ML090210752

Draft RAI Proposed Combined Monticello and Prairie Island Emergency Preparedness Plan

ML090210752
Person / Time
Site:	Monticello, Prairie Island
Issue date:	01/21/2009
From:	Tam P Plant Licensing Branch III
To:	Arias J Northern States Power Co, Xcel Energy
Tam P
References
TAC MD6294, TAC MD6295, TAC MD6296
Download: ML090210752 (21)

Text

Accession No. ML090210752 DRAFT REQUEST FOR ADDITIONAL INFORMATION Note: Reference is made throughout to the evaluation criteria in NUREG-0654. As specified in Regulatory Guide 1.101, NUREG-0654 is an acceptable method for showing compliance with the Commissions regulations. In the absence of an alternative method of demonstrating compliance proposed by an applicant, the NRC staff used NUREG-0654 in evaluating the acceptability of the applicants emergency plans. The only proposed alternatives explicitly identified by the applicant were related to emergency response organization (ERO) staffing and augmentation time.

Note: If the information requested has already been provided in the combined Nuclear Emergency Plan, including the site-specific annexes (NEP), please provide a cross-reference to the location where it can be found. The NEP should be revised to reflect the responses to the RAIs, as appropriate.

Note: Where the staff has requested information in an RAI that is not found in the proposed NEP or site-specific annexes, the staff requests that NEP and the site-specific annexes will be revised as appropriate to provide the requested data and the revised plan and annexes submitted. The RAI response should cross-reference where the information can be found in the NEP and site-specific annexes.

Combined Nuclear Emergency Plan--General

1. Page 2 of the submittal cover letter states that [t]his revision to the Emergency Plans for Prairie Island Nuclear Generating Plant (PINGP) and Monticello Nuclear Generating Plant (MNGP) is a complete rewrite to establish a new baseline commitment. On Page 3, the letter goes on to state [t]he proposed combined NEP standardizes the commitments of both the PINGP and the MNGP emergency preparedness programs.

Beyond the staffing tables and these statements, the submittal does not identify the specific changes made to the individual PINGP and MNGP plans in developing the combined NEP. Nor does the submittal explain the rational and justification for deviations taken from currently approved individual plans and any explanation of how the combined plan incorporating these deviations continues to meet the planning standards of 10 CFR 50.47(b) and the requirements of Appendix E to Part 50.

For each of the currently approved individual PINGP and MNGP plans, please identify those program elements (other than proposed staffing change) that were changed or omitted in developing the combined NEP and site-specific annexes. Explain the rational and justification for each such change or omission and explain how the resulting combined NEP continues to meet the planning standards of 10 CFR 50.47(b) and the requirements of Appendix E to Part 50. (As used here, program elements are those items that comprise the implementation aspects of a planning standard and which generally correspond to the evaluation criteria in NUREG-0654). Editorial or formatting changes which do not change the intent or meaning of the item may be described collectively.

2. Page 2 of the submittal cover letter states that [t]his revision to the Emergency Plans for 1

PINGP and the MNGP is a complete rewrite to establish a new baseline commitment.

However, on Page 4, it states, [t]his letter makes no new commitments or changes to any existing commitments. Please explain the intent of these statements and how they are consistent.

3. Page 3 of the submittal cover letter states that [t]he NEP is organized to align with the section numbering in NUREG-0654 thus providing a direct cross reference to the base planning document. However, the staff has found several NUREG-0654 evaluation criteria that do not appear to have a corresponding section in the NEP, for example:

NUREG-0654 § II.A.1, evaluation criterion 1.b, 1.c, and 1.d do not appear to be addressed in the corresponding NEP Section A.1. Similarly, NUREG-0654 § II.C.1, evaluation criterion 1.a, 1.b, and 1.c do not appear to be addressed in the corresponding NEP Section C.1. In addition, the staff found that the NEP references given in the table of contents for the site-specific annexes did not address all of the NEP references to the site-specific annexes. Please provide a cross-reference for each licensee evaluation criterion in Section II of NUREG-0654 to the corresponding section in the NEP or the site-specific annexes. If the information requested by an evaluation criterion has not been provided, please provide the missing information.

4. The submittal of the NEP cites a periodicity requirement as annual or annually. The NRC expectation is that over time, the performance would average out to approximately every twelve months. This expectation provides scheduling flexibility while at the same time maintaining ERO proficiency and maintaining an effective emergency plan. Please describe, in the NEP, how NMC will interpret such requirements.

NEP Section A

[ref: 10 CFR 50.47(b)(1); Appendix E to 10 CFR Part 50 § IV.A.1-.8]

5. Planning Standard 10 CFR 50.47(b)(1) requires that the plan describe the primary responsibilities of the nuclear facility licensee for emergency response. This requirement is addressed by NUREG-0654 § II.A.1.a states that the plan identify the State, local, Federal and private section organizations (including utilities).

Appendix 5 to NUREG-0654 further clarifies this in its inclusion of licensees. The proposed NEP Section A does not identify the primary responsibilities of the nuclear facility licensee (nor do the site-specific annexes). Please provide the required description for the licensee. This discussion should address responsibilities such as maintaining onsite preparedness, making classifications, notifications to the offsite response organizations, protective action recommendations (as opposed to the ORO implementing same), implementing corrective and mitigative actions, providing and maintaining the alert and notification system (as opposed to the ORO activating it) and other responsibilities as appropriate.

6. The descriptions in NEP Sections A.1.1 through A.1.11 generally describe the possible or statutory role of each agency but do not identify the specific role expected to be played in an emergency response for an event at either PINGP or MNGP, whether the assistance is onsite or offsite, or how the assistance is requested. Please revise NEP Sections A.1.1 through A.1.11 as appropriate to provide a clear explanation of each agencys role and concept of response. The revised descriptions should identify the specific roles that NMC expects the agencies to perform, whether the interface between PINGP and MNGP is direct with the organization, or is via another organization, e.g. the State, and whether a letter of agreement has been obtained. Specific examples include:

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For NEP Section A.1.1, identify the specific technical assistance is NMC expecting from the NRC.

For NEP Section A.1.4, identify the specific role that the Federal Bureau of Investigation performs during an emergency response involving PINGP or MNGP.

For NEP Section A.1.6, identify the specific role that the Environmental Protection Agency performs during an emergency response involving PINGP or MNGP.

For NEP Section A.1.10, identify the specific role that the Bureau of Indian Affairs performs during an emergency response involving PINGP. Identify whether PINGP provides a protective action recommendation to the Bureau, to the State, or both.

