NL-15-1392, Enclosure 4 - Farley Staffing - Detailed Description and Technical Evaluation & Enclosure 5 - Farley Standard Emergency Plan Annex
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Southern Nuclear Operating Company Joseph M. Farley Nuclear Plant Units 1 and 2;Edwin I. Hatch Nuclear Plant Units 1 and 2;Vogtle Electric Generating Plant Units I and 2;Vogtle Electric Generating Plant Units 3 and 4 Enclosure 4 Farley Staffing -Detailed Description and Technical Evaluation This enclosure contains 19 pages.
Enclosure 4 to NL-1 5-1 392 Fariey Staffing -Detailed Description and Technical Evaluation This License Amendment Request (LAR) revises the current on-shift and augmented Emergency Response Organization (ERO) for Farley Nuclear Plant (FNP) Unit 1 and Unit 2 Emergency Plan to incorporate a standard on-shift and augmented ERO staffing plan for the Southern Nuclear Operating Company (SNC) Fleet. This proposed change to the ERO will result in an SNC Fleet standard definition of ERO augmentation time as well as an SNC Fleet standard complement of emergency response positions, titles, duties, and responsibilities.
EP Functions Impacted by the Proposed Chanqe The proposed change impacts the ERO as outlined in 10 CFR 50.47(b) Planning Standards I and 2. This change addresses the following Planning Standard Functions:
- 10 CFR 50.47(b) (1): The response organization has the staff to respond and augment on a continuing basis (24/7 staffing) in accordance with the Emergency Plan.* 10 CFR 50.47(b) (2): Process for timely augmentation of on-shift staff is established and maintained.
The proposed change has been reviewed and continues to perform the functions required of 10 CFR 50.47(b) and the related requirements of 10 CFR 50 Appendix E.Emergency Response Organization (ERO) Activation FNP Unit 1 and Unit 2 Emergency Plan Revision 64.0.0 requires staffing of augmented ERO for the Technical Support Center (TSC) and Operations Support Center (OSC) at 75 minutes from time of declaration of an Alert or higher emergency classification.
The FNP 75 minute Emergency Response Facility (ERF) augmentation time for on-site ERFs was established in Revision 25.0 of the FNP Unit 1 and Unit 2 Emergency Plan in coordination with and with concurrence from the NRC Headquarters and Region II staff.FNP Unit 1 and Unit 2 Emergency Plan Revision 64.0.0 also directs that the SNC Fleet Emergency Operations Facility (EOF) "... will be operational within about an hour of the initial notification.
SNC's goal is to begin notification of all required on-call Emergency Response Organization (ERO) personnel as soon as practicable, within 15 minutes, following the declaration of an Alert emergency or higher emergency classification at any SNC site." This wording was first incorporated in version 41 of the FNP Emergency Plan following prior approval of the SNC Fleet EOF. The augmentation time requirement for the EOF is consistent for the entire SNC Fleet and consistent with the on-site ERF requirements for VEGP 1-2, VEGP 3-4 and HNP, which provide for ERO augmentation within "approximately" one hour.The proposed SNC Fleet standard definition for ERO augmentation is 75 minutes from declaration.
This proposed change redefines the SNC Fleet augmentation time without extension, as the 15-minute notification period will be incorporated in the overall definition of augmentation time. The proposed SNC Fleet definition also removes ambiguous wording such as "about" and "approximately" in order to clearly define the augmentation requirement.
Since FNP augmentation time is already defined as 75 minutes from declaration of an Alert or higher emergency, it is not an actual change for FNP. However, since the SNC ERF augmentation time is part of the SNC Fleet Based Plan, it is being addressed in the FNP technical discussion for consistency.
E4-1 Enclosure 4 to NL-15-1 392 Farley Staffing -Detailed Description and Technical Evaluation Assigqnment of ResponsibilitvlOrgqanizational Control The FNP Unit 1 and Unit 2 Emergency Plan maintains an on-shift organization as documented in the site Emergency Plan Revision 64.0. This Plan identifies the authority and responsibilities for emergency response and assigns major functional areas to on-site and offsite response facilities for augmented response.
In the following analysis, the impact of consolidating ERO positions and reassigning responsibilities is assessed based on the capacity of on-shift staff to perform major tasks for each major functional area of FNP.Plant Operations and Assessment of Operational Aspects NUREG-0654/FEMA REP-01 Revision 1 guidance assumes the on-shift staff will provide the Plant Operations and Assessment of Operational Aspects function throughout the emergency.
The on-shift operations staffing as provided in the current FNP Unit 1 and Unit 2 Emergency Plan Revision 64.0.0 meets the operations staffing requirements of 10 CFR 50.54(m)(2)(i) and the FNP Unit 1 and Unit 2 Technical Specifications.
In addition to these requirements, the FNP Unit 1 and Unit 2 Emergency Plan provides for a dedicated Shift Manager position to perform the NUREG-0654/FEMA REP-01 Revision 1 function of Emergency Direction and Control. Per NUREG-0654/FEMA REP-01 Revision 1, this function may be performed as a collateral duty of one of the individuals performing the Plant Operations and Assessment of Operational Aspects function.
However, providing a Shift Manager to fill this function as a standalone position enhances the ability of the FNP Unit I and Unit 2 control room staff to fulfill the Plant Operations and Assessment of Operational Aspects function while the dedicated ED addresses aspects of the Emergency Direction and Control function.
This has been demonstrated and documented by performing a 10 CFR Part 50, Appendix E shift staffing evaluation.
In accordance with the current FNP Unit I and Unit 2 Emergency Plan and proposed SNC Fleet Emergency Plan, the on-shift staffing exceeds the requirements of NUREG-0654/FEMA REP-01 Revision 1 Table B-i, as well as those prescribed in Revision 25.0 of the FNP Unit 1 and Unit 2 Emergency Plan. The on-shift control room staff for FNP, as described, remains unchanged in the proposed SNC Fleet Emergency Plan and continues to ensure support of the Plant Operations and Assessment of Operational Aspects function at the start of an event and until the on-shift staff is properly augmented.
Emergency Direction and Control NUREG-0654/FEMA REP-01 Revision 1 guidance provides that the Emergency Direction and Control function may be fulfilled by personnel assigned other functions.
Per Revision 25.0 of the FNP Unit 1 and Unit 2 Emergency Plan, the Emergency Director (ED) function is a collateral duty of an ED-qualified individual (Shift Manager or ED)assigned to the Plant Operations and Assessment of Operational Aspects function until relieved by an augmented ED in the TSC within 75 minutes of declaration of an emergency.
As provided in the current Revision 64.0.0 of the FNP Unit I and Unit 2 Emergency Plan, the Shift Manager is designated as the on-shift ED to fulfill the function of Emergency Direction and Control until relieved by the TSC ED within 75 minutes of declaration of an Alert or higher emergency.
This remains unchanged in the proposed SNC Fleet Emergency Plan.In addition to the augmentation of an ED in the TSC within 75 minutes of an Alert or higher declaration, the proposed SNC Fleet Emergency Plan provides an additional ED will be augmented in the Emergency Operations Facility (EOF) within 75 minutes of an Alert or higher declaration.
Aspects of the Emergency Direction and Control function assigned to the TSC and EOF EDs are clearly defined in the proposed SNC Fleet Emergency Plan. The primary role of the EOF ED will be to assume responsibility for state and local notifications and to approve Protective Action Recommendations (PARs). This ensures that in the unlikely event of a Hostile E4-2 Enclosure 4 to NL-1 5-1 392 Farley Staffing -Detailed Description and Technical Evaluation Action Based (HAB) event in which the site is not accessible to the ERO, an ED would be available in the EOE within 75 minutes of an Alert or higher declaration to assume these aspects of the Emergency Direction and Control function and minimize the burden on the Shift Manager/ED.
There would be no undue burden on the Control Room staff or impact on the notification function from an addition of the EOF ED. (See table below.)CONTROL ROOM TSC EOF Shift Manag~er I Emergency TSC Emergency Director EOF Emergency Director Director Classification Classification Notifications Notifications PARS PARS Emergency Exposure Emergency Exposure Controls Controls Finally, the proposed revision to the FNP Unit 1 and Unit 2 Emergency Plan requires augmentation of the following TSC and EOF positions, which support activation of the TSC and EOF, within 75 minutes of declaration of Alert or higher emergency classification event:* TSC Emergency Director* TSC Manager* TSC Operations Supervisor
- TSC Health Physics Network (HPN) Communicator
- EOF Emergency Communications Coordinator
- EOF Security Coordinator
- EOF Offsite Response Coordinator
- EOF Emergency Notification Network (EN N) Communicator
- EOF Nuclear Spokesperson
- EOF Technical Assistant* EOF News Writer E4-3 Enclosure 4 to NL-15-1392 Farley Staffing -Detailed Description and Technical Evaluation
- EOF Field Team Communicator
- EOF Dose Assessment Supervisor
- EOF Dose Analyst* EOF Technical Supervisor Notification and Communication NUREG-0654/FEMA REP-O1 Revision 1 guidance requires one Communicator to be assigned on-shift.
Revision 64.0.0 of the FNP Unit 1 and Unit 2 Emergency Plan provides for two Communicators, but this is modified by a note providing that this function may be fulfilled by individuals assigned other functions (Shift Manager, Shift Supervisor, Shift Support Supervisor, Shift Technical Advisor, Reactor Operator, or other appropriately qualified personnel).
In the proposed SNC Fleet Emergency Plan, the FNP staffing for this position is reduced to a single on-shift communicator as provided in NUREG-0654/FEMA REP-0l Revision 1 guidance.However, the number of control personnel to perform this task will remain unchanged.
This will ensure there will be sufficient, appropriately trained personnel on-shift so that the Communications function may be assigned to a member of the control room staff with no collateral tasks. This has been demonstrated and documented by performing a 10 CFR Part 50, Appendix E shift staffing evaluation.
In addition, the proposed SNC Fleet Emergency Plan provides for the transfer of state and local notifications, including authority to approve the content of the notification form, directly to the EOF from the control room. The proposed change includes both sufficient communications personnel to perform the communications and an ED with the authority to approve the content of the notification.
This ensures that in the unlikely event of an HAB event in which the site is not accessible to the ERO, sufficient personnel will be available in the EOF within 75 minutes from time of declaration of an Alert or higher emergency classification to assume the Communications function and minimize the burden on the Shift Manager/ED.
The ability to transfer the Communications function directly to the EOF, and provision of sufficient augmented personnel in the EOF to perform the Communicator function within 75 minutes, ensure no additional burden is incurred by the on-shift staff.Radiological Accident Assessment and Chemistry/Radio-Chemistry The function of on-site radiological assessment is to: review radiological conditions on site using data from available instrumentation, assess the impact of changing radiological conditions on emergency classification, assist in accident assessment based upon those changing radiological conditions, and recommend appropriate on-site protective measures.Classification is performed by the Shift Manager/ED using NMP-EP-l10, Emergency Classification Determination and Initial Action procedure, which uses readily available and easily recognized plant instrumentation to determine the appropriate emergency classification.
Off-site and onsite surveys provide additional information, such as direct radiation measurements, that can be directly applied to emergency classification.
The on-shift Chemistry Technician takes direction from the Control Room to provide radiological assessment support until the TSC is activated.
As part of the Plant Operations and Assessment of Operational Aspects function, the operating crew uses symptom-based emergency operating procedures (EOPs), which minimize the need for specific accident assessment.
