ML050390212

Licensee Post Exam Comments (Folder 1)

ML050390212
Person / Time
Site:	Nine Mile Point
Issue date:	12/23/2004
From:	Evans T Constellation Energy Group
To:	Collins S, Conte R NRC Region 1, NRC/RGN-I/DRS/OSB
Conte R
References
Download: ML050390212 (39)

Text

Resolution to NMP-1 Question SRO #25 Original Question:

Emergency events are in progress:

(08:OO) General emergency declared.

(08:12) Notification sent with wind direction from 304.

(08:42) EOF is manned including county and state representatives.

(08:52) Radiological Assessment Manager reports radiation levels up to 1 REM TEDE are (08:52) Wind direction HAS SHIFTED and is now from 278.

projected outward to 10.2 miles from the site.

Which one of the following is the correct information to be communicated to the EOF regarding protective action recommendations?

Continue the previously recommended evacuations in SCRIBA and NEW HAVEN Townships. Additional Evacuations are not required.

Continue the previously recommended evacuations in SCRIBA and NEW HAVEN Townships. Additional evacuations are being recommended for MEXICO and RICHLAND townships.

Some evacuations in SCRIBA Township will be discontinued. Continue the previously recommended evacuations in NEW HAVEN Township. Additional Evacuations are not required.

Some evacuations in SCRIBA Township will be discontinued. Continue the previously recommended evacuations in NEW HAVEN Township. Additional evacuations are being recommended for MEXICO and RICHLAND townships.

A.

B.

C.

D.

Original Answer: B LICENSEES JUSTIFICATION FOR CHANGE The flaw stems from the ambiguity in the 3rd bullet that states:

(08:52) Radiological Assessment Manager reports radiation levels up to 1 REM TEDE are projected outward to 10.2 miles from the site. More specifically-...up to 7 REM TED projected outward to 70.2 miles...

The author of the question assumed that the applicants look at the calculation as a linear function and assumed that the applicants would determine that 1 REM TEDE would be exceeded. A faulty mental model during question development and review failed to take into account any meteorological conditions.

In accordance with EPIP-EPP-08 the criteria used to determine PAR for each ERPA is Evacuate when TEDE is >I (greater than). This can be found in several sections including: Step 3.1.I. j. 3., Attachment 1 Flow chart (not provided during exam) and Table 1.3, Attachment 5 step 2.3.4 3.1 Dose Assessment and Protective Action from the Control Room CAUTION Calculation involving the determination of release rates and/or protection action shall be self-checked for accuracy.

3.1.1 Chemistry Technician Actions j.

IF an unmonitored atmospheric release is suspected or known to be in progress, then assist the SSS/ED in the following actions:

1.

Advise the SSS/ED to expedite the dispatch of Radiation Protection (RP)

Technician. Request assistance of the unaffected Unit or J.A. Fitzpatrick if needed.

2.

The RP Technician should be dispatched to potential plume centerline

{wind direction (degrees) 180 = plume centerline}, as close to the site boundary as practical. See Attachment 1, Figure 1.4 for Site boundary location.

3.

IF readings indicate > 1 Rem/hr based on field survey perform the actions indicated in Attachment 1.

TABLE 1.3 - EPA 400 Protective Action Guidelines (EPA PAGs)

PAR)

~ E D E (rem b CDET(rem Evacuate I.1 I> 5 2.3.4 PARs that have been made previously must be accounted for when PARs are revised. For example, if a PAR to evacuate an ERPA was previously made to the State/County and that PAR does not appear on a revised map from 1.2.9.j, that PAR must still be included on the revised recommendation to the State/County.

Once a PAR is transmitted to the State/County, it shall not be changed.

To select between answer A and B, evaluation of the following data is required:

radiation levels are up to 1 REM... outward to 10.2 miles.

There are multiple assumptions that can be made based on the given conditions. Since evacuation of any ERPA or areas beyond 10 miles is based on the dose projection for that specific area and no areas are stated as being greater than 1 REM then it cannot assumed there is an area or multiple areas above 1 REM closer to the plant excess or less than 1 REM based on specific environmental conditions not given in this question such as rain in Mexico beyond a 12 mile radius could be the cause of the readings up to 1 REM at 10.2 miles.

Dose outward to 10.2 miles implies that surveys have been done starting at the plant and traveling away from the plant. Downwind survey teams would be initially dispatched from the plant and with the given wind direction the downwind ERPAs (14 & 15) extends outward in excess of eleven (1 1) miles (see EPIP-EPP-07 Att 3 and attached EPZ figure). 1 REM would be a very significant dose at 10.2 miles and if treated as a point source toward the plant you could have deadly dose rates inside the plant. Dose projections are not treated solely as a point source - meterological conditions and downwind surveys or EDAMS projections are used to project dose. The fact is that dose rates are NOT exceeding 1 REM as reported by the RAM and given in the question stem (without any assumptions added). Therefore no additional PARs are recommended by the flow chart in Attachment 1 or per Attachment 5 for any ERPA or areas beyond 10 miles.

farther from the plant. Dose closer to the plant or beyond 10 miles could be in The attached printout from the EDAMS computer provides indication that dose rates at a greater distance from the source can be greater than the source when taking into account meterological conditions.

On the basis of the above information the facility recommends that question 25 of the SRO exam has 2 correct answers:

A.

B.

Continue the previously recommended evacuations in SCRIBA and NEW HAVEN Townships. Additional Evacuations are not required.

Continue the previously recommended evacuations in SCRIBA and NEW HAVEN Townships. Additional evacuations are being recommended for MEXICO and RICHLAND townships.

LICENSEES SECOND JUSTIFICATION FOR CHANGE This supercedes the NRC INITIAL WRITTEN EXAMINATION POST-EXAMINATION ANALYSIS submitted on 10 December, 2004.

SUMMARY

Per NUREG-1021, Rev 9 Sections ES-402 and ES-501, the facility submits the following NRC INITIAL WRITTEN EXAMINATION POST-EXAMINATION ANALYSIS for your review and consideration.

The facility proposes that question 25 of the SRO examination has Distractor a as the correct answer. This change will affect the grades of the SRO applicants.

Problem Statement:

Keyed Answer (b) is incorrect. Distractor a is the correct answer The following statements used to justify b as the correct answer are incorrect:

If dose at 10 miles is projected to meet or exceed 1 rem TEDE or 5 rem CDE (Thyroid), then make protective action recommendations and recommend evacuation to that distance in the affected areas.

