ML20039B270
| ML20039B270 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 12/17/1981 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Gilberts D NORTHERN STATES POWER CO. |
| Shared Package | |
| ML20039B271 | List: |
| References | |
| NUDOCS 8112220477 | |
| Download: ML20039B270 (10) | |
See also: IR 05000282/1981020
Text
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Docket No. 50-282
Docket No. 50-306
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Northern States Power Company
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ATTN:
Mr. Dennis E. Gilberts
Senior Vice President
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Gentlemen:
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Subject: Emergency Preparedness Appraisal
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To verify that licensees have attained an adequate state of onsite emer-
gency preparedness, the Office of Inspection and Enforcement is conducting
special appraisals of the emergency preparedness programs at all operating
nuclear power reactors. The objectives of these appraisals are to evaluate
the overall adequacy and effectiveness of emergency preparedness and to
identify areas of weakness that need to be strengthened. We will use the
findings from these appraisals as a basis not only for requesting individual
licensee action to correct deficiencies and effect improvements, but also for
effecting improvements in NRC requirements and guidance.
During the period of Ncvember 2-13, 1981, the NRC conducted a special
appraisal of the emergency preparedness program at the Prairie Island
Nuclear Generating Plant. This appraisal was performed in lieu of certain
routine inspections normally conducted in the area of emergency preparedness.
Areas examined during this appraisal are described in the enclosed report
(50-282/81-20; 50-306/81-22). Within these areas, the appraisal team reviewed
selected procedures and representative records, inspected emergency facilities
and equipment, observed work practices, and interviewed personnel.
Significant deficiencies for which you have made acceptable commitments
to resolve are discussed in the Confirmation of Action Letter dated
November 18, 1981, enclosed as Appendix A.
The findings of this appraisal also indicate that there are areas for
improvement in your emergency preparedness program. These are discussed
in Appendix B, " Appraisal Improvement Items."
8112220477 011217
PDR ADOCK 05000282
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Northern States Power
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DEC 171981
Corepany
In conjunction with the aforementioned appraisal, emergency plans for your
facility were reviewed. The results of this review indicate that certain
deficiencies exist in your " Prairie Island Emergency Plan" and " Corporate
Emergency Plan." These are discussed in Appendix C, " Emergency Preparedness
Evaluation Report."
Several areas in your emergency preparedness program were not complete at
the time of this appraisal and therefore were not examined. These items
are identified as Open Items and are listed in the enclosed Appendix D.
These will be. examined by our staff upon complete implementation of the area
involved. Please notify our office relevent to your completion schedule of
these items for re-examination by our staff.
We recognize that an explicit regulatory requirement pertaining to each
item identified in Appendices A, B, and C may not currently exist. Not-
withstanding this, you are requested to submit a written statement within
thirty days of the date of this letter, describing your planned actions
for improving each of the items identified in Appendix A and the results
of your consideration of each of the items in Appendix B.
This description
is to include:
(1) steps which have been taken; (2) steps which will be
taken; and (3) a schedule for completion of actions for each item. This
request is made pursuant to Section 50.54(f) of Part 50, Title 10, Code
of Federal Regulations. With regard to Appendix C, within 90 days of the
date of this letter you are requested to provide changes to the emergency
plan correcting each deficiency. Copies of these changes are to be sub-
mitted in accordance with the procedures delineated in 10 CFR 50.54(q).
This is to inform you that should the deficiencies addressed in the Con-
firmation of Action Letter of November 18, 1981, not be corrected by the
commitment dates provided, the Commission will determine whether the reactor
shall be shut down until such deficiencies are remedied or whether other
enforcement action is appropriate.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy
of this letter, the enclosures, and your response to this letter will be
placed in the NRC's Public Document Room.
If the enclosures contain any
information that you or your contractors believe to be exempt from dis-
closure under 10 CFR 9.5(a)(4), it is necessary that you (a) notify this
office by telephone within seven (7) days from the date of this letter of
your intention to file a request for withholding; and (b) submit within
twenty-five (25) days from the date of this letter a written application
to this office to withhold such information. Section 2.790(b)(1) requires
that any such application must be accompanied by an affidavit executed by
the owner of the information which identifies the document or part sought
to be withheld,.and which contains a full statement of the reasons which
are the bases for the claim that the information should be withheld from
public disclosure. This section further requires the statement to address
with specificity the cor. tiderations listed in 10 CFR 2.790(b)(4). The
information sought to be withheld shall be incorporated as far as possible
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Northern States Power
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tDEC 171981
Company
into a separate part of the affidavit.
If we do not hear from you in this
regard within the specified periods noted above, a copy of this letter, the
enclosures, and your response to this letter will be placed in the Public
Document Room.
