ML20038B569
| ML20038B569 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 11/19/1981 |
| From: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Brons J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| Shared Package | |
| ML20038B570 | List: |
| References | |
| RTR-NUREG-0654, RTR-NUREG-654 NUDOCS 8112080408 | |
| Download: ML20038B569 (9) | |
See also: IR 05000286/1981005
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NOV 1 9198)
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Docket No. 50-286
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Power Authority of the State of New York
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Indian Point 3 Nuclear Power Plant
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ATTN: Mr. J. C. Brons
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Resident Manager
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P. O. Box 215
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Buchanan, New York 10511
Gentlemen:
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Subject: Emergency Preparedness Appraisal'50-286/81-05
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To verify that licensees have attained an adequate state of onsite emergency
preparedness, the Of fice of Inspection and Enforcement is conducting special
appraisals at each power reactor site.
These appraisals are being performed
in lieu of certain routine inspections normally conducted in the area of
emergency preparedness. The objectives of the appraisal at each facility are
to evaluate the overall adequacy and effectiveness of emergency preparedness
and to identify areas of weakness that need to be strengthened. We will use
the findings from these appraisals as a basis not only for requesting individual
licensee action to correct deficiencies and effect improvements, but also for
effecting improvements in NRC requirements and guidance.
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During the period of May 11-15, 1981, the NRC conducted an appraisal of the
emergency preparedness program for Indian Point - Unit 3.
Areas examined
during this appraisal are described in the enclosed report (50-286/81-05).
Within these areas, the appraisal team reviewed selected procedures and repre-
sentative records, inspected emergency facilities and equipment, observed work
practices and interviewed personnel.
The findings of this emergency preparedness appraisal indicate that certain
corrective actions are required in your emergency preparedness program. These
are discussed in Appendix A, "Significant Emergency Preparedness Findings", and
in summary include the following:
1)
Provide a formalized documented training program.
2)
Provide sufficient space in the Emergency Operations Facility.
3)
Provide additional emergency procedures and improve completeness or clarity
in others.
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8112080408 811119
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PDR ADOCK 05000286
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Power Authority of the State of
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NOV 1 91981
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Based on telephone discussions betweer you and Messrs. Gary L. Snyder and
Robert J. Bores of this office on November 10 and 12, 1981, we understand that
you have completed the required improvements for items 1.a,1.c, 4 and 7 of
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Appendix A of this letter. With regard to item 10, we understand that these
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improvements will be completed by November 30, 1981.
For items 1.b, 3, 5, 6,
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8 and 9, we understand that your improvement actions will be completed by
January 15, 1982. With regard to item 2, we understand that the new EOF will
be operational by December 1, 1981, and that the new Alternate EOF will be
operational by December 21,1981. _ Please confirm that the actions specifjed
for items 1.a
1.c, 4 and 7 have been completed. Additionally, if our under-
standing of your proposed actions for these items is not correct, please
inform this office within 5 days of receipt of this letter. You are also.
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requested to inform this' office in writing when the aforementioned actions for
items 1.b, 2, 3, 5, 6, 8, 9 and 10 have been completed.
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The findings of this appr'aisal also indicate that there are areas for improvement
in your emergency preparedness program. These are discussed in Appendix B,
" Emergency Preparedness Improvement Items".
In conjunction with the aforementioned appraisal, emergency plans for your
facility were reviewed by the Emergency Preparedness Licensing Branch. The
results of this review indicate that certain deficiencies exist in your emergency
plan.
These are discussed in Appendix C, " Emergency Preparedness Evaluation
Report".
Appendices A, B and C of this. letter contain an inclusive listing of all
outstanding emergency preparedness items at your facility at this time.
We recognize that an explicit regulatory requirement pertaining to each item
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identified in Appendices A, B, 'and C may not currently exist. Notwithstanding
this, you are requested to submit a written statement within thirty (30) days
of the date of this letter, describing your planned actions for improving each
of the items identified in Appendix A and the results of your consideration of
each of the items in Appendix B.
This description is to include, (1) steps
which have been taken, (2) steps which will be taken, and (3) a schedule for
completion of actions for each item. With regard to Appendix C, you are
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requested to provide to this office within 120 days of the date of this letter,
page changes to the emergency plan correcting each deficiency or provide
written justification as to why you believe a revision should not be made.
