ML20040D391

Forwards Response to App a & App B of 811118 Confirmatory Ltr Re Emergency Preparedness.Nrc 811217 Request

ML20040D391
Person / Time
Site:	Prairie Island
Issue date:	01/15/1982
From:	Gilberts D NORTHERN STATES POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8202010248
Download: ML20040D391 (12)

Text

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Northern States Power Company 414 Nicollet Mall Minneapohs. Minnesota 55401 Telephone (612) 330-5500 ry 15, 1982 p' *, ',

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Dear Mr Keppler:

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PRAIRIE ISLAND NUCLEAR GENERATING PLANT Docket No. 50-282 License No. DPR-42 50-306 DPR-60

Subject:

Emergency Preparedness Appraisal Response Your letter dated December 17, 1981 requested a written statement within 30 days describing planned actions for improving items identified in Appendix A and the results of our consideration of items in Appendix B. In accordance with that request, we are submitting the attached documents.

D E Gilberts Senior Vice President Power Supply cc Mr G Charnoff Mr C D Feierabend Mr Brian Grimes, Director Division of Emergency Preparedness Washington, DC 20555

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8202010248 820115 D PDR F

ADOCK 05000282 PDR

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Januxry 15, 1982 NORTHERN STATES POWER COMPANY PRAIRIE ISLAND NUCLEAR GENERATING PLANT Docket No. 50-282 License No. DPR-42 50-306 DPR-60 Response to Appendix A, Confirmation of Action Letter dated 11/18/81

1. Emergency Equipment and Facilities 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.

Response: 1.a A 60 meter tower and meteorological instruments meeting Reg. Guide 1.23 will be operational by March 13, 1982 at Prairie Island.

1.b Procedures have been made available at Prairie Island to allow remote interrogation of the General Of fice computer meteorological data file that is received from the present tower system. This is a back-up data base for the con-dition when the present plant printer fails. By March 13, 1982 a new data collection multiplexing system will be installed that will increase the reliability of the data collection and transmission system.

l.c By March 13, 1982 a formalized approved preventative main-tenance program of surveillance, calibration, and data reduction activities will be instituted.

2. Prompt Public Notification Required Action Documentation shall be provided to the NRC which technically supports whether the prompt public notification system meets the design objectives of Appendix 3 of NUREG-0654. The licensee's submittal shall clearly indicate when the system will be fully operational.

Response: Documentation was submitted to NRC Region III offices on December 16, 1981.

3. Emergency Plan Implementation Procedures and Interface Procedures Required Action

a. Review and revise, as necessary all plant abnorr.a1 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 Shif t 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.

Response: All plant procedures have been reviewed to determine which ones require a subsequent action step to refer to procedure F3-2 to classify the emergency. The procedures identified shall be changed by March 13, 1982.

b. Check-of f 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.

Response: Check of f lists are in the process of being developed. These lists r' all be completed by March 13, 1982.

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 i positions of NUREG-0654:

(1) Provide EALs for the containment radiation monitor for a primary coolant leak greater than 50 GPM.

(2) Provide EALs for the containment radiation monitor for a loss of 2 of 3 fission product barriers.

(3) Provide steam line radiation monitor EALs for a 50 GPM primary to secondary leak with and without fuel damage indication.

(4) Provide EALs for 1R-50, 2R-50, IR-22 and 2R-22 Shield Building Vent Exhaust for an Alert, Site Area, and General Emergency.

(5) 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 'O CFR 20 limits as an Alert EAL.

(6) 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.

(7) Provide EALs for R-ll/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.

(8) Correct typographical error for Condition No. 13 from Ci/cc to uCi/cc (primary coolant results).

(9) Develop EALs for chlorine, ammonia and hydrazine release onsite including the Control Room, Administration Area,-

and Auxiliary Building.

Response: Emergency Action Level revisions are being developed to address the requirements of NUREG 0654 and shall be implemented prior to February 13, 1982 for all the above examples with the following changes as discussed by telephone with Mr W L i

Axelson of your office:

(3) A 50 gpm primary to secondary leak without fuel damage will not indicate above background on the steam line monitor. There fore ,

the air ejector discharge monitor will indicate a 50 gpm leak and a EAL will be established for the air ejector monitor. A 50 gpm primary to secondary leak with fuel damage EAL for the steam line monitor shall be developed.

