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- MEMORANDUM FOR:. lInciden.t Re'sponse B' ranch, OIE 1
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FROM:
i.C.fJ. ! Nperiello", Chief..
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SUBJECT:
REQUE'ST FOR GUIDdNCE itEGARDING CECO IDENTIFIED CONCERNS
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' DESCRIBED. IN -FEBRUARY 19, 1985 MEETING REPORT WITH t,
' COMMONWEALTH EDISON PERSONNEL.
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.This refers to the enclosed Meeting Report dated February 19, 1985.
The meeti.ng was held at the' request of the Commonwealth Edison Emergency i
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. Preparedness Supervisor:to discuss several topics, some of which were related! ],
- to fthe NRC's Incident Response program.
A copy of the meeting report and its; *
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- attachments is included with this
- memo. 'As a result of the meeting, a I {ds..,.."significant number of; issues :were identified which will require NRC l
- '.lieadquarters clarification.
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.J 4 The areas related to NRC Incident Response were :as follows: (1) who has final!
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- M authority on the use of EALs for event declarations, 'namely, who has the j#
initial responsibility,jwho has the subsequent responsibility, and does the d
- j d.idhiama state or NRC have
- the atJthority 'td! change a classification made by the
' d 31 licensee;'(2) does State (or NRC) reclassification overrule licensee 4gD'. classifications; (3) will the NRC reclassify emergencies or change emergency.:
.s classifications made by:the licensee;- (4) what are the requirements for ENS /HPN d.'
' surveillance, and1what will be done' about the lack of HPN phones at all -
g lidensee ERFs; and (5) does the NRC want to work with the licensee on'the i developmentuof'the State of Illinoi.s Nuclear. Data Link in order to integrate.in 3, D q' Jto.the NRC-ERDS system?~
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The.first three items all relate to' the role of the NRC and other offsite j
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. organizations tolmake emergency classifications or revise licensee Q, (;*.
1 d, Q, classifications. 4 The specific impetus for this issue was the " push to
.I Yg classification" for the LaSalle station staff by the NRC Headquarters Duty,. Officer 4
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1 and the Region III cognizant-Section! Chief,'who said that based'on.h.is review of the EAls they ought to be:in -an Alert..The event occurred.iniAugust 1984.
The opinion expressed by us during the meeting was that the'NRC should not reclassify events at the-Duty Officer or Section Chief level; however, if Senior NRC management (Regional Administrator or his alt'ernate) felt.that a
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reclassification was warranted, this,may occur-efter discussions with the '
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.However,iNRC would senior utility representative at the. time of the event.
have to examine what a reclassification would gain.
In Michigan, the State, -
through statute (PL390), has the authority to make an emergency classification
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different from the licensee's, and NUREG-0654 appears toigive the State this
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authority.
If such were the case, would the NRC response be' commensurate with '
the licensee's classification or the. State's?
i Based on our discussions with the licensee, it appears sone form of.
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Headquarters guidance should be issued to the Headquarters. Duty Officers and regions to clearly spell out NRC policy 'on revising a licensee's emergency classification or activating based-on'a differing-classification between the
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State and licensee.
The fourth item discussed related to testing of the HPN network specifically, and the inability to obtain HPN service for a number of licensee facilities (for example, no HPN available at Byron ~, LaSalle, or Dresden: EOF's).
Enclosed t-(_
with this clarification request are several guidance letters 'provided ~to all.
licensees. and specific guidance provided to D. C. Cook.
Based on the positi~on you and your staff have taken regarding the testing of the.HPN netwoik, the NRC-appears to have taken a complete turn in the. directions provided to the i
licensee regarding this system.
Based.on discussions with ELD regarding the requirements to test communications with the NRC, this requirement is met if any one phone (commercial, ENS, Microwave link, etc.) is used to test communications.
In light of the enclosed memos, it appears to me that we would be hard pressed to cite a licensee for failure to test the HPN lines.
3 Additional Headquarters guidance provided to the licensees is ne'cessary to.
ensure that this communication system (HPN) will be available in the e' vent of an emergency.
2 The' final item dealt with the licensee's implementation of a Nuclear Data Link, which is required by Illinois State law, between the licensee's six facilities and the Illinois Department of Nuclear Safety.
If we want to be involved in j
the initial development of this system so that our ERDS needs,can be..
incorporated into this system, contact should be made with Mr. Larry Duchek o.f the licensee's staff at (312) 294-3285.
