ML17272A445

Responses by Util to Round One,Set Four Questions from Accident Analysis Branch (Emergency Planning) Re OL Application

ML17272A445
Person / Time
Site:	Columbia
Issue date:	05/04/1979
From:	WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:
Shared Package
ML17272A444	List: ML17272A442 ML17272A445
References
GO2-79-88, QU-790504, NUDOCS 7905110237
Download: ML17272A445 (73)

Text

COMMENT 432.01 Your proposed emergency classification/notification/

(3 0)* 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 notification 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 expli-citly states that WPPSS will provide specific recom-mendations 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 con-tained 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 Si,te Accident or the General Accident-Minor class of the State plan for areas beyond your designated "zero population zone." (Refer to page 6-8-18 of your proposed Emergency Plans.) Remove this ambiguity.

RESPONSE

The proposed emergency classification/notification/immediate action schemes presented in Appendix I and II are identical to the State of Washington and local agency plans. Appendix I is the Washington State Plan and Appendix II is the Benton/Franklin County Plan. Both plans use the same emergency classifications as.

the Hanford Site Plan with the exception of dividing the General Emergency class into major and minor. Although both state and county plans distinguish between an airborne release and a water dispersion release, the emergency classes are compatible.

At present, the State of Washington and Benton/Franklin County are".f '

reviewing their plans. The Supply System has discussed with the state and the county the desire to revise the section concerning Protective Action Guides to conform more closely to the EPA Pro-tective Action Guides. The values proposed by the Supply System are given ir Table 432.01-1. If these values are accepted by the state and county, they will be incorporated into the Hanford Site Emergency Plan. Meetings are presently underway in this regard.

The Benton/Franklin County plan states that Supply System will provide specific recommendations for protective actions. This will be performed through the use of an information sheet developed and included in the Emergency Plan Implementing Procedures. The

information sheet will be used to ensure all agencies called receive the same basic information and recommendations for protective actions. The Hanford Site Emergency Plan will be revised to include instructions concerning offsite notifications as follows:

Section 5. 1.4 Site Emergency page 5-5, rewri .e number 7) as 'follows:"

7) Notify the Washington State Department of Emergency Services, Benton/Franklin County Sheriffs,,and the City of Richland to attain alert status.

Section 5.1.5 General Emergency page 5-7, add number 7) as follows:

7) Notify the Washington State Department of Emergency Services, Benton/Franklin County Sheriff, and the City of Richland and provide specific recommendations for protective actions.

Table 432.01-1 presents quantitative emergency action levels and recommended actions for plant, site, and general emergencies, which have been proposed to the state and county. The action levels follow the guidance presented in Table 5.2 of document EPA-520/

1-75-001, Hanual of Protective-Action Guides and Protective Actions for Nuclear Incidents.

In response to the NHA ambiguity with respect to state and local plans, using Table 432.01-1, the AHA would be classified as a General Emergency. Table 432.01-2 shows the coordination of the emergency plan with the state and county plans.

• draft page revisions to the Emergency Plan are attached.

Also included is a draft update to Table 3.3-2, Doses Resulting from WNP-2 Accidents. This table represents updated data from the FSAR and will be incorporated into the Emergency Plan to replace the old table 3 '-2. All of section 3.3 will be revised to reflect the new analysis.

TABLE 432 01-1 F

PROJECTED EXPOSURE AT EXCLUSION AREA BOUNDARY Projected Dose Emergency To The Public C1assification Recommended Actions

<0.1 rem whole body Plant I) No protective actions required.

<0.5 rem thyroid Emergency

>0.1 rem whole body Site 1) Notify state and local emergency Emergency agencies.

>0.5 rem thyroid 2) Monitor environmental radiation levels.

>1.0 rem whole body General I) Control access.

>5.0 'rem thyroid Emergency 2 Monitor environmental radiation level.

3) For low projected doses (1 to 5 rem whole body and/or 5 to 25 rem thyroid) seek shelter and consider evacuation of children and pregnant women.

4) For high projected doses (>5 rem whole body and/or 25 rem thyroid) conduct mandatory evacuation of affected araa.