Copies of these changes are to be submitted in accordance with the procedures
delineated in Section 50.54(q), Part 50, Title 10, Code of Federal Regulatons.
This is to inform you that if the deficiencies listed in Appendix A are not
corrected by the dates agreed upon, the Nuclear Regulatory Commission will
determine whether enforcement action is appropriate.
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Power Authority of the State of
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NOV 191381
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In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of
this letter and the ene.losures will be placed in the NRC's Public Document
Room.
If this report contains any information that you (or your contractors)
believe to be exempt from disclosure under 10 CFR 9.5(a)(4), it is necessary
that you (a) notify this office by telephone within ten (10) days from the
date of this letter of your intention to file a request for withholding; and
(b) submit within 30 days from the date of this letter a written application
to this office to withhold such information.
Section 2.790(b)(1) requires
that any such application must be accompanied by an affidavit executed by the
owner of the information which identifies the document or part sought to be
withheld, and which contains a full statement of the reasons on the basis
which it is claimed that the information should be withheld from public dis-
closure. This section further requires the statement to address with specificity
the considerations listed in 10 CFR 2.790(b)(4). The information sought to be
withheld shall be incorporated as far as possible into a separate part of the
If we do not hear from you in this regard within the specified
periods noted above, the report will be placed in the Public Document Room.
The telephone notification of your intent to request withholding should be
made to the Supervisor, Files, Mail and Records, USNRC Region I, at (215)
337-5223.
The reporting requirements contained in this letter affect fewer than ten
persons and therefore are not subject to Office of Management and Budget
clearance as required by P.L.96-511.
Should you have any questions concerning this inspection, we will be pleased
to discuss them with you. Should you have any questions concerning the items
of Appendix C, please contact Mr. R. Priebe, Emergency Preparedness Licensing
Branch at (301) 492-9695.
Sincerely,
Origina1 Signed B7:
Ronald C. Haynes
Director
Enclosures:
1.
Appendix A, Significant Emergency Preparedness Findings
2.
Appendix B, Emergency Preparedness Improvement Items
3.
Appendix C, Emergency Preparedness Evaluatten Report
4.
Office of Inspection and Enforcement Inspection Report Number
50-286/81-05
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Power Authority of the State of
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NOV 191981
cc w/encls:
George T. Berry, President and Chief Operating Officer
J. P. Bayne, Senior Vice President-Nuclear Generation
C. M. Pratt, Assistant General Counsel
A. Klausmann, Vice President, Quality Assurance
D. Halama, Quality Assurance Superintendent
J. F. Davis, Chairman, Safety Review Committee
K. Burke, Director, Regulatory Affairs (Con Ed)
J. Thoma, Project Manager
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
State of New York
bec w/encis:
Region I Docket Room (with concurrences)
Chief, Operational Support Section (w/o encis)
0FFICIAL RECORD COPY
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APPENDIX _A
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SIGNIFICANT EMERGENCY PREPAREDNESS FINDINGS
Based on the results of the NRC's appraisal of the Indian Point 3 Emergency
Preparedness Program conducted May 11-15, 1981, the following improvements are
required:
(References are to Sections in Office of Inspection and Enforcement
Inspection Report No. 50-286/81-05)
1.
Development and implementation of an emergency response training program
for qualifying individuals and groups who are selected for assignment to
each of the various functional areas of activity, including:
(See Section
3.1)
a.
medical first-aid, onsite and offsite fire response organizations,
post-accident sampling, the recovery organization, other augmentation
personnel, and the news media;
b.
provisions for training affected individuals in major plan, procedur<,
facility, equipment or organizational changes; and
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the means to verify attendee performance against training objectives.
2.
Provisions for sufficient space in the Emergency Operations Facility
(EOF) and Alternate EOF -to enable effective direction, coordination and
evaluation of all licensee activities during emergency conditions.
(See
Section 4.1.1.4)
3.
Development of plans / schemes and procedures for handling, storing, transfer-
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ring, analyzing and discharging post-accident liquid wastes.
