ML20054C162
| ML20054C162 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 03/29/1982 |
| From: | Randazza J Maine Yankee |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20054C158 | List: |
| References | |
| MN-82-63, NUDOCS 8204200152 | |
| Download: ML20054C162 (11) | |
Text
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Qg EDISON DRnfE MAIRE HAllHEE Alom/CPmVERCOMPARUe AUGUSTA, MAINE 04336 jkq-(207) 623-3521 O
l March 29, 1982 MN-82-63 United States Nuclear Regulatory Commission Office of Inspection and Enforcement Region I 631 Park Avenue Kim of Prussia, Pennsylvania 19406 Attention:
Mr. Ronald C. Haynes, Regional Administrator
References:
(a) License No. DPR-36 (Docket No. 50-309)
(b) USNRC Letter to MYAPCO dated February 26, 1982
Subject:
Response to Emergency Preparedness Appraisal 50-309/81-21
Dear Mr. Haynes:
This is in resoonse to your letter [ Reference (b)] in which you requested, within thirty days of the date of your letter, our response to the seven "significant" corrective action items and twenty suggested improvement items that the NRC audit team identified in its recent appraisal of Maine Yankee's emeroency preparedness program.
Our resnonse to Appendix A, Significant Emergency Preparedness Findings are presented in Attachment A.
However, we question whether many of the items in Aopendix A were appropriately classified when placed in the "siqqificant" category.
Our response to Apoendix B, Emergency Preoaredness Improvement Items are presented in Attachment B.
We note the the summary section of your Inspection Reoort 50-309/81-21 stated:
"The auditors concluded that the licensee appeared to be capable of resoonding to and managing the response to an accident at the Maine Yankee Atomic Power Station".
8204200152 820414 DR ADOCK 05000309 PDR
h MAINE YANKEE nTOMIC POWER COMPANY U.S. NtJclear Regulatory Commission
. March 29, 1982 I.
Attention:
Mr. Ronald C. Haynes Page Two We trust our responses, contained in Attachments A and B, sufficiently i
explain our position on each of the items of Appendix A and B of Reference (b).
Very truly yours, MAINE YANKEE ATOMIC POWER COMPANY 3
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pn - - Jos J. B. Randazza f
Vice President J3R/bjp Attachments:
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STATE OF MAINE
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COUNTY OF KENNEBEC )
Then personally appeared before me, J. B. Randazza, who being duly sworn, i
I did state that he is Vice President of Maine Yankee Atomic Power Company, that j
he is duly authorized to execute and file the foregoing request in the name a
and on the behalf of the Maine Yankee Atomic Power Company, and that the statements therein are true to the best of his knowledge and belief.
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ATTACHMENT A: RESPONSE TO APPENDIX A SIGNIFICANT EMERGENCY PREPAREDNESS FINDINGS 1.
Finding:
Develooment of a coordinated, all inclusive training program for qualifying individuals and groups who are assigned various functional areas of emergency activity to include:
Designation of an emergercy preparedness instructor within the a.
training department as well as development of instructor qualifications; b.
Development of lesson plans with defined goals and objectives; c.
Development of a means to be used to train members of the onsite and offsite emergency organizations in changes of assignment, facilities, equipment and procedures which may occur in the period of time between scheduled training iterations; and d.
Centralization of all emergency plan training records such as training given to security, fire protection and offsite personnel and agencies, within the training department.
Re soonse:
a.
An Emergency Preparedness instructor has been designated within the Training Department.
Qualifications are based on: 1) Familiarity with all aspects of the Emergercy Plan and its implementing procedures, and 2)
Experience in Radiological Controls Training.
b.
Lesson Plans have been developed for most of the Bnergency Plan training. Lesson Plans for several new areas of training have to be developed and goals and objectives have to be included in the existing lesson plans.
c.
The Assistant to the Plant Manager responsible for site emergency preparedness will determine which changes in assignment, facilities, eouipment, and procedures will require special training between scheduled training iterations.
He will so advise the Training Deoartment, who will schedule and conduct any special training required.
d.
Emergency Plan training records have been centralized in the Training Depa rtment.
