ML17209A806
| ML17209A806 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 03/09/1981 |
| From: | Clark R Office of Nuclear Reactor Regulation |
| To: | Robert E. Uhrig FLORIDA POWER & LIGHT CO. |
| References | |
| NUDOCS 8103160563 | |
| Download: ML17209A806 (25) | |
Text
e-g~~ 09 1981 DISTR IB ON".
ocket File ACRS (16)
NRC POR JHeltemes L PDR Gr ay Fi le NSIC FPagano TERA DP ORB83 Rdg DEisenhut RPurple TNovak RTedesco GLainas OELD I8IE (3)
RClark
Dear Dr. Uhrig:
CNelson PKreutzer (3) lie have completed our review of the St. Lucie Emergency Plan dated January, 1981.
Your Plan was reviewed against the criteria stated in Revision 1 to HUREG>>0654, "Criteria for Preparation and Evaluation of Radiological Emergency Plans and Preparedness in Support of Nuclear Power Plants" November 1980.
This document addresses the standards set forth in the revised emergency planning regulations of 10 CFR 50 and Appendix E thereto which became effective November 3, 1980.
Docket No..50-335 Dr. Robert E. Uhrig Vice President Advanced Systems 5 Technology Florida Power 5 Light Company P.. 0. Box 529100 Miami,.Florida 33152 Sincerely, Our review has indicated that additional information and commitments are required before we can conclude that your onsite emergency preparedness program meets these criteria.
Enclosed are our corments for which resolution is necessary.
These comments superrede the review comments sent to you on December 18,
- 1980, and will be considered the first round of comments on the upgraded emergency plan.
Your:'mergency Plan should be revised to address these comments in accordance with the provisions of the revised 10 CFR 50.
~
=. You are requested to provide your response within 45 days of receipt of
...is letter;noting changes made in response to our comments; j
As stated in paragraph 50.54(s)(3) of the new rule, the NRC will base its findings on a review of the FEIN findings and determinations as to whether State and local emergency plans are adequate and capable of being implemented, and on the NRC assessment as to whether the licensee's emergency plans are adequate and capable of being implemented.
In addition, an emergency response exercise with State and local government agencies designed to test the integrated capability of the emergency preparedness plans must be conducted
's required by the new rule.
8 208 1605t'
Enclosure:
Comments on St. Lucie Unit Emergency Plan Qr(P];,~I s;,-d b 80Uett Q. Ql;,rp Robert A4 Clal'k, Chief Operating Reaci<<rs'2Branch d3 Division of Licensing OFFICE/
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March 9, 1981 0
Docket No. 5u-3~5 Dr. Robert E. Uhrig Nice President Advanced Systems 5 Technology Florida Power 5 Light Company
,P. 0.
Box 529100 Miami, Florida 33152
Dear Dr. Uhrig:
He have completed our review of the St. Lucie Emergency Plan dated January 2,
198l.
Your Plan was reviewed against the criteria stated in Revision 1 to NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Plans and Preparedness in Support of Nuclear Power Plants" November 1980.
This document addresses the standards set forth in the revised emergency planning regulations of 10 CFR 50 and Appendix E thereto which became effective November 3, 1980.
Our review has indicated that additional information and commitments are required before we can conclude that your onsite emergency preparedness program meets these criteria.
Enclosed are our comments for which resolution is necessary.
These comments supersede the review comments sent to you on December 18,
- 1880, ana will be considered the first round of comments on the upgraded emergency plan.
Your Emergency Plan shou)d be revised to address these comments in accordance with the provisions of the revised 10 CFR 50.
You are requested to provide your response within 45 days of receipt of this letter, noting changes made in response to our comments.
As stated in paragraph 50.54(s)(3) of the new rule, the NRC will base its findings on a review of the FEMA findings and determinations as to whether State and loca'I emergency plans are adequate and capable of being implemented, and on the NRC assessment as to whether the licensee's emergency plans are adequate and capable of being implemented.