(7) The radiation monitor EAL's for a fuel handling accident in the spent fuel building will be for 1R-22, 2R-22, IR-50, 2R-50, and R-5 instead of R-31, R-25, and R-28.

d. Emergency Plan Implementing Procedure (F3-4) shall be revised to include the following conditions:

The Shift Supervisor of the unaffected unit shall initially (within the first hour) ensure that onsite and inplant radiation 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 of fsite agencies for any General Emergency which shall include': (1) activation of the public notification system, and (2) recommendations for sheltering ~ of the public within a two mile

radius of the plant.

l I Response: Emergency Plan Implementing Procedure F3-4 has been revised i to include the following:

The Shif t Supervisor of the unaffected unit shall initially (within the first hour) ensure that onsite and inplant radi-l ation surveys will be conducted as necessary and he shall l direct radiochemistry personnel to take appropriate samples as necessary.

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The Shif t Supervisor of the unaffected unit shall make initial recommendations to of fsite agencies for any General

. Emergency which shall include: (1) activation of the public notification system, and (2) recommendations for sheltering of the public within a two mile radius of the plant.

Additional Long Term Improvement Required Action 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 radiat ion surveys.

Response: The Training Department is developing lesson plans to train personnel in the operations group to develop skills to perform inplant surveys during an emergency. This training program shall be implemented and on shift operations individuals with expertise in inplant surveys shall be provided by July 1982.

January 15, 1982 NORTHERN STATES POWER COMPANY PRAIRIE ISLAND NUCLEAR GENERATING PLANT Docket No. 50-282 License No. DPR-42 50-306 DPR-60 Response'to Appendix B, Preparedness Improvement Items

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)

Response: Dose factors for Cs-134, Cs-137, Ru-106 and Te-132 have -

been calculated for both the whole body and lung, along with the dose calculation and computer format required.

Calculation of inhalation dose to the whole body and lung will be inserted into the dose' assessment computer.

We expect this to be completed by February 1,1982.

2. The dose assessment computer should be revised to calculate stack concentracions from the IR-50, 2R-50, 1R-22 and 2R-22 instrument reading.

(Section 5.4.2)

Response: The calibration curves for the stack monitors are available and have been reviewed with the Computer Engineer.

The dose assessment program will be revised to. cue the operator to input the rad monitor readings directly into the computer such that the computer will calculate the activity-being released. 1me _ computer will use either the low or high range monitor readings, depending on activity levels &

which monitors are on scale.

We expect this to be completed by April 1,1982.

3. The dose assessment computer should be revised to calculate of fsite -

doses directly from the high range dome monitor. (Section 5.4.2)

Response: The calibration curve to determine the containment source term, Xe-133 equivalent, based on the high range dome monitors has been developed. This will be placed'in the dose assessment computer program to enable the computer to automatically cal-culate the containment' source term and project offsite dose rates.

We expect this to be completed by April 1,- 1982.

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4. All RPS personnel should be trained to use the dose assessment computer.

(Section 7.0.11)

Response: No action has been done on this item. When the computer programs have_been modified to calculate stack concentrations from 1R-50, 2R-50, 1R-22, and 2R-22 readings, we will start'to train the Radiation Protection Specialists to use the dose-assessment computer. We expect this training to be completed by mid May 1982.

5. Establish a near-site press briefing area for use during emergencies.

Response: NSP has reconsidered its decision not to establish a near-site media center and has discussed the entire public information function with the State of Minnesota. The State's Division of Emergency Services concurs with the . company's position not-to relocate the Media Information' Facility. The company also is preparing a revised agreement with the state tofassure better coordination of the public information function.

6. Expand the locations for respiratory protective equipment to include emergency kits, assembly areas, and emergency response facilities.

(Section 4.2.2.1)

Response: We have contacted respiratory protection equipment suppliers-concerning canisters for protection from radio-iodines for full face respirators.

The Emergency Kits, Operational Support Center and the Technical Support Center will be stocked with a supply of full f ace respirators and canisters. The canisters will provide protection for iodines. We expect the respirators' to be in place by April 1, 1982 and the iodine protection-canisters to be in place by July 1, 1982.

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

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(Section 5.4.2).

Response: An additional scope of evacuation time estimates for the Prairie Island Plant area will be generated for worst case sectors (E, F, G and H) out to a 10 mile distance from the plant. The identical process used in determining the original and revised estimates will be used to keep the data consistant. A revision to the procedure providing data and maps will'be made. We expect this change to be completed by April 1,1982.