The criterion identified in EPIP-EPP-08 R15 clearly defines the threshold value to be greater 1 rem TEDE or greater than 5 rem CDE. The question stem clearly indicated values less than or equal to 1 rem TEDE. This fact alone means that EPIP-EPP-08 does not require any ERPAs or areas at 10.2 miles distance from.the plant to be evacuated. A follow-up interview with a member of the Emergency Planning Organization (John Kaminski), supports the requirements to use field survey data for EPRA recommendations and not assumed or extrapolated dose information.

Therefore, continue the previously recommended evacuations in SCRIBA and NEW HAVEN Townships for ERPA 1,2,3,4,5,7,9,10 although the new EWAs based on the windshift are 1,2,3,4,7 and NOT 5 and 9.

The previous PARS implied in the question stem are to evacuate ERPAs 1, 2, 3,4, 5, 7, 9, 10, 26,

& 27 for a wind direction of 3040. With the wind shifting to 2780, the afiected ERPAs are 1, 2, 3,4, 7, 9, 26, & 27. ERPAs 5 and 10 are not afiected but will still be included per EPIP-EPP-8.

EPP-EP-P-08 Rev 15, Attachment 5, Refined Dose Assessment and Protective Actions, Steps 2.3 provides guidance for PARS clearly indicates that values greater than 1 TEDE or greater than 5 CDE are the criteria for the PAR for each EPRA Justification for a7 being the correct answer:

IAW EPIP-EPP-08, Attachment 1, PARS are re-evaluated to account for the shift in wind direction. At 2780. All of the previously evacuated ERPAs are still affected except 5 and 10 which are still evacuated L4W EPIP-EPP-08 Attachment 5, Section 2.3.4. No further recommendations are needed since the criterion of Table 1.3 in Attachment 1 is not met.

Justification for c and d being incorrect:

EPIP-EPP-08, Attachment 5, Section 2.3.4 does no allow us to discontinue an evacuation already recommended.

Supporting documentation attached:

EPIP-EPP-08 Revision 15 Section 3.1.1.j, Tables 1.2 and 1.3, Section 2.3 FINAL LICENSEE RECOMMENDATION:

On the basis of the above information the facility recommends that question 25 of the SRO exam has Distractor a as the correct answer:

A. Continue the previously recommended evacuations in SCFUBA and NEW HAVEN Townships. Additional Evacuations are not required.

NRC RESOLUTION:

Background information: The originator of the question (and specified correct answer) assumed that the information in the stem...radiation levels up to 1 REM TEDE are projected outward to 10.2 miles from the site would be extrapolated (by the applicants) to conclude that there was >

1 REM at 10 miles. That is, the applicants would assume a point source and calculate that a reading approaching 1 REM at 10.2 miles would result in equal to or greater than 1 REM at 10.0 miles. Procedure EPIP-EPP-08, Off-site Dose Assessment and Protective Action Recommendations (provided to the applicants during the exam) only address readinas > 1 REM/hr based on field survev. There are no instructions in the procedure to take field data at

10.2 miles and extrapolate to the 10.0 mile range. Likewise, Table 1.3 (addressing EPA PAGs) specifies evacuation for TEDE >1 REM. No where in the stem does it specify that there is a TEDE > 1 REM.

NUREG 1021, Appendix E, Part B: Written Examination Guidelines, Item #7 specifies that the applicants do not make assumptions regarding conditions that are not specified in the question unless they occur as a consequence of other conditions that are stated in the question. As specified in the licensees original response: Dose projections are not treated solely as a point source-meteorological conditions and downwind surveys or EDAMS projections are used to project dose. The attached printout from the EDAMS computer provides indication that dose rates at a greater distance from the source can be greater than the source when taking into account meteorological conditions. Since there is no data in the stem to support (an assumption) that there is a TEDE > 1 REM then additional evacuations are not required. These facts would provide viable arguments that B is not a correct answer (since it requires assumption of a point source and extrapolation of this point source to >1 REM/hr at 10.0 miles)

Step 2.3.4 of EPIP-EPP-08 specifies that once a PAR is transmitted to the State/County, it shall not be changed. Even though the wind shift specified in the stem of the question changed conditions in areas 5 and 10, the evacuations should proceed as originally directed.

This eliminates C and D distractors as correct answers.

Considering this information, as well as interviews with their own EP personnel, the licensee retracted their original request to accept two correct answers (A and B) and concluded there is only one correct answer; A (rather than the original proposed answer B).

Three examiners reviewed both the original and re-submitted licensee responses and have concluded the second recommended resolution (to accept only A as the correct answer) is correct and should be accepted.

Final Resolution:

Change the correct answer for SRO Question #25 from B to A.

P.O. Box 63 Lycoming, NY 13093 IXCEIVED c

Constellation Energya i:ZGION 1 Nine Mile Point Nuclear Station

'04 UEC 28 PI 26 NMP-99404 December 23,2004 Mr. Samuel J. Collins Regional Administrator USNRC Region I 475 Allendale Road King of Prussia, PA 19406 - 1415 ATTENTION: Mr. John G. Caruso, Senior Examiner/Inspector

SUBJECT:

NINE MILE POINT UNIT 1 INITIAL OPERATOR POST WRITTEN EXAMINATION ACTIVITIES

Dear Mr. Collins:

The facility staff administered initial license operator written examinations to nine applicants, as authorized in a letter from the NRC dated November 15,2004. The initial written examination was administered on November 23,2004 in accordance with NUREG 1021, Revision 9.

Nine Mile Point Nuclear Station has conducted the post written exam activities as required by NUREG 1021, Revision 9, Draft. Attached is the written examination post-examination comment for re-submittal as discussed with Mr. John G. Caruso, Senior Examinerhspector. This will supercede the previously submitted comment.

Please contact Michael Jaquin, Supervisor Initial Operator Training, at (3 15) 349-1508 for any questions that you may have.

Terry @vans Manager Nuclear Training TAE/rer Enc.

NMP1 License Class LC 1 03-01 NRC INITIAL WRITTEN EXAMINATION POST-EXAMINATION ANALYSIS This supercedes the NRC INITIAL WRITTEN EXAMINATION POST-EXAMINATION ANALYSIS submitted on 10 December, 2004.

