ML20045D867
| ML20045D867 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/15/1993 |
| From: | Fleming J AFFILIATION NOT ASSIGNED |
| To: | Selin I, Taylor J, The Chairman NRC, NRC COMMISSION (OCM) |
| Shared Package | |
| ML20045D864 | List: |
| References | |
| NUDOCS 9306300151 | |
| Download: ML20045D867 (12) | |
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~ 8' Oceanwo od ' Dr49 e.
Duxbtuty, Ma.. 02332 Ju. rte. f 5 ', 1993 4
J Mt. Jamc4 Ta.ytor i
E.D.C.
USNRC 1
Waahingtort D.C.
20555
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Dear Jim,
Ettc4o4ed 44 a. icopy of the. 'i$.f orma44 ort IC pre 4e.nre,d'tojthe.-
S A L P ' C omm4Lle.e., Jane, ~ 10, 19 9 3. '. Two ; poirthe "I would ;lih.e.' to '
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.4dentify; Fir 4 L, thi4 :44 rtot -Jane.* 4;.opiniort v4. The.!NRC ' 4 lopirtLort '
A4 yoa cart 4ee my docanenta.4Lort 44 i f-area 4:that:have.atreAdy o
bc.en idextr4Le.d land devetope.d.;by the.JNRC; or identifie.d[by; FEMA artd cortcurre.d w4th bs the NRC.;, The. problem apperr4; to:,
be withrn the.: NRC :proce44. 'A4though'att the.jproblem4 had
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b e.e.rt ident4f Led by.the. NRC a t ' d4f f ere.nti time 474t1 appear 4 that ito.. one. co44e.c t4 att pertinert. data 'retate.d (to X orte.:444ae....
.cana4y4c4 that da.ta, and i the.rt pro p erty la44e 44 e4 [the.L e f f e.ctL44 will: ha.v e. - ort planets.rt9
,l The. originnt ' problem with thA4 444ae.' 4e.em47to have.vbe.en;
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inrtiate.d. by the NRC e.vatuntor4;. Tho4e. Iort44te.i and in the. EQF 2 dLd not fally 4 dent 44y the. myriad'of_ problem 4ithat"were.'
pre 4e.rtt4rts themaetve4.
T h 4 4 4 e.e m 4 / t o 1: 6e e4ther a.J La.ch of l L.-Artirtg tot the c.vatuntora backgrou.rtd /or 's delibera.teL overtooh.ing.of flaw 4.
I hope you a4certain what 'the." problem 44 and f4x. Lt.
The. 4e.cortd area not proparty e.va#M e t e.d ; b y: t h.e.: NRC-Wa4' d
the. E0C, Th44 a.rea 44 l e.44ent(at f o.r'.the.! NRC toL o 64e4y e..
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th44 44 Where, the. Prote,c.tive.1 Act4 ort 44~ de.termined and fi44u.c.d1 lJ
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from.. It 44 c e44extiat tha t the.1NRC be, pre.4ert[4rtith44 j
tocatiors to ; a4certairt; f 4444, lthe.Tinf oama.tiert wa4Lproperty -
i and compte tetyl tran4m4tte.d' by _the.1u t4L4ty; andi 4e.cortd; that the. State. proparty re.ce.4ved, analy4e.d,;andIthen) de.vctope.d'the.:
u tit 44y inf orma44on into e the? eorre.c4t prote.c44v'e.? a.ctiort".-
I SECOND, The Chalaman'4 l of fice.' and. the ED0 ' 4 Lof f 4ce. ha.M
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promi4e.d me. that corre.ctive.: a.ctiort4. W444: be. tahentif!the.y are."
decae.d ne.ce44ary.
I; am cortfideAt ' that 7the.' ind orma.tiotti _
y prov4de.d : to I the. SAL P CommLttee.L a.rtd now :to;yoa; define 4 Jthe. ;
- we.a.Ane44 that have. be.eniovertooke.d,f and determine.4!that corre.c.tiv e. actiort4 are. ne.e.de.d 240 ; as4are. ' Pu.bl4c! Health and' e
- Saf e.ty.
