ML20028D104
| ML20028D104 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 12/13/1982 |
| From: | Hunter R INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20028D100 | List: |
| References | |
| AEP:NRC:0754, AEP:NRC:754, NUDOCS 8301170088 | |
| Download: ML20028D104 (10) | |
Text
.
lNDIANA & MICHIGAN ELECTRIC COMPANY P. O. BO X 18 BOWLING GR EEN ST ATION NEW YORK. N. Y.10004 December 13, 1982 AEP:NRC:0754 Donald C. Cook Nuclear Plant Unit Nos. I and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 IE INSPECTION REPORT NOS. 50-315/82-18 (DEPOS);
50-316/82-18 (DEPOS)
Mr. James G. Keppler, Regional Director U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region III Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
This letter and its Attachment respond to your letter of November 15, 1982 which transmitted IE Inspection Report Nos. 50-315/82-18 (DEPOS) and 50-316/82-18 (DEPOS).
The Attachment to this letter contains the responses to the
" Exercise Weaknesses" (Appendix A to the Report) noted by your staff during the annual Emergency Plan Exercise conducted on October 21, 1982.
While not specifically indicated as a weakness in Appendix A to the Inspection Report, we have taken steps to enhance the Recovery and Control Manager's communication with the assessment group by installing a window in the AEP conference room. This window, when completed, will permit the Recovery and Control Manager (RCM) and his staff to view the status boards and activities in the operations area of the EOF. This i
modification will address the comment made in paragraph 4.C of the
" Details" section of the Report.
l This document has been prepared following Corporate procedures which incorporate a reasonable set of controls to insure its accuracy and completeness prior to signature by the undersigned.
i Very truly yours, B301170088 830112 g
PDR ADOCK 05000315
^"r G
, S. Hunter Vice President RSH/ sag Attachment cc: Attached DEC 1 7 I98Z t
j Mr. J. G. Kepper 2
AEP:NRC:0754 cc: John E. Dolan - Columbus M. P. Alexich R. W. Jurgensen W. G. Smith, Jr. - Bridgman R. C. Callen G. Charnoff NRC Region III Resident Inspector - Bridgman l
i I
i
(
J 6
ATTACHMENT TO AEP:NRC:0754 This attachment lists the Exercise Weaknesses identified in the Donald C. Cook Nuclear Plant annual smergency plan exercise inspection conducted on October 21, 1982 and the actions that the licensee has taken to improve each item identified in Appendix A to the inspection report.
NRC COMMENT "1.
Workspace in the TSC cachnical support room is still inadequate."
RESPONSE
Indiana & Michigan Electric Company acknowledges that the D. C. Cook TSC is smaller than specified in the NUREG 0696 guidelines and that the size of our TSC places work space at a premium.
Accordingly, we appreciate your willingness to allow use of office space designated specifically for NRC use. We will re-evaluate the use of existing space within the Technical Support Center to maximize the efficient use of the existing facility.
It is our intention to incorporate the use of the designated NRC space within the operating area of the TSC by March 31, 1983.
NRC COMMENT "2.
Status boards in the TSC communication's room are not readily visible to decision makers in the technical support room and should, therefore, be provided in both rooms."
RESPONSE
A re-evaluation on the use of status boards is underway, as discussed in Item 3 below. Upon resolution of Item 3, it is expected that any l
safety equipment status boards utilized will be provided in the TSC communications room, TSC l
technical support room and in the EOF.
This item will be completed in accordance with the response to Item 3 below.
s-m-
2 l.
l NRC COMMENT i
"3.
Reactor equipment status boards in the TSC and the EOF are inadequate. Protective measures status boards are not available in the TSC and EOF."
RESPONSE
Our status board was developed as an aid for our communicators in responding to the status of ECCS equipment. The board is primarily concerned with the status of electrical power and large equipment driven by electrical power, such as ECCS pumps.
Our " Exhibit B" (copy attached) was developed to substitute for the PSSD until the PSSD was operational and provides plant specific information. This exhibit is distributed to all emergency response personnel, requiring a copy, in the TSC and EOF at regular intervals. A similar technique of distributing printed data derived from the PSSD is intended to be used upon completion of the PSSD.
We have considered up to this point that " Exhibit B" provides more detailed plant specific data to the emergency response personnel than would be available from a status board. This exhibit is augmented by the status board containing information on the availability of major pieces of reactor plant equipment.
We acknowledge your recommendation, however, and will investigate the possibility of improving the dissemination of plant specific data.
