ML20042B849
| ML20042B849 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 03/08/1982 |
| From: | Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Cavanaugh W ARKANSAS POWER & LIGHT CO. |
| Shared Package | |
| ML20042B850 | List: |
| References | |
| NUDOCS 8203260210 | |
| Download: ML20042B849 (13) | |
See also: IR 05000313/1981022
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Dockets: 50-313/81-22
50-368/81-21
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Arkansas Power & Light Company
ATTN: Mr. William Cavanaugh III
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Senior Vice-President, Energy Supply
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P. O. Box 551
Little Rock, Arkansas 72203
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Gentlemen:
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Subject:
Emergency Preparedness Appraisal
To verify that licensees have ' attained an adequate state of on-site emergency
preparedness the NRC 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 aud
guidance.
During the period of August 3-14, 1981, the NRC conducted an appraisal of the
emergency preparedness program for the Arkansas Nuclear One Station (ANO).
Areas examined during this appraisal are described in the enclosed combined
report (50-313/81-22 and 50-368/81-21). W1 thin these areas, the appraisal
team reviewed selected procedures and representative records, inspected
emergency facilities and eo,uipment, observed work practices, and interviewed
personnel.
The findings of the emergency preparedness appraisal at the Arkansas Nuclear
One Station indicate that significant weaknesses exist in several areas.
These are addressed in Appendix A, "Significant Preparedness Deficiencies,"
of this letter. Significant deficiencies for which you have made acceptable
couaitments to resolve were discussed in the Confirmatory Action Letter,
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dated August 19, 1981. A copy of the letter, dated August 19, 1981, is
enclosed for your convenience 'as an attachment to this letter.
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NRC FORM 3tB ttO-80l NRCM O240
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Arkansas Power & Light Company
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The findings of this appraisal also indicate that there are areas for
improvement in your emergency preparedness program. These are discussed
in Appendix B. " Preparedness Improvement Items," of this letter.
We recognize that an explicit regulatory requirement pertaining to each item
identified in these Appendices A and B may not curmntly exist. Foi. withstanding
this, you are requested to submit a written statement, within thirty (30) days
of the date of this letter, de' scribing your planned actions for correcting each
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of the items identified in Appendix A and the results of your consideration of
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the items in Appendix B.
This description shall include: (1)stepswhichhave
been taken; (2) steps which will be taken; and (3) a schedule for completion
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of actions for each item. This request is made pursuant to Section 50.54(f) of
Part 50. Title 10 Code of Federal Regulations.
This is to inform you that if the deficiencies addressed in the Confirmatory
Action Letter, dated August 19, 1981, are not corrected by the cosedtment
dates provided, the Huclear Regulatory Commission will determine whether the
reactor shall be shut down until such deficiencies are remedied or whether
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other enforcesent action is appropriate.
In accordance with 10 CFR 2.790(a) of the Cosedssion's regulations, a copy of
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this letter, the enclosures, and your respons1ts to this letter will be placed
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in the NRC Public Document Room.
If the enclosures contain 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:
within ten (10)) days from the date of this letter of your intention to file a(a) notify t
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request for withholding; and (b) submit within thirty (30) days from the date
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of this letter, a written application to this office to withhold such ir.for-
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mation. Section 2.790(b)(1) requires that any such application must be
accompanied by an affidavit executed by the owner of the information which
identified the document or part sought to be withheld, and which contains a
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full statement of the reasons on the basis of which it is claimed that the
information should be withheld from public disclosure. This section further
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requires the statement to address, with specificity, the considerations listed
in10CFR2.790(b)(4). The information sought to be withheld shall be incor-
porated as far as possible 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.
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The responses directed by this letter and the accompanying attachments are not
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subject to the clearance procedures of the Office of Management and Budget as
required by the Paperwork Reduction Act of 1980, PL 96-511.
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OFFICIAL RECORD COPY
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Arkansas Power & Light Company
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Should you have any questions concerning this appraisal, we will be pleased to
discuss them with you.
Sincerely,
cen.9 sinar ex
K. sent
ohn T. Collins
Regional Administrator
Attachments:
1.
Appendix A - Significant Preparedness
Deficiencies
2.
Appendix B - Preparedness Improvement
Items
3.
Letter to Arkansas Power & Light Company,
dated August 19, 1981
4.