When !the. :wrortg ' Prote.c.tive. Ac44 ort: 44' de.velop'.d and -
s
.444u.e.d be.cau4e. the. ' u tL44ty f aite d? toa deuetop/a. compte.te: and; y
timelyi PAR,Cthe ne.e.d? f or corra.c.tive. a.ct4 orth 44f.4trortgly -
4nd4catc.d.
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I a.pprecia.te. the. Line. ' yon have. glue.rt Lto tht4 L44ae and -
tooh f orwand to hearing f rom you. negarding thc. corre.ctive.-
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a.c.tioita. planne.d f or botA the. NRC e.valuatora a.4 weit a.4 the.
l UtitLty and other organiza.tiorta that f a.4tc.d :to pa. ope.44y pcaf orm. thel.4 plann4rtg f artc.t40rt4..
I remind ' you. that 4A44 44 jaat otte a4pect of paartning. that haa sto 4ab4tartce. beAind the..
ream 4 o f pap er Ed44 ort. re,f c44. to a.4 planit4rts, the. ' othe.n anea4 off-44tc ha4 e.ven te.44 4ab4tance.-
(If te44 thart' th44 14.~
po44Lbte)
Urttll the. NRC - doc.4 'Lt4 iob,'. Ldentif ytrts and pr c p e 1 L Q a4s e44 Lrt9 the. pro b 9. uns Let plartrtietS I W e., the ' pu.btle do rtot and wlLL rtot have planning.
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8 Ocean. wood Dr D.abusy, Ma.. 92332 June 10, 1993 RE. PLfgrim SALP 1993 I a,pprecia.te the. Opportutta.y to a.ddre44 the SALP board the4e 444u.e4, ott bu.t a4 you. Artow I f ee4 4trortsty that the.
Emergency Pla.itrtirts wcahnc44e4 we. a.re a. bout to dL4ca44, 4hould have been part of the, NRC Irtitia.4 S AL P report.
.It L4 my hope that the4e 444u.e4, which ha.ve af4ca.dy iderttified a.nd.
de.veloped by the. NRC, WLtt ttow be. property a44c.44cd for the.-
Ai grtificattt impa.c.t they have had ort the La.ch of ef f ec.tiverteA4 of Emerg ertcy Preparedtte44.
Further the4e. L44u.e4 ortce property as4csae.d f or their 4LgrtLf Leance 4hou.td be LdentLf Led Ltt the FLitat S A L P.
RAe. NRC a.nd proper f ollow u.p to. a44ure. tha.t the. corre.c.44ve. Corrective Actio a.ctiorta have. been ~a.ddre.44e.d by - the. u.tLtity.
What weahrteA4c4?
Throu.gh a. re. vie.w of NRC docume.rttatLon a.itd FEMA cuaAnatiort the, area 4 of weahnc44 that were.
Ldc.rttif Le.d artd deuclope.d but therc. 449ttifica.rtce. rtot propcrty a44es4ed were:
f.
The utility; I44u.ed Lrtcompte.te. ' a.rtd Litaccurate. ' itotLf Lestiott O
form 4, Did rtot is4u.e stotLficaLLort in a. timely ma.rtner DLd rtot use the, proper communica.tiort vehicleA
'DLd rtot L44u.e. a. PAR thru the proper planntrtg' cha.rtneA4.
2.
The EOF aka. Good Ol' Boy 4 Clu.b Acce.pte.d he.ar4ay 42.ther than planiting - rtotif Lcatiort PaA4ed on hear 4a.y to the. ECC f ortm4 Did not po4t irtf orma.tlort ort 4ta.ta4 board j
Krtowingly a.cce.pted a.rtd pas 4e.d ort PAR irtf ormattort from i
unof f LeiaA cha.rtitcL4.
3.
The. EOC Accepted hear 4a.y Du.c. to Litcompte.te., ina.ccaratc., and untimety irtf orma4Lort rece.ived de.vcAope.d and is4aed the WRONG PROTECTIVE ACTION AND THE NRC FOUND THIS AREA AN EXERCISE STRENGTH WHY we. w444 now a.ddre44 the4e. 444aca a.rtd hope.f urty come, to the.
cortctustort that thi4 area was Letdc 2.d a. myrlad of weakne44es.
