ML20038B605
| ML20038B605 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 10/27/1981 |
| From: | Bores R, Desrosiers A, Gallina C, Eva Hickey, Kevern T, Markeg E, Mckenna T, Mojta M, Wojnas E Battelle Memorial Institute, NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20038B570 | List: |
| References | |
| RTR-NUREG-0654, RTR-NUREG-654, TASK-2.B.3, TASK-2.F.1, TASK-TM 50-286-81-05, 50-286-81-5, NUDOCS 8112080429 | |
| Download: ML20038B605 (72) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
50-286/81-05 Docket No.
50-286 License No. DPR-64 Priority Category C
Licensee:
Power Authority of the State of New York P. O. Box 215 Buchanan, New York 10511 Facility Name:
Indian Point Nuclear Power Plant Unit 3 Appraisal at:
Buchanan, New York Appraisal conducted: M
'1-15, 1981 fo))?k/
Team Members:
,94W Edward J. Wtrinas, ' Radiation Specialist, NRC dite ' signed Appraisal Team Leader Y
bk lobs 7hl Marie 7. Mojta, Rad 3htion Specialist (Intern) NRC dite ' signed Aclhh
/o 27$l
/
Thomas J. McKenna, EPLB, Nfg HQ date signed N/3?/h/
W Thomas A. Kfvern,'EPLB,idRC HQ date sighed wal 4/ h
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Arthur E. DerJP6siers', Batt611e Laboratories dat'e signed a
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$ 11e Lap 6ratories date signed 4
INa E. Hickey V B 0
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<0l21fAJ Dr. C. Gallina/ Einergency Planning Coordinator, dite / signed RC Ad h
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' Earl Mar
, Meteoro gi if, NRR, NRC da'te sign' d e
Approved by:
,Egl./
/0A2///
Or. Robert J. BofeA,' Ph]).', Acting Chief, date signed Emergency Prephfedness Section O!$$$$6 PDR
t TABLE OF CONTENTS Page
SUMMARY
vi 1.0 ADMINISTRATION OF EMERGENCY PREPAREDNESS..................
I 1.1 Responsibility Assigned..............................
I 1.2 Authority............................................
1 1.3 Coordination.........................................
2-t 1.4 Selection and Qualification..........................
2 2.0 EMERGENCY ORGANIZATION....................................
3 4
2.1 Onsite Organization..................................
3 i
2.2 Augmentation Organization............................
4 3.0 EMERGENCY PLAN TRAINING / RETRAINING........................
6 q
3.1 Program Establishment................................
6 3.2 Program Implementation...............................
8 4.0 EMERGENCY FACILITIES AND EQUIPMENT........................
9 i
4.1 Eme rg e n cy Fa c i l i t i e s................................
9 4.1.1 Assessment Facilities......................
9 4.1.1.1 Control Room.....................
9 i
4.1.1.2 Technical Support Center (TSC)...
9 l
4.1.1.3 Operations Support Center (OSC)..
11 4.1.1.4 Emergency Operations Facility (E0F)............................
11 4.1.1.5 Post-Accident Coolant Sampling and Analysis.....................
13 4.1.1.6 Post-Accident Containment Air Sampling and Analysis............
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Table of Contents i
Page 4.1.1.7 Post-Accident Gaseous and Particulate Effluent Sampling and Ana!ysis.....................
16 4.1.1.8 Post-Accident Liquid Effluent l
Sampling and Analysis............
17 4.1.1.9 Offsite Laboratory Facilities....
18 4.1.2 Protective Facilities......................
18 l
4.1.2.1 Assembly / Reassembly Areas........
18' 4.1.2.2 Medical Treatment Facilities.....
19 L
4.1.2.3 Decontamination Facilities.......
20 4.1.3 Expanded Support Facilities................
20 I
4.1.4 News Center................................
21 1
4.2 Emergancy Equipment..................................
21 4.2.1 Assessment Equipment.......................
21 4.2.1.1 Emergency Kits and Portable Instrumentation..................
21 4.2.1.2 Area and Process Radiation 22 Monitors.............
4.2.1.3 Non-Radiation Process Monitors...
23 4.2.1.4 Meteorological Instrumentation..
23 4.2.2 Protective Equipment.......................
25.
4.2.2.1 Respiratory Protection...........
25 4.2.2.2 Protective Clothing..............
25 4.2.3 Emergency Communications Equipment.........
25 4.2.4 Damage Control, Corrective Action and Maintenance Equipment and Supplies.........
26 4.2.5 Reserve Emergency Supplies and Equipment...
27 4.2.6 Transportation............................
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0 Table of Contents Page 5.0 PROCEDURES...................
28 5.1 General Content and Format...........................
28 5.2 Emergency, Alarm and Abnormal Occurrence Procedures..
28 5.3 Implementing Instructions..........................
30 5.4 Implementing Procedures..............................
30 5.4.1 Notifications.............................
30 5.4.2 Assessment Actions.........................
31 5.4.2.1 Offsite Radiological Surveys.....
33 5.4.2.2 Onsite (Out-of-plant)
Radiological Surveys.............
34 5.4.2.3 In plant Radiological Surveys....
34 5.4.2.4 Post-accident Primary Coolant Sampling.........................
35 5.4.2.5 Post-accident Primary Coolant Analysis..........
36 5.4.2.6 Post-accident Containment Air Sampling.....................
37 S.4.2.7 Post-accident Containment Air Sample Analysis..................
38 5.4.2.8 Post-accident Gaseous and Particulate Effluent Sampling.....
40 5.4.2.9 Post-accident Gaseous and Particulate Effluent Sample Analysis.........
41 5.4.2.10 Liquid Effluent Sampling.........
41 5.4.2.11 Liquid Effluent Sample Analysis..
42 5.4.2.12 Radiological Environmental Monitoring Program (REMP).......
42 iii i
l
______--__-----------_-----------_--------_-------_-____---------_----J
r Table of Contents Page 5.4.3 Protective Actions.........................
43 5.4.3.1 Radiation Protection During Emergencies......................
43 5.4.3.2 Evacuation of Owner Controlled Areas...............
44 5.4.3.3 Personnel Accountability.........
44 5.4.3.4 Personnel Monitoring and Decontamination..........
45 5.4.3.5 Onsite First Aid / Search ~
46 and Rescue.......................
5.4.4 Security During Emergencies...............
47 5.4.5 Repair and Corrective Actions.............
47 5.4.6 Recovery......................
48 5.4.7 Pub'ic Information........................
48 5.5 Supplementary Procedures........
49 5.5.1 Inventory, Operational Check and Calibration of Emergency Equipment, Jacilities and Equipment...
49 5.5.2 Drills and Exercises......................
50 5.5.3 Review, Revision and Distribution of Emergency Plan and Procedures..............
51 5.5.4 Audits of Emergency Preparedness...........
51 6.0 COORDINATION WITH OFFSITE GROUPS....................
52 6.1 Offsite Agencies.
52 6.2 General Public...................
53 6.3 News Media.................
54 iv
Table of Contents Page 7.0 DRILLS, EXERCISES AND WALK-THROUGH3.......................
55 7.1 Drill and Exercise Program Implementation............
~55 7.2 Wa l k-Th ro ug h Ob s e rva t i o n s............................
55 7.2.1 Emergency Detection (EAL Recognition)......
55 7.2.2 Emergency Classification...................
56 7.2.3 Notifications..............................
56 7.2.4 Dose Calculations..........................
57 7.2.5 Post-accident Coolant Sampling and 59 An a l y s i s...................................
7.2.6 Post-accident Containment Air Sampling and Analysis...............................
61 7.2.7 In plant Radiciodine Sampling and Analysis...................................
62 7.2.8 Protective Action Decision-Making..........
63 Individuals Contacted 64 y
i
\\:
SUMMARY
The appraisal of the state of onsite Emergency Preparedness at Indian Point 3 involved seven general areas:
Emergency Organization; Emergency Training; Emergency Facilities and Equipment; Procedures Which Implement the Emergency Plan; Coordination with Offsite Agencies; and, Walk-throughs of Emergency Duties The Indian Point 3 Emergency Preparedness Program was developed by individuals in the corporate office, as well as individuals at the site.
In general, it appears that the coordination between these two entities was good, with the exception of the interface between the corporate office and the Plant Operations Manager.
The emergency organization was well-defined and'the training program was found to be generally adequate but required formalization.
Emergency facilities and equipment were for the most part satisfactory, however, deficiencies were noted in several areas, including the lack of adequate work space in the Emergency Operations Facility and preparation of the news media center.
Procedures which implement the emergency plan were generally adequate, however, deficiencies were identified in several areas, including post-accident sampling and analysis, storage, sampling and release of liquid waste, Emergency Action Levels and communication of protective action recommendations to local officials and the public; Observation and questioning of selected individuals during walk-throughs of their assigned emergency tasks and functions indicated that the individuals were aware of their assignments and their part in the emergency organization and were able to perform effectively in spite of some procedural shortcomings.
The auditors concluded that the licensee appeared to be capable of responding to and managing the response to an accident at Indian Point 3.
vi i
1.0 ADMINISTRATION OF EMERGENCY PREPAREDNESS-1.1 Responsibility Assigned The Superintendent of Radiological and Environmental Services is the individual formally designated at the site as the Emergency Planning Coordinator. The Assistant to the Superintendent of Radiological and Environmental Services, although not formall/ designated in the Emergency Plan, is the individual charged by plant management with the responsibility of developing and implementing the Emergency Plan. There are two Nuclear Emergency Preparedness Engineers at the corporate level to assist the site Emergency Planning Coorainator.
4 The Assistant to the Superintendent of Radiological and Environmental Services spends approximately 95% of the available time on Emergency Planning functions. One additional person for the Emergency Planning Section has been allocated and budgeted.
Recruitment is in progress to fill this position.
Other departments / organizational entities are assigned responsibilities for maintaining different parts of the response capability. These assign-ments are made in the implementing procedures.
Examples include, Health Physics for instrumentation and performance checks, Technical Services Performance and Reliability for alarm testing, corporate for County and local government-interface, and Consolidated Edison of New York, Inc.
(Con Ed) for environmental and common facilities used under Memorandum of Understanding (MOU) No. 28 between PASNY and Con Ed.
Individuals in management and professional staff at the site, who were interviewed, knew who was responsible for emergency planning.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
1.2 Authority Section 8.1 of the Emergency Plan assigned the responsiblity and authority for Emergency Planning. Based on discussions with personnel responsible for emergency planning and with management, the former appeared to receive management support when exercising their authority.
Personnel responsible 4
for emergency planning report formally to the Superintendent of Power, but informally have direct access to the plant manager.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
2 1.3 Coordination Routine coordination events such as PORC meetings, budget input, and outage scheduling involve personnel responsible for emergency planning.
Budget requests for emergency planning have received both site and corporate support. There appears to be coordination with and between all licensee organizations in the areas related to emergency planning.
The interaction between site and corporate individuals is. depicted in Figure 5-3 of the Emergency Plan.
However, the illustrated site emergency.
response organization conflicts with the described corporate interface.
In the depicted site organization the Plant Operations Manager reports to the Emergency Director, while in the description of the corporate organiza-tion this individual reports to the Recovery Manager with information-being provided to the Emergency Director. Clarification of the interface between the corporate and site structure as it pertains to the Plant Operations Manager is needed.
(See also Section 2.1)
The site and corporate 4. formation officers were assigned responsibility during emergency conditions for coordination of release of information between the licensee and offsite groups, for the general public and news media. These responsibilities were documented in the Emergency Plan on page 5-4, para. 9, and page 5-20, para. 5.2.2.
Based on the above findings, this portion of the licensee's program appears to be acceptaole, but the following matter should be considered for improvement:
Clarification of the interface between the corporate and site emergency organizations as they pertain to the Plant Operations Manager.
(286/81-05-01) 1.4 Selection and Qualification Selection criteria were established for the personnel responsible for emergency planning using exempt position descriptions.
The Radiological and Environmental Services Superintendent appeared to meet the position description criteria, having been at the site in a technical capacity since June, 1964. The Assistant to the Superintendent of Radiological and Environmental Services, the person directly responsible for emergency planning, has been at the site in the capacity for approximately one year. Although this individual's background and training har been in meteorology, the apparent dedication, and overall grasp of the emergency planning requirements appeared to make up for the lack of experience in this area. Professional level courses in emergency planning have been attended by the individual since assuming the position.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
3 2.0 EMERGENCY ORGANIZATION 2.1 Onsite Organization Licensee personnel who may be assigned to the various functional areas of emergency activities were specified on page vii of the Emergency Plan, "IP-3 Emergency Response Organization", by position or title, down to the working level. The descriptions of these personnel and functions were consistent within the various documents and with the actual organization, including:
Emergency Response Coordination, Plant Systems Operation, Operational Accident Assessment, Radiological Environmental Survey and Monitoring, First Aid / Rescue, Personnel Monitoring, Decontamination, security of Plant and Site Access Control, Repair / Corrective Actions, Personnel Accountability, Radiological Accident Assessment,-Communications, Radiation Protection, Plant Chemistry, Radwaste Operations, Technical Support, Manpower Planning and Logistical Support, and Public Information.
The description of the designated management structure for the previously mentioned functional areas were included in the Emergency Plan and Implemen-ting Procedures. There were provisions in the plan to ensure that an emergency coordinator, the Emergency Director, is available on site at all times, having the authority and responsibility to initiate any emergency actions within the provisions of the Emergency Plan, including the exchange of information with authorities responsible for coordinating and implementing offsite emergency measures and the recommendation of protective actions.
Lines of succcession for the Emergency Director position and the management structure for the various functional areas were specified on page 5-10, Figure 5-2, "IP-3 Emergency Response Organization", of the Emergency Plan.
Selection criteria were established for use in assigning individuals to the various functional areas of emergency activity.
The individuals assigned to the various functional areas of emergency activity met the selection criteria or have work experience in the types of duties assigned.
The interfaces between and among the onsite functional areas of emergency activity vare clearly shown on organization chart Figure 5-10 of the Emergency Plan, and, as determined through interviews with selected assigned individuals, were understood by the individuals assigned to the emergency organization.
The auditors determined through discussions with the licensee and review of the staffing plan that the chemistry department had an authorized strength of 12 technicians but was staffed at the 6 technician level during the period of the appraisal.
The auditors, determined through discussions with the licensee and review of the emergency organization that the shortage of chemistry technicians (50% of authorized strength) during an accident would not impact on accident mitigation actions.
4 The licensee did not have a designated oncall TSC Manager within 30 to 60 minutes reporting time of the site although there are 17 personnel on the TSC call list. There was no organization chart for the staff of the Technical Support Center and none of the five senior personnel on the TSC call list were designated as TSC Manager.
The auditors were told by the Assistant Radiation and Environmental Services Superintendent that the organization of the TSC would be roughly equivalent to that of the Technical Services Department.
The Emergency Operations Facility (EOF) had call lists which identified the people who had Emergency Director training, however, none were oncall to assume the position of Emergency Director..The licensee's organizational configuration with the EOF at the Service Center appeared to be adequate for effective NRC interface.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered
~
for improvement:
Provisions for an oncall TSC Manager at all times.
(286/81-05-02)'
2.2 Augmentation of Onsite Emergency Organization Corporate personnel who will augment the onsite emergency organization are specified in Section 5.3.2.1 of the Emergency Plan and in the Interim Corporate Emergency Plan, IEP 5.3.1, dated 3/28/80, by position or title for each of the following areas:
Emergency Response Coordination, Opera-tional Accident Assessment, Radiological Accident Assessment, Radiological Environmental Survey and Monitoring, Health Physics, Technical Support, Manpower and Logistical Support, Public Information, Dosimetry and Measure-ments.