Office of Inspection and Enforcement Combined
Appraisal Report 50-313/81-22 and 50-368/81-21
cc: w/ attachments
Arkansas Nuclear One
ATTH: James P. 0'llanlon
General Manager
Post Office Box 608
Russellville, Arkansas 72801
bcc to DMD for dist.
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Arkansas State Dept. of Health
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OFFICIAL RECORD COPY
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APPENDIX A
SIGNIFICANT PREPAREDNESS DEFICIENCIES
The results of the NRC's appraisal of the Arkansas Nuclear One, Units 1 and 2
Emergency Preparedness Program identified a number of significant deficiencies
which were discussed in detail with the licensee's senior management on
August 14, 1981, and for which commitments were obtained from the licensee for
corrective action.
A confirmatory letter of the agreements was sent to the
licensee on August 19, 1981.
Six (6) areas were identified which had significant deficiencies and the areas
are presented below along with the specific finding number (s) from the appraisal
report which are covered by each significant deficiency area (references are to
the sections in Office of Inspection and Enforcement Combined Report 50-313/81-22
and 50-368/81-21).
SIGNIFICANT DEFICIENCIES
1.
Onsite Emergency Organization
Related specific findings: 313/81-22-18 and 368/81-21-18 (See Section 2.2)
313/81-22-21 and 368/81-21-21 (See Section 3.0)
2.
Offsite Radiological Monitoring Capability
Related specific findings: 313/81-22-34 and 368/81-21-34 (See Section 4.1.1.5.5)
313/81-22-45 and 368/81-21-45 (See Section 4.2.1.1)
313/81-22-56 and 368/81-21-56 (See Section 4.2.6)
313/81-22-71 and 368/81-21-71 (See Section 5.4.2.12)
3.
Personnel Accountability
Related specific findings: 313/81-22-72 and 368/81-21-72 (See Section 5.4.3.2)
313/81-22-73 and 368/81-21-73 (See Section 5.4.3.2)
313/81-22-74 and 368/81-21-74 (See Section 5.4.3.3)
4.
Public Education and Information
Related specific findings: 313/81-22-41 and 368/81-21-41 (See Section 4.1.4)
313/81-22-42 and 368/81-21-42 (See Section 4.1.4)
313/81-22-93 and 368/81-21-93 (See Section 6.2)
313/81-22-94 and 368/81-21-94 (See Section 6.2)
5.
Corporate and Site Emergency Plan
Related specific findings: 313/81-22-22 and 368/81-21-22 (See Section 3.0)
6.
Emergency Action Levels
Related specific fir. dings: 313/81-22-57 and 368/81-21-57 (See Section 5.1)
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APPENDIX B
PREPAREDNESS IMPROVEMENT ITEMS
In addition to the Significant Preparedness Deficiencies identified in Appendix A,
the results of the NRC's appraisal of the Arkansas Nuclear One, Units 1 and 2
Emergency Preparedness Program identified the following items as needing con-
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sideration for improvement in order to achieve an adequate emergency preparedness
program (references are to Sections in the Office of Inspection and Enforcement
combined Report 50-313/81-22 and 50-368/81-21):
1.
Develop and implement explicit and specific functional responsibilities and
authorities for the various emergency preparedness planning and coordination
functions (313/81-22-01 and 368/81-21-01) (See Section 1.5);
2.
Develop and implement a program for training individuals who are assigned
emergency planning responsibilities which will enable them to attain and
maintain a state-cf-the-art knowledge in the field of emergency prepared-
ness (313/81-22-02 and 368/81-21-02) (See Section 1.5);
3.
Evaluate the adequacy of the existing staff assigned responsibility for
emergency preparedness planning and coordination and develop a means to
augment existing staff when necessary (313/81-22-03 and 368/81-21-03)
(See Section 1.5);
4.
Develop and implement a method to provide substantive irtut from plant
staff, down to the working level, to emergency preparedness plans and
procedures development (313/81-22-04 and 368/81-21-04) (See Section 1.5);
5.
Develop and implement specific selection and qualification criteria for
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individuals performing emergency preparedness development activities
(313/81-22-05 and 368/81-21-05) (See Section 1.5);
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6.
Unambiguously define the authorities, responsibilities and duties of
individuals assigned to the licensee's emergency organization
(313/81-22-06 and 368/81-21-06) (See Section 2.1.1);
7.