The responses directed by this letter and the accompanying Notice are not
subject to the clearance procedures of the Office of Management and Budget
as required by the Paperwork Reduction Act of 1980, PL 96-511.
Should you have any questions concerning this inspection, we will be pleased
to discuss them with you.
Should you have any questions concerning the items
of Appendix C, please contact Mr. W. L. Axelson, Chief, Emergency Preparedness
Section at (312)932-2535.
Sincerely,
s
Original signed by
A. Cert Davis
James G. Keppler
Regional Administrator
Enclosures:
1.
Appendix A, Confirmation of
Action Letter dtd 11/18/81
2.
Appendix B, Preparedness
Improvement Items
3.
Appendix C, Emergency
Preparedness Evaluation
Report
4.
Appendix D, Open Items
5.
Inspection Reports
No. 50-282/81-20 and
No. 50-306/81-22
cc w/encls:
F. P. Tierney, Jr., Plant Manager
DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII
John W. Ferman, Ph.D., Nuclear
Engineer, MPCA
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Appendix A
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Docket No. 50-282
Docket No. 50-306
Northern States Power Company
ATTN:
Mr. Dennis E. Gilberts
Senior Vice President
Power Supply
414 Nicollet Mall
Minneapolis, MN 55401
.
Gentlemen:
This letter is to confirm agreemer.ts reached between you and others of
your staff, and Mr. Carl Paperiello and other members of the NRC staff on
November 13, 1981, during the management exit interview following the NRC
Emergency Preparedness Appraisal.
Immediate corrective actions are required for significant Appraisal findings'.
The exact nature of the required actions, as well as the agreed upon dates
,
for such actions, are as follows:
1.
Emergency Equipment and Facilities (282/81-20-18; 306/81-22-18)
Required Action
A primary meteorological measurements system which complies with RG 1.23
criteria shall be installed and made operational. This program as out-
lined shall include:
a.
A 60 meter tower measuring meteorological conditions at a minimum
of two levels (i.e., 10 and 60 meters).
b.
The availability of data on a hard copy, nondestructible media.
c.
A formalized approved preventative maintenance program of surveil-
lance, calibration, and data reduction activities.
This shall be completed by March 13, 1982.
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Appendix A
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2.
Prompt Public Notification (232/81-20-19; 306/81-22-19)
Required Action
Documentation shall be provided to the NRC which technically supports
whether the prompt public notification system meets the design objec-
tives of Appendix 3 of NUREG-0654. The licensee's submittal shall
clearly indicate when the system will be fully operational.
'
This shall be completed by December 16, 1981.
3.
Emergency Plan Implementation Procedures and Interface Procedures
Required Action
a.
Review and revise, as necessary all plant abnormal operating pro-
cedures, emergency instructions, and annunciator procedures which
do not contain, as a subsequent operator action, a statement to
direct the Reactor Operator or user to notify the Shift Supervisor
to classify the emergency in accordance with the Emergency Plan
Implementing Procedure. This review shall also pertain to the
new Westinghouse Owners Group, Symptomatic Emergency Operating
Procedures, when and if they are adopted by the licensee.
This shall be completed by March 13, 1982.
(282/81-20-20;
306/81-22-20)
b.
Check-off lists for key personnel in the Emergency Response
Organization shall be developed and implemented to ensure all
tasks are performed in the proper sequence in order to prevent
reliance on memory.
This shall be completed by March 13, 1982.
(282/81-20-21;
306/81-22-21)
c.
Observable and reliable Emergency Action Levels (EALs) shall be
developed and maintained for the following accident conditions
and correct, as necessary, those EALs which do not meet the
regulatory positions of NUREG-0654:
1
Provide EALs for the containment radiation monitor for a
.
primary coolant leak greater than 50 GPM.
Provide EALs for the containment radiation monitor for a
.
loss of 2 of 3 fission product barriers.
Provide steam line radiation monitor JALs for a 50 GPM
.
primary to secondary leak with and without fuel damage
indication.
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Appendix A
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Provide EALs for 1R-50, 2R-50, IR-22, and 2R-22 Shield
.
Building Vent Extaust for an Alert, Site, Area, and General
Emergency.
Change 100 mR/hr to 1000 mR/hr (EALs) for an Alert indicating
.
a severe degradation in control of radioactive materials and
remove airborne levels greater than 10 CFR 20 limits as an
Alert EAL.
Remove loss of both turbine generators as an Unusual Event
.
and keep loss of both diesel generators as the EAL for loss
of Onsite AC Power Capability.