In addition, an emergency response exercise with State and local government agencies designed to test the integrated capability of the emergency preparedness plans must be conducted as required by the new ruie.
Sincerely, nperatsng Reactors Brancn
=-'3
~ Division of Licensing
Enclosure:
Comments on at. Lucie Unit Emergency Plan cc:
See next page
Florida Power 8 Light Company CC:
Robert Lowenstein, Esquire Lowenstein,
- Newman, Reis 5 Alexrad 1025 Connecticut
- Avenue, N.W.
Washington, D.
C.
20036 Norman A. Coll, Esquire McCarthy, Steel, Hector 8 Davis 14th Floor, First National Bank Building Miami Florida 33131 Indian River Junior College Library 3209 Virginia Avenue Fort Pierce, Florida 33450 Admi ni strator Department of Environmental Regulation Power Plant Siting Section State of F 1 ori da 2600 Blair Stone Road Tallahassee, Florida 32301 Mr. Weldon B. Lewis County Admi ni strator St.
Luci e C ounty 2300 Virginia Avenue, Room 104 Fort Pierce, Florida 33450 Director, Criteria and Standards Division Office of Radiation Programs (ANR-460)
U.S. Environmental Protection Agency Washington, D.
C.
20460 U.S. Environmental Protection Agency Region IV Office ATTN:
E I S COORDINATOR 345 Courtland Street, N-E.
Atlanta, Georgia 30308 Mr. Charles B. Brinkman Manager - Washington Nuclear Operations C-E Power Systems Combustion Engineering, Inc.
4853 Cordell Avenue, Suite A-1
- Bethesda, Maryland 20014 Mr. Jack Schreve Office of the Public Counsel Room 4, Holland Building Ta1 1 ahassee, Flori da 32304 Resident Inspector/St.
Lucie Nuclear Power Station c/o U.S.N.R.C.
P. 0.
Box 400 Jensen Beach, Flori da 33457 Bureau of Intergovernmental Relations 660 Apalachee Parkway Tallahassee, Florida 32304
EMERGENCY PLAN REVIE!;l ST.
LUCIE UNIT 1 FLORIDA POWER AND LIGHT COhPANY The following corr;ients apply to St. Lucie Unit 1 Emergency Plan (Plan) and ideptify, in parenthesis, the applicable evaluation criteria of NUREG-0654, Rev.
1.
A.
Assi nment of Responsibility (Or anizational Control) o The Plan does not describe the local organizations within the Emergency Planning Zones (EPZ), (A.l.a) o The Plan does not'ave a block diagram which illustrates all the Federal and local organizations that are part of the overall response organization for the EPZ.
(A.l.c) o The Plan does not have written agreements for all suppor organizations having an emergency response role within the Emergency Planning Zones.
(A.3.)
o There is no discussion in the Plan of the capability to provide 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> support of the augmented emergency organizations for an extended period; nor the individual responsible for continuity of resources.
(A.4.)
8.
Onsite Emercency Or anization o
The responsibility of the Emergency Coordinator to provide protective action recommendations to offsite authorities should be covered explicitly in the Plan in the listing of responsibilities of this position and also in the listing of responsibilities that cannot be
. delegated.
(8.2 and 8.4) o Ther'e are no conditions given in the Plan for higher level utility officials assuming the function of Emergency Coordinator.
(8.3) o The specific emergency assignments for the plant staff members should be described covering the emergency functions and tasks described in Table 8-1 of the criteria.
The minimum capabilities and staffing onshift and available within 30 minutes and 60 minutes following declaration of an emergency must also be described.
(8.5 and Table 8-1) o The Plan does not illustrate, in a block diagram, the interfaces between and among the onsite functional-areas of emergency activities and offsite support, including the onsite Technical Support Center (TSC), the nearsite Emergency Operations Facility (EOF), the Operations Support Center (OSC),
and any other emergency centers.
