ML20248D325

Forwards Summary of Comments on Action Items Arising from Critique of Plant Alert on 890307-08,per

ML20248D325
Person / Time
Site:	Mcguire, McGuire
Issue date:	08/01/1989
From:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Tucker H DUKE POWER CO.
References
NUDOCS 8908100356
Download: ML20248D325 (4)

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. . AUG 0129 m Duke PowerICompany ATTN: Mr. H. B.: Tucker, Vice President Nuclear Production Department 422 South Church Street-

' Charlotte,- NC 28242 Gentlemen:

SUBJECT:

NRC FOLLOW-UP ON MCGUIRE ALERT (MARCH 7-8,1989) CRITIQUE ACTION ITEMS T This refers to your letter of April 4,1989, addressing the Duke Power Company.

-McGuire Alert critique with selected members of the NRC Regional staff on.

March 14,.1989. The enclosure summarizes our. comments regarding the action g ' items arising from the critique as listed in Attachment 1 to your letter.

, ~ W. H. Rankin,. Chief. Emergency Preparedness Section, ' Region II, will serve as primary contact for the _ action items you - propose in your letter' and for I coordination of a: drill with communications emphasis as deemed necessary once your changes are-in(place.

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.It' isiourLopinion thah the McGuire Alert critique was beneficial and should-

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result . in improved coordination of our joint response ' to future emergency J. = situations.

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. ~ l Should you have any. questions concerning this letter, we will be pleased to discuss-them.

Sincerely, k Stewart D. Ebneter Regional Administrator

Enclosure:

Comments on' McGuire Alert Critique Action Items cc w/ encl: /

T. L. McConnell y State of North Carolina bec w/ enc 1: .l Document Control Desk  ;

.D. Hood, NRR l

.W. Travers, NRR Senior Resident Inspector q RII C RII RIf RII ACunningham WRankin DCollins Stohr n 2" N '

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k ENCLOSURE Comments on McGuire Alert ~ 'itique Action items

1. Communications The following comments on communications are provided in order to better clarify the NRC's emergency communication needs and to asrist you in defining needed emergency communication links.

The McGuire Alert critique stated, and we concur, that the effectiveness of communications between the Regional Incident Response Center (IRC) and .

the licensee's Technical Support Center (TSC) demonstrated during the incident requires improvement. This finding was listed as a critique action item.

Duke Power Company's planning for providing the NRC ir. formation during the event apparently did not contemplate fully the amount and, to some extent, the type of information the NRC would require during our state of

" enhanced readiness." During the event, the NRC experienced some difficulty obtaining details of the progress of the event and the licensee's response to the event through the Emergency Notification System (ENS) phone line, particularly details associated with the reasons for performing or not performing certain actions. As a result, there was a need, at times, for the NRC to communicate directly with the ;icensee's Emergency Coordinator. It is likely that during an event that has proceeded to an ALERT, the NRC will require detailed information on the plant status and the licensee's response to the event even if the NRC does not enter Standby. This may include the need for information on the bases for certain actions. A licensee should include, in their emergency  ;

procedures, training, and staffing, a provision to provide such details.

In addition, after the NRC resident inspector arrives onsite, he should be kept fully informed of decisions and the bases for such decisions on a real time basis. The resident inspector's role is to monitor a licensee's response to an event and his role should not be to provide information to the other NRC components on a continuous uasis. Some licensees have found it useful to f ax to the NRC their emergency response data sheets as t' -

are distributed to their onsite organizations.

It is our understanding that Duke Power Company plans to provide a procedure requiring designated trained TSC contacts to directly respond to and coordinate communications with the NRC during emergencies. Personnel selected will have a technical background equivalent to at least a Senior Reactor Operator, and demonstrate required knowledge of Duke Power Company's reactor operation and emergency procedures. Additionally, contact personnel should keep the Emergency Coordinator informcd regarding communications with the NRC, and upon request, make the '.mergency Coordinator available within a reasonable time to communLate directly with the Regicnal Incident Response Center Base Team Mansger. It should be recognized that the NRC's primary function during emergencies is to L _ - - _ _ _ _ _ - _

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<; Enclosure 2 monitor the ' licensee's actions, and to maintain a full- awareness of all information and plant changes attending such emergencies.

We concur with Duke Power's planned establishment of a specific l

-communication link, other than the TSC Emergency Coordinator, to respond to L Regional questions, requested clarifications, and information.

L Implementation ' of this ; follow up action will allow the Emergency Coordinator to fully maintain command and control 'of the TSC and direct'

! requireo efforts toward accident assessment and mitigation.

L 2.- Radioactive Release

s The critique action item addressing radioactive release (s) during the McGuire Alert relates'more directly to the presence of. releases, release frequency and intervals, and the routine reporting of releases on emergency notification forms used for notifying the State and counties.

The NRC continues to express concern that following.. issuance of the initial notification of Alert, additional releases were not explicitly reported ~ in followup Notifications. It was noted, however, that the

. subject action item placed major emphasis on definition of the term

" radioactive release" during emergency situations in order to preclude misleading the State, counties, and public where such releases were within specific limits.for normal operation under the McGuire Station's Technical Specifications.

The Duke Power Company agreed in the McGuire Alert critique to define

" radioactive release" as it relates to accident conditions, and to determine how such informath n should be entered on Emergency Notification forms and press releases. u was further requested that the NRC consider providing generic ' guidance to .the industry on the definition of

" radioactive release" under emergency conditions. In response to the subject request, Region II has determined that the reference guidance is currently available. Revision 1 of NRC Regulatory Guide 1.21 (" Measuring, Evaluating, and Reporting Radioactivity In Solid Wastes And Releases Of Radioactive Materials In Liquid And. Gaseous Effluents From Light-Water-Cooled Nuclear Power P1 ants") provides adequate definitions of radioactive releases including unplanned and/or uncontrolled releases or radioactive material from the site boundary. Duke Power proposes to i define a reportable " radioactive relcase" during emergency conditions as one which exceeds regulatory limits, or an unplanned release below

. assigned regulatory limits. The cited definition is consistent with

" abnormal release" as defined by the referenced Regulatory Guide which requires quantification of radioactive releases and reporting of same in the Semi-Annual Effluent Report. It is our opinion that quantifiable unplanned radioactive releases which are within regulatory limits for normal plant opert. tion should be reported on Emergency Notification Forms and in press releases during emergency situations. Additionally, such entries should document that protective action responses are not required.

Current Emergency Notification Forms provide for the entry of such I protective action recommendations.

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Enclosure- 3 l

3. Coordination of News Conferences and Press Releases The NRC reconnizes the importance of holding joint news conf erences with i licensees and coordinating news releases during emergencie . During an i

Alert emergency classification, and prior to the arrival of an NRC Site i Team, logistics may present a problem regarding joint news conferences.

However, the Region has in place a procedure which designates the Regional Public Affairs Manager to coordinate public affairs activities with the licensee and other involved organizations. It should be noted that the Public Affairs Manager, or a person designated to act in that capacity, is included in the NRC Site Team when dispatched.

Prior to arrival of the NRC Site Team, the Pegional Public Affairs Manager or his designate would be assigned to review and coordinate (via telephone) with Duke Power's Public Information Division elements of the planned presentations at press conferences. News releases can be reviewed and commented upon by the Public Affairs Manager prior to dissemination to j the media, through use of' facsimile r.nd telephone communications. This j approach should readily ' satisfy required joint coordination of public  !

affairs issues during the period prior to the deployment and arrival of the NRC Site Team. Mr. Ken Clark of the Region 11 staff is available to assist you further in this matter.

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