IR 05000313/1981022

App C to IE Emergency Appraisal Insp Repts 50-313/81-22 & 50-368/81-21,consisting of Emergency Plan Evaluation Rept

ML20055A637
Person / Time
Site:	Arkansas Nuclear
Issue date:	06/25/1982
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20055A633	List: IR 05000313/1981022 ML20055A632
References
50-313-81-22, 50-313-81-22-1, 50-368-81-21, NUDOCS 8207190271
Download: ML20055A637 (25)

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APPENDIX C EMERGENCY PLAN EVALUATION REPORT ON Arkansas Nuclear One Arkansas Power and Light Company Emergency Plan Dated July 1, 1981 EVALUATION SUMMARY The Arkansas Nuclear One Emergency Plan, Volumes I & II (hereinafter called

"the Plan" or the "ANO Plan"), dated July 1, 1981, was evaluated using the 16 Planning Standards and the 96 supporting criteria in NUREG-0654, Revision 1 (Regulatory Guide 1.101, Revision 2). The evaluation also included a review and evaluation of the information contained in: 1) the previous edition of the ANO Emergency Plan,_ dated January 1, 1981; 2) the AP&L Nuclear Contingency Plan & Procedures, dated July 29, 1981; and 3) the AN0 Emergency Plan Procedures Series 1903.xx, 1904.44, 2904.xx, and 1202.xx. The evaluation shows that of the 16 standards, one was satisfied, nine were satisfied except as noted, and six were not satisfie The rating of unsatisfactory was given to Planning Standards B, "0nsite Emergency Organization"; E, " Notification Methods and Procedures"; I, " Accident Assessment"; K, " Radiological Exposure Control"; M, " Recovery and Reentry Planning and Postaccident Operations"; and P, " Responsibility for the Planning Effort: Development, Periodic Review and Distribution of Emergency Plans."

The Planning Standards rated as unsatisfactory were so rated because the ANO Plan and related information failed to address the substantive points expressed in the Standards and in the evaluation criteria. The Planning Standards rated as satisfactory except as noted were so rated because the ANO Plan and related information failed to address, provided insufficient information about, or was unclear regarding some of the pertinent points enunciated in the Planning Standards' evaluation criteri Comments are made on each of the deficiencies noted.

i In the pages that follow, findings on each standard and its evaluation criteria are preserte A synopsis of criteria that are properly addressed is given, an evaluation of the degree of satisfaction provided by the Plan is made, and a set of comments noting deficiencies within criteria is provide ,

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II. GENERAL OVERVIEW COMMEN1S*

. The AP&L " Nuclear Contingency Plan" states cn\page 1 that it "... includes by reference the Arkansas Nuclear One' Emergency' ?lan and Implementing Procedures;...." Thus, it appears;that the AN0 Plan and Procedures are subordinate to the Nuclear Contingency Plan even though the AND Plan was written prior to the Nuclear Contingency Plan and in fact AP&L had not originally intended to docket the Nuclear Contingency Plan with the NRC (see Emergency Preparedness Combined Appraisal Report No. 50-313/81-22 and 50-368/81-21). This problem is made more important by the following facts: 1) the Nuclear Contingency Plan was'not generally available to members of the ANO site emergency response'personr.el; 2) certain of the material necessary to fulfill the criteria of NUREG-0654 is contained in the Nuclear Contingency Plan and not in the AN0 Plan; and 3) there is a lack of adequate referencing between the two, plans to allow the AP&L and ANO emergency response personnel to accurately oetermine exactly what must '

be done, by whom, and whe . While the AP&L Nuclear Contingency Plan provides a detailed description of the various individuals and groups who will; comprise and support the full Emergency Response Organization, as well as their respective responsi-bilities, this level of detail is conspicuously absent from the AN0 Pla . It is unclear exactly what document or pdrts/ sets of documents constitute the " official" AP&L Emergency Response Plae and itg associated Implementa-tion Procedures. A clear ar;d unambiguous ~ statement of the licensee's ~

intended use of these various other ancillary apd supporting documents and procedures is needed. Further, the' exact nature of the relationships between and among the various docu9ents should be included in such a statement. Thus, where the statement-is-hade w page 5 of the AN0 Plan regarding ". . . other AP&L emergeaty plans . . ." (e.g. , Security Plans, Fire Protection Plans, etc.) there should be a detailed summary (by titles) of such plans or other documents, their. relationship to the Plan, the specific area of the ANO Plan which they relate to or implement, when and how they are to be used, and specifically where up-to-date copies are available for immediate emergency us .