The corporate officials selected to augment the site emergency organization have site-specific work experience in the types of duties to which they have been assigned. Most have worked at the site pric. to joining the corporate structure and are familiar with their assigned functional areas.
The licensee's Emergency Plan does not include provisions for augmenting the onsite emergency organization in the area of health physics staff beyond 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> under accident conditions.
In discussions with the auditors, the licensee proposed to use contractor and Consolidated Edison personnel, to complement the onsite emergency organization, however, no letters of agreement existed for contractors. Memorandum of Understanding No. 28, dated April 2,1981, between the Power Authority of the State of New York (PASNY) and Consolidated Edison provided the vehicle for resource augmentation of the site that has had an accident by the unaffected site.
Letters of agreement between the site and private organizations (e.g.,
Verplanck Fire Protection Association-Ambulance and Fire, Buchanan Engine Co. No. 1, New York State Police, Peekskill Community Hospital, etc.) who
5 may be requested to assist are. included in the Emergency Plan..The auditors determined that the licensee has not yet demonstrated through a drill that the minimum augmentation specified in NUREG-0654, Rev. 1, Table B-1 could be accomplished within the 30-60 minute requirement.
Table 5-1, page 5-7 of the Emergency Plan specifies the minimum staffing for emergencies of onshift personnel and additional staffing.within 60 minutes, using existing call-in rosters in Appendix A.
The extension of the organizational capability to be provided by local services for handling emergencies is specified in Section 5.3.3, of the Emergency Plan. Also included in Appendix A of the plan are letters of agreement for ambulance, fire fighting, and hospital organizations.
The authorities, responsibilities and limits of the corporate, contractor, private organizations and local services support groups appear to be understood by these groups. The interfaces between the onsite functional areas of emergency activity and the augmentation groups were specified by an organization chart in the Interim Corporate Plan, IEP 5.3.1, and were understc;d by both parties.
Based oa the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
Provisions of written agreements with contractors for health physics staff support for emergency conditions extending beyond 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
(286/81-05-03) i i
i l
4 h
T 6
4 3.0 EMERGENCY PLAN TRAINING / RETRAINING 3.1 Program Establishment i
The licensee's program for training personnel assigned emergency duties and responsibilities was outlined in-Section 8.2.2 of the Emergency Plan.
l
'The Radiological and Environmental Services Department has responsibility for training of the Emergency Directors, Accident Team, Radiological 7
Monitoring / Analysis Team, Repair and Corrective Action Teams, Communications personnel, Accountability Officers, and local support service groups.
1 I-The Radiological and Environmental Service Department had developed an informal procedure that provided for annual (+ 3 months) training of Emergency Director / Plant Operators / Shift Supervisors,_ Technical Support Groups, Operations Support personnel, Radiological Assessment Teams, Accountability Officers, Security, Medical Emergency Personnel and general employees. This procedure (IP-1085) provided for the maintenance of records and written testing. The procedure did not, however, specify how instructors were to be selected and did not provide for retraining of personnel following major procedure revisions or equipment changes.
The Radiological and Environmental Services Department maintained lesson plans,. tests and attendance rosters that demonstrated training had been provided for all the groups identified in the procedure except for Medical Emergency Personnel.
Licensee personnel stated that medical training was currently provided to offsite hospital and ambulance personnel under the MOU No. 28 provision which required Consolidated Edison to supply medical j
support to the licensee.
Licensee personnel stated that they will also provide this training in the future. Training of hospital and ambulance i
personnel was provided by Con Ed just prior to the annual medical drill.
i This was confirmed by the auditors in their review of the 9/26/80 Radiation Emergency Medical Drill scenario.
The licensee stated that watch personnel had received first aid and CPR training even though this training was not-covered by a procedure. Discussions with watch personnel confirmed that the above medical training nad been provided.
The Radiological and Environmental Services Department lesson plans were reviewed by the auditors and found to contain very general training j
objectives. The lesson plans did not specify the training format, but licensee personnel stated that, for the most part, it was given in a 1ecture/ classroom format.
Except for the dose projection area, the given tests were written and did not involve actual use of procedures or equipment.
During this appraisal, the Radiological and Environmental Services Depart-ment Training Procedure IP-1085, was expanded to proiide for instructor qualification review, practical demonstrations, " hands-on" experience where applicable and training on major procedure and equipment changes.
This procedure was also being expanded to include offsite fire response and first-aid. The revised procedure was in the pr'; cess of being reviewed by the Plant Operating Review Committee (PORC) at the close of the appraisal.
I 4
7 The Emergency Plan specified that the licensee's New Tork office was responsible for training of the recovery organization.
Licensee management stated that no training had yet been provided to the recovery organization, however, a program was under development and training of recovery personnel would be completed by July, 1981.
The Emergency Plan also specified that the Security and Safety Department was responsible for fire support training. Quarterly fire fighting training for onsite personnel was required by Procedure FP-6, " Fire Brigade Training". The licensee stated that offsite fire support is required by Technical Specification but was not addressed by these pro-cedures. As discussed above, this area was addressed in the revision of the emergency training procedure, IP-1085.
Training on post-accident sampling and analysis was documented to include a lesson plan and attendance rosters, but was not covered by a procedure.
This training also included a " walk-through".
Licensee public information personnel stated that the local news media were invited to an onsite briefing in 1979, and that any new news media personnel are invited onsite on an going basis. This training for news media was not documented or covered by a procedure, however.
The site emergency procedures indicated that Indian Point Unit 2 reactor operators and HFs may be requested by Indian Point Unit 3, however, no training had been provided to these personnel to enable them to respond effectively to such a request.
Technical Support Center staff had been trained to access data from the plant process computer.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
Development and implementation of an emergency response training program for qualifying individuals and groups who are selected for assignment to each of the various functional areas of emergency activity, including:
(a) medical first-aid, onsite and offsite fire response organiza-tions, post-accident sampling, the recovery organization, other augmentation personnel, and the news media; (b) provisions for training affected individuals in major plan, procedure, facility, equipment or organizational changes; and (c) the means to verify attendee performance against training objectives.
(286/81-05-04)
In addition to the above findings, the following matter should be considered for improvement:
l 8
Designation of emergency preparedness instructor selection and qualification criteria.
(286/81-05-05) 3.2 Program Imole nentation-The Emergency Planning Coordinator stated that the vast majority of the personnel assigned to perform any of the onsite emergency functions had been trained and tested on the new plan and procedures by April 1, 1981.
The training attendance sheets for the Emergency Director and chemistry and radiochemistry support personnel were cross-checked by the auditors against the rosters of personnel assigned to perform these functions during emergencies. The auditors determined that all personnel had received training and had been tested.
In addition, discussions with control room and HP personnel indicated that they had also received training.
Verplanck Fire Protective Association (fire fighting and ambulance), and Peeskill Community Hospital personnel who were contacted by the auditors stated they were satisfied with the training provided by the licensee and that training had been provided both during drills and on a continuing basis.
As discussed in Section 3.1 of this report, the licensee indicated that no training had been provided to members of the recovery organization or to Indian Point Unit 2 personnel who may be required to augment Indian Point Unit 3 staff.
A review of the attendance sheets by the auditors, and discussions with plant personnel indicated that watch personnel had received first-aid and CPR training. Auditor review of attendance records and discussions with chemistry personnel indicated that they had been trained and were required to perform a walk-through on post-accident sampling and analysis.
Auditors' discussions with Westchester Emergency Services personnel indicated that the licensee had provided training to their monitoring teams.
In addition, they indicated that the licensee conducted regular briefings through the Four County Nuclear Task Force of the County chief executives of the four Counties within the plume EPZ. These briefings included protective actions.
Based on the above findings, improvements in the following arecs are required to achieve an acceptable program:
(See item 286/81-05-04 as it pertains to the recovery organization and to Con Ed augmentation personnel.)
)
9 4.0 EMERGENCY FACILITIES AND EQUIPMENT 4.1 Emergency Facilities 4.1.1 Assessment Facilities 4.1.1.1 Control Room The auditors examined the control room on several occasions during the Emergency Preparedness Implementation Appraisal. Copies of the current Emergency Plan and the Implementing Procedures were placed conspicuously on a bookshelf adjacent to the Senior Reactor Operator's desk.
The control room also contained the protective equipment, monitoring equipment, and communication equipment specified in Appendix F of the Indian Point 3 Emergency Plan.
The use of the monitoring equipment, communication equipment, and the meteorological diffusion overlays and maps was tested during a walk-through drill with the control room shift personnel.
The equipment and procedures were found to be operable.
The auditors examined the provisions for communications between Indian Point Unit 2 and Unit 3.
Communication is possible using commercial telephone lines and a direct line between the Indian Point Unit 3 and Unit 2 control rooms. Direct lines also connected the Indian Point Unit 3 control room to the Emergency Operations Facility (EOF) and to the alternate EOF.
In general, communications were adequate.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.1.1.2 Technical Support Center The temporary Technical Support Center (TSC) is located on the third floor of the Administration Building. The permanent Technical Support Center is proposed to be located on the second floor of the same Administration Building. The auditors observed that the route from the temporary Technical Support Center to the control room leads down a corridor within the Administration Building and up a flight of stairs to the Turbine Generator Building. A short walk across the turbine generator deck leads to the door of the control room. The time required to walk between the two rooms is less than cne minute. The difference in time between the present TSC and the proposed TSC would be the time required to descend'an additional flight of stairs. The auditors noted that the plant records storage area was located adjacent to the TSC,
10 Working space in the present Technical Support Center was adequate.
There were 17 technical personnel on the call list.
The auditors estimated that the Technical Support Center contained adequate working space for the 17 people if all were called to the TSC. The space appeared also to be adequate for NRC personnel who would be assigned. However, the Energency Plan and its implementing procedures did not consider the need for administrative and support staff in the Technical Support Center, such as personnel to update status boards, maintain records, pass out dosimetry, moniter habitability, and provide administrative assistance to the TSC Manager.
The licensee had not analyzed the shielding of the present temporary Technical Support Center. Since the Administration Building has four floors, the shielding would consist of the concrete in the floor above the TSC and the shielding thickness of the roof. This shielding would be less than that afforded to the control room.
Likewise, the ventilation system for the Technical Support Center and the filtration of the ventilation system's intake air were not comparable to the control room ventilation system. There was no radiological filtration of the intake air and the ventilation system for the TSC cannot be isolated from the remainder of the building.
However, there was adequate radiological instrumentation to monitor the-habitability of the Technical Support Center. Both the control room and Technical Support Center were equipped with respirators and potassium iodide as well as portable radiation monitors.
The communications for the Technical Support Center were accessible to the staff. The auditors observed that displays of plant system parameters were available in the Technical Support Center on a realtime basis. These data were displayed on a cathode ray tube terminal. The information is obtained by accessing the plant's process computer. The TSC staff may access a total of 20 blocks of parameters from the computer. Each block was provided in realtime and each block could contain approximately 25 parameters.
There was a dedicated telephone which connected the Technical Support Center and the control room at Indian Point Unit 3.
NRC Emergency Notification System (ENS) and Health Physics Network (HPN) telephones had been installed and were available for NRC use.
There were no dedicated communications links between the Technical Support Center and local or State government response agencies. The single outside line in the Technical Support Center was not considered adequate by the auditors for communication with State and local governments.
(See Section 4.2.1.2 of this report.)
The Technical Support Center could communicate with monitoring teams via a radio which is stored in the Security Office on the third floor of the Adminstration Building.
11 Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
Provision of dedicated communication links from the TSC to State and local government response agencies.
(286/81-05-06) 4.1.1.3 Operations Support Center As stated in the Emergency Plan and Implementing Procedure IP-1047, the Operations Support Center (OSC) as located in the lunch room immediately adjacent to the asserrbly area on the first level of the Turbine Generator Building. The OSC was large enough to accomodate over 100 individuals.
The licensee did not provide an estimate of the dose rates which would be expected in the OSC during a design basis accident. However, the licensee had made provisions for a backup facility at the Emergency Operations Facility (EOF) in the event the OSC becomes uninhabitable.
Communication between the OSC, TSC and Indian Point Unit 3 Control Room consisted of the plant page system and dedicated telephone 4
lines.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.1.1.4 Emeroency Operations Facility The Emergency Operations Facility (EOF) for the Indian Point Unit 3 site consisted of a room in the Consolidated Edison Service Center Building. The EOF would be staffed by an Emergency Operations Facility Director, a communicator, and three radiological assessment staff members.
The size of the facility was adequate for a total staff of approximately 7 individuals; including 5 from Indian Point Unit 3, one representative from State government and one representative from one of the affected counties. The available space was determined to be inadequate to accomodate the number of State, local and Federal (including NRC) response officials expected at the EOF.
The licensee suggested that if additional licensee staff members were needed, certain functions could be transferred to the Recovery Center, although this option was not addressed in the licensee's plans and procedures.
The Recovery Center is located in the Consol-idated Edison Simulator Building. This building would be less i
likely to be habitable than the Service Center during a severe radiological emergency and, therefore, less suitable as an Emergency Operations Facility.
In addition, splitting the major functions of the Emergency Operations Facility and housing these functions in separate buildings could significantly impede the functioning of the Emergency Operations Facility as a result of deviating from the organizational structure outlined in the Emergency Plan.
This would also require increased communications capabilities.
. ~ _ - _ _. _
12 l
The Emergency Operations Facility was equipped as stated in the Emergency Plan, Appendix F.
However, the status board in the facility was relatively old and the arrangement of items on the status board did not offer a clear picture of the status of offsite radioactivity or the status of the reactor itself. The licensee indicated that the status board had not been as useful during previous exercises as had been anticipated.
The EOF was equipped with (1) low range beta / gamma survey meters; (2) low range ion chamber survey meters with beta windows; (3) silver zeolite cartridges; (4) samplers for airborne particulates and iodines; (5) a planchet and filter counter equipped with a sodium iodide detector; (6) personnel dosimeters; (7) check sources for the instruments; (8) copies of the Emergency Plan and Implementing Procedures; and (9) a map of the site showing 22 1/2 degree sectors and preselected monitoring points.
The EOF was also equipped with a set of atmospheric dispersion isopleths which were prepared as map overlays. Writing materials, notepads, and a clock were available. The wind speed, wind direction, and atmospheric stability classification were available from both primary and the backup meteorological instrumentation.
First-aid and decontamination supplies were available in the nurse's office in the Service Center.
The EOF was equipped with protective clothing and respirators.
The EOF was equipped with dedicated voice communications with the Technical Support Center, the Control Room, the NRC, State and local agencies, and the field monitoring teams. Commercial telephones were not available, however, for NRC use.
The Peekskill Substation had been designated by the licensee as the Alternate Emergency Control Center (AECC). The AECC was located approximately three miles from Indian Point Unit 3.
The specific area for the AECC was located on the second floor of the substation.
A tour of the facility indicated that the designated area was also too small to accommodate emergency response presonnel. AECC equipment on the checkoff list in Procedure IP-1070 was inventoried and found to be as stated. Consolidated Edison was responsible for performing operability checks on stored equipment. As identified in IE Report No. 50-247/81-01, Section 4.1.1.4, operability checks could not be performed at the AECC because of a lack of check sources. There were no portable air monitors, continuous air monitors or radiation monitors with visual or audio alarms, clock, direct line to the NRC, emergency lighting, State plan, evacuation route overlays, FSAR, nor emergency power for the radio. Additionally, it was noted that a battery charging room was located on the same floor next to the staircase and constituted a possible fire hazard that could block the only exit of the AECC in the event of fire.
r 13 During the appraisal, the Emergency Preparedness Coordinator for the NRC Region I Office of Inspection and Enforcement met with members
~
of the licensee's emergency planning staff and toured the. licensee's emergency response facilities. The Region I. Emergency Preparedness Coordinator also met with members of the appraisal team in order to discuss organizational and procedural considerations relating to the interface of the licensee's_ response organization with that of the NRC.