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If you'have anp questions concerning t'hese Nems, please feel free to contact me at FTS 388-5517.
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.JPap iallo, Chief
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![s**lC ij fo NUCL'E AR 'R EG U L ATO RY COMMISSION : ;:-*
UNITED $TATES J,
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- 4 Docket Nos. 50-237, 50-249;.
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50-254, 50-265; 50-295,.50-304; j
50-373, 50-374; 50-454,f50-455;
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ATTN: Mr. Cordell Reed
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Vice President l;{5 l', ; i' '
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Post Office Box 767 3
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Chicago, IL 60690 g
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4 Gentlemen:
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between myself and Messrs. M. Phillips arid T. 'Ploski of my;
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staff, and Dr. J. Golden and Messrs. lR. ;Dwyer and T. Blackmon of your staff.
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e This meeting was held at the requestjof.your staff to discuss various items.
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related to emergency preparedness atjall of your sites.
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The enclosed copy of our report identifies' areas discussed;during theimeeting..
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g I believe this meeting was of great benefit to both organizations'. 'The NRC j,,
j views expressed at the meeting were those of my staff and I based on' our understanding of NRC policy and regulations.., A significant number of areas 'as ;-
i noted in the report will require NRC ' Headquarters clarification which we are.
j requesting.
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In accordance with 10 CFR 2.790(a), a copy of this letter and'the meeting d
report will be placed in the NRC's Public Document Room unless. you. notify this_
i office, by telephone, within ten days of.the date of this letter and's.ubmit'.
Q written application to, withhold information: contained therein within thirty,
days of the date of'this cletter., Such application must be consistent ~with the' y
j requirements of 2.790(b)(1).' If.we do not~ hear from you in this regard with'in the' specified periods noted'above, a copy of this letter and the meeting
[d report will be placed in the Public. Document Room.
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f' We will gladly discuss any questions you have' concerning this meeting.
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i Sincerely, j
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J' P.
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- Pape iel10, Chief l,
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Emergency' Preparedness and
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Enclosure:
Meeting' Report 1 '"
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- Nos. 50-237/85-02., ;50-249/85-02';
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' ~50-254/85-03,-50-265/85-03;
295/85-06,'50-304/85-07; i<
i 50-373/85-04, 50-374/85-04; 50-454/85-03, 50-455/85-02;
- U 50-45.6/85-03, and 50-457/85-03 '
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DJ L. Farrar,. Director,;of Nuclear: Licensing
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'V.i.1. Schlosser, Project Manager
-.Gdnner Sorensen, Site; P.ro' ject Manager
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., M.i Wallace, Project Manager ;
p'9 10.:.Shamblin, Construction Superintendent j
J) Golden, Supervisor of Emergency Planning J. F. Gudac, Station' Su'perintendent.
R.E. Querio, Station Superintendent
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D. -J. Scott, Station Superintendent 1
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' G. tJ. Diederich, Station Superintendent j
.N..Kalivianakis,. Plant. Superintend'nt.
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,K; L. ' Graesser,. Statio'n Superintendent J.C. W; Schroeder,; Licensing and Comp.11ance a
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... Superintendent, T Desk (RIDS) j
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- DM/ Document' Contro 1
' Resident ~ Inspectors, RIII d
Phy111s' Dunt.on, Atto' ne General.'s' 'Of fice,
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Environmental Control. Division ij D. W. Cassel.:.Jr;,. Esq.
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Diane' Chavez,: DAARE/ SAFE
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Mayor', City of Zion.
l W. Pat'on,; ELD i
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Li 01shan, LPM,.NRR 4
D. Matthews,. EPB, OIE
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H W. Weave'r, ' FEMA Regi.on V
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1 M. Carroll,! FEMA Region VII
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1 U. S.-NUCLEAR REGULATORY COMMISSION.;
REGION III Report Nos.
50-237/85-02(DRSS), 50-249/85-02(DRSS);
50-254/85-03(DRSS), 50-265/85-03(DRSS)i
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j 50-295/85-06(DRSS), 50-304/85-07(DRSS);
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50-373/85-04(ORSS), 50-374/85-04(DRSS);
50-454/85-03(DRSS). 50-455/85-02(DRSS);.
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50-456/85-03(DRSS), 50-457/85-03(DRSS) 3 i
License!Nos. OPR-19,.DPR-25; Docket Hos. 50-237. 50-249-DPR-29,i.DPR-30; DPR-39.. DPR-48; l, i 50-254, 50-265; 50-295, 50-304;-
50-373, 50-374; 50-454, S0-455;.
