ML20053E304
| ML20053E304 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 01/11/1982 |
| From: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Jackie Jones CAROLINA POWER & LIGHT CO. |
| Shared Package | |
| ML20049J359 | List: |
| References | |
| NUDOCS 8206070784 | |
| Download: ML20053E304 (8) | |
See also: IR 05000324/1981026
Text
_.
YELLOW
J AN 11 1982
Docket Nos. 50-324 and 325
Carolina Power and Light Company
Attn: Mr. J. A. Jones
Senior Executive Vice President
and Chief Operating Officer
411 Fayetteville Street
Raleigh, N. C. 27602
Gentlemen:
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Subject: Emergency Preparedness Appraisal
To veri fy - that licensees have attained an adequate state of onsite emergency
preparedness, the Office of Inspection and Enforcement is conducting special
appraisals of the emergency preparedness programs at each power reactor site.
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These appraisals are being performed in lieu of certain routine inspections
normally conducted in the area of emergency preparedness. The objectives are to
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evaluate the overall adequacy and effectiveness of emergency preparedness'and to
identify areas of weakness that need to be strengthened.
We will use the
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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 October 13 - 22. 1981, the NRC conducted-a special appraisal
of the emergency preparedness program at the Brunswick Steam Electric Plant.
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Areas examined during this appraisal are described in the enclosed report 50-324,
325/81-26. Within these areas, the appraisal team reviewed selected procedures
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and representative records, inspected emergency facilities and equipment.
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observed work practices, and interviewed personnel.
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The findings of this emergency preparedness appraisal indicate that certain
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deficiencies exist in your emergency preparedness program. These are discussed
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in Appendix A " Emergency Preparedness Deficiencies". You_have made acceptable
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commitments to resolve these deficiencies as discussed in Appendix A.
If the
deficiencies are not corrected by the committed dates, you are reminded that
enforcement action will be considered.
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This emergency preparedness appraisal also indicates that there are areas that
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should be evaluated and considered for improvement in your emergency preparedness
program.
These areas are discussea 'n Appendix B, " Preparedness Improvement
Items".
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8206070784 820218
DR ADOCK 05000324
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Carolina Power and Light Company
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We recognize that an explicit regulatory requirement pertaining to each iteia
identified in Appendices A and B may not currently exist. Notwithstanding this,
you are requested to submit a written statement within thirty days of the date of
this letter, describing your corrective action for each of the items identitied
in Appendix A and the results of your consideration of each -f 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.
This request is made pursuant to Section 50.54(f) of Part 50, Title 10,
Code of Federal Regulations.
In conjunction with this appraisal, the emergency plan for your facility was
reviewed to insure compliance with applicable regulations. The results of this
review, included as Appendix C, indicate that certain areas of your plan do not
contain sufficient information to aemonstrate compliance with the planning
standards of 10CFR50.47(b). Changes to the emergency plan to correct these areas
are to be provided to this office and the Office of Nuclear Reactor Regulation
within 30 days of the date of such change in accordance with 10CFR50.54(q). All
identified emergency plan deficiencies are to be corrected within 120 days of
the date of this letter.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures will
be placed in the NRC's Public Document Room unless you notify this office, by
telephone, within ten days of the date of this letter and submit written appli-
cation to withhold information contained therein within thirty days of the date
of this letter.
Such application must be consistent with the requirements of
2.790(b)(1).
The responses directed by this letter and the enclosures are not subject to the
clearance procedures of the Office of Management and Budget as required by the
Paperwork Reduction Act of 1980. PL 96-511.
Should you have any questions concerning this appraisal, we will be pleased to
discuss them with you.
Sincerely,
s/
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James P. O'Peilly
Regional Administrator
Enclosures:
1.
Appendix A, Emergency Preparedness Deficiencies
2.
Appendix B, Preperedness Improvement items
3.
Appendix C, Emergency Plan Deficiencies
4.