7. NEP Sections A.1.1, A.1.2, and A.1.3, in part, do not reference the terms/documents/concepts as stated in the Nuclear/Radiological Incident Annex to the National Response Framework and, as such, the discussions do not reflect the organization and structure of the Federal response. Concepts such as Cognizant Federal Official, Federal Radiological Emergency Monitoring and Assessment Plan (FRMAP), and the Federal Radiological Emergency Monitoring and Assessment Centers have been replaced. Contrary to Section A.1.1, the Chairman of the Commission is not the senior authority for all response aspects. The NRC is the Coordinating Agency for radiological events occurring at NRC-licensed facilities and for radioactive materials either licensed by NRC or under NRCs Agreement States Program. As Coordinating Agency, NRC has technical leadership for the Federal governments response to the event. If the severity of an event rises to the level of General Emergency, or is terrorist-related, Department of Homeland Security (DHS) will take on the role of coordinating the overall Federal response to the event, while NRC would retain a technical leadership role. The last sentence in the 2nd paragraph of Section A.1.1 needs to be clarified as to what control is being transferred and to whom. Please update this discussion to reflect the provisions of the Nuclear/Radiological Incident Annex to the National Response Framework and to clarify the NRC role.

8. NEP Section A.1.7 and Section A.1.8 describe the role of the US Coast Guard and US Army Corps of Engineers during an emergency. The discussion indicates that the USCG would be contacted by the State. Please describe arrangements either PINGP or MNGP have made with the USCG or the Corps to control marine traffic on waterways which traverse or are adjacent to the plants exclusion area boundary as specified in 10 CFR 100.3.

9. The discussion in NEP Section A.4 does not describe the NMC capability for continuous 24-hr operation per NUREG-0654 evaluation criteria § II.A.4 at PINGP or MNGP.

a. Please discuss the capability for protracted response (e.g., number of response teams, method of notification, etc).

b. Identify by title the ERO position responsible for assuring continuity of resources during an emergency response.

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Section B

[Ref: 10 CFR 50.47(b)(2); Appendix E to 10 CFR Part 50 §§ IV.A.2.a,b,c; IV.A.3; IV.C]

NEP Section B.1.1

10. Page 2 of the submittal cover letter states that, for MNGP, the total on-shift responder functions are increased from 10 to 13 by the addition of two plant operators and a shift technical advisor to compensate for the elimination of 10 30-minute responders that would augment the on-shift staff. Although the proposed 19 75-minute responders and the 12 90-minute responders represents a increased staffing over the current ERO staffing of 10 30-minute responders and 13 60-minute responders, their availability is significantly delayed. Although NMC makes broad, summary statements in support to this proposed change, the NMC submittal does not provide sufficient information for the staff to determine that the three additions to the on-shift staff adequately compensate for the elimination of the 10 30-minute responders and the significant increase in overall ERO augmentation time.

a. Please provide a detailed explanation (e.g., a matrix table) of how the functions performed by each current 30-minute responder will be performed by a specific on-shift responder for the period between initial declaration of the emergency and the arrival of the proposed 75-minute and 90-minute responders.

b. For each on-shift responder who is assigned multiple functions or tasks as a result of the proposed staffing change, justify the responders capability to perform functions that would be reasonably expected to be required concurrently (e.g., fire brigade, rescue operations, communicating notifications, etc.), in the event of an accident encompassed in the planning basis established in Section 1.D of NUREG-0654/FEMA-REP-1.

c. Provide a description of the qualification, training and performance enhancing opportunities to be afforded each of the on-shift responders to enable him or her to perform the specific assigned functions that are currently performed by the corresponding 30-minute responders.

11. Page 2 of the submittal cover letter states that, for PINGP, the total on-shift responder functions are increased from 12 to 14 by the addition of a Radiation Protection (RP)

Specialist and a Chemistry Technician to the Chemistry function to compensate for elimination of 11 30-minute responders that would augment the on-shift staff. Although the proposed 19 75-minute responders and the 12 90-minute responders represents a increased staffing over the current ERO staffing of 11 30-minute responders and 15 60-minute responders, their availability is significantly delayed. Although NMC makes broad, summary statements in support to this proposed change, the NMC submittal does not provide sufficient information for the staff to determine that the two additions to the on-shift staff adequately compensate for the elimination of the 30-minute responders and the significant increase in overall ERO augmentation time.

a. Please provide a detailed explanation (e.g., a matrix table) of how the functions performed by each current 30-minute responder will be performed by a specific on-shift responder for the period between initial declaration of the emergency and the arrival of the proposed 75-minute and 90-minute responders.

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b. For each on-shift responder who is assigned multiple functions or tasks as a result of the proposed staffing change, justify the responders capability to perform functions that would be reasonably expected to be required concurrently (e.g., fire brigade, rescue operations, communicating notifications, etc), in the event of an accident encompassed in the planning basis established in Section 1.D of NUREG-0654/FEMA-REP-1.

c. Provide a description of the qualification, training and performance enhancing opportunities to be afforded each of the on-shift responders to enable him or her to perform the specific assigned functions that are currently performed by the corresponding 30-minute responders.

12. The proposed Table B-1 in the NEP tabulates the proposed staffing for both PINGP and MNGP. NMC has identified only three functional areas for which on-shift minimum staffing is assigned:

Plant Operations and Assessment of Operational Aspects Notifications/Communications Radiological Accident Assessment and Support of Operational Accident Assessment NUREG-0654 Table B-1 addresses those three functional areas and identifies the following additional two on-shift functional areas for which NMC has not assigned minimum staffing:

Plant System Engineering, Repair, and Corrective Actions Protective Actions (in-plant)

NMCs submittal cover letter states that [t]he industry adoption of the EOP concept focuses actions on mitigation rather than initial maintenance functions. The NRC staff concurs that the development of emergency operating procedures (EOPs) has properly emphasized mitigation actions. However, many of the response not obtained statements in the EOPs, including in some of the critical safety function restoration procedures, direct the operator to contact the technical support center for assistance (or words to that effect). As proposed, the technical support center (TSC) will not be capable of providing the needed support for more than 75 minutes. Please explain how the on-shift operators will be provided the support called for by the EOPs during the 75-minute augmentation period. Include in your response whether you have re-benchmarked the EOPs in simulator scenarios to evaluate the impact of the 75-minute delay in obtaining the required support.

Although the Augmented Staffing portion of the proposed NEP Table B-1 refers to on-shift for the in-plant protective action function, the corresponding Minimum Shift Staffing portion of the proposed NEP Table B-1 does not assign this function. NMCs submittal cover letter states that [n]on-licensed operators (NLOs) are trained to provide their own radiological coverage, satisfying the requirement for additional Radiation Protection (RP) Technicians. Since the NLO qualification for radiological controls does not extend beyond self-monitoring, please explain how radiological controls will be provided to other persons that will be exposed to radiological conditions onsite prior to the arrival of the 75-minute responders. In your response, please specifically identify how radiological coverage will be provided, prior to augmentation, to:

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a Offsite public service (e.g., fire fighters, local law enforcement) personnel entering a radiologically controlled area during an emergency.

b Site, ambulance, and hospital personnel providing transport or care to a contaminated injured person.

c Contamination monitoring and decontamination for site personnel during a site evacuation.

d Search and rescue actions.

