ML20041E749
| ML20041E749 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 02/22/1982 |
| From: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Lempges T NIAGARA MOHAWK POWER CORP. |
| Shared Package | |
| ML20041E750 | List: |
| References | |
| RTR-NUREG-0654, RTR-NUREG-0737, RTR-NUREG-654, RTR-NUREG-737 NUDOCS 8203110307 | |
| Download: ML20041E749 (9) | |
See also: IR 05000220/1981018
Text
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REB 1982
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Dockat No. 50-220
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Niagara Mohawk Power Corporation
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ATTN:
Mr. T. E. Lempges
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Vice President Nuclear Generation
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300 Erie Boulevard, West
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Gentlemen:
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Subject:
Emergency Preparedness Appraisal 50-220/81-18
To verify that licensees have attained an adequate state of onsite emergency
preparedness, the Office of Inspection and Enforcement is conducting special
appraisals at each power reactor site.
These appraisals are being performed
in lieu of certain routine inspections normally conducted in the area of
emergency preparedness. The objectives of the appraisal at each facility 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 August 17-28, 1981, the NRC conducted an appraisal of the
emergency preparedness program for Nine Mile Point Nuclear Station Unit 1.
Areas examined during this appraisal are described in the enclosed report
(50-220/81-18). Within these areas, the appraisal team reviewed selected
procedures and representative records, inspected emergency facilities and
equipment, observed work practices and interviewed personnel.
The findings of this emergency preparedness appraisal indicate that certain
corrective actions are required in your emergency preparedness program. These
are discussed in Appendix A, "Significant Emergency Preparedness Findings",
and in summary include the following:
1.
Ill-defined emergency organization and non-specific assignment of personnel
to the various functional areas of emergency activity;
2.
Inadequate post-accident sampling and analysis equipment and procedures;
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3.
Inadequate provisions for detection and measurement of airborne radiofodine
under field conditions in the presence of noble gases.
4.
screpancies
mergency implementing procedures (e.g., improper
radiologica'
controls).
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8203110307 820222
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Niagara Mohawk Power Corporation
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2 2 FEG 1982
Significant findings for which you have made acceptable commitments to resolve
were discussed in the confirmatory action letter dated September 8, 1981. A
copy of the letter is enclosed.
Other areas needing improvement are discussed in Appendix B, " Emergency
Preparedness Improvement Items."
In conjunction with the aforementioned appraisal, emeroency plans for your
facility were reviewed by the Emergency Preparedness Licensing Branch. The
results of this review indicate that certain deficiencies exist in your emergency
plan.
These are discussed in Appendix C, " Emergency Preparedness Evaluation
Report."
Appendices A, B and C of this letter contain an inclusive listing of all
outstanding emergency preparedness items at your facility at this time.
We recognize that an explicit regulatory requirement pertaining to each item
identified in Appendices A, B, and C may not currently exist. Notwithstanding
this, you are requested to submit a written statement within thirty (30) 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
eacn 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. With regard to Appendix C, you are
requested to provide to this office within 120 days of the date of this letter,
page changes to the emergency plan correcting each deficiency or provide
written justification as to why you believe a revision should not be made.
Copies of these changes are to be submitted in accordance with the procedures
delineated in Section 50.54(q), Part 50, Title 10, Code of Federal Regulations.
This is to inform you that if the deficiencies listed in Appendix A are not
corrected by the dates agreed upon, the Nuclear Regulatory Commission will
determine whether enforcement action is appropriate.
,
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of
thi: letter and the enclosures will be placed in the NRC's Public Document
Room.
If this report contains any information that you (or your contractors)
believe to be exempt from disclosure under 10 CFR 9.5(a)(4), it is necessary
that you (a) notify this office by telephone within ten (10) days from the
date of this letter of your intention to file a request for withholding; and
(b) submit within 30 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 on the basis
which it is claimed that the information should be withheld fri i public
disclosure. This section further requires the statement to address with
specificity the considerations listed in 10 CFR 2.790(b)(4). The information
sought to be withheld shall be incorporated as far as possible into a separate
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Niagara Mohawk Power Corporation
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2 2 FEB N82
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part of the affiday'it.
If we do not hear from you in this regard within the
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specified periods noted above, the report will be placed in the Public Document
Room.
The telephone notification of your intent to request withholding should
be made to the Supervisor, Files, Mail and Records, USNRC Region I, at (215)
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337-5223.
