ML20076G550

Submits Followup Response to 16 of 19 Open Items Identified in NRC Re IE Emergency Preparedness Appraisal Rept 50-298/82-34 on 821206-10

ML20076G550
Person / Time
Site:	Cooper
Issue date:	05/13/1983
From:	Pilant J NEBRASKA PUBLIC POWER DISTRICT
To:	Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
RTR-NUREG-0654, RTR-NUREG-0737, RTR-NUREG-654, RTR-NUREG-737 50-298-82-34, NUDOCS 8306140716
Download: ML20076G550 (9)

Text

_ _ _ _

o F* GENERAL OFFICE

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Eh Nebraska Public Power District E#0###f"*E*"""*"

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May 13,1983 '

R@ RMRJ Mr. G. L. hladsen, Chief Reactor Proj,ect Brarch 1 MAY l 91983 U. S. Nuclear Regulatory Commission s i g Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011

Subject:

Emergency Preparedness Appraisal Follow-Up Response This letter responds to all open Appendix A and Appendix B items identified in your letter of February 17, 1983, which referred to the Emergency Preparedness Appraisal Follow-Up conducted during the period December 6-10, 1982, at Cooper Nuclear Station. Although the inspection summary in the Appendix to your letter indicates 19 open items are to be addressed,16 open items are actually identified in paragraphs 2 and 3 of the Details section of the report. Our response addresses those 16 open items.

1. Appendix A Items Specific Finding: 298/8113-46 Pursuant to the requirements of 10 CFR 50.47(a)(2), correct the CNS emergency procedure in Volume 5 of the CNS Operations Manual to enable the reactor operations personnel to effectively move through the emergency procedures and into the EPIPs.

Response

The District had deferred updating of the CNS Emergency Procedures (EOPs) until such time as the BWR Owner's Group (BWROG) completed development of comprehensive Emergency Procedure Guidelines (EPGs).

Ilowever, the amount of time involved in BWROG development of the EPGs and NRC review and approval of the EPGs has been more extensive than anticipated. Additionally, NPPD development of updated EOPs from the approved EPGs will probably not be completed until mid-1984. As a result , the decision was made to revise the existing EOPs to meet the intent of this finding. All CNS EOPs are being revised to enable reactor operations personnel to effectively move through the emergency procedures and into the CNS EPIPs. The Shift Supervisor and other operations personnel will be led, by direct reference, from the EOPs into f the pertinent EPIP. The appropriate revisions to the EOPs will be completed by August 1,1983. fy 8306140716 830513 PDR ADOCK 05000298 G PDR )O

. "Mr. G. L. Mads::n Page 2 N,ay 13, 1983 Specific Finding: 298/8113-48 Pursuant to the requirements of 10 CFR 50.47(b)(4) and 10 CFR Part 50, Appendix E(IV)(B), assure that the Emergency Operating Procedures are expanded to include the initiating conditions and EALs in NUREG-0654, Revision 1 Appendix 1, and lead the station operators into the appropriate section of the CNS EPIP.

Response

See the . response to Finding 298/8113-46 above.

Specific Finding: 298/8113-49 Pursuant to the requirements of 10 CFR 50.47(b)(9) and 10 CFR Part 50, Appendix E(V), correct procedures to ensure that all appropriate and applicable emergency actions are defined and properly referenced in the CNS Emergency Operations Procedures and EPIPs.

Response

See the response to Finding 298/8113-46 above.

Specific Finding: 298/8113-74 Pursuant to the requirements of 10 CFR Part 50, Appendix E(IV)(C),

develop and implement methods to lead, by direct reference, the shift supervisor to the applicable section of the EPIPs.

Response

See the response to Finding 298/8113-46 above.

2. Appendix B Items Specific Finding: 298/8113-07 Pursuant to the requirements of 10 CFR 50.47(b)(15) and 10 CFR Part 50, Appendix E(IV)(F), and the guidance contained in NUREG-0654, Revision 1, items 0.1 through 5, develop a program for training individuals who are assigned emergency action responsibilities which will enable them to attain and maintain a state-of-the-art knowledge in the field of their assigned emergency action areas.

Response

On January 26, 1983, a new CNS Emergency Plan Training Program was implemented. This stiuctured training program includes classroom instruction, formal lesson plans , visual aids, and classroom demonstrations as well as student performance objectives. tStudent performance is evaluated by means of approved, comprehensive testing covering each lesson. A minimum score oft 70% on each" applicable lesson N is required of each strainee. i Remedialc training and ' retesting are )

provided for in the ' program.' To^ att'ain-" arid maintain ~ student state-of-the-art knowledge, lesson plans are updated to reflect revisions to the CNS Emergency Plan and EPIPs.

