ML20053A952
| ML20053A952 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 04/02/1982 |
| From: | Beckham J GEORGIA POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20053A914 | List: |
| References | |
| NUDOCS 8205270491 | |
| Download: ML20053A952 (15) | |
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- i April 2, 1982 U. S. Nuclear RegulatoIy Commission
REFERENCE:
Office of Inspection and Enforcement RII: JP0 Region II - Suite 3100 50-321/81-30 101 Marietta Street, NW 50-366/81-30 Atlanta, Georgia 30303 ATTENTION:
Mr. James P. O'Reilly ENTLEMEN:
In your letter of February 17, 1982, transmitting the results of your Emergency Preparedness Appraisal (Report Nos.
50-321/81-30 and 50-366/81-30),
you requested a written response addressing forty-six l
recommended improvement items.
Attached is an item-b/-item discussion of each recommendation.
Implementation dates were not specified; however, completion is scheduled to support incorporation into the next full-scale exercise.
Several recommendations require further assessment before we will be prepared to make a decision on implementation.
At this time we plan completion of these remaining reviews by June 1,1982, and will provide you with our conclusions at that time.
Very truly yours, hY J. T. Beckham, Jr.
SCE/mb Attachment xc:
M. Manry R. F. Rogers, III l
8205 27 Od y
l Attachment to April 2, 1982 letter EMERGENCY PREPAREDNESS APPRAISAL RECOMtENDATIONS FOR IMPROVEMENT 81-30-01 Recommendation Provide selection criteria for the onsite Emergency Planning Coordinator to include qualifications for the position, training and experience requirements to satisfy the selection criteria, and provide for ongoing professional development training to maintain state-of-the-art knowledge in the area of emergency preparedness.
(1.0)*
Response
The minimum position requirements for the onsite Emergency Planning Coordinator are:
1) a 8.
S.
Degree in Health Physics, Nuclear Engineering, or equivalent; and 2) knowledge of emergency planning criteria.
During the course of his employment the incumbent will participate in various seminars and workshops, as they become available, to keep him abreast of state-of-the-art developments in the area of emergency preparedness.
81-30-02 Recommendation Formally assign an onsite Emergency Planning Coordinator who has authority and responsibility for development and maintenance of the emergency preparedness program at the plant site.
(1.0)
Response
A Health Physicist has formally been assigned the authority and responsibility for the development and maintenance of the emergency preparedness program at the plant site as his primary responsibility.
81-30-04 Recommendation Provide a staffing chart delineating the emergency organization by functional positions and identify normal plant organization titles (and alternates) which will fill each emergency position.
(2.1)
Response
The necessary changes have been made to Section B of the Plant Hatch Emergency Plan.
- References are to Sections in OIE Report No. 50-321, 366/81-30 Page 1
e Attachment to April 2, 1982 Letter 81-30-05 Recommendation Provide a description of the activation and augmentation of the emergency response facilities and identify functional responsibilities for each class of emergency along with command and control functions and information flow diagrams.
(2.1)
Response
These items were reflected in the March,1982 revision of the Emergency Plan.
In addition, a discussion of the activation, staf fing, and responsibilities associated with the emergency centers is being factored into the emergency training program.
81-30-07 Recommendation Identify those support agencies with which a formal commitment for support has been obtained and segregate other agencies from which stoport may be expected but with which no binding agreement has been reached.
(2.2)
Response
Agencies with whom formal agreements exist are identified in Appendix 1 of the Plant Hatch Emergency Plan.
Available agencies from whom we expect support (without a formal agreement) are listed in Section C of the Plan.
This section will be expanded to more clearly identify the nature and degree of support expected from these agencies.
81-30-09 Recommendation PIuvide up-to-date copies of the Emergency Plan and Emergency Implementing Procedures to both Control Room Foremens' desks.
(4.1.1.1)
Response
Both Control Room Foremen's desks have been placed on the distribution lists for the Emergency Plan and Emergency Implementing Procedures.
Initial distribution has been completed.
Page 2
Attachment to April 2, 1982 Letter 81-30-10 Recommendation There is no alternate onsite location for essential support personnel to perfom the OSC functions.
