and
EOF as built diagrams, etc.
,
4
l
1
1
"
,
,
i
l
4
.I
,
. - . . . _
...-,_.m.-..-.,_._.-.._,,,..,-,,.-_,-,..,-m..y
, _ . _ . . . . , . . , . - _ . . _ . ,
,,.y.,..
,. _, - , ,- - , _ . _ . _ , - . , _ _ _ . .
alCOPY
.
.
Appendix D
OPEN ITEMS
The following is a list of Open Items identified in the area of Emergency
Preparedness which must be re-examined or completed ir. accordance with
schedules set forth in NUREG-0696 or NUREG-0737.
1.
All needed supplics, drawings, procedures, and equipment must be
installed at the interim E0F prior to the July 29, 1981, exercise.
(Section 4.1.1.4) (295/81-13-23; 304/81-09-23)
2.
Installation of all needed radiological, assessment equipment, supplies,
and the Safety Parameter Display System must be completed in the per-
manent Technical Support Center as per NUREG-0696.
(Section 4.1.1.2)
(295/81-13-24; 304/81-09-24)
3.
Installation and testing of the High Range Sampling System (HRSS)
and completion of required shielding for the sampling lincs is
required.
(Section 4.1.1.5) (295/81-13-25; 304/81-09-25)
4.
Installation and testing of the post-accident gas, particulate, and
iodine effluent sampling system is required.
(Section 4.1.1.7)
(295/81-13-26; 304/81-09-26)
5.
Installation and testing of the containment air post-accident sampling
system is required.
(Section 4.1.1.6) (295/81-13-27; 304/81-09-27)
6.
Installation and calibration of the high range containment radiation
monitor is required.
(Section 4.2.1.2) (295/81-13-28; 304/81-09-28)
7.
Installation and calibration, for the Steam Generator main steam
line radiation monitors (e.g., safety / relief valve pathway) is
raquired.
(Section 4.2.1.2) (295/81-13-29; 304/81-09-29)
8.
Completion of the new environmental emergency kits is required.
(Section 5.4.2.2) (295/81-13-30; 304/81-09-30)
9.
Installation and implcmentation of the meteorological program described
in Appendix 2 of KUREG-0654 is necessary.
(Section 4.2.1.4) (295/81-13-31;
304/81-09-31)
10.
Development of procedures covering sampling and analysis for all post-
accident sampling systems (i.e., HRSS and Sentry Skid) are required.
(Section 5.4.2.4) (295/81-13-32; 304/81-09-32)
.
. - -
-
.
. ._
.~
,
.
I
CONTENTS
1.0- ADMINISTRATION OF EMERGENCY PLAN
3
2.0 EMERGENCY ORGANIZATION
5
2.1
Onsite Emergency Organization
5-
2.2 Augmentation of the Emergency Organization
7
2.2.1
Offsite Emergency Organization
7
2.2.2
Onsite Emergency Organization
8
3.0 TRAINING / RETRAINING
8
3.1
Program Establishment
6
3.2 Program Implementation
9
4.0 EMERGENCY FACILITIES AND EQUIPMENT
9
4.1 Emergency ~ Facilities
9
i
4.1.1
Assessment Facilities
9
4.1.1.1
control Room
9
4.1.1.2
Technical Support Center (TSC)
10
4.1.1.3
Operations Support Center (OSC)
10
4.1.1.4
Emergency Operation Facility (E0F)
11
4.1.1.5
Post-accident Coolant Sampling
and Analysis
12
4.1.1.6
Post-accident Containmant Air Sampling
and Analysis
12
1
4.1.1.7
Post-accident Gas, Particulate, and
Iodine Effluent Sampling and Analysis
12
4.1.1.8
Post-accident Liquid Effluent Sampling
'
and Analysis
12
.
4.1.1.9
Offsite Laboratories
13
1
4.1.2
Protective Facilities
13
4.1.2.1
Assembly / Reassembly' Areas
13
4.1.2.2
Medical Treatment Facilities
13
-
4.1.2.3
Decontamination Facilities
14
,
5
4.1.3
Expanded Support Facilities
14
4.1.4
News Center
14
,
,
j
4.2 Emergency Equipment
15
i
4.2.1
Assessment
15
i
f
I
l-
i
i
.._.,.- - ._,
, . . , .
