ML20116K833
| ML20116K833 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 11/10/1992 |
| From: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NSD921204, NUDOCS 9211180043 | |
| Download: ML20116K833 (4) | |
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GENERAL OrHCE l
P O BOX 499. COLUMBL)S. NEBAASKA (M024490 l ' 4 Nebraska Public Power District
- K"xiel%#t" i erracmemesmesmrmatcmues=razzrarze=w=:rar:ma====ummm wserem+m9 NSD921204 November 10, 1992 U.S. Nucicar Regulatory Commission Attention:
Document Control Desk Vashington, DC 20555 Gentlemen:
Subject:
HPPD Response to Inspection Report 50 298/92-14 This letter is written in response to your letter dated October 15, 1992 tranremitting Inspection Report 50 298/92 14.
Therein you identified five (5) weaknesses in our e.nerr-ncy preparedness program observed during the 1992 The attachment to this letter contains a l
annual emergency exere i
description of our corrective rneasures for the weaknesses noted and our schedule for cornpleting these actions.
Pursuant to discussions between members of the NRC Region V staff and NPPD managernent or October 30, 1992, revisions to the Cooper.uclear Station (CNS)
Etnerc,ency Plan and affected Einer ency Plan Implementini, Procedures (EPIPs) will be implemented to provide for an alternate Operations Support Center (OSC) in the event personnel contamination prevents t'ne return of OSC teams to the primary OSC.
These revisions will be completed by March,1993.
Should you have any questions concerning this raatter, please contact me, Sinyrely,/
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Attachment to NSD921204 Novembei 10, 1992 Page 1 of 3 Statement of Weakness (298/911* 01)
The analysis and technical assessment of plant conditions was identified as a repeat exercise weakness first identified during the 1991 emergency
- exercise, finned Correg_tive Actio,n The Emergency Response Organization (ERvj will be upgraded such that as the event escalates beyond a Notification of Unusual Event (NOUE), the Plant Manager will relieve the Shif t Supervisor as the Emergency Director and function from the Technical Support Center (TSC).
If the event should escalate to a Site Area Emergency or General Emergency, the Site Manager will be-ome the Emergency Director and operate from the Emergency Operations Facility (EOF).
The Plant Manager will remain in the TSC to focus on the analysis and technical assessment of plant problems.
In the existing arrangement, the Emergency Director relocates from the Control Room to the TSC at the Alert classification and then to the EOF as the event escalates to the Site Area or General Emergency classifications. This process tends to cause the technical assessment resources to be focused cnly on the problems uhich are causing the event 4
to cocalate.
Conseq ently, other problem areas do not always receive an adequate level of analysis and technical assessment in a timely manner.
With the arrengement planned, the Plant Manager will stay focussed on the plant and necessary technical assessment activities, while the Site Manager will be abic to concentrate on off-site consequences and interfaces.
Additionally, EPIPs will be revised and position specific training will be conducted to provide detailed guidance for addressing accident management techniques. This ruidance will include techniques for problem recognition and communication, problem categorization, problem prioritization, resource allocation, CNS specific estimating techniques (similar to those in RTM 91), and trending of key parameters, as well as instructions for coping with the dynamic nature of accident management.
Sp1_edule of Implementation The ERO upgrade, EPIP revision, and position specific training will be completed by March 1993.
Statement of Weakness (298/9214-01)
Failure to take steps to ensure Technical Support Center / Operational Support Center continued habitability during a release was identified as an exercise weakness.
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/ %achment to NSD921204 Noveiribei 10, 1992 Page 2 of 3 J1guntad Corrective Actioj)
EPIP 5.7.7, " Activation of TSC", will be revised to relocate the Continueus Air Monit.or (CAM) unit closer to the TSC entrance and to activate liigh Efficiency Particulate Adsorber (llEPA) filters upon activation of the TSC.
EP1P 5.7./, " Activation of TSC", will also be revised to enoure the radiation shiciding doers are closed when radiation surveys indicate the noec.
Schedule of 1mnlerpentation EPIP 5.7.7, " Activation of TSC", will be revised and the CAM unit relocated by November 19??
l Statepent of Waknese (298/9214 02)
The failure to detect and classify general emergency conditions promptly was identified as an exercise weaknesa.
Planned Corrective Arl.1p.n The Diatrict will reviso guidance documents and conduct position specific training for " low threshold" coro darnage events.
The following specific actions will be taken:
EPIP 5.7.1, " Emergency Classification", Appendix 3 will be revised, and Emergency Action Lovel 2.3.1 clarified to add more degraded core symptoms'and indicators for the potential
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loss of the fission product barriers.
The cladding damage criterion will be_ clarified and NOTE 3, to section 8.6 in EPIP 5.7.17. " Dose Assessment", "For the purpose of this procedure, cladding failure below it is considered a non accident condition" will be removed.
The use of the "most conservative" dose model results will be stipulated in partinent proc..
es.
" Low threshold" core damage scenarios will be included in future training and drills.
jghedule of Implementation The procedure revisions will be completed by January 1993. The new material will be included in continuing emergency preparedness training L
' conducted thereafter.
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. Attachment to NSD921204 i
NovembeY 10, 1992 Page 3 of 3 yuttement of Venkness (298/9214 03)
The failure of the licensee.o approvo initial notification inessages properly to state and local goverinnent agenclos and the failure to coroplete the initial notification process in a tiinely manner was identified an an exercice weakness.
Planned Corrective Action EPIP 5,./.6,
" Notification", will be revised to allow Facility Directors te. sign -the initial notification forins with Ecargency Director verbal 4
approval and appropriate Emergency Director log entries.
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Performanco based training was developed and ituplernented f or-the off-site cominunicators. Re.nedial training on the new material, for all of the off sire cornmunicatois was completed October -29; 1962.
Eghedule of Irelementation R
-1 EPIP S.7.6, " Notification", will be revised by November 1992.
Ei;.alernent of Weakrican (298/9214 04)
)
The use of two dora assessment programs for decision making purposes l
without clear guidance on reconciling c< nflicting results was identified.
as an exercise weakness.
l Elanned Corrective Action
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EPIP 5.7.1, " Emergency Classification", and EP1P 5.7.17. "Dsse Assessment" will be revised to provide proc? dural guidance on the use of' both models,.and to act on the.ust conservativo model results, in.the:
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-- event of a release exceeding license limits.
Training reflecting this guidance will t<
- provided for ERO decision snakern and doso anso nment personnel.
l The Atmospheric Do'se Assessment Houel'(ADAM) source term code error will i-.
be corrected.
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Schedule of implementation A
- rocedural guidance, improved training, and ADAt source term code error:
arrection will ba comnleted by January 1993.
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