The operating crew performs actions based on symptoms that are described in the EOPs, not based on specific accident assessment.
Similarly, the Shift Manager/ED uses flowcharts in NMP-EP-1 12, Protective Action Recommendations procedure, which prescribes the decision-making processes for directing on-E4-4 Enclosure 4 to NL-15-1392 Farley Staffing -Detailed Description and Technical Evaluation site protective measures.
The simple information needed to accomplish allows for rapid decision making by the Shift Manager/ED using readily available information.
The Safety Parameter Display System (SPDS) provides the control room with a display of plant parameters from which the status of plant operation can be assessed.
The SPDS has the following functions:
- Aids the control room operators in the rapid detection and identification of abnormal operating conditions.
- Provides additional, specific information to analyze and diagnose the cause of abnormal operating conditions.
- Monitors plant response to corrective actions.* Provides grouping of parameters to enhance the operators' capability to assess plant status quickly without surveying all control room displays concurrently.
- Directs the operators' attention to other specific confirmatory non-SPDS control room displays.* Provides human factors engineered display formats in simple and consistent display patterns and coding.* Provides display information on a real-time basis, along with validation of data.* Provides generated selectable trend displays on a real-time basis for monitoring reactivity control, reactor core cooling and heat removal from the primary system, reactor coolant system integrity, radioactivity control, containment integrity, and other selected parameters.
Therefore, with the proposed changes, the ERO structure continues to meet the intent of the requirements of Appendix E to 10 CFR Part 50 and the standards of 10 CFR 50.47(b).This Functional Area includes three tasks: EOF Emergency Director; Off-Site Dose Assessment and Chemistry/Radiochemistry; and Off-site, On-Site (out of plant), In-Plant Surveys, and Radiation Protection Emergency Operations Facility (EOF) Emergency Director (ED)The TSC ED is not assigned to the on-shift complement.
In the current plan, the TSC ED arrives within 75 minutes of declaration of an Alert or higher emergency classification, and relieves the on-shift ED of overall emergency management as well as all off-site responsibilities including PARs and emergency notifications.
The EOF is also staffed within this timeframe; however, there is currently no ED provided in the Emergency Operations Facility (EOF).Under this proposal, within 75 minutes of classification, the Shift Manager/ED is relieved in the TSC by the ED, who then assumes overall control of the response efforts. The EOF ED arrives and relieves the TSC ED of overall emergency management and off-site responsibilities including.
PARs, dose assessment, and emergency notifications.
This ensures that, in the unlikely event of an HAB event in which the site is not accessible to the ERO, sufficient personnel to perform the Radiological Accident Assessment and Support of Operational Accident Assessment function will be available in the EOF within 75 minutes from time of an Alert or higher declaration and minimize the burden on the Shift Manager/ED.
As discussed earlier, the overall function is enhanced by providing a Shift Manager to fill this function as a standalone position beyond the collateral assignment as designated by NUREG-0654/FEMA REP-01 Revision I Table B-I, during the period prior to augmentation.
E4-5 Enclosure 4 to NL-15-1392 Farley Staffing -Detailed Description and Technical Evaluation The proposed change presents no adverse impact to ERO staffing because TSC and EOF EDs will continue to provide timely relief to the on-shift ED from the duties and responsibilities for offsite functions.
Offsite Dose Assessment (ODA)/Chemistry NUREG-0654IFEMA REP-O1 Revision 1 does not provide for on-shift dose assessment capability.
The current version of the FNP Unit 1 and Unit 2 Emergency Plan does provide for an on-shift capability for performance of dose assessment and is currently assigned to a Radiation Protection individual.
In the proposed change, on-shift dose assessment will be assigned to an on-shift Chemistry individual appropriately trained and dedicated to this task with no other collateral emergency response duties. In turn, this will free the Radiation Protection individual to perform other radiation protection related tasks.With the improvements to the dose assessment software program, as well as plant status, meteorological, and radiation monitoring data, Chemistry can easily and rapidly perform dose assessments during emergency conditions.
Enhancements in dose assessment software have reduced the time required to perform dose assessment runs and provide the results to the ED. In addition, the dose assessment software is operational in a Windows operating system on the SNC Local Area Network (LAN) and as such can be readily accessed from any LAN computer on the SNC network.A second Chemistry individual is provided as part of the minimum on-shift staffing so that any required chemistry samples may be collected without impacting the Chemistry individual assigned to perform dose assessment.
A review of the Emergency Operations Procedures (EOPs), Abnormal Operating Procedures (AOPs), FNP Unit 1 and Unit 2 Emergency Plan, and the procedures used by Operations for off-normal plant conditions, did not identify any conflicts between completion of dose assessment and other on-shift Chemistry functions within the 75 minute augmentation time frame. An additional Chemistry support individual will be augmented in the TSC within 75 minutes, who will provide oversight for chemistry sampling and analysis activities.
An additional Chemistry technician will be augmented in the OSC within 75 minutes to assist in performing chemistry sampling and analysis.Augmentation by the RP Supervisor TSC within 75 minutes will relieve the Shift Manager/ED of the role of oversight of the on-shift dose assessor.
The TSC will retain this task until relieved by the EOF dose assessment staff, which consists of the Dose Assessment Supervisor and Dose Analyst. There is no loss of function or impact on the timing for performing either of the tasks of dose assessment or required radiochemistry sampling by the proposed on-shift staffing provided in the SNC Fleet Emergency Plan.OffsitelOnsite Surveys, In-Plant surveys and Radiation Protection (RP)NUREG-0654/FEMA REP-O1 Revision 1 identifies one on-shift RP Technician who is responsible for performing in-plant surveys. NUREG-0654/FEMA REP-O1 Revision 1 does not provide for any on-shift personnel for on-site out of plant surveys or for off-site surveys.NUREG-0654
/ FEMA REP-O1 Revision 1 further identifies two RP technicians under the Protective Actions function for performing the tasks of Access Control, Radiation Protection coverage for repair, corrective actions, search and rescue, first aid, firefighting, personnel monitoring, and dosimetry.
However, a note modification provides that these individuals may be assigned other functions, for example, the RP technician assigned to the in-plant surveys task and the individual assigned to the Chemistry/Radio-chemistry task under the Radiological Accident Assessment and Support of Operational Accident Assessment function.E4-6 Enclosure 4 to NL-15-1392 Farley Staffing -Detailed Description and Technical Evaluation Revision 64.0.0 of the FNP Unit 1 and Unit 2 Emergency Plan provides for two individuals to perform on-site out of plant surveys -an individual qualified to perform the survey and an assistant to drive a vehicle. A Chemistry technician credited under the Protective Actions (in-plant) function also provides support to coordinate communications between the out of plant team and the dose assessor as needed.As part of the proposed SNC Fleet Emergency Plan, the FNP on-shift staffing for the on-site out of plant survey will be performed by a single RP technician or other appropriately trained individual.
SNC currently uses predesignated, readily accessible survey points around the FNP Unit 1 and Unit 2 plant site for collecting on-site survey data. Prior to dispatch of the on-site out of plant monitoring technician, th'e dose assessor will brief the survey technician on the event conditions, direction of potential/actual plume path, potential radiological conditions, and so forth. The technician will be dispatched to one of the predesignated sample points in the downwind direction of the potential/actual plume path. The survey technician will then obtain the pre-staged on-site out of plant survey kit and vehicle and proceed to the designated location.
The dose assessor and the survey technician will have the capability to maintain near continuous communications, which will allow the dose assessor to redirect the technician while in route if needed. Since the designated sample points are on-site and readily accessible from the FNP Unit 1 and Unit 2 plant site road system, there will be no immediate need for the. survey technician to travel off-site and this survey can be performed by a single individual without impacting the accuracy or timeliness of the survey.Additionally, the proposed SNC Fleet Emergency Plan FNP on-shift staffing will eliminate the on-shift individual coordinating communications between the out of plant survey technician and the dose assessor, and instead has the survey technician communicate directly with the dose assessor.
This will expedite communication of field survey readings to the dose assessor for input into the dose assessment program, resulting in a shorter completion time of dose assessment runs using actual field survey results.Revision 64.0.0 of the FNP Unit 1 and Unit 2 Emergency Plan provides for augmentation of two off-site survey teams as well as a Field Team Coordinator and Field Team Communicator at the EOF. The proposed staffing for the SNC Fleet Emergency Plan augments a single off-site survey team within 75 minutes of an Alert or higher declaration as well as maintaining the augmentation of the EOF Field Team Coordinator and Field Team Communicator positions currently provided.Installed effluent radiation monitors and in-plant radiation monitors are able to detect any radioactive release quickly and accurately.
The enhanced technology provided by the Integrated Plant Computer (IPC) system and the dose assessment computer model provides reliable visual indication of any radioactive plume and its calculated direction.
Quantification of a radioactive release is determined by dose assessment, which is performed by dedicated on-shift personnel then augmented by additional dose assessment personnel in the TSC and EOF. On-site out of plant field teams and off-site field teams are typically used to verify the status of a potential release and validate the dose assessment model. Dose assessment model validation strategies developed and implemented by the EOF staff typically include directing one team to track the leading edge of the radiological plume, and one team to define the lateral edges of the plume and determine plume centerline radiological conditions.
If the field team survey data indicates a departure from the dose assessment model, the radiation surveys and air samples collected by these two field teams can be used to perform dose assessment back calculations.
SNC believes the two proposed field monitoring teams will be satisfactory for performing these surveys. To better E4-7 Enclosure 4 to NL-1 5-1 392 Farley Staffing -Detailed Description and Technical Evaluation support performing surveys off-site, the on-shift field team, which initially consisted of a single RP technician or other appropriately trained individual, can be augmented by the on-shift dose assessor as a vehicle driver (once relieved by the EOF Dose Analyst).
Sufficient instrumentation, communication equipment, and transportation will be maintained on-site for augmenting and dispatching additional teams if needed.Regarding in-plant surveys, Revision 64.0 of the FNP Unit 1 and Unit 2 Emergency Plan provides for two individuals to perform in-plant surveys. These individuals include a qualified RP technician to perform the survey and an assistant (typically a maintenance individual).
As part of the proposed change to the SNC Fleet Emergency Plan, the role of in-plant survey assistant is being eliminated from the FNP on-shift staff, with one RP technician assigned to the task of in-plant under the Radiological Accident Assessment and Support of Operational Accident Assessment function.
An additional RP technician will be provided for the P~rotective Actions function discussed later. However, since both of these individuals are qualified RP technicians, they will be available to collectively support either of these functions as needed. An additional two Radiation Protection technicians will respond within 75 minutes to support Radiological Accident Assessment (in-plant) function.
This will provide sufficient Radiation Protection resources to address the Radiological Accident Assessment needs of both the on-shift and augmented ERO personnel.
With improved installed instrumentation, dose calculation computer modeling, and dedicated on-shift staffing for dose assessment and on-site out of plant surveys, there is no more than minimal impact to the performance of these tasks as a result of the proposed staffing alignments in the SNC Fleet Emergency Plan.Plant System Engineering This functional area includes two tasks: Technical Support, and Repair and Corrective Actions.Technical Support NUREG-0654/FEMA REP-01 Revision 1 guidance provided for a Shift Technical Advisor (STA) to be available on-shift to perform the Technical Support task, including core/thermal hydraulics in response to the NUREG-0737 requirements resulting from the Three Mile Island accident.
