ML20054H727
| ML20054H727 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 06/11/1982 |
| From: | Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Counsil W NORTHEAST NUCLEAR ENERGY CO. |
| Shared Package | |
| ML20054H728 | List: |
| References | |
| NUDOCS 8206240370 | |
| Download: ML20054H727 (9) | |
See also: IR 05000245/1982001
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JUN 11082
Docket Nos. 50-245
50-336
Millstone Nuclear Power Station, Unit Nos. 1 and 2;
ATTN: Mr. W. G. Counsil
Vice President-Nuclear Engineering and Operations
P. O. Box 270
' Hartford, Connecticut
06101
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Gentlemen:
SUBJECT:
EMERGENCY PREPAREDNESS APPRAISAL (50-245/82-01; 50-336/82-01)
To verify that licensee's have attained an adequate state of onsite emergency
preparedness, the Office of Inspection and Enforcement is' conducting a special
appraisal at each power reactor site.
The objectives of the appraisal at each-
facility is to evaluate the overall adequacy and effectiveness of emergency
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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 and guidance..
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During the period of January 4-14, 1982, the NRC conducted an appraisal of the
emergency preparedness program at the Millstone Nuclear Power Station. Areas
examined during this appraisal are described in the enclosed report (50-245/82-01;
50-336/82-01). Within these areas, the appraisal team reviewed selected
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procedures and representative records, inspected emergency facilities and
equipment, observed work practices and interviewed personnel.
The findings of this emergency preparedness appraisal indicate that certain
corrective actions are required-in your emergency preparedness program.' These
are discussed in Appendix A, "Significant Emergency Preparedness Findings."
Significant findings for which you have made acceptable commitments to resolve
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were discussed in the Confirmatory Action Letter dated February 4, 1982, a
copy of which is enclosed for your convenience. These findings are included
in Appendix A.
Other areas needing improvement are discussed in Appendix B, " Emergency
Preparedness Improvement Items."
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In conjunction with the aforementioned appraisal, emergency plans for your
facility are being reviewed by the Emergen.cy Preparedness Licensing Branch,
D.ivision of Emergency Preparedness, Office of Inspection and Enforcement. The
results of this review will be discussed in Appendix C, " Emergency Preparedness
Evaluation Report" which will be sent by separate, letter upon completion.
Appendix A and B of this letter contain an inclusive listing of all
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outstanding emergency preparedness items at your facility at.this time.
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OFFICIAL RECORD COPY
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Millstone Nuclear Power Station,
JUN 111SB2
Unit Nos. I and 2
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We recognize that an explicit regulatory requirement pertaining to each item
identified in Appendices A and B may not currently exist. Notwithstanding
this, you are requested to submit a written statement within thirty (30) days
of the date of this letter, describing your planned actions for improving each
of the items identified in Appendix A and the results of your consideration of
each of the items in Appendix B.
This description is to include, (1) actions
'which have been taken, (2) actions which will be taken, and (3) a schedule for
completion of actions for each item.
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In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure
~will be placed in the NRC Public Document Room unless you notify this office,
by telephone, within ten days of the date of this letter and submit written
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application 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 telephone notification of your intent to request withholding,
or any request for an extension of the 10 day period which you believe necessary,
should be made to the Supervisor, Files, Mail and Records, USNRC Region I, at
(215) 337-5223.
The reporting requirements contained in,this letter affect fewer than ten (10)
persons and therefore are not subject to Office of Management Budget Clearance
as required by P. L.96-511.
Should you have any questions concerning this inspection, we will be pleased
to discuss them with you.
Sincerely,
Original Signou #1
G. H.st4r7M
1
George H. Smith, Director
Division of Emergency Preparedness and
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Operational Support
Enclosures:
1.
Appendix A, Significant Emergency Preparedness F bdings
2.
Appendix B, Emergency Preparedness Improvement Items
3.
Letter to Northeast Nuclear Energy Company dated
February 4, 1982
4.