13. Footnote 2 to the proposed NEP Table B-1 discusses, for MNGP, a possible increase in the number of on-shift radiation protection technicians if contract provisions preclude the assignment of NLOs to these functions. Please identify which alternative NMC is requesting NRC approval for.

14. The Minimum Shift Staffing in the proposed NEP Table B-1 does not indicate that any of the minimum staff has been assigned to any other function. However, the Fire Suppression and Rescue/First Aid functions have no assigned staffing in the proposed NEP Table B-1 other than on-shift. Please explain how the Fire Suppression and Rescue/First Aid functions are staffed at PINGP or MNGP. If these positions are staffed by persons included in the minimum shift staffing, address the burden of this multiple assignment in your response to RAI #10.b (11.b).

15. Page 3 of the submittal cover letter identifies that an Assistant Emergency Manager has been added to the EOF and that an Assistant Emergency Director has been added to the TSC. Although the Assistant Emergency Manager appears in NEP Section B.7.3, the Assistant Emergency Director does not appear to be discussed in NEP Section B.5. However, both positions appear in the respective NEP Figures B.1.c and B.1.e. These titles do not appear in the proposed NEP Table B-1 under augmented staffing and it is not apparent that these two positions are in fact an increase in minimum staffing as stated on page 2 of the submittal cover letter.

a. Please provide a description of the Assistant Emergency Director in the NEP.

b. Please identify these positions in the proposed NEP Table B-1.

16. Page 3 of the submittal cover letter identifies that an Emergency Notification System Communicator has been added to the Control Room, TSC, and EOF. Although the number of communicators has increased for the 75-minute responders (TSC), there does not appear to be a increase in the number of communicators for the control room or EOF, as the control room has one communicator now and will have one after the proposed change and the EOF has two communicators now and will have two after the proposed change. Please explain this apparent discrepancy in the communicator staffing shown in NEP Table B-1 and the increased staffing identified in the cover letter.

17. NEP Table B-1 eliminated the current position Radiological Emergency Coordinator and the Core/Thermal Hydraulics position from the on-shift, TSC, and EOF staffing.

a. Please explain who provides core/thermal hydraulics and senior HP expertise to the 6

augmented ERO?

b. Are these collateral duties that are assigned to others listed in the proposed NEP Table B-1? If so, address the burden of this multiple assignment in your response to RAI #10.b (11.b).

18. NUREG-0654 § II.B.4 states that a clear description of the ED responsibilities that may not be delegated be provided. Although NEP Section B.4.2 and NEP Table B-4 discusses transitions between the control room ED and the TCS ED and the EOF Emergency Manager, there is no clear prohibition against delegation of any of the ED responsibilities tabulated in NEP Section B.4.1. Please describe which ED responsibilities may be delegated and which may not.

19. Although the language of NEP Section B.5 clearly identifies the starting point of the 75-minute or 90-minute augmentation time, the language is not as clear in identifying when the augmentation can be considered as being complete. A primary objective of the emergency response facilities and the associated staffing augmentation is to relieve the on-shift operators of emergency functions not directly associated with manipulation of plant controls. As such, the criterion is not when the minimum number of persons has arrived at the TSC or EOF, but, rather, when those facilities have activated and assumed responsibility for their assigned functions from the Control Room. Please identify the criteria for concluding that the augmentation requirement has been met.

20. NEP Section B.5.7 addresses the TSC Security Manager position, but the position is not explicitly included as a minimum augmentation staffing in the proposed NEP Table B-1.

This appears to be inconsistent with the increased importance of security functions in the post-9/11 environment, and the significant impact a hostile action could have on an emergency response. Please explain (without safeguards information) why this position should not be included on the minimum augmentation staffing table?

21. NEP Section B.5.8.1 identifies the responsibility of the TSC Engineering Manager for directing the Engineering Group activities, but does not identify the activities and assessments to be performed by the Engineering Group. Please identify the expected activities and assessments to be performed by the Engineering Group, with emphasis on how these activities and assessments interface with activities performed by the OSC Engineering Support, EOF Technical Group, and external contractor engineering support.

22. NEP Figures B-1a through B-1f illustrate more ERO positions (some of which call for multiple persons) than can be staffed from the minimum ERO established by NEP Table B-1. For example, there are 19 positions identified for the TSC, 16 positions for the OSC, and 22 positions for the EOF compared to the 19 75-minute responders and 12 90-minute responders provided by the proposed NEP Table B-1.

a. If the ERO established by these figures has been determined to be necessary in responding to an emergency enveloped by the emergency planning basis of NUREG-0654, please provide a justification for the lesser minimum staffing.

b. Has NMC evaluated (e.g., conducted an exercise) an emergency response using only the minimum staffing of Table B-1 assuming arrival at the 75-minute and 90-minute augmentation times, and if so, what were results of the evaluation?

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c. Given the NEP ERO figures establishing an ERO larger than that in the minimum staffing in the proposed NEP Table B-1, please explain from where are the additional persons are obtained, how are they notified, and what is their expected time of arrival?

23. NUREG-0654 § II.B.6 specifies that the licensee identify the interfaces between and among the onsite functional areas, licensee headquarters support, local services support, and State and local government response organization. The evaluation criterion requests that the interfaces be illustrated in a block diagram. NEP Section B.6 is not fully responsive to this evaluation criterion. NEP Section B.6.1.2 cross-references the site-specific annexes. The NRC staff was not able to locate the specified block diagram or any relevant discussion that identifies the significant interfaces amongst the site facilities and those interfaces between the licensee and the OROs. Neither of the site-specific annexes back-references NEP Section B.6 in their table of contents. Please describe the significant interfaces among the site facilities and those interfaces between the licensee and the OROs.

24. NEP Section B.6.1.2 states that the offsite interfaces are detailed in the site-specific annexes. The PINGP annex Section 1.3 states [c]oordination between the plant, state, local and tribal authorities is defined in the Minnesota and Wisconsin state emergency operations plans. Please describe in the NEP or the site-specific annexes how coordination between the plant and each of the state, local, and tribal authorities is accomplished.

25. In NEP Section B.8, many of the descriptions are general in nature and do not clearly specify the technical assistance and ERO augmentation that the NMC expects to receive or the conditions of its receipt. For example, in Section B.8.2.1 [p]rior written agreements frequently exist in these situations. is not acceptable. Do they exist in this situation? Also, in Section B.8.3.5, . . . .may close off locks and dams or divert traffic on the Mississippi River during an emergency. Who makes this decision? Please expand upon these descriptions so that the NEP is clear on what specific technical assistance and ERO augmentation NMC expects to receive.

26. NEP Section B.9 cross-references the site-specific annexes for details on services offered by the local law enforcement agencies, ambulance services, medical services, and fire fighting. Section 2.3 of each site-specific annex addresses these services.