Revision 64.0 of the FNP Unit 1 and Unit 2 Emergency Plan provides an individual to fulfill the STA task. The performance of the Technical Support task includes use of the IPC, which graphically displays the pertinent parameters with trending and graphing capabilities, alarm functions, and color-coded indication for changes in state for the Critical Safety Function Status Trees. This enhances critical parameter monitoring and the rapid identification and assessment of in-plant conditions.
This remains unchanged for FNP in the SNC Fleet Emergency Plan.Repair and Corrective Actions NUREG-0654/FEMA REP-01 Revision 1 Table B-1 specifies the functional area of Repair and Corrective Actions is to be provided on-shift by a total of two individuals who also "may be provided by shift personnel assigned other functions." It further states that the "position title or expertise" for the Repair and Corrective Actions task could be filled by Mechanical Maintenance/Radwaste Operator, Electrical Maintenance, or I&C Technician.
Due to the time needed to stabilize the plant and assess the event, the initial phase of an accident is not expected to involve a significant need for maintenance personnel.
Once plant status is understood and the plant is in a stable condition, attention can be focused on corrective maintenance that may be needed to restore plant capabilities.
E4-8 Enclosure 4 to NL-15-1392 Farley Staffing -Detailed Description and Technical Evaluation Typically, the initial stages of Corrective Actions are minor or of limited scope, such as:* Mechanical
-Identification and operation of faulty valves, clogged filters, packing and seal adjustments, or troubleshooting.
° Electrical
-Identification and correction of tripped breakers and overloads, or hands-off troubleshooting.
- I&C -Identification and correction of controller and set point adjustment, calibration, or hands-off troubleshooting.
Until the reactor is stabilized and the causal agents identified, actual repairs or realignment of plant equipment would not require large-scale maintenance support. The current version of the FNP Unit 1 and Unit 2 Emergency Plan (Revision 64.0) provides for one mechanical journeyman, one electrical journeyman, and one instrument and controls technician on-shift to support the Repair and Corrective Action task. These numbers will be maintained in the proposed SNC Fleet Emergency Plan FNP on-shift staffing.
In addition to these personnel, a maintenance supervisor will be added on-shift to provide supervisory oversight for repair and corrective actions, further enhancing the on-shift response capability.
The proposed SNC Fleet Emergency Plan provides for augmentation of maintenance discipline specific leads in the OSC as well as an overall OSC Manager within 75 minutes of an Alert or higher emergency classification.
The proposal removes one mechanical journeyman, one electrical journeyman, and one instrument and controls technician who currently fulfill Technical Support tasks (Fire Tanker Driver, FMT driver, and in-plant survey assistant) that are addressed elsewhere in this document.
This is a reduction in staffing.
A 10 CFR 50 Appendix E shift staffing eyaluation was performed to validate that removal of the individuals performing the Technical Support tasks did not impact the ability of the proposed on-shift staff to perform all of their assigned tasks during the 75 minutes prior to augmentation.
The NRC Public Meeting on July 16, 2015 discussing proposed changes to guidance regarding ERO staffing and augmentation (ML15174A309) identified that the proposed change primarily meets or exceeds the current regulatory guidance of NUREG-0654/FEMA REP-01 Revision I Table B-I and the proposed NUREG-0654/FEMA REP-01 Revision 2.Based on FNP Unit I and Unit 2 licensing basis (FSAR), the design philosophy with respect to Emergency Safety Features (ESF) and guidance for restoration, it is unnecessary to have additional Mechanical Maintenance, Electrical Maintenance, and l&C Maintenance augmented within the 75 minute timeframe.
ESF systems are redundant in trains (physical separation) and have diversity of subsystems.
Therefore, the inoperability of different system components in different trains is not expected to result in a loss of function of the ESF. This allows flexibility in plant operations under circumstances where components in redundant subsystems may be inoperable.
Protective Actions (In-Plant)
For the Protective Actions (In-Plant) function, NUREG-0654/FEMA REP-01 Revision 1 specifies providing two personnel on-shift who "may be provided by shift personnel assigned other functions." The major tasks of this function are access control, RP coverage for repair, corrective actions, search and rescue, first aid, firefighting, personnel monitoring, and dosimetry.
Revision 64.0 of the FNP Unit I and Unit '2 Emergency Plan provides two individuals for performing this function.
One is an RP technician and the other is a chemistry technician who, as needed, supports dosimetry issuance, and also supports briefing the on-shift on-site out of E4-9 Enclosure 4 to NL-15-1392 Farley Staffing -Detailed Description and Technical Evaluation plant survey team prior to dispatch and communication with this team. Under the proposed SNC Fleet Emergency Plan staffing, a single RP technician will support this function.System Operators are typically dispatched prior to the call-out of augmented personnel.
Normally the initial response phase involves search and rescue operations or manual manipulation of equipment.
Maintenance actions in the initial response phase are anticipated to be minimal as discussed previously.
Installed plant area radiation monitors are used to provide indication of in-plant radiation levels prior to dispatch of personnel into the plant. This allows for personnel to be assigned the appropriate dose and dose rate alarms for their electronic personal dosimetry prior to dispatch and to assign additional Radiation Protection technician support as needed.Personnel accessing the Radiological Control Areas (RCA) at FNP Unit 1 and Unit 2 are required by procedure to obtain electronic personal dosimetry prior to entry. The same dosimetry is also used as a 'key" to unlock turnstiles for access to the RCA. Radiation work permits (RWPs) establish the necessary preset warnings/alarms associated with the dosimetry.
During a declared emergency, the normal RCA entry process may use pre-prepared emergency RWPs using the Digital Alarming Dosimeters DADs. In the event the normal access system is non-functional, an emergency reentry process has been developed to use the pre-prepared emergency RWP dose and dose rate alarms manually programed into the DADs. This ensures the teams dispatched to in-plant areas t6 perform any function during a declared emergency will be afforded ample warning/alarm before exceeding the allowed dose or dose rate. In-plant teams are briefed on radiological conditions prior to being dispatched, including plant event conditions, radiological conditions, dose and dose rate turn back values/alarms, and communications methods to be used if radiological conditions change or if unexpected radiological conditions are encountered.
Thus, under emergency conditions, responding personnel will be knowledgeable of dose rates in the area, and radiation protection personnel may not be required to accompany all teams into the plant areas. Dosimeters also can be programmed at the OSC by RP personnel as needed prior to team dispatch.
The proposed SNC Fleet Emergency Plan FNP on-shift staffing provides for a total of two Radiation Protection technicians between the Protective Actions (in-plant) and Radiological Accident Assessment (in-plant surveys) to ensure appropriate radiological protective measures are available to the on-shift staff.An additional two Radiation Protection technicians and an RP/Chemistry OSC lead will be augmented in the OSC within 75 minutes to support the Protective Actions (in-plant) function.This will provide sufficient Radiation Protection resources to address the needs of both the on-shift and augmented ERO personnel for the Protective Actions (in-plant) function.Fire Fighting For the Fire Fighting function, NUREG-0654/FEMA REP-01 Revision 1 specifies that staffing is per the site Technical Specifications.
Revision 64.0 of the FNP Unit 1 and Unit 2 Emergency Plan states the Fire Brigade staffing is in accordance with the FNP FSAR, where the Fire Brigade commitments for FNP are maintained.
The on-shift Fire Brigade is assigned this task throughout the emergency with off-site support provided by local fire departments.
The Fire Brigade staffing and associated off-site fire response support remains unchanged in the proposed SNC Fleet Emergency Plan.Revision 64.0 of the FNP Unit I and Unit 2 Emergency Plan provides an additional individual designated as Fire Tanker Driver, who is assigned to drive a large transport vehicle pulling a trailer-mounted water tank, used for fires affecting areas external to the plant such as grass fires or outbuildings outside the installed plant fire protection header. There is no requirement in the FNP ESAR for this position, nor is there any regulatory requirement for maintaining this position E4-10 Enclosure 4 to NL-15-1392 Farley Staffing -Detailed Description and Technical Evaluation as part of, the site's emergency planning basis. Furthermore, the type of fires for which this equipment would be used will be addressed by off-site fire responders with whom FNP maintains support agreements.
These agreements with off-site firefighting resources are provided in the current FNP Emergency Plan as well as in the proposed SNC Fleet Emergency.
Plan. Since the equipment operated by this position is not used to fight fires affecting actual plant equipment, there is no impact to the performance of the Fire Fighting function as the result of eliminating this position from minimum FNP on-shift staffing requirements in the SNC Fleet Emergency Plan.A staffing analysis meeting the requirements of 10 CFR 50 Appendix E.IV.A.9 for the proposed organization was performed.
The results of that analysis showed that the required response functions could be conducted with parallel activation of the fire brigade for the subject scenarios.
Rescue Operations and First Aid Per NUREG-0654/FEMA REP-O1 Revision 1, the Rescue Operations and First Aid function"may be provided by shift personnel assigned other functions.'" There are no proposed changes to this area. The FNP Unit 1 .and Unit 2 Emergency Plan provides appropriately trained on-shift personnel to fulfill this function as a collateral duty. There are no additional personnel augmented for this task. Local off-site support provides for any additional assistance.
There are no proposed changes to this area.Site Access Controls and Personnel Accountability There are no proposed changes to this area. This function is part of the Security Contingency Plan and is staffed accordingly.
Onsite Emergency Response Organization (ERO) -10 CFR 50.47(b) (2)The current ERO provided in Revision 64.0 of the FNP Unit 1 and Unit 2 Emergency Plan was developed in response to NUREG-0654/FEMA REP-0l Revision 1.. The ERO developed by NUREG-0654/FEMA REP-01 Revision 1 was developed without a specific technical basis. The Emergency Preparedness Enhanced Rulemaking of November 23, 2011 required the capabilities of the on-shift staff to be validated by a formal analysis.
This requirement was documented in 10 CFR 50 Appendix E.IV.A.9.
In support of this submittal, the proposed ERO for the FNP Unit 1 and Unit 2 Site was analyzed and it was determined that the on-shift staff proposed is capable of performing the response functions required of the revised rule.Reason for the Change The proposed ERO in the SNC Fleet Emergency Plan provides a standard complement of emergency response positions, titles, duties, and responsibilities.
This will result in a more effective interface between ERO members at the sites and their counterparts at the SNC Fleet EOF. Having a common ERO organization for the SNC Fleet will also support sharing of ERO resources between affected and non-affected stations during emergencies.
Establishing an appropriately staffed SNC Fleet standard on-shift and an augmented ERO staffing model with an SNC Fleet standard definition for ERO augmentation time is a practical and prudent alternate method to ensure effective and timely emergency response augmentation.
Details associated with the on-shift ERO, revised augmented ERO, and revised key responsibilities and tasks as identified in NUREG-0654/FEMA REP-0l Revision 1, are included in Enclosure 6.E4-11 Enclosure 4 to NL-15-1392 Farley Staffing -Detailed Description and Technical Evaluation Planning Basis for Auqmented Emergency Response Organization (ERO)Positions have been designated as 75 minutes responders in the TSC, OSC, EOF, and JIC.These positions perform major functions and supporting functions in each facility.