Revise the description of the Initial Response Organization to reflect
functional areas of emergency activity, reporting chains (management
structure) and interrelationship of the functional areas, down to the
working level, consistent with Table B-1, of NUREG-0654, Revision 1
(313/81-22-07 and 368/81-21-07) (See Section 2.1.2);
8.
Develop and implement explicit and specific functional responsibilities
and authorities for the various emergency action functions and all
persons assigned to those functions (313/81-22-08 and 368/81-21-08)
(See Section 2.1.2);
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Develop and implement a program for training individuals who are assigned
emergency action responsibilities which will enable them to attain and
maintain a state-of-the-art knowledge in the field of their assigned
emergency action areas (313/81-22-09 and 368/81-21-09) (See Section 2.1.2);
10.
Include an approved list of licensee personnel (by name) in the Emergency
Plan Implementing Procedures who have been selected and a,re qualified to
perform activities within the functional areas of the on-site emergency
organization to which they are assigned (313/81-22-10 and 368/81-21-10)
(See Section 2.1.2);
11.
Evaluate the adequacy of the station staff assigned responsibility for
emergency actions, by functional area, and develop a means to augment
staff when necessary (313/81-22-11 and 368/81-21-11) (See Section 2.1.2);
12.
Develop and implement specific selection and qualification criteria for
individuals assigned to perform emergency actions and decision making
(313/81-22-12 and 368/81-21-12) (See Section 2.1.2);
13.
Develop and implement quality assurance procedures to evaluate the
effectiveness of the emergency action training for the various functional
areas (313/81-22-13 and 368/81-21-13) (See Section 2.1.2);
14.
Revise the Emergency Plan and implementing procedures to clearly id.entify
the primary responsibilities for emergency response by state and local
organizations within the EPZs, and other various supporting organizations
on which ANO would depend for technical support during an emergency
(313/81-22-14 and 368/81-21-14) (See Section 2.2);
15.
Revise the Emergency Plan and implementing procedures to clearly identify
the functional areas of emergency support to be provided to the station
organization, reporting chains, and the interfaces between the corporate
and non-licensee augmentation organizations and the station emergency
organization down to the working level (313/81-22-15 and 368/81-21-15)
(See Section 2.2);
16.
Develop and implement general plans and procedures for the recovery of
the ANO after an accident, including consideration of criteria for reentry
of the facilities and methods to be used to guide recovery operation until
plant operation could be resumed (313/81-22-16 and 368/81-21-16) (See
Section 2.2);
17.
Provide in the Emergency Plan copies of letters of agreement or contracts
which demonstrate that arrangements have been made with off-site organi-
zations to supply specifically defined support or cooperation during an
emergency (313/81-22-17 and 368/81-21-17) (See Section 2.2);
18.
Develop and implement methods to augment and supplement the AND Health
Physics Staff to assure the capability exists to provide 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day
coverage of the emergency health physics needs for protracted periods
(313/81-22-19 and 368/81-21-19) (See Sectic.1 2.2);
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19.
Provide initial training and at least annual retraining to all individuals,
organizations, and agencies that are expected to respond to an emergency
at an ANO facility.
This training shall include, but not be limited to
formal classroom training, hands-on experience, drills (as described in
NUREG-0654, item 0.2), and demonstrations of proper techniques.
The
material and subject matter to be covered shall include, but not be
limited to, the Emergency Plan, all relevant emergency procedures, duties,
authorities, responsibilities, emergency equipment, hazards associated
with performing emergency functions, and communications (313/81-22-20 and
368/81-21-20) (See Section 3.0);
20.
Provide radiation monitoring equipment with both audible and visual alarms
in the Control Room to determine the presence of both direct radiation
and airborne radioactive contamination (313/81-22-23 and 368/81-21-23)
(See Section 4.1.1.1),
21.
Provide continuous radiation monitoring devices, with both visual and
audible alarms, in the TSC for both direct radiation and airborne
radioactive contamination (313/81-22-24 and 368/81-21-24) (See Section
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4.1.1.2);
22.
Provide continuous radiation monitoring devices, with both visual and
audible alarms, for both airborne activity and direct rcdiation inside
of the OSCs (313/81-22-25 and 368/81-21-25) (See Section 4.1.1.3);
23.
