ML20151L866

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Forwards Emergency Preparedness Implementation Appraisal Rept 50-461/85-39 on 851112-21.No Significant Deficiencies, Deviations or Violations Noted.Lists of Open Items & Improvement Items Encl
ML20151L866
Person / Time
Site: Clinton Constellation icon.png
Issue date: 12/20/1985
From: Shafer W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Gerstner W
ILLINOIS POWER CO.
Shared Package
ML20151L872 List:
References
NUDOCS 8601020412
Download: ML20151L866 (13)
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See also: IR 05000461/1985039

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DEC 2 0 1985

Docket No. 50-461

Illinois Power Company

ATTN: Mr. W. C. Gerstner

Executive Vice President

500 South 27th Street

Decatur, IL 62525

Gentlemen:

SUBJECT: EMERGENCY PREPAREDNESS IMPLEMENTATION APPRAISAL

To verify that applicants have attained an adequate state of onsite emergency

preparedness as required by 10 CFR 50.47(a)(1), the NRC conducts special

preoperational appraisals of their emergency preparedness program. The

objectives of the appraisal are to evaluate the overall adequacy and

effectiveness of emergency preparedness and to identify areas of weakness

that need to be strengthened.

During the period November 12-21, 1985, the NRC conducted a special appraisal

of the state of onsite emergency preparedness at the Clinton Nuclear Power

Station, Unit 1, authorized by NRC Construction Permit No. CPPR-137. Areas

examined during this appraisal are described in the enclosed report

(50-461/85039). Within these areas, the appraisal team reviewed selected

procedures and representative records, inspected emergency facilities and

equipment, observed work practices, and interviewed personnel.

No significant deficiencies, deviations, or violations were identified as a

result of this appraisal.

The findings of this appraisal indicated that a number of areas of your

emergency preparedness program were not complete at the time of this appraisal.

These areas included, among others, installation and calibration of certain

equipment, related procedural development and training, procedure updates, and

demonstration of shift augmentation and assembly / accountability. These items

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

The findings also indicate that there are several items in your emergency

preparedness program which need improvement, and these items are listed in the

enclosed Appendix B. These improvements are areas which we believe, based on

professional judgement, should be corrected.

You are requested to submit a written statement within thirty days of the date

of this letter, describing your planned actions for completing each of the

items identified in Appendix A and the results of your consideration of each

of the items in Appendix B. All of the Open Items must be completed prior to

licensing.

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Illinois Power Company 2 l

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

this letter, the enclosures, and your responses to this letter will be placed I

in the NRC Public Document Room. [

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The responses directed by this letter are not subject to the clearance  !

procedures of the Office of Management and Budget as required by the l

Paperwork Reduction Act of 1980, PL 96-511. L

We will gladly discuss any questions you have concerning this appraisal, f

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Sincerely, l

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" Original tir d by U.D. C.dar" l

W. D. Shafer, Chief

Emergency Preparedness and  :

Radiological Protection Branch (

Enclosures:  !

1. Appendix A, Appraisal  !

Open Items l

2. Appendix B, Appraisal

Improvement Items

3. Inspection Report

No. 50-461/85039(DRSS)

cc w/ enclosures: f

DCS/R$B (RIOS)  !

Resident Inspector, RIII i

Richard Hubbard  !

Gary N. Wright, Manager (

Nuclear Facility Safety i

Jean Foy, Prairie Alliance [

Allen Samelson, Assistant -

Attorney General,  ;

Environmental Control Division  !

H. S. Taylor, Quality Assurance  ;

Division i

D. Matthews, OIE, EPB l

W. Weaver, FEMA, RV j

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Appendix A -

Open Items

The following is a list of Open Items identified in the area of emergency-

preparedness which must be completed prior to fuel load.