However, neither annex describes the services provided by local law enforcement agencies. Please describe the services provided by the local law enforcement authorities.

27. NEP Figures B.1.a and B.1.b illustrate the on-shift organization for PINGP and MNGP respectively. In both figures, the positions TSC/OSC Communicator and ENS Communicator are enclosed in a dashed box labeled Augmented Staff. The Augmented Staffing portion of the proposed NEP Table B-1 does not contain either position for the control room. Proposed NEP Table B-1 contains a Communicator position as part of the minimum on-shift staff. This position does not appear on either figure. Please explain these inconsistencies or revise the table and/or figures accordingly.

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28. NEP Figures B.1.c, B.1.d, and B.1.e illustrate the organizations for the TSC, OSC, and EOF and appear inconsistent with the minimum staffing in Table B-1.

a. Please revise NEP Figures B.1.c, B.1.d, and B.1.e to denote which positions are filled by the minimum staffing shown in Table B-1 (e.g., by block shading or fill).

b. For the remaining positions shown in NEP Figures B.1.c, B.1.d, and B.1.e please identify how and when (minutes after emergency declaration) these positions are to be filled.

c. Is the minimum staffing in NEP Table B-1, synonymous with the minimum staffing identified in NEP Section H.3 as a prerequisite for activating the TSC and EOF? If not, please explain the difference.

Section C

[Ref: 10 CFR 50.47(b)(3); Appendix E to 10 CFR Part 50 §§ IV.A.6, .7]

29. The NEP Section C.1 discussion does not provide sufficient information for the NRC staff to conclude that [a]rrangements for requesting and effectively using assistance resources have been made... as specified in planning standard 10 CFR 50.47(b)(3). In particular, the information requested by NUREG-0654 §§ II.C.1.b and II.C.1.c has not been provided. Please provide the missing information.

30. NEP Section C.2.1 identifies that liaisons are provided to state, tribal, and county personnel. In addition to these liaisons, please identify the arrangements made to accommodate state and local staff at the EOF, as stipulated by planning standard 10 CFR 50.47(b)(3).

31. In NEP Section C.3.1, please describe the ability of the onsite laboratory and counting room to be used in a post-accident environment given a design basis accident.

32. Please describe in more detail the arrangements that NMC has made to utilize the other counting laboratories referred to in the second paragraph of NEP Section C.3.1 and NEP Section C.3.2 in such an event. In your response, please identify:

a The specific NMC, state, federal, or private laboratories would be available and licensed to receive and analyze samples with elevated radioactive material content.

b The sample media, radionuclides, and concentration levels the laboratories are capable of analyzing.

c The arrangements that NMC has made to transport these samples to the external laboratories and arrangements for controlling sample analysis residues.

d For laboratories not under the control of NMC, the existence of letters of agreement.

33. NEP Section C.4.2.5 identifies supplemental emergency assistance provided to the ERO by law enforcement, fire protection, ambulance services, and medical and hospital support. Such groups are often called upon in ORO plans to perform functions associated with offsite response activities such as manning traffic control points and 9

performing route alerting. Please describe the coordination you have had with the OROs to ensure that duties assigned to these groups by the offsite plans do not adversely affect their availability to respond onsite as identified in this section.

Section D

[Per: 10 CFR 50.47(b)(4); Appendix E to 10 CFR Part 50 §§ IV.B, IV.C]

34. NEP Section D does not address the timeliness of emergency classifications. Although the regulations do not currently establish a timeliness criterion, the NRC has issued guidance on the timeliness of classifications (e.g., IN 85-80) , the NRC established 15-minutes as a reasonable period of time for assessing and classifying an emergency once indications are available to control room operators that an EAL has or may be exceeded. It is also stated that this 15-minute period should not be interpreted as providing a grace period in which a licensee may attempt to restore plant conditions and avoid classifying an emergency. Please describe NMC expectations regarding the timeliness of emergency classifications, including clear definition of what constitutes the start and the end of the 15-minute goal. Include in your description how an EAL threshold incorporating a specific time duration (e.g., fire lasting longer than 15 minutes) is addressed with regard to timeliness of classification.

35. NEP Section D does not address the EAL bases document approved in Reference 1 to the submittal cover letter as part of the PINGP EAL scheme, nor does it address the EAL bases approved in Reference 2 to the submittal cover letter as part of the MNGP EAL scheme. The NRC approved the bases as an integral part of the EAL schemes and expects that the EAL bases will be available as a reference to the personnel assigned to perform emergency classifications. Please describe NMCs expectations regarding the use of the EAL bases in the emergency classification process at PINGP and MNGP and the availability of the basis document to personnel performing classifications.

36. Appendix E, § IV.B requires that the emergency action levels be reviewed with state and local governments on an annual basis. The NRC staff could not locate a discussion of this requirement in the NEP. Please identify where in the NEP this requirement is addressed.

Section E

[Per: 10 CFR 50.47(b)(5); 10 CFR 50.72(c)(3), Appendix E to 10 CFR Part 50 §§ IV.D.1,

.IV.D.3]

37. NEP Section E.1.1 states that NMC has proceduralized a 15-minute goal for notifying state, tribal and county authorities of any declared emergency at an NMC operated nuclear power plant. The NRC staff finds this statement to be inconsistent with the requirement in Appendix E § IV.D.3 that [t]he licensee shall have the capability to notify responsible state and local government agencies within 15-minutes after declaring an emergency. The NRC expects its licensees to have the capability to complete notification of all of the responsible agencies promptly within 15 minutes of the declaration of an emergency. Please describe how NMC will meet this regulatory requirement and provide a description of this notification capability in sufficient detail for the NRC staff to determine that this requirement can and will be met.

38. NEP Section E.1.1 states that the methods and forms used for notifying state, tribal, and county authorities are site-specific and detailed in the individual plant annexes. Section 10

4.3.2 of each annex provides tabulation of the content of initial and follow-up messages.

The content of the initial notification identified in each annex is inconsistent with the content established in NEP Section E.3.1. The follow-up message content list in the annexes and in NEP Section E.4.1 does not contain the information stipulated in NUREG-0654 § II.E.4. Please identify the missing information in the NEP or provide justification for the omissions.

39. NEP Section E.2.3 identifies the general conditions that trigger ORO notifications.

Consistent with the language in Appendix E § IV.D.3, the first bullet should be revised to read Declaration of an emergency[.] Please revise the NEP accordingly.

40. NEP Section E.4.1 states, for all emergency classifications, that update messages to state and local officials will be provided on a prearranged schedule and that the state updates will contain the prearranged information. These statements do not provide sufficient information for the NRC staff to determine that the planning standard is met.

Please describe the prearranged schedule of follow up messages.