SUMMARY

Per NUREG-1021, Rev 9 Sections ES-402 and ES-501, the facility submits the following NRC INITIAL WRITTEN EXAMINATION POST-EXAMINATION ANALYSIS for your review and consideration.

The facility proposes that question 25 of the SRO examination has Distractor a as the correct answer. This change will affect the grades of the SRO applicants.

JUSTIFICATION FOR CHANGE PAR Evacuate Problem Statement:

Keyed Answer (b) is incorrect. Distractor a is the correct answer TEDE ( r e m )

CDE, ( r e m )

r l

> 5 The following statements used to justifl b as the correct answer are incorrect:

If dose at 10 miles is projected to meet or exceed 1 rem TEDE or 5 rem CDE (Thyroid),

then make protective action recommendations and recommend evacuation to that distance in the affected areas.

The criterion identiJied in EPIP-EPP-08 R15 clearly defines the threshold value to be greater than I rem TEDE or greater than 5 rem CDE. The question stem clearly indicated values less than or equal to I rem TEDE. This fact alone means that EPIP-EPP-08 does not require any ERPAs or areas at 10.2 miles distance from the plant to be evacuated. A follow-up interview with a member of the Emergency Planning Organization (John Kaminski), supports the requirements to use field survey data for EPRA recommendations and not assumed or extrapolated dose information.

Therefore, continue the previously recommended evacuations in SCRIBA and NEW HAVEN Townships for ERPA 1,2,3,4,5,7,9,10 although the new ERPAs based on the windshift are 1,2,3,4,7 and NOT 5 and 9.

The previous PARS implied in the question stem are to evacuate ERPAs I, 2, 3, 4, 5, 7, 9, 10, 26, & 27 for a wind direction of 304. With the wind shifting to 2780, the afected ERPAs are I, 2, 3, 4, 7, 9, 26, & 27. ERPAs 5 and are not affected but will still be included per EPIP-EPP-8.

EPP-EP-P-08 Rev 15, Attachment 5, Refined Dose Assessment and Protective Actions, Steps 2.3 provides guidance for PARS clearly indicates that values greater than I TEDE or greater than 5 CDE are the criteria for the PAR for each EPRA 2.3 Obtain dose projection f o r each ERPA.

2.3.1 PARS are l i s t e d on the 10 mile ERPA m a p obtained per, Step 1.2.9. 3.

2.3.2 The following c r i t e r i a axe used in determining the PAR f o r each ERPA.

2.3.3 Record the PAR f o r each ERPA on the Part 1 Notification Form and give t o the ED/RM for approval.

2. 3. 4 PARS that have been made previously must be accounted or when PARS a r e revised.

For example, i f a PAR t o evacuate an EFSA was previously made,to the State/County and t h a t PAR does not appear on a revised ma from 1.2.9. j, t h a t PAR must s t i l l be included on the revises recommendation t o the state/county.

Once a PAR is transmitted t o the State/County, it s h a l l not be changed.

2.3.5 If projected doses exceed values l i s t e d i n Attachmeat 5 Step 2. 3. 2 tor distances reater than 1 0 m i l e s, PARS s h a l l be made usin townships?, convenien? geographic boundaries (such a s Justification for a being the correct answer:

2

IAW EPIP-EPP-08, Attachment 1, PARS are re-evaluated to account for the ship in wind direction. At 278. All of the previously evacuated ERPAs are still afSected except 5 and 10 which are still evacuated IA W EPIP-EPP-08 Attachment 5, Section 2.3.4. No further recommendations are needed since the criterion of Table 1.3 in Attachment 1 is not met.

As stated above the follow-up interview with a member of the Emergency Planning Organization (John Kaminski), supports the requirement to use field survey data for EPRA recommendations and not assumed or extrapolated dose information Justification for c and d being incorrect:

EPIP-EPP-08, Attachment 5, Section 2.3.4 does no allow us to discontinue an evacuation already recommended.

Supporting documentation attached:

EPIP-EPP-08 Revision 15 Section 3.1.1.j, Tables 1.2 and 1.3, Section 2.3 RECOMMENDATION:

On the basis of the above information the facility recommends that question 25 of the SRO exam has Distractor a, as the correct answer:

A. Continue the previously recommended evacuations in SCRIBA and NEW HAVEN Townships. Additional Evacuations are not required.

GENERAL SUPERVISOR OPERATIONS U1 SUPERVISOR OPERATIONS TRAINING:

3

Constellation Energy.

Nine Mile Point Nuclear Station P.O. Box 63 Lycoming, New York 13093 NMP-99403 December 10,2004 Mr. Samuel J. Collins Regional Administrator USNRC Region I 475 Allendale Road King of Prussia, PA 19406 - 1415 ATTENTION: Mr. John G. Caruso, Senior Examiner/Inspector

SUBJECT:

NINE MILE POINT UNIT 1 INITIAL OPERATOR POST WRITTEN EXAMINATION ACTIVITIES

Dear Mr. Collins:

The facility staff administered initial license operator written examinations to nine applicants, as authorized in a letter fkom the NRC dated November 15,2004. The initial written examination was administered on November 23,2004 in accordance with NUREG 1021, Revision 9, Draft.

Nine Mile Point Nuclear Station has conducted the post written exam activities as required by NUREG 1021, Revision 9, Draft. The following documentation is being submitted to the NRC Senior Examiner:

Original graded scantron answer sheets and attached cover sheets.

Clean copies of scantron answer sheets.

Master (as given) RO and SRO exam questions and answer keys with annotated changes during exam administration and grading.

Checklists of applicants questiondcomments during NFK initial written examination.

Checklist for NRC initial written examination post-examination comments.

Results of examination and item analysis.

Written exam seating chart.

Signed and completed written exam grading quality checklist Form ES-403-1 for Reactor Operator and Senior Reactor examinations.

The post exam security agreement will be submitted as soon as possible. Call Gregg Pitts, General Supervisor Operations Training, at 3 15-349-1 864 if you have any questions.

Sincerely, Terry A.

Manager Nuclear Training TAE/crr Enc.

NMPI License Class LC1 03-01 NRC INITIAL WRITTEN EXAMINATION POST-EXAMINATION ANALYSIS Per NUREG-1021, Rev 9 Sections ES-402 and ES-501, the facility submits the following NRC INITIAL WRITTEN EXAMINATION POST-EXAMINATION ANALYSIS for your review and consideration.

