ML17272A347

Forwards Addl Info Re Emergency Planning Needed for Completion of First Round Review.Response Requested by 790507

ML17272A347
Person / Time
Site:	Columbia
Issue date:	03/05/1979
From:	Varga S Office of Nuclear Reactor Regulation
To:	Strand N WASHINGTON PUBLIC POWER SUPPLY SYSTEM
References
NUDOCS 7903270245
Download: ML17272A347 (12)

Text

Di ibu'tion NRC PDR R.

DeYoung V. Moore R. Vollmer M. Ernst R. Denise ELD IE (3)

Docket il 1979Ll R ¹4 File R.

Boyd'.

VassaTlo F. Williams

~I S.'arga D. Lynch M. Service R. Mattson D.

Ross y System J.

Knight R."Tedesco Docket No.:

50-397 bcc:

J.

Buchanan, NSIC T. Abernathy, TIC ACRS (16)

The attached set of round one questions represents the review effort of the Emergency Plans Section of the Accident Analysis Branch.

Please contact us ifyou require any, discussion or 'clarification of the enclosed requests.

Sincerely, ftr. Neil O. Strand Washington Public Power Suppl 300 George llashington Hay P. 0. Box 968 Richland, Washington 99352

SUBJECT:

FIRST ROUND QUESTIONS ON THE WNP-2 OL APPLICATION - AAB In our review of your application for,an operating license for the WNP-2 facility, we have identified z need for additional information which we require to complete our review, The,specific requests are contained in the enclosure to this letter atld are the fourth set of our round one questions; additional requests re1ated to other portions of the NNP-2 facility >Iill be sent during this month.

In order to maintain our present

schedule, we need a completely adequate response to all questions in the enclosure by ttay 7, 1979.

This, request for additional information is identical to the draft set forwarded. to you on February 12, 1979.

Enclosure:

Request for Additional Information C

cc:

See next page Steven A, Varga, Chief Light Water Reactors Branc> No. 4 Division of Project Management V9033po gag OIIRNAMEW bATS~

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Washington Public Power Supply System ccs:

Joseph B. Knotts, Jr.,

Esq.

Debevoise 8 Liberman 700 Shoreham Building 806 Fifteenth Street, N.

W.

Washington, D.

C.

20005 Richard g. (<uigley, Esq.

Washington Public Power Supply System 3000, George Washington Way P. 0.

Box 968 Richland, Washington 99352 Nepom 8: Rose Suite 101 Kellogg Building 1935 S.

E. Washington Yiilwaukie, Oregon 97222 Yis. Helen Vozenilek 7214 S.

E. 28th Street

Portland, Oregon 97202 Hs.

Susan Vi. Garrett 7325 S.

E. Steele Street

Portland, Oregon 94206 Nicholas Lewis, Chainiian Energy Facility Site Evaluation Council 820 East Fifth Avenue Olympia, Washington 98504 MAR 5

1979 Mr. 0.

K. Earle Licensing Engineer P.

0.

Box 968

Richland, Washington 99352

l'

ENCLOSURE REQUEST FOR ADDITIONAL"INFORMATION NPPSS

.NUCLEAR PLANT NO.

2 DOCKET NO.

50-397

I l

310. 0 ACCIDENT ANALYSIS BRANCH MAR 5 lggg 432. 0 Emer enc Plannin 432. 01 (3.O)~

Your proposed emergency classification/notification/immediate action

scheme, presented in Appendix I and II of the WNP-2 Emergency

Plans, is not clearly compatible with that of the State of Washington and those of local agencies.

Whereas you have established three classes for which offsite notificatio'n and/or support would be advisable or necessary, the State has six such classes.

~ Additionally, the affected counties have a

priority scheme which your plan does not recognize.

Furthermore, the Benton/Franklin County plan explicitly states that WPPSS will provide specific recommendations for protective action in the 'event of an emergency and this statement is not acknowledged in your plans.

Accordingly, show how your Emergency Plans are coordinated with the various emergency plans of the state and local agencies.

Provide this information in a tabular format using the following column headings:

(1) postulated accident(s);

(2) probable detection means; (3) emergency classification(s);

(4) notification(s) required by WPPSS and expected by the State and the affected counties; and (5) immediate actions planned.