41. Appendix E, § IV.D.3 of 10 CFR Part 50 requires a licensee to demonstrate that administrative and physical means have been established for alerting and providing prompt instructions to the public within the plume exposure pathway EPZ. This section also establishes the performance objectives for the notification system. NEP Sections E.5.1, E.6.1, and Section 4.3.3 do not provide sufficient information for the NRC staff to determine that NMC has met its burden to demonstrate the required capability. Please provide additional information that describes the ANS design basis (including the design objective identified in Appendix E), its periodic test and maintenance program, the licensees role in that program, and provide a confirmation that activation of the system is the responsibility of the state and local governments. This request is applicable to any means that NMC utilizes to satisfy the Appendix E requirement for public alerting and providing prompt instructions. As an alternative, you may respond by providing a copy of the FEMA-approved Final ANS Design Reports for both the PINGPS ANS and the MNGP ANS in your response, and by incorporating by reference in the NEP or site-specific documents these design reports.

Section F

[Ref: 10 CFR 50.47(b)(6); Appendix E to 10 CFR Part 50 § VI]

42. NEP Section F and the corresponding discussions in the site-specific annex do not appear to address communication capabilities at the alternate facilities that would be used if the ERFs were inaccessible due to a hostile attach event. Please provide this information. To facilitate staff review of these communication capabilities, please provide a matrix table with the primary and backup communication capabilities on one axis and the emergency response facilities and offsite entities on the other axis.

Section G

[Ref: 10 CFR 50.47(b)(7); Appendix E to 10 CFR Part 50 § IV.D.2]

43. NEP Section G.1.1 states that detailed information regarding the dissemination of information to the public is provided in the site-specific annexes. NEP Section G.2.1 states that detailed information regarding information for transient populations is provided in the site-specific annexes. The table of contents for the annexes point to Section 2.3.8 (PINGP) and Section 2.3.6 (MNGP) as containing this information. Neither 11

of these two sections provides any information in addition to that in NEP Section G.1.1.;

in fact the three sections contain nearly identical information. Please describe in detail how the dissemination of information to the public, including transient populations will be accomplished in the PINGP and MNGP emergency planning zones.

44. NUREG-0654 § II.G.3.b states that the licensee provide space for a limited number of news media at the near-site emergency operations facility. NEP Section G, and the site-specific annexes, do not appear to address this provision. Please describe how this is accomplished for both PINGP and MNGP.

45. NEP Section G.5 calls for local news media to be provided periodic opportunities to become more familiar with certain planning information. NUREG-0654 § II.G.5 specifies an annual periodicity. The site-specific annex for MNGP provides no periodicity; the PINGP annex states [a]t least once per year. Further, although NUREG-0654 states that each licensee, state, and local government organization is to conduct these programs, the site-specific annexes place this burden on the State of Minnesota. Please describe what NMC, as the licensee, performs in this regard and at what frequency.

Please explain how information specific to the licensees emergency plans, as opposed to the State, is provided at these sessions. Does the letter of agreement between the State of Minnesota and NMC describe the States acceptance of this responsibility? If the State of Wisconsin does not participate in this arrangement, how does NMC coordinate public information with that State and the associated local governments?

Section H

[Ref: 10 CFR 50.47(b)(8); Appendix E to 10 CFR Part 50 §§ IV.E.1-.4, IV.E.8, IV.G]

46. NEP Section H.1.3 describes the generic design of the operations support center (OSC) for PINGP and MNGP as requested by NUREG-0654 § II.H.1, which in turn references NUREG-0696. Consistent with that guidance, please describe the communications capabilities in the OSC and the arrangements for the performance of OSC functions from other onsite locations should the OSC become uninhabitable or inaccessible.

47. NEP Section H.1.4 describes the primary functions of the EOF and describes the design considerations for the backup emergency operations facility (EOF). Please describe the design considerations for the primary EOF, or if the discussion of backup EOF considerations was intended to apply to the primary EOF as well, clearly state this applicability.

48. In comparing the ERF descriptions in the NEP with the descriptions in each of the site-specific annexes, the staff notes a difference in the amount of detail provided in the corresponding descriptions. For example, the NEP states that the EOF is sized for 50 people; neither annex provides this information. In cases of such differences, which description does NMC consider binding as a regulatory commitment?

49. NEP Section H.4.2.2 discusses liquid and gaseous sampling systems and refers to the specific plants UFSAR for further detail. Section 5.5.5 of the PINGP annex and Section 5.5.6 of the MNGP annex describes each sites post accident sampling system. Please describe the design basis of this system with regard to compliance with licensee commitments made to NUREG-0737 §II.B.3 as requested by Generic Letter 82-33, and to RG 1.97.

12

50. NUREG-0737 §II.F.1 and §III.D.3.3 identify requirements related to high range effluent and containment radiological monitoring and in-plant iodine monitoring under accident conditions. Please describe the design basis of the radiological monitoring and laboratory analysis capabilities generally identified in NEP Section H and the corresponding sections in the site-specific annexes with regard to compliance with licensee commitments made to NUREG-0737 and RG 1.97.

51. With regard to NEP Section H.3, the last bullet of Page 2 of the submittal cover letter addresses the ERO augmentation stating that:

The augmented ERO will respond to their respective facilities with a goal of being at minimum staffing level with 75 and 90 minutes of the emergency declaration requiring activation. The expectation is that called out ERO will respond as soon as possible, if fit for duty.

Section B.5.1 of the NEP states:

The minimum quantity of personnel available on shift, and the quantity of additional personnel available within 75 minutes and 90 minutes following declaration of an emergency, to staff the emergency organization, are shown in Table B-1.

Section H.3 of the NEP states, in part:

Augmentation times are not rigid requirements, but rather goals. It is NMCs intent to expend its best efforts to meet any planned augmentation goals for staffing Emergency Response Facilities with appropriately qualified individuals capable of handling an emergency. Due to the diversity of residential patterns for each plant, possible adverse weather conditions and/or road congestion, planned augmentation time frames might be exceeded. . . . . .Although the response time will vary due to factors such as weather and traffic conditions, a goal of 75 and 90 minutes for minimum staffing, following the declaration of an Alert or higher emergency classification, has been established for ERO personnel responding to plant emergency facilities.

Section H.3 of the NEP states, in part:

The TSC and OSC are expected to be operational within 75 minutes, and the EOF within 90 minutes. These facilities can be declared activated when the following conditions are met:

• Minimum staffing has been achieved;

• Personnel have been briefed on the situation;

• The facility is capable of performing the required functions.

Although the proposed values of augmentation times are subject to other RAIs, the NRC staff finds the language in Section B.5.1 to be generally acceptable (with the clarification requested in RAI #19). However, the language in the submittal cover letter and in Section H.3 is unacceptable as neither establishes a clear auditable commitment to maintain the requisite capability. The staff finds the second excerpt from NEP Section H.3 to be unacceptable for the same reason and because it implies that augmentation can be delayed beyond 75 minutes or 90 minutes for briefings and turnovers, and ERF startup.