The. Ftrtat SALP hopef utty WLtt property a.ddres4 the4c L44u.e..
The itsecA4ary corre.crive. a.ctLort will be. tahe.it and the. SALP cAte. gory wLtt be changed to re.f tect the tru.e. charac.ter4ta44on of Emergertey Ptannitt9 3a. rte. A. Fteming.
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4 Problems Areas.
I. Notification
" Prompt notification of offsite authorities is intended to indicate within about 15 minutes for the-unusual event class and sooner ( consistent with the need for other emergency actions) for other classes.
The time is measured from the time at which the operators recognize that events have occurred which make declaration of an emergency class 9ppropriate."
( NUREG 0654 Appendix 1-3 BASIS FOR EMERGENCYLACTION LEVELS FOR NUCLEAR POWER F ACILITIES )
L Timelz notification af unusual event.
"The NOUE was received by Troop D at.0823. Following their procedures, the State EOC called Troop'D at'0837, and verified that Troop D had completed.all necessary notifications, including the notification of'MDPH.
However it was later determined that Troop D did not-notify MDPH of the NOUE until 0856."
(FEMA's Exercise Report page 12)
This is a 33 minute notification, 18 minutes beyond the
,required 15 minute notification time.
MDPH is the...
" commonwealth of ficials ( who) are to determine and implement appropriate Protective Actions."
(FEMA Ex. Report pg. 10.)
Why did this initir delay occur?
Why doesn't the Utility have direct communication with the... of ficials ( who ) are so determine and Implement the protective Action" Doesn't this indicate that Troop D's training did~not identify the importance of MDPH role in planning.
I would-assume MCPH should be first notified or perhaps second only to MEMA.
Is their no prioritizing in the notification?. If not there should be.
Page 26. of the FEMA Ex. Report states: "No communication delays.or problems were observed duringEthe exercise."
Interesting statement... would anyone' care-to explai'n it?
Where were the NRC evaluators to determine that the on-site information was properly and in a: timely manner' disseminated off-site?
'l Timely Notification gi General Emeroency According to the INITIALLNOTIFICATION FORM theievent was upgraded to General Emergency at 13:27 notif.icati'on was initiated at'13:40.
- 13. minutes l
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According to the FEMA Ex. Report.
"The State EOF staff informed the State EOC of the GE ECL declaration at 13:28.
However, the utility was somewhat slow in developine an off-site PAR at the GE ECL.
As a result the MEMA/MDPH EOF staff formulated their own PAR and sent-it to -the State EOC and the AREA II EOC. However, the MEMr. Director at the State EOC met with his key staff and decided to request that the State EOF staff obtain a utility PAR.
Shortly thereafter, the State EOF reported that the utility had developed a PAR at 13:44."
The time. discrepancies are fascinating.here.
As well as the fact this account is no whcre near the account. Nancy Ridley reported to me.
I request a clarification of the time discrepancies.
Clarification of the delay in the notification of the State of the upgraded status.
13:27 to 13: 44 is 17 minutes.
According to the INITIAL NOTIFICATION FORM notification of the upgraded to GE status was initiated at 13:40.
How did the State EOF have this at 13:28?
Shortly there after, the the State reported the'the utility had' developed a PAR at 13:44.
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The term developed and notification do not connote the same meaning. Whether the utility developed the PAR or Notification of the PAR was received must be clarified.
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The Utility supposedly developed the PAR between 13:27 and 13:40 when notification was initiated. The' EOF stated the PAR was developed at 13: 44.
If so it was late.
That should have been recorded by evaluators.
Remember, above NUREG 0654.
states that notification of levels'above unusual Event should be sooner than 15 minutes, not 17 minutes. Later it will be-developed that the EOF never received the PAR through proper communication channels.
Never i-s certainly--a violation of a
the 15 minute guide. NEVER is not SOMEWHAT LATE!
q No matter What the time sequence was or what information was f
developed or not developed ; thg Director af dgh& should aqi have Lg request thg PAR from thg Utility. This is an obvious failure on the part of the Utility.
Again the NRC evaluators did not observe this. Why?
One rationale presented to me was, because, they did not have primary meteorological data, the utility was delayed in there development of a PAR.