. "Mr. G. L. Madssn Page 3

- M,ay 13, 1983 Specific Finding: 298/8113-14 Pursuant to the requirements of 10 CFR 50.47(b)(15) and 10 CFR Part 50, Appendix E(IV)(F), establish a formal radiological emergency response training program to provide specialized training and annual. retraining for each of the functional areas of the emergency organization. The program shall include classroom instructions and practical demonstration drills, walkthroughs, formal lesson plans (LPs),

and means of evaluating student performance objectives; i.e., written tests or evaluations of performance in drills and walkthroughs. LPs shall include student performance objectives. Training for individuals assigned to first aid functions shall include courses equivalent to Red Cross Multi-Media.

Response

a The response to Finding 298/8113-07 above discusses the salient points of the new CNS Emergency Plan Training Program which was implemented in January,1983. This training program and Revision 1 to the CNS Emergency Plan (dated March 15, 1983) provide for annual retraining of station personnel. CNS personnel receive first aid and cardiopulmonary resuscitation (CPR) training under the purview of the NPPD Safety Department.

Specific Finding: 298/8113-16 Pursuant to the requirements of 10 CFR 50.47(b)(15) and 10 CFR Part 50, Appendix E(IV)(F), and the guidance contained in NUREG-0654, Revision 1, items 0.1 through 5, upgrade the training program with the development of formal LPs, dedicated time for classroom training, and appropriate numbers and kinds of drills to ensure that individuals assigned functional responsibilities during an emergency attain consistent levels of knowledge and abilitics within their assigned functional area, and that levels of knowledge and abilities among all functional areas will provide for effective implementation of all functional tasks.

Response

The response to Finding 298/8113-07 above discusses the salient points of the CNS Emergency Plan Training Program which was implemented in January 1983. This training program and Revision 1 to the CNS Emergency Plan (dated March 15, 1983) set forth the specific training requirements for individuals from each functional area of the station organization. Formal classroom training is conducted and graded tests are administered to evaluate individual student performance. Trained observers evaluate emergency preparedness drills to determine that levels of knowledge and abilities in the various functional areas will ,

provide for effective Emergency Plan implementation.

Specific Finding: 298/8113-17 Pursuant to the requirements of 10 CFR 50.47(b)(8) and the guidance  ;

contained in NUREG-0654, Revision 1, Annex 1 to Appendix 2, pages 2-9, paragraph 5(c), provide meteorological data readouts in the control room to the extent necessary for onsite and offsite dose assessment and projection.

. 'Mr. G. L. M:dsen Paga 4 M,ay 13,1983

Response

The availability of meteorological information in the Control Room is being incorporated into the Plant Management Information System. Reference letter dated April 15, 1983, from J. M. Pilant to D. G. Eisenhut, Response to NUREG-0737, Supplement 1, Attachment No. 6.

Specific Finding: 298/8113-24 Pursuant to the requirements of 10 CFR 50.47(8)(8), the guidance contained in NUREG-0696, and the generic letter from D. G. Eisenhut, NRC, to all licensees dated February 18, 1981, assures that the TSC meets the habitability requirements by the required dates.

Response

As indicated in Figure 7.2-1 of the CNS Emergency Plan, a portion of the TSC is in the Control Room. Therefore the habitability of this portion of the TSC is identical to that of the Control Room. The portion of the TSC outside of the Control Room is provided with radiological protection and monitoring equipment to protect personnel under most conditions, the exception being core degradation and leakage to the area above the refueling floor. In the unlikely event that this type of accident were to occur at CNS, TSC personnel would relocate to the Control Room, the OSC's, and/or the EOF as defined in the CNS Emergency Plan Implementing Procedures (EPIP's).

To ensure adequate radiological protection of TSC personnel, a radiation monitoring system is provided in the TSC. This system consists of monitoring equipment dedicated to the TSC, capable of continuous indication of dose rates and airborne radioactivity concentrations. Local alarms provide early warning to TSC personnel.

The TSC ventilation system is comparable to the Control Room ventilation system. Although not seismically qualified, redundant, or automatically activated, it does include high efficiency particulate air filters and charcoal filters. System capacity is based on design basie accident airborne radioactivity levels, independent of thyroid blocking provisions (potassium iodide).

Specific Finding: 298/8113-27 Pursuant to the requirements of 10 CFR 50.47(b)(7) and the guidance contained in NUREG-0654, Revision 1, item H.9, provide sufficient working space in the emergency facilities to accommodate the state, local, and federal response personnel.

Response

The new Emergency Operations Facility (EOF) has been sized to provide sufficient space for the state, local, and federal emergency response personnel to perform their duties. (See Figure 7.2-2 of the CNS Emergency Plan.) The District recently utilized the new EOF during the annual Emergency Exercise conducted on April 6,1983.

