ML20055A653

Forwards IE Emergency Preparedness Appraisal Repts 50-315/82-05 & 50-316/82-05 on 820315-26,notice of Violation,Significant Appraisal Deficiencies,Appraisal Improvement Items,Evaluation Rept & Preparedness Open Items

ML20055A653
Person / Time
Site:	Cook
Issue date:	06/30/1982
From:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Dolan J AMERICAN ELECTRIC POWER SERVICE CORP., INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
Shared Package
ML20055A654	List: IR 05000315/1982005 ML20055A653 ML20055A655
References
NUDOCS 8207190290
Download: ML20055A653 (4)

See also: IR 05000315/1982005

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Docket No. 50-315

Docket No. 50-316

American Electric Power Service

Corporation

Indiana and Michigan Electric Company

ATTN: Mr. John E. Dolan

Vice Chairman, Engineering

2 Broadway

New York, NY 10004

Gentlemen:

Subject: Emergency Preparedness Appraisal

To verify that licensees have attained an adequate state of onsite

emergency preparedness, the Office of Inspection and Enforcement is con-

ducting special appraisals of the emergency preparedness programs at all

operating nuclear power reactors. The objectives of these appraisals are

to evaluate the overall adequacy and effectiveness of emergency 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. .

During the period of March 15-26, 1982, the NRC conducted a special, appraisal

of the emergency preparedness program at the Donald C. Cook Nuclear Plant.

This appraisal was performed in lieu of certain routine inspections normally

conducted in the area of emergency preparedness. Areas examined during this

appraisal are discussed in the enclosed reports (50-315/82-05 and 50-316/

82-05). Within these areas, the appraisal team reviewed selected procedures

and representative records, inspected emergency facilities and equipment,

observed work practices, and interviewed personnel. In addition to the

above, a special management meeting was conducted at the site on May 4,

1982, with Mr. Hunter of your staff to discuss the significant deficiencies

identified relevant to the interim Emergency Operations Facility (EOF).

During the appraisal certain of your activities appeared to be in noncom-

pliance with NRC requirements, as described in the enclosed Notice of

Violation. The item in the enclosed Notice of Violation (Appendix A) is

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American Electric Power Service 2

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classified as a Severity Level III since the interim EOF, a system designed

to prevent or mitigate a serious safety event, would be unable to perform

its intended function when needed (e.g., any Site Area or General Emergency).

This letter is being issued now to ensure prompt corrective actions and

subsequent enforcement action from this office will be forthcoming. We

find there are several aggravating circumstances surrounding this non-

compliance. Emergency Plan, Revision 0, January 1981, has misrepresented

the facts relevant to the state of preparedness of your " operational" EOF

and appears to be another case of less than candid representations to the

NRC staff. Secondly, you were in noncompliance from April 1, 1981, until

about mid May 1982, in spite of the fact that in a letter dated April 16,

1981, you recognized the need for an offsite EOF. Finally, after this

matter was brought to the attention of the Plant Manager at the conclusion

of the appraisal on March 31, 1982, and in a subsequent telephone call on

April 2, 1982, between Mr. Robert Hunter of your staff and Dr. Carl Paperiello

of the Region III Office, no action was initiated by you to take corrective

action. Only after an enforcement meeting between Mr. Hunter and me on May 4,

1982, was action initiated.

The findings of this appraisal also indicated that several significant defi-

ciencies exist in you emergency preparedness program. These are discussed

in Appendix B, "Significant Appraisal Deficiencies" and in summary include:

. Inadequate Accident Assessment Capability

. Inadequate Protective Response For Onsite Emergency Personnel

. Inadequate Radiological Exposure Control for Onsite Emergency Personnel

. Inadequate Emergency Action / Classification System

The findings of this appraisal indicate that there are areas for improvement

in your emergency preparedness program. These are discussed in Appendix C,

" Appraisal Improvement Items."

In conjunction with the aforementioned appraisal, emergency plans for your

facility were reviewed. The results of this review indicate that several

significant auficiencies exist in your Emergency Plan. These are discussed

in Appendix D, " Emergency Preparedness Evaluation Report."

Several areas in your emergency preparedness program were not complete at

the time of this appraisal and therefore were not examined. These items

are identified as Open Items and are listed in the enclosed Appendix E.

These will be examined by our staff upon complete implementation of the

area involved.

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Each significant deficiency identified in Appendix B is related to a i

standard of 10 CFR 50.47(b) of the Commission regulations. The l

deficiencies and noncompliance identified in Appendix A and B lead the i

NRC staff to the conclusion, under 10 CFR 50.54(s)(2) of the Commisrion

regulations, that the onsite state of emergency preparedness does not

provide reasonable assurance that appropriate protective measures for

the public can and will be taken in the event of a radiological emergency.

Pursuant to 10 CFR 50.54(f) you are requested to submit a written statement

upon completion of the planned actions described in your May 21, 1982, letter

from Mr. G. Smith, Plant Manager to J. Keppler, NRC, for improving each of

the items identified in Appendix B. With regard to Appendix A (Notice of

Violation), actions shall be taken as outlined in that appendix pursuant to

the provisions of 10 CFR 2.201.

This is to inform you that should the deficiencies addressed in Appendix B

and the noncompliance item identified in Appendix A not be corrected within

the commitments stated in your letter dated May 21, 1982, the Commission will

determine whether the reactors shall be shut down until such deficiencies are

remedied or whether other enforcement action is appropriate.

We are particularly concerned that during the Exit Interview of the

Emergency Preparedness Appraisal, your management would not make acceptable

commitments to the NRC staff to resolve these significant deficiencies.

This management practice has not been generally observed throughout the

nuclear industry and will be reflected in our SALP review of your management -

attitude and willingness to cooperate with the NRC.

In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of

this letter, the enclosures, and your response to this letter will be placed

in the NRC's Public Document Room. If this report contains any information

that you (or your contractors) believe to be exempt from disclosure under

10 CFR 9.5(a)(4), it is necessary that you (a) notify this office by tele-

phone within ten (10) days from the date of this letter of your intention

to file a request for withholding; and (b) submit within twenty-five (25)

days from the date of this letter a written application to this office i

to withhold such information. If your receipt of this letter has been

delayed such that less than seven (7) days are available for your review,

please notify this office pr7motly so that a new due date may be estab-

lished. Consistent with Sec cion 2.790 (b) (1), any such application must

be accompanied by an affidavit executed by the owner of the information

which identifies the document or part sought to be withheld, and which

contains a full statement of the reasons which are the bases for the claim

that the information should be withheld from public disclosure. This section

further requires the statement to address with specificity the considerations

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American Electric Power Service 4

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listed in 10 CFR 2.790(b)(4). The information sought to be withheld shall be j

incorporated.as far as possible into a separate part of the affidavit. If we

do not hear from you in this regard within the specified periods noted abov,e,

a copy of this letter, the enclosures, and your response to this letter will

be placed in the Public Document Room.

The responses directed by this letter (and the accompanying Notice) 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).

We will gladly discuss any questions you have concerning this inspection.

Sincerely, ,

James G. Keppler

Regional Administrator

Enclosures:

1. Appendix A, Notice of

Violation

l 2. Appendix B, Significant

l Appraisal Deficiencies

l 3. Appendix C, Appraisal

Improvement Items

l 4. Appendix D, Emergency Preparedness

Evaluation Report

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5. Appendix E, Open Items

cc w/encls:

W. G. Smith, Jr, Plaat Manager

DMB/ Document Control Desk (RIDS)

Resident Inspector, RIII

Ronald Callen, Michigan

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