(8 6) o There is no discussion of logistic support for emergency personnel in the Plan.
(8.7.a)
o The Plan does not specify ambulance transportation support.
(B.9) o The Plan does not include copies of agreement le'.ers for services to be provided by all support agencies.
The agreements shall delineate the authorities, responsibilities, and limits on the action of the contractor, private organization, and local services support group.
The Plan contains letters of agreement which appear to be out-of-date and/or no longer valid (USNRC-Appendix G, Shands Teaching Hospital; Appendix H, Radiology Associates
- Appendix I).
These letters should be updated or removed from the Plan.
Appendix C of the Plan is Florida Highway Patrol Order No. 25.
An agreement letter should be established with the Florida Highway Patrol in accordance with Criterion B.9 of NUREG-0654, Rev.
1, and if desired, Order No.
25 may be appended to the agreement letter.
(B.9)
C.
- -meraency
Response
Suo ort and Resources o
Although the Plan designates the person who is authorized to request RAP assistance, it is not made clear where the Rk? team would be expected to report or with whom they would maintain contact.
Section 4.2.2 of the Plan should be changed with respect to "onsite" assistance from DOE.
The Federal Emergency Management Agency (FEMA),
in the proposed Master Plan (See Federal
- Register, Vol. 45, No. 248, December 23, 1980),
has designated DOE as having responsibility to coordinate all off-site radiological monitoring, assessment, evalua-tion, and reporting activities of all Federal agencies during the initial phases of an accident.
(C. 1) ihe Plan does not provide for the dispatch of a representative
,rom the
licensee tp the principal of. site EOC.
(C.2.
)
o The Plan does not describe th g'eneral capabilities, expected availability, and analyses services of alternate radic, ',
I facilities.
(C.3) o The Plan does not include letters of agreement for the outside support organizations identified in the Plan, pages 2-6, 2-31 and
'-38.
(C.4)
D.
Emer enc Classification S stem o
The emergency action level (EAL) scheme as set forth in Appendix 1
to NUREG-0654 is not established in the Plan.
The initiating conditions shall include the example conditions, as applicable, found in Appen-dix 1, and all postulated accidents in the Final Safety Analysis Report (FSAR).
Section la4 of the Plan, page 1-8, which states "The Unusual Event class is not an emergency,"
must be changed in order to comply with Appendix 1 to NUREG-0654 and the reporting require-ments of 10 CFR 50.72, and in order to be consistent with the
'otification actions described in Sections
- 2. 1.4 and 4.4. 1 of.he Plan.
As it currently stands, the Plan commits to notifying the NRC within one hour after identifying the existence of an
~amer enc condition, which does not include the Unusual Event class.
(D.l, 2) o The references to Technical Specifications in the Emergency Action Level Classification
- scheme, Table 3-2 of the Plan, should be converted to direct instrument readings, and the appropriate Technical Specifications included.
(D. 1)
o
=xample PHR sequences 5.a through e and I on pages 1-18 and 1-19 o-.
<<."p n ix 1 to NUREG-0654, Rev.
1 should be explicitly treated in t."..
Plan.
The Plan should state clearly whether the FSAR accidents are in Table 3-2.
(D-2)
E.
Ho.ification Hethods and Procedures o
There is no discussion in the Plan of the means for verification o,
- messages, other than the Florida Bureau of Disaster Preparedness procedure to authenticate emergency messages from Turkey Point Plant.
(E.l) o The Plan does not include in the content of initial messages, information regarding potentially affected population and areas, and whether protective measures may be necessary.
(E.3) o The Plan does not describe the provisions for followup messages from the facility to o fsite authorities which con ain information including projected integrated dose at the prcjected peak and at 2, 5, and 10 miles; recommended emergency actions, including protective measures; request for any needed onsite support by offsite support organizations; and prognosis for worsening or termination of even..