NPF-11,1NPF-18; NPF-23,.CPPR-131; 50-456, and 50-457-CPPR-132,:and CPPRH133 ~
Licensee:
Commonwealth Edison Company Post Office Box 767 j
Chicago, IL 60690
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i Facility Names:
Dresden,. Units 2 and 3; Quad-Cities, Unils'l.and 2.;
.1 Zion, Units 1 and 2; LaSalle, Units 1 and 2; Byron,. Units 1 and 2;.and Braidwood, Units l'and 2 i;
Meeting At:
Region III 0'ffice, Glen Ellyn, IL i-h j
Meeting Conducted:
January 18, 1985 1
7 Meeting
Participants:
T P
J Date
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Approved By:
M. P.
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Emergency ~ Preparedness Section
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j Meeting Summary
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j Meeting on January 18, 1985 (Report Nos.' 50-237/85-02(DRSS), 50-249/85-02(DRSS);
4 50-254/85-03(DRSS), 50-265/85-03(ORSS);.50-295/85-06(DRSS), 50-304/85-07(DRSS);
1 50-373/85-04(DRSS), 50-374/85-04(ORSS);.50-454/85-03(DRSS), 50-455/85-02(ORSS);
j 50-456/85-03(ORSS), and 50-457/85-03(DRSS))
'l Areas Discussed:
A, special meeting was conducted to discuss' varfous items related to emergency preparedness,at all of your sites.
An agenda was d
presented by CECO represeritatives which is-attached to this reporti : The 1
meeting involved 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> by three NRC representatives.
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- Meeting Attendees 7
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Commonwealth ~E'diAo'n Coinpany i
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J. Golden,; Supervisor of Emergency Planning i
T. Backmon;. Lead. Emergency Planner, South Team
. i, R. Dwyer, Lead Emergency Planner,'NorthlTeam 4
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Nuclear' Regulatory Commission- '; Region III
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C., J. Paperielloj Chief, Emergency Preparedness 'and Radiological r
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' Protection Branch'
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- T ' p M. P. Phillips," Chief,' Emergency Preparedness Section l.'
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.T.' J. Ploski, Emergency Preparedness Analyst
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- - 2; Meeting Details-
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3 This meeting was held at the request of the licensee to discuss their j
2 emergency preparedness pror, ram.- 'The licensee presented an agenda', whichl' i
addressed the following:
Opening Remark'; Ceco Performance in Emergency lj s
. Planning;; Emergency Action Lev'els (EALs);' Exercises; Facilities;_and I '4 j 'j.
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. Miscellaneous. :A: copy of the agenda is attached.
Topics discussed are i
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' described below asthey were covered on the agenda.
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Opening Remarks.
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lMr. Gol' den described the highlights. of 1984 regarding Ceco i
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t activities in; emergency preparedness.
These included the
~ establishment:of a field ' office for the Illinois Emergency Services' b
'and Disaster Agency (ESDA); complete 44 CFR 350 approvals for all
. plants:except Iowa for Quad-Cities; preparation of the draft 3
Revision 5 to:the generic GSEP;~ and revision of the EOF /CCC.
implementing procedures.. In addition, ESDA and the Illinois t
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. " Department of. Nuclear Safety,(DNS) are working on a Memoraridum' of Understanding to define their respective responsibilities. ;Under d
c'urreht;IT11nois law, DNS. has many.of the responsibilities tthat
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ESDA~ isjcurrently fulfil. ling.
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1 For 1985 the licensee planned to obtain all unconditional approvals'.
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for the : Alert and Notification Systems from FEMA; complete i
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.p, laboratories in,each EDF for analysis of offsite monitoring team 0;!
' samples;: achieve a staffing *1evel of 18 not counting the six Station 1
!:j I GSEP Coo'rdinators; conduct unannounced exercises at some sites; R
! conduct' the Braidwood exercise, more for ASLB purposes than to mee'ti
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'. Appendix E requirements; and install a remote interrogation
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9 capability to determine siren malfunction.
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.To meet several commitments made to INPO based.on the results of i
g their audits, CEto: was dev' eloping a program to have' the GSEP Q
Coordinator at esi:h site review or audit the surveillance done' by -
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other groups on;eiguipment; that would be used.iri an' emergency (e.g.,
l containment high range mon'itor maintenance and calibration, HRSS, i
,etc.).