The NRC recognizes that there can be constraints to augmentation that may not always be under the licensees control and that an inflexible performance criterion is inappropriate. The column heading in Table B-1 of NUREG-0654/FEMA-REP-1, reads capabilities for additions. The NRC expects that licensee to have and be able to 13

demonstrate the stated capabilities absent unanticipated circumstances outside of the licensees control. If the licensee cannot routinely demonstrate during drills, exercises, or actual emergencies that it has the capability to augment the on-shift staff due to persistent traffic congestion, employee residential patterns, persistent climatic weather conditions, or employee fitness for duty concerns within the committed time, the NRC expects the licensee to take compensatory measures to restore the capability. A promise of a best-effort is not an acceptable commitment. An infrequent inability to gather the required minimum of staff due to unanticipated external conditions (e.g.,

performance) is not a regulatory concern. However, a persistent inability to meet the minimum staffing in the required time for whatever cause (i.e. capability) is a regulatory concern. Please describe the capability for augmentation in Section H.3 in manner consistent with the language in Section B.5.1 as modified to address RAI #19.

52. In support of the proposed extension of the augmentation times, please describe PINGP and MNGP experience to date in meeting the current times by identifying the number of condition reports that have been initiated because of an inability to achieve staff augmentation within the current 30 minutes commitment and the range of minutes the 30-minute commitment was missed. Include in your response a discussion of the corrective actions that were attempted and why those actions were not successful such that it now has become necessary to extend the augmentation time from 30 minutes to 75 minutes. Please provide the same information separately for the current 60 minute commitment.

NEP Section H.5

53. The NRC staff has issued guidance on monitoring instrumentation that would be used in the event of a radiological emergency, including Regulatory Guide 1.97 and NUREG-0737. This guidance identified requirements related to ranges, accuracy, power supplies, environmental qualification, and redundancy. Please identify NMCs commitments to this guidance with regard to instrumentation used in emergency classification and accident assessment. This RAI is not requesting a tabulation of the instrumentation, but rather a statement of NMCs commitment to the guidance and summary description of any approved deviations from the guidance.

54. The National Weather Service generally reports wind speeds and wind directions at higher elevations than would be useful in a dose assessment. The National Weather Service cannot report delta-T or sigma-theta as used at nuclear power plants for determining stability class. Please describe how PINGP and MNGP will adapt the NWS data for use in site dose assessments. Please describe the location of the nearest NWS station(s) to PINGP and MNGP and provide a summary statement regard the representativeness of these data sources to the meteorological conditions at the two sites. This RAI also applies to NEP Section H.7.

55. During an emergency, how does the ERO determine which earthquake monitoring facility to contact as stated in NEP Section H.5.1? Is there a list in an emergency plan implementing procedure? Are these facilities available 24/7?

56. With regard to NEP Section H.5.3, see RAI #32.

57. Please describe how the routine operations REMP identified in NEP Section H.6 would be adapted for use during a radiological emergency. To what ERO position do these 14

personnel report? If the REMP program is implemented with contractor support, does the contract provide for monitoring functions during high ambient dose rates associated with a radiological emergency?

58. NEP Sections H.5 (onsite) and H.7 (offsite) cross-references the site-specific annexes for a description of the meteorological measurements capabilities. Section 5.6.1 of the MNGP annex provides the cited description for onsite. However, the corresponding section on the PINGP annex does not describe the onsite capabilities, but rather the offsite. Please provide information for PINGP onsite capabilities to a level of detail comparable to that provided in the MNGP annex.

59. NUREG-0654 § II.H.10 provides for equipment calibration at intervals recommended by the supplier of the equipment. Please include a comparable statement in NEP Section H.9.

60. NUREG-0654 § II.H.11 provides for an E-plan appendix that identifies the emergency kits by general category. Although inventory data is appropriate in an emergency plan maintenance procedure as provided in this NEP Section, the E-plan should identify the licensees commitment regarding the number and type of kits. The descriptions in the site-specific annexes provide insufficient information to determine compliance with the planning standard. Please provide a tabulation of the emergency kits identifying the kit locations and generally describing the type of material and equipment to be found in that kit.

61. NEP Section H.11 states that each NMC plant has a designated point for receipt and analysis of field monitoring team environmental samples. The MNGP site-specific annex identifies this location. Please identify where this point is located at PINGP.

Section I

[Ref: 10 CFR 50.47(b)(9); Appendix E to 10 CFR Part 50 §§ IV.B, IV.E.2]

62. The description in this section of the NEP is not sufficient for the staff to assess the acceptability of the PINGP and MNGP dose assessment capabilities described in NEP Section I.3. Appendix 2 to NUREG-0654 provides some guidance on characteristics of dose assessment capabilities. Please provide the following information:

Describe the ability of the PINGP and MNGP dose assessment capabilities to provide near real-time, site-specific atmospheric transport and diffusion estimates (e.g., concentrations, dose/dose rate, transit time) for the plume exposure EPZ within 15 minutes following classification of an emergency. Identify the model characteristics (e.g., Class A, or Class B, straight-line Gaussian, segmented plume, particle-in-cell). The bases and justification for these models should be documented.

Generally describe the user options available in the PINGP and MNGP dose assessment capabilities for input of actual or projected meteorological data, and the user options for the generation of source terms based on area, process, or effluent radiation monitor readings in conjunction with release stream flow rates, sample analysis results, containment dome monitor readings, pre-defined accident source terms, back calculation from field results, etc.)

Describe the ability of the model to provide reliable estimates that address seasonal, 15

diurnal, and terrain induced flows; and release mode (e.g., elevated, ground, split) as well as building complex influence.

63. Please identify in NEP Section I.5 the regulatory guidance or criteria that the meteorological measurements system is designed to meet. For example, Regulatory Guide 1.97, Regulatory Guide 1.23, ANS-2.5, etc. Please identify backup sources of meteorological data representative of the site that may be used in event the primary system is inoperable. Is this data available 24/7? Is there a letter of agreement?

64. NEP Section I.7 and I.8 and Section 4.2.3 in the site-specific annexes, generally describe the capability for field monitoring. NUREG-0654 §II.I.8 required this description to include: activation, notification means, field team composition, transportation, communication, monitoring equipment and estimated deployment times. Please provide this information or provide cross-references to where the specific items can be found in the NEP or the site-specific annexes in sufficient detail to enable evaluation. Section 4.2.3 of the site-specific annexes states that the onsite teams may be relieved by survey team comprised of personnel from the other site. Please provide the above requested information, especially deployment times, for these teams as well.

65. Please describe the NMC capability to detect radioiodine concentrations as low as 1.0E-7 uCi/cc under field conditions as stipulated by NUREG-0653 § II.I.9.