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The reporting requirements contained in this letter affect fewer than ten
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persons and therefore are not subject to Office of Management and Budget
clearance as required by P.L.96-511.
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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. R. Priebe, Emergency Preparedness
Licensing Branch at (301) 492-9695.
Sincerely,
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M onald C. Haynes
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Regional Administrator
Enclosures:
1.
Appendix A, Significant Emergency Preparedness Findings
2.
Appendix B, Emergency Preparedness Improvement Items
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3.
Appendix C, Emergency Preparedness Evaluation Report
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4.
NRC Region I Inspection Report No. 50-220/81-18
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5.
Confirmatory Action Letter dated September 8,1981
cc w/encls:
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T. Perkins, General Superintendent, Nuclear Generation
T. Roman, Station Superintendent
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J. Aldrich, Supervisor Operations
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W. Drews, Technical Superintendent
Leonard M. Trosten, Esquire
Carl D. Hobelman, Esquire
Public Document Room (PDR)
local Public Document Room (LPOR)
Nuclear Safety Information Center (NSIC)
State of New York
NRC Resident Inspector
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bec w/encls:
Region I Docket Room (with concurrences)
Chief, Operational Support Section (w/o encls)
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APPENDIX A
SIGNIFICANT EMERGENCY PREPARE 0 NESS FINDINGS
Based on the results of the NRC's appraisal of the Nine Mile Point Nuclear
Station Unit 1 Emergency Preparedness Program conducted August 17-18, 1981,
the following improvements are required:
(References are to sections in the
NRC Region I Inspection Report No. 50-220/31-18).
1.
Revise the emergency organization to provide for all the emergency functions
required during initial, intermediate and final phases of augmentation;
update the site Emergency Plan to describe the revised organization; and
issue revised implementing procedures as necessary to be consistent with
the revised organization.
The updated description in the plan shall
include a sufficient level of detail to: unambiguously delineate the
command hierarchy; clearly specify its structure, reporting chains and
inter-relationships at any phase of augmentation; and, include supervisory
as well as non-supervisory elements.
(See Section 2.1)
2.
Provide approved lists of personnel in the emergency organization segregated
by individual training qualification which reflects each functional area
specified within the emergency organization.
These lists shall identify
the current training status of each individual.
Provisions to maintain
the lists current shall be developed and implemented.
(See Section 2.1)
3.
Develop a document to implement the Emergency Plan training program
including the alignment of the training categories with.the functional
areas of emergency activity in the emergency organization.
(See Section
3.1)
4.
Provide training / retraining for all individuals with specific functional
duties in the emergency organization to meet schedule reqairements, and
additional training between scheduled sessions, as needed, to update
recipients on changes in emergency response (e.g. equipment, procedures)
(See Section 3.1)
5.
Develop a training course to cover all aspects of post-accident sampling.
(See Section 3.1)
6.
Complete the installation of ventilation and protective equipment to
ensure the habitability of the TSC during the various accident scenarios,
and rearrange communication equipment so that clustering of phones and
personnel is prevented.
(See Section
4.1.1.2
7.
Re-evaluate interim facilites and equipment used for post-accident coolant
sampling and analysis during accidents to determine maximum concentrations
that could be sampled, handled and analyzed.
Provide a written report of
the results to the NRC Region I Office and include a schedule of any
planned actions.
(See Section 4.1.1.5)
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Appendix A
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8.
Re-evaluate interim facilities, equipment for sampling and analysis of
the drywell atmosphere, to determine maximum concentrations that could be
sampled, handled and analyzed.
Provide a written report of the results
to the NRC Region I Office and include a schedule of any planned actions.
(See Section 4.1.1.6)
9.
Re-evaluate facilities and equipment for sampling and analysis of noble
gases, radioiodines and particulates to determine maximum concentrations
that could be sampled and analyzed during accidents.
Provide a written
report of the results to the NRC Region I Office and include a schedule
of any planned actions.
(See Section 4.1.1.7)
10. Complete the radioactive waste storage and demineralizer system to provide
additional storage capacity for radioactive liquid wastes that may be
generated during accidents.
(See Section 4.1.1.8)
11. Provide appropriate facilities and supplies needed to decontaminate the
number of persons that might be expected to be contaminated during severe
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emergencies.