Provide respiratory protection equipment and protective clothing for
the maximum number of persons who may report to each OSC (313/81-22-26
and 368/81-21-26) (See Section 4.1.1.3);
24.
Perform dose calculations based on the as-built configuration of the ECC
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with its associated room assignments to assure a radiation protection
factor of at least 5.0 exists for the dose assessment and decision making
functions.
The dose calculation shall be based on the full immersion of
the ECC in a cloud of 0.7 Mev. Gamma radiation (313/81-22-27 and 368/81-21-
27) (See Section 4.1.1.4);
25.
Install the portable shielding and extended reach tools as called for in
procedures 1607.01 and 2607.01 so that post-accident samples of primary
coolant may be taken safely (313/81-22-28 and 368/81-21-28) (See Section
4.1.1.5.1);
26.
Review all post-accident sampling and analysis procedures to assure that
ALARA considerations have been fully implemented (313/81-22-29 and
368/81-21-29) (See Section 4.1.1.5.1);
27.
Evaluate and correct the existing systems used to obtain a sample of
the containment atmosphere to assure that representative samples can
be safely taken and analyzed within a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> time frame and that
personnel exposures do not exceed the guidance contained in NUREG-0737,
Item II.B.3 (313/81-22-30 and 368/81-21-30) (See Section 4.1.1.5.2);
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28.
Upgrade the existing sampling system as necessary to ensure that the
provisions for sampling capability as specified in NUREG-0737 are met.
This includes considerations for procuring and analyzing a representa-
tive sample and ensuring that personnel exposures do not exceed 3 and
18 3/4 rem to the whole body or extremities, respectively (313/81-22-31
and 368/81-21-31) (See Section 4.1.1.5.3);
29.
Ensure that adequate methods, systems and equipment for assessing and
monitoring actual or potential off-site consequences of a radiological
emergency condition are in use (313/81-22-32 and 368/81-21-32) (See
Section 4.1.1.5.4);
30.
Provide for sampling of containment sump, ELCs pump room sumps, and other
similar Auxiliary Building sump liquid samples (313/81-22-33 and
368/81-21-33) (See Section 4.1.1.5.4);
31.
Provide sufficient respiratory protection equipment for all on-site
emergency workers in the assembly / reassembly areas (313/81-22-35 and
368/81-21-35) (See Section 4.1.2.1);
32.
Provide radiological monitoring equipment in all assembly / reassembly areas
to determine both direct radiation and airborne radioactive contamination
(313/81-22-36 and 368/81-21-36) (See Section 4.1.2.1);
33.
Assess the adequacy of the existing first-aid facility and the path to
it to assure that an injured person on a stretcher can be moved to and
treated at the first-aid facility (313/81-22-37 and 368/81-21-37) (See
Section 4.1.2.2);
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34.
Provide instructions for diverting normal shower drains to the radioactive
waste retention tank when the facilities are used for decontamination
purposes (313/81-22-38 and 368/81-21-38) See Section 4.1.2.3);
35.
Provide towels and soap at both decontamination facilities (313/81-22-39
and 368/81-21-39) (See Section 4.1.2.3);
36.
Provide instructions for decontamination at both decontamination facilities
(313/81-22-40 and 368/81-21-40) (See Section 4.1.2.3);
37.
Provide additional emergency kits and radiation detection instruments to
adequately equip the emergency teams as described in section 5.2.5 of the
AND Emergency Plan (313/81-22-43 and 368/81-21-43) (See Section 4.2.1.1);
38.
Provide high range radiation survey instruments with extendable probes
for in plant monitoring under emergency conditions (313/81-22-44 and
368/81-21-44) (See Section 4.2.1.1);
39.
Provide a remote readout to the Control Room of the emergency feedwater
suction pressure for Unit 2 (313/81-22-46 and 368/81-21-46) See Section
4.2.1.3);
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40.
Resolve the matter of exposure of the meteorological sensors at the 10
meter level of the tower with regard to the likelihood of the effects
from the trees to the east of the tower (313/81-22-47 and 368/81-21-47)
(See Section 4.2.1.4);
41.
Identify the means to be used for determining the magnitude of and for
continually assessing the impact of the release of radioactive materials,
including dose projections using real-time meteorological information
and consideration of terrain affected flow conditions (313/81-22-48
and 368/81-21-48) (See Section 4.2.1.4);
42.