ThePlan(whateveritisfinalh'consideredtobe)shallbeastand-alone document, containing sufficient detail on which the NRC can base its safety findings. While other am7rgency plans, procedures, provisions,

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and other appropriate documn < can and should be referenced to provide the reader with addition >! in umation and insight, the Plan itself must also contain a summar. J Jc eferenced documents. Such summaries should be short but must cou p w $ i t'ent detail on which the NRC can base its safety finding )

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. Appendix 0 of the AN0 Plan should include a complete list of implementing procedures (including normal procedures which are also intended to be

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used during emergencies) as well as the specific portions of the Plan p' - which they implement, the procedure numbers and title, and where up-to-date copies may be found for immediate emergency use. It should be noted that the short descriptions of the procedures as provided in Appendix D were considered an excellent addition to the planning document.

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. The terminology used in the AN0 Plan does not match exactly that used in the State and County Plans (e.g., titles of EAL's, titles of ERF's, etc.).

Better coordination should be used to avoid misunderstandings during an ( actual emergency situatio . The term " Unusual Event" for the first classification of an emergency has been changed to " Notification of Unusual Event" in both NUREG-0654, Revision 1, and 10 CFR Part 50, Appendix E(IV)(c).

. The term " Site Emergency" for the third classification of an emergency x.'s'

has been changed to " Site Area Emergency" in both NUREG-0654, Revision 1, and 10 CFR Part 50, Appendix E(IV)(c).

. Development of a subject index, similar to that used in the State Plan, would increase the retrievability of important information in the licensee emergency plan (s) under the possibly stressful conditions associated with an actual emergenc . In-text references shall be as specific as possible; e.g., the reference should be to a specific page, not to an entire section. While this policy must be tempered to reduce the overall amount of work necessary to make simple changes and corrections to the Plan, the policy must be given due consideration so as to aid the reader in moving from one part of the Plan to anothe . In the " Emergency Plan Implementation Procedures" (EPIP's), all in-text references shall be as specific as possibl During an emergency, it is the EPIP's which will be used and the reader will not have the time to hunt for a general referenc . All pages for the emergency planning documents (including graphics)

should be dated and the appropriate revision number indicated so as to facilitate awareness of changes which are made to the document Further, the specific changes should be identified by " change bars" in the margin of the pag . The cross-reference index of NUREG-0654 Planning Standards and the ANO Emergency Plan does not include any reference to the AP&L Nuclear Contingency Plan. Further, the index is not correct; e.g., see reference to Appendix 0 for Planning Standards E-1 thru E- ._ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _

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II FINDINGS ON STANDARDS AND CRITERIA ASSIGNMENT OF RESPONSIBILITY (0RGANIZATIONAL CONTROL)

Planning Standard Primary responsibilities for emergency response by the nuclear facility licensee, and by State and local organizations within the Emergency Planning Zones (EPZ's), have been assigned; the emergency responsibilities of the various supporting organizations have been specifically established; and each principal response organization has staff to respond and to augment its initial response on a continuous basi Synopsis

. The Federal, State, and local organizations that are intended to be part of the overall response organization for the EPZ's are identifie The licensee's concept of operations and its relationship to the total effort are specifie . The interrelationships among organizations are illustrated in block diagram . The Duty Emergency Coordinator (Shift Operations Supervisor, until relieved) is identified as the individual who shall be in charge of the initial emergency response (INITIAL RESPONSE ORGANIZATION) and the Incident Response Director is identified as the individual who shall be in charge of the fuli 'icensee response (EMERGENCY RESPONSE ORGANIZATION).

. 24-hour per-day emergency response, including 24-hour per-day manning of communications links, is provided to . Written agreements referring to the concept of operations developed between Federal, State, and local agencies and other support agencies having an emergency response role within EPZ's are include . The Incident Response Director is the individual who will be responsible for assuring continuity of resource Evaluation: The Plan satisfies Planning Standard A, except as noted belo DEFICIENCIES Criterion A-la:

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. The Plan depends heavily upon the provisions for assistance contained in other emergency plans (such as the State of Arkansas Plan, etc.). The Plan shall be a stand-alone document. While it is acceptable to incorporate, by reference, other emergency plans, the specific nature of the services and assistance expected from other organizations, including private organizations and contractors (A/E, NSSS, etc.) must be presented to a degree which enables the reader to determine the functions to be performed by support organization Criterion A-3:

. /ppendim A provides insufficient detail regarding the manpower, material and equipment, and excepted response times of emergency response oroanization Further, letters of agreement were not presented for such groups as: 1) private organizations such as INP0, B&W, CE, A-E firms, etc., and 2) appropriate Federal organizations such as NOAA (NWS),