(E.4.i, l, m, n) o The Plan fails to acknowledge the requirement that notification of offsite authorities and the population of the plume exposure pathway EPZ is subject to a 15 minute time constraint.
There is, moreover,
no documentation of specific prior arrange."..ents that have been made to use public communications media (e.c.,
radio stat'ions) for issuing emergency instructions to the public.
(E.6) o The Plan does not indicate that an Early Naming System meeting the design objectives of Appendix 3 of the cri eria has been developed.
The Plan should address the administrative and physical
- means, and the time required to promptly notify the public of an emergency.
The Plan should comnit to the establishment of such a system and indicate when the system will be implemented.
(E.6) o The Plan does not address written messages intended for the public,
~
consistent with the licensee's classification scheme.
(E.7)
F.
Emergency Communications o
The Plan does not specifically state that provision for 24-hour per day notification and activation of the State/local emergency response network including 24-hour per day manning of "communication links" (that initiate emergency response actions) are established for the "Unusual Event" and "Alert" categories.
(F.l.a) o The Plan does not contain provisions for communications between the various EOC's and the radiological monitoring teams.
(F.l.d) o The communications plan does not include organizational titles and alternates for both ends of the communication links.
(F.1)
c There are no provisions in the Plan for a coordinated co...~unication 1 ink for fixed and mobile medical support facilities.
(r".2)
G.
Public Information o
The plan does not provide for annual dissemination of information to
'he public regarding how they will be notified and what their actions should be in an emergency.
(G.l)
This information should include, but not necessarily be limited to:
a.
educational information on radiation; b.
contact for additional information; c.
protective measures, e.g.,
evacuation routes and relocation
- centers, sheltering, respiratory protection, radioprotective drugs; and d.
special'eeds of the handicapped.
o The Plan does not provide for a public information program which provides the permanent and transient adult population within the plume exposure pathway EPZ an adequate opportunity to become aware of the information annually.
(G.2) o The Plan does describe the arrangements for timely exchange of C
information among designated'spokespersons.
(G.4.b)
o The Plan does not address coordinated arrangements or dealing with rumors.
(G.4.c)
H.
Emerqenc Facilities'nd E uipment o
The Plan does not address the functional criteria of NUREG-0696 for the onsite TSC, the nearsite EOF, the Nuclear Data Link and the Safety Parameter Display System.
(H. 1) o There is no discussion in the Plan of the time required to staff the centers.
Criterion 4, page 52 of NUREG-0654, Rev.
1, requires timely staffing.
o There is no discussion in the Plan of hydrologic or seismic monitors onsite and offsite, that are to be used to initiate emergency measures in accordance with Appendix 1 to NUREG-0654, Rev.
1.
The plan should describe the NOAA seismic equipment referred to in Table 3-2, page 3-14.
(H.5.a, H.6).
o There is no discussion in the Plan of wound portable monitors.
The Plan does not describe the provisions for offsite radiological monitoring equipment in the vicinity of the nuclear facility.
(H.7) o The Plan does not meet the meteorological program of Appendix 2 of NUREG-0654, Rev.
1.
(H.S)
o The Plan does not provide for an onsite OSC which shall have supplies, including respiratory protection, ""ot ctive clothin~, portable lighting, etc., for personnel present in the assembly area.
(H.9) o There is no discussion in the Plan of inspecting, inventorying and operationally checking emergency equipment/instruments at least once each calendar quarter and after each use.
(H.10) o The Plan does not include, in an appendix, identification of emergency kits by general category (protective equipment, communications equipment, radiological monitoring equipment and emergency supplies).
(H.11) o The Plan does not discuss a central point for the receipt of analysis of all field monitoring data and coorcination of sample media.
(H. 12)
I.
Accident Assessment o
Section
- 5. 1.1 of the Plan does not adequately describe the onsite capability and resources to provide initial values and continuing assessment throughout the course of an accident, including post accident sampling capability, radiation and effluent monitoring
- systems, in-plant iodine instrumentation and containment radiation monitoring in accordance with NUREG-0578 and.t<URfG-0737.