The tables below outline these positions and functions as provided in the proposed SNC Fleet Emergency Plan.TSC 75 Minute Augmentation ERO Major Functional Area Major Task Position Title Emergency Director (ED)TSC Manager Emergency Direction and Operations Supervisor Control Security Supervisor*
______________________Support Coordinator**
Notify licensee, state, local, Emergency Notification and federal personnel
& System (ENS) Communicator Notification/Communication maintain communication HPN Communicator Intra-facility Communications Emergency Response Facility___________________(ERF)
Communicator Offsite Dose Assessment Radiation Protection (RP)Radiological Accident Supervisor Assessment and Support of OfiesresNtapial o hsfclt Operational Accident Onfsite andun-vantsurveplalefrshs ailt AssessmentOnieadn-atsuvy
______________________Chemistry/Radio Chemistry Chemistry Support Technical Support Engineering Supervisor Reactor Engineer Engineering Support (2)Plant System Engineering, Repair and Corrective Actions Repair and corrective Maintenance Supervisor actions Access Control Not applicable for this facility RP coverage for repair, corrective actions, search Protective Actions and rescue, first aid &firefighting Personnel monitoring
____ ___ ____ ___ ____ ___ Dosimetry
_ _ _ _ _ _ _ _ _ _ _ _ _* Security Supervisor filled by one of the on-shift Security Supervisors.
- Support Coordinator does not have a 75 minute augmentation time.E4-12 Enclosure 4 to NL-15-1392 Farley Staffing -Detailed Description and Technical Evaluation OSC 75 Minute Augmentation ERO Major Functional Area Major Tasks Position Title Emergency Direction and 0S0 Manager Control Notify licensee, state, local Not applicable for this facility and federal personnel
&Notification/Communication miti omncto Intra-facility communications ERF Communicator Radoloicl AcidntOffsite Dose Assessment Not applicable for this facility Rassessmentand Suppornt of Offsite surveys Field Monitoring Team Assesmet ad Supor ofPersonnel (2)Opertioal ccientOnsite and in-plant surveys RP Technicians (2)AssssmntChemistry/Radio Chemistry Chemistry Technician Technical Support Not applicable for this facility Repair and corrective Mechanical Maintenance Plant System Engineering, actions Group Lead Repair and Corrective Actions Electrical Maintenance Group Lead I&C Maintenance Group Lead Access Control RP / Chemistry Group Lead* RP coverage for repair, RP Technicians (2)corrective actions, search Protective Actions and rescue, first aid &firefighting
- Personnel monitoring
- Dosimetry E4-13 Enclosure 4 to NL-1 5-1 392 Farley Staffing -Detailed Description and Technical Evaluation EOF 75 Minute Augmentation ERO _____________
Major Functional Area Major Task Position Title Emergency Direction and EQE Director ED Control EOF Manager Support Coordinator*
Emergency Communication Coordinator Security Coordinator Offsite Response Coordinator Administrative Support Staff *Liaisons (at EOCs)*-GA-AL-SC Notification/Communication Notify licensee, state, local ENN Communicator and federal personnel
& ENS Communicator maintain communication HPN Communicator Intra-facility ERE Communicator Communications Nuclear Spokesperson Technical Assistant News Writer Field Team Communicator Radiological Accident Offsite Dose Assessment Dose Assessment Supervisor Assessment and Support of Dose Analyst Operational Accident Offsite surveys Field Team Coordinator Assessment Onsite and in-plant surveys Not required in this facility Chemistry/Radio Chemistry Not required in this facility Plant System Engineering, Technical Support Technical Supervisor Repair and Corrective Actions Repair and corrective Not required in this facility actions Protective Actions Access Control Not required in this facility RP coverage for repair, corrective actions, search and rescue, first aid &firefighting Personnel monitoring Dosimetry* Support Coordinator, Administrative Support Staff, Liaisons (at EOCs) GA, AL, SC do not have a 75 minute augmentation time.E4-14 Enclosure 4 to NL-15-1 392 Farley Staffing -Detailed Description and Technical Evaluation J10 75 Minute Augmentation ERO Functional Area Major Task Position Title Media Response Media Response Public Information Director Facility Coordinator*
Clerical Staff*Secu rity*Public Response Coordinator Public Response Staff*Media Relations Representative
- JIC Assistant, Facility Coordinator, Clerical Staff, Security, and Public Response Staff do not have a 75 minute augmentation time.Minimum staff positions have been identified for each facility.
Facility activation may be completed upon filling of minimum staffing positions and completion of a briefing on the event to ensure personnel in these positions are ready to accept responsibility for their functions.
Minimum staffing positions for the TSC Organization are as follows:* TSC Emergency Director (ED)* TSC Emergency Response Facility (ERF) Communicator
- TSC Dose Analyst* TSC Engineering Supervisor Minimum staffing positions for the Operations Support Center (OSC) Organization are as follows:* OSC Manager* OSC Emergency Response Facility (ERF) Communicator
- OSC RP/Chemistry Group Lead Minimum staffing positions for the EOF Organization are as follows:* EOF Emergency Director (ED)* EOF Emergency Response Facility (ERF) Communicator
- EOF ENN Communicator Minimum staffing positions for the Joint Information Center (JIC) Organization are as follows:* Public Information Director (PID)* Emergency Response Facility (ERF) Communicator
- JIC Manager E4-15 Enclosure 4 to NL-15-1392 Farley Staffing -Detailed Description and Technical Evaluation
- Media Relations Representative
- Public Response Coordinator In addition to the functional analysis provided, the key Emergency Response Facilities were analyzed to determine the minimum staffing (both numbers and positions) needed for the facilities to activate the facilities and begin facility operations.
Any personnel determined to be required to support the minimum staff activation and initiation of activities were added to the revised augmented ERO.Program Enhancements The following section discusses technical changes in plant systems, dose assessment, procedures, and training which have been completed in order to better support on-shift functions and ease operator burden. Additional information regarding on-shift and augmented positions and their responsibilities as identified in NUREG-0654/FEMA REP-01 Revision I are outlined in Enclosure 6.Plant Computer System At the time of the original approval of the FNP Unit I and Unit 2 Emergency Plan, the site used a Westinghouse P2500 Plant Computer System. The operator interface consisted of a small number of printers located in the control room and computer room.In the mid-I1980s, the Westinghouse P2500 Plant Computer System was upgraded to a Gould Encore 32/67 Computer System. The design criteria for the new plant computer were based on the requirements of NUREG-0737, Supplement I for a Safety Parameter Display System (SPDS) and the upgrading of ERFs. The requirements Specified for the SPDS were met or exceeded by a system of displays provided by the Gould Encore 32/67 Computer System. The parameters on the SPDS displays were provided by integrated software on the plant computer system. The system upgrade included introduction of automatic updates to plant overview and system displays on the computer monitors, consolidated safety parameter displays, and increased frequency of parameter updates.In 2006 for Unit 1 and 2007 for Unit 2, the site installed a Data Systems and Solutions (DS&S)SAIPMS Integrated Plant Computer System. The new IPC significantly improved plant monitoring capabilities in the control room as well as in the site's ERFs, by integrating other independent standalone systems.Benefits of the upgraded systems include:* Programming capability for automated response such as indication of critical parameter alarms.* ImProved plant monitoring capability for ED functions.
- Fewer keystrokes required to switch between graphical displays.* Real time plant data available through graphical displays.* Functions are available to any desktop computer through the plant's site-wide intranet.Computer basic functions are supported by instrument buses with back-up power provided by vital buses.E4-16 Enclosure 4 to NL-15-1392 Farley Staffing -Detailed Description and Technical Evaluation Dose Assessment The original FNP dose assessment program used the automated rapid dose assessment (ARDA) software for performing dose assessment.
The ARDA model was a Class A dose assessment model with limited user interface.
In 1994, the FNP dose assessment capability was upgraded when the MIDAS dose assessment program was installed on the ERF Computer to provide FNP a Class B dose assessment model.Improvements have been made to the dose assessment program resulting in minimal user interface required to quickly produce results. Radiological dose assessment has benefited from technological advances that make dose assessment simpler and less time-consuming.
Dose assessment is currently performed by on-shift Chemistry personnel using the MIDAS-NU program. This program supports multi-unit and multi-accident assessment of radiological releases.
The MIDAS-NU program has minimal data entry needs and a minimal number of program windows the user needs to access to perform a dose projection.
With the use of the dose assessment program, as well as plant status, meteorological, and radiation monitoring data, one person can easily and rapidly perform dose assessments during emergency conditions.
Specifically designed displays have been developed for obtaining the necessary plant, radiological effluent, area radiation monitor, and meteorological information for dose assessment personnel on-shift using the Meteorological Information Dose Assessment System-Nuclear (MIDAS-NU) program.Automated Call-Out System Automated call-out systems have been enhanced to streamline processes for activation of the ERO. A single phone call initiates rapid notification of ERO members, in lieu of individual calls to fill the ERO positions included in the Emergency Plan. The system includes a primary activation location as well as a remotely located back-up capability to ensure uninterrupted operation.
Procedure Improvements Emergency Operations Procedures (EOPs)/Abnormal Operating Procedures (AOPs)Since the original emergency plan approval, EOPs have been improved through industry initiatives.
EOPs now use a symptom-based approach that demands less assessment and interpretation of plant conditions by the operating crews. EOPs interface well with new technology such as IPC. EOP curves are generated by IPC to graphically display plant conditions relative to limits or required actions.Emergency Plan Implementing Procedures (EPIPs)In 2007 (Reference Revision 43.0 of FNP Unit 1 and unit 2 Emergency Plan) FNP Unit 1 and Unit 2 updated the classification methodology to NEI 99-01, Revision 4. EALs now incorporate guidance that has simplified the classification process, including the use of an overview matrix of EAL initiating conditions and threshold values, which streamlines the process of evaluating EALs against plant conditions.
Training Improvements Operations Training Training is used to strategically drive improved performance at FNP Unit I and Unit 2. Since NRC approval of the FNP Unit 1 and Unit 2 Emergency Plan, the application of the Systematic Approach to Training (SAT) has resulted in developing a task list for Operations E4-17 Enclosure 4 to NL-15-1392 Farley Staffing -Detailed Description and Technical Evaluation personnel.
The SAT process ensures training is conducted to industry-accepted standards and has led to accreditation of the Operations Training Programs by the National Academy for Nuclear Training.A dynamic simulator is routinely used during Operations Training.
Simulator evaluations include emergency response scenarios that periodically exceed 75 minutes in length and are part of the requalification cycle. Simulator scenarios are designed to be realistic and reflect a wide range of plant conditions, including emergency conditions.
During evaluated simulator sessions, the control room staff is taken from normal operation to accident conditions resulting in declaration of at least one event, which can range from Unusual Event to General Emergency.
The crew performs critical tasks, classification, accident mitigation, response prioritization, and communications without augmentation from additional responders.
The proficiency of the control room staff to perform these functions while maintaining situational awareness, without additional support, is assessed in every training cycle.The Licensed Operator Continuing (LOOT) Program includes licensed crew performance evaluations that consider the scenario guidance attributes of INPO Operations Department Standing Instruction, ODSI-3, and "Operations Department Guidance." Attachment C of ODSI-3 provides guidance on the realistic integration of the emergency response into crew performance evaluations.
The purpose is to ensure crew performance evaluations realistically represent the additional challenges that the emergency plan responsibilities add to the crew's ability to manage an event. Representing the event as realistically as possible, which includes the additional challenges of emergency plan responsibilities, helps promote the situational awareness necessary during a real event.STA Training The Shift Technical Advisor (STA) was originally trained as an advisor to the operating shift per NUREG-0737.
