ML20091B267
| ML20091B267 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 03/30/1984 |
| From: | Williams J FLORIDA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20091B249 | List: |
| References | |
| L-84-88, NUDOCS 8405300231 | |
| Download: ML20091B267 (4) | |
Text
h P.O. 80 X 529100 Mi AMI, F L 33152 FLOHf DA POWER & LIGHT COMPANY Ik h,* th f
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March 30, 1984 L-84-88 Mr. Jmes P. O'Reilly Regional Administrator, Region 11 U. S. Nuclear Regulatory Commission 101 Marietta Street NW, Suite 2900 Atl anta, Georgi a 30303
Dear Mr. O'Reilly:
Re: Turkey Point Units 3 and 4 Docket Nos. 50-250, 50-251 Inspection Report 84-01
' Florida Power & Light Company has reviewed the subject inspection report and a response is attached.
Also included is a discussion of corrective actions which had previously been reviewed with your staff and ciarified in a telephone conversation on this d at e.
There is no proprietary information in the report.
Very truly yours, J. W. Willi ms, Jr.
Vice President Nuclear Energy JWW/PLP/js Att achment i
cc: Document Control Desk Harold F. Reis. Esquire PNS-LI-84-115 8405300231 840509 PDR ADOCK 05000250 0
ATTACIMENT RE: TURKEY POINT UNITS 3 AND 4 DOCKET NOS. 50-250, 50-251 IE INSPECTION REPORT 84-01 FINDING 1:
1.
10 CFR 50.54(q) requires thai, nuclear power reactor licensees follow and maintain in effect emergency plans which meet the requirements of Appendix E to 10 CFR Part 50 and the pl anning standards of 50.47(b).
Section IV.B of Appendix E requires that a licensee's energency plans shall include energency action levels based on in-plant conditions and instrumentation in addition to on-site and off-site monitoring.
Section (b) (10) of 10 CFR 50.47 requires that the licensee's energency plans shall include a range of protective actions, consistent with Federal Guidance, for the plume exposure pahtway EPZ for energency workers and the public.
The Federal guidance on protective actions to be recommended to off-site officials for general energencies is addressed in Appendix 1 of NUREG 0654/ FEMA-REP-1, Rev.1, entitled "Criteri a for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Pl ants." This guidance is clarified by IE Information Notice No. 83-28: " Criteria for Protective Action Recommendations for General Emergencies".
Contrary to the above, in the case where prompt protective action recommendations are warranted by plant conditions and small doses are projected for the site boundary due to present small releases, no protective actions are addressed by the implenenting procedures.
RESPONSE
1.
FPL concurs with the finding.
2.
The reason for the finding was the energnecy plan implenenting procedures (EPIP) did not specifically direct the energency coordinator to compare the protective action recommendation (PAR) guidelines based on dose projections with the PAR guidelines based on plant conditions prior to making the recommendation for protective action.
3.
Corrective actions which have been taken include:
a.
References have been added as appropriate in EPIP 20101 to instruct the energency coordinator to compare the PAR based on plant conditions to the PAR based on dose projections prior to making the reconnendation and to select the more conservative PAR.
b.
Training of Plaqt Supervisors - Nuclear on protective action reconnendations has been performed.
4.
In order to prevent recurrence of similar events:
1 a.
An augmented emergency plan training segment will be incor porated j
into the licensed operator requalification cycle.
J 5.
Full compliance was achieved by February 1,1984.
L
ATTACHNENT RE: TURKEY POINT UNITS 3 AND 4 DOCKET NOS. 50-250, 50-251 IE INSPECTION REPORT 84-01 FISING 2:
10 CFR 50.54 (q) requires that nuclear power reactor licensees follow and maintain in effect emergency plans which meet the planning standards of 50.47(b).
10 CFR 50.47 (b) (15) requires that those who may be called on to asist in an emergency be provided radiological emergency response training.
Sections 5.2.1 and 5.2.3 of the Turkey Point Emergency P1 anstates, in part, that recommendations for protective actions will be made by the Emergency Coordi n ator. Section 2.2.2.1 states in part that after declaring an energency the Plant Supervisor - Nuclear becomes the Emergency Coordinator.
Section 7.2.2.1 of the Turkey Point Emergency Plan states that Emergency Coordinators will be trained in dose assessments. Section 5.2 of EPIP 20126 states that the Emergency Coordinator may call a Chemistry Department representative to perform dose assessments.
Contrary to the above, Plant Supervisors - Nuclear interviewed during the inspection were not adequately trained in that they were unf aniliar with the Emergency Plan Implementing Procedures to the extent that incorrect protective action recommendation decisions were made for a range of situations and corresponding action levels. Additionally, the P1 ant Supervisors - Nuclear, initially the Emergency Coordinators, are not trained to perfonn dose calculations and were generally unfaniliar with the procedure. Also, individuals selected by the Plant Supervisor - Nuclear, on other than the day shift, to perfonn the dose calculations (one HP and one Chemistry Department staff) were unf aniliar with the procedures and unable to perfonn the required cal cul ati ons.
RESPONSE
1.
FPL concurs with the finding with the following exception:
a.
Emergency plan implementing procedures (EPIP) do not specify any dose calculation responsibilities for Health Physics and, therefore, there is no requirement for health physics personnel to be f aniliar with dose calculation procedures or able to perfonn i.he c alcul ations.
2.
The reasons for the finding were:
a.
The dose calculation training of the chemistry technicians emphasized dose calculation using the primary method with the computer instead of the backup method of hand calculations.
b.
The hand dose calculation training for the Plant Supervisors -
j Nuclear was 'not sufficient to instill a high confidence level.
c.
EPIPs 20101, 20103, and 20126 are not structured for optimum work ability.
)
-O ATTACIMENT RE: TURKEY POINT UNITS 3 AND 4 DOCKET NOS. 50-250, 50-251 IE ~ INSPECTION REPORT 84-01 3.
As corrective action, the following actions have been taken:
a.
Radiochemistry has been formally given the responsibility for performing dose calculations and the Plant Supervisors - Nuclear have been informed to contact Radiochemistry whenever dose calculations are required.
b.
Chemistry technicians have been retrained in the hand calculation method of making dose assessments.
4.
In order to prevent recurrence:
a.
EPIPs 20101, 20103, and 20126 are being reviewed aad will be revised to improve workability.
b.
An augmented emergency plan segment (including dose calculations and protective action recommendations) will be incorporated into the licensed operator requalification training cycle, c.
Chemistry technicians will receive training in dose calculations.
d.
Appropriate dose calculation procedures will be revised to specify that Radiochemistry has responsibility for dose calculations.
5.
Full compli ance will be achieved by May 17, 1984.
~
CLARIFICATION TO ITEN 7. " CORRECTIVE ACTION" By February 3,1984, eight of twelve chemistry technicians were trained in Emergency Pl an Implementing Procedure (EPIP) 20126. The remainder were trained by March 30, 1984. All Nuclear Plant Supervisors received training in EPIP 20101 and 20103.
Watch Engineers will receive this training by May 17,1984.
L