1. An actual drill demonstrating the capability to implement staff

augmentation in accordance with the CPS Emergency Plan must be performed

prior to fuel load. (Section 2.2) (461/85039-01)

2. All primary and alternate personnel must be trained in their emergency

functions prior to fuel load. (Section 2.2) (461/85039-02)

3. The Emergency Plan and/or EPIPs must address relocating the TSC and OSC

if they become uninhabitable. This must be completed prior to fuel

load. (Sections 4.1.1.2 and 4.1.1.3) (461/85039-03)

4. Installation of the telephones planned for the TSC's NRC Consultation

Room must be completed prior to fuel load. (Section 4.1.1.2)

(461/85039-04)

5. Develop and maintain an official controlled inventory list for the supply

cabinet in the TSC containing administrative and support material;

including a provision for periodic inwmterics. This must be completed

prior to fuel load. (Section 4.1.1.2) (461/85039-05)

6. The Area Radiation Monitoring / Process Radiation Monitoring (ARM /PRM)

system and the Performance Monitoring System / Display (PMS/ DES) system

(data acquisition *ystems) must be operable in the TSC and EOF, and

operators trained in its use prior to fuel load. (Sections 4.1.1.2 and

4.1.1.4) (461/85039-06)

7. Revise EPIP FE-02, Operations Support Center Operations, to reflect the

correct location of the OSC prior to fuel-load. (Section 4.1.1.3)

(461/85039-07)

8. Establish and maintain operability of telephone systems in the OSC prior

to fuel load. (Section 4.1.1.3) (461/85039-08)

9. Develop and maintain an official controlled inventory list for the EOF

cabinet containing administrative and miscellaneous supplies, including a

provision for periodic inventories, prior to fuel load. (Section 4.1.1.4)

(461/85039-09)

10. Equipment (sample containers, shielding, handling, and transport equipment)

needed to enable sampling at existing grab sample ports for the HVAC vent

and SGTF offgas system must be developed and tested prior to fuel load.

(Section 4.1.1.7) (461/85039-10)

11. Accessibility to and from the HVAC vent and SGTF offgas system sample

ports, while using all necessary equipment, must be verified prior to

fuel load. (Section 4.1.1.7) (461/85039-11)

12. Procedure CPS 1890.36 must be completed and approved prior to fuel load.

(Section4.1.1.7) (461/85039-12)

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Appendix A 2

13. Complete the installation of the Germanium Detector and make necessary

repairs to the Phoswich System located in the. EOF Environmental Sample

Analysis Laboratory. This equipment must be operational prior to fuel

load. (Section 4.1.1.8) (461/85039-13)

14. Training lesson plans, for both Emergency Response and nonessential

personnel, must be change to reflect actual assembly and reassembly

areas and evacuation routes r.c. all plant personnel retrained. This

must be completed prior te iuet load. (Section 4.1.2.1) (461/85039-14)

15. The assembly and reassembly areau and evacuation routes must be identified

and quipped with appropriate communication and protective equipment,

including provisions for decontamination. This must be completed prior

to fuel load. (Section 4.1.2.1) (461/85039-15)

16. Provide extremity dosimetry for the OSC and hospital kits prior to fuel

load. (Section 4.2.1.1) (461/85039-16)

17. Confirm that the operational meteorological measurements programs meet

the system accuracy specifications stated in ANSI /ANS 2.5-1984 and

Regulatory Guide 1.97 for wind speed, wind direction and vertical

temperature difference. This must be completed prior to fuel load.

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(Section 4.2.1.4) (461/85039-17)

. 18. Confirm that meteorological data availability goals can be achieved during

. plant operation prior to fuel load. (Section 4.2.1.4) (461/85039-18)

19. Demonstrate that meteorological data from the NWS station at Springfield

adequately represents the Clinton site in real-time for use as backup

information. (Installation of onsite backup or redundant sensors at the

10-meter level would be an adequate alternative to the use of Springfield

j, data). This must be completed prior to fuel load. (Section 4.2.1.4)

(461/85039-19)

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20. Incorporate the specific methodology and responsibility for acquisition

j of NWS forecast inforr.ation and integration of this information into

protective action recommendations and dose assessment prior to fuel load.