Of fice of Inspection and Enforcement
Inspection Report No. 50-324, 325/81-26
cc w/ encl:
C. R. Dietz, Plant General Manager
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Carolina Power and Light Company
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bcc w/ encl:
NRC Resident Inspector
Document Management Branch
State of North Carolina
Emergency Preparedness Licensing Branch IE:HQ
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APPENDIX A
EMERGENCY PREPARE 0 NESS DEFICIENCIES
Based on the results of the NRC's appraisal of the Brunswick Steam Electric Plant
Emergency Preparedness Program conducted October 13 - 22, 1981, the following
deficiencies were identified:
(References are to Sections in OIE Report
No. 50-324, 325/81-26 and the applicable standard of 10 CFR 50.47).
1.
Emergency Plan Training / Retraining Program (Section 3.0; 50.47 (b) (15)).
An adequate training and .etraining program had not been established and
implemented for all emergency response personnel and general employees.
2.
Dose Assessment (Section 7.2; 50.47(b) (9)).
Capability to perform initial offsite dose projection / assessment in the
event of an emergency was not adequate.
During the appraisal exit meeting, October 22, 1981, and by subsequent telephone
conversation with Mr. G. R. Jenkins of this office on October 28, 1981, the
licensee committed to resolve the above deficiencies as follows:
The Emergency Plan training / retraining program will be defined by
December 23, 1981 and will be fully implemented by April 1,1982.
The procedure for performing initial of fsite dose projection / assessment will
be upgraded by November 6, 1981.
Retraining on this procedure for appro-
priate personnel will be completed, in:luding drills / walk-throughs, by
January 30, 1982.
These commitments are considered acceptable.
The aforementioned areas will be
reviewed during a future inspection.
APPENDIX B
PREPARE 0 NESS IMPROVEMENT ITEMS
Based on the results of the NRC's appraisal of the Brunswick Steam Electric Plant
Emergency Preparedness Program conducted October 13 - 22, 1981, the following
items should be considered for improvement: (References are to Sections in GIE
Report No. 50-324,325/81-26).
1.
Revising the Corporate Emergency Plan to be compatible with Revision 2 of
the Emergency Plan pertaining to the augmented emergency response
organization (2.2).
2.
Ensuring that the ENS telephone extensions in the TSC are operable (4.1.1.2).
3.
Providing procedures to allow personnel traveling from the TSC to the
Control Room to do so in a timely manner (4.1.1.2).
4.
Adding shielding and installing HEPA and charcoal
filters in the
ventilation system for the TSC (4.1.1.2).
5.
Specifying areas or rooms in the Service Building which are to be used for
OSC purposes (4.1.1.3).
6.
Establishing a backup OSC (onsite or near site) (4.1.1.3).
7.
Ensuring that the ENS telephone in the EOF is operable (4.1.1.4).
8.
Storing radiological equipment, decontamination supplies and emergency
protective supplies in the EOF (4.1.1.4).
9.
Improving the EOF habitability to meet NUREG-0696 criteria (4.1.1.4).
10.
Shielding of lines leading to the sample hood which are likely to contain
high concentrations of radioactivity during an emergency, in order to
maintain radiation exposures as low as reasonably achievable (4.1.1.5).
11.
Ensuring that provisions are made such that a containment air sample can be
taken nder a full range of accident conditions. Shielding and/or modifica-
tions should be made s Jch that radiation doses received by the personnel
taking the samples are ALARA. In addition, consideration should be given
to the handling and analysis of particulate and iodine samples from the
drywell continuous air monitor (4.1.1.6).
12.
Establishing a mechanism (monitoring device or administrative control) to
,
permit
postaccident
collection
of
particulate
filters
and
charcoal / silver zeolite cartridges from the stack and Turbine Building vents
prior to the accumulation of activity levels which are difficult, if not
impossible, to quantify via gamma spectroscopy (4.1.1.7).
.
Appendix B
2
Preparedness Improvement Items
13.
Reviewing the need for special sampling equipment and sample station
shielding to determine whether any improvements are needed in present
liquid radsaste/ effluent sampling capability (4.1.1.8).
14.