FEMA, NRC, etc. It is also suggested that these letters be reviewed at '

least every 12 months (see criterion D-9 of NUREG-0654). ONSITE EMERGENCY ORGANIZATION Planning Standard On-shift facility licensee responsibilities for emergency response are unambig-uously defined; adequate staffing to provide initial facility accident response in key functional areas is maintained at all times; timely augmentation of response capabilities is available; and the interfaces among various onsite response activities and offsite support and response activities are specifie Synopsis The Shift Operations Supervisor is designated the acting Duty Emergency Coordinator (of the INITIAL RESPONSE ORGANIZATION) and has the authority and responsibility to immediately and unilaterally initiate any emergency action . The interfaces between and among the onsite functional areas of emergency activity, licensee headquarters support, local services support, and State and local government response organizations are illustrated in a block diagra The services to be provided by local agencies for handling emergencies are identified. Copies of letters of agreement are appended to the Pla Evaluation: The Plan fails to satisfy Planning Standard B for the following reasons:

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DEFICIENCIES Criterion B-1:

. The Plan does not adequately describe the onsite emergency organizction of plant staff personnel for all shifts and its relationship to the responsibilities and duties of the normal staff complement. For each shift, specify the types and number of personnel on duty, what their regular duties are, and how their duties would change during an emergenc . The Plan does not clearly and unambiguously define its authority which

" assigns specific duties to members of the Emergency Organization" (see page 8 of the Plan).

. The Plan does not unambiguously identify the authorities of all persons assigned to the Emergency Organization which would enable them to perform their " assigned" task . The Plan does not identify, for each emergency duty position, the primary and alternate person, by name or normal duty title, who is trained and otherwise qualified to fill the positio Criterion B-2:

. Section 5.2.2 of the Plan does not explicitly identify the authority and responsibility of the Duty Emergency Coordinator (or ultimately the Incident, Response Director) to provide protective action recommendations to authorities responsible for implementing offsite emergency measure Criterion B-3:

. The Plan does not contain a clear line of succession for the Duty Emergency Coordinator position nor does it specify the cor.ditions for higher level utility officials assuming this functio Criterion B-4:

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. The Plan does not clearly establish specific functional responsibilities assigned to the Duty Emergency Coordinator which may not be delegated to other personnel within the onsite emergency organization. Note that among the responsibilities which may not be delegated shall be the decision to notify and recommend protective actions to authorities responsible for offsite emergency measures.

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. The Plan (see pages 26 and 27) holds the Shift Operations Supervisor responsible to make notification (see Figs. 15, 16 & 17) for all classifications of emergencies. This is not appropriate as this duty will shift to the Duty Emergency Coordinator, the Incident Response Director, or the Recovery Manager in later stages of an inciden _

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Criterion B-5: )

. The Plan does not fulfill either the scope or the intent of this criterio No table, similar to Table B-1 of NUREG-0654, Rev. 1, is incorporated into the Plan, nor is any other method apparent which supplies the required information regarding shift manning and augmentatio . The exact meaning of the statement on page 11 of the Plan that " full augmentation by the members of the Initial Response Organization who are not onsite at the time of the incident" must be clarifie Criterion B-6:

. It would be beneficial to rework Figures 10 thru 13 to identify the persons by normal duty title, emergency duty title, where they will be located during their emergency response, and a short listing of their major duties. Further, Figure 12 would be more helpful if it were organized according to the onsite functional areas of emergency response activit Criterion B-7:

. The Plan does not address this criterion. The information is contained in the Nuclear Contingency Plan but no reference is made to that documen Further, there is no specific criteria identified which would be used to determine when and exactly how much of the Augmentation Emergency Response Organization would be activate Criterion B-8:

. The Plan does not identify all of the contractor and private organizations who may be requested to provide technical assistance to and augmentation of the emergency organization Care must be taken to ensure that all such potential organizations are identifie Criterion B-9:

. The Plan and its associated letters of agreement do not specifically delineate the authorities, responsibilities, and imits of the actions of support organization EMERGENCY RESPONSE SUPPORT AND RESOURCES Planning Standard Arrangements for requesting and effectively using assistance resources have been made, arrangements to accommodate State and local staff at the licensee's near-site Emergency Operations Facility have been made, and other organizations capable of augmenting the planned response have been identifie !

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Synopsis

. Federal assistance may be requested by the Technical Support Manage . The expected Federal resources are specifie . Licensee representatives will be dispatched to principal offsite E0C' . Radiological laboratories and their general capabilities and availability are specifie Evaluation: The Plan satisfies Planning Standard C, except as noted belo DEFICIENCIES Criterion C-lb:

. Expected times of arrival at specific sites are not give Criterion C-1c:

. No resources for support of the Federal response are identifie Criterion C-2b:

. While the Plan does indicate that a site representative may be sent to the affected local or State emergency operations facilities, provisions shall be made to ensure that a sufficient number of persons are trained and available to maintain 24-hour per-day coverage during a protracted perio Criterion C-3:

. The Plan does not provide sufficient information concerning availability of offsite laboratory capabilities, especially regarding the analysis of postaccident samples should the station radiochemistry laboratory not be usable during emergencie Criterion C-4:

. Section 5.3.4 does not contain sufficient information regarding nuclear and other facilities, organizations, or individuals which could be relied upon in an emergency to provide assistanc EMERGENCY CLASSIFICATION SYSTEM Planning Standard A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measure ,,, , - - . - - __,-. - - . .. . . . - . , . - . _ , . . - - - - - . - - - - . _ -

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Synopsis

. An emergency classification and emergency action level scheme compatible with the schemes in Appendix 1, NUREG-0654, has been establishe . Some of the example initiating conditions listed in Appendix 1, NUREG-0654, were addresse All postulated accidents in the FSAR were covere Evaluation: The Plan satisfies Planning Standard D, except as noted belo DEFICIENCIES

Criterion D-1

Notification of Unusual Events

. Initiating Condition 1 (ECCS activation). EAL's based on indications of flow in ECCS systems should be devd ope . Initiating Condition 2 (radiological effluents). The relevant gaseous and liquid alarms should be liste g

. Initiating Condition 3 (fuel damage indication). An EAL for rate of fuel failure should be adde . Initiating Condition 4 (abnormal coolant temperature and/or pressures).

EAL's shculd be added for high and low reactor pressure, high fuel temperature, and high T avg'

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. Initiating Condition 6 (failure of a safety or relief valve in a safety-related system to close). EAL's indicating leakage (e.g. , acoustic monitors, temperatures) are needed for all primary system and steam generator safety and relief valve . Initiating Condition 10 (fire). The licensee's EAL is nonconservative as it requires that the fire be in a vital area; all that is required is a fire anywhere within the plant that lasts for more than 10 minute . Initiating Condition 12 (security). The licensee's definition of the initiating condition is nonconservative in that it requires an ongoing security compromise; all that is required is a " security threat or attempted entry or attempted eabotage."

. Initiating Condition 13 (tornado and high winds). The licensee's definition of the initiating condition is nonconservative as it requires facility damage; any tornado onsite is sufficient reason for declaring a Notification of Unusual Event. The licensee should provide a quantitative EAL for high wind .- __ ,_, __ .,. - _

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. Initiating Condition 14 (other hazards). An EAL is required for unusual aircraft activity over the facilit The licensee's explosion EAL is nonconservative in that it requires damage to equipment or personnel injury; any onsite explosion suffices for declaring a Notification of Unusual Event. The licensee's requirement that a toxic or flammable gas spill require a plant evacuation is nonconservative; any near or onsite release of such gases is grounds for declaring a Notification of Unusual Even Alert

. Initiating Condition 1 (severe loss of fuel cladding). An EAL for rate of fuel failure is require . Initiating Condition 5 (primary coolant leak greater than 50 gpm). The licensee has used a subcooling margin of less than 20 F as an EAL. An EAL based upon a 50 gpm leak rate is required, such as falling pressurizer level with charging flow in excess of 50 gp . Initiating Condition 10 (loss of function needed for plant cold shutdown). The licensee's EAL is merely a rewording of the initiating condition. An EAL specifying which systems or capabilities needed, to be lost should be prepared. 113 suggestions of NUREG-0818 should be considere . Initiating Condition 17b (water level). An EAL for low water level is require Site Area Emergency

. Initiating Condition 1 (LOCA greater than makeup pump capacity). The licensee's EAL set is incomplete as only an EAL for RCS system saturation is used. The suggestions of NUREG-0818 should be considered in developing an acceptable EAL se . Initiating Condition 18 (control room evacuation and control of safety shutdown systems not established within 15 minutes). The 15-minute time delay should be specifie General Emergency

. Initiating Condition 2 (loss of two out of three fission product barriers with potential for loss of third barrier). The licensee has prepared a criterion for this event which would form the basis for an EAL set but has prepared no EAL' The suggestions of NUREG-0818 should be considered in preparing an acceptable set of EAL' .

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The licensee did not address the following initiating conditions:

. Notification of Unusual Event: 5, 7, 8, 9, 13a, 13b, 14e, and 1 . Alert: 2, 3, 4, 6, 7, 12, 13, 17c, 17d, 18, and 1 . Site Area Emergency: 2, 3, 5, 6, 7, 8, 9, 10, 11, 12, 15, 16, and 1 . General Emergency: 4, 5, and NOTIFICATION METHODS AND PROCEDURES Planning Standard Procedures have been established for notification, by the licensee, of State and local response organizations and for notification of emergency personnel by all response organizations; the content of initial and followup messages to response organizations and the public has been established; and means to provide early notification and clear instruction to the populace within the plume exposure pathway EPZ have been establishe Synopsis

. Procedures which describe mutually agreeable bases for notification of response organizations consistent with the emergency action level scheme l

are establishe . Procedures for alerting, notifying, and mobilizing emergency response personnel are establishe Evaluation: The Plan fails to satisfy Planning Standard E for the following reasons:

DEFICIENCIES Criterion E-1:

. The verification of notification messages to offsite authorities is not discussed in the AND Plan. There is some discussion of this subject in the State and County Plans and the AP&L Nuclear Contingency Plan, but it is not referred to in the ANO Pla Criterion E-3:

. The Plan does not adequately develop the content of initial emergency messages to be sent from the station. The messages contained in Appendix K are poorly worded and could cause undue panic by the publi Further, no messages were developed for general information or shelterin r-

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Criterion E-4:

. The Plan does not identify such a followup message form which contains i the necessary informatio Criterion E-6:

. The Plan does not adequately provide detailed information regarding the administrative and physical means, and the time required, for notifying and providing prompt instructions to the public within the plume exposure pathway EPZ. Sufficient information is needed to demonstrate that all criteria in Appendix 3 to NUREG-0654, devision 1 (R.G. 1.101, Rev. 2) are me Criterion E-7:

. The Plan does not adequately address the preparation of messages intended for the public to inform them of such areas as appropriate aspects of sheltering, ad hoc respiratory protection, evacuation routes, and other important issues during an emergency. AP&L shall coordinate the preparation of such messages with the State and local authoritie F. EMERGENCY COMMUNICATIONS Planning Standard Provisions exist for prompt communications among principal response organiza-tions to emergency personnel and to the publi Synopsis

. 24 per-day notification to and activation of the State / local emergency response network is provide . Communications with State / local governments within the EPZ's are provide . Communications, as needed, with Federal emergency response organizations are provided.

. Communications between the nuclear facility, State, and local E0C's and l

radiological monitoring teams are provide . Provisions are made for alerting or activating emergency response personnel, f

. Communication by the licensee with NRC Headquarters and NRC Regional Office E0C's is provide . Periodic testings of communications systems are provided.

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a Evaluation: The Plan satisfies Planning Standard F, except as noted belo DEFICIENCIES Criterion F-1:

. Organizational titles and alternates for both ends of the communication links are not included in the Pla Criterion F-2:

. A coordinated communication link for fixed and mobile medical support facilities is not discusse G. PUBLIC EDUCATION AND INFORMATION Planning Standard Information is made available to the public on a periodic basis on how they will be notified and what their initial actions should be in an emergency (e.g., listening to a local broadcast station and remaining indoors); the principal points of contact with the news media for dissemination of informa-tion during an emergency (including the physical location or locations) are established in advance; and procedures for coordinated dissemination of information to the public are establishe Synopsis

. A coordinated yearly dissemination of information to the public regarding how they will be notified and what their actions should be .'n an emergency is provide . The points of contact and physical locations for use by news media during an emergency are designate . Space will be provided at the licensee's Emergency Control Center for use by a limited number of news media representatives during an emergenc . The Communications Superintendent is designated as the licensee's j spokesperson to the news medi . Information releases will be coordinated with the appropriate governmental

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Evaluation: The Plan satisfies Planning Standard G, except as noted belo DEFICIENCIES Criterion G-Id

. The special needs of the handicapped are not addressed in the licensee's I

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Criterion G-2:

. No information program for the transient population in the plume exposure EPZ is provide Criterion G-4c:

. No coordinated arrangements for dealing with rumors are establishe EMERGENCY FACILITIES AND EQUIPMENT Planning Standard Adequate emergency facilities and equipment-to support the emergency response are provided and maintaine Synopsis

. A primary and alternate TSC and OSC have been establishe . A primary and alternate Emergency Control Center for evaluation and coordination of licensee emergency-related activities have been estab-lished, including transmission of information to appropriate State / local authoritie . Provisions have been made for timely activation and staffing of emergency response facilitie . Geophysical phenomena, radiological and process monitors, and fire and combustion detectors have been installed onsit . Provisions have been made to acquire or have access to offsite meteorological and hydrological dat . Radiological monitors have been installed at offsite location . Provisions have been made to use offsite laboratory facilities at the company headquarters in Little Roc . Provisions have been made to inspect, inventory, and check equipment /

instruments each quarter and after each use. Sufficient reserves are available to replace those removed for repair or calibratio . Emergency kits are identified in Appendix E by location and content Evaluation: The Plan satisfies Planning Standard H, except as noted belo DEFICIENCIES

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. There is no evidence in the Plan that the TSC, OSC, and ECC have been or will be established in accordance with criteria in_NUREG-0696, Revision . The Plan shall describe monitoring, either portable or permanent, for both direct radiation and airborne radioactive contamination at the TSC (NRC letter 10/30/79).