Again according to the PRIMARY NOTIFICATION FORM the lack of meteorological data was determined at 13:15.
18 minutes before'they declared GE and 25 minutes before they initiated notification.
Or, 29 minutes before FEMA's Ex. report states they developed a PAR.
The' initial notification form requests Meteorological: Data, it does not indicate primary source or secondary source, it appears that within the 18 minutes, 25 minutes or 29 minutes the utility had sufficient time to obtain secondary meteorological data and include:this data in the Initial
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Notification Form.
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Why was it that the Director of MEMA had to request.a PAR from the Utility?
Why was it the meteorological' Data was not completed on the form and why wasn't the PAR completed on page one of the INITIAL NOTIFICATION FORM?
This indicates not only a. problem of timeliness for.the Utility but procedural or training problems as well.
No matter which story of actual time sequence one believes the bottom line is the EOC Staff formed their own PAR and sent-it to the EOF as well as AREA II EOF;.
That original PAR developed by the State was incorrect.
The reason for the incorrect PAR was either -the. Utility was slow (17 minutes =a-violation) or the Utility"s-Initial Notification Form sent to the States MEMA/ FEMA EOC was incomplete.. Nancy Ridley who developed the incorrect' PAR only received the first page of-the INITIAL NOTIFICATION FORM.
That firstLpage did nat include Boston Edison's Protective Action Recommendation nor did it include the meteorological data.
Without that information the State could not possibly determine and implement a proper Protective Action. -Blami'ng the error on the " State Trainee" as the NRC is now attempting to characterize Nancy Ridley, does not^ hold up.
Nancy couldn't develop the proper information-she was not provided with the complete information by the utility. If Jerry Parker was the-
~fficial actually in charge of the development of the-
< rotective Action. As Bob Gregor of f the EDO's of fice inferred, why didn't he step in-and direct Nancy rather-than-the paid BECo exercise official.
Parker has years of.
experience in this area.
The utility is at fault here either:due to untimeliness or
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incomplete information.
The action of the Director of_MEMA requesting the PAR fromlthe Utility supports the position that the root cause of the problem was the util'ity. The NRC observers or investigators did not seem to have' observed these problems.
Why??
The NRC finds no weakness. WHY?
EXERCISE WEAKNESSES "An exercise weakness is_a matter that could preclude, in an area observed, effective Emergency Plan' implementation -in an actual emergency.
An exercise weakness is not, of itself,-an-overall response inadequacy, but does require correction under 10CFR 50, Appendix E, Section IV.F.5."
Explain why these events do not represent an exercise weakness?
- Effective Emergency = Plan implementation" The state developed.the wrong Protective Action.because the Utilities information was either untimely or-incomplete.
This.in my mind precludes effective Emergency Plan implementation.
The NRC found this area an Exercise Strength.
Why?
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What db1 the NRC observers-find?
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- i Accordingsto the the NRCfs
. Emergency Preparedness Program!
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and Exercise-Inspection.50-293/91-28 "No vi~olations or exercise weakness (were.: identified."
"2:.3 Activities observed-y Dumns theTe~xercise,'NRC team members madef observations of l
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the notification;and augmentation?ofLtheLEmergency Response.
Organization (ERO) activation of emergencyfresponse q
facilities', andfact-ions-of-emergencylresponse? facilities,~and;
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actions'of emergency' response personnelcduring the. operation?
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of the emergency response.facilitiesi'The-following activities were observed:
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- 1. Detection. classification,c andLassessment of-scenarioL
.j events;
- 2. Direction and coordination of the' emergency response;-
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- 3. Notification-of-licensee personnel 1and'offsitefAgencies';
4'.-Communications,'information flow,landLrecord; keeping; c
51 Assessment and: projection of;offsitefradiological* dose.,
consideration of' protective! actions, land' recommendation of, d
protectiveL action' to state of ficials;/"
z 6-10 not pertinent at'this, time.
A's-a. refresher',.from the same'NRC exercise. report; "3.0 Classification of Exercise 1F ndings
-Exercise Strengths.
3 Exercise-strengths provide strong positive *. indication of the-licensee's ability to cope with'abnormalsplant' conditions:and
'i implement;the Emergency Plan.