'Mr. G. L. Mrdsen P:ga 5 May 13, 1983 Specific Finding: 298/8113-29 Pursuant to the requirements of 10 CFR 50.47(b)(9) and NUREG-0737, TAP III. A.2, implement a meteorological measurements program with a primary system and a backup system which has the following provision:

Resolution of siting and exposure deficiencies of the systems relative to the site characteristics and facilities in place to be consistent with " good engineering practice" as outlined in Regulator Guide 1.23, proposed Revision 1.

Response

The location of the new meteorological towers are as follows:

o Primary Tower (100 Meters) - 1230.00' from NW corner of Reactor Building at a polar bearing of 309.45o. The base elevation is 888.98' MSL.

o Backup Tower (10 Meters) - 1600.00' from NW corner of Reactor Building at a polar bearing of 348.39 . The base elevation is 889.43' MSL.

The levels of measurement and the parameters measured are listed below.

Tower Level (Meters Parameter (s)

Primary 100 Wind Speed l Wind Direction l Temperature Primary 60 Wind Speed Wind Df.rection Temperature Primary 10 Wind Speed Wind Direction Temperature '

Dew Point Backup 10 Wind Speed -

Wind Direction Temperature Precipitation The sensor instrumentation for the meteorological monitoring system was purchased from Climatronics. The signal conditioners are installed in the instrument rack in the shelters located at the base of each tower.

The instrument specifications for each parameter are listed in Table 1.

The system accuracy is . shown in Table 2. System frequency of operability checks are done once during each -shift. Calibrations of the meteorological sensors and recorders are done on a quarterly basis while the translator cards are calibrated weekly. Maintenance of the meteorological sensing instrumentation, translator cards, and recorders is dor.e by the CNS Instrument & Control Department. The communications equipment is maintained by the York Operations Center (YOC) communications department.

Mr. G. L. Madsen P:ga 6 May 13,1983 The computer hardware is maintained via a service contract with Digital Equipment Corporation with offices in Omaha, Nebraska.

Reference letter dated April 15, 1983, from J. M. Pilant to D. G. Eisenhut, Response to NUREG-0737, Supplement I, Attachment No. 6.

TAB 12 1 Instrument Specifications Climatronics Wind Wind Dew Speed Direction Temperature AT Point Precipitation Accuracy 10.15 mph or 1% 13' *0.2C 5% not to 10.5C i1% up to exceed 0.17' 3"/hr Threshold 0.5 mph 0.5 mph - - - -

Range 0-100 mph 0-540' - - - -

Distant Constant 5 ft Max 3.7 f t Max - - - -

DImping Ratio -

0.4 - - - -

Trsperatute Range -40'C to -40'C to -34*C to -10*C to -40'C to -

+60'C +60*C +50'C +10*C +42'C Response Time - -

10 sec 10 see IC/ min -

to 63% to 63%

Linearity - -

• 0.2'C - - -

Size - - 1/4" x 4" long - -

Diameter 8" Height 24"-

Risolution - - - - -

0.01" Conversion Accuracy - - - - -

10.2%

TABLE 2 SYSTEM ACCURACY Parameter Digital Analog Total Met + Card + CPI + Recorder Wind Speed < 25 mph 10.25 mph 10.125 mph *0.025 mph 10.125 mph = *0.4175 mph Wind Direction i3.0* *0.27* 10.135' *2.76 = *6.105 degrees azimuth Temperature 10.2*C *0.0125'c 10.0125'C *0.25'c = *0.4750'C Dew Point 10.5'C 10.021*C *0.0105'C- 10.147'C = 10.6785'C Prscipitation *1.0% 10.05% 10.00125% *0.35% = *1.40125%

l AT = calculated sigma theta = calculated l

Mr. G. L. Mads:n Page 7

, May 13,1983 Specific Finding: 298/8113-40 Pursuant to the requirements of 10 CFR 50, Appendix E(IV)(B) and (H), identify the means to be used for determining the magnitude and for continually assessing the impact of the release of radioactive materials. These means shall include dose projection using real-time meteorological information.

Response

The annual Cooper Nuclear Station Emergency Exercise was conducted April 6, 1983. During this exercise, . NRC dose assessment personnel conducted independent dose assessment activities. The whole body gamma (dose rates and integrated doses) and the thyroid inhalation (dose rates and dose commitments) computations conducted by NRC personnel correlated very well with the computations conducted by NPPD personnel. Projected dose calculations were completed by NPPD personnel in a timely and efficient manner, thus providing a basis for decision-making concerning recommendations of appropriate protective actions to offsite authorities. Appropriate protective actions were recommended, with NRC concurrence, in a timely manner.