All the above actions will be completed by June 26, 1982.
i 2.
Finding:
Provisions for adequate space at the OSC to accomodate 25 to 30 individuals as well as supplies of radiation survey instrumentation, continuous air monitors and other equipment that may be required.
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Resoonse:
The OSC is within the Administration Building.
It is capable of accomodating 25 to 30 support personnel and such equipment as may be required as they stand by awaiting assignment.
The OSC is the assembly area for the predesignated operations support personnel.
If for any reason this number of individuals creates any difficulties, some of the personnel can be assigned to stand in reserve in other areas within the Administration Building.
s Provisions have already been made to increase the emergency supplies located at the OSC.
This will be completed by June 26, 1982.
3.
Findino:
Provision for post-accident coolant and containment sampling systems that will allow sampling and analysis within three hours without receipt of excessive personnel exposure, along with provisions for remote handling, storage and transport of samples.
Resnonse:
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The new post accident sampling system has been installed and is being tested.
The procedures and training required for personnel using the system will be completed by June 26, 1982.
The containment air sampling system is installed and will be operable by June 26, 1982.
The procedures and training will be completed by June 26, 1982.
Procedures for remote handling, storage and transport of samples are addressed in the new system and procedures.
4.
Findino:
Specification of facilities in the vicinity of the site which would be used for administrative and logistical support by the expanded support organization in the event of a large scale response to an emergency situation and incorporation of such facilities into the Emergency Plan.
Resconse:
Several areas are available for expanded support facilities in the event of a large scale response to an emergercy situation.
Witnin a mile of the plant site the company owns a large farm house and barn which can be used as a central administrative and logistical support cent er.
Large cleared fields adjacent to the barn can support parking and trailers if necessary. We believe this is adequate.
This site will be included in the Emergercy Plan by June 26, 1982.
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In addition, new facilities currently under construction will be available by March 1,1983 and will be incorporated into the plan at that time.
5.
Findino:
Provisions in the Emergency Plan and procedures for the needs of onsite damage control, corrective action and/or maintenance equipment and suoplies.
Resoonse:
Maine Yankee believes that this topic is adequately addressed in procedure 2.50.11 " Entry and Recovery Plan" and Section 9.0 " Recovery" of the Emergency Plan. We will however reexamine the plan and procedure to determine if additional provisions are warranted. We note you have not found our provisions for these activities deficient - only that not enough documentation was provided.
6.
Findino :
Expansion of the emergency classification scheme to include revision of projected dose levels and use of basic core / containment status indicators to identify General Emergencies as well as determine the relationship of the containment monitor to core / containment status.
Revision of the classification procedure to ensure prompt classification of all emergency conditons.
Resoonse:
The classification procedure (2.50.5 Declaration and Categorization of Emergency Condition" will be reviewed to assure that, where practical, observable explicit indicators will be added to the characterized emergercy conditions.
This will be completed by June 26, 1982.
This procedure now notes that " Completion of this activity must be achieved rapdily".
The procedure will be revised to indicate that this activity must be completed within 15 minutes.
7.
Finding:
Revision of sample analysis procedures to provide for analysis of high level samples as well as remote handling of the samples.
Resoonse:
The newly installed accident sampling system provides for large dilutions of high level samples to allow for safe handling and gamma scanning of accident samples.
Procedures developed for this system will address the safe handling and methods to be used for the required analyses.
This will be completed by June 26, 1982.
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ATTACHMENT B: RESPONSE TO APPENDIX B EMERGENCY PREPAREDNESS IMPROVEMENT ITEMS 1.
Item:
Provision for additional management emphasis and resources at the site level to the licensee's emergency planning effort.
Resoonse:
Maine Yankee believes the present emphasis and resources at the site level for emergercy preparedness are adequate.
As the NRC appraisal team noted, there is good coordination between the site and corporate levels of responsibility with corporate level providing site assistance as necessary.
Therefore, no changes are deemed necessary in this area.
2.
Item:
Revision of the description of the onsite emergency organization in Section 5.2 and Figure 5-1 of the Emergency Plan to reflect functional areas of emergency activity, reporting chains (management structures) and interrelationships down to the working level consistent with Table B-1 of NUREG-0654.