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Exercise Weaknesses.
.An exercise weakness is a. matter'that,could preclude, vin the.
j area observed. effective Emergency Plan implementat' ion in an-actualEemergency.
An1 exercise weakness is not Lof: itself, an overall' response of inadequacy, but does require correction u nder 10CFR. 50, Appendi'x~E. Section;IV',F.5.
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Areas' for:. Improvement-1 An1 area for ' improvement is an~ area.which did not.have
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1 signI#icant negative? impact on exercise performance.
However., it should-be evaluated by1the' licensee to determine ~
if corrective action couldJimprove performance i
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"4.0 Exercise Observations 4.1 Control Room No exercise weakness identified" BUT "After the Unusual Event was declared and prior to activation of emergency. response facilities, additionalLpersonnel were not.immediately available to carry out in-plant assignments made by the Nuclear Operations Supervisor ( NOS )"
Why not? According to NUREG 0654 Table B-1 Mi nimum Staf finq for NRC~ Licensees for Nuclear Power' Plant Emergencies the vast majority of these positions are on-shift personnel..
Where were they?
Staging the control room portionuof this in the NOS's office' certainly was.not realistic.
l "4.4 Emergency Operations Facility....
The following areas were identified as exercise. strengths:
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Performance by key members of EOF support groups was very-effective.
This included response actions in engineering'and technical assessment, radiation Protection, dose assessment, and administration.
1, Review 'of expected protective Action Recommendations ( PARS )'
4 and'and related informatlon with the offsite-impact was l
continuously discussed with the Massachusetts' staff who were 1
present in the EOF."
l Unfortunately while the boys were chatting-about.what they were expecting ( the INITI AL NOTIFICATION FORM)' and' passing aan hearsay'that there'was a General Emergency.to the States-I MEMA/MDPH EOC 17 minutes before the incomplete INITIAL NOTIFICATION FORM was developed..This resulted in the MEMA/MDPH EOC issuing an inaccurate Protective Action.
It is nice that the offsite impact was ~" continuously discussed" in the EOF, it would have been far more-effective if the personnel in the EOF'and especially'the personnel in the EOC, had had timely ^and complete information from the utility following the plan.
It also would be far more effective if the' EOF personnel, Bob Hallissey had the sense to convey the' accurate weather'information and the. Utility-PAR.to the EOC.
That:is, after. Director Rodham did finally request and receive this information, at.13:44 or later.
Remember.the FEMA Ex. Report states.the EOF was aware the utility developed a PAR.at 13:44 it-did not state they received the official notification-at that. time.
The MEMA/MDPH EOC is the official' state organization that'must determine and implement the~ Protective Action. Not the EOF l.
Planning should reflect that'as a secondary verification'the EOF should communication with-the EOC and verify the 5
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a-receiving oft a lli of f icialf notif icationi per ti ne ntito1 thel-EOC c determination-and-implementation?offa Protective Action. This action'should=be 'a: secondary.' verification, fthe utilitly a
should send of ficial notificat' ion tthatEi'sibothitimely; /a nd complete to' the EOC- ( the 'commonwdalthiof ficiall( wh'o Mare to' 1
determine and implementLa-protective; action.- ' '
M The EOF. sounds'llke'another " Good old Boy 3M'e'eting*/ Everyone Il
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m chattedsaboutDwhat,they'wheretexpecting',7lut[didn'tfreceive; q
b thru prope'r - communication, channels. JThek "al10 impressed ;one; another and:obbiously the!NRC.inspectovs.Jwithltheirlsfibi ',
O knowledge-oftthe situation...They passedDon! hearsay:Joriverball knowledge thatfa General Emergency'hadlbeenicalled,; seventeen minutes before'the'. Utility developediafPAR;. jThat1 hearsay; resulted :I n Lthe~- MEMA/MDPH. EOC: attempting; to :; determine?a Protective Action.