1 The Region I Emergency Preparedness Coordinator noted that available work space in the E0F, as well as existing telecommunications equipment l
in the E0F and TSC, did not demonstrate adequate licensee interface 1
with the NRC.
(See Section 6.1 of this report.)
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
3 Provisions for sufficient. space in the Emergency Operations Facility (EOF) and Alternate EOF to enable effective direction, coo'rdination and evaluation of all licensee activities during emergency conditions.
(286/81-05-07) 4.1.1.5 Post-accident Coolant Sampling and Analysis i
The auditors reviewed the licensee's implementation of NUREG-0578, 4
paragraph 2.1.8.9 and NUREG-0737, paragraph II.B.3, post-accident coolant sampling and analytical capabilities to verify that the licensee had the ability to obtain and analyze high activity reactor coolant samples during accident situations. The auditors compared the licensee's interim reactor coolant sampling provisions with the i-licensee's response letter dated January 8,1980.
The auditors inspected the sampling location, reviewed the sampling procedures (See Section 5.4.2.4 of this report) and discussed the shielding i
design parameters with the Radiological Engineer, Chemistry Project i
Coordinator, and chemistry and health physics technicians.
The licensee's original design review of the primary coolant sampling laboratory indicated that additional dose reduction was required.
The licensee's response was to extend the piping system through the south wall of-the laboratory into a series of 4" thick lead-shielded enclosures.
The piping valve and shielded enclosure arrangement outside the laboratory would then function as the modified sampling location which would be accessible (i.e., dose rates would not exceed 5 R/hr) under worst case accident situations.
The above design assumed a 2.75 Ci/g primary coolant source as opposed to-10 Ci/g as stated in NUREG-0737.
i 2
14 The use of lead enclosures for the off-line sampling arrangement provided a completely closed system for the sampling and transporting processes. Additionally, a specially designed reach-rod would be used to disconnect the " quick-connects" between the piping and sample vessel. All supplies were readily available in a locker adjacent to the Chemistry Laboratory.
The sampled primary coolant in the sample vessel could then be transported to the 41-foot elevation of the Primary Auxiliary Building (PAB) for analyses in the shielded sample cask. The auditors noted that the system design allowed for flushing the sample piping into a waste sample cask from the sampling room and the sample vessel to reduce radiation fields from the system after use. The licensee also had the onsite capability to obtain six primary coolant samples during an accident sequence.
The auditors determined that the provisions for reducing personnel radiation exposure appeared adequate.
However, because the volume of the sample is on the order of 60 m1, assuming a worst case accident of 10 Ci/g primary coolant (NUREG-0737 criteria), the use of two teams might be considered to limit radiation doses to individuals on the teams.
Like the sampling system, the analytical facility was for the most part a closed shielded system.
Dilutions occur before any microliter or milliliter quantities of primary collant are extracted from the shielded analysis " fort", reducing radiation levels to which personnel are exposed. The analytical facilities appeared to have adequate instrumentation and procedural capability for analyzing the sample for hydrogen, chlorides, boron and fission products.
The auditors reviewed the licensee's shielding de-ign for the analytical facilities and determined that this location would be accessible during accident conditions. The auditors noted, however, that the use of syringe shields should be encouraged to reduce the exposure to the chemistry technicians when withdrawing the one m1 sample for fission product determination.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
Re-evaluation of the primary coolant sampling and analytical facilities for adequacy assuming u 10 Ci/g primary coolant source term.
(286/81-05-08) i
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4 4
l 15 4.1.1.6 Post-accident Containment Air Sampling and Analysis The auditors reviewed the licensee's implementation of NUREG-0578, l
paragraph 2.1.8.a and NUREG-0737, paragraph II.B.3, post-accident sampling and analytical capabilities to verify that the licensee had the ability to sample and analyze high activity containment air samples during accident situations. The auditors inspected the sampling and analytical locations, reviewed the sampling procedures (See Section 5.4.2.6 of this report.) and discussed the shielding design parameters with the Radiological Engineer, Chemistry Project Coordinator and nther licensee representatives.
The original design review of the containment air sampling location indicated that additional dose reduction was required.
In response
~
to guidance in NUREG-0578, the installed containment air sampling locaticn was modified and the sample lines were extended and isolated (containment atm:_ nere sample would return to the containment in a one loop pipe design) to permit sampling at an accessible location under accident conditions.
Four-inch thick lead shielding surrounded the gas collecting compartment, as well as the particulate and iodine filter assembly. Additionally, the area.would be monitored by an HP technician throughout the sampling.
The auditors determined that the post-accident containment air sampling equipment would be accessible during accident conditions.
Personnel would not have to traverse or work in areas of high radiation fields in order to obtain the sample. The design and shielding of the area equipment and stainless steel sampling lines in conjunction with the applicable procedures were such that radiation doses received by the user while collecting the sample would be ALARA. However, lead pigs for transporting the iodine cartridges to the counting facility were not available.
The sample analysis facility would be accessible during accident conditions and the instruments and detectors described in the procedure were in place and calibrated.
The samples would be transferred to the chemistry counting room for analysis.
P Con-Ed facilities would also be available if the Indian Point Unit 3 counting facilities should become inaccessible.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be considered for improvement:
Provision of appropriate shielding for transporting collected containment air samples to the radioanalytical laboratory and provisions for the storage / maintaining of the samples obtained.
(286/81-05-09) y g e
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16 4.1.1.7 Post-accident Gaseous and Particulate Effluent Sampling and Analysis The auditors reviewed the licensee's implementation of NUREG-0578, paragraph 2.1.8.b, and NUREG-0737, paragraph II.F.1, increased range radiation monitors and additional accident monitoring instrumentation, to verify that the licensee had the ability to monitor, sample and analyze high activity gas and particulate effluents during accident situations. The auditors compared the licensee's interim, in place high range effluent monitoring instrumentation with the system described in licensee's letter dated February 3, 1980.
The auditors inspected installed equipment and sampling locations, reviewed sampling procedures (See Section 5.4.2.8 of this report) and discussed post-accident airborne effluent sampling and monitoring with the Chemistry Project Coordinator, Radiological Engineers and Health Physics Supervisor.
The high range effluent monitoring and sampling instrumentation consisted of an ion chamber for noble gas detection (designated RD-17A) and a separate sampling line to the shielded plant vent iodine and particulate sampling system.
The high level noble gas detector was installed adjacent to the plant vent R-13 Particulate Monitor. The exhaust stream from the R-13 monitor would not contain particulates but would be representa-tive of the vent gases from which to infer gas vent releases. The sample lire and monitor were isolated within a three-inch th"ck lead wall enclosure.
Adjacent to the shielded monitor, another monitor (unshielded) was installed to record the background radiation levels.
The auditors noted that the unshielded reading could be related to the shielded monitor reading to minimize inaccuracies related to high level radiation fields in the area of the monitors.
The ion chambers were readout remotely on an Eberline RM-16 readout device. The location on the 55-foot level of the PAB appeared to be accessible during emergency situations.
Engineering calculations were performed to provide a conversion factor the reading (counts 1
per minute) on the instrument to concentration (microcuries/cc) in i
the plant vent.
The auditors noted that the high range vent stack
-7 5
nonitor had the range 10 uti/cc to 10 uCi/cc (for Xe-133) specified in NUREG-0578.
I The location of the vent sampling point for radioiodine and particulates i'
was on the 41-foot elevation of the PAB.
The post-accident sampling system was installed by extending stainless steel tubing 200 feet from the plant vent to a filter paper and silver zeolite collection assembly. The location was determined by the licensee to be the closest possible sampling point to the vent without incurring excessive personnel radiation exposures. To reduce personnel exposure while sampling, the collection assembly was encased using 4 'nch thick lead shields. The sampling system was also designed to incorporate provisions for purging the extended sample line before and after each sample.
17 -
The auditors determined that.the post-accident vent sampling location would be accessable to personnel in order to obtain effluent samples without receiving excessive radiation exposure.
The auditors noted that the area would be monitored by an HP technician for the duration of the sampling process. Necessary' equipment and supplies were readily available from a nearby locker.
The auditors questioned the capability of the sampling system for obtaining representative particulate effluent samples, since it appeared sample losses would occur within the long sampling lines.
1 The licensee stated that the 3/8 stainless steel tubing and 3 cfm rate had not resulted in major sample losses.
However, the licensee did not have experimental evidence suppcrting the representativeness
~
of particulate sampling.
Concerning the analytical laboratory, adequate instrumentation and procedure capabilities for evaluating high activity samples appeared to be available. Also, the auditors reviewed the design of the facility and determined that tha laboratory would be habitable during most accident situations.
In the event the location would have to be evacuated, off-site analytical laboratories would be avati.:ble.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement.
. Determination of the representativeness of post-accident airborne effluent particulate sampling.
(286/81-05-10) 4.1.1.8 Post-accident Liquid Effluent Sampling and Analysis The auditors reviewed the licensee's post-accident liquid effluent sampling and analytical facilities to verify that the licensee could j
effectively' sample and analyze high activity liquid effluents during l
an accident situation. The auditors inspected installed equipment.
I and discussed post-accident sampling and analysis with the Chemistry Project Coordinator and other licensee personnel.
l i
/
l The licensee's installed liquid processing system consisted of tanks and equipment for collecting and transferring liquid waste to a contractor (Chem-Nuclear), through a demineralizer or to Indian Point Unit 1 Processing Center where liquid wastes are monitored and processed before release. The licensee's capacity for liquid storage includes three tanks (90,000 gallons each) and one waste hold-up ttnk (24,000 gallons). Construction of two additional waste hold-up
~
tanks is to be completed by September, 1981.
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2 18 Because of this storage capacity the licensee stated that they would not have to-release any liquid effluents during an accident situation.
In discussions with the auditors, however, the licensee agreed that 4
plans should be formulated and procedures developed for circumstances where previously stored low level waste might be transferred to the Con Ed (Indian Point Unit 1) processing facility and for accident j
situations during which excessive quantities of liquid wastes would be generated. Any option to transfer post-accident effluents to Consolidated Edison's Unit I should be included in a letter of agreement or Memorandum of Understanding. (See Section 6.1 of this report.)
The analytical facility appeared to be accessible during accident conditions based on the licensee's shielding design-review. Adequate analytical instrumentation was available. Due to lack of procedures (See Sections 5.4.2.10 and 5.4.2.11.) the auditors were unable to determine whether the sampling technique produced' representative samples or whether the sampling and analyses could be completed within the three hour constraint.
1 Based on the above' findings,_ improvements in the following areas are required to achieve an acceptable program:
Development of plans / schemes and procedures for hanaling,
. storing, transferring, analyzing and discharging post-accident-liquid wastes.
(286/81-05-11) 4.1.1.9 Offsite Laboratory Facilities I
Consolidated Edison Company provides the offsite environmental monitoring program for the entire Indian Point site. Arrangements have been made with the Interex Corporation of Framingham, Massachusetts and the Teledyne Corporation, Inc. in Westwood, New Jersey, for offsite radiological analysis of environmental samples during emergencies. The auditors did not specifically examine these facilities during the appraisal.
However, past experience with these analytical companies indicates that the laboratory capabilities provided by these companies would be adequate.
l Based on the above findings, this portion of the licensee's progrcm appears to be acceptable.
4.1.2 Protective Facilities t
4.1.2.1 Assembly / Reassembly Areas Emergency Plan Implementing Procedure IP-1050 identified five assembly areas onsite for accountability of personnel as follows:
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19 Lunch Room (2nd Floor, Administrative Service Building)
South Loading Well, Unit 3 Turbine Hall Warehouse Office Training Trailer Construction Conference Trailer The procedure further identified the location of the assembly areas by means of a site diagram. The auditors toured the assembly areas and verified their locations.
Each of the assembly areas was of sufficient size to accomodate the
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personnel expected to assemble.
Telephone. communications existed at each of the areas. Habitability of the various areas under accident conditions was diverse - ranging from the lunch room (inside the brick and block Administrative Building) to the Construction Conference Trailer (located in an open area approximately 100 yards from the reactor building).
Supplies, such as protective clothing, portable lighting, or monitoring equipment were not specifically stored at the areas.
Emergency Plan Implementing Procedure IP-1053 specified that, in the event of a site evacuation, personnel would depart their respective assembly areas and reassemble at the Service Center Building, located adjacent to the site boundary. There reaccountability would occur prior to evacuating the site. This Service Center Building was inspected and appeared to provide sufficient space for the number of personnel that could be expected to be evacuated. The reassembly area is located in the same building as the Emergency Operations Facility but would not impact on the EOF. The Emergency Plan Implemen-ting Procedure IP-1060 provided for the monitoring and decontamination of personnel at this area.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.1.2.2 Medical Treatment Facilities The appraisal team reviewed the onsite medical treatment facilities i
and determined that their locations are consistent with the description in the plcn and proceduras. At the present time there was no centralized first-aid facility.
First-aid trauma kits were placed in various areas of the plant.
The First-Aid Room, located on the 33-foot elevation in the Turbine Building was available for non-contaminated, injured personnel.
Contaminated, injured individuals could be treated either at the Health Physics Control Decontamination Room or at the Indian Point Unit 1 Contamination Control Center or by using portable decontamination kits.
20 Unfettered and immediate access was available to the first-aid team, as well as to the Consolidated Edison nurse and the ambulance, who could be called to the site. The Indian Point Unit I decontamination room is easily accessible to a stretcher carried by two individuals.
The Health Physics Control Decontanination Room was better suited to ambulatory patients and was nut easily accessible by a stretche,.
A health physics technician accompanying the first-aid team would check for contamination with a radiation survey instrument.
The technician would also supply the first-aid team with dosimetry, if they had not received it when they passed through the health physics control point.
Communications were available for onsite communication as well to offsite medical support facilities and personnel by security radio, control room telephone, and plant page.
Procedures IP-1020, IP-1021, and IP-1022 provided instructions for treatment of injured personnel.
Supplies of KI for thyroid biccking were available and would be distributed to both the licensee and offsite emergency workers when authorized by the Emergency Director.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.1.2.3 Decontamination Facilities The licensee could perform decontamination of personnel at three locations, the Indian Point Unit 3 Health Physics Control Point, Indian Point Unit 1 Contamination Control Center and the Service Center Building, as stated in Section 6.7.2 of the Emergency Plan.
The primary area for decontamination is at the Indian Point Unit 3 HP Control Point. This location had adequate supplies and facilities to decontaminate several individuals at one time.
Portable decontam-ination kits were also available.
The Indian Point Unit 1 decontam-ination facility could also be utilized for a larger number of contaminated people. Arrangements have been made for decontamination at the Service Center Building.
There were provisions for disposal of solid and liquid waste at the Service Center Building as described in Procedure IP-1060.
Replacement clothing was available at the Indian Point Unit 3 Health Physics Control Point and at the warehouse.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.1.3 Expanded Support Facilities Section 5.3 of the licensee's Emergency Plan stated that offsite support would be available from the following sources:
Corporate deadquarters, local services, Consolidated Edison, and private
l.
21 i
l sector organizations. Additional technical assistance required to i
cope with a large scale emergency would be obtained by the Senior Vice President Nuclear Generation (Recovery Manager), who may call upon additional corporate resources and other organizations such as the nuclear system supplier (Westinghouse) and mutual aid agreements with four other nuclear power plant utilities.
Space for expanded support personnel would be available in the Emergency Control Center as outlined in Figure 5-3 of the Emergency Plan.
In addition to the above facilities, there are meeting rooms in the construction contrac-tors trailers, the training center, and the fourth floor of the Administration Building.
Based on the above findings, this portion of the licensee's program 1
appears to be acceptable.
4.1.4 News Center i
Section 7.1.4 of the Emergency Plan described the Special News i
Center which will be actuated by the licensee in the event of an emergency.