In 1990, additional guidelines were developed by INPO for the training of STAs. This is detailed in the document INPO 90-003, Guidelines for Training and Qualifications of Shift Technical Advisors.The INPO Guidelines describe the role of the STA. The STA performs independent assessments of plant operating concerns, technical support, appropriate corrective actions, analysis of events and their effects, effectiveness of response(s) to emergent conditions, classifications of emergencies, development of recommendations to protect the public, and any other actions related to critical safety functions and plant safety during abnormal and emergency situations.
By routinely monitoring equipment and plant operations, the STA can focus on preventive actions to mitigate the consequences of an accident and protect public health and safety.Increases in On-Shift Staffing There has been an increase in on-shift staffing since the original approval of the FNP Unit 1 and Unit 2 Emergency Plan, in order to ensure adequate performance of the major emergency plan functions and tasks. A total of 28 persons are identified for on-shift staffing in Revision 64.0 of the FNP Unit 1 and Unit 2 Emergency Plan, which is an increase from the total of 10 persons in the regulatory guidance provided by NUREG-0654/FEMA REP-01 Revision 1. A comparative chart depicting on-shift and augmented staffing based on NUREG-0654/FEMA REP-O1 Revision 1, Revision 25.0 of the FNP Unit 1 and Unit 2 Emergency Plan, Revision 64.0.0 of the FNP Unit 1 and Unit 2 Emergency Plan, and proposed revisions are included in Enclosure 6.E4-18 Enclosure 4 to NL-1 5-1 392 Farley Staffing -Detailed Description and Technical Evaluation Enhancements in Information Sharing with Offsite Agencies There has been a dramatic increase in the ability of the 'site to share event-specific information with Offsite Response Organizations (OR~s) from the one-to-one telephone systems at the time the original FNP Unit 1 and Unit 2 Emergency Plan was approved.
Real-time plant data is communicated to the Nuclear Regulatory Commission using the approved Emergency Response Data System (ERDS). Additionally, local OROs are provided real-time data with automated methods (currently WebEOC). These enhancements provide more timely and accurate information of actual plant conditions than was originally available.
Improvement Summary The improvements to staffing, equipment, procedures, communication of plant information, and training since initial approval of the FNP Unit I and Unit 2 Emergency Plan have resulted in a significant increase in on-shift capabilities and knowledge.
The ERO maintains the depth and capability for continuous 24-hour coverage of the Emergency Response for a protracted period.S unmma ry Based on overall improvements in technology, procedures, training, and staffing levels available to ERO since the original implementation of the guidance contained in NUREG-0654/FEMA REP-O1 Revision 1, the proposed Emergency Response Organization is capable of implementing the Emergency Plan in accordance with the requirements of 10 CFR 47 and 10 CFR 50 Appendix E.E4-19 Southern Nuclear Operating Company Joseph M. Farley Nuclear Plant Units 1 and 2;Edwin I. Hatch Nuclear Plant Units 1 and 2;Vogtle Electric Generating Plant Units 1 and 2;Vogtle Electric Generating Plant Units 3 and 4 Enclosure 5 Farley Standard Emergency Plan Annex This enclosure contains 29 pages.
Southern Nuclear Operating Company STANDARD EMERGENCY PLAN ANNEX for Farley Nuclear Plant Units 1 and 2 Revision 0 Enclosure 5 to NL-15-1 392 Farley Standard Emergency Plan Annex Table of Contents Section 1: Introduction (SEP) ................................................................................
3 1.1 Facility Description
........................................................................................
3 1.2 Emergency Planning Zones (SEP J.5)...................................................................
3 1.3 Department of the Army -8 9th Explosive Ordnance Disposal (EQO) Detachment
..................
3 1.4 State of Alabama (SEP A.2.1)............................................................................
3 1.5 State of Georgia (SEP A.2.2).............................................................................
4 1.6 State of Florida ............................................................................................
4 1.7 Local Organizations (SEP A.2.4, B.6.1) .................................................................
4 1.8 24-Hour Staffing (SEP F.1.2).............................................................................
5 1.9 Hostile Action Based Events (SEP H.1.4) ...............................................................
6 Figure 1.1 .A -Location and Vicinity Map......................................................................
7 Figure 1.1 .B -Joseph M. Farley Nuclear Plant Site Plan ....................................................
8 Figure 1 .2.A Mile Emergency Planning Zone (EPZ)...................................................
.9 Figure 1.2.B- 50 Mile Ingestion Pathway IPZ ...............................................................
10 Section 2: Organizational Control of Emergencies (SEP B.1)..........................................
11 2.1 Normal Plant Organization (SEP B.1) ..................................................................
11 2.2 Emergency Organization (SEP B.2, B.3)...............................................................
11 Table 2.2.A -Farley Nuclear Plant On-Shift Staffing ........................................................
12 2.3 Non-SNC Support Groups (SEP B.4, B.5, B.6) ........................................................
13 Section 3: Classification of Emergencies (SEP 0.1).....................................................
15 3.1 Emergency Classifications: (SEP D.1)...- .............................................................
15 3.2 Determination of Levels: (SEP D.1.2) ..................................................................
15 3.3 Operating Mode Applicability (SEP D.2.7) .............................................................
15 Section 4: Emergency Measures (SEP E) .................................................................
16 4.1 Notification of Off-Site Agencies (SEP E.2.2)..........................................................
16 4.2 Alert and Notification System (ANS) (SEP E.2.5) .....................................................
16 4.3 Protective Actions for Onsite Personnel (SEP J.4)....................................................
17 4.4 Protective Actions for the Offsite Public (SEP J.5) ....................................................
17 Section 5: Emergency Facilities and Equipment (SEP H)...............................................
19 5.1 Emergency Response Facilities (SEP H.1, H.2) ......................
"...................................19 Figure 5.1 .A -Sample Technical Support Center...........................................................
21 Figure 5.1 .B -Sample Operations Support Center..........................................................
22 5.2 On-Site Communications (SEP F.1)....................................................................
23 5.3 Offsite Communications (SEP F.1) .....................................................................
23 5.4 Communications System Testing (SEP F.3)...........................................................
23 5.5 Emergency Kits (SEP H.9) ..............................................................................
23 5.6 Facilities and Equipment for On-site Monitoring (SEP H.5)...........................................
23 5.7 Protective Facilities and Equipment (SEP J)...........................................................
24 5.8 Medical Support (SEP B.6, SEP L).....................................................................
25 Appendix A -Evacuation Time Estimate Study and Map Reference (SEP J.6)......................
26 Appendix B -Emergency Action Level (EAL) Scheme (SEP 0.1)......................................
28 Appendix C -Supporting Plans & Implementing Procedures (SEP P.3)..............................
29 E5-2 Enclosure 5 to NL-1 5-1 392 Farley Standard Emergency Plan Annex Section 1: Introduction (SEP)This document serves as the Farley Nuclear Plant (FNP) Units 1 and 2 Annex and contains information and guidance that is unique to FNP. This includes Emergency Action Levels (EALs) and facility geography.
In an emergency situation at FNP, the initial response would be made by the site staff and, if needed, by local support agencies.
This Annex addresses the actions and responsibilities of the FNP plant staff and the offsite support agencies.1.1 Facility Description The Farley Nuclear Plant (FNP) is a two unit pressurized water reactor. The plant site is in Houston County, Alabama, approximately 15 miles east of Dothan, Alabama.1.2 Emergency Planning Zones (SEP J.5)1.2.1 Plume Exposure Pathway (SEP J.7)The 10-mile Emergency Planning Zone (EPZ) for FNP approximates a 10-mile radius around the plant site and is depicted in Figure 1.2.A.Alabama and Georgia, as well as the counties (Early County in Georgia and Houston and Henry Counties in Alabama) are located within the plume exposure pathway EPZ.1.2.2 Ingestion Pathway (SEP J.7)The area between the 10-mile and 50-mile radius is considered the Ingestion Pathway Zone (IPZ). The 50-mile IPZ is depicted in Figure 1.2.B. Planning for the ingestion exposure pathway is a responsibility of the states of Alabama, Florida, and Georgia. More information about the IPZ can be obtained from the States' Radiological Emergency Plans.1 .3 Department of the Army -8 9 th Explosive Ordnance Disposal (EOD) Detachment In the event of an emergency involving the discovery of unexploded ordnance or an improvised explosive device at FNP, an agreement has been established with the 8 9th Explosive Ordnance Disposal Detachment of Ft. Benning, Georgia for the collection and disposal of the discovered device(s).
1.4 State of Alabama (SEP A.2.1)The Alabama Department of Public Health, Office of Radiation Control (ADPH-ORC) is responsible for initiating the "Alabama Radiological Response Plan for Nuclear Power Plants" in support of an emergency at the Farley Nuclear Plant.This plan provides a detailed description of the notification procedures and responsibilities and duties of the local and state agencies involved.
Since the primary concern of the Alabama Radiation Control Division is the welfare and safety of the general public, it will have primary responsibility and authority for handling the offsite aspects of the emergency in Alabama.An agreement is in place with the State of Alabama to provide available resources and equipment to support mitigation and response to an emergency at Plant Farley, including Hostile Action Based events. These resources include, but are not limited to, Local Law Enforcement Agency (LLEA) assets, fire fighting assets, medical support resources (including transportation), and coordination through an Incident Command Post. Requests for offsite resources and E5-3 Enclosure 5 to NL-15-1 392 Farley Standard Emergency Plan Annex equipment will be communicated from the control room to the Houston County 911 center, the county EOC, or through the Incident Command Post, as applicable, based on the nature and timing of the event.1.5 State of Georgia (SEP A.2.2)Upon notification of an emergency condition, the Georgia Emergency Management Agency will implement the "State of Georgia Radiological Emergency Plan." The Georgia Emergency Management Agency has the authority and responsibility for coordinating the efforts of local and state agencies in Georgia to provide for the health and safety of the general public in the event of a radiological incident.An agreement is in place with the State of Georgia to provide available resources and equipment to support the mitigation and response to an emergency at Plant Farley, including Hostile Action Based events. These resources include, but are not limited to, Local Law Enforcement Agency (LLEA) assets, fire fighting assets, medical support resources (including transportation), and coordination through an Incident Command Post. Requests for offsite resources and equipment will be communicated from the control room to the Early County 911 center, the county EOC, or through the Incident Command Post, as applicable, based on the nature and timing of the event.1.6 State of Florida Upon notification of an emergency condition by SNC or the Alabama Emergency Management Agency, the Florida Department of Community Affairs, Division of Emergency Management, State Warning Point will implement the "State of Florida Radiological Emergency Management Plan for Nuclear Power Plants." The Department of Community Affairs, Division of Emergency Management has the authority and responsibility for coordinating the efforts of local and state agencies in Florida to provide for the health and safety of the general public in the event of a radiological incident.