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/of fsite surveys. (Section 5.3)

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Response: The sampling and onsite/inplant survey requirements have been reviewed. Upon completion of review and approval, they will be incorporated into F3-4, under the Radiological Emergency Coordinator (REC) responsiblities.

We expect this to be completed by March 13, 1982.

9. Modify EPIPs for the Radiation Emergency Coordinator and the Radiation 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 location).

(Section 5.4.2)

Response: The plant and Corp EPIP's have been reviewed and we do concur that the Radiological Emergency Coordinator (REC) and the Radiation Protection Support Supervisor (RPSS) should be provided guidance to indicate that plume diversion is likely to occur if the pluma travels towards the bluf fs. A statement indicating such will be added to F3-4, under the Radiological Emergency Coorlinator (REC) responsibilities and into the Corporate EPIPs, under the Radiation Protection Support Supervisor responsibilities.

We expect this to be completed by April 1, 1982.

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)

Response: A graph has been developed to calculate the expected sample dose rates, based on the containment dome monitor radiation levels. Sample dose rates have been calculated for various size samples. Samples are now being analyzed on the GeLi to determine an adequate range of dose rates acceptable for individual sample sizes.

We expect this to be completed by March 1,1982.

11. Make available the Draeger kit for monitoring chlorine, ammonia, and hydrazine levels during emergencies. (Sect ion 4.2.1.3)

Response: The Draeger kit for monitoring chlorine, ammonia, and

! hydrazine has been placed in the emergency locker in the l

Operations Support Center next to the Control Room.

12. Installation of radioiodine and particulate containment air sampling i capability with adequate shielding should be installed. (Section l 4.1.1.6) t Response: See the following response in Item #13.

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13. The Containment air sampling method must be modified, either pro-cedurally~or structurally to ensure that all samples obtained are representative of. containment air. The modification must be accompanied by a technical justification. (Section 4.1.1.6)

Response: Containment air samples are drawn'using the Automatic Hydrogen Oxygen Gas Analyzer System by way of the Post LOCA Hydrogen' Control System. The Gas Analyzer sample pumps take suction simultaneously from both trains of the Post LOCA Hydrogen Control System. The containment air samples originate from the discharge of the Dome Recirculation Fans, thus ensuring the samples are representative of the containment atmosphere. Grab samples are then taken from the 'ef fluent of the Gas Analyzer for isotopic activity analysis.

A Shielded in-line radioiodine and particulate filter is to be installed upstream of the sample pumps. This is to eliminate plate-out in the sample pumps and sample lines downstream of the filter. In addition, a high pressure nitrogen bottle will be utilized to purge the sample lines at the completion of each sample. This will ensure subsequent samples are representative of the containment atmosphere.

A radioiodine and particulate filter with flow indication is to be installed in parallel with the shielded'in-line radioiodine and particulate filter. This filter may be manually valved in for suf ficient amount of _ time to obtain an iodine and particulate sample. This filter assembly .

may then be removed. By determining the activity on the filters and knowing the sample flow rate and collection time the containment radioiodine and particulate activities can then be calculated. Noble gas activities will be determined by obtaining the grab sample from the Gas Analyzer effluent.

We expect the above modifications to the containment air sampl-

ing equipment and the associated procedure changes to be i

completed by March 1, 1982.

l l 14. Distribution of emergency measures information should be made available to local parks and other public use areas.

i l_ Response: NSP will provide public information brochures a97ually to public use areas, including' local parks and camping areas, l if facilities exist. The company's alert and notification-system, which includes warning sirens' and radio alerts, also

j. provides some notification. Additionally, the company will discuss this item further with local law enforcement officials who are responsible for assuring that all public areas are l informed during an emergency. We expect this action to be i completed by April 1, 1982.

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'15 . Following installation of the high range dome ARM, color code the instrument readout for an Unusual Event, Alert, Site Area and General Emergency. (Sect ion 4.2.1.2)

Response: The containment area monitor reading for each classification of action has been determined.

The high range containment rad monitors will be color coded or labeled for a Site and General Emergency Classification.

We expect this action to be completed by June 1,1982.

16. Adequate (ALARA) shielding on sample lines from the shield building exhaust a snitor/ sampling station should be provided. (Section 4.1.1.7)

Response: We have reviewed the system and determined we will probably provide lead shielding on the inlet sample line and outlet sample line.

We expect the shielding to be installed by July 1, 1982.

