ML14115A041

Request for Additional Information, License Amendment Request to Revise Permanently Defueled Emergency Plan and Emergency Action Level Scheme

ML14115A041
Person / Time
Site:	Kewaunee
Issue date:	08/14/2014
From:	Thomas Wengert Plant Licensing Branch IV
To:	Heacock D Dominion Energy Kewaunee
Huffman W
References
TAC MF3411
Download: ML14115A041 (21)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 14, 2014 Mr. David A. Heacock President and Chief Nuclear Officer Dominion Energy Kewaunee, Inc.

lnnsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

KEWAUNEE POWER STATION- REQUEST FOR ADDITIONAL INFORMATION CONCERNING LICENSE AMENDMENT REQUEST FOR EMERGENCY PLAN CHANGES {TAC NO. MF3411)

Dear Mr. Heacock:

By letter dated January 16, 2014, Dominion Energy Kewaunee, Inc. (DEK), requested a license amendment to its Radiological Emergency Response Plan and Emergency Action Level (EAL)

Scheme. On April 27, 2014, the Nuclear Regulatory Commission (NRC) staff transmitted a request for additional information (RAI) regarding the proposed amendment. DEK responded to the staff's RAI in a letter dated June 19, 2014, and provided proposed revisions to the originally submitted emergency plan and EAL scheme.

The NRC staff has determined that additional information is needed to continue the review as discussed in the Enclosure. We request that DEK responds to these requests for information within 30 days from the date of this letter.

Sincerely,

~+e~<t--~

Thomas J. Wengert, Senior Project Manager Plant Licensing IV-2 and Decommissioning Transition Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-305

Enclosure:

Request for Additional Information

REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST FOR EMERGENCY PLAN CHANGES DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION DOCKET NO. 50-305 By letter dated January 16, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14029A076), Dominion Energy Kewaunee, Inc. (DEK) requested a license amendment to the Radiological Emergency Response Plan, hereafter identified as the Permanently Defueled Emergency Plan (PDEP), for the Kewaunee Power Station (KPS). DEK requested review and approval of a revision to the KPS PDEP to revise the emergency action level (EAL) scheme and emergency plan (EP) consistent with the KPS permanently shutdown and defueled condition. The proposed license amendment would implement the request for exemptions to certain emergency planning requirements in Title 10 of the Code of Federal Regulations (1 0 CFR) Part 50 contained in DEK's letter dated July 31, 2013 (ADAMS Accession No. ML13221A182), and therefore, is contingent on the Nuclear Regulatory Commission's (NRC's) approval of requested exemptions to Part 50.

The NRC staff is reviewing the license amendment request using the guidance contained in NUREG-0654/FEMA-REP-1, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980 (ADAMS Accession No. ML040420012), as applicable to support KPS's permanently defueled condition. Based on the NRC staff's initial review of the submittal, the staff provided requests for additional information (RAis), dated April 27, 2014 (ADAMS Accession No. ML14132A206), to facilitate the staff's continued technical review. The staff informed DEK that supplemental RAis may be required based on the staff's concurrent technical review of DEK's requested exemptions to Part 50 and other relevant decommissioning issues. DEK provided a response to these RAis via letter dated June 19, 2014 (ADAMS Accession No. ML14178A167),

as well as a response to additional RAis related to spent fuel pool (SFP) mitigation strategies via letter dated April29, 2014 (ADAMS Accession No. ML14126A005).

Further review of these RAI responses in light of current Commission's consideration of the exemption request to certain requirements of Part 50, necessitates additional RAis to ensure that the NRC staff can reach a reasonable assurance finding in accordance with 10 CFR 50.47(a)(1 )(i).

Notes:

1) These RAis are numbered as a continuation of the numbering sequence presented in the previous set of RAis related to this license amendment request.

2) A draft of the proposed evaluation criteria for permanently defueled emergency plans, based on remaining applicable portions of NUREG-0654/FEMA-REP-1, is attached for your information only. The proposed evaluation criteria is based on proposed exemptions to EP requirements as outlined in SECY-14-0066 and is Enclosure

still under staff review. However, it is provided to help inform your response to these RAis.

3) These RAis refer to the revised PDEP submitted in the June 19, 2014, supplemental submittal.

KPS-RAI-19 Under Section 6.4, "Functional Responsibilities," of the PDEP, please respond to the following:

a. NRC's evaluation of the requested exemption considers the licensee's ability to promptly implement mitigation measures for the SFP. Please explain if KPS has performed an on-shift analysis for Emergency Response Organization (ERO) functions to ensure sufficient personnel will be able to respond to a catastrophic loss of SFP water inventory using the minimum shift staffing as indicated in Section 6.4.

