ML20028B590
| ML20028B590 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities |
| Issue date: | 11/08/1982 |
| From: | Rausch T COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20028B587 | List: |
| References | |
| 0389N, 389N, NUDOCS 8212030056 | |
| Download: ML20028B590 (3) | |
Text
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C ~ Addrtss RIply to: P:st Offica Box 767 Chicago Illinois 60690 Novembe r 8, 1982 l
Mr. Jame s G.
Keppler, Regional Administrator 4
Directerate o f Inspection and En forcement -
Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137
SUBJECT:
Problems Identified During the
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August 24, 1982 Emergency Preparedness Exercise at the Quad-Cities bbclear t
Generating Station (NC IR Nos.
50-254/82-14 and 50-265/82-16 NRC Docket Nos. 50-254 and 50-265
REFERENCE:
J.
G. Keppler letter to Cordell Reed dated September 30, 1982.
Dea r Mr. Keppler :
)
The purpose of this letter is to provide a description of i
actions being taken to resolve the problems identified in paragraph 5 o f Inspection Report Numbers 50-254/82-14 (DEPOS) and 50-265/82-16 (D E POS).
j 1)
Failure to evacuate non-essential personnel a f ter declaration o f a Site Area Emergency.
1 For the near term, a memorandum will be issued by December 1,1982 to all Recovery Managers and Station Directors stating that site evacuation of non-essential personnel will be implemented for any Site Area or General Emergency unless unusual conditions such as severe weather, security threat, or radiological conditions prohibit evacuation.
For the long term, GSEP and EPIP's will be appropriately j
revised to reflect this policy.
2)
Last minute changes, technical inadequacies, and lack of suf ficient operational data in the exercise scenario.
Two important steps are being taken to improve the scenarios:
a)
Examples of scenarios deemed adequate by the NRC Region III staf f have been obtained and reviewed i
by our corporate emergency planners.
In lieu o f any regulatory guidance provided in this area, these " acceptable" scenarios will be used to aid our planning ef fort.
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J. G. Keppler Novembe r 8, 1982 b)
Additional corporate emergency planning positions have been budgeted for 1983 which should provide sufficient personnel to allow scenario development for more than one site at a time.
(Ourrent planning schedules initiate scenario development approximately three months prior to an exercise and include at least one licensed person from the station to generate the necessary plant operational data.
The increasing complexity of exercises has shown this amount of time to be inadequate.)
These actions along with active participation by NRC staff at scenario planning meetings should minimize scenario deficiencies and last minute changes.
3)
Failure o f o f f-site teams to utilize procedures.
An improved training program for o f f-site environmental team members has been under development during 1982 for implementation during 1983.
This program will place increased emphasis on content of emergency procedures.
As an interim measure, a memorandum will be issued by December 1, 1982, to all station personnel who supervise and participate as off-site team members, instructing them to review procedure EG-3 which emphasizes the importance of using this and related procedures during field team activities.
4)
Delay in transmission o f emergency status to o ff-site agencies.
Part of the delay in notification was due to a misunder-standing of when the "15 minute" clock starts and stops.
It is apparent now, a f ter clarification by NRC s taf f, that an inappropriate time was being entered on the NARS form by the utility personnel and consequently was being used as the start time.
Our understanding o f the NRC's position is that the clock starts when the emergency has been properly classified, including recommending protective actions.
The time previously being used had either been when the event occurred or when the TSC was in.brmed o f the event.
If a clarification of the NRC's position could be provided to State and local agencies, it would aid in their understanding o f this issue.
Another source of delay was that the NARS code being used for notification only contacted IESD A and IDNS; the Iowa O f fice o f Disaster Services was not included.
Th e N ARS code which has 10DS on it only included IESD A and not IONS.
J.
G. Kepple r Novembe r 8, 1982 This NARS code has been expanded to include IDNS and will be used for simultaneous notification of the three principal Illinois and Iowa state agencies.
Please address any questions you may have concerning this matter to this o f fice.
Very truly yours, h Wf
'**'**d e
Thoma s J. Raus ch Nuclear Licensing Administrator RAF/pa p/im cc: Region III Inspector - Quad Cities Brian Grimes, Director, Div. o f Emergency Preparedness O f fice o f In spection and En forcement, USNRC 0389N