(See Section 4.1.2.3)
12. Provide work facilities and resources in the vicinity of the site which
would be available for corporate, contractor, and non-licensee augmentation
personnel in the event of a large, prolonged response.
(See Section
4.1.3)
13. Provide space and install communications and other equipment in the
Emergency News Crsnter, as needed to ensure the performance of its designated
functions during emergencies.
(See Section 4.1.4)
14.
Provide portable instruments to measure radiciodine from cartridges in
accordance with criteria set forth by NUREG-0654.
(See Section 4.2.1.1)
15. Rewrite Implementing Instructions for each emergency class, from the
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perspective of the ED to orchestrate other detailed emergency implementing
procedures, so that a coherent emergency direction is made possible.
(See Section 5.3)
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16. Prepare an overall procedure which integrates the various sources of
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radiological assessment information to allow the RAC to make a coherent
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response and enable him to estimate the radiological consequences resulting
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from the various accidents scenarios. (See Section 5.4.2)
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17. Clarify and simplify the dose assessment calculation procedure (EPP-8).
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(See Section 5.4.2)
18. Review procedures for dose projections and protective action recommendations
to take into account uncertainty of plume locations.
(See Section 5.4.2)
19.
Review EPP-7 and 8 to include guidance on how to deal with errors resulting
from variance in the plume pathway. (See Section 5.4.2)
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Appendix A
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20. Revise EPP-6 to include:
radiation protection precautions for unusual
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plant conditions; radiological survey and sample counting instructions
(within the action steps); time of dose rate measurements; techniques for
taking radiation measurements (e.g. ground level versus waist level);
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and, disposition of original data sheets.
(See Section 5.4.2.3)-
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21. Revise NI-PSP-10 to include limiting exposure; clear assignment of respon-
sibility; a check list for radiological precautions to bc taken during
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sampling, transportation and analysis; communications; maximum concentrations
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of radioactivity in the sample for handling and analysis; and ALARA
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considerations.
(See Section 5.4.2.4)
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22. Develop a procedure for analyzing liquid waste samples resulting from
severe accidents. (See Section 5.4.2.11)
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Revise EPP-04 and -15 to include specific guidance on technique for
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p rsonnel monitoring for the number of persons expected during emergencies;
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and cross-references to decontamination and follow-up bioassays.
(See
Section 5.4.3.4)
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24. Develop procedure to orchestrate the transition from an emergency classifi-
cation to a recovery mode, including specific criteria upon which the
emergency classes will be downgraded and provisions for notification of
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federal, state and local officials prior to entering a downgraded mode.
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(See Section 5.4.6)
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APPENDIX B
EMERGENCY PREPAREDNESS IMPROVEMENT ITEMS
Based on the results of the NRC's appraisal of the Nine Mile Point Nuclear
Station Unit 1 Emergency Preparedness Program conducted August 17-28, 1981, the
following items should be considered for improvement:
(References 1re to
sections in NRC Region I Inspection Report No. 50-220/81-18).
1.
Formally assign a Corporate EPC or another qualified individual to
assist the site EPC so that all aspects of the development and
maintenance of the site and corporate emergency response
capability are addressed with suf ficient depth.
(See Section 1.1)
2.
Outline of a scheme to ensure that a sufficient number of professionals
and technicians will be available to support a continuous emergency
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response beyond 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
(See Section 2.2)
3.
Upgrade emergency traicing material in the Security Department to
ensure consistency with present Emergency Plan and Procedures.
(See
Section 3.1)
4.
Provide formal documentation for emergency training program conducted
for all offsite organizations; including responsibilites for training
in each area, frequency of training, instructors' lesson plans and record
keeping.
(See Section 3.1)
5.
Provide means to ensure that all personnel assigned emergency functions
are properly trained and qualified to fulfill their duties; and are
made cognizant of their responsibilities during emergency conditions.
(See Section 3.2)
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6.
Provide a separate office for NRC personnel with adequate habitability
and communications.
(See Section 4.1.1.2)
7.
Complete and rearrange the communications network in the EOF to improve
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its efficiency and lower noise levels.
(See Section 4.1.1.4)
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8.
Develop means for calibrating the high range survey meters for high
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radiation fields.
(See Section 4.2.1.1)
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9.
Describe the method to deal with illegible wind direction traces during
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on-shore flow conditions.
(i.e. A 0-360 degrees wind vane rather than
0-540).