The facility is located at the-Verplanck Fire Hall in Verplanck, New York. The auditors toured the facility and found the i
area designated as the main briefing room large enough to accommodate media representatives. The licensee, however, had no provisions for communications nor other equipment needed to operate the News Center consistent with its designated functions during emergencies (e.g.,
telephone service, electric supply to carry added TV load, copying I
machines, public address system and audio visual equipment.) Pro-visions for security (media badging, crowd control, etc.) had not been addressed either.
Based on the above findings, improvements in the.following area are j
required to achieve an acceptable program:
Provisions for communications and other equipment needed to operate the News Center consistent with its designated functions during an emergency, as well as for security at the News t,e ter.
(286/81-05-12) 4.2 Emergency Equipment g
4.2.1 Assessment Equipment 4.2.1.1 Emergency Kits and Emergercy Survey Instrumentation The licensee had pre positioned emergency supplies and survey instru-mentation at specified locations in the Control Room and Technical Support Center. The equipment and supplies were located as specified in the Implementing Procedure IP-1070 and Surveillance Test Procedure 3PT-M40.
Emergency equipment assigned to the Emergency Operation Facility (EOF), Alternate Emergency Operation Facility (AEOF),
emergency vehicle, and alternate emergency vehicle are inventoried
22 and operationally checked by Consolidated Edison (personnel from Indian Point Unit 2) on a monthly basis. Audits performed by Indian Point Unit 2 personnel of common use facilities and equipment indicated a recurring finding of inoperable equipment and support vehicles.
The licensee maintained no documentation to confirm that Indian Point Unit 2 personnel were conducting the monthly audits as specified in Implementing Procedure IP-1070.
(See Section 5.5.1 of this report.)
Each emergency team assigned had ready access to all assessment and protective instrumentation, equipment and supplies described in the emergency procedures applicable to their emergency duties. Onsite inventories were correct and the equipment operable.
Equipment to be used by teams re-entering the facility, or portions thereof, included provisions for extremity monitoring and detection and measurement of beta / gamma radiation fields.
Instrumentation used for environmental surveys was maintained, inventoried, and calibrated by Indian Point Unit 2 personnel.
The Consolidated Edison Nuclear Environmental Monitoring Group constituted the offsite monitoring teams for Indian Point Unit 3 as specified in Implementing Procedure IP-1011.
Portable instruments with beta / gamma distinguishing capability for measuring whole body dose rates were available, as well as, instruments with beta / gamma distinguishing capability for detecting contamination on individuals and in the environment.
Contents of emergency kits provided sufficient numbers of instruments and supplies to equip the team members for their intended function.
There was an in plant capability for detecting airborne iodine in the presence of noble gases. The licensee stated inoperable instru-ments were promptly repaired or replaced according to Surveillance Test Procedure 3PT-M40. Available equipment was adequate in number for all intended uses, e.g., assembly area monitoring, decontamina-tion, in plant surveys, etc.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.2.1.2 Area and Process Radiation Monitors The area and process monitors described in Sac'icn 7.4.1 of the Emergency Plan were available and operable.
Thc readouts for these monitors were in the Indian Point Unit 3 Control Room.
Process radiation monitor (PRM) data were recorded; area radiation monitor (ARM) data were not. Alarm set points for both types of monitors were posted adjacent to the monitor readout location.
The ARM system was part of the station original equipment, having eight detectors with local and control room readouts.' alarms. The upper detection limit was generally 10 R/hr (one ARM, R-10, had an upper limit of 1 R/hr).
The auditors determined that the number of i
23 detectors did not appear to be adequate for mapping post-accident conditions.
Further, the upper detection limit was considered to be inadequate for accident monitoring. ANSI-N320-1979, " Performance Specifications for Reactor Emergency Radiological Monitoring Instru-4 mentation", recommends an upper detection limit of 10 R/hr.
The alarm points for the ARMS ranged from 2 to 200 mR/hr depending on the location of the detector. These alarms appeared to generate response actions relative to the Emergency Plan and Implementing Procedures. ARM readings ware referenced in the Emergency Action Levels (EALs) for site and general emergencies. ARMS arc calibrated during each refueling outage. The most recent calibration was performed during the period June 21 - 26, 1981.
The process radiation monitor (PRM) system included twelve monitors, six of which were either gas or particulate monitors. All PRMs observed by.the auditor appeared to be original plant equipment.
These monitors are calibrated quarterly.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be considered for improvement:
Performance of an engineering study of the existing ARM system to upgrade post-accident radiation level mapping capability and to extend the upper limit of detection.
(286/81-05-13) 4.2.1.3 Non-Radiation Process Monitors The process monitors described in Sections 7.4.1.2, 7.4.1.5 and 7.4.1.6 of the Emergency Plan which measure vital parameters of a non-radiological nature, such as: pressure, flow, temperature, fluid level, fire detection, etc., being relied upon for accident assessment, were in place and operable.
All monitor readouts were accessible in the control room and were readily observable.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.2.1.4 Meteorological Instrumentation The bases for the auditors review of the licensee's meteorological measurements program included Regulatory Guides 1.23 and 1.97, and the criteria set forth in NUREGs -0654, -0696, and -0737.
The licensee outlined a description of the meteorological measurements program in Section 7.3.1 and Appendix H of the Emergency Plan. The integration of meteorological information into the licensee's dose assessment scheme was described in Appendix H of the Emergency Plan.
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24 4
l The auditor reviewed with the licensee's contractor (York Research Corp.), the preventative maintenance program, calibraticn records and site logs. He also reviewed with the licensee's staff meteorologist the procedures and systems for integrating meteorological information i
into the dose assessment schemes.
The meteorological instruments provide the basic parameters (e.g.,
wind direction, wind speed, temperature, and an estimate of atmospheric stability based on temperature differences) as required by the Emergency Plan and Implementing Procedures.
The auditors noted that the mounting of instrument sensors on the i
primary towers did not appear to meet the guidance presented.in Regulatory Guide 1.23, in that, the sensors were mounted less than two tower widths from the tower on the instrument booms. The potential influences of the tower on the instrumentation were discussed with the licensee.
Instrument readouts were located in the control room and at other user locations.
Instrumentation was maintained in accordance with the 2
provisions of Regulatory Guide l.23 and there appeared to be adequate assurance that data availability and accuracy goals can be achieved.
i A licensee contractor. University of Pennsylvania Accu-Weather, provided acceotable information to shift operations personnel of severe weather warnings and watches in the site vicinity. Provisions existed for obtaining real-time meteorological information through use of backup systems if the primary system becomes inoperable.
With regard tu the backup tower, the auditors noted that this tower was mounted atop a building with instrumentation at a level of 1/3 to 1/2 the building height above the building roof. The auditors 4
discussed with the licensee the possible effects of the building influences on the tower instrumentation and questioned the representa-i tiveness of this data with regard to actual site meteorology.
Compar-ison of this data (15-minute averaged data) with that of the primary l
tower was discussed with regard to determining the representativeness j
of the backup tower data.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be considered for improvement:
9 Justification of the positioning of instruments mounted on the primary tower or relocation of these instruments to conform to Regulatory Guide 1.23.
(286/81-05-14)
Determination of whether 15-minute averaged data from the backup tower reasonably represent information from the primary system (i.e., the site meterology) and if not representative, appropriate modifications to assure representativeness of the backup tower data.
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25 4.2.2 Protective Equipment 4.2.2.1 Respiratory Protection The licensee had self-contained breathing apparatus (SCBA) reserved for emergency use in the Control Room and Technical Support Center.
Four units with six spare bottles, as well as hose connectors to a centralized air system were available in the Control Room, two units with four spare bottles were stored in the Technical Support Center for use by technicians that would require them to perform HP surveys.
The licensee had a capability for refilling SCBA bottles using a cascade refilling system. The auditors determined that the number and capacity of available self-contained breathing apparatus (SCBA) devices would not be adequate to support the activities that may be required during a, emergency, e.g.,
search and rescue, fire, inpiant surveys, etc.
Based on the above findings, this portion of the licensee program appears to be acceptable, but the following matter should be considered for improvement:
Provisions for additional respiratory protection equip tent for use during emergencies.
(286/81-05-16) 4.2.2.2 Protective Clothing The licensee had stores of protective clothing reserved for emergency use as specified in Implementing Procedure IP-1070, located in the control room, Technical Support Center, Command Guard House, Emergency Control Center, and Alternate Emergency Control Center. Additional protective clothing was readily available from onsite warehouse inventories, which were maintained at or above minimum stocking levels based on outage usage. Stores of protective clothing woulc' be accessible under emergency conditions.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.2.3 Emergency Communications Equipment The communications equipment specified in the licensee's Emergency Plan and Implementing Procedures was available. There were alarms located through the facility, the specific meanings of which were discussed as part of the general employee indoctrination training.
These alarms are:
fire alarm, evacuation alarm, containment evacua-tion alarm, and air raid alarm.
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26 1
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f Voice communication equipment consisted of commercial telephone lines through the PASNY switchboard, dedicated telephone lines, National Warning System (NAWAS), two radio' systems, radio pagers, 4
4 and a State Police radio in the Control Room.~ In addition to the licensee's communication systems, two NRC telephone nets, the Emergency-Notification System (ENS) and the Health Physics Network (HPN), have i
extensions at strategic locations throughout the facility. The normal mode of voice communication between onsite emergency operations centers was by land-line telephone. The backup mode was by radio for the Control Room, EOF, AEOF, and Indian Point Unit 2.
The i
auditors noted that no direct radio communication capability existed between the offsite emergency operations centers.
The only means of radio communication between the site and the offsite State and local emergency operations centers was through the New York State Police radio in the Control Room and NAWAS.
(See Section 4.1.1.2 of this report.)
Emergency Plan Implementing Procedures IP-1075 and IP-1076 provided for routine checks of the emergency communications equipment.
i Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be considered 4
3 for improvement:
1 i
Provision of direct means of communication other than land-line telephone (e.g., a radio system) from the EOF. to offsite author-ities to ensure capability of communicating protective action recommendations in the event that telephone systems are unusable.
(286/81-05-17)
Revision of emergency procedures to incorporate the use of the New York State Police radio located in the Control Room.
(286/81-05-18) j 4.2.4 Damage Control / Corrective Action and Maintenance Equipment and Supplies Section 7.7 of the Emergency Plan states that equipment and supplies necessary to perform repair and corective actions of plant equipment are available.
The auditors noted that the licensee maintained i
routine stocks of equipment, supplies, and spare parts; however, the licensee had not identified such items specifically for damage control purposes.
Licensec management stated that equipment needed to support damage control / corrective action activities have been evaluated and such needs are included and maintained in the routine level of stocks.
The licensee also stated that additional equipment needs would be available under the Memorandum of Understanding No. 28, from the l
adjacent Consolidated Edison Company Indian Point Unit 2 Nuclear
^
Power Plant, which is of similar design to the licensee's plant.
I s
27 Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.2.5 Reserve Emergency Suoplies and Equipment The licensee relies upon the'onsite inventory of supplies, e.g.,
survey instruments, dosimetry, protective clothing and equipment to support emergency operations.
Reserve emergency supplies are stocked at Indian Point Unit 3 in the site warehouse where minimum stocking levels are maintained and inventoried on a continuing basis. Additional emergency supplies of equipment and personnel are available under the Memorandum of Understanding No. 28, dated April 8, 1981, with Consolidated Edison Company of New York from Indian Point Unit 2.
Equipment available there is the same or equivalent in operational characteristics to that of the licensee's.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.2.6 Transportation The licensee did not have vehicles specifically dedicated to emergency response operations.
For the purpose of radiation monitoring other than at the plant, the licensee relies upon the capabilities and services provided by personnel of the Consolidated Edison Company of New York. The auditors noted that this arrangement had been formalized by Memorandum of Understanding No. 28 and the auditors verified Consolidated Edison's capability to meet this commitment. A personnel van was available onsite to serve as a backup ambulance. The licensee had additionally arranged for Consolidated Edison to provide a variety of vehicles at the Emergency Operations Facility.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
1
28 5.0 PROCEDURES 5.1 General Content and Format The Indian Point Unit 3 Emergency Plan Implementing Procedures generally specified the individual or organizational element having the authority and responsibility for performing the tasks covered by the procedure.
Procedures such as IP-1002, " Determination of Magnitude of Release",
might be performed by several individuals and are, therefore, using a -
more general assignment.
Emergency Action Levels (EAls) and protective action guides (PAGs) were specified along with the emergency actions or protective actions to be implemented. Where actions are to be taken, these actions and their sequential steps were not always clearly defined.
(See Section 5.2 of this report.)
Procedures generally described and highlighted the prerequisites and conditions that must exist before the specified actions are to be perfonaed, as well as the precautions and limitations to be observed during the performance of the actions. Guidelines were provided for each area in which the user of the procedure is permitted to exercise judgement in the implementation of specific actions, in the interpretation of emergency action levels, the application of protective action guides or the recom-mendation of protective actions.
Procedures referred the user to other procedures already in existence (chemistry, health physics, etc.) to complete the detailed actions. The references appeared in the body of the procedure at the point at which implementation of the other function or procedure is to be performed or considered.
References were available to the user.
~
The procedures,had sign-off sheets and data sheets, but checklists were generally not included. The Emergency Plan Implementing Procedures appeared to be direct and clearly worded. They provided detailed action instructions for the emergency staff, yet they were short and simple enough to be useful during an actual emergency.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.2 Emergency, Alarm, and Abnormal Occurrence Procedures The auditors reviewed the Emergency Operating Procedures (EOPs) used by the operators of Indian Point Unit 3 and noted that they did not specif-ically contain or reference the Emergency Action Levels (EALs) which are found in Table 4.1 of the Emergency Plan.
Each E0P contained a statement, however, in the Discussion Section which referred the operator to Table 4.1 of the Emergency Plan which contained all of the EALs, "for further information" regarding the classification of the emergency. The Emergency Operating Procedures did not reference the Emergency Plan Implementing Instructions.
t
29 The coordination of Emergency Operating Procedures with the Emergency i
Action Levels in the Emergency Plan is one of the crucial aspects of emergency preparedness. Unless there is assurance that the operators will correctly identify and evaluate an accident and then promptly classify and declare an emergency, there is no assurance that shift augmentation, assessment, and offsite protective measures will be initiated in a timely fashion.
Based en discussions with licensee personnel, given-an emergency situation the operators would give first consideration to the diagnosis and mitigation of the cause of the emergency and attempt to return the reactor to a safe condition, then determine and declare the emergency classification.
Based on discussion with the reactor operators, the auditors determined that operators had problems with Table 4.1 of the Emergency Plan containing the EAL descriptions. This table was not a clearly organized and useable reference.
It did not assist the operator in determining how to recognize an accident and decle i the proper emergency classification.
During practical drills in the control room, the Shift Supervisor bypassed Table 4.1 and used his judgement and experience to classify the emergency.
(See also Section 7.2.1 of this report.) The Shift Supervisor referred to the implementing instruction which orchestrates the Emergency Director's tasks and responsibilities for classifying the emergency. The Shift Supervisor indicated he would have taken the same action without a table of EALs, indicating that the present system for classifying emergencies was too difficult to use effectively.
I Emergency Action Levels in the plan were also deficient in that the nonradiological instrumentation was not incorporated in sufficient detail in the emergency classification scheme, and consequently was not used as the basis for making protective action recommendations to offsite authorities.
This fault is also seen in the Emergency Plan Implementing Instructions (See Section 5.3 of this report.) because the Emergency Director is not given clear guidance on recognizing conditions which should form the basis for making protective action recommendations in the absence of radiological effluents.
Based on the above findings, improvements in the following area are required to achieve an acceptable program.
Development of unambiguous Emergency Action Leveis based on control room and plant instrumentation and conditions, including appropriate references between the Emergency Operating Procedures and the appro-priate emergency classification in the Emergency Plan.