.! (Section 4.2.1.4) (461/85039-20)

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i 21. Correct inaccurate and incomplete references to meteorological information

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(i.e., determination of atmospheric stability) from EPIP RA-01, Manual

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Dose Assessment, and identify averaging periods that are to be used in

i the calculations. This must be completed prior to fuel load.

i (Section 4.2.1.4) (461/85039-21)

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l 22. Protectivc clothing supplies now stored in the Unit II Crossover Room

i must be placed in designated areas of the plant in accordance with

! Emergency Plan, Chapter 3.2.10.1 and Table 3-8 prior to fuel load.

j (Section 4.2.2) (461/85039-22)

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Appendix A 3

23. The public address system must be completely installed and operational

prior to fuel load. (Section 4.2.3) (461/85039-23)

24. All emergency alarms must be completely installed and operational prior

to fuel load. (Section 4.2.3) (461/85039-24)

25. Complete the stocking, organization and inventories of damage

control / corrective action equipment and supplies prior to fuel load.

(Section 4.2.4) (461/85039-25)

26. Where appropriate, Systen/ Plant Operating Procedures (3000 Series),

Off-Normal Procedures (4000 Series) and Annunciator Procedures

(5000 Series) must be completed and appropriately reference and implement

EPIP EC-02, Emergency Classifications. This must be completed prior to

fuel load. (Section 5.2) (461/85039-26)

27. Ensure to the maximum extent possible that EALs are quantified and that

criteria constituting EALs shall be as-read or as observed, minimizing

computations or calculation to determine if the EAL is exceeded. This

must be completed prior to fuel load. (Section 5.3) (461/85039-27)

28. Revise EPIP EC-07, Emergency Plan Notification, prior to fuel load to be

consistent with the methodologies actually employed. (Section 5.4.1)

(461/85039-28)

29. Revise the Emergency Plan and EPIPs prior to fuel load to conform with

the requirements of 10 CFR 50.72(a)(3) concerning notification time limits.

(Section 5.4.1) (461/85039-29)

30. Procedure CPS 1890.34 for use of the PASS must be completed and approved

prior to fuel load. (Section 5.4.2.3) (461/85039-30)

31. Revise the EPIPs to correctly reflect the actual location of the assembly

areas prior to fuel load. (Section 5.4.3.1) (461/85039-31)

32. Develop and implement a means for verifying that personnel outside the

protected area but inside the CPS exclusion area have actually received

the notification of the emergency condition and have followed the

instructions provided prior to fuel load. (Section 5.4.3.1) (461/85039-32)

33. Revise the Emergency Team Data Sheet to provide for individual

authorization signatures for each person who is authorized to exceed

10 CFR 20 limits. The data sheet should also provide for an acknowledge-

ment signature by each authorized worker to signify his understanding of

the assignment, the potential risks, and his willingness to accept those

risks. This must be completed prior to fuel load. (Section 5.4.4)

(461/85039-33)

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Appendix A 4

34. Revise the procedures to identify media organizations, media locations,

and specific methods for contacting the media in the event of an

emergency. This must be completed prior to fuel load. (Section 5.4.6)

(461/85039-34)

35. The procedures should be revised to prescribe the means for coordinating

i.nformation among spokespersons of various organizations and groups prior

to the activation of the JPIC. This must be completed prior te fuel

load. (Section 5.4.6) (461/85039-35)

36. Procedure EPIP FE-05, Emergency Kits, must be modified prior to fuel load

to assign responsibility for inventory and maintenance of emergency

equipment in the Control Room, TSC, OSC, E0F, and BE0F, (Section 5.5.1)

(461/85039-36)

37.' Procedure EPIP AP-09, Emergency Communications Surveillances, must be

modified prior to fuel load to specify the testing frequencies of

emergency communications equipment. (Section.5.5.1) (461/85039-37)

38. All Letters of agreement must be obtained and/or updated prior to fuel

load. (Section 6.1.7) (461/85039-38)

39. The public information brochure must be oisseminated to the public prior

to fuel load. (Section 6.2) (461/85039-39)

40. Emergency information must be made available to the transient population

prior to fuel load. (Section 6.2) (461/85039-40)

41. The operability of the final siren system must be ' demonstrated prior to

fuel load. (Section 6.2) (461/85039-41)

42. The news media must be informed of the applicant's program for media

familiarity with emergency plans, points of contact for release of public

information, space allocated for the media's use, information about

radiation, normal plant operation versus accident operation and accident

sequences. This must be completed prior to fuel load. (Section 6.3)

(461/85039-42)

43. Control Room personnel must be provided with additional training regarding

emergency classifications, especially related to the relationship between

emergency classifications and fission product barrier status. This must

be corrected prior to fuel load. (Section 7.2.2) (461/85039-43)-

44. Conduct additional practical training prior to fuel load for Control Room

personnel concerning notifications, message preparation, and communications

to ensure uniform and timely accomplishment of notification requirements.