The? Protective'?Actionithe1EOCididfissue" was. inaccurate. The'onlyfonelout.yofi the' group whoiseem:to:-
have'any common' sense was'DaveLRodham' Director..'ofEMEMA[who finally, requestedLthe: Utilityito develop 1afPAR'. Lbut',J that
- was af ter an inaccurate ' Protective; Action 1was: issued byJth'e:
MEMA/MDPH-EOC-.
lAM E $ INSPECTORS-FOUND THIS AREA M EXERCISE'STRENGTHi WHY? WHY?:WHY?
If this-is:not-~an' exercise' weakness. "Almatterithat could' preclude; in:an~ area observed,ieffective.cemerdency(plan implementationLinLan~ actual emergencv."'
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L The' wrong ' Protective ActionL was Lissued,' 'iff thatNwasi note "a matter thatEwould preclude effective ^emergenep plan',
implementation"'I:can't imagin'e manyfthings.?thatlWould preclude effective Emersency!Planfimplementatio.n; How and why-'did'this happen?'
- Accordingitolthen."Of ficial'
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FEMA a'nd NRC~ evaluations. Lack.of-timely!developmentiof the utilities PAR, ! incomplete. Information :( no. met Ldatai no : PAR ) lon the' Utilities Initial _ Notification;FoVm!andiunofficial hearsay being passed from the'. EOF:toftheT OC.
iIf'the. plans; E
' har' been properly implemented'and. adhered to this wouldlnot-have happened.
- AND THE:NRC INSPECTOR-F.OUNDrTHIS; AREA ~ AN-EXERCISE: STRENGTH i
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WHY why WHY.???-
And:then what' happened; Following' the' FEMA Put. ':: Meeting I;
. entered into discussion with Nancy Ridley?The'.MuiA/MDPH EOC
- official'in chargeilof determining:and_ implementing:a?
L Protective 1 Action.
Nancy.'s-versionfof events differ Econsiderably. f rom-the - FEMA or NRC reports l. :.( SeeJ Apr '.2,1993 J Letter tol David. Williams pgs.. 5181 At tac hed )'.
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As stated following my discussion with Nancy Ridley..I called Jim Taylor EDO.
At Jim's request I explained my concerns to Ebe Mc Cabe.
Ebe then researched this area and developed an extensive understanding of the: problem that.
occurred in this area of the exercise.
Ebe and I stayed in close communication during this time and I was kept up to speed on the development of this issue.
Tim Martin also, in the communication loop.was helpful in adding additionally to my knowledge.
It was Tim who sent along the Initial notification Form.
What was learned in'this process:
1.
The initial notificat' ion form of the upgrade to GE sent to the EOC did not include weather data.nor'a utility PAR.
Initial Notification Form 2."It Was indicated the the State (EOC) was provided scenario weather by an exercise controller..."
As Nancy indicated.
NRC Inspection report No.50-293/92-04.pg9-3.
"NRC follow-up found no specific: transmission of scenario-weather to the State.
NRC INS REP pg 9 4
"The backup meteorological tower data (scenario wind speed and wind direction) were available in the EOF, 'but were not included on the notification-form transmitted to the EOC."
NRC INSP. REP.pg 9
? If'there was no specific transmission of scenario-weather transmitted to the state, see 3 how did the EOF'obtain the weather data?
The' good ol' boys' club. Why didn't the utility'
. follow planning procedures for proper' notification?
5.
"NRC discussion with the licensee emergency preparedness personnel confirmed the backup (scenario) weather information on data sheets for entry onto EOF status boards.
However, na record or specific recollection of ' posting of that information on the status boards or'af communication af that information t_q thg Commonwealth responders wgg provided."
NRC INSP REP pgs 9-10 Obviously, Planning procedures of proper. notification by the utility nor the EOF were followed. gThe basic essence of planning ; the proper notification'of Stnte official of the Utilities PAR and supporting weather data, did'not~ adhere to planning procedures nor-did the utility comport with NUREG 10654 E.
1.,2.,3.
4.9.,1..
And THE NRC INSPECTOR FOUND THIS AREA AN EXERCISE STRENGTH-WHY, WHY WHY?
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The information developed bV Ebe McCabe portrayed in the'NRC Insp: Rep states further tha-;
"The licensee expressed the foll6 wing / intentions."