(286/81-05-19) i f
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30 5.3 Icplementing Instructions The auditors determined that a separate Implementing Instruction was prepared for each class of emergency.. Implementing Instructions were written for use by the Emergency Director and outlined the tasks the Emergency Director must perform, including ' making protective action recommendations to the state and local agencies.
The Implementing Instructions included the scope of the authority and responsibility vested in the Emergency Director, and orchestrated the implementation of other, more specific procedures which had been developed to implement or support implementation of the Emergency Plan.
The auditors determined through the review of the EALs and the Implementing Instructions that provisions had not been included for classifying emerg-encies and recommending protective actions to state _and local officials for accident situations which did not involve ongoing releases of radio-activity. That is, the EALs (See also Section 5.2 of this report.) and the Implementing Instructions were deficient for those situations in which no releases have occurred, but the plant conditions as evidenced from available control room instrumentation (radiation levels in contain-ment, containment pressure, temperature, parameter trends, operation or inoperation of safety systems, etc.) are deteriorating such that radio-active releases arc inevitable.
(See also Section 5.4.2 of this report.)
Based on the above, improvements in the following area is required to achieve an acceptable program:
Provisions for making protective action decisions based on current and projected plant status and conditions, i.e., for accident situa-tions in which minimal radiological releases have occurred, but plant status, as evidenced from instrumentation, is deteriorating.
(286/81-05-20) 5.4 Implementing Procedures 5.4.I Notifications l
Implementing Procedure IP-1030 contained instructions and a sequence of notifications for onsite and offsite organizations in the event I
of an emergency at Indian Point Unit 3.
In general, the action levels for performing the various notifications were tied to the declaration of the various emergency classes.
The procedure provided for authentication schemes, lists and telephone numbers, and described the preferred means of contacting major i
response agencies.
It did not, however, address the railroad line that runs in close proximity to the site.
The procedure (IP-1030) failed to specify emergency classification and any protective action recommendations (prepared messages or announcements) to be made to offsite response agencies during initial notification.
i
31 Section 4.2.5 of Implementing Procedure IP-1030 stated that the NRC and the New York State Department of Health will be kept informed of plant and environmental conditions approximately every 15-30 minutes.
There was no similar requirement to notify the adjacent four counties of significant changes in plant conditions.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be considered for improvement:
Provision of prepared messages for informing response groups including State and local officials, during the initial notifica-tica sequence, of the emergency classification and any protective action recommendations based on current and projected plant status and conditions, as well as radiological dose projections.
(286/81-05-21)
Provisions for including pertinent railroad lines in the notifica-tion scheme.
(286/81-05-22) 5.4.2 Assessment Actions The auditors reviewed the licensee's procedures for collect data to assess accident consequences and the bases of recommendat, i for onsite and offsite protective actions. -Procedures IP-1001, "b.
ussion of Determination of the Magnitude of Release" and IP-1002, "Detei..:ina-tion of the Magnitude of Release", orchestrated the implementation of the licensee's accident assessment scheme.
Procedure IP-1002 provided a flow chart for determining dose which provided a reasonably good overview of the licensee's offsite dose projection methodology.
The flow chart was not coordinated with the offsite survey effort, however, so that the Emergency Director would not have the means by.
which offsite assessment could be properly considered in the overall assessment scheme.
Offsite dose projection methods used by the licensee werd contained in the following procedures:
IP-1001 Discussion of Determination of the Magnitude of Release IP-1002 Determination of the Magnitude of Release IP-1003 Obtaining Meteorological Data IP-1004 Midas Computer System: Dose Assessment Models IP-1005 Planned Discharge of Containment Atmosphere During Accident Conditions
32 IP-1017 Recommendation of Protective Actions for Offsite Population IP-1034 Recommendations to U.S. Coast Guard IP-1040 Habitability of the Emergency Facil' ties IP-1041 Issuance of Personnel Monitoring Devices to E0F, TSC, and OSC Personnel The auditors reviewed the above procedures for' clarity, completeness, j
and licensee reviews and approvals. These procedures, as well as 4
the other Emergency Plan Implementing Procedures, had been reviewed by the Plant Operations Review Committee (PORC). The notation that the procedures had been approved by POII and by other plant management, as well as dates of approval, were on a cover sheet for each procedure.
Procedure IP-1017 provided guidance to the Emergency Director for 3
l determining-the protective actions which would be recommended to offsite authorities. The procedure did not, however, provide a basis for determining protective action recommendations based upon plant system parameters. Such provisions are specifically required by Section 4.b of Appendix E, 10 CFR 50.
(See Section 5.3 of this I
report.)
Procedure IP-1017 stated that its intent was to provide guidance for protective action recommendations to State and county authorities.
Discussion with the licensee indicated that the Emergency Director would recommend protective actions to the New York State Bureau of Radiological Health. The recommendations would then be distributed to county and local authorities. However, this did not satisfy NUREG-0654, Criterium J.7, which states "... prompt notification shall be made directly to the offsite authorities responsible for implementing protective measures within the plume exposure pathway l
EPZ".
In the case of Indian Point Unit 3, this specifically requires i
that the licensee provide protective action recommendations to the four affected county governments. Notification of only State author-l ities and not county and local authorities did not meet the notifica-tion criteria.
(See also Section 4.2.3 of this report.)
Procedure IP-1001 clearly outlined the initial steps for assessing release rates. Descriptions of the diffusion overlays and instructions j
in their use were included.
Section A.3.2 of the procedure directed the initial assessment be based on the assumption that the ratio of iodines to noble gases in the effluent is 0.01%. The licensee explained that this ratio is based on the assumption that the effluent is filtered by the normal plant vent charcoal and particulate filters.
The procedure did not provide guidance for the condition where the release pathway is not filtered, f
l r
33 The procedure also mentioned that.the dose rate, multiplied by the number of hours of exposure, gives the total dose.
However, the procedure did not provide guidance for estimating the duration of exposure. This omission would allow each individual who is completing the procedure to use different assumptions'about the release duration.
The dose assessment personnel were not instructed to call a specific individual such as the Shift Supervisor or the Manager of the Technical Support Center (TSC) for s.ch information.
Procedure IP-1004 stated that the Midas computer system had two computer models available to access the real-time values of radiological releases. The auditors determined that both were available for use under emergency conditions.
The auditors requested a demonstration of the Midas computer system during the tour of the Emergency Operations Facility (EOF). The auditors were told that, during a real emergency, the isopleth overlays would be used in preference to the computer system.
During the walk-through of the Emergency Operations Facility (EOF),
the dose assessment person was asked to calculate the dose at an offsite point of interest.
(See Section 7.2 of this report.) The computer system was not used.
i Based on the above findings, improvements.in the following area are required to achieve an acceptable program.
i Provisions for communicating protective action recommendations based upon plant system parameters and/or radiological dose projections directly to the local offsite authorities responsible for implementing protective measures within the plume exposure EPZ.
(286/81-05-23) 5.4.2.1 Offsite Radiological Surveys Discussions with the licensee indicated that the Con Edison Nuclear 2
Environmental Monitoring Group would perform environmental monitoring as requested by the licensee using Implementing Procedure IP-1011, "Offsite Monitoring Team", and also Con Edison would perform all offsite surveys.
Paragraph B.6 of Memorandum of Understanding (MOV)
No. 28 between the licensee and Con Edison provides for the use of site environmental monitoring facilities, personnel and equipment, as needed.
E Implementing Procedure IP-1011 clearly indicates the methods and j
equipment to adequately perform the offsite monitoring. The procedure can be easily understood and followed by the monitoring team.
i Offsite emergency sampling sites were indicated in the procedure by sector, distance from the plant, location description and village, town or city.
f l
Based on the above findings, this portion of the licensee's program appears to be acceptable.
)
i
~
34 5.4.2.2 Onsite (Out-of plant) Radiological Surveys The licensee's Implementing Procedure IP-1010, " Site Perimeter Survey", discussed methods and procedures for emergency radiological monitoring. The procedure was clear and concise and can be followed by the technicians performing the surveys. Communication with the E0F is by Con Ed supplied radio from the Command Guard House, however, no back up method of communication was discussed.
Radiation protection guidance was adequately addressed in the procedures.
The procedure indicated that site perimeter surveys of beta / gamma fields would be performed.
Discussions with health physics technicians revealed that air samples would be collected and analyzed by Con Ed personnel using Con Ed Procedure IP-1005 and air sampling equipment.
How air sample data are to be provided to the licensee was not clearly defined in the procedure.
The site perimeter field survey data sheet identified the monitoring locations by the sector and also whether the measurement was for gamma or beta.
The data sheet did not have provisions for recording the date, time, names of technicians, instruments used for survey by type and serial number, the duration of the meter reading, air sampler flow :ates, nor background data and sample count time.
The procedures did not specify where or to whom original data sheets are to be provided for incorporation into emergency assessment.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be considered for improvement:
Data sheets which include provisions for recording the date and time of each survey, the names of the technicians, the duration of the meter readings, the instruments used by type and serial number, as well as air sample flow rates, background radiation and sample count times.
(286/81-05-24)
Specification in Procedure IP-1005 and IP-1010 of the organiza-tional element to whom collected data and the data sheets are to be provided for emergency assessment.
(286/81-05-25) 5.4.2.3 In plant Radiological Surveys Through discussions with the licensee and review of Procedure HPP 3.4, " Emergency Health Physics Monitoring and Sampling", the auditors determined that methods and equipment needed to perform emergency radiological surveys were specified. The proceaures were straight forward and could be followed by the persons responsible for performing the surveys.
35 4
f 4
Data sheets did not provide for recording the date, time, location, instrument used, mode used (open or closed window), duration of reading, nor technician performing the survey.
l The procedure did not instruct the technicians on how to label-samples collected for analysis, nor did it indicate a central collec-4 tion point for these samples.
In addition, the procedure did not discuss means of communications, 4
nor to whom the collected data would be transmitted to assure the-data were provided to the organizational element responsible for assessment.
Discussions with the health physics technicians, however, i
revealed that radios would be used to send information back to the control room.
4 Some general radiation protection guidance, including necessary protective clothing and dosimetry was addressed, however, the use of lapel samplers by technicians performing airborne radioactivity surveys was not addressed. Other precautions and prerequisites that were not addressed included; pre-task survey briefings by supervisory 1 -
personnel regarding known or anticipated plant conditions; radiation and radioactivity levels; instrumentation use to assure personnel exposures are monitored (especially when a telescoping instrument is used); and specific mission to be accomplished by the surveys.
Based on the above findings, improvements in the.following araa are l
required to achieve an acceptable program.
Revision of Procedure HPP 3.4 to include: pre-task supervisory briefings concerning precautions and prerequisites to be observed based upon unusual plant / radiological conditions expected and mission direction; provisions for communication (with designation of backup means) of data, including transmittal of original data sheets to the organizational element responsible for assessment; provision of data sheets to assure recording of all i
pertinent data relevant to the surveys; and provisions for labeling collected samples for future identification and analyses and for a central collection point for such samples.
(286/81-05-26) i l
5.4.2.4 Post-accident Primary Coolant Sampling The operation of the reactor coolant post-accident sampling system was discussed with the Project Chemistry Coordinator and with the Senior Production Technician, who was instrumental in the design and installation of the system.
Primary coolant can be sampled during accident conditions from outside of the normal sample room in a totally shielded system.
(See also Section 4.1.1.5 of this report.)
Procedure RE-CS-042, Rev. 2, was reviewed. The sequential steps that the chemistry technician must follow to take the primary coolant sample and perform the analyses were clearly detailed.
i
36 The procedure described the sampling location and addressed equipment.
t necessary to obtain the sample.
Methods of transporting and transfer-ring the sample were clearly defined.
Sample containers were to be labeled before use.
The auditors determined that sampling could be conducted in one hour.
Drovisions to limit exposure included a totally shielded system, l
remote handling of the sample cask and a specially designed device used to remotely operate the quick disconnect mechanisms in the system. Provisions also included the verification of the habitability of areas to be traversed and worked in by the health physics technician i
accompanying the chemistry technician.
Section 2.2.3 of Procedure RE-CS-042, Rev. 2, stated that the health physics technician would determine the radiological protection equipment required, however, the auditors noted that the procedure did not provide adequate guidance to perform the above tasks. The procedure included a list of protective clothing and one type of health physics survey instrument (teletector).
The auditors determined through review of the procedure and discussions with the licensee that data sheets were not included in the procedure.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
Provision of data sheets for post-accident primary coolant sampling in Procedure RE-CS-042, Rev. 2.
(286/81-05-27) i 5.4.2.5 Post-accident Primary Coolant Sample Analysis i
l The auditors reviewed Procedure RE-CS-042, Revision 2, " Sampling Various Plant Systems During Accident Conditions", to evaluate the analytical procedure for reactor coolant post-accident samples.
Special calibration of the counting equipment is not necessary since the equipment was specifically developed or purchased for counting the high level activity samples.
The means of diluting samples was addressed in the procedure.
Section 2.0 of the procedure listed precautions to be taken to protect laboratory personnel working with high activity primary
{
coolant, as well as other safety related problems identified with obtaining and analyzing the sample. Contamination control was not specifically addressed in the procedures, however, discussions with the Senior Production Technician indicated that the chemistry technicians were trained to wrap samples in cellophane as one means of preventing l
the spread of contamination. Other means of contamination control were also described by the Senior Production Technician. The procedure did not make provisions for analysis if the primary counting area had a high background, however, it appears that the system was designed taking iqto account high background radiation.
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o 37 Analytical data sh;ets were not provided in the procedure, however, the data record sheets were available in the counting lab and the chemistry technician performing the analyses would have data sheets.
Results of the reactor coolant analyses were not keyed to Emergency Action Levels (EAls), nor were the means specified by which data were to be provided to the personnel responsible for assessment of the accident (See Section 5.2 and 5.3 of this report.) Discussions with chemistry technician personnel indicated that all results would be turned over to the Chemistry Supervisor who is located in the TSC.
Storage of the reactor coolant samples will be provided in a shielded liquid waste cask. The sample aliquots withdrawn for analyses would also be placed in a shielded cask and placed in a shielded area for storage until the analyses are performed.
The auditors determined that the analytical methods d deribed ir. the procedure would achieve the results desired to aid the assessment of the accident. The sampling and analyses could be completed within three hours as required.
Based on the above findings, this portion of the licensee's program appears to be acceptable but the following matter should be considered fcr improvement:
Revision of Procedure RE-CS-042, Rev. 2 to include:
provisions /
precautions for contamination control during post-accident sampling and analyses; provisions for analysis of above samples if primary analytical area has elevated radiation levels; provision of data sheets; and provisions for transmitting the data, as well as, the original data sheets to the organizational element responsible for assessment.
(286/81-05-28) 5.4.2.6 Post-accident Containment Air Sampling Section II.B.3 of NUREG-0737 specifies that licensees should be able to sample the containment air and complete the analyses within three i
hours under accident conditions. The auditors reviewed available procedures and held discussions with the Chemistry Project Coordinator, chemistry technicians, and other licensee personnel to evaluate the licensee's conformance with NUREG-0737.
Post-accident containment air sampling would be performed using Procedure RE-CS-042, rev. 2, " Sampling Various Plant Systems During 3
Accident Conditions". The auditors noted that this procedure generally i
i reflected the appropriate cautions, precautions or prerequisites that would be necessary for use of the procedure during emergency conditions. However, a statement warning the user against opening the shielding doors during the sampling period was not included.
(See also Sections 5.4.2.5 and 5.4.2.8 regarding this item).