The response should include:

• SFP mitigation strategies as described in DEK's letters dated January 10, 2014, and April 29, 2014 (ADAMS Accession Nos. ML14016A078 and ML14126A005, respectively); and

• All functional areas of the table in Section 6.4 to address any potential collateral duties.

b. Please describe the personnel that are assigned on-shift to monitor personnel exposure and determine if radiological conditions exist that may preclude access to the SFP to perform mitigation actions, if required.

KPS-RAI-20 The PDEP is based on the NRC's granting of exemptions from certain portions of 10 CFR 50.47 and 10 CFR 50, Appendix E Section IV. The NRC staff based its evaluation of the DEK request for exemptions from EP requirements on site-specific analyses.

DEK's analysis is based on reasonable assurance that in granting the requested exemption to DEK: (1) an offsite radiological release will not exceed the Environmental Protection Agency (EPA) Protective Action Guides (PAGs) at the site boundary for a design-basis accident; and (2) in the unlikely event of a severe beyond design-basis accident resulting in a loss of air cooling, there is sufficient time to initiate appropriate mitigating actions and if a release is projected to occur, there is sufficient time for offsite agencies to take protective actions using a Comprehensive Emergency Management Plant (CEMP) to protect the health and safety of the public.

Under Section 6.4, "Functional Responsibilities," of the PDEP, please respond to the following:

a. Historically, the NRC staff has generally approved a range of ERO augmentation times of 1 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Provide further justification why a 4-hour ERO augmentation time is acceptable, in the event of a catastrophic loss of SFP water inventory, to successfully implement required mitigation actions, and, if necessary, for offsite response organizations to implement early protective measures.

KPS-RAI-21 Section 8.0, "Emergency Classification System," of the PDEP, states, in part, "Once indications are available to plant operators that an Emergency Action Level (EAL) has been met, the event is assessed and classified, and the corresponding emergency classification level is declared."

The proposed exemption to rule language is as follows:

8y June 20, 2012, nuGiear power reaGtor licensees-shall establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and shall promptly declare the emergency condition as soon as possible [emphasis added] following identification of the appropriate emergency classification level. ...

The information provided in Section 8.0 does not appear to meet the intent of the regulations, as modified by the proposed exemption, to ensure the prompt declaration of an emergency condition. Please revise accordingly or provide further justification for retaining existing language.

KPS-RAI-22 Appendix E.IV.E.9.a, "Emergency Planning and Preparedness for Production and Utilization Facilities," to 10 CFR 50 requires that State/local and the NRC communication methods be tested monthly. Section 10.0, "Emergency Communications," of the KPS PDEP does not provide any information as to the testing requirements and frequency for the listed communications systems. Please clarify whether this information is provided in any other procedure, and if so, submit a copy for staff review.

KPS-RAI-23 Please provide additional detail in Section 12.0, "Emergency Equipment and Facilities," and Appendix A, "Emergency Equipment, Supplies and Reference Material," of the proposed KPS PDEP, consistent with information that supports NUREG-0654 evaluation criteria H.1 0 and H.11. For example, Appendix A does not list any emergency supplies or radiation protection equipment.

KPS-RAI-24 Section 14.0, "Protective Response," of the KPS PDEP states, in part, "Accountability of all personnel onsite should be accomplished within 60 minutes after the announcement and maintained thereafter." Please revise accordingly to reflect the 60-minute time clock starting at event declaration or provide further justification for retaining existing language.

KPS-RAI-25 Please clarify how Section 15.0, "Radiological Exposure," of the KPS PDEP addresses the NUREG-0654 evaluation criteria K.3.a.

KPS-RAI-26 Section 18.0, "Exercise and Drills," of the KPS PDEP does not differentiate between equipment checks and performance enhancing drills for communications. State and county governments require monthly testing as stated in Appendix E.IV.E.9.a, with an annual performance enhancing drill as stated in NUREG-0654.11.N.2.a. Please clarify if this information is provided in any other procedure, and if so, submit a copy for the NRC staff's review.