The facility proposes that question 25 of the SRO examination has 2 correct answers. This is a result from the lack of stem focus. This change will affect the grade of one applicant.

OPS-UNIT1 Page: 1 of 6 1211 0104

~~

EXAMINATION ANSWER KEY NRC 2004 UNIT 1 SRO WRITTEN EXAMINATION 25 SYSID: 21206 Emergency events are in progress:

Points: 1.00 0

(08:OO) General emergency declared.

a 0

0 0

(08:12) Notification sent with wind direction from 304'.

(08:42) EOF is manned including county and state representatives.

(0852) Radiological Assessment Manager reports radiation levels up to 1 REM TEDE are projected outward to 10.2 miles from the site.

(08:52) Wind direction HAS SHIFTED and is now from 278'.

Which one of the following is the correct information to be communicated to the EOF regarding protective action recommendations?

A.

Continue the previously recommended evacuations in SCRIBA and NEW HAVEN Townships. Additional Evacuations are not required.

6.

Continue the previously recommended evacuations in SCRIBA and NEW HAVEN Townships. Additional evacuations are being recommended for MEXICO and RICHLAND townships.

C.

Some evacuations in SCRIBA Township will be discontinued. Continue the previously recommended evacuations in NEW HAVEN Township. Additional Evacuations are not required.

D.

Some evacuations in SCRIBA Township will be discontinued. Continue the previously recommended evacuations in NEW HAVEN Township. Additional evacuations are being recommended for MEXICO and RICHLAND townships.

Answer:

B Associated objective(s):

Development Area (FIO)

OPS-UNIT1 Page: 2 of 6 1211 0104

EXAMINATION ANSWER KEY NRC 2004 UNIT 1 SRO WRllTEN EXAMINATION u

Question 25 Details L'

Question Type:

Topic:

System ID:

User ID:

Status:

Must Appear:

Difficulty:

Time to Complete:

Point Value:

Cross

Reference:

User Text:

User Number 1:

User Number 2:

Comment:

Multiple Choice NRC SRO REPLACEMENT #25 21206 Active No 0.00 0

1.oo LC1 03-01 0.00 0.00 EPIP-EPP-08, Attachment 1, Table 1.2 EPIP-EPP-08, Attachment 5, 2.3.4, 2.3.5 Answer:

b. If dose at 10 miles is projected to meet or exceed 1 rem TEDE or 5 rem CDE (Thyroid), then make protective action recommendations and recommend evacuation to that distance in the affected areas. Also, PARs made previously must be accounted for when revised. For example, if a PAR to evacuate an ERPA was previously made and that PAR does not appear on a revised map (ERPAs change) that PAR must sill be included in the revised recommendations to the State/County. Once a PAR is transmitted to State/Count, it shall not be changed.

Therefore, continue the previously recommended evacuations in SCRIBA and NEW HAVEN Townships for ERPA 1,2,3,4,5,7,9,10 although the new ERPAs based on the windshift are 1,2,3,4,7 and NOT 5 and 9. Additional evacuations are to be recommended out to 10 miles which includes areas in NEW HAVEN, MEXICO, and RICHLAND townships. If projected doses exceed 1 REM TEDE for distances greater than 10 miles, PARs shall be made using convenient geographical boundaries (such as townships).

a. Additional evacuations are to be recommended for affected areas out to 10 miles.

c. PARs made previously must be accounted for when revised. For example, if a PAR to evacuate an ERPA was previously made and that PAR does not appear on a revised map (ERPAs change) that PAR must sill be included in the revised recommendations to the State/County. Once a PAR is transmitted to State/Count, it shall not be changed. Additional evacuations are to be recommended for affected areas out to 10 miles.

d. Additional evacuations are to be recommended for affected areas out to 10 miles.

Distractor:

Distractor:

Distractor:

References Provided: EPIP-EPP-08 (entire procedure), Ten Mile Emergency Planning Zone (COLOR) map with ERPAs and Townshiplines.

OPS-UNIT1 Page: 3 of 6 1211 0104

EXAMINATION ANSWER KEY NRC 2004 UNIT 1 SRO WRITTEN EXAMINATION Question 25 Cross References (table item links) 10CFR55

- 43(b)(4)

Coanitive Level

- 3 NUREG 1123 KA Catalog Rev. 2

- G2.4.44 2.1/4 Knowledge of emergency plan protective action recommendations

- 295038 High Offsite Release Rate Question Source

- New PROC

- EPIP-EPP-08 Rev. NA OPS-UNIT1 Page: 4 of 6 1211 0/04

JUSTIFICATION FOR CHANGE The flaw stems from the ambiguity in the@ bullet that states:

(08:52) Radiological Assessment Manager reports radiation levels up to 1 REM TEDE are projected L

outward to 10.2 miles from the site. More specifically -...up to 1 REM TEDEprojected outward to 10.2 miles...

The author of the question assumed that the applicants look at the calculation as a linear function and assumed that the applicants would determine that 1 REM TEDE would be exceeded. A faulty mental model during question development and review failed to take into account any meteorological conditions.

In accordance with EPIP-EPP-08 the criteria used to determine PAR for each ERPA is Evacuate when TEDE is >I (greater than). This can be found in several sections including: Step 3.1.I. j. 3., Attachment 1 Flow chart (not provided during exam) and Table 1.3, Attachment 5 step 2.3.4 3.1 Dose Assessment and Protective Action from the Control Room CAUTION Calculation involving the determination of release rates and/or protection action shall be self-checked for accuracy.

3.1.1 Chemistry Technician Actions j.

IF an unmonitored atmospheric release is suspected or known to be in progress, then assist the SSS/ED in the following actions:

1. Advise the SSS/ED to expedite the dispatch of Radiation Protection (RP) Technician. Request assistance of the unaffected Unit or J.A.

Fitzpatrick if needed.

2. The RP Technician should be dispatched to potential plume centerline

{wind direction (degrees) 180 = plume centerline}, as close to the site boundary as practical. See Attachment 1, Figure 1.4 for Site boundary location.

3.

IF readings indicate > 1 Rem/hr based on field survey perform the actions indicated in Attachment 1.