It is our intention to review this item considering the following Cactors:
The use and information of status boards.
l The use and function of " Exhibit B" and the PSSD information display.
The information distribution method with regard to the use of personnel.
The available space in the TSC and EOF for status boards and personnel SLn11arly, the use of the protective measures status board versus " Exhibit C" (copy attached) will be re-evaluated.
The evaluation of the concerns discussed above is expected to be completed by March 31, 1983, and changes identified by the evaluation implemented by June 30, 1983.
3 i
NRC COMMENT "4
Procedure PHP 2081 EPP.022 does not require the EOF Recovery and Control Manager to formally approve protective action recommendations or changing recommendation messages prior to their release to offsite authorities."
RESPONSE
The procedure will be revised to require the EOF Recovery and Control Manager to formally approve changes to protective action recommendations prior to their release.
This change will be completed by January 31, 1983.
NRC COMMENT "S.
The present procedure for formulating protective action recommendations does not provide for incorporating evacuation time estimates into the decision-eaking process."
RESPONSE
Our protective action recommendation-making procedure will be modified to facilitate making recommendations for off-site actions. The changes will include provisions for using the existing estimates of the time required to take possible off-site protective actions.
This item is expected to be completed by March 31, 1983.
NRC COMMENT "6.
A status board displaying current personnel assign-ments in the emergency organization is not available in the EOF, Position title name tags are not availa-l ble at work locations in the EOF. The county map in the EOF dose assessment area is not labeled to include sector nomenclature."
RESPONSE
A listing of AEP-ERO personnel (i.e, upon full EOF activation) assigned to the EOF and their function will be maintained.
Since this listing will primarily be used by representatives of off-site response groups not thoroughly familiar with the individuals within the AEP organization, copies will be distributed and updated as necessary.
4 Position / title tags will be provided at EOF work stations. This provision of position / title tags also performs the function of identifying personnel assignments and compliments the personnel listing discussed above.
We will provide labels, including sector nomenclature, on the county map located in the EOF dose assessment area.
Labeling of the county map, provision of position /
title tags and the personnel status sheets will be completed by March 31, 1983.
NRC COMMENT "7.
The container used to transport a primary reactor 1
coolant sample is inadequately shielded."
RESPONSE
An analysis was performed to determine shielding required on the sample container. The result of our calculations indicated that a new sample container with a 2" shield would afford adequate protection.
A new sample container with a 2" shield will be l
available by March 31, 1983.
NRC COMMENT "8.
Prior to sampling, no radiation exposure assess-ment of the primary coolant sample was provided to the sampling team."
RESPONSE
This item is correct in that no exact exposure assessment was given to the sampling team. The team was, however, briefed as to possible Plant conditions and the potential for high activity samples. Prior to dispatching the sampling team from the Operational Support Area (OSA), the Chemical Supervisor at the OSA was in direct communication with the TSC and was aware of all Plant conditions that might affect sampling.
i It is our intention to provide all available I
information to the post-accident sampling team prior to their being dispatched to the sampling area. In response to the identified weakness, we will include in the briefing a best estimate of the primary coolant dose rate value.
A procedure will be developed to relate known 1
5 plant paramoters that could affect the primary coolant system with an estimate of possible fuel damage and dose value of primary coolant sample.
This procedure will be developed by May 31, 1983.
NRC COMMENT "9.
Procedure PHP 2081 EPP.012 does not provide for plume mapping in the vicinity of established survey points. Due to the numerous variations in terrain elevation within and near the property line, mapping techniques are necessary for obtaining measursments representative of the area around these points."
RESPONSE
Plant Emergency Plan Implementing Procedure PMP 2081 EPP.012, (Off-Site Radiological Monitoring) describes in paragraph 3.7 the procedure to be utilized by the monitoring teams when obtaining plume survey data and samples. The procedure requires the team to traverse the plume in a crosswind direction to determine the maximum ar/hr reading and record that 1
information on the designated form. This step in effect identifies the centerline of the plume and can provide, if required, off centerline doses relative to the area being monitored. The " plume mapping" technique described in the procedure is considered adequate to provide the required information on offsite survey monitoring.
The monitoring team performing the offsite surysy on October 21, 1982 did not perform the survey in accordance with this procedure. The team has been reinstructed on proper off-site monitoring require-ments. Performance of proper off-site monitcring surveys is part of the normal radiation protection training program.
NRC COMMENT "10. Inadequate plume monitoring techniques for air sampling were demonstrated during the exercise.