Develop a dose calculation and assessment capability that includes a
treatment of meteorological factors, source characteristics, and building
configuration effects to provide realistic transport and diffusion
estimates for inclusion in the dose calculational methodology.
This
capability shall be outlined in a technical bases document discussing
the entire dose calculation scheme (313/81-22-49 and 368/81-21-49)
(See Section 4.2.1.4);
43.
Provide direct telephone access by NRC to the individual responsible for
making off-site dose projections and develop and implement procedures
for establishing contact and identification of contact individuals
(313/81-22-50 and 368/81-21-50) (See Section 4.2.1.4);
44.
Establish a QA program to provide the mechanism for review and evaluation
of the quality of data obtained for the meteorological monitoring systems
(313/81-22-51 and 368/81-21-51) (See Section 4.2.1.4);
45.
Develop and implement mechanisms to simplify the calculational require-
ments of the dose projection methods (313/81-22-52 and 368/81-21-52)
(See Section 4.2.1.4);
46.
Establish procedures to determine stability class from available data
from off-site locations (e.g., NWS) rather than presuming "G"
stability
independent of actual conditions.
This procedure could consider para-
meterization schemes such as the Pasquill or Pasquill Turner Solar
Index scheme (313/81-22-53 and 368/81-21-53) (See Section 4.2.1.4)
47.
Provide sufficient respiratory protection equipment for all on-site
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emergency workers (see also section 4.1.2.1 of this report) (313/81-22-
54 and 368/81-21-54) (See Section 4.2.2.1);
48.
Provide an HPN telephone in the TSC (this will require NRC action)
(313/81-22-55 and 368/81-21-55) (See Section 4.2.3);
49.
Correct the EPIPs by providing sections in each procedure on prerequisites,
precautions, limitations of actions and checklists to assure that the
procedure steps have been followed (313/81-22-58 and 368/81-21-58) (See
Section 5.1);
50.
Correct the EPIPs by specifically identifying those individuals by title
and name who have the authority, responsibilities, and qualifications
necessary to perform the tasks governed by the procedure (313/81-22-59
and 368/81-21-59) (See Section 5.1);
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51.
Correct the EPIPs by providing specific guidelines to be used in
exercising judgment in the implementation of specific actions and the
development of off-site recommendations of protective actions for the
public (313/81-22-60 and 368/81-21-60) (See Section 5.1);
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52.
Correction of the EPIPs and E0Ps to incorporate human factor consid-
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erations such as indexes, color coding, tabs, and different type styles
(FONTS) to highlight important items (313/81-22-61 and 368/81-21-61)
(See Section 5.1);
53.
Provide a high-range radiation survey instrument with an extendable probe
for inclusion in one of the on-site emergency kits (313/81-22-62 and
368/81-22-62) (See Section 5.4.2.2);
54.
Develop and implement the specific and explicit procedures, methods,
systems, and equipment for obtaining a representative reactor coolant
sample that shall not require an isolated auxiliary system to be placed in
operation in order to use the sampling system and for which exposures to
personnel in obtaining and analyzing the sample does not exceed the criteria
of GDC 19 (Appendix A, 10 CFR 50) (313/81-22-63 and 368/81-21-63) (See
Section 5.4.2.4);
55.
Develop and implement procedures that will provide for analysis of
representative post-accident samples of the primary coolant to include
explicit provisions for sample preparation, adequate data collection and
processing and counting of high level samples with ALARA considerations
(313/81-22-64 and 368/81-21-64) (See Section 5.4.P.5);
56.
Develop and implement specific and explicit procedures for the acquisition
of representative samples of the containment atmosphere under accident
conditions consistent with NRC guidance contained in NUREG-0737 (313/81-
22-65 and 368/81-21-65) (See Section 5.4.2.6);
57.
Develop and implement specific and explicit procedures for the preparation
and analysis of representative samples of the containment atmosphere con-
sistent with the NRC guidance contained in NUREG-0737 (313/81-22-66 and
368/81-21-66) (See Section 5.4.2.7);
58.
Develop and implement specific and explicit procedures for the acquisi-
tion of representative gaseous and particulate (stack) effluent samples,
under accident conditions, consistent with the NRC guidance conta.nea in
NUREG-0737 (313/81-22-67 and 368/81-21-67) (See Section 5.4.2.8);
59.