This was to be dis' cussed with the Statiori GSEP Coordinators in approximate 1f two to th'ree months.
In additio'nilCEco. corporate l.
I representatives.will audit' train.ing courses related. to: EP idone by, the Stations orjProduction[ Training Center, and observe other
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also intend to' chserve other utilities exercifes,. e;. Ceco' p'ersonne1 f
non-Ceco exercises as partsof the. INPO audit team.
j specially wh'en O
1 NRC participation is expected.
Plans were also underway.to have the.
President of the company establish a policy ta,sking each Department.
1 Head with the responsibility to ensure their staff'slattendance.at required emergericy. preparedness training courses; '
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Mr. Golden then presented l a ' diagram of the lichnsees' cdrporate emergency preparedness staff structure.
Mr. Paperiello 'f the NRC 1
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then presented a similar. diagram,of the Division.of Radiation Safety :
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and Safeguards. - A copy of!the divisional. organization chart is
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included with ~this report' i.
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Discussion of CEto Performance ~
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l CECO representatives were concerned about what they 'perce'ived to be j__
a continual' change in theme'g'ulatory basis for the~ evaluation of 1 {"B adequacy of licensee Joint:Public Information Ce'nters (JPICs), and a j
lack of guidance on what' was required involving both FEMA and NRCi
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evaluations.
Specifically; they wanted to know the basis.of j
j evaluations.. They suggested. the cr.eation of a State, NRC,. FEMA,-
i Utility task" force.to determine what was acceptable.
CECO
1 guidance and evaluation criteria. NRC representatives stated that :
j guidance and ; eval.uation c' iteria were available on what was expected r
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in a JPIC..This. consisted of. appropriate sections of;the appraisal' a
and exercise inspection. modules., and guidance for Emergency. News Center forjNuclear Power Plants. 'As agreed during~the meeting,
these documents' have beert enclo' sed with this inspection. report. NRC i
l representatives.also 1ndicated that' they would be willing.to, participate in a ~ task force to discuss JPIC improvements.
-1 gj As part of a coeuritment to INPO,.'the licensee was developing a 3
training matrix 'and course ' structure for all emergency. response d
organization ' personnel.
The goal for meeting the INPO. commitment Fj was to have the first iound of this training completed by O'ctober, p
1985.
d 7,j With regard to real events,: NRC concerns primarily deal Yith' timely a
classification.and notification.
The information flow from Ceco to N
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,i the:NRC Duty Officers in generalgis satisfactory.
One concern 4 'h mentioned was that if the NRC decides to utilize'.the HPN circuit to
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. obtain health physics data, someon'e from the' licensee's organization j
would:be. required to man.the phone. and provide this data.
Another
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concern dealt with being. told to change emergency classifications.
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j by,the NRC Duty Officer either from. Headquarters or the Regional 1
office.; They! specific' ally pointed to the LaSalle event in' August i '.
l 1984 'in'which,the. Shift Engineer!was persuaded by the regiunal: NRC 3
Duty Officer or. Section Chief into, declaring an. Alert although' the 4
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Shift' Engineer!belfevedheldidnot'havean. emergency.
The major G
concern was who classifiesf the emergency the licensee, State,.or NRC. This is.:further'. discussed under EALs below.
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t Ceco wanted to'know...what:they'could do better during exercises. They
.;3.,,. ' s.h 1:
ex'ressed'some difficulty:in; sorting out the various categories p
" ' J, of findings; identified.in.exercisejreports.
NRC defined thelvariousl~
categories of findings as'follows: I(l)' Weaknesses (referenced in.
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Appendix E of Part'50)'were items 'which required correction and thusl j
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a forma 1' response was requested; (2) Deficiencies (referenced in' ~
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50.54(s))'.were items that must be corrected because they indicated a.
3 substantial breakdown in the ability of the plan to protect ' ublic.
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health and safety; (3) Open Items were areas of NRC concern:that.
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.'should be a~ddressed by the.. licensee and corrtected because they couldl
'hampeiemergencyresponse,andaresponsewasnormallyrequestedon;'j.
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d their correction; and ;(4) Improvement Items were areas where the.j "
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' NRC. felt the ilicens.'ee's program could be improved. This last ql g. m licensee to'look at the item and take whatever action they fait wasi 1
- category could be thought of,as an ' rea where NRC expected the-a
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i appropriate.,: No written. reply. to improvement items would be i
q requested.:
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.. Ceco was' also, trying to. develop a policy for participation frequenc'y:.
