ML20215L918
| ML20215L918 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 10/24/1986 |
| From: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Schaufelberger NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 8610290367 | |
| Download: ML20215L918 (2) | |
Text
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Docket No:
50-298 Nebraska Public Power District ATTN:
Donald E. Schaufelberger, President and Chief Executive Officer P.O. Box 499 Columbus, Nebraska 68601
Dear Mr. Schaufelberger:
We have received the enclosed Federal Emergency Management Agency (FEMA) letter dated October 10, 1986, and associated report on the evaluation of the prompt public alert and notification system (ANS) for the Cooper Nuclear Station.
The report includes the results of FEMA's review of the Cooper ANS design and eval-uation of the capabilities of offsite authorities to implement alert and noti-fication procedures.
Several deficiencies and inadequacies in the ANS identified over a two year period remain uncorrected. As a result of its review, FEMA has found that the condition of adequacy of the ANS in the 44 CFR 350 approval of offsite plans dated July 2, 1984, is not satisfied.
Therefore, FEMA has invoked the provisions of 44 CFR 350.13 to withdraw approval of the Missouri and Nebraska offsite emergency plans site-specific to the Cooper Nuclear Station if corrective actions have not been implemented by the States of Missouri and Nebraska within four months of the date of their official notification.
The governors of the States of Nebraska and Missouri have been notified of this proposed withdrawal of approval by letters dated October 14 and 16, 1986, respectively.
Recognizing the seriousness of this situation and the fact that it has remained uncorrected for two years, it is essential that you work expeditiously with the States of Nebraska and Missouri and with FEMA to resolve all notification problems to their satisfaction. We recommend that you initiate steps to meet jointly with all parties concerned as soon as possible to achieve a concensus regarding the required actions to be taken.
Since you as an NRC licensee are responsible for demonstrating that admini-strative and physical means have been established for alerting and notifying the public, you are requested to submit a written response to this office within 30 days of the date of this letter describing: (1) your planned actions to correct the deficiencies in the Cooper alert and notification system, (2) a schedule for completing the corrective actions, and (3) supplemental means you have provided for promptly alerting and nutifying the public until the deficiencies are corrected. We will determine an appropriate course of action under our regulations based on your response and the results of the subsequent demonstration of the system.
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r liebraska Public Power District In accordance with 10 CFR 2.790 of the Ccmmission's regulations, a copy of this letter and the enclosures will be placed in the NRC's Public Document Room.
Should you have any questions regarding this letter, we will be pleased to discuss them with you.
Sincerely, ORIGINAL SIGNED Y:
W s&
obert D. Martin v
Regional Administrator Region IV
Enclosure:
FEMA letter dated 10/10/86 w/ report cc w/ enclosure:
Guy Horn, Division Manager of Nuclear Operations Cooper fluclear Station P.O. Box 98 Brownville, Nebraska 68321 Kansas Radiation Control Program Director Nebraska Radiation Control Program Director Missouri Radiation Control Program Director Nebraska Civil Defense Agency Missouri Emergency Management Agency Federal Emergency Management Agency, Region 7 911 Walnut Street Kansas City, Missouri 64106 bcc to DMB (IE35) bcc distribution by RIV:
RPB DRSP Resident Inspector R. D. Martin, RA Section Chief (RPB/a)
D. Weiss, LFMB (AR-2015)
R&SPB RSB MIS System C. A. Hackney RIV File L. A. Yandell RSTS perator R. L. Bangart D. B. Matthews, IE W. L. Fisher
(E Federal Emergency Management Agency Washington, D.C. 20472 OCT l o iggs. _. _
.s Mr. Victor Stello, Jr.
Executive Director for Operations U.S. Nuclear Regulatory Ccumission OCT I 71986 Washington, D.C.
20555 h.
d -- - - -.._ _ 2 j j Dear Mr. Stello j
The purpose of this letter is to advise you of several deficiencies in the alert and notification system (ANS) installed around the Cocper Nuclear Station in Brownsville, Nebraska. The Federal Dnergency Management Agency (FEMA) has ccmpleted a review of the Cooper ANS pursuant to FDIA Rule 44 CFR 350; selected evaluative criteria and Appendix 3 in NURII;-0654/ FEMA-REP-1, Revision 1; and FDtA-43, the " Standard Guide for the Evaluation of Alert and Notification Systens for Nuclear Power Plants" (now published as FEMA-REP-10 ).