The Plan should provide a table of the monitoring systems, describing location of detectors, type of detectors, range of measurement, alarm set-points, etc.
( 1.2)
The Plan does not address the m -;hods and techniques (procedures) io be used for determining
.the source term of pot ntia] ;;1 ases of radioactivity material from additional potential release points such as steam generation blowdown, rad waste vent, laundry facility vent and auxiliary steam-driven boiler feed pump exhaust, as applicable.
(I.3.a) o, The Plan does not specify the capability of acquiring and evaluating meteorological information sufficient to meet the criteria of Appendix 2 to NUREG-0654, Rev.
1.
There shall be provisions for access to meteorological information by at least the nearsite
(I.5) o The Plan has not established the me hodology for determining the release rate/projected doses if the instrumentation used for assessment are offscale or inoperable.
( I.6) o The Plan does not describe th capability and resources for field monitoring within the plume exposure pathway EPZ.
( I.7) o The Plan does not describe the methods, equipment and expertise to make rapid assessments of the actual or potential magnitude and locations of any radiological hazards through liquid or gaseous release
- pathways, including activation, notification means, field team compositions, transportation, communications, monitoring equipment and estimated deployment times.
(I.S) 10
o The Plan does not describe the carabil i:y to detect and measure radioiodine concenirations in air in the plume exposure pathway EPZ as low as 10 " microcuries per cubic centimeter und r field conditions.
(I.g) o The Plan does not describe the means for estimating integrated dose from the projected and actual dose rates and for comparing these estimates with the protective action guides.
(I.10)
J.
Protective
Response
o The Plan does not discuss evacuation routes and transportation for individuals onsite including alternatives for inclement weather, high densi ty traffic and specific radiological conditions.
The Plan does not include maps showing evacuation
- routes, evacuation
- areas, pre-selected radiological monitoring points, relocation centers and shelter areas.
(J.2 and J.10.a) o The Plan does not describe the provisions for radiological monitoring of people evacuated from the site, nor is the decontamination capa-bility at the assembly area for evacuated personnel described in the Plan.
(J.3 and J.4) o There is no commitment in the Plan for the gime required to account for missing individuals (within 30 minutes of the start of an emergency),
and for accountability of all onsite individuals continuously thereafter.
(J.5) 11
o There is no explicit discussion in the Plan of providing individuals l emaining or arriving onsito during an emergency, individual respira-tory protection, protective clothing and use of radioprotective drugs.
(J.6) o The Plan does not contain the time estimates for evacuation within
~I
'the.plume exposure pathway EP2, in accordance with Appendix 4 to NUREG-0654.
(J.S) o The Plan does not contain maps showing population distribution around the nuclear facility, nor does the Plan describe the means of notifying all segments of the transient and resident population.
(J.10.b and c) o The Plan does not discuss tne means for protecting those persons whose mobility may be impaired due to such factors such as institutional or other confinement.
(J.10.d) o The Plan does not describe the bases for the choice of recommended actions from the plume exposure pathway during emergency conditions.
(J.10, m)
Radi ol o ica 1 Exposure Control o
The Plan does not describe onsite exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activities Protective Action 12
Guides (EPA 520/1-75/001) for providing ambulance service and medical treatment services.
(K.l.f and g) o The Plan does not specify that procedures shall be established, in
- advance, for permitting onsite volunteers to receive radiation exposures in the course of carrying out lifesaving and other emergency activities.
(K.2) o The 'Plan does not provide for assurance that dosimeters are read at appropriate frequencies.
(K.3.b) o The Plan does not specify action levels for determining the need for decontamination of personnel who have become contaminated in the course of an emergency.
(K.5.a) o The Plan does not describe the means for waste disposal during an emergency.