KPS-RAI-27 In several sections of the KPS PDEP, the expected level of detail needed to support review of the PDEP seems to have been placed within the associated implementing procedure. Please submit, for the NRC staff's review, the following procedures listed in Appendix B, "Cross Reference Table- PDEP Section to Planning Standards/Requirements/Criteria to Procedures,"

of the KPS PDEP, or consider adopting the appropriate information from these procedures (consistent with the criteria from the attached draft emergency plan review guide) into the PDEP, thus removing the need to review these procedures:

• EP-KW-EIP-001 ,

• EP-KW-EIP-003,

• EP-KW-3001 ,

• EP-KW-EMP-009-002 ,

• EP-KW-EIP-005,

• EP-KW-400, and

• TR-KW-TPG-2400

Attachment:

Draft Evaluation Criteria

Attachment Draft Evaluation Criteria

DRAFT- FOR INFORMATION USE ONlY Regulations (as NUREG-0654 (Revised -

exempted per ISG) Evaluation Criteria Decommissioning) 50.47(b)(1) Primary Primary responsibilities for 1.b. Each organization and sub-organization having an operational role shall responsibilities for emergency response by specify its concept of operations, and its relationship to the total effort.

emergency response by the nuclear facility the nuclear facility licensee and by State and 1.c. Each plan shall illustrate these interrelationships in a block diagram.

licensee and by State and local organizations have 1.d. Each organization shall identify a specific individual by title who shall be in local organizations have been assigned, the charge of the emergency response.

been assigned, the emergency responsibilities emergency responsibilities of the various supporting 1.e. Each organization shall provide for 24-hour per day emergency response, A of the various supporting organizations have been including 24-hour per day manning of communications links.

organizations have been specifically established, specifically established, and each principal 4. Each principal organization shall be capable of continuous (24-hour) and each principal response organization has operations for a protracted period. The individual in the principal organization response organization has staff to respond and to who will be responsible for assuring continuity of resources (technical, staff to respond and to augment its initial administrative, and material) shall be specified by title.

augment its initial response on a continuous response on a continuous basis.

basis. [E.IV.1; IV.A.1, 2, 4, 7]

50.47(b)(2) On-shift facility On-shift facility licensee 1. Each licensee shall specify the onsite emergency organization of plant staff licensee responsibilities responsibilities for personnel for all shifts and its relation to the responsibilities and duties of the for emergency response emergency response are normal staff complement.

are unambiguously unambiguously defined, defined, adequate staffing adequate staffing to 2. Each licensee shall designate an individual who shall be on shift at all times B to provide initial facility provide initial facility and who shall have the authority and responsibility to immediately and accident response in key accident response in key unilaterally initiate any emergency actions.

functional areas is functional areas is maintained at all times, maintained at all times, 4. Each licensee shall establish the functional responsibilities assigned to the timely augmentation of timely augmentation of emergency coordinator.

DRAFT- DECOMMISSIONING REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014

DRAFT- FOR INFORMATION USE ONLY Regulations (as NUREG-0654 (Revised -

Evaluation Criteria exempted per /SG) Decommissioning) response capabilities is response capabilities is

5. Each licensee shall specify the positions or title and major tasks to be available and the available and the pe~~rmed by the persons to be assigned to the functional areas of emergency interfaces among various interfaces among various act1v1ty. For emergency situations, specific assignments shall be made for all onsite response activities onsite response activities shifts and for plant staff members, both onsite and away from the site. The and offsite support and and offsite support and licensee must be able to augment on-shift capabilities within a short period response activities are response activities are after declaration of an emergency.

specified . specified.

9. Each licensee shall identify the services to be provided by local agencies for

[E.IV.A.1, 2, 4, 9; A.3; handling emergencies , e.g ., police , ambulance, medical, hospital , and fire-C.1] fighting organizations shall be specified. The licensee shall provide for transportation and treatment of injured personnel who may also be contaminated. Copies of the arrangements and agreements reached with contractor, private, and local support agencies shall be appended to the plan.

The agreements shall delineate the authorities , responsibilities, and limits on the actions of the contractor, private organization , and local services support

_L_ - ~- -- -- - - - - - - - -~

grou~s .

, DRAFT- DECOMMISSIONING REACTOR EMERGENCY PLAN REVIEW GUIDE July_ 2014

DRAFT- FOR INFORMATION USE ONLY Minimum Staffing Requirements for NRC Licensees for Decommissioning Nuclear Power Plant Emergencies (See 8.5.)