(Section 7.2.3) (461/05039-44)

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45. Conduct training for appropriate personnel on the use of SAARS Emergency

Dose Calculation Package and the utilization of computed data from SAARS

prior to fuel load. (Section 7.2.4) (461/85039-45)

46. Revise RA-02, Protective Action Recommendations, to ensure functionality

and compliance with regulatory requirements and guidance, prior to fuel

load. (Section 7.2.5) (461/85039-46)

47. Conduct practical training for emergency response organization personnel

in formulating protective action recommendations based on varying plant

conditions and status, dose assessment / projection, and environmental

conditions prior to fuel load. (Section 7.2.5) (461/85039-47)

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Appendix B -

Improvement Items

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Based on the results of the NRC's apprdtisal of the Clinton Nuclear Power

Station emergency preparedness program conducted November 12-21, 1985, the

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following items should be considered for improvement:

1. A formal program for training should be developed and implemented for

individuals who are assigned Emergency Planning responsibilities, which

will enable them tLattain and maintain a state-of-the-art knowledge in

the field of emergency planning and preparedness. (Section 1.3)

2. Section 5.4.3 of the Emergency Plan should be amended to provide that no

one will be assigned a position in the Emergency Response Organization

prior to satisfactorily completing all required training. (Section 3.1)

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3. The Training Department should be represented on the Safety Evaluation

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. Review Board _when proposed changes to the EPIPs are considered.

(Section 3.1)'

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4. Section 5.4.3.2 of the Emergency Plan should be revised so that it clearly

indicates that fire brigade members will receive all required refresher

training at least biannually. (Section 3.1)

5. The discrepancy between Section 5.4.2 of the Emergency Plan which

indicates that lesson plan concurrence is a responsibility of the

Supervisor - Emergency Planning and the CPS position description which

assigns that responsibility to Supervisor - Emergency Response, should

be reconciled. (Section 3.1)

6. A set of selected models and/or color photographs and layouts of key

areas within the' plant should be prepared and maintained for use in job

planning / training for re-entry under accident and/or accident recovery

conditions. (Section 4.1.1.4)

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7. A routine quality control check, either manual or automated, should be

implemented for, meteorological data. (Section 4.2.1.4)

8. The return-to-service times for replacement of inoperable meteorological

equipment should be reduced. (Section 4.2.1.4)

9. Procedures for obtaining and using backup or offsite meteorological data

should be clarified and simplified, and reflect the uncertainties in

these data sources in the dose assessment and protective action

+decisionmaking process. (Section 4.2.1.4)

10. The plume-segment atmospheric dispersion model used for dose assessment

should be documented and veriff,ed. (Section 4.2.1.4)

11. The following should be considered for inclusion in damage control /

maintenance kits: fire suits; acid suits; steam suits; respiratory

equipment (including ancillary support equipment); protective clothing;

portable lighting; portable radiation monitors; Polaroid cameras and

film; rubber nats; and, Wiggins voltage testers. (Section 4.2.4)

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Appendix B 2

12. Procedure indexes should be provided, where appropriate, to relieve

operator memory tasks. (Section 5.2)

13. References to deleted procedures should be deleted in the operating

procedures. (Section 5.2)

14. Emergency procedures should be prepared for loss of DC power and

Combustible Gas Control. (Section 5.2)

15. Temporary changes should be entered into the body of emergency procedures

to reduce operator workload. (Section 5.D

16. . Emergency Action Levels (EALs) (defined in 10 CFR 50, Appendix E, IV.B)

and emergency cl. asses (Appendix E, IV.C) should be differentiated and

made in accordance with the regulations throughout the Emergency Plan and

EPIPs. (Section 5.3)