Provide EALs for R-11/12, R-7 and R-2 for a fuel handling
.
accident at the Alert Level and provide EALs for R-31, R-25,
and R-28 at the Site Area level.
Correct typograpuical error for Condition No. 13 from Ci/cc
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to uCi/cc (primary coolant results).
Develop EALs for chlorine, ammonia and hydrazine release
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onsite including the Control Room, Administration Area,
and Auxiliary Building.
This shall be completed by February 13, 1982.
(282/81-20-22;
306/81-22-22)
d.
Emergency Plan Implementing Procedure (F3-4) shall be revised to
include the following corrections:
The Shift Supervisar of the unaffected unit shall initially
.
(within the first hour) ensure that onsite and inplant radi-
ation surveys will be conducted as necessary and he shall
direct radiochemistry personnel to take appropriate samples
as necessary.
The Shift Supervisor of the unaffected unit shall make initial
.
recommendations to offsite agencies for any General Emergency
which shall include:
(1) activation of the public noti fication
system, and (2) recommendations fec sheltering of the public
within a two mile radius of the plant.
This shall be completed by January 13, 1982.
(282/81-20-23;
306/81-22-23)
In addition to the above actions the following long term improvement was
agreed upon:
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Appendix A
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A dedicated 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day coverage for inplant surveys during an emergency
shall be provided. This position / expertise shall be in addition to the
existing onshift Radiation Protection Specialist. Training shall be provided
for this position with particular attention to emergency inplant radiation
surveys. This shall be completed by July 1982.
(282/81-20-24; 306/81-22-24)
If our understanding of your planned actions described above is not in accord-
ance with the actual plans and actions being implemented, please contact this
office by telephone and in writing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Further, please inform
this office, in writing, upon completion of all the above action items.
Sincerely,
James G. Keppler
Regional Administrator
cc:
F. P. Tierney, Jr., Plant
-Manager
DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII
John W. Ferman, Ph.D.,
Nuclear Engineer, MPCA
A pendix B
J
PREPAREDNESS IMPROVEMENT ITEMS
Based on the results of the NRC's appraisal of the Prairie Island Nuclear
Plant Emergency Preparedness Program conducted Novemer 2-13, 1981, the
following items should be considered for improvement:
These items are prioritized in order of importance.
1.
Include dose factors for cesium-134, cesium-137, ruthenium-106, and
te11urium-132 in the dose assessment computer for whole body and lung
doses.
(Section 5.4.2).
2.
The dose assessment computer should be revised to calculate stack
concentrations from the IR-50, 2R-50, IR-22 and 2R-22 instrument reading.
(Section 5.4.2).
3.
The dose assessment computer should be revised to calculate offsite
doses directly from the high range dome monitor.
(Section 5.4.2).
4.
All RPS personnel should be trained to use the dose assessment computer.
(Section 7.0.11).
5.
Establish a near-site press briefing area for use during emergencies.
(Section 4.1.4).
6.
Expand the locations for respiratory protective equipment to include
emergency kits, assembly areas, and emergency response facilities.
(Section 4.2.2.1).
7.
Determine evacuation time estimates for worst-case sectors (E, F, G and
H) out to 10 miles and incorporate these estimates into the procedure.
(Section 5.4.2).
8.
Revise EPIP F3-4 to assure that the Radiation Emergency Coordinator
will provide guidance relevant to establishing priorities for post-
accident sampling and inplant/onsite/offsite surveys.
(Section 5.3).
9.
Modify EPIPs for the Radiation Emergency Coordinator and the Radia-
tion Protection Support Supervisor to indicate that plume diversion
is likely if the plume travels towards the bluffs.
Consider such a
diversion as part of the plume monitoring strategy (i.e. , team ? ocation).
(Section 5.4.2).
10.
Develop a graph for EPIP F3-23 to calculate expected containment air
sample dose rates from the dome monitor radiation levels.
(Section
5.4.2.6).
Appendix B
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11.
Make available the Draeger kit for monitoring chlorine, ammonia, and
hydrazine levels during emergencies.
(Section 4.2.1.3).
12.
Installation of radioiodine and particulate containment air sampling
capability with adequate shielding should be installed.
(Section
4.1.1.6).
13.
The containment air sampling method must be modified, either proce-
durally or structurally, to ensure that all samples obtained are
representative of containment air.
The modification must be
accompanied by a tech _i-al justification.
(Section 4.1.1.6).
14.
Distribution of emerge 2cy ceasures information should be made avail-
able to local parks ar.d other public use areas.
(Section 5.4.7).
15.
Following installation of the high range dome ARM, color code the
instrument readout for an Unusual Event, Alert, Site Area and General
Emergency.