(4.1.1.3)
Response
The final Technical Support Center (TSC) should be habitable this summer.
At this time the current (interim) TSC will be available for use as the OSC. The Unit 2 conference room area will then be used as an alternate OSC.
81-30-12 Recommendation Keep keys that are necessary for access to sampling areas in a location that is near the Chemistry Lab / Health Physics office area.
(4.1.1.5)
Response
Keys for access to sampling areas are kept in the Chemistry Lab / Health Physics office with the exception of the access key to the Turbine Building roof which foms a vital area barrier. The Security Department maintains the keys to all vital area doors.
81-30-13 Recommendation Establish the equipment and procedures for obtaining a high-level noble gas sample if the present gaseous effluent monitor goes offscale or is inoperable.
(4.J.1.5)
Response
Work is in progress to install new high range effluent vent monitors to ensure that all gaseous effluents will be properly monitored; hence, the need for additional equipment and procedures to obtain high level noble gas samples has been alleviated.
Page 3
I Attactnent to April 2,1982 Letter 81-30-14 Recommendation Provide shielding for the reactor building vent and main stack sampling equipment.
(4.1.1.5)
Response
This item is under review.
Additional response to this item will be provided by June 1,1982.
81-30-15 Recommendation Establish procedures and equipment for counting high activity samples on or near the plant site.
(4.1.1.5)
Respunse This item is under review.
Additional response to this item will be provided by June 1,1982.
81-30-16 Recommendation There are no secondary assembly areas on or offsite that provide alternatives for inclement weather, high traffic density and specific radiological conditions.
(4.1.2.1)
Response
Revisions to the Emergency Plan and Emergency Implementing Procedures now state that the location of the assembly points will be announced over the public address system. There are two alternative locations.
81-30-17 Recommendation Provide specific decontamination procedures in the decontamination kits.
(4.1.2.3)
Response
Specific decontamination procedures will be provided in the decontamination kits.
Page 4
Attachment to April 2,1982 Letter 81-30-18 Recommendation Work facilities / resources have not been designated for corporate, contractor and non-licensee augmentation personnel.
(4.1.3)
Response
This item is under review.
Additional response to this item will be provided ty June 1,1982.
81-30-19 Recommendation The Inventory Procedure should be changed to require inventory and operational checks of emergency kits after each use as well as quarterly.
(4.2.1.1)
Response
The Inventory Procedure (HNP 4892) has been changed to require the perfonnance of inventory and operational checks of emergency kits after each use as well as quarterly.
81-30-20 Recommendation The installation of high range monitors which meet the TMI Action Plan requirements will be evaluated during subsequent inspection.
(4.2.1.2)
Response
The appropriate high range monitors will be installed per TMI Action Plan requirements (see item 81-30-13).
81-30-21 Recommendation The wind direction indicator and chart recording should be aligned and torus water temperature recording should be made more readable.
(4.2.1.3)
Page 5 I
0
Attachment to April 2,1982 Letter
Response
Work is currently in progress in the area of meteorological parameter display systems.
Work will be done in determining and rectifying any problems with meteorological parameter display systems.
(See item 81-30-23).
Torus water temperature is one of the parameters currently included in the Safety Parameter Display System scope.
While this would resolve any concerns about parameter " readability" we will examine the problem and make improvements as necessary.
81-30-22 Recommendation The EAL for the seismic instrument should be specified in terms of the instrument readout.
(4.2.1.3)
Response
The Emergency Action Level (EAL) for the seismic instrument will be specified in terms of the instrument readout.
81-30-23 Recommendation Strip charts of meteorological parameters in the control room should be clearly labeled and graduated in accordance with the proper reference scales for each parameter and with clock time.
(4.2.1.4)
Response
Work is currently in progress in the area of meteorological parameter display systems.
Work will be done in determining and rectifying any problems with meteorological parameter display systems.
81-30-24 Recommendation During conditions of meteurological measurement system unavailability, an alternate source of meteorological data characteristic of site conditions, to which the licensee can gain access should be identified J
and established.
(4.2.1.4)
Response
A new Meteorological tower and system is going to be installed.
Following installation of the new tower, the existing tower will be rebuilt to serve as a back-up system to provide extra assurance that local meteorological data will be available.