"..To include' bac k up =.meteorolog'icalldata on;the.' notific'ation '
forms when. prima'ry meteorologicalEtower)? data?is not':
available"-
(What about i.ncluding.theLPARlas well,.seeLIdITIAt?
' NOTIFICATION 1 FORM)'
"..To furthers discuss' EOF 41nformation': sources UWithithef resconders'..- a nd to : providei a written idescr iptiont.off thosel sources for the responders'information folders W This has'to be a' JOKE. :Ebe clearlyddeterminedlthatytheT
. Utility did not - followipl'anningsprocedures, nThefutilitWdid i not'use theLproper' communication channel.,The 1 u t i'li ty':'did i
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not-communication.the'pr6perinf6rmationDonithe;propet;
'o notification formsk The Utility:vio'latedithefabovefmentioned s'ection'of-'NUREG 0654 The'EOFJreceived?information.
Knowingly-from incorrectJsources andEthe;NRCyagreesithey) should PUTiA WRITTEN REPORT;IN'THEIR: FOLDERS.
e tch',tch tch, obviouslyfthis?isLnoththe(appropriatefaction.
What is:therapproprlatetaction?
Whyididn't the"NRCjproper19:
address:this? Problemsandidemand correctiveXactions;as wellpas-retraining 1of:both' utility:and statelofficials.
And.the NRC INSPECTORS FOUND LTHIS : AREA - AN' EXERCISE'. STRENGTH-
~-WHY why'why'? '
Further information,gsined from.Ebe.Mc Cabe's::investigatiorU
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intoithis area.
- in EBE's'
- June 19,1992fletter?toime?he states-
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"also, the'11icensee had changed there' notification? form to better' insure thatcsuch; data:would belprovided even if the
-j primary'meteorologica12 ower inputs;were1 unavailable."
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Great but.what about. inclusion of theiPARion the1 notification.~
l form
'no mention'of that.:
'The letter goes onsto.' state:
T..there :isllicensee.NRC,= a nd Commonwealth ofLMassachusettsistaff:developmentJand-.
assessmentiof protective:actionirecommendations."'
~Did this' include training theTotility..toluse;the pr'oper
, J notification formsi'and completelyfandzaccuratelyyfillinglthe forms out?: Did it include 7trainingithefutility1to'use2the.
' proper Plan ~ designated:meansSof' communication?-':Didathis.
train the ' state toaccepttinformatibn) onlyDfrom the; properi.
plan > designated form andMcommunication.
Did thiss train the)
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Utility and the State Official in the EOF to.give.up.the; Good Ol' Boy Method of communicating the most essential emergency, planning information?
The letter goes-on to state. the NRC' recognizes my concern.
about variability of coast'al winds and the use-if off-site' l
( logan) data is less than accurate -( totally not pertinent).
but the utility will now assure us they will1 include on-site weather data in the future.
?
The letter goes on to say because'the state finally produced the correct PAR their is no need for.the NRC to initiate a separate review of off-site planning.
The question is why hasn't the NRC initiate a thorough investigation-in.to.the on-site problems, as well as the NRC evaluators assessment.of.
this issue, reassess 'the informationL Ebe : developed irt his investigation of this area.
Properly and clearly identify-all problem areas and implement 10 CFR150 Appendix E,'Section IV.F.5. forcing the Utility to take proper corrective Actions.
Then the NRC can take the' proper action against the Exercise Investigators. discipline retrain or whatever the NRC does Ne't reassess when they fail this miserably at their-job.
x the work Eoe did and determine the proper corrective, action r
that should be taken there.
l Then the NRC can investigate.what went wrong off-site.
- BUT, get your focus correct-the:EOC did go.to a back up weather source that would not be accurate, they did develop.and issue an inaccurate Protective Action but the. root-cause of the EOC 's problem was the Utilities lack of completeJand-timely information.
The NRC should' direct its investigations to the EOF aka the GOOD Ol' BOYS CLUB were everything'was cosy and friendly and no planning procedures were'followed; But for right now the NRC'can correct ~ the FINAL SALP-remove the mis statement-no weaknesses were found.
Insist theJBECo take the proper corrective actions'and.then.the.NRC can put SECo's emergency. planning into Catergory'3, where it. belongs.
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