The Department of Health-Bureau of Radiation Control will provide support to Plant Farley in matters related to the Florida ingestion pathway radiological emergency response.1.7 Local Organizations (SEP A.2.4, B.6.1)Principal activities of Local Emergency Management Agencies (LEMA) and Local Law Enforcement Agencies (LLEA) in Georgia, Alabama, and Florida are described in the respective State and County Emergency Operations Plans.1.7.1 Houston County, Alabama (SEP A.2.4)The Chairman of the Houston County Commission has the overall responsibility for emergency preparedness and local response in Houston County. Houston County also has accepted responsibility for evacuations in Henry County out to the 10-mile EPZ. The Houston County Emergency Management Agency coordinates planning and operations of all local agencies in support of an incident at Farley Nuclear Plant. A detailed emergency plan is maintained in case of an emergency at the Farley Nuclear Plant.An agreement is in place with Houston County, Alabama to provide available resources and equipment to support mitigation and response to an emergency at Plant Farley to include Hostile Action Based events.E5-4 Enclosure 5 to NL-1 5-1 392 Farley Standard Emergency Plan Annex These resources include, but are not limited to, Local Law Enforcement Agency (LLEA) assets, fire fighting assets, medical support resources (including transportation), and coordination through an Incident Command Post. Requests for offsite resources and equipment will be communicated from the control room to the Houston County 911 center, the county FOC, or through the Incident Command Post, as applicable, based on the nature and timing of the event.1.7.2 Early County, Georgia (SEP A.2.4)The Chairman, Early County Board of Commissioners, has responsibility for overall radiological emergency response planning.
The actual plan development and coordination of emergency actions is carried out by the Blakely-Early County Emergency Management Agency. The "Blakely-Early County Emergency Management Agency Radiological Emergency Plan for Nuclear Incidents/Accidents Involving Joseph M. Farley Nuclear Power Plant'" is given as part of the "State of Georgia Radiological Emergency Plan." An agreement is in place with Early County, Georgia, to provide available resources and equipment to support mitigation and response to an emergency at Plant Farley to include Hostile Action Based events. These resources include, but are not limited to, Local Law Enforcement Agency (LLEA) assets, firefighting assets, medical support resources (including transportation), and coordination through an Incident Command Post.Requests for offsite resources and equipment will be communicated from the control room to the Early County 911 center, the county EOC, or through the Incident Command Post, as applicable, based on the nature and timing of the event.1.7.3 City of Dothan, Alabama (SEP B.6.4)In the event an emergency is declared as a result of a fire at Farley Nuclear Plant, the Dothan Fire Department has agreed to provide support to help combat the fire. The estimated response time to Farley Nuclear Plant is 30 minutes. The Emergency Director is authorized to request this assistance.
Request for fire support will be made by the control room or site security to the Houston County 911 center, Houston County EOC, or the Incident Command Post, as applicable, based on the nature and timing of the event.1.8 24-Hour Staffing (SEP F.1.2)Primary offsite authorities provide 24-hour-per-day staffing of communications links as follows: State of Alabama* Alabama Emergency Management Agency.State of Geor~qia:* Georgia Emergency Management Agency (GEMA).Alabama Counties:* Houston County -Sheriffs Department.
E5-5 Enclosure 5 to NL-1 5-1 392 Farley Standard Emergency Plan Annex Georqiia County Authorities:
SEarly County -Sheriff's Department.
1.9 Hostile Action Based Events (sEP H.1 .4)Agreements are in .place with the states of Alabama and Georgia, Houston County, Alabama and Early County, Georgia to provide available resources and equipment to support mitigation and response to an emergency at Farley Nuclear Plant, including Hostile Action Based events. These resources include, but are not limited to, Local Law Enforcement Agency (LLEA) assets, Firefighting assets, medical support resources (including transportation), and coordination through an Incident Command Post. Requests for offsite resources and equipment will be communicated from the control room or site security to Houston County 911 Center, the EOC or through the Incident Command Post as applicable based on the nature of the event. Copies of these agreements are maintained in accordance with Emergency Plan procedures.
E5-6 Enclosure 5 to NL-15-1 392 Farley Standard Emergency Plan Annex rENE ESE Figure 1.1 .A -Location and Vicinity Map E5-7 Enclosure 5 to NL-15-1392 Farley Standard Emergency Plan Annex Figure 1.13. -Joseph M. Farley Nuclear Plant Site Plan E5-8 Enclosure 5 to NL-15-1392 Farley Standard Emergency Plan Annex Joseph M. Farley Nuclear Plant Emergency Planning Zone 10 Mile Radius Figure 1 .2.A -1 0-Mile Emergency Planning Zone (EPZ)E5-9 Enclosure 5 to NL-15-1 392 Farley Standard Emergency Plan Annex Figure 1 .2.B -50 Mile Ingestion Pathway IPZ E5-10 Enclosure 5 to NL-15-1392 Farley Standard Emergency Plan Annex Section 2: Organizational Control of Emergencies (SEP B.1)2.1 Normal Plant Organization (SEP B.1)The normal plant operating crew is staffed and qualified to perform actions that may be necessary to initiate immediate protective actions and implement the emergency plan, and is designated as the responsible group for such actions.The normal plant organization is described in Section B.1 of the Emergency Plan.2.2 Emergency Organization (SEP B.2, B.3)2.2.1 The FNP On-Shift Emergency Response Organization is described in Table 2.2.A (SEP B. 1).2.2.2 The FNP Augmented Emergency Response Organization is described in Figures B.2.1.A, B.2.2.A, B.3.1.A, and B.3.2.A in the Emergency Plan (SEP B.2, B.3).An On-Shift Staffing Analysis was completed in accordance with the requirements of 10 CFR 50 Appendix E IV.A.9. This analysis forms the basis for the on-shift staff as described in Table 2.2.A. A copy of the analysis is maintained in the SNC document management system.E5-11 Enclosure 5 to NL-15-1392 Farley Standard Emergency Plan Annex Table 2.2.A -Farley Nuclear Plant On-Shift Staffing Major Functional Area Major Tasks Position On-Shift Emergency Direction Shift Manager (SM)/ 1 and Control ______________Emergency Director (ED)Plant Operations and Shift Supervisor (SRO) 2 Assessment of Reactor Operator (RO) 4 Operational Aspects Shift Support 1 Supervisor/Fire Brigade Leader (SRO/FBL) ate 1 System Operator (SO) Not, 1 7 Plant System Technical Support Shift Support 1 Engineering, Repair Supervisor/Shift Technical and Corrective Actions ______________Advisor (SROISTA)Notification/
Notify licensee, state, local, and Licensed Operator (RO or Note 2 Communication federal personnel and maintain SRO)communication Radiological Accident Offsite Dose Assessment Chemistry Technician or 1 Assessment and other trained personnel Support of Operational In-plant surveys RP Technician or other 1 Accident Assessment trained personnel Offsite Surveys, Onsite (out-of- RP Technician or other 1 plant) trained personnel Protective Actions Radiation Protection:
RP Technician 1 a. Access Control b. RP Coverage for repair, corrective actions, search and rescue, first-aid, and firefighting
- c. Personnel monitoring
- d. Dosimetry____________
Chemistry/Radio-chemistry Chemistry Technician 1 Plant System Repair and Corrective Actions Maintenance Supervisor 1 Engineering, Repair Eetia aneac and Corrective Actions Eetia aneac Mechanical Maintenance 1 I&C Maintenance 1 Total: 25 Fire Fighting Fire Brigade Notel1 Rescue Operations and Rescue Operations/First 2 First Aid Aid Note 2 Site Access Control Security Security and Personnel Plan Accountability
_____________
______Note 1 -Fire Brigade made up of FB Leader (5SS) and 4 System Operators not assigned safe shutdown responsibilities.
Note 2 -May be provided by shift personnel assigned other functions E5-12 Enclosure 5 to NL-15-1392 Farley Standard Emergency Plan Annex 2.3 Non-SNC Support Groups (SEP B.4, B.5, B,6)2.3.1 Fire Fighting (SEP B.6.4)In the event an emergency is declared as a result of a fire at Farley Nuclear Plant, the City of Dothan Fire Department has agreed to provide support to help combat the fire. The Dothan Fire Department resources are listed in applicable site procedures.
The estimated response time to Farley Nuclear Plant is 30 minutes. The Emergency Director is authorized to request this assistance.
Request for fire support will be made by the control room or site security to the Houston County 911 center, Houston County EOC, or the Incident Command Post, as applicable, based on the nature and timing of the event. Fire Drills are conducted annually and involve the Dothan Fire Department.
2.3.2 Hospital and Medical Support (SEP B.6.3, K.1.3, L.1)The detailed plans for the handling and care of injured personnel potentially contaminated and/or highly irradiated are contained in site procedures.
A brief description of the facilities and services available for medical support is given below.2.3.2.1 Southeast Alabama Medical Center The Southeast Alabama Medical Center in Dothan, Alabama, has agreed to receive and care for injured personnel that may be contaminated or irradiated.
In addition to routine medical care, space has been provided for decontamination and emergency treatment and for storage of emergency medical equipment, monitoring equipment and dosimeters.
Entrance to this facility will not affect the use of the hospital emergency room.2.3.2.2 University of Alabama at Birmingham Hospital The Division of Oncology of the University of Alabama at Birmingham (UAB) Hospital in Birmingham, Alabama, has agreed to provide, on a priority basis, definitive care for irradiated and/or contaminated casualties.
An area of the hospital has been modified to provide for such radiological emergencies.
At the physicians' discretion, persons who have been exposed may be sent to UAB after receiving treatment at the Southeast Alabama Medical Center.2.3.2.3 Oak Ridge Institute for Science and Education
-REAC/TS The Oak Ridge Institute for Science and Education-REAC/TS team at Oak Ridge, Tennessee, has agreed to accept any type of radiation accident victim in need of hospitalization.
At the physicians' discretion, persons who have been exposed may be sent to ORISE-REAC/TS after receiving treatment at the Southeast Alabama Medical Center.E5-13 Enclosure 5 to NL-15-1 392 Farley Standard Emergency Plan Annex 2.3.3 Ambulance Services (SEP B.6.2, L.4)Requests for ambulance support will be made by the control room or site security to the Houston County 911 center, Houston County EOC, or the Incident Command Post, as applicable based on the nature and timing of the event.2.3.3.1 Local Ambulance and Rescue Squads* Ashford Rescue Squad.* Columbia Rescue Squad.* Dothan Ambulance Service (Pilchers Ambulance Service), Inc.2.3.4 Voluntary Assistance Group (SEP B.4.2)SNC is a signatory to two comprehensive agreements among electric utility companies:
- Nuclear Power Plant Emergency Response Voluntary Assistance Agreement.
- Voluntary Assistance Agreement By and Among Electric Utilities Involved in Transportation of Nuclear Materials.
2.3.5 Information for Transients (SEP G.8)Several communications methods may be used to acquaint the public with plans for their protection during a Plant emergency.
Effort will be concentrated on providing information to the public by written material that is likely to be available in residences and in locations frequented by transients.
The information will also provide instructions on which local media will be providing additional information in the event of an emergency.
E5-14 Enclosure 5 to NL-15-1 392 Farley Standard Emergency Plan Annex*Section 3: Classification of Emergencies (SEP D.1)3.1 Emergency Classifications: (SEP 0.1)There are four classes of Emergency Action Levels based on severity, taking into consideration both potential and actual events in progress.
They are, from the least to the most serious, Unusual Event, Alert, Site Area Emergency, and General Emergency.
Initiating Conditions (ICs), which determine which level will be declared, are predetermined subsets of plant conditions where the potential exists for a radiological emergency, or such an emergency has occurred.
Emergency Action Levels (EALs) are plant-specific indications, conditions, or instrument readings used to classify emergency conditions.
3.1.1 The described emergency classes and the emergency action levels are agreed on by SNC and state and local authorities.