TABLE 1.3 - EPA 400 Protective Action Guidelines (EPA PAGs)

PAR)

I TEDE(rem I ) cDE~(rem Evacuate I > 1 I > 5 2.3.4 PARs that have been made previously must be accounted for when PARs are revised. For example, if a PAR to evacuate an ERPA was previously made to the State/County and that PAR does not appear on a revised map from 1. 2. 9. j,

that PAR must still be included on the revised recommendation to the State/County. Once a PAR is transmitted to the State/County, it shall not be changed.

To select between answer A and B, evaluation of the following data is required:

radiation levels are up to 1 REM... outward to 10.2 miles.

There are multiple assumptions that can be made based on the given conditions. Since evacuation of any ERPA or areas beyond 10 miles is based on the dose projection for that specific area and no areas are stated as being greater than 1 REM then it cannot assumed there is an area or multiple areas above 1 REM closer to the plant farther from the plant. Dose closer to the plant or beyond 10 miles could be in OPS-UNIT1 Page: 5 of 6 1211 0104

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City and Villages Railroads Emergeny Response Planning Area (ERPA) & Number ERPA-Water Area Numbers Emergency Facility Radiological Emergency Plans and Procedures NINE MILE POINT EMERGENCY PREPAREDNESS

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c NINE MILE POINT NUCLEAR STATION EMERGENCY PLAN IMPLEMENTING PROCEDURE EPIP-EPP-08 REVISION 15 OFF-SITE DOSE ASSESSMENT AND PROTECTIVE ACTION RECOMMENDATION TECHNICAL SPECIFICATION REQUIRED Approved by:

G. L. Detter Manager Security and Emergency Preparedness Date Effective Date:

PERIODIC REVIEW DUE DATE:

2.0 2.1 2. 2 2. 3 2. 4 2. 5 2.6 3.0 3.1 PURPOSE To provide the methods for determining meteorology data, release rates, dose assessment and protective actions during accident conditions at Nine Mile Point.

PRIMARY RESPONSIBILITIES The Station Shift Supervisor/Emergency Director (SSS/ED) :

2.1.1 Ensures meteorological data acquisition, release rate determination, and dose assessment are performed during the initial stages of an emergency to support development of Protective Action Recommendations (PARs) 2.1.2 Approves PARS and ensures their timely issue to the State and The Emergency Director/Recovery Manager (ED/RM) approves PARs prior to their transmittal to the State and County, following EOF activation.

The Radiation Assessment Manager (RAM) is responsible to the TSC Manager for managing the onsite radiological monitoring and assessment aspects of the station during an emergency, following TSC activation.

Chemistry Technicians perform release rate assessments, obtain meteorological data, and develop PARs, prior to EOF activation.

The Offsite Dose Assessment Manager (ODAM) manages the offsite dose aspects of an emergency in order to assess the radiological consequences to the public, following EOF activation.

The Radiological Assessment Staff is responsible to the ODAM for obtaining meteorological data, determining source term, performing dose assessment, and developing PARs, following EOF activation.

County PROCEDURE Dose Assessment and Protective Action from the Control Room CAUTION Calculation involving the determination of release rates and/or protection action shall be self-checked or accuracy.

3.1.1 Chemistry Technician Actions

a. Review and complete (as appropriate) EPIP-EPP-23 Attachment

8.

Page 1 EPIP-EPP-08 Rev 15

3.1.1 (Cont) v

b. Consult the SSS/ED on plant conditions and possible release paths. If a General Emergency has been declared, assist SSS/ED in making Protective Action Recommendations based on plant conditions using Attachment 1.

c. Access EDAMS computer using Attachment 2.

d. Obtain meteorological data using Attachment 3 (each 15 minutes).

e. Assess effluent monitor readings and conditions.

f. Determine release rates using Attachment 4.

1.

Sum all release points from the same elevation (ground or elevated).

2.

Calculate the total release rate from combined ground and elevated sources using the workspace on Attachment

1.

g. Compare the release rate to the Table 1.1 values.

h. Use Attachment 1 flowchart and advise SSS/ED of any PARS recommended by the flowchart.

NOTE :

A release (tube leak) from the Emergency Condenser (EC)Vent is considered an unmonitored atmospheric release. An out of plant survey is needed to determine actual Release Rate.

i.

Compare monitor readings and calculated release rates to ODCM limits using Attachment 4A.

IF an unmonitored atmospheric release is suspected or known to be in progress, then assist the SSS/ED in the following actions :

1.

Advise the SSS/ED to expedite the dispatch of Radiation Protection (RP) Technician. Request assistance of the unaffected Unit or J.A. Fitzpatrick if needed.

2.

The RP Technician should be dispatched to potential plume centerline {wind direction (degrees) i 180" =

plume centerline}, as close to the site boundary as practical. See Attachment 1, Figure 1.4 for Site boundary location.

3.

IF readings indicate > 1 Rem/hr based on field survey perform the actions indicated in Attachment 1.

Page 2 EPIP-EPP-08 Rev 15

3.1.1 (Cont)

k. Assist the SSS/ED in completing the Part 1 Notification Fact Sheet.

1. Continue to monitor meteorological data, changes in effluent conditions or conditions that might lead to abnormal radiological effluents (or changes to PARs).

m. When contacted by EOF Dose Assessment Staff, provide briefing on:

Status of any radiological releases Dose assessments efforts to date Impending or actual PARs 3.1.2 SSS Actions

a. Verify that the Chemistry Technician is performing dose assessment and protective action development in a timely fashion and in accordance with Attachment 1.

b. Assess any release rates or monitor readings provided by the Chemistry Technician against the Emergency Action Levels (EAL).

c. Review AND approve PARs recorded on the Notification Fact Sheet Part 1, as required. Use ERPA map in Attachment 1 if desired.

3.2 Dose Assessment and Protective Actions from the EOF 3.2.1 Offsite Dose Assessment Manaqer (ODAM) Actions

a. IF at any time the initiating conditions listed in are met, THEN perform the actions listed in that attachment.

b. Perform actions as indicated in EPIP-EPP-23.

c. Verify Environmental Survey Sample Team Coordinator has been assigned and is:

1.

Preparing for the dispatch of downwind survey teams.

2.

Aware of Meteorologist availability.

Page 3 EPIP-EPP-08 Rev 15

\\---

d. Perform or have performed the following:

1.