(See Sections
4.1.1.8, 5.4.2.10 and 5.4.2.11)
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4.
Provisions for communicat. ions and other equipment needed to operate the
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News Center consistent with its designated functions during an emergency
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as well as for security at the News Center.
(See Section 4.1.4)
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5.
Development of unambigious Emergency Action Levels based on control room
and plant instrumentation and conditions, including appropriate references
between the Emergency Operating Procedures and the appropriate emergency
classification in the Emergency Plan.
(See Section 5.2)
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6.
Provisions for making protective action decisions based on current and
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projected plant status and conditions,
i.e., for accident situations in
which minimal radiological releases have occurred, but plant status, as
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evidenced from instrumentation, is deteriorating.
(See Sections 5.3 and
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Appendix A
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7.
Provisions for communicating protective action recommendations based upon
plant system parameters and/or radiological dose projections directly to
the local offsite authorities responsible for implementing protective
measures within the plume EPZ.
(See Section 5.4.2)
8.
Revision of Procedure HPP 3.4 to include:
pre-task supervisory briefings
concerning precautions and prerequisites to be observed based upon unusual
plant / radiological conditions expected and mission direction; provisions
for communication (with designation of backup means) of data, including
transmittal of original data sheets to the organizational element respon-
sible for assessment; provisions of data sheets to assure recording of
pertinent data relevant to the surveys; and provisions for labeling
collected samples for future identification and analyses, and for a
central collection point for such samples.
(See Section 5.4.2.3)
9.
Development of procedures for maintenance of security during emergency
conditions.
(See Section 5.4.4)
10.
Development and implementation of a program for dissemination of information
to the public and the news media regarding the actions to be taken by
individuals within the plume EPZ during an emergency.
(See Sections
5.4.7, 6.2 and 6.3)
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APPENDIX B
EMERGENCY PREPAREDNESS IMPROVEMENT ITEMS
Based on the results of the NRC's aopraisal of the Indian Point 3 Emergency
Preparedness Program conducted May 11-15, 1981, the following items should be
considered for improvement:
(References are to Sections in Office of Inspection
and Enforcement Inspection Report No. 50-286/81-05)
1.
Clarification of the interface between the corporate and site emergency
organizations as they pertain to the Plant Operations Manager.
(See
Section 1.3)
2.
Provisions for an on-call TSC Manager at all times.
(See Section 2.1)
3.
Provisions of written agreements with contractors for health physics
staff support for emergency conditions extending beyond 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
(See
Section 2.2)
4.
Designation of emergency preparedness instructor selection and qualification
criteria. (See Section 3.1)
5.
Provision of dedicated communication links from the TSC to State and
local government response agencies.
(See Section 4.1.1.2)
6.
Re-evaluation of the primary coolant sampling and analytical facilities
for adequacy assuming a 10 C1/g primary coolant source term.
(See Section
4.1.1.5)
7.
Provision of appropriate shielding for transporting collected containment
air samples to the radioanalytical laboratory and provisions for the
storage / maintaining of the samples obtained.
(See Section 4.1.1.6)
8.
Determination of the representativeness of post-accident airborne effluent
particulate sampling.
(See Section 4.1.1.7)
9.
Performance of an engineering study of the existing ARM system.to upgrade
post-accident radiation level mapping capability and to extend the upper
limit of detection.
(See Section 4.2.1.2)
10. Justification of the positioning of meteorological instruments mounted on
the primary tower or relocation of these instruments to conform to
(See Section 4.2.1.4)
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11.
Determination of whether 15-minute averaged data from the backup meteor-
ological tower reasonably represent information from the primary system
(i.e. , the site meteorology) and if not representative, appropriate
modifications to assure representativeness of the backup tower data.
(See Section 4.2.1.4)
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Appendix B
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12. Provisions for additional respiratory protection equipment for use during
emergencies.
(See Section 4.2.2.1)
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13.
Provision of direct means of communication other than land-line telephone
'(e.g., a radio system) from the EOF to offsite authorities to ensure
capability of communicating protective action recommendations in the
event that telephone systems are unusable.
(See Section 4.2.3)
14.
Revision of emergency procedures to incorporate the use of the New York'
State Police radio located in the control room.