Identify liquid effluent release points or potential release points that
may cause off-site radiological consequences as a result of an emergency
condition (313/81-22-68 and 368/81-21-68) (See Section 5.4.2.10);
60.
Develop and implement speciifc and explicit procedures for the acquisi-
tion of representative samples from liquid effluent release points or
potential release points under emergency conditions consistent with the
NRC guidance contained in NUREG-0737 (313/81-22-69 and 368/81-21-69)
(See Section 5.4.2.10);
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Develop and implement specific and explicit procedures for the analysis
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368/81-21-70) (See Section 5.4.2.11);
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62.
Develop and implement specific procedures which govern the radiological
i
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monitoring and decontamination of personnel and use of special decontamina-
tion aids, e.g., potassium permanganate, etc. (313/81-22-75 and
368/81-21-75) (See Section 5.4.3.4);
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63.
Correct the emergency imp'lementation procedures to explicitly identify the
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" appropriate medical kit as discussed in procedure 1903.42 (318/81-22-76
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and 368/81-21-76) (See Section 5.4.3.5);
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64.
Provide adequate first aid supplies throughout the plant and develop a
)
method to insure that adequate stocks of such supplies are maintained and
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immediately available for emergency use (313/81-22-77 and 368/81-21-77)
(See Section 5.4.3.5);
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65.
Develop and implement provisions for briefings of emergency reentry
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teams to include maps, decisional aids, conduct of walk-throughs and special
,
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radiation protection considerations prior to reentry into accident areas
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(313/81-22-78 and 368/81-21-78) (See Section 5.4.5);
66.
Develop and implement plans and procedures which will govern the operations
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of the AN0 Recovery Organizations and criteria for its initiation and
transfer of command authority and responsibilities (313/81-22-79 and
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368/81-21-79) (See Section 5.4.6);
67.
Develop and implement procedures with specific criteria upon which the
emergency class will be downgraded and provisions for notification of
Federal, State, and local officials prior to entering a downgraded mode
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(313/81-22-80 and 368/81-21-80) (See Section 5.4.6);
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68.
Develop and implement procedures to handle rumors and provide the public
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with accurate information during emergencies (313/81-22-81 and
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368/81-21-81) (See Section 5.4.7);
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69.
Develop provisions to assure continuity of news releases during the
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time required to move the corporate news contacts from the corporate
offices to the news center at ANO (313/81-22-82 and 368/81-21-82)
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(See Section 5.4.7);
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70.
Compile, document, and correct deficiencies noted in the drill and/or
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exercise critiques, and maintain such records on file (313/81-22-83 and
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368/81-21-83) (See Section 5.5.2);
71.
Develop and implement procedures which specify guidelines for emergency
.
preparedness exercises and drills (313/81-22-84 and 368/81-21-84) (See
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Section 5.5.2);
12.
Perform communications drills with state and local governments at frequen-
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cies corresponding to the communication test frequencies specified in
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Section 8.3 of the Emergency Plan and/or frequencies specified in
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NUREG-0654, Regision 1, item N.2.a for all emergency response organizations
and agencies (313/81-22-85 and 368/81-21-85) (See Section 5.5.2);
73.
Review the Emergency Plan and its implementing procedures at least
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annually and establish a means to assure that up-to-date copies of the
appropriate sections of the Plan and its EPIPs are available for imme-
diate access to off-site response organizations (313/81-22-86 and
368/81-21-86) (See Section 5.5.3);
74.
Conduct at least yearly audits of the Emergency Plan, Emergency Pian
Implementing Procedures, and all supplementary procedures necessary for
full emergency response (313/81-22-87 and 368/81-21-87) (See Section 5.5.4);
75.
Provide for QA personnel to audit emergency preparedness drills and
exercises (313/81-22-88 and 368/81-21-88) (See Section 5.5.4);
76.
Review and evaluate the usability of existing documents and instruments
which would be used during an emergency, for human factors engineering
considerations (313/81-22-89 and 368/81-21-89) (See Section 5.6);
77.
Evaluate the status of training of off-site response personnel, develop a
listing and course description of the types of training the licensee
could provide for off-site response personnel, and offer initial training
and annual retraining classes (in addition to the training received by
participation in exercises and drills) to all off-site response organizations
(313/81-22-90 and 368/81-21-90) (See Section 6.1);
78.