NRC Region I Inspection Report Number 50-245/82-01;
50-336/82-01
cc w/encls:
E. J. Mroczka, Station Superintendent
D. G. Diedrick, Manager of Quality Assurance
R. T. Landenat, Manager, General Facilities Licensing
J. F. Opeka, Vice President, Nuclear Operations
Central Files
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
State of Connecticut
J. T. Shediosky, NRC Resident Inspector
OFFICIAL RECORD COPY
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Millstone Nuclear Power Station,
JUN 111932
Unit Nos. I and 2
3
bcc w/encls:
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Region I Docket Room (with concurrences)
Chief, Operational Support Section (w/o encis)
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OFFICIAL RECORD C
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Appendix A
Significant Emergency Preparedness Findings
Based on the results of NRC's appraisal of the Millstone Nuclear Power Station
Emergency Preparedness Program conducted January 4-14, 1982, the following
improvements are required:
(References are to sections in the NRC Region I
Inspection Report No. 50-245/82-01; 50-336/82-01.)
1.
Revise the emergency organization to provide for all emergency functions
needed during initial, intermediate and final phases of augmentation.
Revise the Emergency Plan to include a description of the emergency
organization and update administrative and implementing procedures to be
consistent with the revised organization. The description shall include
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sufficient detail to define the command hierarchy; specify its structure,
reporting chains and interrelationships at any phase of augmentation; and
include suparvisory as well as nonsupervisory elements.
(See Section 2.1)
2.
Develop lists of personnel trained and qualified to perform the tasks
associated with each functional area specified within the revised emergency
organization. These lists shall identify the current training status of
each individual, and provisions to maintain the lists current shall be
developed and implemented.
(See Section 2.1)
3.
Pursuant to the requirements of the generic letter dated February 18,
1981 to all licensees from Mr. D. Eisenhut, NRR, regarding the minimum
staffing requirements for nuclear power plant emergencies, perform a
study to determine how the augmentation of the on-shift staff can be
achieved within the 30 and 60-minute goals of NUREG-0654, Table B-1,
after the declaration of an emergency. The results of this study will be
documented and forwarded to the NRC Region I office for review and evaluation
along with a description of compensatory measures for any augmentation
goals not met.
(See Section 2.1)
4.
Establish an integrated emergency plan training / retraining program to
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ensure that lesson plans are developed and training is accomplished for
each functional area of emergency activity including radiation protection
during emergencies, emergency repair / corrective actions, search and
rescue, and radwaste operations.
(See Section 3.1)
5.
Develop a procedural method to ensure'that members of the emergency
organization are trained in any pertinent changes to emergency procedures,
facilities or equipment which occur between scheduled training sessions.
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(See Section 3.1)
6.
Develop a systematic method for documenting and maintaining records of
emergency training and retraining.
(See Section 3.1)
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7.
Establish a Technical Support Center (TSC) for Unit 2 which provides on
an interim basis until a permanent TSC can be established which meets
applicable regulatory criteria, adequate working space for assigned
personnel and which alleviates potential crowding in the control room.
(See Section 4.1.1.2)
8.
Describe in the Emergent.y Plan the division of technical support functions
between the TSC, the Emergency Operations Facility, and the Corporate
Emergency Operations Ceater for Units 1 and 2 and indicate the functional
areas of emergency activity to be performed at each technical support
function location.
(See Section 4.1.1.2)
9.
Develop an implementing procedure for activating and staffing the TSC and
establishing the responsibilities and functional areas of emergency
activity to be performed in the TSC.
(See Section 4.1.1.2)
10.
Establish an Operations Support Center (OSC) with sufficient space for
assigned emergency response personnel to assemble in the event of an
emergency, and which includes communication, protective equipment and
supplies needed for the performance of emergency activities that may be
required of assigned personnel.
(See Section 4.1.1.3)
11.
Revise the Emergency Plan to describe the-location of the OSC and the
concept of operations for the OSC including how work teams will be formed,
equipped, dispatched, and controlled in an emergency.
(See Section 4.1.1.3)
12. Develop an implementing procedure for activating and staffing the OSC.
(See Section 4.1.1.3)
13.
Expedite the development of precedures and training on the post-accident
sampling systems presently being installed to ensure that the systems are
fully operational in the minimum amount of time.
Provide a status report
and schedule for these activities to the NRC Region I office.
(See
Section 4.1.1.5)
14. Perform a radiological analysis which demonstrates that liquid and gaseous
effluent samples can be obtained under postulated accident conditions.
(See Section 4.1.1.5)
15. Develop specific detailed procedures and training for obtaining liquid
and gaseous effluent samples under post-accident conditions.
(See
Section 4.1.1.5)
16. Propose a plan of action to establish consistency between the onsite
emergency classification and action level scheme those of local and State
emergency response organizations in accordance with the guidance of
NUREG-0654, Appendix 1.