Your response in the suggested format will conform to the guidance contained in Section 4.2 of the Guide~" as well as most parts of Sections 4-.1 and 6.2 of the Guide.

In this regard, we note that the consequences of your Maximum Hypothetical Accident Case (MHA), as described in Table 3.3-1 and Figures 5.4 and 5.5 of your, Emergency

Plans, could fall into either the Site Accident or the General Accident-Minor class of the State plan for areas beyond your designated "zero population zone."

(Refer to page G-8-18 of your proposed Emergency Plans.)

Remove this ambiguity.

432. 02 (3.2-.4)

Identify the value of the potential doses at the site boundary, as used in Section 3.2.4.2 of your proposed Emergency Plans, from which you derive emergency action levels for the declaration of a Site Emergency.

These dose values should be compatible with the qua'litative descriptions of this class of emergency.

in the State and local plans rather than with your technical specifications.

Our concern is that a violation of your.

technical specifications would not necessarily be sufficient for your declaration of a State or local Site Emergency class.

Accordingly, provide examples of the emergency action levels derived from the dose criteria which are related either to evidence of damage to irradiated fuel (either in the core or The section numbers in this set of, questions refers to your Emergency

Plans, unless otherwise noted.

The term "Guide" used in these questions refers to Annex A to Regulatory Guide l. 101, Revision 1, "Emergency Planning for Nuclear Power Plants,"

March 1977.

432-1,

lP,AR 5

1979 in the spent, fuel pool) or to an indication of the clear potential for damage.

432.03 (3.2.5)

You state in the second paragraph of Section 3.2.5.2 of your proposed Emergency Plans that, protective action criteria for long-term hazards are based on action levels determined by the State.

However, we find only one action level in the State Plan presented in Appendix II; i.e.,

the only action level

,. designated by the State is for the release of radioactivity into water.

We note that only Protective Action Guides (PAG's) are specified in the State and local plans.

Your proposed Emergency Plans should include emergency action levels at which you would recommend protective actions for milk, water, soil and vegetation pathways.

For the milk pathway in particular, specify the dose rate (one meter above pasture forage) at which you would recommend that grazing dairy herds be placed on stored feed, assuming that a serious release from the site has actually occurred.

432. 04 (3.2.4)

Your proposed Emergency Plans include provisions for evacuating the construction workers at the WNP-184 site.

However, some items'ere not addressed in your proposed evacuation plan for these workers.

Accordingly, revise your proposed Emergency Plans to include the following items:

a ~

b.

The emergency action levels at which the construction workers at the WNP-184 site will be evacuated.

While these action levels should be set conservatively, it is important that they not be established in a manner which would result in a high rate of false alarms.

The provision of visual indicators of wind direction at the WNP-184 construction site (e.g., flags and windsocks).

Workers should be instructed to avoid evacuation routes in the downwind direction, especially while.on foot.

C.

Testing should be implemented to provide assurance that an evacuation signal at the WNP-2 site can be observed by the construction workers at the WNP-184 site.

This testing program should be announced and planned while the construction workers are on the job site.

d.

Inasmuch as there is a potential for the release of significant radioactivity at the Fast Flux Test Facility (FFTF) which would warrant the evacuation of the construc-tion workers at the WNP-184 site, you'hould-establish notification criteria (i.e.,

emergency action levels) that are mutually agreeable to WPPSS and the management of the FFTF.

These criteria should be based on observed

.parameters in the control room of the

FFTF, as well as on the environmental measurements now proposed.

Provide a

summary of these mutually agreeable notification criteria in your proposed Emergency Plans.

'432"2

~4

MAR 5

e.

An annual site evacuation drill during peak const'ruction years which we define as those years when there will be more than 500 construction workers on site.

432. 05 (5.2.5) 432. 06 432. 07 (App.III)

Describe the conservative assumptions you mention in the first paragraph of Section 5.2.5. l.

(Your response to Item 432.2 may be sufficient to satisfy this item.)

You state in Table 2.2-2 of the FSAR that visual approaches by aircraft pass directly over the WNP-2 facility.