Re sponse:
Section 5.2 and Figure 5.4 of the Emergency Plan will be revised to more clearly identify functional areas of emergercy response and those individuals by position to fulfill these emergency functions.
Although the interrelationships between functional responsibilities, reporting chains, etc. are not completely depicted in Figure 5.4, this l
Information is covered in the Emergency Plan Implementing Procedures.
However, as the NRC auditors noted the reporting chains, fv.rtional responsibility, and overall responsibility for emergency caoldination is clearly understood by the plant staff.
3.
Item:
Development of lesson plans and qualification criteria to assure adequate training of specific licensee and non-licensee groups or individuals.
Resoonse:
The need for lesson plans was previously identified in section 3.1 of the Appraisal Report.
See our response to Finding 1, Attachment A.
We believe Region I staff agreed with our " hands on" approach to training although this was not reflected in this report.
4.
Item:
Imorove the habitability of the TSC.
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Resoonse:
A new building is presently under construction at the site that will house an expanded hardened TSC.
The building is scheduled to be completed by the end of 1982, and should be fully operational by April 1,1983.
5.
Item:
Provisions in the Emergency Plan clearly indicating that the classroom and training center in the Information Building could be rapidly transformed into an active Emergency Operations Facility (EOF).
1 Resoonse:
By designating the classroom and training center in the Information Building as the EOF, the provision already exists that these facilities can be rapidly transformed to their emergency functions upon delcaration of an emergency.
This will be demonstrated during the periodic drills.
No additional actions are planned in this area.
6.
Item:
Provisions for remote handling of gas and particulate effluent sample i
i filters as well as high level liquid samples.
Resconse:
This is addressed in the response to Item 3, Appendix A findings.
7.
Item:
l Provisions at the News Center for security, communications and other equipment needed to operate the center consistent with its designated l
functions during an emergency.
Resoonse:
If conditions indicated that a serious protracted emergency was imminent, then a decision would be made regarding the activation of the National Guard Armory in Augusta which has been designated as the Emergency News Center. Many facilities exist in the immediate area that would be able to more than adequately support its function.
Absent a requirement for a News Center and specific criteria for equipment we consider these provisions to be adequate.
8.
Item:
Calibration / testing of the high range containment air monitor over its entire range.
Resoonse:
The feasibility of calibrating-the high range containment monitor over its 8
entire range is under study.
The monitor reads over the range 10 to 10 R/hr.
9.
Item:
Provisions for written agreement with offsite agencies for self-contained breathing apparatus (SCBA) support.
Resoonse:
There are two air compressors located in the turbine building used for filling the plant's self-contained breathing apparatus (SCBA) including the units stored for emergency use.
In addition to the on site capability there are at least two offsite commercial facilities that can refill the SCBA.
There is no need to have a written agreement for support with these commercial enterprises.
- 10. Item:
Provision for inventory controls to ensure that adequate emergency equipment supplies would be available in the event of an emergercy.
Re snonse:
Specific emergency plan equipment in kits and the emergency response facilities is inventoried on a regular scheduled basis and after each usage. Radiation Protection instrumentation, orotective clothing, and miscellaneous supplies are maintained at a level that will support emergency ooerations.
- 11. Item:
Revision of the dose assessment procedure to highlight the steps to be performed by the control room and emphasize the need for prompt assessment of potential iodine releases.
Resoonse:
The dose assessment procedure is in the process of being revised and the revision will include the recommended items.
- 12. Item:
Reference Procedure No. 2.50.12 in Procedure No. 2.50.5 as well as provide Procedure No. 2.50.7, the Control Room and OSC with site survey maps.
Re soonse:
These recommendations will be incorporated in the next revisions of the Onergency Plan Procedures, scheduled to be completed by July 1,1982.
- 13. Item:
Reference to the in-plant survey forms and maps in Procedure No. 2.50.7 to l
include their location as well as classification of the purpose of the procedure.
Re sponse:
Procedure 2.50.7 will be revised to include the suggested improvements.