Providing copies of decontamination procedures for the decontamination
kits at the TSC and Visitor's Center (4.1.2.3).
15.
Designating the necessary number of Emergency Environmental Monitoring Teams
and providing a complete emergency kit for each team (4.2.1.1).
16.
Providing respiratory protection and protective clothing for each Emergency
Environmental Monitoring Team (4.2.1.1).
17. Maintaining a copy of the emergency kit inventory in each kit as required
by PEP 4.2 (4.2.1.1).
18. Making provisions for obtaining a backup source of representative
meteorological
information which should reflect access to real-time
information witi, specific procedures for obtaining and utilizing the
information and for routine checks of communication (4.2.1.4).
19.
Providing for severe weather information to be available to the Control Room
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day (4.2.1.4).
20.
Upgrading / improving the PEP dose assessment procedures (5.4.2).
21.
Improving PEP-3.5.1 to address *he use of silver zeolite cartridges in taking
air samples and to identify the specific instrumentation to be used by the
teams and the storage locations (5.4.2.1).
22.
Referencing the RC&T procedures to be used for in plant surveys in ?EP-3.3.1
and PEP-3.3.2 (5.4.2.3).
23.
Iden ti fying the relationship between PEP-3.3.3 and RC&T-1500 in each
procedure (e.g. , cross-referenced) (5.4.2.4).
24.
Adding precautionary notes and other appropriate conditions to Procedure
RC&T-1500 relative to sample preparation and handling for chloride and
boron analyses (5.4.2.5).
25.
Revising procedure RC&T-0150 to recognize that post-accident particulate and
radioiodine samples from containment may contain significant quantities of
radioactivity such that they present a handling problem (5.4.2.6).
26. Making provisions for greater sample-to-detector distances (as much beyond
10 cm as possible), for counting high level charcoal / silver zeolite
cartridges and particulate filters via gamma spectroscopy (5.4.2.7).
Appendix B
3
Preparedness Improvement Items
27.
Establishing a procedure for post-accident collection of particulate
filters and charcoal / silver zeolite cartridges from the stack (5.4.2.8).
28.
Providing for informing personnel of recommended evacuation routes from
plant areas in emergency conditions (5.4.3.2).
29.
Specifying the assembly areas for a site evacuation in PEP-3.8.1 (5.4.3.2).
30.
Making agreements for medical assistance with more than one general
practitioner (5.4.3.5).
31.
Improving information procedures to identify information liaison with State
and Federal organizations (5.4.7).
32.
Improving provisions for rumor control (5.4.7).
33.
Reviewing procedure RC&T-0600 to express more clearly the limits in
Section 2.1 and the limits referenced in Section 8.6.
Reviewing the
appendices of RC&T-0600 to ensure that the information is current (5.5.1).
34.
Preselecting personnel for the Reerstry Teams prior to an emergency (5.5.1).
35.
Developing a program to implement the commitment for drills and exercises
(5.5.2).
36.
Documenting corrective actions resulting from drills and exercises (5.5.2).
37.
Revising PEP-4.5 to clarify that updated dissemination of information to the
public is accomplished annually as specified in the Plan (6.2).
38.
Revising information procedures to identify a program for familiarization of
the news media (6.3).
.
_ _ _ _
APPENDIX C
EMERGENCY PLAN DEFICIENCIES
Based on the results of the NRC's review of the Brunswick Steam Electric Plant
Radiological Emergency Plan (Revision 2), the following deficiencies have been
identified: (References in parentheses are to criteria of NUREG-0654, Rev.1).
1.
(B-5) The minimum staffing requirements identified in Table B-1 of
NUREG-0654 should be satisfied.
The staffing identified in the Plan and
clarified by your letter dated June 9,
1981, is deficient in augmented
staf fing and should be upgraded to provide for augmentation of on-shift
staffing within the time limits and in those functional areas identified in
Table B-1.
2.
(0.1, 0.2) The emergency classification and emergency action level scheme
set forth in the Plant Emergency Procedures should clearly identify the
specific instruments, parameter values, and equipment status.