N
j 1
38 The auditors noted that_ a qualified health physics technician would function as the Radiation Exposure Authority (REA) as specified in procedure RE-HPP-2.1 and accompany the chemistry technician. His duties would include recommending the type of protective clothing, respirator, dosimetry, verification of habitability of the area, and assistance in procedural tasks. General instructions were included i
for the health physics technician within RE-CS-042, Rev. 2, with c
more detailed precautions and specific instructions in Procedure RE-HPP 3.4, Rev. 1, " Emergency Health Physics Monitoring and Sampling".
The procedural format and content was sufficiently written for a complicated sampling arrangement, but user's aides were not included.
Provisions for " pause checklists" after completion of sub-areas, diagrams indicating the expected higher radiation areas or data I
sheets were not included.
The auditors noted that'the sampling points and valves were all labeled and that the sampling could be completed within one hour.
Provisions for labeling the cellected samples or methods for trans-porting the radioactive samples were not-included or referenced to other procedures. Discussions with the licensee indicated that these tasks were included in their training.
I Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be con-sidered for improvement:
Revision of the post-accident sampling and analytical procedures to include provisions for: valving diagrams and schematics; checklists for assuring task completion; and labeling, transpor-ting, handling and storage of high activity samples.
(286/81-05-29)
+
See also item (286/81-05-28).
5.4.2.7 Post-accident Containment Air Sample Analysis l
Section II.B.3 of NUREG-0737 specifies that licensees be able to I
sample and analyze she containment air for iodines, particulates and noble gases within three hours under accident conditions without incurring a radiation exposure to any individual in excess of 3 rems to the whole body or 18 3/4 rems to the extremities.
The auditors reviewed available procedures and held discussions with licensee representatives to evaluate the licensee's conformance with NUREG-0737.
Containment air sample analyses would be performed using the following procedures:
RE-CS-042/Rev. 2 Sampling Various Plant Systems During Accident Conditions I
39 RE-CI-007/Rev. 0 Operstion of the Fisher Model 1200 Gas Partitioner RE-CA-300/Rev. O Radiochemical Analysis Using Nuclear Data ND6620 System The auditors noted that RE-CI-007 and RE-CA-300 were written for use during normal operation.
RE-CS-042, Rev. 2 had been developed for emergency conditions and reflected appropriate cautions, precautions and prerequisites.
The licensee stated that all personnel who would use the Procedurc RE-CS-042 would be properly trained and that attempts to video tape the correct method for sampling were being pursued.
Some of the actions required by Procedure RE-CS-042 included donning anti Cs, preparing the sample size and use of counting and analytical procedures RE-CI-007 and RE-CA-300. The auditors noted that although the radiochemical analysis procedure, RE-CA-300, resulted in a printout of results, the results were not keyed to Emergency Action Levels (EALs).
Likewise, the results of the gas partitioning procedure, RE-CI-007, did not key EALs. (See Section 5.2 and 5.3 of this report.) Additionally, no data or calculation sheets were provided with the Procedure RE-CI-007 although manual calculations were needed.
The auditors determined that the analytical procedures provided procedural capability for evaluating the collected samples using a GeLi gamma spectrometry system and it appeared that sample analyses could be completed within two hours. However, no provisions addressed the handling and counting of high activity particulate filters and silver zeolite cartridges.
Discussions with the licensee indicated that instructions for sample activity reduction methods (i.e.,
cutting a small section of collection media) or adjusting the distance between the sample to the detector and counting times would be given as the situation warranted.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be considered for improvement:
i
(
See also item (286/81-05-28)
Revision of post-accident sample analytical procedures to include provisions for analyzing high activity particulate and iodine samples.
(286/81-05-30) l f
l 1
40 5.4.2.8 Post-accident Gaseous and Particulate.
Effluent Sampling The auditors reviewed the licensee's implementation of NUREG-0737, Paragraph II.F.1, " Additional Accident Monitoring Instrumentation",
to verify that the licensee could sample high activity effluents during accident situations. The auditors reviewed available procedures and held discussions with the licensee's health physics and chemistry personnel to evaluate the provisions.
Stack effluent sampling would be performed using Procedure RE-HPI-12.4, Revision 1, " Post-Accident Monitoring of Noble Gas Concentration in the Plant Vent", and Procedure RE-CS-042, Revision 2, " Sampling Various Plant Systems During Accident Conditions".
The auditors noted neither procedure had a detailed checklist for the emergency sampling or monitoring equipment, however, an apparatus list was included. The sampling locations were listed in the procedure, but diagrams describing or illustrating procedure steps and sample valve locations, were not included.
Precautions concerning high activity sampling were addressed but were not sufficient.
In particular, the discussion addressing the sampling media made no mention that the iodine sample cartridge could have collected up to 85 Ci of radioiodines during a 30-minute sampling period, using the NUREG-0737 source criteria.
Also, instruc-tions informing the user of Procedure RE-CS-042 not to open any of the shielding doors during the sampling period were not included.
Other shortcomings of the emergency sampling procedure, RE-CS-042, involved transporting and labeling of the high activity samples.
Equipment provisions and methods for transporting the samples to the counting labs or labeling them for subsequent identification were not described.
(See also Section 5.4.2.6 of this report.)
The auditor noted that noble gas monitoring procedure, HPI-12.4, was clearly written and included a data sheet for all instrument readings.
Additionally, conversien factors for the calculations to determine noble gas concentration were included within the procedure as attachments.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be considered for improvement:
52e items (286/81-05-28) ar.d (286/81-05-30).
m.
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41 l
5.4.2.9.
Post-Accident Gaseous and Particulate Effluent Sample Analysis The auditors reviewed the licensee's implementation of NUREG-0737, i
Paragraph II.F.1, to verify that the licensee had the ability to analyze high activity effluent samples during accident situations.
The auditors reviewed available procedures and held discussions with licensee representatives to evaluate the licensee's provisions for j
performing stack effluent sample analyses. The auditors noted that no special procedures were developed for emergency conditions, but rather, the procedure used during routine operation was relied upon.
Stack effluent sample analyses would be performed using Procedures RE-CA-300, Revision 0, " Radiochemical Analysis Using Nuclear Data ND 6620 System", and RE-CI-007, Revision 0, " Operation of the Fisher Model 1200 Gas Partitioner". These procedures were referenced in Procedure RE-CS-042, Revision 2 (See Section 5.4.2.8 of this report).
t The auditors noted that since these procedures were written for use during norma' operations, they did not reflect appropriate cautions, precautions or prerequisites that would be necessary for use of the i
procedure during emergency conditions. The only radiological precaution described was to wrap all samples in plastic to prevent the counting i
facility from becoming contaminated. During discussions with the licensee, the auditors were informed that the appropriate supervisors would determine how to count the samples and prescribe these measures to the lab personnel worFing with the high level samples.
i The analytical procedure appeared to be adequate for evaluating the samples collected.
Results could be completed in two hours, however, 4
the auditors noted that the procedure did not specify provisions for reporting the results to the organizational element responsible for the assessment function. (See also Section 5.4.2.5 of this report).
+
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the folicwing matters should be conidered for improvement:
See items (286/81-05-28) and (286/81-05-30).
5.4.2.10 Liquid Effluent Sampling The auditors reviewed available procedures and held discussions with chemistry personnel to evaluate the licensee's provisions for performing liquid effluent sampling under emergency conditions. The auditors noted that no special procedures were developed for emergency conditions.
,aring discussions with th: licensee, the auditors determined that procedures had not addressed post-accident tanks because the high level waste would not be released into the environment. However, the licensee also stated that during an accident situation, transfer I
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42 of previously stored liquid waste (routine storage approximately 22,500 gallons) could be transferred to the Con Ed Process Center Indian Point Unit 1 or the Chem-Nuclear demineralizer on site.
(See Section 6.1 of t'ns report.)
5pecific procedures to cover the possibility of high level liquid waste being present in the tanks, storage availability at the Indian l
Point Unit I facilities and special sampling techniques, e.g.,
precautions, sample size, labeling, handling, monitoring, etc. were not formulated by the licensee.
Based on the above findings, improvements in the following area are required to achieve an acceptable program:
See item (286/81-05-11).
5.4.2.11 Liquid Effluent Sampling Analysis 4
1 The auditors held discussions with the Chemistry Project Coordinator to evaluate the licensee's provisions for performing liquid effluent analysis under emergency conditions.
The auditors noted that special procedures were not developed for liquid effluent analyses since the licensee's intent was not to sample the waste hold-up or other storage tanks during accident situations (See Sections 4.1.1.8 and 5.4.2.10 of this report.)
l During the discussions, the licensee realized that the liquid waste tanks may have to be sampled and analyzed during accident situations.
The licensee stated that an analytical procedure with the appropriate precautions. prerequisities and analytical techniques would he i
developed aiong with a general plan for handling or storing accident-generated liquid wastes.
Based on the above findings, improvement in the following areas are required to achieve on acceptable program.
See item (286/81-05-11).
5.4.2.12 Radiological Enviror. mental Monitoring Program (REMP)
The auditors reviewed Section 7.4.2 of the Emergency Plan; Memorandu.
of Understanding No. 28 between Consolidated Edison and the licensee; and Procedure IP-1018, " Post-Accident Environmental Sampling and Counting".
Rev 4w of the above references and discussions with licensee personnel indicated they could likely implement REMP sample collection and analysis in a timely manner following an accident. The mechanism for program implementation, however, was informal.
IP-1018, which appeared to be designed to orchestrate environmental sampling, only
43 addressed itself in a general way to REMP implementation.
The procedure was li.cking assignments of personnel; priorities for sample collection and analyses; and preplanned sample collection frequencies for various magnitudes of activity released during an accident.
IP-1018 also indicated that the degree of REMP implementation post-accident would be decided by the Emergency Director (located in the ECC) with input from the Nuclear Environmental Monitoring (NEM)
Supervisor.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
Revision of procedure IP-1018 and other relevant procedures to detail the method by which the Emergency Director is to orchestrate the REMP sample collection and analyses, and to provide, as far practicable, for preplanned sample collection frequencies for various magnitudes and modes of activity releases following an accident.
(286/81-05-31) 5.4.3 Protective Actions 5.4.3.1 Radiation Protection During Emergencies The auditors reviewed the provisions for radiation protection during emergencies found in Procedures IP-1027, " Emergency Personnel Exposure";
IP-1040, " Habitability for Emergency Facilities"; IP-1041, " Issuance of Personnel Monitoring Devices to E0F, TSC, and OSC Personnel";
i IP-1045, " Technical Support Center"; as well as the Emergency Director's instructions, such as, notification of unusual event, alert, site area emergency, and general emergency.
Personnel dosimetry control is to be provided at the Control Room, Technical Support Center, Emergency Operations Facility and Operational Support Center. The guard force was equipped with dosimeters and will issue dosimetry to fire fighting personnel.
Exposure records are to be kept at each dosimetry location and access point.
Emergency workers will be assisted by health physics technicians to assure exposure control.
Procedure IP-1027, " Emergency Personna Exposure", provided for l
limiting personnel exposures and required the Emergency Director's approval for exposures above 10 CFR Part 20 limits.
Special controls consisted of monitoring the habitability of emergency facilities, i
limiting site access, monitoring workers outside of the emergency facilities, and assigning radiation protection responsibilities.
Procedure IP-1047, " Operations Support Center (OSC)", assigned the major health physics functions to the health physics team leader in the Operations Support Center.
Priorities for accomplishing radiation
4 44 i
J protection functions are to be correlated with the. priority of performing accident mitigation functions established by the Emergency Director in accordance with his emergency instructions.
Topics covered by the remainder of the procedures included exposure limits, personnel dosimetry, ALARA, access controls, exposure records, training, potassium iodide for thyroid blocking, and protective i
clothing and equipment.
In addition, the auditors noted that the l
majority of the procedures which required the performance of actions involving actual or potential exposure to radiation contained appropri-ate radiological cautions, precautions and prerequisites.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
i 5.4.3.2 Evacuation of Owner Controlled Areas Emergency Plan Implementing Procedure IP-1053 specified the actions to be taken by personnel and identified the routes in a diagram to be utilized by non-essential personnel for evacuation of the site.
According to Procedure IP-1053, evacuation of the site is.a three-step 4
process as follows: (1) the evacuation alarm is sounded and personnel immediately proceed to their predesignated assembly areas for account-ability; (2) when directed by the Emergency Director, personnel walk to the Service Center Building (at the site boundary), via the identified evacuation routes, for reassembly and reaccountability; and (3) when directed by the Emergency Director, personnel depart from site property.
The licensee had made provisions for monitoring and decontamination of personnel at the Service Center Building and for transportation of evacuees by means of Consolidated Edison Company vehicles.
F Assembly areas were conspiciously identified by.large blue / orange signs and evacuation routes were clearly marked with posted blue / orange arrows.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.4.3.3 Personnel Accountability l
i Emergency Plan Implementing Procedure IP-1050 specified the actions for personnel accountability. This procedure identified the locations of the assembly areas, specified the actions to be taken by onsite personnel, specified the duties and responsibilities of individuals responsible for the accountability process, and included reference to the search and rescue procedure, IP-1054.
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45 1
- i Person al are accounted _for by Area Accountability Officers in each of the six accountability areas.
First.line supervisors will account for their personnel and report any missing individuals to the Area
'{
Accountability Officer. Accountability.results are reported to the Officer Manager who is designated as the Lead Accountability Officer.
If assembled personnel are directed to proceed to the-assenbiy. area-
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at the Service Center Building, reaccountability will be performed upon arrival.
The auditors noted that during a recent accountability drill, approxi-mately 45 minutes were required to complete accountability of personnel during the day shift.
Based on the above findings, this portion'of the licensee's program appears to be acceptable.
5.4.3.4 Personnel Monitoring and Decontamination The auditors reviewed Procedure IP-1060, " Personnel Radiological Check and Decontamination", and spoke with the Health Physics Super-I visor concerning personnel monitoring and decontamination. The Health Physics Supervisor indicated that all personnel would ba checked for decontamination before leaving the site, however, the procedures did not address which individuals will be frisked nor where the monitoring would take place.
The procedure provided for a means for recording the names of individ-uals found to be contaminated, the level of contamination, the survey instrument used,'and the agents and methods used for deconta'm,.
ination. However, the procedure did not include a list.of personneF M frisked and not found to be contaminated.
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Contamination levels that required decontamination and,the decontamina-tion actions were provided in Procedure IP-1060, however, special-considerations for skin contamination with radiciodine were not ti addressed.
Problem contamination cases were to be handled by the Radiological Assessment Team Leader at the Emergency Operations
/
Facility.
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,s The procedure did not address means for providing collected data to the organizational element responsible for radiation protection n
during emergencies.
i1 Based on the above findings, this portion of the licensee's program f
appears to be acceptible, but the following matter should be considered.'
A-for improvement:
+
Modification of Procedure IP-1060 to include provisions:
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is (a) to ensure that all personnel leaving restricted areas or other-n areas suspected to be contaminated and individuals in assembly ~
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and reassembly areas are monitored for contamination; s
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46 (b) for maintaining records of all individuals checked for contamina-tion; (c) for special considerations for skin contaminated with radiciodine; and (d) for ensuring that collected data are provided to the crganiza-tional element responsible for radiation protection during emergencies.
(286/81-05-32) 5.4.3.5 Onsite First Aid / Rescue The auditors reviewed the licensee's procedures and held discussions with the Security and Safety Supervisor and other licensee personnel to verify that provisions for recovering, handling and transporting injured personnel were adequate.
The following procedures discussed the licensee's provisions for locating and treating injured persons, some of whom may also be contaminated.
IP-1020 Non-Radiological Medical Emergency IP-1021 Radiological Medical Emergency IP-1022 Transport of Contaminated Individuals between Unit 3 and 1 IP-1054 Search and Rescue Teams The auditors noted that the above procedures covered all key aspects such as search methods, first aid and radiation protection considera-tions, interface with offsite medical treatment facilities and transport methods.