AUGMENTED STAFF EMERGENCY POSITION, CAPABILITY FOR MAJOR FUNCTIONAL AREA MAJOR TASKS ON-SHIFT TITLE, OR EXPERTISE RESPONSE IN 2 HOURS Plant Operations and assessment of Plant Operations Shift Supervisor 1 Operational Aspects Shift Operator 1 Emergency Direction and Control Emergency Coordinator Shift Supervisor

• Notification/Communication Notify State and Federal personnel and Communicator

• maintain communications Radiological Accident Assessment and Onsite Dose Assessment and Monitoring Heath Physics Expertise

• 1 Support of Operational Accident Assessment Protective Actions (In-Plant) In-Plant Surveys Radiation Protection Health Physics Technician 1 As needed

a. Access Control

b. HP Coverage for Repair, Corrective Actions, Search and Rescue, First Aid , and Firefighting

c. Personnel Monitoring

d. Dosimetry Engineering Support Technical Direction Technical Expertise 1 Plant Condition Evaluation, Repair and Repair, Mitigation and Corrective Action Shift Operators ** As needed Corrective Action Firefighting Firefighting Per Fire Protection Plan Rescue Operations/ First Aid Rescue and First Aid

• As needed Security Security Per Security Plan

• May be provided by shift personnel assigned other functions. Identify if the shift personnel assigned EP functions/tasks are from Firefighting or Security resources.

• • Number of additional personnel required to perform site-specific mitigation strategies required for a catastrophic loss in spent fuel pool inventory.

DRAFT- DECOMMISSIONI~G REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014

DRAFT- FOR INFORMATION USE ONLY Regulations (as NUREG-0654 (Revised -

Evaluation Criteria exempted per /SG) Decommissioning)

1. The Federal government maintains in-depth capability to assist licensees, States and local governments through the Federal Radiological Monitoring Arrangements for and Assessment Plan (formerly Radiological Assistance Plan (RAP) and (b )(3) Arrangements for requesting and effectively Interagency Radiological Assistance Plan (IRAP). Each State and licensee requesting and effectively using assistance shall make provisions for incorporating the Federal response capability into its using assistance resources have been operation plan, including the following:

resources have been c made and other organizations capable of made and other organizations capable of

a. specific persons by title authorized to request Federal assistance augmenting the planned b. specific Federal resources expected augmenting the planned response have been response have been identified. 4. Each organization shall identify nuclear and other facilities, organizations or identified.

[E.IV.A.6-7] individuals which can be relied upon in an emergency to provide assistance.

Such assistance shall be identified and supported by appropriate letters of agreement.

A standard emergency 1. An emergency classification and emergency action level scheme must be (b)(4) A standard classification and action established by the licensee. The specific instruments, parameters or emergency classification level scheme, the basis of equipment status shall be shown for establishing each emergency class, in and action level scheme, which include facility the in-plant emergency procedures. The plan shall identify the parameter the basis of which include D facility system and effluent system and effluent values and equipment status for each emergency class .

parameters, is in use by 2. The initiating conditions shall include all postulated accidents in the Final parameters, is in use by the nuclear facil ity Safety Analysis Report (FSAR) for the nuclear facility.

the nuclear facility licensee.

licensee.

[E.IV.1; IV.B.1, 2; C.1, 2]

(b)(5) Procedures have Procedures have been 1. Each organization shall establish procedures which describe mutually been established for established for notification, agreeable bases for notification of response organizations consistent with the notification, by the by the licensee, of State emergency classification and action level scheme. These procedures shall licensee, of State and and local response include means for verification of messages. The specific details of verification E local response organizations and for need not be included in the plan.

organizations and for notification of emergency notification of emergency personnel by all 2. Each organization shall establish procedures for alerting, notifying, and personnel by all organizations; the content mobilizing emergency response personnel.

DRAFT- DECOMMISSIONING REACTOR EMERGENCY PLAN REVIEW GUIDE Julv 2014

DRAFT- FOR INFORMATION USE ONLY Regulations (as NUREG-0654 (Revised -

Evaluation Criteria exemtJted per ISGJ Decommissioning) organizations; the content of initial and follow up

3. The licensee in conjunction with State and local organizations shall establish of initial and follow up messages to response the contents of the initial emergency messages to be sent from the plant.

messages to response organizations has been These measures shall contain information about the class of emergency.

organizations has been established established. [E.IV.1; IV.A.6, 7; C.1, 2;

4. Each licensee shall make provisions for follow-up messages from the facility 0.1, 3; E) to offsite authorities which shall contain the following information if it is known and appropriate:

a. location of incident and name and telephone number (or communications channel identification) of caller;

b. date/time of incident;

c. class of emergency;

k. licensee emergency response actions underway;

m. request for any needed onsite support by offsite organizations; and

n. prognosis for worsening or termination of event based on plant information.