Pcge 6 l
Attachment to April 2, 1982 Letter 81-30-25 Recommendation All EAL's should be clearly stated and readily accessible to the operators.
(5.1)
Response
The Emergency Action Levels are being revised to make them more functional for the operators.
Several possible schemes are under review.
81-30-26 Recommendation References contained in the procedures should be reexamined for sufficiency and appropriateness.
(5.1)
Response
References contained in the procedures have been reexamined for sufficiency and appropriateness.
This is a continuing process.
81-30-27 Recommendation The emergency, alarm, abnormal occurrence and fire protection procedures should state emergency classifications, where appropriat.3, or make more specific references.
Each procedure should also contain well defined "Immediate Action" and " Followup Action" sections.
(5.2)
Response
This item is under review.
Additional response will be provided by June 1, 1982.
81-30-28 Recommendation Review all instructions to ensure that specific references to the Emergency Plan or Emergency Implementing Procedures are included.
(5.3)
Response,
This has been and will continue to be done as part of an ongoing review effort at the plant.
An EIP/ Emergency Plan cross reference chart has been completed and incorporated into the Emergency Plan.
Further refinement of this chart is expected.
Page 7
t.
Attachment to April 2, 1982 Letter 81-30-31 Recommendation The data sheets provided for the offsite monitoring teams should be corrected to provide for recording survey instrument type and serial nunber.
(5.4.2.1)
Response
The data sheets provided for the offsite monitoring teams have been corrected to provide for recording survey instrument type and serial nunber.
81-30-32 Recommendation Emergency Procedures should be amended to make provision for disposition of data recorded by the offsite monitoring team, including a description of communication methods to be used and backup, and should provide radiation protection guidance.
(5.4.2.1)
Response
Emergency Procedures will be amended to make these provisions.
81-30-33 Recommendation The Emergency Implementing Procedures should be changed to include provisions for disposition of data recorded by the inplant monitoring teams and to include discussion of communications to be used by the teams.
(5.4.2.3)
Response
The Emergency Implementing Procedures will be changed to incorporate this recommendation.
81-30-34 Recormiendation Delete statements in the emergency procedures that state that high-level samples will be sent to offsite vendors for analysis and implement onsite or nearsite capabilities.
(5.4.2.4 - 5.4.2.11)
Page 8 I
i
Attachment to April 2,1982 Letter
Response
This item is under review.
Additional response to this item will be provided by June 1,1982.
4 81-30-35 Recommendation i
i Re-evaluate post-accident sampling procedures with regard to the number of persons required to obtain each sample.
(5.4.2.4 - 5.4.2.11) 4
Response
Post-accident sampling procedures (HtF-4825, 4828, 4829, 4830, 4831) have been revised to state that a minimum of two persons will be 4
required to perform the specified actions.
l 81-30-36 1
Recommendation j
Clarify the location to which analysis equipment will be moved if the analysis lab is not accessible or has a high background.
(5.4.2.4 -
5.4.2.11)
Response
Work is currently underway to ensure that the counting facility remains habitable under all conditions.
The ventilation system is being restructured to eliminate the possibility of airborne radioactivity entering the counting facility.
If the background should increase to a level which would prohibit proper counting of samples, the analysis equipment will be moved to the Environmental Building.
Following completion of the simulator building, provisions will be made to have the training laboratory as the alternate counting facility.
81-30-37 Recommendation Detemine counting efficiency factors for the counting shields to be used with high level charcoal, silver zeolite, and particulate samples.
(5.4.2.4 - 5.4.2.11)
Response
The counting efficiency factors are being developed.
Page 9 1
Attachment to April 2, 1982 Letter 81-30-38 Recommendation Establish proper procedures for the labeling and disposition of all post-accident samples (including liquid effluent samples) and consider using preformatted data sheets when obtaining the samples.
(5.4.2.4 -
5.4.2.11)
Response
This item is under review.
Additional response will be provided by June 1, 1982.
81-30-39 Recommendation Clarify the method by which reactor building vent and main stack samples are transported from the sampling area to the analysis facility and the location of shielding for these samples to be used during transport.
(5.4.2.4 - 5.4.2.11)
Response
This item is under review.