17. The Emergency Classification scheme (and supporting EALs) should be

structured in a manner that' establishes the following equivalencies of

fission product barrier integrity and classifications: (a) Unusual Event -

all barriers intact; (b) Alert - one barrier challenged or failed;

(c) Site Area Emergency - two barriers challenged, failed, or combination

thereof; and (d) General Emergency - all three barriers challenged, failed,

or combination thereof. (Section 5.3)

18. Iniiernal references and requirements in the EPIPs and the Emergency Plan

should be consistent. (Section 5.3)

19. . Assumption of duties in various disciplines should be provided by the

first responder to.the facilities. (Section 5.3)

' 20. An authentication scheme should be provided in event of NARS failure.

(Section 5.4.1)

21. The Emergency Plan should specify that a certain percentage of the-drills

will be conducted on the backshifts. (Section 5.5.2)

22. The specific requirements for the annual Emergency Preparedness Program

Audit.should be defined in an expanded version of Section 5.2 of the plan

or in the EPIPs and these requirements should be cited as a reference in

the annual audit order. (Section 5.5.4)

23. The team conducting the annual. audit of the Emergency. Preparedness

Program should observe an emergency drill.other than as controllers or

evaluators. (Section 5.5.4)

24. The applicant should consult and coordinate with'the ambulance service

to improve enroute communications. '(Section 6.1.2)

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Appendix B 3

25. The Sheriff Department's training should be improved to include

information on siren activation, purpose of siren system modifications,

and notification sources. (Section 6.1.5)

26. A sufficient amount of respiratory equipment should be provided *n fully

equip properly manned fire trucks. (Section 6.1.6)

27. Training should be sufficient to distinguish between security requirements

and health physics practices. (Section 6.1.6)

28. IPC Corporate Nuclear Procedure 4-03, Revision 2 should be revised to

accurately reflect who has responsibility for coordination of publication

of the public information brochure. (Section 6.2)

29. A rumor control number should be listed in the public informatico

brochure's next update; in the interim, the rumor control number should

be placed in the monthly newsletter after fuel load. (Section 6.2)

30. Additional practical training for MCR personnel should be conducted to

ensure adequate capability to implement plant emergency procedures.

(Sections 7.2.1)

31. Additional training should be conducted for watch organizations to assure

personnel assignments in the emergency organization make the most efficient

use of the expertise of the various individuals to meet the needs of the

existing situation. (Section 7.2.3)

32. Additional practical training should be conducted for appropriate personnel

in performing EPIP RA-01, Manual Radiological Dose Assessment, and

evaluation of computed data. (Section 7.2.4)

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CONTENTS

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1.0 ADMINISTRATION OF THE EMERGENCY PREPAREDNESS PROGRAM................ 2

1.1 Responsibility and Authority Assigned.......................... 2-

1. 2 Planning Coordination.......................................... 3

1.3 Selection and Qualification.................................... 3

2.0 EMERGENCY ORGANIZATION.............................................. 3

2.1 Onsite Emergency Organization.................................. 3

2. 2 Augmentation of the Emergency Organization. . . . . . . . . . . . . . . . . . . . . 4

3.0 TRAINING AND RETRAINING.............................................. 5

3.1 Program Establishment.......................................... 5

3.2 Program Implementation......................................... 7

4.0 EMERGENCY FACILITIES AND EQUIPMENT.................................. 8

4.1 Emergency Facilities........................................... 8

4.1.1 Assessment Facilities..................... ............. 8

4.1.1.1 Control Room................................... 8

4.1.1.2 Technical Support Center (TSC)................. 8

4.1.1.3 Operational Support Center (05C)............... 10

4.1.1.4 Emergency Operations Facility (E0F)............ 11

4.1.1.5 Post-Accident Coolant Sampling and

Analysis..................................... 14

4.1.1.6 Post-Accident Containment Air

Sampling and Analysis........................ 14

4.1.1.-7 Post-Accident Gas, Particulate, and

Radiciodine Effluent Sampling and

Analysis..................................... 15

4.1.1.8 Offsite Laboratory Facilities.................. 16

4.1.2 Protective Facilities................................... 16

4.1.2.1 Assembly / Reassembly Areas...................... 16

4.1.2.2' Medical Treatment Facilities................... 17

4.1.3 Expanded Support Facilities............................. 18

4.1.4 Joint Public Information Center (JPIC).................. 18

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4.2 Emergency Equipment............................................ 19