The emergency action levels will be reviewed by state and local officials annually.3.2 Determination of Levels: (SEP D.1.2)Appendix B to this Annex contains the matrix for Initiating Conditions used to determine an Emergency Action Level (EAL). They are part of the scheme established by NEI 99-01, Methodology for Development of Emergency Action Levels.3.3 Operating Mode Applicability (SEP 0.2.7)The plant operating mode that existed at the time the event occurred, prior to any protective system or operator action initiated in response to the condition, is compared to the mode applicability of the EALs. If an event occurs, and a lower or higher plant operating mode is reached before the emergency classification level can be declared, the emergency classification level shall be based on the mode that existed at the time the event occurred.PWR Operating Modes at FNP 1&2 Power Operations (1): Reactor Power > 5%, Ke. > 0.99 Startup (2): Reactor Power < 5%, Keff > 0.99 Hot Standby (3): RCS > 350 °F, Keff < 0.99 Hot Shutdown (4): 200 °F < RCS < 350 °F, < 0.99 Cold Shutdown (5): RCS <200 0 F, Keff < 0.99 Refueling (6): One or more vessel head closure bolts less than fully tensioned Defueled (None): All reactor fuel removed from reactor pressure vessel.(Full core off load during refueling or extended outage)E5-15 Enclosure 5 to NL-15-1392 Farley Standard Emergency Plan Annex Section 4: Emergency Measures (SEP E)4.1 Notification of Off-Site Agencies (SEP E.2.2)4.1.1 Notification Process (SEP E.2.2.1)State and local counties surrounding FNP will be notified within 15 minutes of the declaration of an emergency condition are: State of Alabama* Alabama Emergency Management Agency (AEMA).State of Georgqia:* Georgia Emergency Management Agency (GEMA).Alabama County Authorities
- Houston County -Sheriff's Dispatch Center.Georgqia County Authorities:
- Early County -Sheriff's Dispatch Center.4.2 Alert and Notification System (ANS) (SEP E.2.5).Within the Plume Exposure Emergency Planning Zone (EPZ), there exist provisions for alerting and providing notification to the public. The state and/or local authorities are responsible for activation of this system.Primary alerting is accomplished by use of a siren system. Each siren operates on battery power with battery charge maintained through an inverter that receives power from the local electrical grid or from a solar panel(s).
Siren system activation, test, and monitoring panels are provided for Houston County and Henry County in Alabama, Early County in Georgia, and the state of Georgia.Special alerting uses a calling system. Special alerting is initiated in the event of a failure of the system to activate multiple sirens resulting in a loss of coverage in any area. Special alerting may be initiated for a predefined area, a user specified area, user defined groups, or the entire Emergency Planning Zone (EPZ). The calling system serves as a complete independent backup to the ANS. The system provides both alerting and notification of EPZ residents independent of the alerting capabilities of the installed siren system and the notification capability of local radio and television stations through EAS. Capability to activate the calling system is provided by Houston County and Henry County, Alabama, and Early County, Georgia.A full description of the Farley ANS design is provided in the FEMA approved ANS Design located in the SNC document management system.Residents in the plume exposure pathway EPZ have been instructed to tune to specific emergency alert radio or TV stations if the sirens are activated.
Following activation of the siren system, emergency notifications will be made to the public within the 10-mile plume exposure pathway EPZ by activation of the Emergency Alert System (EAS). State and local Emergency Management Agencies will initiate activation of the local EAS stations.
Emergency messages are coordinated between the local Emergency Management Agencies and the state Management Agencies prior to activation of the local radio stations, as specified in the local area plans.E5-16 Enclosure 5 to NL-15-1 392 Farley Standard Emergency Plan Annex 4.3 Protective Actions for Onsite Personnel (SEP J.4)Protective response for onsite personnel (including visitors and contractor personnel) depends on alerting, assembly and accountability, site evacuation, monitoring, and decontamination.
Protective actions may also be taken for onsite personnel for emergencies such as fires, security related events, or natural disasters where personnel safety is threatened.
4.3.1 Alerting (SEP E.2.1, J.1)Section E of the Emergency Plan (EP), Notification Methods and Procedures, describes the methods to alert onsite personnel of emergency conditions.
4.3.2 Assembly (SEP J.4.1)Personnel assembly is mandatory at the Site Area Emergency or higher level classification.
Upon activation of the plant emergency alarm, plant personnel who are assigned specific emergency responsibilities will proceed to their designated emergency response locations.
Assembly of site personnel who are outside the Protected Areas is accomplished by non-essential personnel reporting to designated assembly areas. Assembly may be initiated any time site management deems it appropriate for personnel safety reasons.Nonessential plant personnel located within the Protected Area will exit the protected area upon hearing the Site Area or the General Emergency alarm and report to designated assembly areas. Visitors, contractors, and escorted personnel will leave the protected area during an Alert or higher declaration.
4.3.3 Security Events (SEP J.4)Onsite protection of employees during security events involves a combination of restricted movement, movement to safe locations, and site evacuation depending on the nature of the event and advance warning. Specific actions to be taken during such events are included in site procedures.
4.3.4 Monitoring and Decontamination (SEP K)When an Alert is declared but no site evacuation is anticipated, personnel who have left the protected area are monitored by portal monitors.
If necessary, decontamination is completed using the plant decontamination facilities located in the Auxiliary building or other onsite locations.
For a Site Area Emergency or a General Emergency, or when site evacuation with monitoring is expected and release of radioactivity has occurred, monitoring is performed by Houston County and/or Alabama emergency workers at an established reception center.4.4 Protective Actions for the Offsite Public (SEP J.5)The Emergency Director will recommend the necessary protective actions to offsite authorities, based on predetermined protective actions for a General Emergency Classification or results of offsite dose assessment.
Upon activation of the EOF, the EOF Manager will be responsible for recommending protective actions for the offsite population.
Responsibility for carrying out the protective actions rests with offsite authorities.
E5-17 Enclosure 5 to NL-15-1 392 Farley Standard Emergency Plan Annex 4.4.1 Protective Action Recommendations (SEP J.5)Protective actions have been developed and agreed on with state and local authorities.
They may include the following:
- Evacuation.
- Shelter in place.* Monitor and prepare.* Thyroid blocking agent (consider the use of KI (potassium iodide)) in accordance with state plans and policy.E5-18 Enclosure 5 to NL-15-1392 Farley Standard Emergency Plan Annex Section 5: Emerciencv Facilities and Equipment (SEP H)5.1 Emergency Response Facilities (SEP H.1, H.2)5.1.1 Control Room (SEP H.1.1)The Control Room contains the necessary instrumentation, both process and radiological, to evaluate plant conditions, as detailed in the plant Final Safety Analysis Report. Habitability is maintained by shielding and by the Emergency Filtration Train (EFT) ventilation system, which is capable of operating in a cleanup or recycle mode. All plant emergency equipment is supplied power from the emergency diesel generators, with vital instrumentation powered from inverters connected to the storage batteries located in the battery rooms.5.1.2 Technical Support Center (SEP H. 1.2)Located immediately north of the Unit 2 control room area, the TSC (Figure 5.1.A) is designed for the evaluation of plant status, coordination of damage assessment and emergency actions, and interface with the NRC, Emergency Operations Facility (EOF), and Operations Support Center (OSC). Provision is also made for control and coordination of communications with offsite agencies and of out-of-plant radiation monitoring activities until the EOF is activated and assumes these functions.
The TSC is designed to be habitable to the same extent as the control room for postulated radiological accidents.
Its ventilation system includes a deep-bed charcoal filter to remove air-borne contamination, and it has the capability of pressurizing the TSC area and recirculating the room air through the charcoal ,filter. A permanent radiation monitor is provided to continuously indicate radiation dose rates and airborne activity.
A radiation alarm in the main control room make-up air supply duct automatically initiates room pressurization and recirculation.
Electrical power sources are designed so the HVAC, wall outlets, and lighting can be powered from the diesel generators if offsite power is lost.The TSC maintains access to drawings and records necessary for the response to an emergency event at FNP. These records can be accessed on a digital records system. This system is supplied backup power from an uninterruptible power supply to allow retrieval of records in the event of a loss of power. These records include but are not limited to:* Technical specifications.
- Plant operating procedures.
- Final safety analysis report.* Emergency Plan.* Emergency Plan Implementing Procedures.
- Plant operating records.* System piping and instrumentation diagrams; heating, ventilation, and air-conditioning (HVAC) flow diagrams.* Electrical one-line, elementary, and wiring diagrams.* Control logic and loop diagrams.The above records are updated as necessary to ensure currency and completeness.
E5-19 Enclosure 5 to NL-15-1392 Farley Standard Emergency Plan Annex 5.1.3 Operations Support Center (SEP H.1.3)The break room adjacent to the TSC (outside the Technical Support Center) will serve as the Operations Support Center (Figure 5.1.B), from which emergency operations support will be provided.
The OSC is where operational support personnel such as instrument technicians, mechanics, electricians, chemical/radiation technicians, equipment operators, and incoming shift personnel assemble to aid in the response to an emergency.
The OSO will accommodate the support and technical staff to respond to an event on one or both Units. The OSC has the capability to communicate with the control room, the Technical Support Center (TSC) and the Emergency Operations Facility (EOF). Operations at this facility will be directed by the OSC Manager.5.1.4 Alternative Facility (SEP H.1.4)During a security-related event or other event that precludes onsite access, the TSC and OSC ERO staff will be directed to an alternative facility.
This facility is located in the Alabama Power Company (APC) Old Crew Headquarters Building in Headland, Alabama. The alternative facility is equipped with the necessary communications and data links to support communications with the control room, site security, and the EOF.The available communications and data links also provide access to SNC document management resources, work planning resources, plant technical data displays, and other SNC-specific ,resources for performing engineering assessment activities, including damage control team planning and preparation for return to the site. Guidance for the alternative facility activation and operation is provided in implementing procedures.
5.1.5 Emergency Operations Facility (SEP H.2.1)The EOF is the central location for management of the offsite emergency response, coordination of radiological assessment, and management of initial recovery operations.
The EOF is a dedicated facility located in Birmingham, Alabama, and serves as the EQE for SNC sites (VEGP, FNP, and HNP).Additional details of the EOF are in section H.2.1 of the Emergency Plan.A near site location is maintained at the FNP Training Center. It has space for members of an NRC Site Team and federal, state, and local responders, including space for conducting briefings with emergency response personnel and communications with other licensee and offsite emergency responders, access to plant data and radiological information, and access to copying equipment and office supplies.5.1.6 Joint Information Center (JIC) (SEP H.2.2)The JIC is the central location for the coordination and dissemination of information to news media and responses to media inquiries.
Details of the JIC for FNP are in section H of the Emergency Plan. If the decision is made to move the JIC function to a forward near site location from the Birmingham location, the Birmingham facility will maintain media coordination until the JIC is operational at the near site location.
The near site location is in Dothan, Alabama at Houston County Juvenile Court Services Building.E5-20 Enclosure 5 to NL-1 5-1 392 Farley Standard Emergency Plan Annex OPERATIONS SUPPORT CENTER AIRTIGHT TECHNICAL SUPPORT CENTER PLANNING AND COORDINATION AREA ENTRY CONTROL ROOM Figure 5.1 .A -Sample Technical Support Center E5-21 Enclosure 5 to NL-1 5-1 392 Farley Standard Emergency Pian Annex 4-UN~1 Rm 2452 Rad Side F~Af Foreman's Office Figure 5.1.B -Sample Operations Support Center E5-22 Enclosure 5 to NL-15-1 392 Farley Standard Emergency Plan Annex 5.2 On-Site Communications (SEP F.1)Normal on-site communications is provided by the plant telephone system (network and commercial).