Beca/gansna versus gamma measurements with a thin window detector were not made to ensure that l
representative air samples were taken of the plume I
a tmo sphere. "
6 e
l
RESPONSE
Procedure PMP 2081 EPP.012 (Off-Site Radiological Monitoring) will be revised to incorporate the use of beta-sensitive instruments in release plume monitoring.
This item will be completed by March 31, 1983.
t i
I
(
l 1
m
TECHNICAL INFORMATION SHEET PMP 2081.EPP.020 EXHIBIT B D. C. Cook Unit No:
__ Data Taken By Date Time RCS PARAMETER 1.
RWST Level 2.
Containment Pressure PSIG 3.
Containment Sump Level 4.
Containment Level 5.
BIT Flow LPI GPM LP2 GPM LP3 GPM LP4 GPM 6.
SI Flow North GPM South GPM 8.
RER To CTS Flow East GPM West GPM 9.
CTS East (ON OFF
)
West (ON OFF
)
10.
RCP Status LP1 (ON OFF
) LP2 (ON OFF
)
LP3 (ON OFF
) LP4 (ON OFF
)
11.
RCS Press.
PSIG + t 4 12.
PZR Level
%+t+
13.
PZR Liquid Temp.
- F 14.
PZR Steam Temp.
- F 15.
PZR Backup Htrs. (ON OFF
)
16.
PZR Cycling Htrs. (ON OFF
)
l 17.
Charging Flow GPM 18.
Letdown Flow GPM NSSS LOOP PARAMETERS Loop 1 Loop 2 Loop 3 Loop 4 19.
Wide Range T
- F
- F
- F
- F 20.
Wide Range F
- F
- F
- F C
21.
S/G Pressure PSIG PSIG PSIG PSIG 22.
S/G N.R. Level 23.
S/G W.R. Level 0
24.
Steam Flow (pph X 10 )
25. Feed Flow (pph X 10 ) 3 26.
Aux. Feed Flow (pph X 10 )
27.
MSIV Status (OP CL
)
(OP CL
)
(OP CL
)
(OP CL
)
28.
CST Level Ft.
DOSE PARAMETERS SPECIAL NOTES OR DATA 29.
R-2 Contain. Area R/Hr.
30.
R-11 Contain. Part.
CPM 31.
R-12 Contain. Gas CPM 32.
R-33 Gland Exh. Vent CPM 33.
R-15 Air Ejector Vent CPM 34.
R-26 Vent Stack Gas CPM 35.
Vent Flow CFM 36.
GSLO Flow CFM 37.
Wind Speed MPH 39.
Wind Direction
- (From) 40.
Air Temp. AT
'C Data Verified By Page 6 of 7 Revision 1,
i ACCIDENT INFORMATION REPORTING DATA SHEET PMP 2081 EPP.020 EXHIBIT C D.C. Cook Unit Date Description of Event Prognosis For Termination or Worsening l
Classification:
Unusual Event Alert Site Emergency General Emergency Injured Personnel: Yes, Number
, No Radioactivity Contaminated:
Yes No Estimated Duration of Release 55555555555555555555555555555555555555555555555555555555555555555555555555555555555555555 Basis for Projected Dose Calculation i
(
Source Term for Calculation Flow for Calculation Monitor Reading Measurements
___ I!,ger Limit of Monitor Range Upper Limit on Containment Dose Rate 6" from Effluent Pipe Leak Rate Sample Time Flow Obtained Time Source Tern Obtained Measured Dose Rate Time of Measurement Dose Rate Location of Measurement Iodine Conc.
Meteorological Conditions:
Wind Speed (mph)
Wind Direction: From To Stability Class:
AT Pasquill Cat.
A B C D E F Precipitation:
Yes No Release Rate: Total Gas Ci/sec Release Height: Ground Level Projected Dose At:
Site Boundary 2 Miles 5 Miles 10 Miles Dose Rate, Whole Body, R/hr
- Integrated Dose, Whole Body, R Dose Rate, Thyroid, R/ar
- Integrated Dose, Thyroid, R Sectors Affected
- Integrated from the time of initial calculation to end of projected release.
Calculation Performed By Time Input Verified By 55555555555555555555555555555555555555555555555555555555555555555555555555555555555555555 Support Requested From State or County Agencies:
Yes No TYPE Recommended Emergency Actions For State or County Agencies Page 7 of 7 Approved for Release:
Time:
Revision 1,
--