. The Plan should include maps or graphic diagrams depicting the locations, size, and physical layouts (both principal and alternate) of the:

1) near-site ECC and the E0C's (both State and local); 2) Onsite Technical Support Center; 3) Control Room (no alternate); and 4) Onsite Operational Support Cente . The Plan should specifically define the criteria used to determine if and when the TSC/0SC must be evacuated and the methods / equipment used to make such a determinatio Criterion H-4:

. The Plan does not provide adequate information regarding the projected time required to fully activate and staff the emergency response facilities (including the time required to move from the primary EOF to the alternate E0F). Nor is there an adequate description of the methods and procedures which will be used to assure that functional continuity will be maintained during these item Criterion H-Sa:

. It is assumed that the word " indications" on page 37, Section 7.3.1c, is misspelled and should be " indicators."

Criterion H-5b:

. Wound and portable monitors and sampling equipment are not identifie Criterion H-6a:

. Provision to acquire data from or have access to offsite seismic instrumentation is not addresse Criterion H-6b:

. The Plan does not indicate if the offsite dosimetry provided by the licensee meets the NRC Radiological Assessment Branch Technical Position for the Environmental Radiological Monitoring Progra r

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Criterion H-7:

. The Plan does not indicate if the licensee has provided radiological monitoring equipment at locations near the facility for use in emergency situation Criterion H-8:

. The Plan does not contain enough information to determine if the meteorological instrumentation and procedures satisfy the criteria in Appendix 2, NUREG-065 Criterion H-10:

. The Plan also fails to provide sufficient information regarding the calibration of equipmen Criterion H-12:

. The Plan does not state if provisions have been made to establish a central point for receipt and analysis of field monitoring data and coordination of sample medi ACCIDENT ASSESSMENT Planning Standard Adequate methods, systems and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in us Synopsis

. A system of effluent parameter values characteristic of a spectrum vi off-normal conditions has been established (see comments under Standard D).

. The plant has the onsite capability and resources to provide initial values and continuing assessment throughout the course of the acciden . Procedures have been developed for determination of the source term of releases within plant systems and the magnitude of radioactive materials releases based on plant parameters and effluent monitor . The relationship between effluent monitor readings and onsite and offsite exposures and contamination under various meteorological conditions has been establishe . The methodology for determining release rate / projected dose rates if instruments are off-scale has been establishe r

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Evaluation: The Plan fails to satisfy Planning Standard I for the following reasons:

DEFICIENCIES Criterion I-1:

. The Plan fails to reference the emergency procedures that contain parameter values and the corresponding emergency class, and the instruments used and their capabilitie Criterion I-2:

. The Plan indicates there is capability to provide initial and continuing assessment but fails to indicate if this capability includes postaccident sampling, radiation and effluent monitors, in plant iodine monitors, and containment radiation monitoring in accordance with NUREG-0578/073 Criterion 1-5:

. The Plan does not contain enough information to determine if the licensee has the capability to acquire and evaluate _ meteorological data sufficient to meet Appendix 2, NUREG-0654 criteri Criteria I-7 and I-8:

. The Plan is not specific regarding the licensee's capability and resources for field monitoring within the plume exposure EPZ. The methods, equipment and expertise for making evaluations in the field are not addresse . A figure should be included in the Plan showing all environmental sampling points, not just the TLD location Criterion I-9:

. The Plan does not address the licensee's capability to detect and measure radjoiodineconcentrationsinairintheplumeexposureEPZaslowas 10 uCi/cc under field condition Criterion I-10:

. The Plan in the cross-reference index refers to Appendix D, " Emergency Plan Implementing Procedures," but fails to identify the EPIP that relates to the criteri . Population distribution data should also be provided for 1980, 1990, and 200 .-. - - . .. _ .

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• . PROTECTIVE RESPONSE Planning Standard A range of protective actions have been developed for the plume exposure pathway EPZ for emergency workers and the public. Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been develope Synopsis

. Provisions have been made to warn or advise onsite individuals and persons who may be in.the exclusion area of an accident or emergency situatio . Evacuation routes and transportation for evacuated onsite personnel are provide . Radiological monitoring and decontamination if necessary will be provided at the EC . Provisions have been made to account for individuals onsite at the time of an emergenc . A mechanism (s) has been established for promptly notifying and making protective action recommendations to appropropriate State and local authoritie . Time estimates for evacuation within the plume exposure EPZ are shown in Figure 1 . Maps showing evacuation routes, evacuation areas, monitoring points, relocation areas, and shelter areas are either in the licensee Plan (Figure 5) or in Annex A of Appendix C.

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. Maps showing population distribution by sector and evacuation area are in

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the Plan (Figure 6 and Appendix C, respectively).