Obtain meteorology data using Attachment 3 of this procedure.

rate using Attachment 4 of this procedure.

2.

Obtain effluent monitor readings and calculate release

3.

Perform dose assessment calculations and PARs using of this procedure.

e. Interface with State and County representatives in the EOF.

1.

Keep State/County representatives informed of confirmed data and results.

f. Complete Part 2 Notification Fact Sheet in accordance with NOTE :

A release (tube leak) from the Emergency Condenser (EC)

EPIP-EPP-23.

Vent is considered an unmonitored atmospheric release.

An out of plant survey is needed to determine actual Release Rate.

g. Constantly reassess effluent monitors (release rate) and meteorological data for changes. Perform new dose assessment as needed. Develop new PARs and/or verify the adequacy of PARs already made.

h. As Downwind Survey Team (DST) becomes available, utilize it to verify release rates. If these refined release rates differ significantly from those calculated from effluent monitor readings, reperform dose assessment using refined release rates.

i. Provide data for the Part 1 Notification Fact Sheet as requested.

j. Provide ED/RM with pertinent information as needed.

1.

Changing radiological conditions that may lead to PARS.

2.

Protective actions for site staff.

k.

Maintain Chronological Release Rate Log (see.1).

Page 4 EPIP-EPP-08 Rev 15

4. 0 4. 1 4. 2 4. 3 4. 4 4. 5 4. 6 5.0 5.1 3.2.2 EOF Dose Assessment Staff

a. IF at any time the initiating conditions listed in are met, THEN perform the actions listed in that attachment.

b. Perform actions as indicated in EPIP-EPP-23.

c. Perform any actions as requested by the ODAM, including:

Obtaining meteorological data (Attachment 3)

Obtaining release rate data (Attachment 4)

Performing dose assessment and protective action recommendations (Attachment 5 )

DEFINITIONS CDE,.

Committed dose equivalent to the thyroid for the child.

EDAMS. Emergency Dose Assessment Modeling System. A PC-based computer program that calculates release rates, doses and protective actions, and obtains meteorological data for emergencies.

MMS. Meteorological Monitoring System. Consists of the dedicated computer, main, backup and inland towers and software. Stores and edits site meteorological data.

RADDOSE. A subprogram of EDAMS, it performs the dose assessment functions during emergencies.

SHELTERING. A protective action whose benefit is to bring the public to a heightened state of awareness. No dose reduction is assumed for sheltering.

TEDE. Total Effective Dose Equivalent.

REFERENCES/COMMITMENTS Technical Specifications None Page 5 EPIP-EPP-08 Rev 15

5.2 Licensee Documentation 5.2.1 NMP Unit 1 FSAR,Section XV

a. Table XV-32

b. Table XV-28

c. Table XV-29

d. Table XV-23

e. Table XV-29d

f. Section 1.3.1

g. Section 2.1 5.2.2 NMP Unit 2 USAR, Section 15

a. Table 15.6-15b

b. Table 15.4-12

c. Table 15.7-11

d. Table 15.6-8

e. Table 15.7-4

f. Table 15.6-3

g. Table 16.6-19 5.2.3 SEP, Nine Mile Point Nuclear Station Site Emergency Plan 5.2.4 NMPC Correspondence 96-MET-001 (Backup Tower Wind Speed Correction Factor) 5.2.5 NMP Correspondence 96-MET-002 (Main Tower Wind Speed Correction Factor) 5.2.6 NMP Correspondence 96-MET-004 (Backup Tower Wind Direction Concerns) 5.2.7 NMP Correspondence 96-MET-003 (Discussion at DER C-95-0693) 5.2.8 NMP Correspondence 96-MET-005 (Main Tower 30' Sigma Theta Concern) 5.2.9 NMP Correspondence 97-MET-002 (Main Tower Wind Obstructions)

Page 6 EPIP-EPP-08 Rev 15

5.3 Standards, Resulations, and Codes NUREG-0654, FEMA-REP-1, Rev 1, Supp 3, Criteria for Protective Action Recommendations for Severe Accidents 5.4 Policies, Prosrams, and Procedures 5.4.1 EPIP-EPP-07, Downwind Radiological Monitoring 5.4.2 EPIP-EPP-15, Emergency Health Physics Procedure 5.4.3 EPIP-EPP-23, Emergency Personnel Action Procedures 5.4.4 N2-CSP-LWS-M203, Monthly Liquid Release Dose Calculation 5.4.5 Nl-CSP-M204, Liquid Release Dose Calculation 5.4.6 "Implementation of the use of KI as a protective action for the public", New York State EP Subcommittee Technical Issues Task Force, March 2003 5.5 Commitments DER C-95-0693 (for Attachment 3) 6.0 RECORDS REVIEW AND DISPOSITION 6.1 The following records generated by this procedure shall be maintained by Records Management for the Permanent Plant File in accordance with NIP-RMG-01, Records Management:

NOTE: For records generated due to an actual declared emergency only., Initial Dose Assessment and Protective Actions, Release Rate Determination.1, Chronological Release Rate Log.2, EDAMSjRadDose Data Entry Form 6.2 The following records generated by this procedure are not required or retention in the Permanent Plant File:

NOTE: For records generated NOT due to an actual declared emergency only., Initial Dose Assessment and Protective Actions, Release Rate Determination.1, Chronological Release Rate Log.2, EDAMS/RadDose Data Entry Form Page 7 EPIP-EPP-08 Rev 15

~~

~~

ATTACHMENT 1: INITIAL DOSE ASSESSMENT AND PROTECTIVE ACTIONS Sheet 1 of 4 A-(I) Use this formula if release has a ground AND elevated source:

IF 2 1, A General Emergency Exists I

1 Elevated Release Rate (Ci/s)

Table 1.1 Elevated release rate (Ci/s)

Ground Release Rate (Cils)

Table 1.1 Ground Release Rate (Ci/s) t 7+1 7 =

Page 8 EPIP-EPP-08 Rev 15

Sheet 1 o f 4 P Obtain meteorological Is total release rate data P Determine re!-

rates ( 1 )

V

$- YES r

EVACUATE AND IMPLEMENT KI PLAN ERPAs 2 miles around and 5 miles downwind using Table 1.2 or EDAMS AND Verify thaf release rates are supported by RadlPlant Advise SSSED that conditions. Consider:

conditions for a P

CoreDmage P

Effluent monitor EMERGENCY have EWAs EOF Only: If lake breeze is present, THEN EVACUATE Zake Breeze adjusted ERPAs in Table 1.2 L-Monitor wind direction I+

2 I

w t

I made?