Effluents emitted from the Elevated Release Point under fumigation conditions will be dispersed - towards the ground, resulting in high ground level concentrations. Therefore, ground level X/Q dispersion factors will be used to estimate population doses when effluents are discharged from the Elevated Release Point during fumigation conditions.

Because it is very difficult to predict the first point at which the plume contacts the ground, it will be assumed that the plume first contacts the ground at the base of the ERP. This method will overpredict ground level concentrations at distances very close to the ERP. However, for the purpose of estimating offsite population doses this method will provide realistic results.

The hand-calculation technique will be modified to calculate concentrations from ground-level type releases for each stability category.

The backup procedure will be modified to couple the 97m wind speed with elevated releases. For ground level releases the backup procedure uses the 10m wind speed.

Ground level X/Q dispersion factors will be used to estimate population doses when effluents are discharged from the Elevated Release Point during fumigation conditions . For further discussion refer to the first paragraph of this response.-

The values for the. primary stability indicator - the temperature difference between the 97m and 10m levels were derived directly from the Pasquill Stability Categories contained in Atomic Energy 1968. These values were adjusted to account for a 97m - 10m difference (A 87m) vs a a 100m difference.to specifically avoid skewing the stability distributions in either direction.

Mr. G. L. M dsen P gs 8

, .May 13,1983 The initial dose assessment by control room operators specifically refers the operator to Section B.3 of EPIP 5.7.17 (see C.5) . Section B.3 details the method for determining the atmospheric stability category using the differential temperature recorder and the primary stability indicator - the temperature difference between the 97m and 10m level.

For stability category determinations, this is the method of choice. The method of last resort for determining stability categories involves using incoming solar radiation and cloud cover information. This information is obtained through visual observations (see Attachment "D" of EPIP 5.7.17). Once the stability category is determined in accordance with the method of choice (Section B.3) it is not necessary to obtdn incoming solar radiation and cloud cover information.

The appropriate revisions to EPIP 5.7.17 will be completed by August 1, 1983.

Specific Finding: 298/8113-41 Pursuant to the requirements of 10 CFR 50.47(b)(9) and 10 CFR Part 50, Appendix E(IV)(B) and (E), develop a dose calculation and assessment capability that includes a treatment of meteorological factors, source characteristics, and building configuration to provide realistic transport and diffusion estimates for including in the dose calculational methodology. This capability shall be outlined in a technical bases document discussing the entire dose calculation scheme.

Response

See the response to Finding 298/8113-40 above.

Specific Finding: 298/8113-69 Pursuant to the requirements of 10 CFR 50.47(b)(15) 10 CFR Part 50, Appendix E(IV)(F), and the guidance contained in NUREG-0654, i Revision 1, items 0.1-5, evaluate the status of training of offsite response personnel, develop a listing and course description of the types of training the licensee could provide for offsite response personnel, and offer initial training and annual retraining classes (in addition to the training received by participation in exercises and drills) to all offsite response organizations.

Response

Section 8.1.1.C and Figure 8.1-1 of Revision 1 to the CNS Emergency Plan '(dated March 15, 1983) set forth the types of training which are provided to offsite response personnel. Initial training and annual retraining (in addition to the training received by participation in exercises and drills) are required for offsite medical support personnel and members of supporting volunteer fire departments. Radiological orientation training is offered to supporting sheriffs and civil defense directors.

l

. Mr. G. L. Mrds:n Pega 9

. May 13, 1983 Specific Finding: 298/8113-107 j Development of QA procedures to evaluate the effectiveness of the emergency action training for the various functional areas.

i

Response

The CNS Emergency Plan Training Program was implemented in January, 1983. QA Procedure 1900 has been subsequently revised to provide for

evaluation of the effectiveness of the CNS Emergency Plan Training Program.

Specific Finding: 298/8113-119 Development of a QA procedure that provides for the criteria in NUREG-0654, Revision 1, item P.5, including a review of all EP training.

Response

The CNS Emergency Plan Training Program was implemented in January, 1983. QA Procedure 1900 has been subsequently revised to provide for a review of the effectiveness of the CNS Emergency Plan Training Program. The procedure consists of a review of EP classroom training records, exercise records, and drill records. Also included is QA observation of drills and exercises. The procedure is augmented, as necessary, with spot checks by QA personnel in plant functional areas to evaluate EP training effectiveness.

Should you have any questions concerning this response, please contact me.

1 Sincerely, A

// . M. Pflant - 7 .W& M Division Manager '

of Licensing and Quality Assurance JMP/ daw:sm13/5 i

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