(See Section 5.3)
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17. Develop specific detailed procedures and training for chemistry personnel
for the analysis in the chemistry laboratory of primary coolant', containment
air, and liquid and gaseous effluent samples containing high levels of
radioactivity. (Section 5.4.2.5)
18. Develop detailed organization and procedural methods for implementing a
radiation protection program for emergency response personnel which
provides for the continuity of critical radiation protection procedures
and functions during accident conditions.
(See Section 5.4.3.1)
19.
Improve management controls to ensure that all recuired drills and exercises
are performed and properly documented as specified in the Emergency Plan
and Implementing Procedures.
(See Section 7.1)
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An andix B
Emergency Preparedness Improvement Items
Based on the results of the NRC's appraisal of the Millstone Nuclear Power
Station Emergency Preparedness Program conducted January 4-14, 1982, the
following should be considered for improvement:
(References are to sections
in the NRC Region I Inspection Report No. 50-245/82-01; 50-336/82-01.)
1.
Formally appoint a full-time Emergency Planning Coordinator for the
Millstone Nuclear Power Station. The appointment should include the
development of a position description clearly specifying the duties,
responsibilities, and authority of the EPC.
(See Section 1.1)
2.
Revise the Emergency Plan to fully reflect the assignment of responsibilities
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for maintaining emergency preparedness of Corporate and Station personnel
including the Emergency Planning Coordinator.
(See Section 1.1)
3.
Develop specific selection and qualification criteria for the Emergency
Planning Coordinator and other Station personnel with emergency planning
responsibilities.
(See Section 1.4)
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4.
Establish a professional development program for individuals who are
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assigned emergency planning responsibilities which will enable them to
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attain and maintain state-of-the-art knowledge in the field of emergency
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preparedness.
(See Section 1.4)
5.
Describe in the Emergency Plan the State role in an emergency situation
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identifying the lead State agencies.
The interfaces between the onsite
and Corporate emergency organizations and the State of Connecticut and
other offsite emergency response agencies should be included in the
revised emergency organization description.
(See Section 2.2)
6.
Align the training categories of the emergency plan training / retraining
with the functional areas of emergency activity in the revised emergency
organization and develop a procedure to implement the program. .(See
Section 3.1)
7.
Develop a training document which describes the program for training
offsite support agencies and specifies the responsibilities for the
different training courses, training objectives, subject content of the
courses, and means for documenting the training.
(See Section 3.1)
8.
Provide means to ensure that all personnel assigned emergency response
duties receive the required training in the emergency plan training
program.
(See Section 3.2)
9.
Develop a training course for emergency managers which emphasizes the
protective action decision making process, protective action strategies,
and the use of protective action guides.
(See Section 3.2)
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10. Designate an offsite location or locations where site personnel could
reassemble in the event of a site evacuation.
(See Section 4.1.2.1)
11. Provide personnel decontamination procedures at the Emergency Operations
Facility personnel decontamination facility and in the decontamination
kit located in the Condensate Polishing Facility assembly area.
(See
Section 4.1.2.3)
12. Describe how work facilities and other resources in the vicinity of the
site would be made available for Corporate, contractor and other personnel
in the event of a large, prolonged response.
(See Section 4.1.3)
13. Develop a system to ensure that the integrity of the emergency monitoring
kits is maintained and replacements are provided for instruments taken
out of the emergency monitoring kits for calibration until the original
instruments are returned.
(See Section 4.2.1.1)
14.
Include provisions for extremity monitoring in emergency kits.
(See
Section 4.2.1.1)
15. Duplicate the readouts for the main stack effluent monitors in the Unit 2
control room.
(See Section 4.2.1.2)
16.
Install a supplementary meteorological tower to better characterize air
flow and effluent transport at the site.
(See Section 4.2.1.4)
17. Develop procedures-to ensure meteorological strip charts are properly
timed and checked at an appropriate surveillance frequency.
(See Section
4.2.1.4)
18. Provide information on a nearby source of offsite or onsite meteorological
data that can be used as a backup in the event of loss of the primary
tower, rather than the two proposed locations, Middletown or Waterbury, CT.
(See Section 4.2.1.4)
19. Provide dedicated self-contained breathing apparatus in the TSC.
(See
Section 4.2.2.1)
20. Provide reliable emergency vehicles for use by Emergency Monitoring Teams
for plume tracking capable of transporting equipment and personnel off
road and in adverse weather.