4.2.1 Assessment Equipment.................................... 19

4.2.1.1 Emergency Kits and Emergency Survey

Instrumentation.............................. 19

4.2.1.2 Area and Process Radiation Monitors............ 20

4.2.1.3- Non-Radiation Process Monitors................. 20

4.2.1.4 Meteorological Instrumentation................. 21

4.2.2 Protective Clothing..................................... 23

4.2.3 Emergency Communications Equipment...................... 24

4.2.4 Damage Control / Corrective Action and

Maintenance Equipment and Supplies.................... 25

4.2.5 Reserve Emergency Supplies and Equipment................ 26

4.2.6 Transportation.......................................... 27

5.0 EMERGENCY PLAN AND IMPLEMENTING PROCEDURES.......................... 27

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5.1 General Content and Format..................................... 27

5?2 Emergency,_ Alarm, and Abnormal Occurrence Procedures........... 27

5.3 Implementing' Instructions...................................... 30

5.4 Implementing Procedures........................................ 32

5.4.1 Notifications........................................... 32

5.4.2 Assessment Actions...................................... 33

5.4.2.1' Offsite and Onsite Radiological Surveys. . . . . . . . 36

5.4.2.2 Inplant Radiological Surveys................... 36

5.4.2.3 Primary Coolant Sampling and Analysis.......... 37

5.4.2.4- Fire Assessment and Classification............. 37

5.4.3 Protective Actions...................................... 38

5.4.3.1 Evacuation of Owner Controlled Areas........... 38

5.4.3.2 Personnel Accountability....................... 39

5.4.3.3 Onsite irst Aid and' Rescue.................... 39

5.4.4' Repair and Corrective Actions........................... 39

5.4.5 Recovery................................................ 40

5.4.6 Public Information...................................... 41

5.5 Suppl ementa ry Procedu re s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i41

5.5.1 . Inventory, Operational Check, and Calibration of

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-Emergency Equipment, Facilities, and Supplies.........

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5.5.2 ' Drills and Exercises.................................... 42

5.5.3 Review, Revision and Distribution....................... 43-

5.5.4 Audits.................................................. 43

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6.0 COORDINATION WITH OFFSITE GR0UPS.................................... 44

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6.1 Offsite Agencies............................................... 44

6.1.1 DeWitt County Board..................................... 44

6.1.2 Clinton Ambulance Service................. ............. 45

6.1.3 Illinois and DeWitt County /Clinton Emergency

Services and Disaster Agency (ESDA)................... 45

6.1.4 Medical Services Arrangements........................... 45

6.1.5- DeWitt County Sheriff................................... 46

6.1. 6 Clinton Fire District................................... 46

6.1.7 Letters of Agreement.................................... 47

6.2 General Public and Transient Population........................ 47

6.3 News Media..................................................... 49

7.0 DRILLS, EXERCISES AND WALKTHROUGHS.................................. 49

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7.1 Drills and Exercises........................................... 49

7.2 Main Control Room Wal kthrough Observations. . . . . . . . . . . . . . . . . . . . . 49

7.2.1 Emergency Detection..................................... 49

7.2.2 Emergency Classificaticn................................ 50

- 7.2.3 Notifications........................................... 50

7.2.4 Dose Calculations....................................... 51

7.2.5 Protective' Action Decisionmaking........................ 52

7.3 Emergency Response Organization Walkthrough Observations....... 53

8.0 PERSONS C0NTACTED................................................... 53

8.1 - Illinois Power Personnel....................................... 53

8.2 Non-Illinois Power Personne1................................... 55

9.0 EXIT INTERVIEW...................................................... 55

Attachment: -Emergency Response Organization

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