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- for. key;'esponse and support staff.' NRC stated in their opinion key' r
L.j individual,s should participate in an exercise at least once every a
t.
two years :in some related role.
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, (. ' ca.. Emergency Action Level'f(EALs')
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Ceco Y.epreserd.atives proEided a proposed plan revision for-the' lll generic GSEP which would! delete all of the EAL tables from the j
generic ~ portion of the. plan"and add a paragraph that would indicate:
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that each site specific annex would contain a table of EALs.
NRC j.
.j. representatives, stated that this appeared to be acceptable since all j
site: annexes currently have~ EAL tables, and these are really the -'
4 1
EALs. evaluated for acceptance rather 'than the generic tables.
The" d
licensee also indicated that a draft of the LaSalle EALs was '
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- .scurrently. undergoing onsite review and should be issued shortly. :j t
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[lCECo:als'o; hoped to get PWR EALs standardized by June 1985.
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CECO representat'ives then requested clarification! on who thad final 1%
authority l on EALs,:bothLfrom the standpoint of approval, :and their 1
!. 9 Specifica11 ;; who approved EAls, the NRC 'or-the iState; and.
use.
what happens whenione agency states something. opposite th~lother.
e a
According to the 1,1censee.j I111nois DNS representatives '.and stated l
M that they disagreed.with some of,the EALs and wanted themichanged, L8 even though they apparently met the guidance ' inia'pp'endfil of
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NUREG-0654, Revision 1..nditheir change appeared,'to7 result. in ov r.
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classification.,, Ceco did not want to negotiate. with' NRC; State,. and, I-g local governments becauseof the; potential fon different'EALs' for h,
different' sites for the: same events.
Several1,"whatif% scenarios u
were then' mentioned. regarding various combinations o'f two, out.of three agree.
Finally, guidance was requested 'on how. negotiated EALs a:l q
would then get' i.nto the. plan if the plant in q'uestion disagreed..
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q li NRC representatives. suggested that all parties!be.'i'nvolved in the l,
j review of proposed. changes [to the.EALs (e.g.
NRCr plantI,: corporate',
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4 and State), arid. stated that they would request gu1 dance from NRC,
'I Headquarters regarding the. differences between th(terms:" agree" 1
used in conjunction'with the State and " approve"'.usedliniconjunction :,
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with the NRC inEsection. IV.B of Appendix E to 10.CFR Part 50. NRCi
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personnel also stated that j.his was the kind of.ldis'cussion,that ' '
1 1
should be carr.ied;out whenilicensees met with State.and 1.ocal J.
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governmental agencies to annually review EALs as,' required.
0 Regarding accident classifications, Ceco requestep.some.;,
.e clarification on who has the' initial responsibility, 'who has the O
subsequent' responsibility, !and' does the State or! NRC. have :the authority to change a classification made by a responsible. licensee
]7 individual. NRC representatives stated that it appeared from th'.
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text of Appendix 1 in NUREG-0654, Revision.1 that.the: State did have '
I the authority to. revise;an ' emergency classification; however, the licensee is always responsible' for the initial classification. NRC qj personrrl also indicated that: Michigan law allowed the State' t.o l
1 reclassiiy events., and.this was addressed in the 0.. C. Cook emergency plan.
The licensee;was provided with a cop 9 of the i
,j.
appropriate pages from the Cook plan which addressed this issue.. NRC d
will obtain Head' quarte'rs guidance -on whether Stateireclassification:
i was intended :to. 'verrul.e licens'ee classifications. ', Reg'arding NRCl N
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reclassification o;f emergencie's, NRC personnel stated. in their.
j opinion that we should not classify or reclassify an emergency for M
the licensee 'at the Duty Offic.er level or Section Chief level; y
however, if Senior NRC Management,' namely the Regional ~' Administrator cr his alternate, felt'that a reclassification was warr' anted this 4
1 may occur after discussions'.with the senior utility repres'entatives i
at the time of the; event. However, NRC would have~to exami'ne; wha.t a M
reclassification would' gain-Ceco, representatives were'.also concerned that if the NRC expected. a different classification suc'h
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as an Alert and dispatched a team to the site, they would'no't find y
any,ERFs acti,vated.
They~were concerned that this type.ofs,
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disorganized'. response was not what was intended by the upgrading of
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emergency prepar'edness after THI. ;NRC representatives showed the A?