It was also ncted that the patient will not be l
transported without approval of the physician for Indian Point, his l
alternate or the Radiation and Environmental Service Superintendent l
(RESS) if no other medical representative can ba contacted.
l Within the procedures, a General Instruction section was provided to the first aid, security, control room and health physics personnel.
l However, some of these instructions were vague.
For example, HP l
personnel were instructed to respond to the scene with proper survey instruments, evaluate fields and mark victims.
Specifics, such as type l
of instrument and range desired, criteria for evaluating dose rates l
and the labeling technique with which the patient would be marked, were not included.
Procedures IP-1021 and 1022 should also emphasize that medical attention takes precedence over decontamination if the patient's life is endangered.
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47 Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
Provision of specific instructions, guidance and criteria in Procedures IP-1020, IP-1021, IP-1022, and IP-1054 to ensure the proper instruments and techniques are used. (286/81-05-33) 5.4.4 Security During Emergencies Licensee management stated that there were no procedures for special security measures or consideraticns during radiological emergencies and that site contingency procedures did not address radiological emergencies.
Based on the above findings, improvement in the following area is required to achieve an acceptable program:
Development of procedures for maintenance of security during emergency conditions.
(286/81-05-34) 5.4.5 Repair / Corrective Actions Emergency Plan Section 6.5.2 states that a repair and corrective action team would be organized by the Operations Support Center Supervisor or Shift Supervisor as needed.
Emergency Plan Implementing Procedure IP-1025, " Repair and Corrective Action Teams", outlines the actions the team are to take to provide themselves with radiological protection. However, the procedure did not provide for development and review of ad hoc special procedures to be used nor for practice of the actions to be taken by repair and corrective teams in high radiation areas. The procedure specified that the HP who accompanied the team will carry an instrument that can measure at least 25 R/hr.
The procedure also stated that the applicable Radiation Exposure Authorization (REA) would be followed but does not discuss how REAs would be executed under accident conditions.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be considered for improvement:
f, Procedural provisions for:
I' (a) Development and review of ad hoc procedures for repair and corrective actions during emergencies; (b) Team practice of corrective actions to be performed prior to entry into high radiation areas; i
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48 (c) Clarification as to how REAs are to be executed during accident conditions; and (d) Use of a survey instrument for the team with a range sufficient to measure radiation fields of 1000 R/hr or more.
(286/81-05-35) 5.4.6 Recovery The Corporate Emergency Plan (Interim) identified the individuals who would occupy the key positions in the recovery organization and specified their authorities and responsibilities. Section 9.0 of the Emergency Plan generally described the recovery organization and recovery operations.
The Emergency Plan provided for the tran;ition from the emergency phase to the recovery phase after mutual agreement between the Recovery Manager and the Emergency Director that plant conditions are stable and the transition is appropriate. There were no specific criteria for implementation of the recovery phase nor criteria upon which the emergency classes will be downgraded. The auditors also determined that the licensee had no specific provisions for notification of the response organizations nor the various
'offsite agencies prior to entering the recovery mode.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be considerea for improvement:
Specification of specific criteria-upon which the emergency classes will be downgraded and for entering the recovery mode.
(286/81-05-36)
Provisions for notification of Federal, State 2nd local officials and response organizations prior to entering a downgraded or recovery mode.
(286/81-05-37) 5.4.7 Public Information The Corporate Emergency Plan specified the authority, responsibilities, and duties of the Public Information Director. The Public Information Director was designated as the company spokesperson and is responsible for disseminating public information and coordinating information releases among Federal, State, and local agencies. The plant Emergency Plan and Information Procedures identify the plant Information Officer as the Special News Center Director. The Special News Center Director, under the Public Information Director, is responsible for the activation and operation of the Special News Center.
Licensee personnel stated that the plant Information Officer would be the point of contact for the news media prior to activation of the Special News Center.
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49
'the plant Information Procedures identify the media organizations involved in news dissemination and the locations and means of contac-ting these organizations.
At the present time no procedure or program exists for providing residents of the plume EPZ with information regarding action to be taken during an emergency.
(See also Sections 6.2 and 6.3 of this report.)-
Based on the above findings, improvements in the following area are required to achieve an acceptable program:
Development and implementation of a program for dissemination of information to the public and the news media regarding the actions to be taken by individuals within the plume EPZ during an emergency.
(286/81-05-38) 5.5 Supplementary Procedures 5.5.1 Inventory, Operational Check and Calibration of Emergency' Equipment, Facilities and Supplies The licensee's Procedure IP-1070 provided a specific inventory listing of all equipment reserved for use during emergencies and specified the location of this equipment.
The frequency at which emergency equipment was to be inventorted, operationally checked and/or calibrated is specified in Paragraph 3.2 of Procedure IP-1070. The responsibility for the performance of emergency equipment readiness checks was assigned to health physics personnel for the equipment located _in the Control Room and Technical
'~
Support Center. The Security Shift Coordinator.was assigned the-responsibility for inventories of emergency equipment, including communications equipment in the Command Guard House.
There were no provisions by the licensee (PASNY) to verify emergency equipment inventories dedicated for use during emergencies at either Indian Point Unit 2 or Indian Point Unit 3.
This equipment was inventoried by Indian Point 2 personnel, but records of such inventories were not supplied to the licensee.
Based on the above findings, this portion of the licensee's program appears acceptable, but the following matter should be conidered for improvement:
Verification and documentation that inventories of emergency equipment designated for common use for emergencies at Indian Point Unit 2 and Indian Point Unit 3 are correct and that routine equipment operability checks were performed.
(286/81-05-39)
50 5.5.2 Drills and Exercises Procedure IP-1080, " Conduct of Emergency Drills", specified that drills and exercises would be conducted.
Section 8.2 of the Emergency Plan designated the Assistant to the Radiological and Environmental Services Superintendent as the drill and exercise coordinator. The procedure and Emergency Plan provided for scenario development in advance of the drill, emergency plan training, review of the scenarios, assignment of observers, guidelines for conducting the drills and exercises, critiques, duties of the coordinator, and PORC review of deficiencies and recommendations for resolution. The procedure assigned the Plant Manager and/or Superintendent of Power the respon-sibility to ensure that all deficiencies were adequately reviewed and corrected. Section 3.0 of Procedure IP-1080 specified the drill and exercise schedules for the following:
Independent Radiological Drill (annually)
Joint Radiological Drill with Indian Point Unit 2 (annually)
Fire Drill (quarterly)
Medical Emergency Drill (annually)
Environmental Monitoring Drill (annually)
Health Physics Drill (semiannually)
Inplant Liquid Sampling Drill (annually)
Communications Drill (monthly with government agencies in the l
plume exposure pathway; cuarterly with the States of New Jersey, Pennsylvania and Connecticut and the NRC, as well as New York State counties; and annually with State and local Emergency Operations Centers).
There were also provisions for routinely inviting Federal, State and local offsite agencies and groups to participate in the drills and exercises.
There were provisions for handling news media coverage of the drills / exercises using the news media facilities, equipment and procedures that would be used during an emergency (See Section 4.1.4 of this report.)
Based on the above findings, this portion of the licensee's program appears to be acceptable.
51 5.5.3 Review, Revision and Distribution of Emergency Plan and Procedures Telephone numbers were reviewed quarterly as specified in the Emergency Plan, however, the " call-in rosters" in Appendix A of the Implementing Procedures were not dated to indicate the last update.
Section 8.3 of the Emergency Plan described how pracedures which implement the emergency plan are reviewed annually to incorporate changes resulting from drills or changes in the facility or environs.
The responsibility for the review was specified.
The plan and procedures had been reviewed, approved and updated as required.
Changes had been distributed in accordance with the approved distri-bution list. Names, titles, and phone numbers in the Implementing Procedures, Appendices A and B were correct except for the Putnam County Warning Point.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter shoulu be considered for improvement:
Provisions for dating " call-in rosters" to ensure that the current revisions are properly distributed and in use.
(286/81-05-40) 5.5.4 Audits of Emergency Preparedness The Emergency Plan and procedures which implement the Emergency Plan were audited at no longer than four month intervals and generally were done on a quarterly basic in accordance with the QA procedures.
All audits reviewed had included discussions with pertinent personnel and inspection of equipment. Any deficiencies were noted and correc-tive actions documented.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
52 6.0 COORDINATION WITH OFFSITE GROUPS 6.1 Offsite Agencies The auditors contacted responsible individuals within the following groups: Westchester County Office of Emergency Services and County
-Warning Point; Rockland County Warning Point; Orange County Civil Defense Office and County Warning Point; Putnam County Civil Defense 0ffice and County Warning Point; U. S. Coast Guard; Verplanck Fire Protection' Associa-tion; Peekskill Community Hospital; and Consolidated Edison Westchester Emergency Supervision No. 9 (evacuation transportation).
(The auditors noted that the phone number for the Putnam County Warning Point listed in Appendix B of the Implementing Procedures and in the control room was incorrect for off-hour notifications; however, this number would be the third means of offsite notification.) (See Section 5.5.3 of this report.)
These contacts verified that the licensee had contacted the responsible agencies for the purpose of conducting drills, exercises and training.
Each agency representative contacted expressed satisfaction with the coordination efforts as they related to notification arrangements, training and routine information exchange.
Agreements between the licensee and Peekskill Hospital, fire / ambulance, DOE and the U. S.~ Coast Guard were current and the groups contacted stated that the agreements would be honored.
The licensee's protective action guides and those of the counties within the plume exposure EPZ were consistent with the EPA protective action guides. However, the arrangements between the counties and the licensee did not require the licensee to recommend protection actions promptly.
The licensee was only required to provide emergency class, wind speed and direction, Pasquill category and the status of safeguards systems within 15 minutes of declaration of a General Emergency. The Site Area and General Emergency procedures required the assessment of projected offsite doses by the Emergency Director or Radiological Assessment Team Leader and the recommendation of protective actions by the Emergency Director, however, there was no indication when this would be accomplished,'nor did the notification procedure (IP-1030) mention protective action recommenda-tions.
(See also Section 5.4.2 of this report.)
The county officials stated that the current county emergency plans required implementation of protective actions based on EPA PAGs as they relate to dose projections.
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53 The NRC Region I Emergency Preparedness Coordinator inspected the licensee's E0F, TSC and other emergency response facilities and equipment and discussed with the licensee the emergency organization and concept of operations to assure that the NRC could. effectively interact with the licensee's organiza-tion in response to an emergency at Indian Point Unit 3.
The auditors noted that the available work space for the NRC in the EOF was inadequate for this purpose.
Further, the existing telecommunications. equipment at the EOF and TSC for use by the NRC was not sufficient for NRC needs. As discussed in Section 4.1.1.8 of this report, the licensee has contemplated the option of transferring post-accident liquid wastes to con Edison's facilities at Indian Point Units 1 and 2.
The auditors were unable to verify that the licensee (PASNY) had obtained any written agreements with Con Ed relative to these actions.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be considered for improvement:
Coordination of the interface between the licensee and NRC Region I through the Region I Emergency Preparedness Coordinator concerning the work space and communication needs of the NRC emergency response organization.
(286/51-04-41)
Provision of a writtun agreement with Consolidated Edison concerning transfer of post-aceident liquid effluents, if such transfers are considered as an option.
(286/81-05-42) 6.2 General Public Section 8.5 of the Emergency Plan describes the licensee's provisions for disseminating emergency planning information to the permanent and transient population within the plume exposure EPZ by means of mass-mailed publica-tions, telephone book advertisements, and posters installed at motels, hotels and other transient areas. The emergency information is being coordinated with State and local agencies and neighboring licensee's.
The Emergency Plan provides for the update and dissemination of the information on an annual basis.
The auditors were informed by licensee management that emergency information for the public is currently under development and that no information had yet been disseminated.
Consequently, the auditors were unable to verify -
i whether the information to be provided to the public meets the content outlined in the Emergency Plan.
The licensee had committed to a program for dissemination of emergency information to the general public by August 1981.
(See also Section 5.4.7 of this report.)
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
Sea item (286/81-05-38).
r 4
54 1
6.3 News Media 2
Section 8.5 of the Emergency Plan specified that familiarization programs
~
will be conducted on an annual basis to acquaint news media personnel with information concerning' emergency plans, radiation, and licensee 4
points of contact.
The auditors noted that such a program was conducted i
in September, 1979 but the scope of the presentation did not include 1
information relative to protective actions.
Licensee management stated that protective action information would be incorporated into the program.
The licensee has information kits to be distributed to news media personnel.
The kits contained general and technical information, diagrams, and photographs; however, the kits contained no-information relative to protective actions.
Licensee managerrant stated that protective action information will be included in the kits.
(See also Sections 5.4.7 and
. 6.2)
Based' on the above findings, improvement in the following area is required to achieve an acceptable program:
See Item (286/81-05-38).
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55 7.0 DRILLS, EXERCISES AND WALK-THROUGHS 7.1 Drill and Exercise Program Licensee management stated that the required drills and exercises were conducted during the past year. The auditors reviewed a sampling of the
-licensee's drill records and noted that critique sheets and drill descrip-tions had been prepared as required by the emergency procedures (See Section 5.5.2 of this report.) The critiques identified items requiring improvement. The Senior Engineer or Assistant to the Radiological and Environmental Services Superintendent was responsible for review and correction of deficiencies.
Licensee mariagement stated that the defic-iencies identified during the past year have been addressed.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
7.2 Walk-Through Observations 7.2.1 Emergency Detection (EAL Recognition) and Emergency Classificat<.on The auditors performed walk-throughs with two Emergency Director qualified personnel through Emergency Action Level (EAL) recognition and event classification; one during dayshift and a second during the backshift.
In both cases, the personnel were presented with the following conditions:
R-2 monitor offscale; R-7 monitor offscale; ECCS acti-vation; and containment pressure greater than 23 psig and rising slowly and all actions to reduce it are ineffectiva. The individuals were told to assume that the conditions existed and to denonstrate and talk his way through the response. The individuals proceeded immediately to the " Indication to Operators" Section of Plant Emerg-ency Procedure PEP-ES-1, "ECCS Activation", and did not acknowledge the general note on page one of the procedure, which states:
" Fo r additional information on classification of the events contained in this emergency procedure, refer to ' Emergency Conditions Indicators and Categories' (Table 4.1) of the Emergency Plan." One of the individuals implementing this procedure stated that this situation was at least a Site Area Emergency and he proceeded to the.SA (Site Area) procedure and attempted to classify the event. They proceeded to examine each emergency action level (EAL) in the Site Area and General Emergency procedures to determine if it had been exceeded.
The auditors observed that one of the individuals apparently had difficulty in classifying the event. The individual was asked by the auditors to establish the reason for this apparent difficulty.
He indicated that the EALs were not organized in the same manner as the Plant Emergency Procedures (PEPS). That is, by initial plant condition indicator (in this case, ECCS activation) and then by the
-~
56 indicators checked by the operators in implementing the PEP.
In addition, many of the EALs were not in terms of specific plant instrument readings. The Emergency Director qualified individuals stated if the EALs were organized to follow the operator checks in the PEPS, this would be very helpful. The auditors also asked the individual if he had been given the opportunity to review the EALs contained in the Emergency Procedure prior to their issuance. He stated that he had received training on the EALs but had not been asked to review them for useability.
(See Section 5.2 of this report.)
7.2.2 Emergency Classification Two individuals on different shifts were instructed by the auditors to walk-through the steps taken by them to determine the classifica-tions of an emergency. They proceeded to the Site Area Emergency i
Control Room Step List. They were then asked by the auditors to demonstrate calculation of site boundary doses. They selected Implementing Procedure IP-1002, " Determination of the Magnitude of Release", and demonstrated a thorough understanding of its use and their ability to calculate site boundary doses.
Findings and observations summarized above were evaluated as part of findings in Sections 5.1, 5.2 and 5.3.