DRAFT- DECOMMISSIONING REACTOR EMERGENCY PLAN REVIEW GUIDE

DRAFT- FOR INFORMATION USE ONLY Regulations (as NUREG-0654 (Revised -

Evaluation Criteria exempted per ISG) Decommissioning)

1. Each organization shall establish reliable primary and backup means of communication for licensees, local, and State response organizations. Such systems should be selected to be compatible with one another. Each plan shall include:

a. provision for 24-hour per day notification to and activation of the State/local emergency response network; and at a minimum , a telephone link and alternate, including 24-hour per day manning of communications links that initiate emergency response actions.

Provisions exist for prompt b. provision for communications with contiguous State/local governments; (b )(6) Provisions exist for communications among prompt communications c. provision for communications as needed with Federal emergency response principal response F among principal response organizations to organizations; organizations to emergency personnel . e. provision for alerting or activating emergency personnel in each response emergency personnel.

[E.IV.1; IV.C.1; 0.1, 3; E] organization; and

f. provision for communication by the licensee with NRC headquarters and NRC Regional Office Emergency Operations Centers.

2. Each organization shall ensure that a coordinated communication link for fixed and mobile medical support facilities exists.

3. Each organization shall conduct periodic testing of the entire emergency communications system (see evaluation criteria H.1 0 and N.2.a.

(b )(7) The principal points The principal points of 3.a. Each principal organization shall designate the points of contact and physical G of contact with the news contact with the news locations for use by news media during an emergency.

DRAFT- DECOMMISSIONING REACTOR EMERGENCY PLAN REVIEW GUIDE -----'J_u~ IY 2014

DRAFT- FOR INFORMATION USE ONLY Regulations (as NUREG-0654 (Revised -

Evaluation Criteria exempted per ISG) Decommissioning) media for dissemination of media for dissemination of 4.a. Each principal organization shall designate a spokesperson who should have information during an information during an access to all necessary information.

emergency) are emergency are b. Each organization shall establish arrangements for timely exchange of established in advance, established in advance, information among designated spokespersons.

and procedures for and procedures for c. Each organization shall establish coordinated arrangements for dealing with coordinated dissemination coordinated dissemination rumors.

of information to the public of information to the public are established. are established.

[E.IV.A. 7; 0.2]

2. Each licensee shall establish an Emergency Facility from which evaluation and coordination of all licensee activities related to an emergency is to be carried out and from which the licensee shall provide information to Federal, State and local authorities responding to emergencies.

4. Each organization shall provide for timely activation and staffing of the facil ities and centers described in the plan .

5. Each licensee shall identify and establish onsite-monitoring systems that are Adequate emergency (b)(8) Adequate to be used to initiate emergency measures as well as those to be used for facilities and equipment to emergency facilities and conducting assessment.

support the emergency H equipment to support the response are provided and The equipment shall include:

emergency response are a. geophysical phenomena monitors, (e.g. , meteorological , hydrologic, maintained.

provided and maintained . seismic);

[E.IV.1; IV.E; G]

b. radiological monitors, (e.g. , process, area, emergency, effluent, wound and portable monitors and sampling equipment);

d. fire and combustion products detectors.

6. Each licensee shall make provision to acquire data from or for emergency access to offsite monitoring and analysis equipment including:

a. geophysical phenomena monitors, (e.g ., meteorological, hydrologic, seismic);

, DRAFT- DECOMMISSIONING-REACTOR EMERGENCY PLAN REVIEW GUIDE Ju~y 2014

DRAFT- FOR INFORMATION USE ONLY Regulations (as NUREG-0654 (Revised -

Evaluation Criteria exempted per ISG) Decommissioning) 1O.a. Each licensee shall make provisions to inspect, inventory and operationally check emergency equipment/instruments at least once each calendar quarter and after each use. There shall be sufficient reserves of instruments/equipment to replace those which are removed from emergency kits for calibration or repair. Calibration of equipment shall be at intervals recommended by the supplier of the equipment.

10.b Communication systems shall be functionally tested as follows : State/local and NRC (ENS) communication systems shall be tested monthly This is not the same as a communication drill as stated in N.2.

11. Each plan shall, in an appendix, include identification of emergency kits by general category (protective equipment, communications equipment, radiological monitoring equipment, and emergency supplies).