TABLE 432.01-2 POSTULATED ACCIDENT WHICH COULD RESULT IN RELEASES FSAR EMERGENCY CHAPTER POSTULATED ACCIDENT PROBABLE DETECTION MEANS* CLASSIfICATION NOTIfICATIONS IHNED IATE ACTIONS I

15.4.9 Control rod drop l. Area radiation alarms Plant Headquarters 1. Declare plant accident 2. Hain steam line radiation emergency and monitoring system initiate Emer-

3. Turbine - generator gency Plan building ventilation Implementing release duct radiation Procedures monitoring system 15.6.2 break I'.

Instrument line pipe Area radiation alarms

2. Radiation monitor in the reactor building exhaust Plant Headquarters 1. Declare plant emergency and initiate Emer-air plenum gency Plan 3; Release duct - radiation Implementing monitor reactor building Procedures elevated

FSAR EMERGENCY CHAPTER POSTULATED ACCIDENT PROBABLE DETECTION MEANS" CLASSIFICATION NOTIFICATIONS IM1EDIATE ACTIONS 15.6.4 Steam system piping 1. Area radiation alarms Plant Headquarters Declare plant break outside con- 2. Hain steam line radiation emergency and tainment monitoring system initiate Emer-

3. Turbine - generator gency Plan building ventilation Implementing release duct radiation Procedures 15.6.5 Loss of coolant l. Area radiation'alarms 1. Headquarters 1. Declare general accident 2. Reactor building 2. NRC emergency and monitor'eneral elevated release duct 3. Washington initiate Emer-radiation State Dept. gency Plan of Emergency Implementing service Procedures

4. Benton County 2. Consider.evac-Sheriff uation of 5'. Franklin County exclusion Sheriff area and low

6. WNP-1/4 Construc- population zone tion site based on projected

7. Fast Flux Test dose and estab-Facility lished protective

8. FAA action guides

9. U.S. Coast Guard

FSAR EMERGENCY CHAPTER POSTULATED ACCIDENT PROBABLE DETECTION ilEANS* CLASSIFICATION NOTIFICATIONS IMMEDIATE ACTIONS

10. Dept. of Energy Patrol Emergency officer

11. City of Richland 15.6.6 - Feedwater line break l. Area radiation alarms Plant Headquarters 1. Declare plant

2. Turbine - generator emergency and building ventilation initiate Emer-release duct radiation gency Plan monitoring system Implementing Procedures

FSAR EHERGENCY CHAPTER POSTULATED ACCIDENT PROBABLE DETECTION HEANS* CLASSIFICATION NOTIFICATIONS IHHEDIATE ACTIONS'5.7.1 Radioactive gas waste 1. Area radiation alarms Plant Headquarters l. Declare plant system leak or failure 2. Rad-waste building ven-I emergency and tiliation release duct initiate Emer-radiation monitoring gency Plan system Implementing Procedures 15.7.2 Liquid radioactive 1. Area radiation alarms Plant Headquarters 1. Declare plant system failure 2. Rad-waste building ven- emergency and tilation release duct initiate Emer-radiation monitoring gency Plan system Implementing Procedures

FSAR EMERGENCY CHAPTER POSTULATED ACCIDENT PROBABLE DETECTION MEANS* CLASSIFICATION NOTIFICATIONS I tOED IATE ACTIONS 15.7.3 Radioactive release due 1. Area radiation alarms Plant Headquarters 1. Declare plant to liquid radwaste tank emergency and failure -initiate Emer=

gency Plan Implementing Procedures 15.7.4 Fuel handling accident l. Area radiation alarms Site 1. Headquarters 1. Declare site

2. Reactor building elevated 2. NRC emergency and release duct radiation 3. Benton/Franklin initiate Emer-County Sheriff gency Plan

4. Wash. State Implementing Dept. of Emer-. Procedures gency Services

5. City of Richland

6. DOE-PEO

7. FFTF

8. WNP-1/4 Construc-tion Site 15.7.5 Spent fuel cask drop l. Area radiation alarms Plant Headquarters 1. Declare plant accident 2. Reactor building elevated emergency and release duct radiation initiate Emer-monitor gency Plan Implementing Procedures

• These systems indicate the quantity of material being released.