(See Section 4.2.1.4)
10.
Establish an alternate stability class determination scheme for use when
the primary source of information cannot provide this parameter.
(Consider
the data types available from the alternate data sources).
(See Section
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4.2.1.4)
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Appendix B
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11.
Include the characteristic wind direction traces to determine atmospheric
stability class in EPP-8 rather than depend on posted material external
to the plan or procedures.
(See Section 4.2.1.4)
12.
Identify the method for adjusting wind speed measurements (32' or 200')
to the characteristic release height (32' or 350').
(Wind speed profiles,
for example could be used to apply the appropriate value to the dose
projection contingent on release pathway.) (See Section 4.2.1.4)
13. Relocate the cascade generator to an area which would be accessible under
accident conditions to provide quality breathing air, and obtain written
agreements with offsite groups to ensure alternate air refilling services.
(See Section 4.2.2.1)
14.
Develop means to permit audible radio communications within the plant.
(See Section 4.2.3)
15.
Include cross-references to specific E0P in cperating procedures.
(See
Section 5.2)
16.
Review EPP-7 and 8 to include radiological protection measures for survey
team members, backup communications and a protocol for relaying survey
results.
(See-Section 5.4.2.1)
17.
Revise EPP-7 to include radiation protection guidelines and modify data
sheets to provide space for recording the time at which each sample was
taken, and team member's names.
(See Section 5.4.2.2)
18.
Specify how to dispose of samples and provide instructions indicating the
flow of information from field survey teams to other elements of the
emergency organization.
(See Section 5.4.2.2)
19. Review procedure used for primary coolant analysis to instruct the user
on relaying information to organizational elements performing assessment
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functions (e.g. E0, RAC).
(See Section 5.4.2.5)
20.
Reevaluate procedures for containment (dry well) sampling in accordance
with rindings in Section 4.1.1.6.
(See Section 5.4.2.6)
21.
Review N1-PSP-11 to include instruction for the user to forward data to
organizational elemerits performing offsite dose assessment (e.g. RAC, ED)
and how to dispose of samples.
(See Section 5.4.2.7)
22.
Review Stack Effluent Sampling Procedure to incorporate guidelines for:
conducting pre-entrance precautionary meetings during off-shifts; handling
highly radioactive charcoal and other filter media; and relaying data to
organizational elements in charge of making offsite dose assessment.
(See Section 5.4.2.8)
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Appendix B
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23.
Review N1-SP-7 to include radiological precautions expected when handling
and analyzing highly radioactive samples and instructions for the user to
relay information to emergency personnel responsible for offsite assessment
actions (e.g. ED, RAC).
(See Section 5.4.2.9)
24. Develop a procedure for sampling liquid wastes which addresses the radio-
logical conditions expected during severe accidents.
(See Section 5.4.2.10)
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25.
Revise emergency implementing procedures to include responsibilities for
radiological protection (e.g., briefings of emergency personnel, dosimetry,
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etc) in the action steps portion of the procedures.
(See Section 5.4.3.1)
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26.
Include provisions for evacuation of park area around the EIC.
(See
Section 5.4.3.2)
27.
Include body sketches and data sheets to record decontamination progress.
(See Section 5.4.3.4)
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28.
Provide consistent personnel decontamination limits between the Emergency
Plan and those stated in EPPP-04 and 19.
(Sea Section 5.4.3.4)
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29.
Incorporate into EPP-22 the criteria and logistics of selection of team
members and communication means to be employed.
(See Section 5.4.5)
30.
Revise EPP-21's format to clearly outilne responsibilities, guidelines
and specific sequential actions required of the various individuals
dealing with public information during accidents.
(See Section 5.4.7)
31. Develop provisions for responding to public inquiries separate from the
news media.
(See Section 5.4.7)
32.
Revise of EPP-10 to include: unambiguous specification of radiation
survey instrumentation consistent with their intended use; development of
procedures for operationally checking the same; and a criteria for acceptance
or rejection of instruments.
(See Section 5.5.1)
33.
Review Emergency Plan and procedures to include a requirement for updating
letters of agreement with offsite support agencies.
(See Section 6.1)
34.
Disseminate emergency planning information brochures to the public within
the plume exposure EPZ.
(See Section 6.2)
35. Review the Emergency Plan to include a description of the media educational
program, responsibilities, implementation dates and its frequency.
(See
Section 6.3)
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