66. With regard NEP Section I.10, the corresponding guidance in NUREG-0654 § II.I.10 addresses the ability of the licensee to analyze the surface contamination, water, and air activity levels obtained from environmental measurements (NEP Section I.8), summing and integrating the data from various exposure pathways, and comparing these estimates against the protective action guides. NEP Section I.10 is not fully responsive to this evaluation criterion in that it fails to describe the ability to equate the field measurements to dose rates of key isotopes, as well as gross radioactivity levels, and their summing and integration. Please describe the capabilities that address NUREG-0654 § II.I.10 Section J

[Ref: 10 CFR 50.47(b)(10)]

67. NEP Section J.1 states that the site-specific annexes describe the assembly areas for personnel onsite. Section 5.8.1 in each annex addresses this program element.

Although each annex refers to a ...Offsite Assembly Point, its location is not identified in either annex. Please describe this location. The PINGP annex identifies two assembly points, both of which are warehouses, which are selected on the basis of wind direction. The MNGP annex identifies only one onsite assembly area and notes that the area does not provide special ventilation or shielding. Please describe how assembly is to be accomplished when the primary facilities are inaccessible or inhabitable.

68. Please describe how the monitoring of evacuees will be accomplished when evacuees are directed to proceed to their homes as stated in NEP Section J.2.1. Are the protected area exit portal monitors capable of monitoring for contamination in projected post-accident radiation fields? What alternative monitoring capability would be used in that event?

69. Please describe the criteria, including the site area emergency or general emergency 16

criteria stated in NUREG-0654 § II.J.4 used to initiate an evacuation of non-essential personnel NEP Section J.4 also states that Section K addresses actions for known or suspected overexposures or contamination. Although Section K addresses decontamination, the staff found no discussion in Section K or the site-specific annexes that addresses overexposures. Please describe actions to be taken in the event of an overexposure, or provide a cross-reference to where that information can be found.

70. Since the EPIPs are sub tiered documents that were not submitted for review, please summarize the decontamination arrangements in either the NEP or site-specific annexes in sufficient detail to enable the NRC to assess the acceptability of these arrangements.

71. In the first paragraph of NEP Section J.5 it is stated that accountability is initiated when deemed necessary by the Emergency Director. In the second paragraph, it is stated that accountability is performed in conjunction with assembly and is required whenever a Site Area or General Emergency is declared. In the interest of clarity please describe the initiation of accountability as being required whenever deemed necessary by the Emergency Director and whenever a Site Area or General Emergency is declared.

72. NEP Section J.6 addresses onsite protective actions for emergency workers... The first paragraph limits applicability to onsite personnel. The last sentence in NEP Section J.6 limits KI issuance to site emergency workers. The corresponding guidance in NUREG-0654 § 11.J.6 addresses protective actions for individuals remaining or arriving onsite during the emergency. Please describe arrangements for non-licensee personnel (e.g., Federal, state, local responders, local law enforcement personnel or fire fighters, etc.) who arrive onsite during an emergency.

73. NRC Bulletin 05-02 identified concerns that typical onsite protective measures may be inappropriate during hostile action events as they could place response personnel at increased risk. Please describe, without the use of safeguards information, the initiatives NMC implemented at PINGP and MNGP in response to the Bulletin 05-02 to address onsite protective measures during a hostile action event

74. NEP Section J.7 does not provide an adequately detailed description of the protective action recommendation process for the staff to determine that NMC has met the associated planning standard. The staff believes that this section should address considerations such as (but not limited to):

The protective actions considered within the NMC PAR logic.

The advantages and disadvantages of each protective action.

When the individual actions are appropriate / inappropriate.

When PARs based on plant condition are appropriate. When PARs based on dose assessments are appropriate.

How conflicts between plant condition-based and dose-based PARs are resolved.

How PARs beyond ten miles are assessed and determined.

The timeliness criterion for making the initial PAR and follow-up PARs based on 17

change in conditions.

When an issued PAR may be relaxed because the action is no longer required due to changes in conditions.

How the licensee PAR process considers known impediments to evacuation.

State protective action protocols that differ from the Federal guidance and how these protocols affect the licensees PARs.

Licensee PARs (e.g. isolate downstream water treatment plants) related to liquid releases within the plume exposure EPZ.

The rational behind the PINGP decision block that forces an all sector evacuation in lieu of downwind wedge whenever the wind speed is less than 5 miles per hour and the rational for establishing the downwind wedge as five sectors.

75. The staff reviewed the protective action recommendation flowcharts in the site-specific annexes and found them to be generally consistent with guidance. However, noting that an emergency response for both PINGP and MNGP involves the same states, the staff suggests that NMC undertake an effort to make the two figures consistent to the extent possible to facilitate communication and understanding between the plants and the states. The staff recognizes that the PINGP chart includes different downwind sector assignment based on wind speed, whereas, the MNGP does not. Nonetheless, this doesnt explain all of the textual and layout differences that exist. No response required.

76. NUREG-0654 § II.J.10.a requires that each organizations plans provide certain maps.

NEP Section J.10 generally states that NMC plants has maps or Maps are also available The site-specific annexes are similarly worded. The NEP, as proposed, contains no maps. The staff expects that the emergency plan contain whatever maps and figures are necessary for understanding the content of the plan and its response concept. Not all of the responders will proceed to the emergency response facilities at which NMC proposes to locate the maps. Other Federal agencies (NRC, DHS, EPA, etc) have a role in the Federal response plan and likely will not proceed to the ERFs.

Instead, these agencies will rely on the licensees plan for this information. Discussions of field survey results are seriously impeded if all parties do not have access to maps showing survey point locations. Similarly, discussions of protective action recommendations would be impeded if maps showing evacuation zone and sectors are not available to all parties. Please provide the maps specified in NUREG-0654 §J.10.a, and §J.10.b as enclosures or attachments to the NEP and/or the site-specific annexes, or provide justification for their exclusion.

77. NUREG-0654 § II.J.10.m requires the licensee to provide information regarding evacuation time estimates (ETE). Although the site-specific annexes describe the evacuation time study as being on file, neither the NEP nor the site-specific annexes provide the results of the studies. The objective of the ETE requirement is to provide information to those entities responsible for pre-emergency development of evacuation strategies and to inform protective action recommendations and decisions during emergencies. As such, the staff expects that the licensee will make copies of the study (and any updates) available to the cognizant OROs, and that a summary table of ETE 18

results be provided in the site-specific annexes for use by the ERO. Please provide a summary of the ETE results in the NEP or the site-specific annexes, or explain how the ETE data is made available to the ORO and ERO during an emergency response.

Section K

[Ref: 10 CFR 50.47(b)(11); Appendix E to 10 CFR Part 50 §§ IV.E.1]

78. Several subsections in Section K refer to equipment and resources controlled by the site radiological protection group and do not identify any resources (e.g., respiratory equipment, dosimeters, protective clothing, decontamination supplies, monitoring equipment) removed from routine use and set aside (e.g., in emergency cabinets) for emergency use). Please describe in the NEP and/or the site-specific annexes the availability of resources sufficient to support the needs of a protracted emergency response. Are these resources located such that they would be readily available to the ERO on demand? Does the proposed delay in augmenting on-shift radiological protection staff impede access to these resources?