TABLE 3.3-2.

DOSES RESULTING FROM MNP-2 ACCIDENTS Accident Exclusion Area Boundar Rem Low Po ulation Zone Boundar Rem

~Mhole Bod ~Th roid Whole Bod ~Th roid 1.. Loss of coolant (15.6.5)*

Design Basis Analysis 2.49 6.2 2.33

- Realistic Base 6.08E-07 4.44E-07 1.38E-05 1.93E-05

2. Fuel Ha'ndling Accident (15.7.4)

Design Basis Analysis 0.16 0.19 0.06 0.07 Realistic Case 4.9E-04 9.4E-03 '.3E-03 2.1E-02

.3. Control Rod Drop Accident (15.4.9)

Design Basis Analysis 8.6E-03 8.18E-02 7.54E-03 1. 77E-01 Realistic Case 1.1E-06 1.3E-05 4.4E-06 4.7E-05

4. Steam Line Break Outside Containment (15.6.4)

Design Basis Analysis 3.05E-03 3.00E-01 1.14E-03 1.12E-Ol Realistic Case 4.1E-05 2.1E-02 1.9E-05 7.8E-03

5. Spent Fuel Cask Drop Accident (15.7.5)

Design Basis Analysis 6.6E-07 5.4E-07 1.6E-06 - 8.7E-07 Realistic Case (considered negligible)

6. Feedwater Line Break Accident (15.6.6)

Design Basis Analysis (Not considered)

Realistic Case 1.3E-07 8.3E-05 6.3E-08 3.1E-05

7. Gaseous Radwaste System Failure (15.7.1)

Charcoal Absorber Vessel Rupture-Design Basis Analysis 5.2E-03 3.1E-04 1.9E-03 1.2E-04 Delay Line Rupture - Design Basis Analysis 3.3E-02 1.2E-02 First Charcoal Tank Rupture-Realistic Case 1.6E-03 1.6E-04 5.8E-04 5.8E-05

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TABLE 3.3-2 DOSES RESULTING FROM lOP-2 ACCIDENTS Accident Exclusion Area Boundar Rem Low Po ulation Zone Boundar Rem Hhole Bod ~Th roid M~hl 8 d chid I

8. Liquid Radwaste System Failure (15.7.2)

Design Basis Accident 1.9E-05 1.2E-02 8.8E-06 4.2E-03

.Realistic Case 5.4E-07 3.3E-04 3.5E-07 1.2E-04

9. Instrument Line Pipe Break (15.6.2)

Design Basis Analysis (Not considered)

Realistic Case 4.0E-07 4.5E-05 1.9E-07 3.8E-05 "Indicates FSAR Chapter number NOTE: 4.0E-02 is read as 4.0 x 10"2

1) Severe weather conditions - alerting of plant emergency 1

staff offsite and the NPPSS Emergency Coordination Center.

2) Fire in plant - activation of the plant fire brigade and/or the fire department depending on magnitude of the f're and available'lant personnel. A major fire will require activation of all of the plant emergency staff, alerting medical services, notification to the NPPSS Duty Officer, and, DOE.

3) Xn plant flooding - activation of plant emergency staff and notification to the NPPSS Duty Officer and DOE.

4) Explesion or explosive gas release - activation of plant emergency staff, notification to DOE and NPPSS Duty Officer, and activation oz fire department.

5) Toxic or noxious.gas release inside plant - activation oz BHO Fire Department Rescue Squad, plant emergency staff and notification to NPPSS Duty Ozficer.

6) 'Radioactive material release or spill 'within plant-activation of health physics group for evaluation and alerting balance of plant staff; Action level for this type of emergency is determined by direct observation of the occur ence, or an increase in plant radiation moni-toring systems. acta

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~ sac/myra ~i 6n Anv of the above conditaons may require evacuation of specific a eas or buildings of the plant. and this vill be accomplished by use of the evacuation sirens and the public address svstem, followed by an accountability check of personnel.

