ML20235T888

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Advises That 870529 Changes to Emergency Plan Do Not Decrease Effectiveness.Areas Requiring Clarification or Better Definition Listed
ML20235T888
Person / Time
Site: Cooper 
Issue date: 10/06/1987
From: Gagliardo J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Trevors G
NEBRASKA PUBLIC POWER DISTRICT
References
TAC-65621, NUDOCS 8710130269
Download: ML20235T888 (3)


Text

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OCT 6 1987 In. Reply Refer To:

Docket:

50-298 Nebraska Public Power District ATTN: George A. Trevors Division Manager - Nuclear Support P. O. Box 499

' Columbus, NE 68601 Gentlemen:

The Region IV staff has completed review of the emergency plan changes which you submitted to this office by letter dated May 29, 1987. The emergency plan changes do not appear to decrease the effectiveness of the Cooper Nuclear Station Emergency Plan.

There are areas which should be clarified or better defined in your next Emergency Response Plan change.

It is requested that you make the correction to your plan and procedures in your next plan or procedure change.

Section 5 - Organizational Control of Emergencies

p. 5-8 First sentence - The OSCs should be added to the emergency response facilities that are activated at an Alert.

I

p. 5-9 List of key positions supporting the Emergency Director - According to Figure 5.2-2, the Control Room. Director reports to the TSC Director -- not the Emergency Director, F age 5-9 and Figures 5.2-2, S.2-3,. 5.3-2 should be consistent l

with regard to the functional reporting organization and l

interrelationships.

p. 5-10 Note 1 of Figure 5.2-3 and various other sections - The Emergency Director has the option of locating:in the Control l

Room, TSC or E0F throughout the emergency.

To. accomplish the l

functions assigned solely to this position, an Emergency Director must be able to interface directly with the staff who are providing the information needed to make decisions-regarding those functions.

Interfacing with several persons over the phone can cause delays in critical decisions. The purpose of emergency response facilities (ERF) is to gather all the personnel and equipment in one place in order to' perform a-specific function in. a timely fashion. The purpose of the ERFs is lost when-the decisionmaker and the technical support staff-are in different locations. The location'for the Emergency Director should be whe ( :9 information and support' staff necessary to perfor I e unctions of.the Emergency Director.

are available.

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D Nebraska Public Power District p. 5-29 Paragraph 5.3.3.3

" Institute of Nuclear Power" should be

" Institute of Nuclear Power Operations."

' Figures 5.2-2, 5.2-3 and 5.3-1

.The titlesLfor the CNS Emergency Preparedness Coordinator, Radiological Control Manager and the Environmental Support Manager should be corrected.

Section 6'- Emergency Measures 1

Table 6.5.-1,- The difference between planned and unplanned exposures-during a response to an emergency is' difficult to define. The criteria:

for defining each and the procedures to. assure compliance with this requirement should be evaluated to determine'if the distinction is necessary and the method.to assure compliance is feasible.

Section 7 - Emergency Response Facilities and Equipment

p. 7-8 First Sentence - It is.not clear what information is obtained from the Control Room and how the information is used.

Section 8 - Maintaining Emergency Preparedness

p. 8-7 Paragraph 8.2.1 and p. 8-8, third paragraph - Joint emergency exercises are required on a. biennial basis. All essential elements should be tested within a six year period. More information on exercise frequency is contained in FEMA' Guidance Memorandum PR-1, " Policy on NUREG-0654/ FEMA-REP-1 and 44 CFR 350 Periodic Requirements."

p, 8-7 Paragraph 8.2.2 - The last sentence is-.not completely true.

If a required drill is conducted in conjunction with an exercise, on-the-spot instructions should not be given and the drill should be conducted using the guidelines for the conduct of an exercise.

Section 9 - Recovery

p. 9-1 The Vice-President-Nuclear or his designee is not listed as a member of the Recovery Panel, which is inconsistent 'with Corporate Nuclear Emergency Procedure 5.0, Recovery.

There is no discussion of when and how. notification to onsite' and offsite' emergency organizations occurs after the Vice-President-Nuclear initiates recovery,

p. 9-6 Off-Site Liaison' Manager duties - Interface with the NRC through an onsite person would be more appropriate as. indicated on page 9-3, Senior Manager of. Technical Support Services duties.

1 1

6 Nebraska Public Power District If there are any questions in regard to this letter please contact Charles A.

Hackney (817) 860-8188.

Sincerely, 5

J. E. Gagliardo, Chief Reactor Project Branch cc:

Guy Horn, Division Manager of Nuclear Operations Cooper Nuclear Station P. D. Box 98 Brownville, Nebraska 68321 Program Manager FEMA Region 7 911 Walnut Street, Room 300 Kansas City, Missouri 64106 Director Nebraska Civil Defense Agency 1300 Military Road Lincoln, Nebraska 68508 Kansas Radiation Control Program Director Nebraska Radiation Control Program Director bec to DMB (A045) bcc distrib. by RIV:

RPB DRSP RRI R. D. Martin, RA Section Chief (RPB/A)

D. Weiss, RM/ALF MIS Systen.

Project Inspector, RPB RIV File R. Hall RITS Coordinator W. Long, NRR Project Manager Inspector W. L. Fisher R. L. Bangart D. B. Matthews, NRR G. Bates

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