1. Each licensee shall identify plant system and effluent parameter values Adequate methods, characteristic of a spectrum of off-normal conditions and accidents, and shall (b)(9) Adequate methods, systems, and equipment identify the plant parameter values or other information which correspond to systems, and equipment for assessing and the example initiating conditions. Such parameter values and the for assessing and monitoring actual or corresponding emergency class shall be included in the appropriate facility I monitoring actual or potential consequences of emergency procedures. Facility emergency procedures shall specify the kinds potential consequences of a radiological emergency of instruments being used and their capabilities.

a radiological emergency condition are in use.

condition are in use.

2. Onsite capability and resources to provide initial values and continuing

[E.IV.1; IV.A.4; 8.1; C.2; assessment throughout the course of an accident shall include radiation E]

monitors.

1. Each licensee shall establish the means and time required to warn or advise onsite individuals and individuals who may be in areas controlled by the operator, including :

A range of protective (b)(10) A range of a. Employees not having emergency assignments; actions has been protective actions has b. Visitors; developed for the J been developed for emergency workers and

c. Contractor and construction personnel ; and emergency workers and d. Other persons who may be in the public access areas on or passing the public.

the public. through the site or within the owner controlled area .

[IV.1; IV.C.1; E; I]

2. Each licensee shall make provisions for evacuation routes and transportation for onsite individuals to some suitable offsite location , including alternatives for inclement weather, high traffic density and specific radiological conditions .

DRAFT- DECOMMISSIONING REACTOR EMERGENCY PLAN REVIEW GUIDE

DRAFT- FOR INFORMATION -= U=-

S=-E -=

O:..:...:

N=-= L~

Y _ _ _ _ _ _ _ ____,

Regulations (as NUREG-0654 (Revised -

Evaluation Criteria exempted per ISG) Decommissioning)

3. Each licensee shall provide for radiological monitoring of people evacuated from the site.

5. Each licensee shall provide for a capability to account for all individuals onsite at the time of the emergency and ascertain the names of missing individuals within 60 minutes of the start of an emergency and account for all onsite individuals continuously thereafter.

6. Each licensee shall, for individuals remaining or arriving onsite during the emergency, make provisions for:

a. Individual respiratory protection

b. Use of protective clothing.

1. Each licensee shall establish onsite exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protective Actions Guides (EPA Means for controlling 520/1-75/001) for:

(b)( 11) Means for radiological exposures, in a. removal of injured persons; controlling radiological an emergency, are b. undertaking corrective actions; exposures, in an established for emergency c. performing assessment actions; emergency, are workers. The means for d. providing first aid; established for emergency controlling radiological e. performing personnel decontamination; workers. The means for exposures shall include f. providing ambulance service; and K controlling radiological exposure guidelines g. providing medical treatment services.

exposures shall include consistent with EPA 2. Each licensee shall provide an onsite radiation protection program to be exposure guidelines Emergency Worker and implemented during emergencies, including methods to implement exposure consistent with EPA Lifesaving Activity guidelines. The plan shall identify individual(s), by position or title, who can Emergency Worker and Protective Action Guides. authorize emergency workers to receive doses in excess of 10 CFR Part 20 Lifesaving Activity limits. Procedures shall be worked out in advance for permitting onsite Protective Action Guides.

[IV.E] volunteers to receive radiation exposures in the course of carrying out lifesaving and other emergency activities. These procedures shall include expeditious decision making and a reasonable consideration of relative risks.

DRAFT- DECOMMISSIONING REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014

DRAFT- FOR INFORMATION USE ONLY Regulations (as NUREG-0654 (Revised -

Evaluation Criteria exempted per ISG) Decommissioning) 3.a. Each organization shall make provision for 24-hour-per-day capability to determine the doses received by emergency personnel involved in any nuclear accident, including volunteers. Each organization shall make provisions for distribution of dosimeters, both self-reading and permanent record devices.

b. Each organization shall ensure that dosimeters are read at appropriate frequencies and provide for maintaining dose records for emergency workers involved in any nuclear accident.

5.a. Each organization as appropriate, shall specify action levels for determining the need for decontamination.

b. Each organization, as appropriate, shall establish the means for radiological decontamination of emergency personnel wounds, supplies, instruments and equipment, and for waste disposal.

6. Each licensee shall provide onsite contamination control measures including:

a. area access control;

b. drinking water and food supplies;

c. criteria for permitting return of areas and items to normal use.

1. Each organization shall arrange for local and backup hospital and medical Arrangements are made services having the capability for evaluation of radiation exposure and uptake, (b)(12) Arrangements are for medical services for including assurance that persons providing these services are adequately made for medical services contaminated injured L for contaminated injured individuals.

prepared to handle contaminated individuals.