5.l.4 Site Emergency An emergency in this classification involves uncontrolled release of radioactive materials from the plang to an evtent that initial assessmgnt indicates dS~ ~$ '

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~a 6sei peg roi H~ d I~n.AI.<.AThei/4Site+ Emergency ae s,sn~p sard~ vl wig may evolve from a Plant Emergency, although this would not be the normal circumstance. Of site assessment actions may be zecuized.. D'scovery of this type oz emergency is almost cer-5-4

I tainly by main control room personnel, since action levels are based on control room instrumentat'on and alarms. Xm-mediate notification of the Shift Supervisor on-duty by the person discovering this condition is essential. The Emer-gency Director will initiate the following steps:

1) Evacuation of all plant personnel not assigned to the control room .to the Primary Emergency Relocation Center by use of the evacuation sirens and public address system.

2) Activation of the plant emergency organization to report to their assigned locations. Communications will be acti-vated and maintained between the two centers. Plant emer-gency staff coming. to the plant f om offsite will be advised as to where to report.

3) Provide notification and action criteria to construction sites of WNP-1/4

4) Activate  %'PSS Emergency Coord'nat'on Center personnel by

. notification to the- Duty Officer on call.

5) Obtain an accounting of personnel onsite from the Security Station.

6) Directly notify FFTF Control Room and the DOE PEO.

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Action levels for this classification or emergency are deter-mined by an alarm on one of the following .effluent monitors and verification by observation of an increase in a redundant or related system by direct sampling or measurement:

1) Reactor Building Elevated Release Point Monitor

2) Turbine Building Fxhaust Monitor

3) Radwaste Builcing Exhaust Mon'itor "

4) Liquid Effluent Monitor.

Alarm settings for these monitors are based on potential dose at the exclusion area boundary, and although this does not,I indicate an offsite emergency condition, site areas may be severeLy affected.

5.1.5 General Emergency This classification of emergency is characterized by offsite consequences which require mobilization of the outside sup-port agencies, as well as the WPPSS emergency organization.

Action levels for a General Emergency resulting from air-borne releases are determined by the same effluent monitoring instrumentation used for the Site Emergency, and surveys on site and at the exclusion boundary to verify that these con-ditions exist. Based on recommended protective action levels of the Environmental Protection Agency, a General Emergency will be declared if exposur'e of the whole body due to noble gases and/or of the thyroid due to the release of radioiodine is pro-jected for, members of the general public which exceed the minimum values specified below for Nonessential Personnel:

POPULATION AT RISK PROJECTED DOSE (Rem)

Nonessential Personnel 1 to 5 5 to 25 Emergency Norkers 25 125 Lifesaving Activities 75 (a)

(a) No specific upper limit is given for thyroid exposure since in the extreme case, complete surgical or radiolo-gical thyroid loss might be an acceptable penalty for a life saved. However, loss should not be necessary if respirators and/or thyroid protection are used.

The implementing procedures provide guidance to the Plant Emer-

.gency Director for making the determinations necessary to give sound recommendations to offsite agencies.

I con'trolroom instrumentation indicates that the above conditions might exist or are developing, the on-dutv Shift Supervisor will initiate the zollowing communications steps to activate the necessary emergency organization:

1) Evacuation of all plant personnel .not recuired in the control room to the Primary Emergency Relocation Center by use of the evacuation siren and public address system.

2) Activation of the plant emergency organization to report to the Primary Emergency Relocation Center. 'They will establish communications back to the control room and prepare to render assistance. Dispatching emergency monitoring teams rapidly has high priorit:. Plant emer-gency staff arriving from ofzsite will be adv'sed to proceed to .the Primarv Emergency Re'ocation Center unless stopped at the .Backup Emergency Relocation Center.

3) Provide not'fication and action crj.teria to construction sites oz gNP-i]4 I ord8r N

4) Activate WPPSS Emergency Coordination Center pe sonnel-by notification to the Duty Officer on call.

5) Recuest Secur'y Guard provide rosger of personnel on site for accountability check.