(Section 4.2.1.2).
16.
Adequate (ALARA) shielding on sample lines from the shield building
exhaust monitoring / sampling station should be provided.
(Section 4.1.1.7).
17.
Relocate the sampling room ARM readout for use during post-accident
sampling work such that it can be read and the alarm silenced.
(Section 4.1.1.5).
18.
Calculations to determine ground deposition of radioiodine and partic-
ulate releases should be programmed into the dose assessment computer.
(Section 5.4.2).
19.
Revise EPIP F3-4 to assure that the TSC and OSC coordinators estab-
lish communications with the other Emergency Response Facilities.
(Section 5.3).
20.
Remove the RG 1.145 plume meander factor from the dose assessment
computer program.
(Section 5.4.2).
21.
Label or otherwise color code the control room ARM readouts to indi-
cate that 1000 times the normal dose rates is an Alert Emergency.
(Section 4.2.1.2).
22.
Emergency respiratory protective equipment should comply with ANSI-
Z88.1-1980 standards.
(Section 4.2.2.1).
23.
Increase the number of persons capable of conducting the Radiation
Emergency Monitoring Program (REMP) (management and team persons) to
assure that the planned number of persons required to implement the
program would be available.
(Section 5.4.2.12).
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Appendix B
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24.
Upgrade the following Letters of Agreement to include specific
responsibilities, limits of action, and delineation of authority:
Fluor Power Service Inc.; Westinghouse Electric Corporation; Office
of Sheriff of Pierce County, Wisconsin; Office of Civil Defense of
Pierce County, Wisconsin; Fire Department, City of Red Wing, Minnesota.
(Section 6.2 and Section 2.2).
25.
Modify the EPIPs to assure that the emergency organization will
promptly notify all appropriate individuals and agencies that the
emergency has terminated and recovery will be initiated.
(Section 5.4.6).
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(Section 5.4.2.1).
27.
Provide fixed emergency lighting in the OSC.
(Section 4.1.1.3).
28.
Professional training courses should be provided for corporate and
site Emergency Planning Coordinators.
(Section 1.0).
Appendix C
EMER/;ENCY PREPAREDNESS EVALUATION REPORT
The following is a list of significant deficiencies identified in the
Prairie Island Site and Corporate Emergency Plans. These deficiencies
are categorized as per the planning standards of 10 CFR 50.47(b). These
deficiencies as well as those listed in Appendix A, must be corrected in
accordance with the provisions of 10 CFR 50.54(s)(2):
Planning Standard (b) (2) (Onsite Emergency Orgainization) (282/81-20-01;
306/81-22-01). The Plan does not reflect the current minimum shift staffing
or shift augmentation capability.
Indicate in Table 5-3 of the site plan that a dedicated Shift Emergency
.
Coordinator is on duty and onsite 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day.
Indicate in Table 5-3 that a dedicated Health Physics trained individ-
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ual will be onsite, in addition to a Radiation Protection Specialist for
post-accident inplant surveys, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. This position will be
fully staffed and the personnel trained by July 1, 1982.
Indicate that a EOF coordinator will be available to the EOF within one
.
hour af ter declaration of a Site or General Emergency. This position /
expertise should be added to the 60 minute shift augmentation column.
Further, the Plan should be revised to reflect this function.
Planning Standard (b) (4) (Emergency Classification System) (282/81-20-02;
306/81-22-02). The Plan does not adequately provide Emergency Action Levels
(EALs) as per Appendix 1 of NUREG-0654 in the following areas:
UFUSUAL EVENT
a.
Condition No. 4 (Abnormal Coolant Temperature) does not provide for
incore themocouple reading for abnormal coolant / fuel temperatures.
^
b.
Condition No. 16 (Hazards to Plant Operations) does not provide EALs
for onsite chlorine, ammonia, and hydrazine accidental releases.
c.
Condition No. 8 (Major Electrical Failures) should not consider loss
of both turbine generators as part of onsite AC power capability but
only consider availability of the diesel generators.
d.
Condition No. 6 (Secondary Coolant Anomaly) does not provide for a
rapid depressurization. of the secondary side.
ALERT
a.
Condition No. 16 (Hazards to Plant Operations) does not provide for
EALs for onsite chorine, ammonia, and hydrazine accidental releases.
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Appendix C
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b.
Condition No. 10 (Fires) should be reworded to state " fires potentially
affecting safety systems."
Condition No. 7 (Radiological Effluents) does not provide EALs for
c.
1R-50, 2R-50, 1R-22 and 2R-22 for noble gas releases greater than
ten times technical specifications.
SITE AREA EMERGENCY
a.