Review all letters of agreement with off-site support organizations to
ensure that all are still acceptable and will be honored, and ensure that
adequately detailed Letters of Agreement exist for all o ganizations the
licensee will depend on for aid during an emergency (313/81-22-91 and
368/81-21-91) (See Section 6.1);
,
79.
Ensure that the EALs are discussed and agreed on by the licensee, State
and local governmental authorities, and develop and implement a method
to review the acceptability of the EALs with the State and local govern-
mental authorities on an annual basis (313/81-22-92 and 368/81-21-92)
(See Section 6.1);
80.
Provide for adequate and timely drills and exercises to test the
licensee's capabilities to effectively perform the various emergency
response functions as identified in the Emergency Plan and its
Implementation procedures (313/81-22-95 and 368/81-21-95) (See
Section 7.1);
81.
Provide for formal critique of all emergency drills and exercises and
methods to correct deficiencies identified (313/81-22-96 and 368/81-
21-96) (See Section 7.1);
82.
Ensure that personnel are sufficiently trained in their respective
emergency procedures, location, and use of emergency equipment for
off-site /on-site dose calculations (313/81-22-97 and 368/81-21-97)
(See Section 7.2.1);
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83.
Ensure that the appropriate personnel are properly trained to take samples
of primary coolant safely and efficiently during an incident (313/81-22-98
and 368/81-21-98) (See Section 7.2.2); and
84.
Ensure that all personnel are properly trained to perform their emergency
tasks safely and efficiently during an incident (313/81-22-99 and
368/81-21-99) (See Section 7.2.3).
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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HEGION IV
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611 RY AN PLAZA DRIVE, EulTE 1000
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August 19, 1981
Docket Nos. 50-313
50-368
Arkansas Power & Light
ATTH: Mr. William Cavanaugh III
Senior Vice President Energy
P. O. Box 551
Little Rock, Arkansas, 72203
Gentlemen:
This letter is to confirm the agreements reached between Mr. J. M. Griffin,
Assistant Vice President Operations, and others of your staff, and Mr. J. T.
Collins, Deputy Director, Region IV, and other members of the Nuclear Regula-
tory Commission staff on August 14, 1981, during the management exit inter-
view following the NRC Emergency Preparedness Appraisal of Arkansas Nuclear
One, Unit I and Unit 2.
Immediate corrective actions are required for the significant Appraisal
findings, The exact nature of the required actions, as well as the agreed
upon dates for such actions, are as follows:
1.
'Or. site Emergency Organization Augmentation
A.
Required Action
Pursuant to the requirements of the generic letter dated Feburary 18,
1981 to all licensees from Mr. D. Eisenhut regarding the minimum
staffing requirements for Nuclear Powar Plant Emergencies, Arkansas
Power and Light (AP&L) shall demonstrate by an unannounced drill that
the 30 and 60 minute minimum staff augmentation ior emergencies can
be achieved.
Further, augmentation deficiencies identified by the
drill shall be immediately corrected. Results of the drill shall be
documented and forwarded to the NRC for review and evaluation.
B.
Agreed Upon Maximum Date for Completion
The licensee shall conduct the above specified drill and submit
drill results to the NRC by September 19, 1981.
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
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Mro William Cavanaugh III
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August 19, 1981
2.
Offsite Radiological Monitoring Capability
A.
Required Action
The licensee shall describe their capabilities to perform offsite
radiological monitoring to a sufficient level of detail to demonstrate
that the offsite radiological monitoring teams can find and character-
ize an airborne release plume and obtain the necessary infonnation
with which the licensee can perform dose calculations, consequence
assessment, and provide input to the decision making for recommending
offsite protective actions to appropriate officials. The licensee's
response shall include, at a minimum, location, availability, and
capability of vehicles which would be used by the offsite radiological
monitoring team during an emergency; location, availability, and
capability of necessary radiological detection and measurement
instrumentation and equipment; location and capability of offsite
laboratories for radiological analysis of samples taken during an
emergency; the time and methods used to determine and transmit tha
field data to the location where the licensee will perform the dose
assessment calculations; and the licensce's provisions for training
and retraining members of the offsite radiological monitoring teams
sufficient for them to be able to perform their assigned tasks.