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Evaluation: The Plan satisfies Planning Standard J, except as noted belo DEFICIENCIES Criterion J-1:

. The means used and the time required to warn or advise onsite personnel are not addressed. Onsite contractor / construction personnel (Criterion Ic)

are not mentioned. The time required to notify individuals in the exclusion area is not give . The entire exclusion area should be evacuated at one time, not just "that portion of the exclusion area affected by the emergency ..." (see page 29 of the Plan). Further, the criteria for such evacuation should be reconsidered from the present, as "a projected dose for 12 months" is not appropriat Criterion J-2:

. The Plan does not provide adequate information including the projected numbers of evacuees, the time required to evacuate the site and gather the evacuees at a remote assembly area, and the handling and control of traffic flo Criteria J-3 and J-4:

. The Plan fails to provide detailed descriptions of the manpower, equipment and methods to be used to provide the capability to monitor and decontaminate the people and equipment evacuated frem the site during an emergenc Criterion J_5:

. The Plan does not state if onsite personnel accountability can be achieved within 30 minutes of the start of an emergency or continuously maintained after the initial effor The Plan refers to the Industrial Security Plan and Implementing Procedures that are not available for revie Criterion J- . The Plan indicates that protective equipment will be made available to onsite personnel as required but does not specifically address the items in the criterio Reference is made to the Radiological Protection Procedures and Respiratory Protection Procedures that are not available for review. Use of radioprotective drugs is not addresse . The Plan should provide information regarding minimum inventories of these items, projected numbers of emergency workers who may need these items, provisions to acquire additional supplies, and methods to distribute and periodically check that these items are being properly used during an emergenc I .

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Criterion J-7:

. There is no indication in the Plan that recommended protective actions comply with EAL criteria in Appendix 1, NUREG-0654, or with Tables and 2.2 of the Manual of Protective Action Guides and Protective Actions for Nuclear Incidents (EPA-520/1-75.001).

Criterion J-8:

. Time estimates for evacuation (Figure 18) are not in accordance with the requirements of Section D, Appendix 4, NUREG-065 Criterion J-10a:

. The map showing preselected monitoring points (Figure 5) does not include designators or an equivalent system as shown in Table J.1, NUREG-065 Preselected sampling points are not show Criterion J-10a:

. There is no map showing population distribution around the plant in the 10-mile EPZ by evacuation are Criterion J-10m:

. Local protection afforded by residential units or other shelter for direct or inhalation exposure is not addresse RADIOLOGICAL EXPOSURE CONTROL Planning Standard Means for controlling radiological exposures, in an emergency, are established for emergency workers. The means for controlling radiological exposures shall

include exposure guidelines consistent with EPA Emergency Worker and i Lifesaving Activity Protective Action Guide Synopsis

. Onsite exposure guidelines consistent with EPA Emergency Worker and

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Lifesaving Activity Protective Action Guides (EPA 520/1-75/001) have been establishe . An onsite radiation protection program has been established. Procedures have been established for permitting workers to receive radiation doses in excess of 10 CFR Part 20 limits. The Duty Emergency Coordinator or Recovery Manager is authorized to approve excess exposure i L .

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Evaluation: The Plan fails to satisfy Planning Standard K for the following reasons:

DEFICIENCIES Criteria K-3, K-4, K-6, and K-7:

. The Plan does not contain enough information to permit adequate evaluatio The cross-reference index refers to Appendix D, Emergency Plan Implement-ing Procedures; Appendix E, Emergency Supplies and Equipment; and Radiation Protection Procedures without identifying those specifically addressing the criteria requirements. A review of Appendices D and E failed to uncover any information pertinent to the criteri Radiation Protection Procedures are not available for revie . The Plan does not clearly describe the provisions made to ensure that a capability exists to determine and record doses received by emergency workers on a 24-hour per-day basis, nor the methods to ensure that dosimeters are read at appropriate frequencie . The Plan does not specify action levels of determining the need for decontamination nor does it establish the means (equipment, manpower, supplies, and procedures) for such required decontamination with subsequent remonitorin . The Plan does not establish a definitive program to govern the control of contamination during an emergency nor the criteria for permitting return of areas and items to normal us . The Plan does not include a detailed description of the means of providing the capability for decontamination of onsite personnel and equipment which may be required to be relocated offsite during an emergency, including the provision of extra clothing, decontaminants, and capabilities to detect and remove radioiodine contamination of the ski MEDICAL AND PUBLIC HEALTH SUPPORT Planning Standard Arrangements are made for medical services for contaminated injured individual Synopsis

. Local and backup hospital and medical services having the appropriate capabilities are arranged fo . Onsite first aid capability is provide . Arrangements have been made to transport victims of radiological accidents to medical support facilitie Evaluation: The Plan satisfies Planning Standard . .. ..

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. RECOVERY AND REENTRY PLANNING AND POSTACCIDENT OPERATIONS Planning Standard General plans for recovery and reentry are develope Synopsis (Note: The Plan does not address this Planning Standard.)