2. Each licensee shall provide for onsite first aid capability.

individuals.

4. Each organization shall arrange for transporting victims of radiological

[E.IV.A.6, 7; E]

accidents to medical support facilities.

1. Each organization, as appropriate, shall develop general plans and General plans for recovery procedures for reentry and recovery. This process should consider both (b)( 13) General plans for and reentry are existing and potential conditions.

M recovery and reentry are developed. 2. Each licensee plan shall contain the position/title, authority and responsibilities developed. of individuals who will fill key positions in the facility recovery organization.

[IV.1; IV.H] This organization shall include technical personnel with responsibilities to develop, evaluate and direct recovery and reentry operations.

DRAFT- DECOMMISSIONING REACTOR EMERGENCY PLAN REVIEW GUIDE

~--------~------~ DR~A~F~T~--F ~O ~R~IN~F~ORMA_ TI~O_ N_U~S~E_O ~N_L_Y________________~

Regulations (as NUREG-0654 (Revised -

Evaluation Criteria exempted per ISG) Decommissioning) 1.a. An exercise is an event that tests the integrated capability and a major portion of the basic elements existing within emergency preparedness plans and organizations. Exercises shall be conducted as set forth in NRC and FEMA rules.

b. The organization shall provide for a critique of the annual exercise by Federal and State observers/evaluators. The scenario should be varied from year to year such that all major elements of the plans and preparedness orQanizations are tested. Some exercises should be unannounced.

Periodic exercises are (will 2. A drill is a supervised instruction period aimed at testing , developing and

{b){14) Periodic exercises be) conducted to evaluate maintaining skills in a particular operation. A drill is often a component of an are (will be) conducted to major portions of exercise. A drill shall be supervised and evaluated by a qualified drill evaluate major portions of emergency response instructor. Each organ ization shall conduct drills, in addition to the annual emergency response capabilities, periodic drills exercise at the frequencies indicated below:

capabilities, periodic drills are (will be) conducted to a. Communication Drills: Communications with State and local governments N are (will be) conducted to develop and maintain key shall be drilled annually. Communications with Federal emergency response develop and maintain key skills, and deficiencies organizations shall be drilled annually. Communication drills shall also include skills, and deficiencies identified as a result of the aspect of understanding the content of messages.

identified as a result of exercises or drills are (will b. Fire Drills: Fire drills shall be conducted in accordance with the plant exercises or drills are (will be) corrected. (nuclear facility) technical specifications.

be) corrected. c. Medical Emergency Drills: A medical emergency drill involving a simulated

[E.IV.1; E.9; F] contaminated individual which contains provisions for participation by the local support services agencies (i.e. , ambulance and offsite medical treatment facility) shall be conducted annually. The offsite portions of the medical drill may be performed as part of the required annual exercise.

d. Radiological Monitoring Drills: Plant environs and radiological monitoring drills shall be conducted annually.

e. Health Physics Drills: {1) Health Physics drills shall be conducted semi-annually which involve response to, and analysis of, simulated elevated airborne and direct radiation measurements in the environment.

DRAFT- DECOMMISSIONING REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014

DRAFT - FOR INFORMATION USE ONLY .J Regulations (as NUREG-0654 (Revised -

Evaluation Criteria exempted per ISG) Decommissioning)

3. Each organization shall describe how exercises and drills are to be carried out to allow free play for decision making and to meet the following objectives.

Pending the development of exercise scenarios and exercise evaluation guidance by NRC and FEMA the scenarios for use in exercises and drills shall include but not be limited to, the following:

a. The basic objective(s) of each drill and exercise and appropriate evaluation criteria;

b. The date(s), time period , place(s) and participating organizations;

c. The simulated events;

d. A time schedule of real and simulated initiating events;

e. A narrative summary describing the conduct of the exercises or drills to include such things as simulated casualties, offsite fire department assistance, rescue of personnel, use of protective clothing, and

f. A description of the arrangements for and advance materials to be provided to official observers.

4. Official observers from Federal governments will observe, evaluate, and critique the required exercises. A critique shall be scheduled at the conclusion of the exercise to evaluate the ability of organizations to respond as called for in the plan. The critique shall be conducted as soon as practicable after the exercise, and a formal evaluation should result from the critique.

5. Each organization shall establish means for evaluating observer and participant comments on areas needing improvement, including emergency plan procedural changes, and for assigning responsibility for implementing corrective actions. Each organization shall establish management control used to ensure that corrective actions are implemented.