The plant public address (PA) system also may be used for in-plant communications.
The PA system is powered by normal plant power.Portable radios are used for communications between individuals and base stations located in the Control Room, TSC, OSC EOF, and Security.
There is also a plant intercom system. Intercom units are installed at selected plant locations primarily for specific task related activities.
5.3 Offsite Communications (SEP F.1)5.3.1 Communications with the States and Local Counties (SEP F.1.2)The primary means of communication between FNP, the state of Alabama, state of Georgia, Houston County, and Early County is the Emergency Notification Network (ENN). The ENN is a dedicated communications system from the plant to the Alabama Emergency Management Agency Communication Center, Georgia Emergency Management Agency, the Houston County Sheriff's Dispatch Office, and the Early County Sheriff's Dispatch Office, which are staffed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. Extensions for this system are located in the Control Room, the TSC, and the EOF.5.3.2 Alternate Offsite Communications (SEP F.1.1)Commercial telephones or land lines provide backup for the ENN.5.4 Communications System Testing (SEP F.3)Communication channels with the state of Alabama, the state of Georgia, the plume exposure pathway EPZ counties, and the NRC (with the exception of EROS) are tested each calendar month, using the extensions in the Control Room, the TSC, and the EOF.EROS is tested each calendar quarter. Communications procedures and systems are also tested each calendar year.5.5 Emergency Kits (SEP H.9)Emergency supplies and equipment are located at various places at the plant.Procedures require an inspection and operational check of equipment in these kits on a quarterly basis and after each use. Equipment in these kits is calibrated in accordance with the suppliers' recommendations.
A set of spares of certain equipment is also maintained to replace inoperative or out-of-calibration equipment.
5.6 Facilities and Equipment for On-site Monitoring (SEP H.5)The plant instrumentation and monitors perform indicating, recording, and protective functions.
The Reactor Protection System and associated plant instrumentation provide the ability to maintain plant safety from shutdown to full power operations, and to monitor and maintain key variables such as .reactor power, flow, temperature, and radioactivity levels within predetermined safe limits at both steady state conditions and during plant transients.
Plant instrumentation and control systems also provide means to cope with abnormal operating conditions.
The control and display of information of these various systems are centralized in the unit Control Room. This instrumentation would provide the basis for initiation of protective actions.E5-23 Enclosure 5 to NL-15-1 392 Farley Standard Emergency Plan Annex 5.6.1 Geophysical Phenomena Monitors (SEP H.5.1)Meteorologqical (SEP H.5.1 )A meteorological monitoring program is in place at FNP. Instruments are mounted on a 60-meter tower located on the plant site. Parameters measured and transmitted to the control room include:* Windspeed (10 m and 45.7 in).* Wind direction (10 m and 45.7 in).* Vertical temperature difference (10 m and 60 in).* Ambient temperature (10 m and 60 in).* Dewpoint temperature (10 in).* Precipitation (base).The meteorological tower instrumentation feeds wind speed, wind direction, precipitation, dew point, delta temperature, and sigma theta data to the plant computer.
This data is used for dose calculations.
Computer terminals in the TSC and EOF can obtain real time or 15-minute average readouts of meteorological data. Should the plant's meteorological equipment become inoperable, information is available from the approved Flight Service, from the Georgia Pacific Paper Company, or from the regional National Weather Service offices.The important parameters for characterizing the transport of airborne radioactivity are wind speed, wind direction, and atmospheric stability (derived from the standard deviation of the horizontal wind direction or vertical temperature difference).
These meteorological parameters are used in a calculation methodology to assess the offsite radiological consequences of accidental releases of airborne radioactivity.
Hydrologqic (SEP H.5.1)The plant is equipped with hydrologic monitors to monitor river water level and service water pond level. These monitors have readout and annunciation in the control room. Redundant river water level monitors provide control room indication from 65 to 130 feet MSL river level. A discussion of service water pond level monitors is given in ESAR Section 9.2.1.5.Seismic (SEP H.5.1)Various types of seismic instrumentation are located throughout the site, a number of which have readout and/or annunciation in the control room. A complete discussion of these monitors is given in FSAR Section 3.7.4. Seismic information may also be obtained from the National Earthquake Center in Golden, Colorado.5.7 Protective Facilities and Equipment (SEP J)Assembly Areas (SEP J.4.1)In the event of a plant evacuation, the On-Site Assembly Areas (or Off-Site Assembly Areas, as appropriate) will be used. The function of the assembly area is to provide a E5-24 J Enclosure 5 to NL-15-1 392 Farley Standard Emergency Pian Annex center for personnel accountability and radiological contamination screening along with any other immediately necessary actions.The assembly areas are located in various buildings throughout the site. Alabama Power Company facilities may be used as the off-site assembly area at the discretion of the Emergency Director.
The off-site assembly area location will be announced over the public address system when the announcement of evacuation is made.Protective actions, including relocation of onsite personnel in the event of an attack or threat of hostile action against the site, have been developed for that specific situation.
Specific protective actions in this case are identified in site procedures not readily available to the public.5.8 Medical Support (SEP B.6, SEP L)5.8.1 Hospital and Medical Support (SEP B.6.3, L.1)Agreements are in place with the Southeast Alabama Medical Center, the University of Alabama in Birmingham (UAB) Hospital and Oak Ridge Institute for Science and Education to provide assistance for injured personnel, including cases involving radioactive contamination.
This assistance will be requested whenever necessary in accordance with plant procedures.
5.8.2 Ambulance Service (SEP B.6.2, L.4)Injured or externally contaminated personnel who require medical attention will normally be transported by ambulance to the cooperating hospitals.
Ambulance crews are trained to handle external contamination cases. Ambulance services are coordinated through the Houston County 911 center. Houston County maintains agreements with local fire and ambulance services that may respond to FNP.E5-25 Enclosure 5 to NL-1 5-1 392 Farley Standard Emergency Plan Annex Appendix A -Evacuation Time Estimate Study and Map Reference (SEP J.6)In order to ensure the safety of the public living in the vicinity of nuclear power plants in the nation, the U.S. Nuclear Regulatory Commission (NRC) requires licensees to develop and update evacuation times estimates (ETEs) for areas within the emergency planning zone (EPZ).Population reviews will be conducted annually using the most recent U.S. Census and local information.
Updates are required following the availability of data from the decennial census (10 years) or when the sensitivity factor for changes in population within the EPZ has been exceeded.
This appendix contains information from the ETE update performed in 2012. This update implements the requirements of the revised regulations relevant to ETE updates in accordance with the guidance provided in NUREG/CR-7002, Criteria for Development of Evacuation Time Estimate Studies.Southern Nuclear Operating Company (SNC) contracted IEM to estimate evacuation times for the 2012 populations within the 10-mile plume exposure pathway emergency planning zone (EPZ) surrounding the Joseph M. Farley Nuclear Plant (FNP). This appendix provides a summary of the final report describing the methods used to obtain population data, and to estimate evacuation times, population figures, evacuation road network information, and ETEs.The report provides a breakdown of the population by geographic areas and protective action zones (PAZ). Five categories of population are identified in the report:* Permanent residents.
- Transient population.
- Transit dependent permanent residents.
- Special facility residents.
- Schools The permanent resident population is made up of individuals residing in the 10-mile EPZ. The total year 2012 permanent resident populations within the 10-mile EPZ for FNP are estimated to be 7,188. The transient population consists of workers employed within the area, recreational sportsmen, and visitors.
The total transient population within the 10-mile EPZ is estimated to be 4,734, which includes 600 transient workers at FNP. The school populations identified in the FNP EPZ include six schools, which are a combination of both public and private. In these analyses, IEM contacted the schools within the EPZ area to collect current enrollment and staff figures. The total peak population for the schools in the 10-mile EPZ is estimated to be 3,225.Transit dependent permanent residents in the 10-mile EPZ are estimated to be 94. This study also considered the voluntary evacuees, who are also known as shadow evacuees and consist of 20% of the residents within 10 to 15 miles from FNP.IEM utilized a computer traffic simulation model, PTV Vision VISUM, to perform the ETE analyses.
For the analyses, the 10-mile plume exposure pathway EPZ was divided into 25 unique geographic areas based on two-mile, five-mile, and ten-mile radius rings, the 16 22.5-degree PAZs, as well as keyhole and staged evacuation logic. In order to represent the most realistic emergency scenarios, evacuations for the 25 geographic evacuation areas were modeled individually for the midweek daytime, midweek -weekend evening, and weekend daytime scenarios.
Each of these scenarios was then considered under both normal and adverse weather conditions using the 2012 population projections.
A total of 150 evacuation scenarios were considered as part of this study to represent different wind, temporal, and seasonal weather conditions.
Both 100% and 90% ETEs for each scenario were collected.
The 100% ETEs for 2012 normal weather conditions ranged from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 20 minutes. The 100% ETEs for 2012 E5-26 Enclosure 5 to NL-1 5-1 392 Farley Standard Emergency Plan Annex*adverse weather conditions ranged from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 5 minutes to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 25 minutes. The 90%ETEs for 2012 normal weather conditions ranged from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 15 minutes to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 50 minutes.The 90% ETEs for 2012 adverse weather conditions ranged from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 20 minutes to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 50 minutes. The factors that contributed to the variations in ETEs between scenarios include differences in the number of evacuating vehicles, the capacity of the evacuation routes used, the type of warning systems within the zones, or the distance from the origin zones to the EPZ boundary.Based on the data gathered and the results of the evacuation simulations, the existing evacuation strategy was determined to be functional for the 2012 conditions, given the lack of severe congestion or very high ETEs. Recommendations were provided for enhancements to improve the evacuation time estimate.Assumptions utilized in the ETE will be reviewed when evaluating changes to roadways or evacuation networks to ensure the results of the ETE remain valid. Changes in population will be evaluated utilizing the sensitivity factor developed during the ETE analysis.The full Evacuation Time Estimate was submitted for NRC review in accordance with NRC regulations 10 CFR 50, Appendix E, Section IV.3. Following the NRC review, the results of the study and recommendations were reviewed with applicable offsite agencies.
The review focused on the utilization of the results of the evacuation simulations provided in the ETE for comparison to existing protective action strategies.
Modifications were incorporated as part of the ongoing emergency planning process. (
Reference:
Evacuation Time Estimates Update dated November 26, 2013 NL-13-2340; ETE Report ETE-FNP-001; Annual ETE Review ETE-FNP-002).E5-27 Enclosure 5 to NL-15-1 392 Farley Standard Emergency Plan Annex Appendix B -Emergency Action Level (EAL) Scheme (SEP 0. 1)HOLD FOR EAL SCHEME E5-28 Enclosure 5 to NL-15-1 392 Farley Standard Emergency Plan Annex Appendix C -Supportingi Plans & Implementing Procedures (SEP P.3)Supportincq Plans* State of Alabama Radiological Emergency Response Plan* State of Georgia Radiological Emergency Plan* State of Florida Emergency Response Plan* Early County Georgia Emergency Response Plan* Houston County Alabama Emergency Response Plan* FNP Security Plan Administrative and Emergency Plan Implementingq Procedures (EPIP)Placeholder for future EPIPs to be developed Procedure
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