This should be completed by July 1,1982.
- 14. Item:
Specification of the radiation protection steps in Chemistry Procedure No.
7.1 to be taken as well as the location of special tools (e.g. lead pig) required for containment air sampling and primary coolant sampling.
Re sponse:
Procedures are being developed for the new accident sampling system which will address all the areas mentioned in this item.
The procedures should be completed by July 1,1982.
- 15. Item:
Develooment of a post-accident liquid waste sampling and analysis procedure that addresses radiation protection and special handling of high level samples.
Re sponse:
The handling of high level samples is always approached on a case by case basis with all the required Radiation Protection precautions considered.
The problem lies in being unaware of the high activity of the sample.
The post accident sampling procedure will include a precaution that warns the Chemist to aporoach all sampling with caution after an accident.
- 16. Item:
Establishment of an emergercy offsite environmental monitoring program that meets the requirements of NUREG-0654, criteria H.6.b, and development of appropriate supporting procedures.
Re sponse:
As the auditors noted in the appraisal report, the offsite environmental monitoring program is currently being updated to meet the requirements.
Procedures will be revised to incorporate the new program.
- 17. Item:
Specifications of the location of equipment and other supplies used for high radiation entry as well as the need for a high range survey instrument (1000 R/hr); reference to other procedures (e.g. Procedure Nos.
2.50.7 and 2.50.20) in Procedure No. 2.50.14, "Emergercy Radiation Exposure Control"; and specification of who has the authority to authorize the issuance of potassium iodide (KI).
Resnonse:
Procedure 2.50.14 will be revised at the next review to include the suggestions.
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- 18. Item:
Provision for direct offsite evacuation to a predesignated assembly j
a rea( s).
Resoonse:
A suitably sized facility capable of serving as predesignated assembly area in the event of offsite evacuation of site personnel will be investigated and the plan will be revised accordingly.
- 19. Item:
t Provisions to annually survey and assess local population awareness of the public notification system.
j Resoonse:
Maine Yankee will make reasonable efforts to ensure the public is aware of the notification system.
Maine Yankee has and will continue to provide annual disseminations to the public within the Emergency Planning Zone (EPZ) with basic emergency planning information in accord with 10CFR50.47(b)(7) which includes information on the Public Emergency Alerting System (PEAS) that Maine Yankee installed throughout the EPZ before July 1981.
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- 20. Item:
1 Provisions for the performance of all necessary drills and exercises in accordance with the requirements set forth in Procedure NO. 2.50.5,
" Emergency Plan Training and Exercise".
Re sponse:
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Drills will be held as indicated in Procedure 2.50.5.
- 21. Item:
Establishment of a priority distribution system whereby the EOF receives controlled copies of the Emergercy Plan and implementirg procedures expeditiously.
Re soonse:
The EOF will be given a priority listing on the Emergency Plan controlled distribution listing.
- 22. Item:
Update agreements between the licensee and offsite groups and provide for refresher training of offsite agencies including discussion of State resconsibilities in conjunction with the licensee's emergency response.
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Resoonse:
The Maine Yankee Emergency Plan including all written agreements between Maine Yankee and other parties will be reviewed and updated as a result of the experiences of the September 26, 1981 full scale exercise.
This review and update as needed should be completed by late June 1982.
The audit report stated that "no current agreement existed with the U.S.
Coast Guard (and Maine Yankee) regarding its responsibilities during an emergency".
The U.S. Coast Guard has a written agreement with the Maine Bureau of Civil Emergency Preparedness (MCEP) outlining its responsibilities in emergency response.
(See the State of Maine Radiological Incident Plan). This serves the same purpose as an agreement with Maine Yankee.
The Maine Bureau of Civil Emergency Preparedness through the federal government conducts specialized training and retraining for non-licensee emergency resoonse and planning personnel through existing programs as needed.
They also plan to conduct refresher training for interested offsite emergency response personnel in basic radiation protection, radiological monitoring, etc.
There is no need for Maine Yankee to duolicate this training. Maine Yankee is responsible for providing the training required for its emergency response personnel and those offsite agencies that may be required to provide onsite assistance.
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