17. Relocate the sampling room ARM readout for use during post-accident sampling work such that it can be read and the alarm silenced. (Sect ion 4.1.1.5)

Response: The present location of the sampling room ARM behind a ventilation duct is such that reading the meter is ext remely di f ficult . It has been decided to move the sampling room meter and detector to a position free of obstructions such that the meter can be clearly read.

Although suggested by the NRC an audible alarm bypass on the sampling room ARM will not be installed. The reason for this is that installation of an alarm bypass would defeat the purpose of the ARM, namely to warn personnel that a high radiation condition exists. With an alarm bypass installed and an existing high radiation condition, personnel could enter the sample room forgetting to look at the ARM and receive high exposure without their knowledge. Instead of an alarm bypass a device that will muffle the audible alarm will be used.

We expect the completion date for the above listed modification to be by April 1, 1982.

18. Calculations to determine ground deposition of radioiodine and particulate releases should be programmed into the dose assessment computer. (Section l 5.4.2.)

Response: The calculation to determine ground deposition of radioiodine and particulates exists presently in a manual calculation fo rmat . The dose factors for the particulates have been calculated. This has been reviewed with the computer engineer and will be programmed into the dose assessment i computer. We expect this'to be completed by April 1, 1982.

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19. Revise EPIP F3-4 to assure that the TSC and OSC coordinators establish communications with the other emergency response facilities. (Section 5.3)

Response: F3-4, " Responsibilities during an Alert, Site Area, or General Emergency", has been reviewed and revised to incorporate action statements to ensure that both the TSC and OSC Coordinators establish or verify that communications are established with other emergency response facilities (CR, TSC, OSC and EOF, once ac t iva t ed ) .

20. Remove the RG 1.145 plume meander factor from the dose assessment computer program. (Section 5.4.2.)

Response: The dose assessment computer program and RG 1.145 have been reviewed to determine the plume meander factor. The plume meander factor will be removed from the dose assess-ment computer program. We expect this to be completed by February 1, 1982.

21. Label or otherwise color code the control room ARM readouts to indicate that 1000 times the normal dose rates is an Alert Emergency. (Section 4.2.1.2.)

Response: The control room ARM readouts associated with charging pumps, sampling and chemistry, letdown and waste gas will be labeled such that a reading approximately 1000 times normal will be an Alert Emergency. Stick on labels will be used on each of the above listed ARM readout meters. We expect the completion for labeling these ARM meters to be completed by '

February 1, 1982.

22. Emergency respiratory protective equipment should comply with ANSI-Z88.1-1980 Standards. (Section 4.2.2.1.)

Response

! ANSI-Z88.2-1980 has open reviewed for compliance. Actions will be taken where we feel appropriate to meet the intent of the standard.

[ We expect these actions to be completed by July 1, 1982.

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).

Response: Additional personnel will be added to the call list for immplementing the Emergency Radiological Environmental

Monitoring Program (EREMP). We expect this action to be j completed by April 1, 1982.

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24. Upgrade the following Letters of Agreement to include specific respons-ibilities, limits of action, and delineation of authority: Fluor Power Service Inc.; Westinghouse Electric Corporation; Of fice of ' Sheriff of Pierce County, Wisconsin; Office of Civil Defense of Picree County, Wisconsin; Fire Department, City of Red Wing, Minnesota. (Section 6.2 and Section 2.2).

Response: We expect to update Letters of Agreement as.part of the annual review prior to April 1, 1982.

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).

Response: Procedures will be revised to notify appropriate individuals and agencies that the emergency has terminated and whether a

-recovery operation will be initiated. We expect this action to be completed by April 1, 1982.

26. The offsite surveillance procedures should address plume monitoring (Section 5.4.2.1).

Response: The of fsite surveillance procedures have been reviewed.

An action statement for the radiation monitoring teams to perform plume searching will be inserted into both the plant and corporate offsite surveillance procedures.

We expect to complete this item by April 1, 1982.

27. Provide fixed emergency lighting in the OSC. (Sect ion 4.1.1.3) .

Response: Emergency lights have been ordered for the OSC. We expect to install the emergency lighting in the OSC by April 1, 1982.

28. Professional training courses should be provided for corporate and site Emergency Planning Coordinators. (Section 1.0)

Response: Investigation of the limit'd options for professional training of Emergency Planning Coordinators is proceeding. At this time it appears that available contractor training lacks required specificity. It is expected that training could be completed during CY1982 if an ef fective professional training course can be made available, r

If the expected date of completion for any of these activities will be significantly delayed, the Region III Office will be advised of the revised date and the reason for any delay.

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