(K.5.b) o The Plan has not clearly established provisions for onsite contamination control measures for drinking water and food supplies, and criteria for permitting return of areas and items to normal use during an emergency condition.
(K.6.b and c) o The Plan does not describe the capability for decontaminating reloacted onsite personnel, including provisions for extra clothing and decontaminants suitable for the type of contamination
- expected, with 13
particular attention given to radioiodine contamination of the skin.
(~;.7)
L.
Medical and Public Health Support o
The Plan does not identify the primary offsite support group for transporting victims of radiological accidents to medical support facilities.
(L.4)
Yi.
Recovery and Reentr Plannin and Postaccident Operations o
There is no discussion in the Plan of the key positions in the
~
facility recovery plan other than the Emergency Control Officer.
(>i.2) o There is no discussion in the Plan of population exposure estimates.
(r,.4)
I; ~
=xercises and Drills o
The Plan does not include varying scenarios from year to year so that all the major elements of the Plan are tested within a five-year period.
(N. l.b) o The Plan does not specify that communications with Federal response organizations and States within the ingestion exposure pathway EPZ shall be tested quarterly.
(N.2.a)
o There is no discussion of cotn~unications, between the nuclear facility, State and local
=OC's and the field asses
.-.,"nt te=--..s, being tested annually.
(t'.2.a) o There is no discussion in the Plan of radiological monitoring drills which involve collection and analysis of offsite vegetation and soil.
(N.2.d) o There is no discussion in the Plan of Health Physics drills involving analysis of inplant liquid samples with actual elevated radiation levels, including the use of the post-accident sampling system.
(N.2.e(2))
o The Plan does not describe scenarios which will include the stimulated events; a time schedule of real and simulated initiating events; a
narrative summary describing the conduct of the exercises; and a
description of the arrangements for and advance materials to be provided to official observers.
(N.3.c, d, e and f) o The Plan does not address the assigning of responsibility for implementing corrective actions for those needed improvements identified during the exercise critique.
(N.s) as
0.
Radiolo ical Emergency
Response
Trainino o
Except for offsite utility personnel, the Plan does not describe th training to be provided for those offsite emergency organizations who may be called upon to provide assistance in the event of an emergency.
(O.l.a) o The Plan does not include on-the-spot correction o
erroneous performance during drills as part of the overall training program.
o The Plan does not describe the program for training a~d retraining of personnel in the following categories:
a.
Police and fire fighting, personnel; b.
Local support services personnel including Civil Defense/Emergency C.
d.
e.
Service personnel; Yiedical support personnel; Licensee's headquarters support personnel (the Plan addresses only the Emergency Control Officer, the Emergency Information Officer, and the Emergency Technical Officer); and Personnel responsibile for transmission of emergency information and instructions.
(0.4.d, g, h, i and j) o The Plan does not specify annual retraining for offsite FPL and non-licensee personnel with emergency response responsibilities.
P.
Pes onsibility for the Planninq '.'ort:
Development, Periodic. Review and Distribution of Emer enc Pla>>;
o The Plan does not provide for training of individuals responsible for the planning effort.
(P. 1) o The Plan does not specify that the plan and agreements will be updated as needed, reviewed and certified current on an annual basis.
(P.4) o Revised pages of the Plan, dated 1/2/81, are not marked according to Criterion P.5.
o The Plan does not contain a detailed listing of supporting plans and their source.
(P.6) o The Plan appendices do not contain a list of the Emergency Plan Implementing Procedures.
The listing shall include the section(s) of the Plan to be implemented by, each procedure.
(P.7) o The Plan does not contain a specific table of contents which is cross-referenced to the criteria contained in NUREG-0654, Rev. l.
(P.8)-
o The Plan does not provide for an independent review of the emergency preparedness program at least every 12 months.
(P.9)
o The Plan does not provide fo1 updating telephone.
numbers in emelgency procedures at least quarterly.
(P. 10)
Yiiscellaneous Comments 1.