Thus far, FEMA has coupleted a preliminary engineering review of the ANS design submitted by the Nebraska Public Power District (NPPD),
evaluated the results of a telephone survey of residents of the emergency planning zone (EPZ) following activation of the Cooper ANS on October 17, 1985, and evaluated ANS conponents during several offsite radiological energency preparedness exercises and ranedial drills.
FEMA's review of the Cocper ANS design and evaluation of the capabilities of offsite authorities to implement alert and notification procedures has revealed deficiencies and inadequacies in various ccaponents of the system that have essentially renained uncorrected for cuer two years despite atterpts by the States of Missouri and Nebraska and NPPD to correct the problems. Below is a listiry of reoccurring inadequacies and deficiencies related to the Cooper ANS that have been cited by FDIA during various exercises. Although scme of these deficiencies and inadequacies were corrected during remedial exercises, scme have been repeated in the latest exercise conducted on September 24-25, 1986, despite the past corrective actions.
- May 15,1984 Exercise i
Evaluators cited 75 " Deficiencies" (these deficiencies would now be classified as areas requiring corrective action) of which five were j
directly related to the ANS and two of these related to alerting transients at the Indian Cave State Park.
- October 16, 1985 Exercise Evaluators cited three " Deficiencies" directly related to ANS procedures at Indian Cave State Park, Brickyard Hill State Wildlife Area, and the Atchison County, Missouri Emergency Operations Center (BOC). The Deficiency related to the Atchison County DOC was subsequently corrected at a Ncuember 26, 1985 remedial exercise and the defleiency related to the Brickyard Hill State Wildlife Area was subsequently corrected at a June 16,1986 remedial exercise.
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September 24-25, 1986 Exercise Evaluators cited 2 " Deficiencies" directly related to ANS procedures for Indian Cave State Park, Brickyard Hill State Wildlife Area, portions of the Missouri River between. the two States, and the Atchison County, Missouri EOC. The results of this exercise will be forwarded to you in early November 1986.
The enclosed chronology prepared by FEMA Region VII, and supported by relevant documentation, details efforts to resolve the inadequacies and deficiencies identified in the Cooper ANS review and exercises over the past two years.
In consideration of the Cooper ANS deficiencies cited in the September 24-25, 1986, exercise and the fact that these deficiencies have reoccurred despite the i
i.
efforts of Nebraska, Missouri, and NPPD to correct them over the past two years, y
FEMA nust advise NRC that the Cooper ANS does not currently satisfy the require-ments of FEMA Rule 44 CFR 350 and the Nuclear Regulatory Conunission (NRC) ble 10 CFR 50, Appendix Er nor have the design objectives in NUREGK)654/ FEMA-REP-1, Revision 1, and FENA-43 been satisfied. Therefore, FEMA cannot make a statement of reasonable assurance that the Cooper ANS is adequate to provide prcstpt alerting j
and notification to the population in the event of an emergency at the site. In light of this, PTMA finds that the condition on the adequacy of the ANS in the
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44 CFR 350 approval of offsite plans dated July 2,1984, is not satisfied, thus creating a serious shortfall in the overall adequacy of offsite planning and pre-paredness.
FEMA is, therefore, invoking the provisions of FEMA ble 44 CFR 350.13 to withdraw approval of the Missouri and Nebraska offsite plans site-specific
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to the Cooper Nuclear Station.
The Governors of the States of Missouri and Nebraska will be officially notified through the Director of FEMA Region VII of the specific reasons for FEMA's in-i voking of 44 CFR 350.13. If af ter four nonths fran the date of their official notification, Missouri and Nebraska have not either corrected the deficiencies noted, or subnitted an acceptable plan for correcting the deficiencies, FEMA will withdraw approval of both State plans and innediately inform the NRC and the Governors of both States of the determination to withdraw the approvals. At that time FEMA would also publish notification of the withdrawal in the Federal Register and in the local newspapers having the largest daily circulation.
Copies of all correspondence regarding this matter will be provided to you.
If you have any questions please contact Mr. Robert S. Wilkerson, Chief, Techno-logical Hazards Division at 646-2860.
Sincerely, ha V
-r Dave McIoughlin Deputy Associate Director 1
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Region VII 911 Walnut Street Kansas City, Missouri 64106
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001 3 ES MEMORANDUM FOR:
tvid McLaughlin, Acting Associate Director
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ptate&LocalPrograms& Support FROM:
r e,
egional Director, FDM Region VII
/
SUBJECT:
Findings of Inadequate Planning to Protect Public Hea1Q and Safety for the Transient Population in the 10 mile'F EPZ of the Cooper Nuclear Station 6
.e In accordance with hk CFR 350.13(a), the purpose of this memo is to provide the infor=ation necessary to support my position that the portions of Nebraska and Missouri State Plans addressing Planning Standards E, F N, and Appendix 3 of NURE-065L/FDM-REP-1, Rev.