B.
Agreed Upon Maximum Date of Completion
The licensee shall submit the above information to the NRC by Sept-
ember 19, 1981.
3.
Personnel Accountability
A.
Required Action
The licensee shall demonstrate that the administrative and physical
means exist to perform accountability of all potential persons with-
I
in the exclusion area within 30 minutes of the start of the account-
ability process and provide continuing accountability of licensee
controlled emergency workers thereafter.
B.
Agreed Upon Maximum Date of Completion
The licensee shall submit by September 19, 1981 corrections of their
Emergency Plans and appropriate Emergency Plan Implementation Procedures
and submit any additional infonnation you deem necessary to demonstrate
that 30 minute personnel accountability capability exists.
4.
Public Education and Information
A.
Required Action
,
The licensee shall disseminate to members of the public population,
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Mr. William Cavanaugh III
3
August 19, 1981
within the 10 mile EPZ, material to inform and educate the population
concerning how they will be notified and what their actions should be
in an emergency. This information shall include educational informa-
tion on radiatioa; contacts for additional information, protective
measures such as evacuation routes and relocation centers, sheltering,
respiratory protection and special needs of the handicapped.
In the
,
dissemination process, the licensee shall make special provisions to
,
place this information at points where the transient population will
have access to it. Further, the licensee shall prepare preplanned
initial and followup messages to the public for broadcast over the
EBS immediately following initiation of the siren / tone alert radio
warning system and shall identify the individuals ty title who are
responsible for transmittal of such messages to the EBS radio
station during an emergency.
B.
Agreed Upon Maximum Date for Completion
The licensee shall submit documentation to the NRC showing that the
above actions are complete by September 19, 1981.
5.
Corporate and Site Emergency Plan
)
A.
Required Action
The licensee's Corporate Emergency Plan shall be integrated into the
Site Emergency Plan or submitted to the NRC as a separate plan which
is referred in the Site Emergency Plan. The Corporate Plan must
interface with the Site Emergency Plan such that areas of authority
and responsibilities are defined.
B.
Agreed Upon Maximum Date of Completion
The Corporate Emergency Plan and necessary revisions to the Site
Emergency Plan shall be submitted to the NRC by September 19, 1981.
>
6.
Emergency Action Levels
A.
Required Action
The licensee's Emergency Action Levels (EALs) shall be integrated
into the present Operating Procedures such that they are site specific.
The flow of procedures shall be written to reflect continuity from
normal operations, to abnormal operations, into emergency plan
implementing procedures.
B.
Agreed Upon Maximum Date of Completion
. The response for corrective action, including a description of the
action and time projections for accomplishing these actions, shall
be submitted to the NRC by September 19, 1981.
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Mr. William Cavanaugh III
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August 19, 1981
In addition to the commitments noted above, the following issues were discussed
at the exit interview held on August 14,1981, and are considered open items
pending additional information from Arkansas Power and Light company (AP&L).
'
Information sufficient to close out these issues shall be submitted to the NRC
by September 19, 1981.
1.
Provide shielding calculations and other appropriate information to
demonstrate that the permanent Emergency Control Center provides a dose
protection factor of five with regard to the design basis criteria of
immersion in a cloud of 0.7 Mev. gamma radiation.
2.
Provide a description of your interim provisions for post accident
sampling and methodology which describes obtaining representative primary
coolant samples and representative containment air samples for Unit 1 and
Unit 2.
Demonstrate that capabilities exist for obtaining post accident
samples safely.
In addition, the licensee shall verify that appropriate
portable shielding and equipment as described in your post accident
sampling procedures can be erected in a safe and timely manner until the
permanent post accident sampling system is initiated in accordance with
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3.
In a letter to D. Eisenhut dated January 17, 1980, AP&L proposed the
use of closed circuit television and that this system would be installed
in the Permanent Technical Support Center. To date, the equipment has
not been installed.
Provide information as to why the system is not
installed and what you intend to use in its place.
If our understanding of your planned actions described above is not in
accordance with your actual plans and actions being implemented, please contact
this office by telephone, (817)465-8100, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Sincerely,
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(b.uf$rfG
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/ Karl V. Seyfrit
Director
cc:
J. P. O'Hanlon, AN0 General Manager
Arkansas Nuclear One
Russellville, Arkansas 72801
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