ML20024E565

Forwards Response to Four Emergency Plan Items Identified in App D to Jg Keppler Re Ltrs of Agreement W/Local Authorities,Emergency Action Level Guidelines,Evacuation Time Estimates & Training for Onsite & Offsite Groups

ML20024E565
Person / Time
Site:	Cook
Issue date:	07/29/1983
From:	Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
AEP:NRC:0824, AEP:NRC:824, NUDOCS 8308150305
Download: ML20024E565 (9)

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7 Donald C. Cook Nuclear Plant Unit Nos. 1 and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 RESPONSE TO OUR DIERGENCY PREPAREDNESS APPRAISAL Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Keppler:

On June 7, 1983 we were informed by your staff that there were four items in our Emergency Plan listed in Appendix D to your letter of June 30, 1982, which required a response from us in order to allow you to complete the evaluation report on the Donald C. Cook Nuclear Plant Emergency Plan. The four areas are:

(1) letters of agreement with local authorities, (2) emergency action level guidelines, (3) evacuation time estimates, and (4) training for certain on-site and off-site groups. to this letter responds to these items by clarifying our position or by explaining what changes will be included in our next revision (Revision 2) to the Emergency Plan. Revision 2 will be issued on or before September 16, 1983.

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We trust that Attachment I will clarify these four areas to your satisfaction.

This docum.nt has been prepared following Cor[> orate Procedures which incorporate a reasonable set of controls to ensure its accuracy and completeness prior to signature by the undersigned.

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W. G. Smith, Jr. - Bridgman R. C. Callen G. Charnoff NRC Resident Inspector'at Cook Plant - Bridgman s

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i to AEP:NRC:0824 This attachment addresses four items identified in Appendix D

' Emergency Preparedness Evaluation Report" of Mr. James G. Keppler's letter to John E. Dolan dated June 30, 1982.

I.

Letters of Agreement Your staff asked for the status of the letters of agreement with the City of Bridgman Fire Department, and Lake Township Ambulance and Rescue. The letters of agreement with the City of Bridgman Fire Department are in the current revision (i.e. Revision 1) of the i

Emergency Plan, Appendix C.

This revision was transmitted to you in our letter No. AEP:NRC:0719 dated August 12, 1982. The letters of agreement with the Lake Township Ambulance Service, as well as another letter of agreement with Medic Community Emergency Service, will be included in Revision 2 of the Emergency Plan. Copies of the letters from the City of Bridgman Fire Department and Lake Township Ambulance Service are attached.

Your staff asked for more detail in the letters of agreement in Appendix C to our Plan. We will inform the agencies with which we have agreements of the detail required by NUREG-0654 to be in these letters; and we will ask them to include this detail in the bi-annual upgrade of their letters where it is possible for them to do so.

II.

Emergency Action Levels Each Emergency Condition Category (ECC) for which your staff had questions is addressed below.

a.

You asked for a clarification of ECC 10, Loss AC Power, Unusual Event. In the next revision we will change it to read:

1.

Loss of all off-site AC power capabilities such that the T-ll A, B, C, D buses for U-l (or T-21 A, B, C, D buses for U-2) cannot be energized from these sources.

2.

Loss of all on-site AC power capabilities (both diesel generators for one unit and that unit's main turbine-generator are unavailable or inoperable due to mechanical, electrical or error effects).

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b.

For ECC 12, Unusual Event, Item le., you asked us to clarify

" essential comaninication." We will delete Item le in its entirety. Any event that could cause a loss of communication would be covered by other ECC's (i.e. Sabotage of system covered under ECC-7; damage by natural disaster would be covered under ECC-3 (earthquake), ECC-8 (Tornado or severe winds) ).

For ECC 12, under Site Emergency, we will add another c.

guideline to cover anticipated transients without the ability to SCRAM. This guideline will be l

2.

Transient requiring operation of shutdown systems with failure of both manual and automatic SCRAM capabilities (continued power generation but no core damage immediately evident).

d.

For ECC 3, your staff wanted us to use OBE and SSE levels in determing the EAL.

We feel that our guidelines are conservative and more quickly and easily used by the operator, than waiting for a seismic accelerometer trace to be taken off-site and analyzed; therefore, we will retain the ECC but with two changes. First to clarify the word "significant" under site emergency, we will change the guideline to read:

1.

Earthquake that is of sufficient magnitude to cause damage to equipment needed to safely shut down the Unit.

It may cause an automatic trip of the reactor and/or turbine due to equipment or instrumentation malfunctions.

Also, we will add a footnote for Alert 1 and Site Emergency 1 that reads:

Seismic instrumentation is installed at the plant (Emergency Plan 12.3.9.5.2.1, pg 12.3-176). In the event of an earthquake the traces will be analyzed off-site to determine the level of the earthquake (i.e. OBE or SSE) for post-emergency assessment.

ECC 17 was unclear as to what " confirmed high radiation e.

levels" are when the Steam Jet Air Ejector Monitor (R-15) goes off-scale and the Steam Generator Blowdown Monitor (R-19) has a large increase. These two monitors provide a degree of redundancy and they would be an indication of high radiation levels. Therefore, we will eliminate "and confirmed high radiation levels" from ECC 17, Alert 2.

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f.

For Alert 4 of ECC 14, your staff asked us to clarify the wording for " leak rate above the Technical Specifications" l

It would be difficult for an operator to determine the exact leak rate. To make it more easily understood, we will change it to read:

4.

Primary Coolant leak rate is too high for one charging pump to maintain level in pressurizer above 22%.

Also, in ECC 14, General Emergency Ic, "High potential for loss of containment integrity" was unclear. To clarify it we will add "(ie. containment pressure is 9 psig and increasing)" to the end of the statement. Accident analyses of the ice condenser containment show that the pressure for a large LOCA should peak at approximately this value and then dec,rease. Hence, an increasing pressure above this value would be considered a high potential for loss of containment integrity as far as emergency response is concerned.

III. Evacuation Time Estimates Your staff could not locate these estimates in the Cook Plant Emergency Plan. The Berrien County Emergency Operations Plan was referenced in our plan in Section 12.3.11.7 on page 12.3-223. The County Plan includes evacuation time estimates. We do not feel that these evacuation time estimates should be included in our Emergency Plan since this reference is already provided in the appropriate Plan.

IV.

Training Your staff pointed out that the training program for security; repair and damage control; ambulance and rescue; and local civil defense or local sheriff personnel did not seem to be addressed in the plan. The training programs for these groups are covered by our Emergency Plan Implementing Procedure PMP 2082 EPP 006. The Emergency Plan references the emergency procedure for the training of the ambulance and rescue personnel in Section 12.3.13.2 of the plan.

Training of repair and damage control, security and local sheriff personnel vill be covered in the plan by adding to Section 12.3.15.1 a brief discription of this training program.

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