1, relating to the Cooper Nuclear Station, are deficient.
Therefore, I can no longer attest that these State and local plans are adequate to protect public health and safety by providing reasonable assurance that appropriate protective measures can be taken.
This action is necessary since, on July 2, 198h these plans were approved on "the condition...that the adequacy of the public alert and notification system already installed and operational must be verified as meeting the standards set forth in Appendix 3 of NUREG-065h/FDM-REP-1, Rev. 1".
(See exhibit #1.)
The recent exercise of September 2h and 25, 1986, failed to de=onstrate alert and notification within h5 minutes in accordance with the special alerting provisions of Revision 5 to the Alert and Notification System (ANS)
Design Report.
(Sec exhibit #2.)
Specifically, the aircraft failed to fly the assigned route over the Brickyard Hill State Wildlife Area in Missouri, Indian Cave State Park in Nebraska, and portions of the Missouri River separating the two States in the time required; and the State of Nebraska declined to demonstrate the ground vehicle route alerting within Indian Cave State Park. The State declined, due to the reported unwillingness of Park Officials, to run the routes because of personal injury sustained when the system was initially tested.
This failure in itself would not cause me to adopt such a strong position, except that it has been preceeded by a history of persisting deficiencies in the ANS.
Following is a chronicle of events outlining FD%'s relationship with Missouri, Nebraska and the Nebraska Public Pover District (NPPD) in attemptin8 to provide an ANS that will conform to the applicable requirements:
May 15, 198h - The annual exercise was conducted this date.
Evaluators cited
'I'> " Deficiencies" (now known as " ureas requiring corrective action").
Five of them were directly related to the ANS.
Two of them occurred in the process of alerting transients at Indian Cave State Park.
(See exhibit
- 3.)
The corrective actions called for by FDM VII required a successful demonstration at the 1985 exercise.
-g-October 9,198h - In response to a FEMA VII inquiry, NPPD promised delivery of its ANS not later than March 31, 1985.
May 23, 1985 - NPPD's ANS arrived in FDM VII, forwarded by State of Nebraska.
October 16, 1985 - Conducted annual exercise at Cooper.
Six deficiencies were cited, three were directly related to ANS.
One was at Brickyard Hill State Wildlife Area, one at Indian Cave State Park, and one at the Atchison County EOC.
(See exhibit #h.)
October 31, 1985 - FEMA VII sent a memo to Missouri detailing the ANS exercise deficiencies relating to the Atchison County EOC and the Brickyard Hill fi followed
( pis memo State Wildlife Area.
A remedial exercise was needed.
7 exhibit #5.)
numerous telephone communications regarding the matter.
November k.1985 - Received from FDM Headquarters the preliminary technical review of the Cooper MIS.
It indicated the lack of any provisions 'or alert at the Brickyard Hill State Wildlife Area.
(See exhibit #6.)
November 8, 1985 - The Director and staff of the Missouri State Emergency Management Agency (Missouri SD!A) came to the FEMA VII to discuss alert and notification at Brickyard Hill.
November Ih, 1985 - FDM VII memo responded to Missouri's proposed remedy to the ANS deficiencies.
FD!A VII response was essentially negative, due to the ' lack of sufficient information regarding equipment specifications.
(See exhibit #7.)
November 26, 1985 - Remedial exercise successfully demonstrated correction of mis deficiency at Atchison County EOC.
December 20, 1985 - Cooper Exercise Evaluation Report was issued.
The deficiency at Brickyard Hill remained open.
(See exhibit #8.)
January 27, 1986 - FDM VII memo responded to Missouri notification that they cannot acco=plish remedies for Brickyard Hill by the February 1h,1986 deadline.
Called for Missouri response by February 3, 1986.
(See Exhibit
- 9.)
February 3, 1986 - Missouri memo to FDM VII gave proposed time frame for correcting alert and notification at Brickyard Hill.
(See exhibit #10.)
February 10, 1986 - FDM VII response to Missouri said they continue to ignore the issue of amendments to the ANS Design Report and again cited required actions and timetables.
(See exhibit #11.)
February 13, 1986 - Missouri submitted proposed changes to State and local plans implementing the revised (and still " proposed") ANS.
February 20, 1986 - Missouri Director of SDM came to Kansas City to meet with FDM VII concerning remedial action for Brickyard Hill.