(See Section 4.2.3)
15.
Provision of prepared messages for informing response groups including
State and local officials, during the initial notification sequence, of
the emergency classification and any protective action recommendations
based on current and projected plant status and conditions, as well as
radiological dose projections.
(See Section 5.4)
16.
Provisions for including pertinent railroad lines in the notification
scheme.
(See Section 5.4)
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17. Data sheets which include provisions for recording the date and time of
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each survey, the names of the technicans, the duration of the meter
readings, the instruments used by type and serial number, as well as air
sample count times.
(See Section 5.4.2.2)
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18.
Specification in Procedure IP-1005 and IP-1010 of the organizational
element to whom collected data and the data sheets are to be provided for
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emergency assessment. (See Section 5.4.2.2)
19.
Provision of data sheets for post-accident primary coolant sampling in
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Procedure RE-CS-042, Revision 2.
(See Section 5.4.2.4)
20.
Revision of Procedure RE-CS-042, Revision 2, to include:
provisions / pre-
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cautions for contamination control during post-accident sampling and
analyses; provisions for analysis of above samples if primary analytical
area has elevated radiation levels; provision of data sheets; and provisions
for transmitting the data, as well as, the original data sheets to the
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organizational element responsible for assessment.
(See Sections 5.4.2.5,
5.4.2.6, 5.4.2.7, 5.4.2.8 and 5.4.2.9)
21.
Revision of the post-accident sampling and analytical procedures to
include provisions for: valving diagrams and schematics; checklists for
assuring task completion; and labeling, transporting, handling and storage
of high activity samples.
(See Sections 5.4.2.6 and 5.4.2.8)
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22.
Revision of post-accident sample analytical procedures to include provisions
for analyzing high activity particulate and iodine samples.
(See Sections
5.4.2.7 and 5.4.2.9)
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Appendix B
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23. Revision of Procedure IP-1018 and other relevant procedures to detail the
method by which the Emergency Director is to orchestrate the REMP sample
collection and analyses, and to provide, as far as practicable, for
preplanned sample collection frequencies for various magnitudes and modes
of activity releases following an accident.
(See Section 5.4.2.12)
24. Modification of Procedure IP-1060 to include provisions:
to ensure that
all personnel leaving restricted areas or other areas suspected to be
contaminated and individuals in assembly and reassembly areas are monitored
for contamination; for maintaining records of all individuals checked for
contamination; for special considerations for skin contaminated with
radioiodine; and for ensuring that collected data are provided to the
organizational element responsible for radiation protection during emergen-
cies. (See Section 5.4.3.4)
25. Provision of specific instructions, guidance and criteria in IP-1020,
IP-1021, IP-1022, and IP-1054 to ensure the proper instruments and techniques
are used.
(See Section 5.4.3.5)
26. Procedural provisions for:
development and review of ad hoc procedures
for repair and corrective actions during emergencies; team practice of
corrective actions to be performed prior to entry into high radiation
areas; clarification as to how REAs are to be executed during accident
conditions; and use of a survey instrument for the team with a range
sufficient to measure radiation fields of 1000 R/hr or more.
(See Section
5.4.5)
27. Specification of specific criteria upon which the emergency classes will
be downgraded and for entering the recovery mode. (See Section 5.4.6)
28. Provisions for notification of Federal, State and local officials and
response organizations prior to entering a downgraded or recovery mode.
(See Section 5.4.6)
29. Verification and documentation that inventories of emergency equipment
designated for common use for emergencies at Indian Point Unit 2 and
Indian Point Unit 3 are correct and that routine equipment operability
checks were performed.
(See Section 5.5.1)
30.
Provisions for dating " call-in rosters" to ensure that the current revisions
are properly distributed and in use.
(See Section 5.5.3)
31. Coordination of the interface between the licensee and NRC Region I
through the Region I Emergency Preparedness Coordinator concerning the
work space and communication needs of the NRC emergency response organization.
(See Sections 4.1.1.4 and 6.1)
32. Provision of a written agreement with Consolidated Edison concerning
transfer of post-accident liquid effluents, if such transfers are considered
as an option.
(See Sections 4.1.1.8 and 6.1)
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