On page iii of Plan, change Title of Appendix G to "f~iscellaneous Letters 2.
Appendix I, on page iii, is listed twice.
3.
Appendix J is missing in the Plan.
Are there any inhabited islands without ground transportation within the 10-mile EPZ?
Provide the documentation justifying the exclusion of the area of extended waterway east o
the plant from being part of the plume exoosure pathway EPZ.
(Peference Fia.
1-1 o
the Plan).
in first paragraph at top oi page 2-9, chanae reference of Appendix G -;o Appendix H.
6.
Table 2-1 of the Plan lists the line of succession for the Emergency
'oordinator.
Paragraph C)
- 1) on page 2-24 describes other individuals who may succeed to the position of :mergency Coordinator.
The Plan needs clarification.
7.
In paragraph 2.3.1, page 2-30 of the Plan, change reference of Appendix E
to Appendix F ~
8.
Figure 2-6, page 2-32 of the Plan does not show the location of the Operations Support Center.
9.
On page 2-33 of the Plan, change Region I to Region II.
10.
On page 2-38 of the P'lan, change (EllC) to ~OSC 11.
On page 2-38 of the Plan, clarify the distance from the plant site to the alternate ENC at" the Jensen Beach Holiday Inn.
12.
Revise paragraph 3.1, Unusual
- Event, on page 3-1 of the Plan.
See reviewer's coranent pertaining to criterion D. 1, 2 of NUREG-0654, Rev.
1.
'3.
Figure 4-1, St. Lucie Plant Initial Notification Flow, does not include notification of Unusual Event to offsite agencies.
14.
The role of the US Coast Guard in providing "on-site rescue assistance,"
described in paragraph 4.4.3 of the Plan, needs clarified.
The agreement letter with the U.S. Coast Guard, dated February 19, 1980, indicates a
normal response time of 30-45 minutes from their Ft. Pierce Station.
15.
~ The Radio Paging System "beepers" are described on page 4-11 of the Plan for Dade,
- Broward, Palm Beach and Sarasota Counties.
Are beepers also available for St; Lucie and Martin Counties?
Ifpo, this should be described in the Plan.
I 19
16.
Provide the impleme~tation schedule or the remote lab facility referred to on page 5-3 o the Plan.
17.
The second paragraph of Section 5.2. 1, on page 5-9 of the Plan, states I
that control room personnel are in an isolated environment and need protec-tive equipment only if they leave the control room. If there is a fire
'or smoke in the control room, or if the control room envelope became contaminated with airborne radioactivity, control room personnel may have to don respiratory protective equipment in order to remain in the control room to handle the emergency.
This should be clarified.
18.
Section
- 7. 1.4.1 of the Plan specifies, in part, that a major radiological emergency
- response, held every 12 months, will be conducted as a Site
'rea Emergency or General Emergency and will provide for the coordination with and participation of off-site emergency response organizations including federal, state and local governments.
The Site Area type of emergency exercise does not lend itself to full participation of local and State organizations, and as such should not be considered for the major exercises.
The exercise would normally be expected to be initiated as an Unusual Event or Alert type, and then escalated to a General type.
Appendix E to 10 CFR 50, Para IV.F. requires a full-scale exercise which
'ests as much of the licensee, State and local emergency plans as is reasonably achievable without mandatory public participation be conducted.
The General Emergency is the only type exercise that would fulfillthis requirement and the Plan should be changed accordingly.
20
'9.
The reference to appendix I on page 7-13 of ihe Plan should be changec io Appendix J.
20.
All of the agreement letters predate the effective date of the new rule on emergency preparedness, and, with the exception of the U.S.
Cpast Guard (2/19/80), are between 2-1/2 and 5 years old and should be updated, unless the agreement contains a statement of longev=ty similar to thai contained in Appendix B, Agreement between Florida Power and Light Company and Department of Health and Rehabilitative Services.
21