1. Each organization shall assure the training of appropriate individuals.

Radiological emergency a. Each facility to which the plant applies shall provide site specific (b)(15) Radiological response training is emergency response training for those offsite emergency organizations who emergency response provided to those who may be called upon to provide assistance in the event of an emergency.

training is provided to 0 those who may be called may be called on to assist 2. The training program for members of the onsite emergency organization shall, in an emergency. besides classroom training, include practical drills in which each individual on to assist in an demonstrates ability to perform his assigned emergency function. During the emergency.

[E.IV.1; IV.F] practical drills, on-the-spot correction of erroneous performance shall be made and a demonstration of the proper performance offered by the instructor.

DRAFT- DECOMMISSIONING REACTOR EMERGENCY PLAN REVIEW GUIDE

DRAFT- FOR INFORMATION USE ONLY Regulations (as NUREG-0654 (Revised -

Evaluation Criteria exempted per ISG) Decommissioning)

3. Training for individuals assigned to licensee first aid teams shall include courses eauivalent to Red Cross Multi-Media.

4. Each organization shall establish a training program for instructing and qualifying personnel who will implement radiological emergency response plans. The specialized initial training and periodic retraining programs

{including the scope, nature and frequency) shall be provided in the following categories:

a. Directors or coordinators of the response organizations;

b. Personnel responsible for accident assessment;

d. Police, security and fire-fighting personnel;

e. Repair and damage control/correctional action teams (onsite);

f. First aid and rescue personnel;

g. Local support services personnel;

h. Medical support personnel;

j. Personnel responsible for transmission of emergency information and instructions.

5. Each organization shall provide for the initial and annual retraining of i

personnel with emergency response responsibilities.

1. Each organization shall provide for the training of individuals responsible for the planning effort.

2. Each organization shall identify by title the individual with the overall authority and responsibility for radiological emergency response planning.

Responsibilities for plan

3. Each organization shall designate an Emergency Planning Coordinator with (b)( 16) Responsibilities for development and review responsibil ity for the development and updating of emergency plans and plan development and and for distribution of coordination of these plans with other response organizations .

review and for distribution emergency plans are p established , and planners

4. Each organization shall update its plan and agreements as needed, review of emergency plans are and certify it to be current on an annual basis . The update shall take into established , and planners are properly trained .

account changes identified by drills and exercises.

are properly trained.

5. The emergency response plans and approved changes to the plans shall be

[IV.1; IV.G]

forwarded to all organizations and appropriate individuals with responsibility  !

for implementation of the plans. Revised pages shall be dated and marked to ,

show where changes have been made. I

6. Each plan shall contain a detailed listing of supporting plans and their source.

DRAFT- DECOMMISSIONING REACTOR EMERGENCY PLAN REVIEW GUIDE

DRAFT- FOR INFORMATION USE ONLY Regulations (as NUREG-0654 (Revised -

Evaluation Criteria exempted per ISG) Decommissioning)

7. Each plan shall contain as an appendix listing, by title, procedures required to implement the plan. The listing shall include the section(s) of the plan to be implemented by each procedure.

8. Each plan shall contain a specific table of contents. Plans submitted for review should be cross-referenced to these criteria.

9. Each licensee shall arrange for and conduct independent reviews of the emergency preparedness program at least every 12 months. (An independent review is one conducted by any competent organization either internal or external to the licensee's organization , but who are not immediately responsible for the emergency preparedness program). The review shall include the emergency plan , its implementing procedures and practices, training , readiness testing , equipment, and interfaces with State and local governments. Management controls shall be implemented for evaluation and correction of review findings. The result of the review, along with recommendations for improvements, shall be documented , reported to appropriate licensee corporate and plant management, and involved Federal, State and local organizations , and retained for a period of five years.

10. Each organization shall provide for updating telephone numbers in emergency procedures at least quarterly.

DRAFT- DECOMMISSIONING REACTOR EMERGENCY PLAN REVIEW GUIDE

ML14115A041 *via e-mail OFFICE NRR/DORULPL4-2/PM NRR/DORULPL4-2/PM NRR/DORULPL4-2/LA NAME WHuffman TWengert MHenderson DATE 08/11/14 08/11/14 8/1/14 OFFICE NSIR/DPR/ORLOB/BC NRR/DORULPL4-2/BC NRR/DORULPL4-2/PM NAME JAnderson* DBroaddus TWengert DATE 7/31114 08/14/14 08/14/14