. March T.1986 - FEMA VII sent detailed critique to Missouri regarding proposed alert and notification plan changes.
Memo noted that there is still no amendment to the Design Report, and plan changes are based on assumptions that may not be substantiated by the Design Report.
(See exhibit #12.)
March 18. 1986 - Memo from FD(A Headquarters concerning FEMA VII's position that the procedures for alerting transients on the Missouri River are inadequate. Stated that ANS vould not be approved until the issue is settled.
(See exhibit #13.)
April 3.
1986 - FINA VII memo to Missouri and Nebraska cited alert and notification problems on the River.
(See exhi$tt #1k.)
fA April IT. 1986 - Memo from NRC to NPPD dirented them to interact with the appropriate State agencies and coordinate with FEMA VII to solve the river problem within 30 days.
(See exhibit #15.)
May 13. 1986 - NPPD memo to NRC claimed they never received the April 17, 1986 memo and asked for extension to June 5, 1986.
(See exhibit #16.)
May 14. 1986 - FINA VII memo to Missouri expressed concern that no amendment to the Design Report had yet been received, and that the remedial exercise depended on this document and the revised plans.- (See exhibit #17.)
May 16 1986 - Missouri SD(A submitted a descri of the alert and notification for Brickyard Hill, dated May 12, 1986. ption(See exhibit #18.)
May 21, 1986 - FEMA VII held a Regional meeting for States and Utilities to discuss a variety of issues including the new Guidance Memoranda.
Principal participants from Cooper met at length with FD(A VII staff. Alert and notification was fully discussed, especially the river and Brickyard Hill.
May 23. 1986 - FEMA VII faxed memo to Missouri SDtA responding to their May 16, 1986 submission.
Main concern was the continued absence of Design Report amendment to support the proposed plan changes.
(See exhibit #19.)
May 30,1986 - FDiA VII received from Missouri Revision 1 to ANS for Brickyard Hill and the plan changes necessary to implement the system.
(See exhibit
- 20.)
June 2 1986 - FDtA VII memo to Missouri SD(A evaluated the ANS Revision 1 and the plan changes; cited lack of coverage of Missouri River, and several other short comings.
A response date of June 9, 1986, was established.
(See exhibit #21.)
June 5.1986 - FD!A VII received from Nebraska copies of NPPD letters sent to Missouri and Nebraska, and NPPD letter to NRC.
They aret (1) May 30, 1986, NPPD to Missouri and Nebraska stating that NPPD's closed circuit TV security camera which monitors river traffic for 2 miles up and down stream detected only 66 craft carrying
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1 transients in a period from May 15, 1982 to May 1, 1983.
Based on this activity level NPPD asserted that its ANS was adequate.
They did agree with FDIA that signs should be erected at public 1
river access areas and the boundaries of the EPZ.
NPPD agreed l
to erect the river access signs by September 1, 1986.
(As of September 2h, 1986 this had not been done. )
Boundary signs were scheduled to be in place on or before January 1, 1987.
i (2) June 2,
1986, NPPD to NRC stated that a true assessment of the i
ANS is not possible without the results of FDM VII's evaluation i
of the Design Report, and results of FDM VII's telephone survey taken on October 17, 1985.
(But FDR VII had, as chronicled above, issued to NPPD the porti"pn of the evaluation pertinent to the issue i
at hand.)
They also p% pose to NRC that they can deal with FDM VII's ANS river concenis using their TV cameras, mobile alerting, Cox Aviation, the Nebraska Civil Air Patrol, and the United States Air Force.
(Cox Aviation is the only one mentioned in Revision 1 to the ANS and that is for alerting Brickyard Hill, not the river.)
(3) June 3,1986, NPPD memo to Missouri and Nebraska stated that Cox Aviation vill perform alert on the north segment of the river between 5 and 10 miles.
NPPD is currently negotiating with the USAF and the Nebraska CAP to perform alert on the south segment of the river, 1
and project August 1,
1986 for the completion of arrangements.
(See exhibit #22.)
i June 6.1986 - FDM VII memo to Missouri and Nebraska responded to the NPPD l
memos cited above. FDM VII referred to the NPPD correspondence as a " concept
)
paper" with no substantiation and cited applicable regulations requiring an amendment to the Design Report.
Deadline August 15, 1986.
(See exhibit
- 23.)
l June 6.1986 - FDM VII received fax from Missouri SDM containing Revision 2 to the ANS, and necessary changes in State and local plans. They described the combined use of a Park Ranger in a vehicle to provide route alerting 1
and. Cox Aviation flying over Brickyard Hill to provide initial alert.