Provide your proposed plans for appropriate notifications to those respo'ns-ible for'ir traffic control in the vicinity of the WNP-2 facility in the event of a General Emergency (ice., for a severe event involving an atmospheric release).

Inclusion of these notifications in the State or local war ning "fan-'out" system would satisfy us.

In Section 3.a. (1)(c)l, "Sheriff's Dispatcher," of Tab A to Appendix 8 to Annex G (Refer to Page G-8-A-3 of the Benton/

Franklin Counties Nuclear Incident Response Plan),

you state that the dispatcher must await the sheriff's instructions on further warning actions.

Obtain a clarification of this statement from the Sheriff's Office to show that there would be an authority immediately available (i.e.,

a line of succession) in the event of a General Emergency which, by definition, would warrant initiation of protective actions offsite.

432.08 (5.i.4)

In Section 5.1.4 of your proposed Emergency P,lans, you state that you would notify the Sheriff if a Site Emergency were to escalate into a General Emergency.

.However, it is stated in Appendix II to your proposed Emergency Plans that the Sheriff also expects notification in the event of a Site Emergency.

Revise your notification plans to conform to the Sheriff's expectations.

TheSheriff should also be notified in the event that a site evacuation is necessary to areas outside the Hanford reservation.

432. 09 (5.i. 1)

In Table 5.1.1 of your proposed Emergency

Plans, there are three columns which have the same-heading; ice.,

"Necessity for Corrective Actions."

Revise these headings to remove this ambiguity.

432. 10 (7. 1. 2)

Provide a commitment to conduct an announced emergency drill involving State and local agencies and local supp'ort services, prior to loading fuel into the WNP-2 facility; Additionally,

, revise the last sentence in the fourth paragraph of Section

7. l. 2 of your proposed Emergency Plans to read "... will be tested to demonstrate that the capability for early warning of the public, is maintained."

432-3

h 432. 11 (App. IX) liQR 5

]g79 In Section IV.B of Appendix IX of your proposed Emergency

Plans, you describe the duties of your Information Officer.

Revise your proposed Emergency Plans to make provisions for the participation of your Information Officer in coordinated drills with State and local agencies.'rovide a line of succession of authority from the Managing Director for the purpose of providing news releases which are coordinated with State and.local agencies, to the public in the event of an emergency.

432. 12 (7. 1. 1)

Describe the steps you will take to provide information to plant visitors and to construction workers regarding the noti-.

fication procedures of your Emergency Plans.

Indicate

how, they can expect to be advised on what to do in the event of an emergency.

432. 13 (7. 1. 1)

Revise your proposed Emergency Plans to include a desc'ription of the specialized initial tr aining and the periodic retraining programs to be provided for each of the categories'f emergency personnel listed in Section

8. 1. 1 of the Guide.

References to applicable sections of your FSAR are acceptable if the training is adequately summarized and the average frequencies for training are stated.

432. 14 (S.i.S)

Your criterion in Section

5. 1.5 (Page 5-8) of your proposed Emergency Plans for declaring a water pathway General Emergency, is within the requirement specified in 10 CFR Part 20.

We do not understand why this condition would be considered an emergency if it is within the dose limits specified in 10 CFR Part 20 and it is not clear to us that this particular criterion has been accepted by cognizant offsite agencies.

(Refer to page G-8-19).

Further, since the Maximum Permissible Concen-tration (MPC) of tritium is much larger than those for most other radionuclides, con'sider excluding tritium from the value of 18 curies derived in Section

5. 1.5 of your proposed Emergency Plans.

Provide the results of your reevaluation of these two matters.

432. 15 (5. 2. 1)

In Section 5.2.

1 of your proposed Emergency

Plans, you state that you will provide for continuous monitoring and recording of particulates, halogens and gases inside the primary contain-ment.

Describe this monitoring system with particular emphasis on its ability to identify each type of material and discriminate against the other two types.

Indicate the detection sensitivity and the saturation point(s) of this monitoring system.

432. 16 Discuss the impact that a severe dust storm could have on your proposed protective actions.

In responding to this question, cross-reference your response to Item 372.8 contained in our letter of December 8, 1978.

432-4

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