7.2.3 Notifications Control room personnel were asked by the auditors to demonstrate -
offsite notification. They utilized Implementing Procedure IP-1030,
" Emergency Nctification and Communications", and deTanstrated a thorough understanding of its use and the communications system in the control room. The auditors contacted by telephone the Westchester County Warning Point at 1843 hours0.0213 days <br />0.512 hours <br />0.00305 weeks <br />7.012615e-4 months <br /> from the control room.
Following an explanation of the purpose of the call, the auditor requested the warning point to contact county officials who were responsible for making protective action decisions and asked them to call the control l
room. The County Health Officer returned the call at 1853 hours0.0214 days <br />0.515 hours <br />0.00306 weeks <br />7.050665e-4 months <br /> and the County Emergency Services Director at 1859 hours0.0215 days <br />0.516 hours <br />0.00307 weeks <br />7.073495e-4 months <br />.
Both officials indicated that they would meet at the County Control Point with other county officials before implementing a site protective action recommendation.
The findings and observations summarized above were evaluated as l
part of the findings in Sections 5.4.1 and 6.1.
l l
57 7.2.4 Dose Calculations The auditors conducted a practical drill of Indian Point Unit 3 offsite dose assessment capabilities.
The auditors asked that a qualified Emergency Director, a Communicator, and two health physics technicians participate in the drill.
The drill required activation of the Emergency Operations Facility, performance of monitoring along the site boundary and communications between the survey team and the Emergency Operatiens Facility.
The Emergency Director was also asked to calculate offsite doses at specified points based upon the readings provided by the site boundary monitoring team.
The auditors specified that the wind direction was from 0 degrees and that all plant instrumentation was available to determine the source term and the release rate. The Emergency Director contacted the control room to obtain the stability class. This information was only requested once from the auditor. Assuming that the control room followed Procedure IP-1003, this stability class was subject to rapid change and the stability class should have been requested repeatedly from the control room or a time average should have been used. The Emergency Director selected the correct overlay for the specified direction and stability class and placed it correctly on the map table. The Emergency Director proceeded to use Procedure IP-1010, " Site Perimeter Survey", as required by the Site Area Emergency Instruction.
The Emergency Director attempted to use the diffusion overlay to identify the portions of the site boundary which would have the highest dose rate.
This was difficult to do since there is very little detail on the site boundary on the Emergency Planning map.
He also attempted to find the numbered monitoring locations using the map in Procedure IP-1010.
The Emergency Director directed the monitoring team to locations "12 through 14" rather than locations "10 through 12", as was indicated in the table in Procedure IP-1002. The Emergency Director apparm tly did not realize that a detailed version of the site perimeter map was posted on the wall of the Emergency Operations Facility.
This is not a serious error because wind shifts can easily change the location of the maximum site boundary dose rate between the time that the teams are dispatched and the time that the teams arrive at the site boundary.
The procedures that the teams follow for site boundary monitoring clearly instruct them to continue monitoring until they have unambigiously determined the location of the plume central line.
The above observations were made in order to provide a complete record of the practical drill and to indicate what is possibly a lack of coordination between procedures.
It should be noted that the objective of this emergency procedure was in part to determine location and magnitude of the plume center line dose rate.
58 The auditors then d'vided into two teams, one followed the health physics technicians while the second remained with the Emergency Director and the Communicator in the Emergency Operations Facility.
The health physics technicians followed the instructions given by the Emergency Director. They made frequent measurements, both used instruments, obtained beta / gamma readings and recorded all data.
When asked to perform a measurement of airborne radioiodine they replied that they did not have access to portable air monitoring equipment. They indicated that such equipment had been purchased but not yet been issued for use by the health physics technicians.
They stated that airborne iodine measurements along the site boundary would be made by the offsite monitoring team maintained by Consolidated Edison Company. When the auditors asked the technicians to return to the Emergency Operations Facility and perform airborne iodine measurements there, the health physics technicians replied that the Emergency Operations Facility contained Consolidated Edisons equipment and that during an emergency Consolidated Edison personnel would operate that equipment.
During the time the health physics technicians were monitoring site boundary dose rates, the Emergency Director correctly calculated the child thyroid dose rate at the site boundary from the gamma dose rate according to Procedure IP-1001 and correctly used the overlays to determine the dose rate at a location selected by the auditor.
The auditor then asked the Emergency Director what protective actions were appropriate at this offsite location. He stated that the appropriate protective actions are dependent upon the duration of the release. He stated that the duration of the release would be supplied by the control room. The auditors asked what duration would be used if the control room could not supply a firm value.
The Emergency Director indicated that there was no specific predeter-mined default value for the duration of exposure. As discussed in Section 5.3 of this report, this was a deficiency in the procedures used to determine protective actions.
When the health physics technicians returned to the Emergency Operations Facilities they quickly found silver zeolite cartridges.
The auditors requested that charcoal cartridges be used for the purpose of the drill. The technicians took an air sample at a flow rate of 1.3 cubic feet per minute.
The technicians then prepared to measure the activity on the air filter using the SAM-2 radiation detector. The technicians seemed to be unfamiliar with the radiation detector and referenced the Consolidated Edison Procedures for using this detector.
They did not use the Indian Point Unit 3 Procedure, IP-1015, " Airborne Iodine-131 Determination Using the SAM-2/RD-22 or RM-14/HP-210".
59 The HP technicians followed the Consolidated Edison procedures and began to make measurements of the radiation sources in the background.
The background count rate was extremely high, being approximately 54,000 counts per minute. The technicians demonstrated a high level of proficiency by surveying around the SAM-2 detector with a. survey meter. They found a check source had been lodged between the detector and its lead shield. This accounted for the excessive background count rate. The technicians then proceeded to' count the radioactivity on a " spiked" sample cartridge provided by the auditors as well as a filter obtained from sampling room air. The technicians made several errors in calculating the iodine concentration.
They used the flow rate in one equation rather than the volume sampled.
This was'at least partly due to the Consolidated Edison procedure not being very clear on this point. The procedure was not well-designeJ for a user who is not thoroughly familiar with it.
(It should also be noted that the licensee's procedure IP-1015 contained a similar error on page 4 where the volume and the flow rate were both given in units of cubic feet). Next the technicians inserted the detector efficiency into the equation as a percentage rather than a decimal number.
This was again partly attributable to the procedures which did not clearly identify the units of efficiency and partly because the calibration sticker on the top of the SAM-2 instrument gave efficiency in the form of percentage.
The technicians also confused the check source reading with the readings of one of the air filters, thereby creating a third error.
The auditor felt that during a real emergency the dose assessment team would have been available in the Emergency Operations Facility to provide guidance to the health physics technicians. The Emergency Director and the health physics technicians demonstrated good practical knowledge of the tasks that they were assigned.
The problems that were encountered could be readily resolved by better coordination of the procedures, better knowledge of the Memorandum of Understanding, training the technicians with Procedure IP-1015, and providing portable air monitoring equipment for the site boundary teams.
The findings and observations summarized above were evaluated as part of the findings in Sections 5.4.2, 5.4.2.1 and 5.4.2.2.
7.2.5 Post-Accident Coolant Sampling and Analysis The auditors conducted a walk-through of the licensee's reactor coolant accident sampling system with chemistry and health physics personnel to simultaneously evaluate organizational factors, equipment, facilities, procedures and training. The auditors made observations, proposed questions and discussed the procedures with licensee represen-tatives.
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60 A two-man team composed of a chemistry technician and health physics technician was used to take '.he simulated reactor coolant sample.
The team dressed in protective clothing as advised by the health physics supervisor.
They were provided with dosimetry, which included a TLD, a low-range pocket dosimeter (0-200 mR), high range dosimeters taped to the inside of their wrists (0-10 R), and TLD finger rings.
Self-contained breathing apparatus (SCBA) devices were also used.
The team had a short briefing from the Project Chemistry Coordinator and the Health Physics Supervisor. The chemistry technician was given last minute instructions concerning the procedure (RE-CS-042) to be used and the health physics technician was advised on where and how to survey the areas.
The team performing the reactor coolant sampling and analyses was also demonstrating the sampling of containment air and plant vent.
For the purpose of this section of the report, only the reactor coolant sampling will be addressed.
The chemistry technician appeared to be very familiar with the procedure and the equipment. The technician quickly located valves that needed to be opened or shut. He had a slight problem confirming that he had performed the necessary manipulations on the valves for each step of the procedure. This problem could be resolved by some method of checking off performed steps.
(Refer to Sections 5.4.2.4 and 5.4.2.L of th:s report.)
The auditors observed that the chemistry technician was able to communicate adequately with the control room and with the health physics technician while wearing the self-contained breathing apparatus.
The chemistry technician quickly set up and made the necessary preparations to take and analyze the primary coolant sample.
The technicians, however, had a problem with the winch used to raise the lead wall on the shielded sample container.
It took the technician in excess of 10 minutes to raise the wall and proceed with the preparations.
It was demonstrated to the auditors that the shielded sample cask could be moved around with relative ease.
For safety reasons, the cask was not hoisted from the 41-foot level to the 55-foot level; however, the technician explained how the cask would be lifted and said it would take approximately 30 minutes to lift the cask to the higher elevation.
The technician said that he did not perform the calculations on the sample data.
The information would be given to his supervisor for computation. The technician was unaware of what would then happen to the information obtained from the reactor coolant sample. The procedures did not address how the reactor coolant sample data would be used.
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61 Based on the observations during the walk-through, it was evident that the chemistry technician was well trained and capable of performing the necessary sample taking and analysis.
Findings and observations summarized above were evaluated as part of the findings in Sections 5.4.2.4 and 5.4.2.5.
7.2.6 Post-Accident Containment Air Sampling and Analysis The auditors conducted a post-accident containment air sampling and analysis walk-through with a chemistry and health physics technician to allow for simultaneous evaluation of organizational factors, equipment, facilities, procedures and training. The auditors made observations, proposed questions and discussed the procedures with the technicians.
The chemistry technician was charged with taking the samples while the health physics technician acted as the Radiation Exposure Authority (REA). A survey of the area for air contamination and dose rates was started before the sampling. The two individuals were wearing SCBA, Anti-Cs, high range dosimeters, extremity dosimeters, protective gloves and booties. The dressing procedure, with help from other technicians, took approximately 15 minutes.
Although a diagram of the sampling locations was not included with the procedure, the chemistry technician followed the blueprint information to properly isolate the containment sampling line.
For each of the valve opening / closing steps, the chemistry technician followed the procedure as written. While the chemistry technician prepared the sampling eauipment, the health physics technician continued to take dose rate readings.
However, when the sampling team returned from exchanging respirator bottles, the health physics technician did not take survey readings as they traversed to the work area.
When the gas sample was to be withdrawn, the chemistry technician opened the shielded sampling compartment instead of extracting the sample from outside the compartment. The auditors noted that the procedure was not clear as to specifically where or how the gas sample was to be taken.
When it was time to retrieve the particulate and iodine sample, the health physics technician did advise the chemistry technician to keep the sample away from his body.
The auditors noted that a lead pig would have been more croropriate. No information concerning sample transportation was included with the procedure.
62 During the analysis, good counting practices were observed and the technician discussed with the auditors how he operated the counting equipment'. (For analvsis of percent hydrogen, the instrument was operated on the incorrect setting for the sample size taken.)
However, no written procedures were available to follow concerning reporting the results to the organizational element responsible for assessment action.
Based on the observations during the walk-through, the individuals performed well. However, there were a few equipment and procedural problems as were discussed in Sections 4.1.1.6 and 5.4.2.6 of this report.
4 7.2.7 In plant Iodine Measure:nents and Monitoring The auditors conducted practical drills in three areas:
iodine monitoring in the Control Room, iodine monitoring in the Emergency Operations Facility (EOF), and plant vent monitoring using a high range survey instrument (Teletector).
As part of the practical drill of the Shift Supervisor's implementation-of the Site Area instructions, a health physics technician was called to the control room to assess habitability. This drill occurred on the back shift. The health physics technician was interviewed and the contents of the emergency locker was examined.
The locker was stocked as indicated in the Emergency Plan. The health physics technician was asked to measure the iodine concentration in the control room atmosphere. He immediately began to sample the control room atmosphere for airborne particulate and iodine and then i
he assembled and checked a SAM-2 type of counting device.
The technician appeared to be familiar with the equipment and well practiced in the measurement technique. He measured the particulate filter j
and the charcoal filter simultaneously as a conservative prr.ctice.
The result was 3.6 E-10 uCi/cc of I 231.
The value was approximately equal to the MDA of the measurement process. This measurement satisfied the sensitivity requirements of NUREG-0654.
As part of the practical drill of the Emergency Operations Facility (EOF), the health physics technician who performed the site boundary survey was requested to measure the iodine concentration in the EOF.
The actual measured value was 1.2 E-10 and the MDA was 7 E-10 uCi/cc of I-131.
This practical drill has been discussed above in greater detail.
The health physics technicians who performed the iodine survey in 1
the control room was also requested to explain the process of obtaining a measurement of the release rate by use of a measurement of direct radiation at contact with the plant vent duct. The health physics technician was aware of the procedure for this measurement and
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measures to be taken. These measures included dosimetry, high range monitor, anti-C clothing, a rainsuit, and respiratory protection.
He was aware that the procedure mentioned two-measurements: one 10-feet above the surface elevation six feet from the duct and another 10 feet above the surface at contact with the duct.
He explained that he w3uld use the teletector to survey around corners, partitions, etc., probing each area prior to entering.
The auditors concluded, based upon the above observations, that the Indian Point Unit 3 reactor is adequately equipped for in plant radiciodine monitoring and the health physics technician exhibited a reasonable understanding of the measurements required and an acceptable level of practical skill.
Findings and observations summarized above were evaluated as part of the findings in Sections 5.4.2.3, 5.4.2.6 and 5.4.2.8.
7.2.8 Protective Action Decision-Making Control room personnel were asked to determine what protective actions should be recommended to offsite agencies. They proceeded to Implementing Procedure IP-1017, " Recommendation of Protective Actions for Offsite Population," and demonstrated they could implement the procedure.
However, it was stated that this procedure would probably only be used by the Emergency Director at the EOF once it was activated.
Findings and observations summarized above were evaluated as part of findings in Section 5.3.
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.o INDIVIDUALS CONTACTED 1.
Licensee Personnel
- J. Bayne, Senior Vice President, Nuclear Generation (PASNY)
R. Bowman, Office Manager (IP-3)
- J. Brons, Resident Manager (IP-3)
- J. Dube, Security and Safety Supervisar (IP-3)
R. Deschamps, Health Physics Supervisor (IP-3)
- C. Faison, Nuclear Emergency Preparedness Engineer (PASNY)
- J. Gillen, Project Chemistry Coordinator (IP-3)
- D.-Halama, Quality Assurance Superintendent (IP-3)
- W. Hamlin, Assistant to the Resident Manager (IP-3)
- W. Jostger, Superintendent of 'Pswer (IP-3)
- J. Kelly, Manager of Radiation Health and Safety (PASNY)
B. Lindgren, Information Officer (IP-3)
- L. Lomonaco, Assistant to the, Radiation and Environmental Services Superintendent (IP-3)
- S. Munoz, Technical Services Superintendent (IP-3)
A. Nelson, Senior Emergency Preparedness Engineer (PASNY)
- N. Passman, Reactor Analy'st Supervisor (IP-3)
- J. Perotta, Radiation and Environmental Services Superintendent (IP-3)
D. Quinn, Radiological Engineer (IP-3)
- C. Spieler, Vice President, Public Relations (PASNY)
- E. Tagliamonte, Operations Superintendent (IP-3)
- Denotes those also present at the exit meeting.
2.
In addition to the above, members of the appraisal team also interviewed licensee members of plant operations, radiation protection, corporate staff personnel as well as local, county and State officials.
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