SSS dispatch RP Tect to plume centerline (wind direction t 1 8 0 degrees) as close to site boundary as practical. RF Tech to take dose rate readings P

Monitor Emergency Classification

> Monitor Release Rates P

Monitor Plant Conditions 4-( 7 )

Use this formula if release has a ground AND elevated source:

- IF 2 1, A General Emergency Exists Elevated Release Rate (Cils)

Table 1.1 Elevated release rate c

(Cils)

I+[

(Cils)

Ground Release Rate (Ci/s)

Table 1.I Ground Release Rate Page 8 EPIP-EPP-08 Rev 15

ATTACHMENT 1:

(cont)

Sheet 2 of 4 TABLE 1.1 - GENERAL EMERGENCY RELEASE RATES Wind Direction From TABLE 1.2 - AFFECTED ERPAs Lake Breeze Adjusted 15 Mile Radius) 2 Miles Around and 5 Miles Downwind PAR TEDE (rem)

CDE, [rem)

Page 9 Evacuate

>I EPIP-EPP-08 Rev 15

> 5

'L L

ATTACHMENT 5:

REFINED DOSE ASSESSMENT AND PROTECTIVE ACTIONS Sheet 1 of 6 1.0 DOSE ASSESSMENT 1.1 General Considerations 1.1.1 The dose assessment program is called RADDOSE.

1.1.2 Meteorological data is automatically sent to RADDOSE by the Meteorological Monitoring System (MMS). The user can use this data or manually input data.

that described in Attachment 4.

1.1.3 Source term and release rate determination is identical to 1.2 Dose Assessment Procedure NOTE :

The dose assessment model has many capabilities beyond those used in this procedure. Use the "EDAMS Operators Manualvg (available in the EOF) for further reference.

1.2.1 Log on to EDAMS computer using Attachment 2.

1.2.2 Select the affected Unit "Dose Assessment Model."

1.2.3 Utilize "EDAMS/RadDose Data Entry Formrz,.2, or 1.2.4 Select "Begin New Incident" at the options.

1.2.5 Select "Yesr1 to erase all previous data when prompted.

1.2.6 Enter the following at the Accident Scenario Definition equivalent.

screen :

a.

Reactor Trip Date. This is the date that the reactor scrammed or was manually tripped. IF the reactor is not shut down, enter tomorrow's date.

b.

Reactor Trip Time (24-hour format). This is the time that the reactor scrammed or was manually tripped.

c.

Release Date. This is the date that the release to the atmosphere began, or is projected to begin.

d.

Release Time (24-hour format). This is the time that release to atmosphere began or is projected to begin.

e.

Enter ;he lake temperature (deg F).

If unknown, hit "Enter and historical data will be entered.

f.

Enter the initials of the user (two or three initials).

g.

Verify entries, make any necessary changes, and select accept to continue.

Page 34 EPIP-EPP-08 Rev 15

ATTACHMENT 5:

(Cont)

Significant (grain boundary -melt)/SBGT or GTS Severe (melt)/SBGT or GTS Sheet 2 of 6 LOCA Severe Accident 1.2.7 Select "Enter/Edit Source Term Data" from the EDAMS main menu.

Severe (melt) /none NOTES :

1.

Use Attachment 4 to obtain the information needed to complete this section.

2.

The preferred source of release rate data is the actual isotopic distribution, if available.

Severe Ac c i dent

a.

Select the accident type that most closely matches the source term going to the environment. Use the table below as a guide.

Fuel Damage/Reduction Mechanism I Accident Type 11 II I1 None/none I

II I1 Minor (gap release)/SBGT or GTS I

II I1 (1

Significant (grain boundary - melt)/none 1

DBA NOTE :

llElevatedll releases are releases from the stack. llGroundll releases are from any other release point.

Page 35 EPIP-EPP-08 Rev 15

ATTACHMENT 5 :

(Cont)

Sheet 3 of 6 1.2.7 (Cont)

c.

Select the I1Methodl1 used to determine the release rate by selecting the highlighted

!IF2 key and selecting.

1.

Utilize Attachment 4 Section 2.0 for Unit 1 cell or by hitting the releases.

2.

Utilize Attachment 4 Section 3.0 for Unit 2 releases.

a.

Enter correct Calibration Factor, if appropriate, then select I9OKl1.

b.

Enter appropriate Flow Rate and monitor reading.

d.

Select the Iodine release rate I1Methodr1 by selecting the highlighted cell or by hitting I1F2l1 key. Utilize one of the following:

1.

Grab Sample:

This section can be used if concentrations (pCi/cc) by isotope, and associate flow rate are available

a.

obtain sample analysis results from TSC

b.

enter concentration of each isotope

c.

enter flow rate (cfm) associated with sample NOTE :

This method will override previously input Total Release Rate method the release rate (in Ci/Sec) obtained by any method, including the following

2.

Direct:

This selection utilizes direct entry of a)

Use of downwind survey team data

1) determine the representative I/NG ratio using field data and the methodology described in EPIP-EPP-07.

2) multiply the NG or total release rate (obtained from Attachment 4) by the I/NG ratio.

3) enter the Iodine release rate in the appropriate column.

Page 36 EPIP-EPP-08 Rev 15

Y Accident Type

/I ATTACHMENT 5:

I/NG Ratio u1 u2 (Cont

)

Steam Line Break Sheet 4 of 6 1.2.7 (Cont)

3.

Ratio:

This selection utilizes the UFSAR/USAR I/NG ratio and multiplies it by the Total Release Rate.

7.64 33.5 LOCA I 5.59 E-4 I 2.23 E-4 11 II DBA I

8.2 E-4 I 1. 9 7 E-2 11 II

4.

UFSAR:

e.

Up to three Accident Types (and therefore three release paths) can be entered. To enter additional release paths, repeat Steps a - d above. When all applicable accident types have been entered, proceed to the next step.

f.

Upon completion of this screen, verify data and make any necessary changes before IlAcceptIl.

required. Enter meteorological data as required:

a.

Select "Enter/Edit Meteorological Data", Elevated or

b.