- licensee the revised NRC Regio'nal. Duty Officer procedure which n
,i s; clearly indicated..that NRC ' Duty.0fficer would not reclassify an j
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emergency,; but would. base his respo'nse on the perception of the.
events occurrjng at the plant..Mr. Paperiello stated in his opinion 9
d-that only'.the! Regional. Administrator or his' alternate should pursue "li
^
4-the' reclassification ; issue for 'the NRC.. NRC personnel stated that this type. of.jiscussion shou' d also be included lin the annual lreview
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'of EALs with'offsite agencies required by Appendix E.
Region lIIIwill 4'
4 seek clarification of. this issue from NRC headquarters.
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Exercises' i L
.n. h Ceco representa'tives, requested that NRC personnel attend scenario.
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.E p1'anning' meetings' as they:had in: previous years rather than listen y
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in using-a conference call. (They were also concerned that the FEMA
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personne1'who would be. evaluating the. adequacy of the scenario, a"
namely person'nel from INEL,' should be'in attendance at the meetings that. established the scenar.io.
NRC personnel stated that asia 1.
result.of the.0MB proposals to reduce the deficit, travel funds. had 'il 1
j
,been severely; cut back, and therefore NRC would not be able to attend!
4
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.the scenarioidevelopment meetings this fiscal year, but would have
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to ' participate via'a; conference cal.1 Although we agreed with'the a,!.
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. licensee's concern.regarding attendance by INEL at scenario developmen.t'. meetings, NRC suggested that this topic needed to be
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j discusse'd 'whh FEMA.
Licensee representatives stated that it'was,!
Q their position that once t5e. scenario: development meetings had beenl -
Q held and agreement reached 7on the content of the scenarios, nof j
further ' hanges should be made to source terms or other items which' l -
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.had been discussed at these meetings.
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The li'censee requested clarification on FEMA's role with the onsite '
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- scenario.
In:the case' of FEMA Region VII, the licensee had,been
' requested 'to make substantial changes to the scenario based;on si 4
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perceived' iodine filtration efficiencies and other characteristics.
A which; had been evaluated by. the FEMA contractor, and subsequently '.
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- FEMA:had requested the licensee directly to modify the scenario.
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NRC was not a. party to the discussions, and became aware' of them d
after being informed by the licensee.
NRC personnel agreed with the d
licensee's position, and : stated that NRC's comments 'on the proposed; 9
revision to FEMA Guidance Memorandum 17 specifically stated that all-d
^
communications with the licensee would be through the NRC rather than' Lj
.directly by FEMA. This matter will also be brought to the attentidri-j j
- of. NRC. Headquarters and a'n NRC position on this issue sought..
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Based on a December. 14, 1984 letter from NRC Region.IIIito the
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licensee, the licensee had: been under the impressf ori 'that.
5 if participants,in exercises'were not to see the scope'or objectives l}
for the exercise. :The licensee disagreed with this postion,-
1 1
although they'did: agree that no form of the scenario.shoul.d be i
. revealed to participants..rNRC ' personnel clarifie'd this position by 1
endorsing that of the licensee.
1 l
Iowa performance in exercihes was ! discussed. lyENARegionVIIhad E
i statedthatthey'hadaproblemwithstateperformance.,'andithat' based d
j' on their list of sxercise objectives to be demonstrated.. Quad-Cities,
o would likely involve Iowa participation.
CECO. stated that they were J
aware that FEMA VII' wanted Iowa participation,ibut. Iowa'.wasi I
y challengingthefindingsthat;certainelementsjhadnotb'een j i [;..
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demonstrated.
F.inal resolution on the status of Iowa.pa',rticipation:
q was still' pending according to the licensee.
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Licensee: personnel asked about!the possibility of' substituting real U
i events for an exercise,.such as what was done'at~VermontiYankee.
-E NRC personnel indicated that s'uch 'a substitution Vould. require an exemption from the requirements of Section IV.FJ.of. Appendix E to
]
10 CFR Part 50, and grantirig 1t' would be dependent on what type of i
exercise was expected at the. facility (fu11 scale,: partial:,..or
'i utility only), who partici;iated in the real event, whether all ERFs' were activated,; and.how close. the date of the real.i event'was to the i
j scheduled exercise date. :Further guidance on thistiteni would be 1 Q requested from NRC Headquar'ters, i.
1 The status of remedial drills for Grundy County and Illinois was'. -
discussed. According to the : licensee, FEMA was no lorige;r..
4 requiring a remedial exercise for Grundy County since they. were participating in the Dresden ;e~xercise.