Evaluation The Plan fails to satisfy Planning Standard M for the following reasons:

DEFICIENCIES Criterion M-1 thru M-4:

. The Plan includes no discussion of these criteri . The Plan does not address Recovery Planning and Postaccident Operation The information contained in the Plan is vague and unsupported and mainly deals with reentry of the facility for medical emergencies or search and rescue missions for personnel accountability. AP&L should review the recommendation of the Atomic Industrial Forum's " Nuclear Power Plant Emergency Response Plan," dated October 11, 197 . The Plan should unambiguously defina exactly when the Recovery Phase begins (and thus the Recovery Manager assumes command) and the specific criteria for determining when to enter the recovery phase, including formal criteria and procedures for transfer of the command to the Recovery Manage EXERCISES AND DRILLS Planning Standard Periodic exercises are (will be) conducted to evaluate major portions of emergency response capabilities; periodic drills are (will be) conducted to develop and maintain key skills; and deficiencies identified as a result of exercises or drills are (will be) correcte Synopsis

. An emergency preparedness exercise that simulates an emergency that results in offsite radiological releases is provided fo . A joint exercise to involve mobilization of State and local personnel and resources is provided fo . A critique of the annual exercise by Federal and State observers is provided fo . .. .

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. The scenario for the exercise will be varied each year to provide for testing all elements of the Emergency Plan within a 5 year perio . Fire drills in accordance with the Station Technical Specification are provided fo . A medical emergency drill shall be conducted each yea . Exercise scenarios include the required informatio . A critique by government observers, resulting in a formal evaluation, is provided fo . Deficiencies are identified in a postexercise critique and proper corrective actions are determined by responsible plant staf Evaluation: The Plan satisfies Planning Standard N, except as noted belo DEFICIENCIES Criterion N-1:

. No mention is made of the requirements to conduct exercises in accordance with NRC and FEMA rule Criterion N-2a:

. Communications with Federal and State emergency response organizations within the ingestion pathway shall be tested quarterly. No mention is made of the requirement that communication drills include the aspect of understanding the content of message Criterion N-2d:

. Radiation monitoring drills do not include provisions for communications

, and recordkeeping.

!

Criterion N-2e:

l Health physics drills do not include the analysis of in plant liquid

'

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< samples with actual elevated radiation levels on an annual basis.

! RADIOLOGICAL RESPONSE TRAINING Planning Standard c Radiological emergency response training is provided to those who may be i

called on to assist in an emergenc ,

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Synopsis

. Provisions have been made to provide emergency response training for onsite personnel and offsite response organizations who may provide assistance in event of an emergenc . Provisions have been made for classroom training as well as practical drills for members of the onsite emergency organizatio . Provisions have been made for first aid team members to receive a standard first aid cours . An initial training and retraining program has been established for instructing and qualifying most personnel who will implement radiological response plan . Provisions have been made for initial and annual retraining of personnel with emergency response responsibilitie Evaluation: The Plan satisfies Planning Standard 0, except as noted belo DEFICIENCIES Criterion 0-2:

. The Plan does not indicate if on-the-spot correction of erroneous performance will be made by the drill instructo Criterion 0-3:

. The Plan does not indicate if the " standard first aid or comparable course" offered to first aid team members includes Red Cross Multi-Media or equivalent trainin Criterion 0-4:

. A training program for police and security personnel, onsite repair and damage control / correctional teams, Civil Defense / Emergency Service personnel, and personnel responsible for transmission of emergency information and instructions are not addressed in the Pla . The Plan does not identify training requirements as part of the selection and qualification criteria used to assign persons to fill positions in the emergency response organization RESPONSIBILITY FOR THE PLANNING EFFORT:

DEVELOPMENT, PERIODIC REVIEW, AND DISTRIBUTION OF EMERGENCY PLANS Planning Standard Responsibilities for plan development and review and for distribution of emergency plans are established, and planners are properly traine ,

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Synopsis

. The individual with the overall authority and responsibility for radiological emergency response planning is the Vice President, Energy Suppl .

. The Emergency Planning Coordinator is responsible for the development and updating of emergency plans and coordination of these plans with other response organization . Periodic revisions of the Plan, as needed, including changes identified by drills and exercises, are provide . A table of contents and cross-reference index to NUREG-0654 are include Evaluation: The Plan fails to satisfy Planning Standard P for the following reason DEFICIENCIES Criterion P-1:

. No training for individuals responsible for the planning effort is provide Criterion P-6:

. No detailed listing of supporting plans is provide Criterion P-7:

. The listing of procedures does not include the section(s) of the Plan to be implemented by each procedur Criterion P-9:

. No arrangements of annual independent reviews of the emergency preparedness program are describe Criterion P-10:

. No provisions are made for the quarterly updating of telephone numbers in emergency procedure ..

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