. .._ ~ _ _ ,_ ,..,,_-.___ _ . , , _ .
_ _ .
- - - -
. - _ . _ - - _ . _ _ _ - , . . . _ .
. - , . .
.
.
4.2. .1
Emergency Kits and Survey Instrumentation
15
4.2.1.2
Area and Process Radiation Monitors
15
4.2.1.3
Non-Radiati m ecocess Monitors
16
4.2.1.4
Meteorologicai Instrumentation
16
4.2.2
Protective Equipment
19
4.2.2.1
Respiratory Protection
19
4.2.2.2
Protective Clothing
19
4.2.3
Emergency Communications
19
4.2.4
Damage Control / Corrective Action and
Maintenance Equipment and Supplies
20
4.2.5
Reserve Emergency Supplies and Equipment
20
4.2.6
Transportation
21
5.0 PROCEDURES
21
5.1
General Content and Format
21
5.2 Emergency, Alarm, and Abnormal Occurrence Procedures
22
5.3
Implementing Instructions
23
5.4 Implementing Procedures
24
5.4.1
Notifications
24
5.4.2
Assessment Actions
26
5.4.2.1
Offsite Radiological Surveys
27
5.4.2.2
Onsite Radiological Surveys
27
5.4.2.3
In plant Radiological Surveys
28
5.4.2.4
Post-accident Primary Coolant Sampling
29
5.4.2.5
Post-accident Primary Coolant Analysis
29
5.4.2.6
Post-accident Containment Air Sampling
29
5.4.2.7
Post-accident Contarament Air Analysis
29
5.4.2.8
Post-accident Stack Effluent Sampling
29
5.4.2.9
Post-accident Stack Effluent Analysis
29
5.4.2.10 Liquid Effluent Sampling
30
5.4.2.11 Liquid Effluent Analysis
29
5.4.2.12 Radiological Environmental Monitoring
Program (REMP)
30
5.4.3
Protective Actions
31
5.4.3.1
Radiation Protection During
Emergencies
31
5.4.3.2
Evacuation of Owner-controlled Areas
31
5.4.3.3
Personnel Accountability
32
5.4.3.4
Personnel Monitoring and
Decontamination
32
5.4.3.5
Onsite First Aid / Rescue
32
ii
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.--__
--..
-
.
, . -
5.4.4
Security During Emergencies
33
5.4.5
Repair and Corrective Actions
33
5.4.6
Recovery
33
5.4.7
Public Information
34
5.4.8
Fire Protection
35
5.5 Supplemental Procedures
35
i
5.5.1
Inventory, Operational Check and Calibration of
Emergency Facilities and Supplies
35
1
5.5.2
Drills and Exercises
36
5.5.3
Review, Revision, and Distribution of Emergency
Plan and Procedures
37
6.0 COORDINATION WITH OFFSITE GROUPS
37
6.1 Offsite Agencies
37
6.2 General Public and Transient Populations
42
6.2.1
Information Distribution
42
!
6.2.2
Prompt Notification cf the Public
43
6.3 News Media
44
6.4 NSSS Vendor Walk-Through
44
7.0 DRILLS AND EXERCISES
44
7.1 Walk-Through of Inplant/ Field Radioiodine Analysis
44
8.0 LICENSEE ACTION ON PREVIOUSLY IDENTIFIED ITEMS RELATED TO
45
8.1
Health Physics Appraisal Items (IE Inspection Reports
No. 50-295/80-05; 50-304/80-04)
45
8.2 Confirmatory Order dated February 29, 1980
45
9.0 PERSONS CONTACTED
46
10.0 EXIT INTERVIEW
47
ANNEX A - FIGURES
2.1
GSEP Station Group Organization
2.2 Limited Response Offsite GSEP Organization
2.3 Full Response Offsite GSEP Organization
5.4 Simplified Emergency Notification Scheme
j
'iii
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