Also 1
included was description of route alerting by park employees at Indian Cave State Park.
(See exhibit #2k.)
t June 9,1986 - FDM VII memo to Missouri SDM approved proposed plan changes as suitable for testing at Brickyard Hill remedial exercise on June 16, i
1986, and provisionally accepted ANS Revision 2, for Brickyard Hill contingent upon technical review.
(See exhibit #25.)
June 11. 1986 - FDM VII forwarded ANS Revision 2 to FDM Headquarters for technical review.
(See exhibit #26.)
i June 19. 1986 - FDM VII transmitted to FD!A Headquarters the report of a successful remedial exercise at Brickyard Hill held on June 16, 1986.
I (See exhibit #27.)
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-5 July 15. 1986 -
NPPD, Nebraska and Missouri met with FD(A VII to present a " DRAFT" of Revision 3 to the ANS.
It included two new fixed sirens for the Missouri River within 5 miles; provision for signs on the river; and airborne alerting for portions of the river without sirens between 5 and 10 miles.
However, Letters of Agreement (LOAs) were unsigned and the DRAPI left 3/h mile of the river within the 5 mile ring uncovered by any means of alert.
These inadequacies were cited by FDIA as requiring correction by August 15, 1986 in a final ANS revision.
(See exhibit #28.)
August 15. 1986 - NPPD submitted Revision 3 to the ANS, but still in DRAFT form without having corrected the inadekuacies cited at the meeting of July 15, 1986.
August 19. 1986 - FDM memo to Nebraska and Missouri rejected NPPD's submission due to the fact that the Design Report amendment was only a DRAFT; it still did not address a 3/h mile stretch of river within the 5 mile ring; and LOAs were still unsigned.
Gave deadline of September 9, 1986, for corrective action.
(See exhibit #29.)
September 9.1986 - FD% received from NPPD Revisions 3 and 4 for the ANS.
Revision 3 restated the addition of two more sirens for installation in mid October, 1986. Revision h addressed alert and notification of transients on the Missouri River and presented NPPD rationale to eliminate the need for airborne alert on the southern portion of the river.
The rationale was that 50 dB siren coverage would be extended to these areas based on the loss of 10 dB per distance doubled, and the claim that ambient noise levels are 38.3 dB.
NPPD applied the same rationale to the 3/k mile stretch of river within the 5 mile ring previously unaccounted for.
(See exhibit
- 30.)
September 15. 1986 - Revisions 3 and h were sent to FD4A Headquarters for technical review, particularly in the area of the ambient noise survey.
(See exhibit #31.)
September 18. 1986 - FDM VII memo to Nebraska acknowledged receipt of Revisions 3 and 4.
It also noted that we had received verbal communication that Nebraska vould use aircraft for alert at Indian Cave State Park.
Requested additional a=endment to Design Report.
(See exhibit #32.)
September 23. 1986 - NPPD submitted Revision 5 to ANS.
Primary alert on all parts of the river without sirens was to be covered by Cox Aviation.
It also added a third new siren, and introduced airborne alerting for Indian Cave State Park for the first time.
(See exhibit #33.)
September 24 and 25. 1986 - FDM VII evaluated exercise for Missouri and Nebraska at Cooper Nuclear Station and observed deficiencies related to the ANS.
September 26. 1986 - FDM VII memo to FDM Headquarters detailed the two (2) deficiencies and recommended a negative finding regarding the Cooper ANS.
(See exhibit #3h.)
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September 26, 1986 - Received memo from IEAL to FDM Headquarters concerning Revisions 3 and 4 Preliminary analysis indicated a failure to provide information required by FEMA REP-10, pages E-8 and E-9 to justify the claimed anbient noise levels.
(See exhibit #35.)
As a result of the information provided herein, I find that I no longer have reasonable assurance that the health and safety of the public can be protected and recommend that the Alert and Notification System for the Cooper Nuclear Station be returned to the licensee as disapproved; that the Associate d
Director, SLPS, take the action outlined in hk CFR 350.13 of informing the States of Nebraska and Missouri that the Plans submitted by those States, and their respective local governments, are no longer adequate, as described in 350.13; that the Associate Director, SLPS, give notice to the affected States, that within four months of the date of said letter, should the planning deficiencies herein noted fail to be corre"d,ted, action vill be taken by the Federal Emergency Management Agency fog full withdrawal of the approval of the 350 Planning submission for the Cooper Nuclear Station.
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