Although the'licens~ee also stated that no'r'emedial exercise was now required'to' address'the i
Illinois finding.for the Quad-Cities exercise, NRC personnel noted A
that the report issued from the FEMA National office.i~ndicated that' j
such a remedial exercise would be held prior to January' 31,'.1985.,
'l CECO requested that NRC partici' at.e.at an exercise 'withithem.by at p
least sending a component.of the' Site Team to exercise, e.g...
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protective measur'es at one exercise, reactor safety.at another, J
etc. They also requested the.date of the next exercise'where NRC
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would be participating.
Ceco wanted to observe our participation.
NRC personnel stated that Region III would next be participating in the Callaway ' exercise on June 5,1985; and that we would' examine the possibility of particip'ating more frequently with a smalli Base Team j
component and a.few people in.a Site Team.
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j The logistics and arrangements for unannounced exercises were discussed.
Currently, LaSalle and. possibly(Quad-Cities exercises '
} pA would 'be' unannounced, with only the month being known.
NRC representatives stated' that the logistics of site arrival and access.
~
could be sorked out far enough in.~ advance to preclude possibilities' of advance knowledge:of exercise initiation.
Ii ij CECO wanted to know the status of the transportation exercise.
- I planned for.NRC and the State of Illinois, and whether it would be i
worth wa'tching.
They were thinking about the possibility of using a
~
transportation eve ~nt asi anlexercise, since their plan specifically F
3 addresses transportation. accident emergencies.
NRC stated that the.
3 current projected:date fo'r the drill was mid-April, and the date may j
' slip depending on jthe completion status of the: new NRC Headquarters
~
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Operations Center.:
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Regarding tihe' future of :off-hours 'eMercises, which the licensee. hopeif.
J would be deleted, NRC stated that there was no foreseeable intention..
~l to delete the off-hours exercise requirements; however, the time period specified may be expanded, and the need to conduct exercises -
under varying weather conditions would be removed.
These proposed I
changes wouldinot be.made until the' next revision of NUREG-0654, j
which was not'. planned until issuance of the revised emergency j
' planning rule.; Revision of this rule would not probably occur.untilj,'
q the' revised. source term studie's were completed.
i
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Facilities <
.).
g The licensee discussed the ' requirements and need for ENS /HPN
.a j
s surveillance. ' NRC stated that the licensee must perform the surveillance,! and this would be doEumented'in a forthcoming -
j
-Information Notice.
The licensee stated that this could pose a
]
considerable manpower ~ drain if all HPN phones at all locations: for i each facility had to be tested every month, and that for several of g
l their facilities, no HPN phones had been installed.
In addition, 1
the licensee had never been.provided with the codes (phone numbers)'
]
to use;to' contact anyone.iis~in'g the HPN phones, and the last.~.
correspondence they had received stated that they were not.to luse the phone ~unless contacted by' the NRC.
NRC representatives' stated.
that the Information Notice would spell out how to test the' phones,
and when they were to be 'used.
In addition, NRC Headquarters would j
- be contacted regarding' th'e lack of HPN phones at all facilities.
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.,'; Ceco also. wanted to obtain a master copy of the ENS form, or eventi1'.
notification form.
This form is located in the NRC emergency plan;,
4 O
which the licensee has.
NRC personnel stated that the form in the','
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. plan is; also a copy, but that the new Regional Supplement will i.
contain'.a better copy of the form since it is being printed ratherh.',
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th'an c~ople'd.
A copy of the revised event notification form is 1
3 enclosed with this report.
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The licensee wan.ted to know the status of the ERF. Appraisal-program. 'NRC representatives ~ stated that although : budget reduc'tions j
3 j
may have an, impact on this program, there was no intent,to: eliminate m @'
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this program..However,.no' ERF Appraisal would be' scheduled -until i
the licensee felt-that their ERFs' were complete ~, :and. the dates l
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specified in' the.1,icensees Conf.irmatory Order hid passed 2 Since A
all. dates for. CECO. facilit'ies were in 1986, no' ap'pruisals kould be
'.i j
sheduled duringjth.is fiscal year. for their facilities.!!
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The 11censee 9teted that.they were in the protesis off. redesigning:
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their EOFs, and would welcome NRC. input into this'pr.ogram now rather t,
1 than wait until it!was' completedi: Mr. Barr and Ms. Nellis 'were'
~
j handling.this program. 'NRC stated that after 'the issuance of ' n
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Information Notjce'. which.should: be coming out[ shortly,lthat j
described the. Expanded Activation ' Site Team and outifned logistical:
j 2
considerations for.its use', NRC Region III would.be: sending their
.. ~.