Additional response will be provided by June 1, 1982.
81-30-40 Recommendation Resolve the differences in the emergency response personnel exposure guides (whole body and thyroid) for oroviding first aid (non-life saving) that are listed in HW-4812 and the Emergency Plan.
(5.4.3.1)
Response
The differences in the emergency response personnel exposure guides which are listed in HP-4812 and the Emergency Plan will be resolved.
81-30-41 Recommendation The exposure criterion for aborting an attempt to obtain specific samples or readings (e.g., stack monitor reading in HP-4850, airborne radioactivity sample in HP-4826) should be re-evaluated to determine if a reading or sample could be obtained without exceeding the emergency exposure guideline of 3 rem. (5.4.3.1)
Page 10 J
Attachment to April 2, 1982 Letter
Response
l This item is currently under review.
Addition response to this item will be provided by June 1,1982.
81-30-42 Recommendation Resolve the discrepancy between Section 8 and J of the Emergency' Plan concerning emergency levels at which site evacuation is reautred.
(5.4.3.2) l
Response
I Sections B & J of the Emergency Plan have been revised and both sections now state that evacuation of.non-essential personnel from the site will occur during Site Area and General Emergencies only.
81-30-43 i
Recommendation
'}
There -is no procedural guidance provided on how accountability of protected area personnel will be conducted during Site Area or General i
Emergency.
(5.4.3.3) l
Response
The method by which the security department accounts for protected area i
j personnel during Site Area or General Emergencies will be included in the appropriate procedures.'
4 81-30-44 4
j Recommendation l
Plant Security Procedures do not make reference to the Security-actions required in the Administrative and Emergency Implementing Procedures.
(5.4.4)
Response
i j
This item is under review.- Additional response to this item will be provided by June 1,1982.
I Page 11 l
l i
i j
Attachment to April 2, 1982 Letter 81-30-45 Recommendation An Emergency Implementing Procedure has not been developed for Repair / Corrective Actions.
(5.4.5)
Response
A procedure has been written and approved to provide guidance for repair and corrective actions incorporating the ALARA philosophy.
81-30-46 Recommendation Clearly identify the organizational authority for initiating a recovery phase for all classes of emergency.
(5.4.6).
Response
The organizational authority for initiating the recovery phase will be clarified in Section M of the Emergency Plan.
81-30-47a Recommendation A more coordinated drill and exercise program should be developed which includes:
a drill and exercise schedule, assurances that all drills will be coordinated by the Emergency Planning Coordinator, and requirements which clearly state the management control of disposition of improvement items identified during critiques.
(5.5.2)
Response
Preliminary contacts have been made with a consultant to develop a series of exercises and assist with the next full scale exercise.
Development and management of the scenario and full scale exercise will be handled by a cross discipline Task Group.
Exercise and drill management will become an ongoing activity of Emergency Planning staff.
81-30-47b l
Recommendation Provide provisions for rumor control during emergencies and include references 'to the rumor control provisions in the public information program.
(6.2) l Page 12
m Attachment to April 2, 1982 Letter
Response
Provisions for rumor control during emergencies are provided in the public infomation program.
Emergency Plan references to the public infomation program will be clarified.
81-30-48 Recommendation Expand discussion of the public information program in the Emergency Plan and provide an implementing procedure dealing with activation and operation of the public infomation program during emergencies.
(6.2)
Response
Section G of the Emergency Plan has been revised to expand discussion of the public information program.
An implementing procedure will be developed, if deemed necessary, to deal with activation and operation of the public information program during emergencies.
81-30-49 Recommendation Better accountacility should be maintained on drill performance records.
(7.1)
Response
The drill evaluation process will be formalized to assure documentation of critique and other recommendations.
81-30-51 Recommendation Radiological Emergency Team members should be provided more training in the use of the graphs provided in the Emergency Procedures.
(7.2)
Response
RET members will be provided more training in the use of the graphs provided in the emergency procedures.
RET Training is being upgraded in response to other identified deficiencies.
Page 13 l
Attachment to April 2, 1982 Letter 81-30-52 Recommendation Electronic calculators should be provided in the Emergency Kits.
(7.2)
Response
Electronic calculators have been provided in the Emergency kits.
Page 14