(See Section 4.2.6)
21. Develop a more usable format for EALs in Procedures OP 501 and OP 250 and
provide additional training for Shift Supervisors and other Directors of
Station Emergency Operations in classifying emergencies.
(See Section 5.3)
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22. . Changes should be made as indicated in Section 5.3 of this report to the
emergency action levels for Unit I and Unit 2 in Procedures OP 501 and
OP 2501, respectively.
(See Section 5.3)
23.
Perform a drill to verify the adequacy of the alert, call-in, and augmentation
capabilities of the emergency response organization.
(See Section 5.4.1)
24.
Implement the procedure used to ascertain the containment source term
based on containment high-range monitor readings and provide training on
its use to dose assessment personnel.
(See Section 5.4.2)
25.
Provide action steps in Procedure EPIP 4201 for the prompt transmission
and continuous update of assessment information to State and local agencies-
responsible for protective action decision making. (See Section 5.4.2)
26. Develop provisions for trend analyses of assessment data.
(See Section 5.4.2)
27. Develop the methodology to utilize in plant sampling results and offsite
environmental survey data in the radiological consequence assessment
program.
(See Section 5.4.2)
28.
Ensure that instrumentation specified in the emergency monitoring and
sampling ;.ucedures is available for use by EMT. members; include guidance
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for self-extremity monitoring in the procedures.
(See Section 5.4.2.3)
29.
Provide emergency data sheets for each sample and establish a method for
providing the information to personnel in the emergency organization
responsible for assessment decisions.
(See Section 5.4.2.5)
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30.
Reference in emergency sampling procedures any routine procedures that
are to be used during emergencies.
(See Section 5.4.2.10)
31. Develop a specific procedure for site evacuation specifying the emergency
position or individual in the emergency organization responsible for each
action and including references to other pertinent procedures.
(See
Section 5.4.3.2)
32.
Develop a personnel accountability procedure which lists each step in the
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accountability process, identifies the responsible individual, and provides
for a full accounting of plant personnel within 30 minutes from the
declaration of an emergency.
(See Section 5.4.3.3)
33.
Revise the appropriate procedures to provide for the monitoring and
decontamination of personnel in the control room and at all assembly area
locations.
(See Section 5.4.3.4)
34. Develop decontamination procedures for skin contaminated with radioiodine.
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(See Section 5.4.3.4)
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35. Specify in Procedure EPIP 4208 the emergency position or individual
within the emergency organization responsible for organizing, controlling,
and supervising the search and rescue effort.
(See Section 5.4.3.5)
36. Specify in Procedure EPIP 4209 the emergency position or individual
within the emergency organization responsible for organizing, controlling
and supervising the repair and corrective action effort.
Include in the
procedure the criteria for team selection, location of emergency equipment
and means for communicating.
(See Section 5.4.5)
37. Develop a procedure to implement the transition from an emergency
classification to a recovery mode, including specific criteria upon which
the emergency classes will be downgraded and provisions for notifying
Federal, State and local of ficials prior to entering a recovery mode.
(See Section 5.4.6)
38. Develop a specific procedure for disseminating public information which
describes the information flow process and provides for the initial
period of time prior to the establishment of the Media Center and for
public inquiries separate from the news media.
(See Section 5.4.7)
39. Revise EPIP 4603 to include provisions to specify frequency of inventories
and operational checks of emergency equipment; responsibility for the
performance of emergency equipment inventories, operational checks, and
calibration; and change-out and replacement schedules for items having
limited shelf life.
(See Section 5.5.1)
40. Consolidate into one Emergency Plan Implementing Procedure all of the
requirements and responsibilities for drills and exercises.
(See
Section 5.5.2)
41. Revise the Technical Specifications to be consistent with the requirement
in 10 CFR 50.54(t) that an audit of the emergency preparedness program be
done at least every 12 months.
(See Section 5.5.4)
42. Develop a procedure to ensure that all letters of agreement with offsite
support agencies are reviewed and updated on an annual basis.
(See
Section 6.1)
43. Disseminate emergency planning information to the public including transient
populations within the plume exposure pathway Emergency Planning Zone.
(See Section 6.2)
44,
Revise the Emergency Plan to include, or make reference to, the media
education and familiarization program including a description of the
program and program responsibility.
(See Section 6.3)
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