If the MMS is available, the data will be automatically 1.2.8 The user will be queried for the meteorological data Ground as appropriate.

displayed for the current time step.

1.

Select "Requery MMS".

2.

Select l1Acceptf1 as necessary.

Page 37 EPIP-EPP-08 Rev 15

ATTACHMENT 5 :

(Cont

)

Sheet 5 of 6 1.2.8 (Cont)

c.

If the MMS is unavailable, then enter both ground and elevated met data obtained from alternate sources, as outlined in Attachment 3 of this procedure and select IIAccept 1.2.9 Select llPerform Calculationsf1 from the EDAMS main menu.

NOTE :

The purpose of the following steps is to determine the projected avoidable dose resulting from the incident.

Any calculations performed on actual data shall be verified. The ODAM may act as the checker for calculations performed by the Rad Assessment Staff.

CAW I ON

a.

b.

C.

d.

e.

f.

g.

h.

i.

1.

k.

1.

m.

n.

The map of the 10 mile Emergency Planning Zone (EPZ) will appear with centerline dose rates when the calculation is complete.

Select llContinuell to go to the output menu.

Select llContinue Calculations" from the output menu.

Select IIPerform Forecastg1 from the RADDOSE main menu.

Verify both meteorology and source term data as required.

Enter llForecast Period" (i.e. - release duration). Use 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> as a default value.

Select I1OK1I.

Select I1Yes1l if a GE has been declared for any reason, OR llNolr if GE has not been declared.

After the forecast map appears I1Continuer1 to go to the output menu.

Select " G o to Report Menu".

Select "Print 10-Mile ERPA Map".

Select l ' P r i n t Complete DosejDose Rate Report".

Select "Print Notification Form Part 211, as directed by the ODAM, to print Part I1 Notification Fact Sheet.

Attach results of Step 1. 2. 9. j and k to EDAMS/RadDose Data Entry Form, Attachment 5. 2 or equivalent.

Page 38 EPIP-EPP-08 Rev 15

ATTACHMENT 5 :

(Cant 1.3 Sheet 5 of 6 1.2.9 (Cont)

0.

Verif that any results are supported by radiological and pyant conditions. Consider:

9 Core damage Drywell high range monitor readings Effluent monitor readings Inplant radiological conditions Containment hydrogen monitor readings

p.

If the next 15 minute internal is part of the forecast for ERPAs/towns/etc., where the plume has not yet arrived at those locations, add data to the next projection.

If it is desired to utilize EDAMS to track near real-time doses, then perform the following steps:

CAUTION The results of this step shall NOT be utilized to determine PARs.

1.3.1 Enter accident, source term and meteorological data in accordance with Steps 1.2.1 through 1.2.8 of this attachment.

1.3.2 Select lIPerform Calculations" from the EDAMS main menu.

1.3.3 Enter meteorological and source term data at 15 minute 1.3.4 Determine dose at any time by viewing the displayed 10 mile intervals.

ERPA map.

2.0 REFINED PROTECTIVE ACTIONS 2.1 These actions are initiated for the Eurpose of verifying the adequacy of PARs made using Attachment 1 of t is procedure OR to develop PARS using projected doses obtained from Attachment 5, Step 1.2.9 of this procedure.

2.2 In determining PARS based on dose assessment, carefully consider factors such as release duration and Evacuation Travel Time Estimates (ETTE). (For example, puff releases may yield doses in excess of Protective Action Guidelines for an evacuation, but the plume will pass before an evacuation could be completed). ETTEs are available in the EOF.

shall include implementation of the KI Plan.

2.3 If evacuation is recommended for an ERPA, Then the recommendation Page 39 EPIP-EPP-08 Rev 15

2. 3 PAR Evacuate

'v TEDE (rem)

CDE, (rem)

> 1 5

-\\

ATTACHMENT 5 :

(Cont

)

Sheet 6 of 6 NOTE :

County and State PARs take many factors into account that NMP rocedures do not (i.e. - road conditions, s ecial popu?ation needs evacuation scenarios, and shelrer vs evacuation dosesj. Therefore, differences in PARs may occur. The ODAM must account or differences in PARs, when those differences exist. This can be accomplished via consultation with County and State representatives in the EOF as to the assumptions used in their dose calculations and PAR development.

Obtain dose projection for each ERPA.

2. 3. 1 PARs are listed on the 10 mile ERPA map obtained per, Step 1. 2. 9.

1.

2. 3. 2 The following criteria are used in determining the PAR or each ERPA.

TABLE 5.1 - FSARlUSAR ACCIDENT TYPE Unit 1:

DBA Loss of Coolant Control Rod Drop Refueling Accident Steam Line Break Loss of Coolant (Realistic)

Unit 2:

DBA Loss of Coolant Control Rod Drop Refueling Accident Steam Line Break Rad Gas Waste System Leak Instrument Line Failure Fuel Cask Drop Loss of Coolant (Realistic) 5.50E+O 2.51 E+l 6.36E+0 3.78 E-2 1.79E-3 I

4.53E-3 6.03E-5 3.84E-5 1.00E-6 4.86E+1 1.03E+1 1.77E+1 3.64E+0 4.06E+O 0.00 2.06E+O 4.22E-2 1.05E-2 2.03E-1 4.70E-4 1.65E-1 0.00 2.1 7E-2 2.68E-3 2.38E-5 1.22E+2 Analyzed Release Point Elevated Elevated Elevated Ground Elevated Elevated Ground Ground Ground Ground Ground Ground Elevated Page 4 0 EPIP-EPP-08 Rev 15

0.628 0.856 0.976 0.710

. -. PERFORM FORECAST - -

If current dose rates continua, dases may exceed FAG:

KEM (.976) with the greatest Dose at 5 miles from the site and all Dose prqjections below 1 REM. Note that the wind direction change was included in this case approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> into the event.

This dose calculation was made by RADDOSE software described in EPIY-E1I-08 (see Attachment 5) and maintained in accordancc with EPMP-EIP-03 (see step 3.1.4). These doses are based. ~ 6 a LOCA with manually input release data and meteorological data.

a I,

L

Raddose-V Source Term Data Entry I

1 I

k+U

dosc elratad Meteorotogi t

r t

L Data 1111 Requery MMS e d

>..- e id Meteorological U ut

~

I I

I Enter wind speed betwsen 0 wph to I D 0 mfi