Condition No. 5 (Core Fuel Damage) does not provide EALs for a degraded
core with possible loss of coolable geometry.
b.
Condition No. 11 (Plant Shutdown Functions) does not provide for,
including EALs, a transient requiring operation of shutdown systems
with failure to scram.
c.
Condition No. 7 (Radiological Effluents)-does not provide EALs for
1R-50 and 2R-50 which correspond to whole body dose rates at the site
boundary for 50 mR/hr (1/2 hour) and 500 mR/hr (2 minutes) for adverse
meteorology.
d.
Condition No. 16 (Hazards to Plant Operations) does not provide EALs
for chlorine, ammonia, and hydrazine releases onsite.
Condition No. 10 (Fires) should be reworded to state " fire compromising
e.
the functions of a safety system."
GEpERAL EMERGENCY
Condition No. 5 (Core Damage) does not provide EALs for the containment
a.
dome monitor.
b.
Condition No. 7 (Radiological Effluents) does not provide EALs for
1R-50 and 2R-50 corresponding to IR/hr at the site boundary under
average meteorological conditions.
c.
The following initiating conditions were missing: Items 4a, 4b,
and 4c of page 1-17 of NUREG-0654; and those initiating conditions
(Page 1-18 of NUREG-0654) relevant to PWR sequences leading to core
melt accidents with probable containment failure.
Planning Standard (b) (5) (Notification Methods and Procedures)
(282/81-20-03; 306/81-22-03). The Plan does not describe the administrative
and physical means, and the time required for notifying and providing prompt
instructions to the public within the plume exposure pathway EPZ.
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Appendix C
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Planning Standard (b) (6) (Emergency Communication) (282/81-20-04;
306/81-22-04). The Plan does not include a description and figure of the
organizational titles and alternates for both ends of the communication
links.
Planning Standard (b) (9) (Accident Assessment) (282/81-20-05; 306/81-22-05).
The Plan does not describe the use of containment dome monitor reading as
it relates to accident assessment, and the accident assessment methodology
does not consider all radionuclides in Table 3 of NUREG-0654.
Planning Standard (b) (11) (Radiological Exposure Control) (282/81-20-06;
306/81-22-06). This Plan does not adequately define an emergency worker.
The applicable exposure limits for offsite activities can not be defined.
The Plan does not make provision for radiciodine decontamination of the
skia.
Planning Standard (b) (13) (Recovery) (282/81-20-07; 306/81-22-07). The Plan
does not contain the referenced Recovery Plan. This information must be sub-
mitted to the NRC for review.
Planning Standard (b) (15) (Training) (282/81-20-08; 306/81-22-08). The
Plan does not indicate that semi-annual Health Physics drills will be
conducted, onsite and offsite, involving response to, and analysis of,
simulated elevated airborne and liquid samples and direct radiation
measurements.
Planning Standard (b) (16) (Responsibility of the Planning Effort)
(282/81-20-09; 306/81-22-09). The Plan does not provide a cross-refrence
between NUREG-0654 and the Site Plan.
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Appendix D
OPEN ITEMS
The following is a list of Open Items identified in the area of Emergency
Preparedness which must be re-examined or completed in accordance with
schedules set forth in NUREG-0696 or NUREG-0737.
1.
Completion of the TSC is required by October 1982.
(Section 4.1.1.2)
(282/81-20-10; 306/81-22-10)
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2.
Completion of the near-site EOF is required by October.1982.
(Section 4.1.1.4) (282/81-20-11; 306/81-22-11)
3.
Re-location and addition of shielding of primary coolant sample lines
in the primary coolant sample hood must be completed by January 1,
1982.
(Section 4.1.1.5) (282/81-20-12; 306/81-22-12)
4.
Installation of a purging system for the containment air sampling
lines must be completed by February 1, 1982.
(Section 4.1.1.6)
(282/81-20-13; 306/81-22-13)
5.
- Secondary side steam relief monitors must be installed by January 1,
1982.
(Section 4.1.1.7) (282/81-20-14; 305/81-22-14)
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6.
Installation of the high range (10 R/hr) containment dome monitor
ARMS must be completed by January 1,1982.
(Section 4.2.1.2)
(282/81-20-15; 306/81-22-15)
7.
Training of Reactor Operators in basic inplant radiological survey
techniques in order to provide dedicated backshift radiation protection
must be implemented by July 1, 1982.
(Section 7.0.12) (282/81-20-16;
306/81-22-16)
8.
The inability of the portable inplant radio system to communicate
between the control room and certain areas in the Auxiliary Building
must be corrected by April 1982.
(Section 7.0.8) (282/81-20-17;
306/81-22-17)
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