Emergency Response Coordinator out to review ex,jsting. fai:ilities to 1
1
' l determine whether they would sieet NRC's needs, and 'make recommendation's 1
]
for better interaction betseen NRC Site Team 'an'd: utility'ip' rsonnel; In
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the interim, NRC would work,with the licensee to Mdentify improvements
,l which would enhance;NRC/ licensee, interaction and' communications.
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l The licensee. requested'12 copies'of the Regional 'upplement to
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NUREG-0845 (NRC Region. III Incident Response Pla'n)'so that lthey4.,
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would be available at each' EOF, the CCC, and each TSC.. NRC' agreed
,!.I!
11 toprovidethe.requestedcopTes;totheEmergencyjPlanning Document
'F Control C1'erk.
In accordance with Illinois law, the licensee is developing' ~a i
Nuclear Data Link which will, provide real time dataito the Illinois 7'
't Department of Nuclear Safety:(IDNS).
System capability.is to be
.]
installed at. Zion by March.1985, however, interface.protilems between q
the licensee computers output [and the IDNS computer; input format is.
delaying implemeritation of. the, program.
The licensee. contact for this program in Mr. Larry; Duchek.' ' Data transmitted will be. raw,
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non-edited data,.unlike the system used by Duke Power. NRC,;
's personnel indicated that they:.had mentioned the possibility.of d
linking tie' Emerjency Response Data. System (ERDS) un'deridevelopmen',t at NRC Headquarters with the Ceco : system, and thatthe NRC point of A
contact was Mr. Ken Perkins of the Incident Response Branch.
Licensee b}
representatives ~ stated;that if, the NRC was reallyL int'erested in this program, they;should contact Mr.. Duchek as soon as possible so' that.,
y the NRC could be involved in the development of. the ;syste's.
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'i The licensee requested, clarification on the :need. for agreement letters with Federal agencies. :The NRC position was that agreement 1etters were not.necessary with federal agencies who were legally
. required to respond based.on Federal law;.however, agreements,were a
necessary if.the agency was: expected to provide. assistance not i
required by law; :For example, a:. letter of agreement with the.U. S.
L i
..1 the Corps provided information on' river level which was used to l
' Army Corps of Engineers was necessary for the Dresden facility sjnce
{
f)j determine emergency action' levels.
u a
The;11bensee'. proposed the exc'hange ;of liaison representatives 1for t-il
~
j actual events '.with the Base Team. '. NRC personnel stated that :there t
i j
t i, was.no need to send personnel to 'the regional Incident Resporise.-
1 1
Center since 'the Base Team would ' essentially be disbanded within i
H several hours and all personnel would report to the site as part of the expanded site team.
'~
l The'11'censee requested 'information on the, status of the Federal l
j Lj Response Centers (FRCs) which would;be established by FEMA a'nd.the,'d
.1 Federal Radiological Monitoring and Assessment Centers (FRMACs) lJ i
i
. which would 'be established by DOE.
NRC personnel indicated that l
?they had also requested information1on the status of these centers j i
fromtherespe'ctiveFederalagencies;buthadreceivednoreplyor,j!.
information; ; The 1.icensee was informed that when such information '
becameavail.able.it!wouldbeincludedinSectionIIIoftheregional1:
?; (%}'.
. g incident response plan.
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- The licensee: requested' info'rmation.pn.'the status of the Federal
)
j Radiological Emergency Response Plan (FRERP) and its implications 1.r>
i NRC Region III.
NRC personnel stated that the FRERP had been
- incorporated into the next revision' of the regional incident j
response plan, which should be available for distribution by the end d
of February 1985.
i:
~
The licensee requested' clarification on the status of the FEMA 43
?
i-
. t'esting.and exercise participation, especially with regard to' j
offsite: liability issues l.i NRC personnel stated that this area was-n beyond :o'ur scope, and suggested that they discuss it with the ' State-
?.j
. and/or appropriate FEMA. region.
l 7
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I' Miet'ing Agendai 2
Q 2.
Region III: Division of Radiation.
d
- Safety and Safeguards Organization Li
' Chart-..
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3.
Guidanceffor! Emergency News Centers fd.
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for Nuclear Power Plants 3
4.
Event Notification Form idl lj
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