79. Several subsections in Section K make assignments to site radiation program personnel.

These assignments appear to be inconsistent with the proposed staffing in Section B, with regard to number of personnel available and the proposed delay in augmentation, particularly those personnel qualified to provide radiological monitoring for other onsite personnel and for offsite personnel who respond and remain onsite. Please ensure that these assigned functions are included in the analysis requested in RAI #10.b/ 11.b

80. NEP Table K-1 addresses TEDE dose as does the corresponding table in the EPA Protective Action Manual. However, Table K-1 does not include the footnotes in the EPA table that address lens or eye, organ, extremity doses. Please describe the corresponding modifiers for lens of eye, organ, or extremity doses in this table.

81. The staff finds the discussion in NEP Section K.1 to be generally compliant with NUREG-0654 § II.K.1. However, the staff believes that this section needs to address two considerations if proper radiation exposure control is to be maintained and requests that the NEP be changed to describe how:

The radiation protection standards of 10 CFR 20 will be observed to the extent practicable during emergency conditions but that these standards will not be construed as limiting actions that may be necessary to protect health and safety.1 All radiation exposure received by emergency workers during an emergency response will be recorded as occupational exposure pursuant to 10 CFR 20.2 1

In the statements of consideration for the final 10 CFR 20 rule (56 FR 23365; May 21, 1991), the Commission addressed the applicability of the radiation protection standards in Part 20 to emergency situations. The Commission stated its intent that regulations [10 CFR 20] be observed to the extent practicable during emergencies provided that conformance with the regulations not hinder any actions that are necessary to protect public health and safety such as lifesaving or maintaining confinement of radioactive materials. The Commission stated its belief that dose limits for normal operation should remain the primary guidelines in emergencies.

2 Paragraph 2 of NEP Section K.1 states that the emergency director will use the guidance of the EPA manual.

The EPA Manual in Section 2.5 states that dose to workers performing emergency services maybe treated as once-in-a lifetime exposure, and not added to occupational exposure accumulated under non-emergency conditions for ascertaining conformance to normal occupational limits. 10 CFR 20.1002 and 10 CFR 1201(a) do NOT exclude emergency exposure from the scope of 10 CFR 20. See Question 472, 473, and 474 of the eighth 19

82. NEP Table K-1 states that emergency workers receiving exposures greater than 25 rem shall be volunteers, which is consistent with the corresponding table in the EPA Manual.

However, NEP Section K.2 states that any exposure in excess of occupational limits (i.e., 5 rem) shall be on a volunteer basis. Please explain the apparent inconsistency or modify the NEP accordingly.

83. NEP Section K.3.1 states that, in an emergency situation, all onsite personnel, some offsite support personnel and some local governmental emergency response personnel will be issued TLDs and/or self-reading pocket dosimeters, or electronic dosimeters.

Please describe the criteria used to determine which offsite support personnel and local governmental emergency response personnel that arrive or remain onsite would be monitored? Please confirm that these criteria are compliant with 10 CFR 20.1502.

Section L

[Ref: 10 CFR 50.47(b)(12); Appendix E to 10 CFR Part 50 §§ IV.E.5-7]

84. The 3rd paragraph of NEP Section L.1 states that plant personnel are available to assist medical personnel with decontamination, radiation exposure, and contamination control.

NEP Section L.4 states that NMC plant personnel will provide radiation monitoring services whenever ambulance services are used for transporting contaminated individuals. Since these are radiological protection functions it is assumed that these will be performed by site radiation program personnel. As such, these assignments appear to be inconsistent with the proposed staffing in Section B and the assignments made in Section K, with regard to number of personnel available and the proposed delay in augmentation, particularly those personnel qualified to provide radiological monitoring for other onsite/offsite personnel. Please ensure that these functions are included in the analysis requested in RAI #10b(11b).

85. The last paragraph of NEP Section L.1 discusses special care necessary for the treatment of persons having radiation injuries. Please describe:

Generally identify the pre-determined criteria (e.g., accumulated dose, etc.) that would trigger these arrangements.

Identify the letter of agreements for these services.

86. NEP Section L.2 states that first-aid treatment of injured personnel shall be administered by trained personnel. Please identify the number of trained first aid personnel available on shift. Do these persons have any multiple assigned duties that would preclude them administering first at6id in a timely manner?

Section M

[Ref: 10 CFR 50.47(b)(13)]

87. NEP Section M.1 (last paragraph on page 80) states that: [w]hen possible, any necessary release of radioactive materials or effluent during recovery will be planned, controlled, evaluated in advance for radiological impact NEP Section M.2.2 states set of Questions and Answers on 10 CFR Part 20.

20

that recovery exposures should not exceed 10 CFR 20 Limits. The staff believes that the transition to recovery operations signifies that the emergency phase of the accident has ended and that compliance with 10 CFR 20 radiation protection standards (including planned special exposures, as necessary) and the controls established by the sites Offsite Dose Calculation Manual are required. If these requirements can not be met then regulatory relief must be requested. Please clarify the NEP in this regard.

88. NEP Section M.4 is noncompliant with the corresponding NUREG-0654 § II.M.4 evaluation criterion that [e]ach plan shall establish a method for periodically estimating total population exposure. The staff does not believe that crediting an analysis that may be made by the FRMAP adequately describes the licensees capability. Please describe in the NEP and/or the site-specific annexes how NMC will meet this evaluation criterion.

Section N

[Ref: 10 CFR 50.47(b)(14); Appendix E to 10 CFR Part 50 §§ IV.F.1-2]

89. NEP Section N.3 tabulates characteristics of scenarios. It addition to the characteristics identified, the staff believes that the scenario needs to identify expected outcomes (e.g.,

classifications and their bases, timing of call-outs, timing of notifications, timing of PAR upgrades and the content thereof, etc) necessary to evaluate successful completion of objectives and performance opportunities. Please describe these additional characteristics in the NEP and/or site-specific annexes.

90. NEP Section N.4 addresses exercise and drill critiques. The staff believes that this discussion is missing an important expected outcome of exercise and drill critiques, namely, identification of opportunities for improving the ERO performance and of the effectiveness of the NMC NEP, as well as correcting ERO weaknesses as addressed in this NEP section. Please describe in the NEP and/or the site-specific annexes how opportunities for improving ERO performance identified in critiques will be captured for evaluation and implementation.

Section O

[Ref: 10 CFR 50.47(b)(15); Appendix E to 10 CFR Part 50 §§ IV.F.1]

See general RAIs #1-4 above Section P

[Ref: 10 CFR 50.47(b)(16)]

None.

See general RAIs #1-4 above 21