6) Directly notify the PPTP. Control Room and the DOE PEO.

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~4+ Sl4njl/s ~ 4r~ 4r)y elf ~>c 4 ~o+ 0+2 /~vlk s/Ni)lc f5:oa~e~<4(i~ +r The ~emergency Coordinat'on Center Director will establish back to the WNP-2 Contxol Room or Emergency p~uj'ommunications Relocation Center and if it has been established that a General Emergency exists or might develop, will notify the azfected County Sheriff and anv other outside agencies recuired bv the condi"ions, wno have not already been notified by the Plant Emergency Director.

Although highly improbable, ~~ . 1 Emergency could be created by release of radioac'tivity in liauids to the Columbia River. Action levels ar based on dose to downstream 'ndividua's

L CONMENT: 432. 02 Identify the value of the potential doses at the (3.2.4) 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 com-patible with the qualitative 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 in the spent fuel pool) or to an indication of the clear potential for damage.

RESPONSE

Table I presented in the response to guestion 432.01 provides the action levels at the exclusion area boundary for declaring a Site Emergency from an atmospheric release. The answer to Ouestion 432.14 provides the basis for action levels for water releases.

Examples of how the postulated accidents involving fuel damage relate to the emergency action levels are shown in Table 432.02-1.

These numbers are from the current fSAR which will be reflected in a future revision of the Hanford Site Plan.

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TABLE kSt'CCIOFHT CI ASS ArrIDH Ii:.Vn. DOSE m A L'0 T FUCL 0 HAD II R A I'0 0 I'0

~re ra Hhule Body ~I rom Loss of Coolant Accident Whole Body 2.49 rem 'IIAGI.'hole Thyroid "5 rem Thyroid 6.2 rem Body 0. 1 to 1.0 rem Fuel Ilandling Accident Mhole Body 0. 16 ran Thyroid 0.5 to 5.0 rem Thyroid 0.19 rem Plant Whole Body <O.l rem Control Rod Drop Accident Whole Body 8.6 x 10 rem instrument Line Pipe Whole Body 4.0 x 10 Thyroid 0.5 rem Thyroid 8.18 x 10 rem Break Thyroid 4.5 x 10 Spent Fuel Cask Drop Whole Body 6.6 x 10 Steam System Piping Whole Body 3.05 x 10 Thyroid 5.4 x 10 Break Outside Containment Thyroid 3.00 x 10 Feedwater Line Break Whole Body 1.3 x 10 Thyroid 8.3 x 10 Radioactive Gas Haste Hhole Body 5.2 x 10 System Leak Thyroid 3. 1 x 10 Liquid Raduaste System Whole Body 1.9 x 10 Failure Thyroid 1.2 x 10

COMMENT: 432.03 You state in the second paragraph, of Section 3.2.5.2 (3.2.5) 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 p'rotective 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.

RESPONSE

The Supply System, the State, and the local emergency planning agency are aware of the need to add protective action guides for milk, soil, and vegetation pathways into the respective emergency plans. The proposed FDA regulations concerning human and animal feeds will be used when promulgated in developing appropriate action levels.

The proposed FDA regulation from the Federal Register (4110-03-M)

Docket No. 76N-0050 recommend that when exceeding the preventive PAG, lactating dairy cows should be removed from contaminated pasturage and placed on uncontaminated stored feed. Using the infant as the critical segment. of the population an initial

deposition of 0. 14 microcuries/meter and a peak activity on the pasture of 0.27 microcuries/kg are given as the Preventive PAG.

Attempting to take readings above the pasture forage presents several problems. Mainly, the sensitivity of the GM's too low to detect the Preventive PAG and interference from a passing plume would prevent accurate readings.

Lab analysis will be performed on forage samples from pastures in the downward direction after an accident to ensure that Preventive PAG are not exceeded. The WNP-2 plant and Radiological Services will

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have analytical capabilities. Since a vegetation sample will be-collected for the analysis, a reading can be taken in the field with the GM placed inside the sample bag. Using Table XL, page 75 of'AEA Technical Report 152 Evaluation of Radiation Emergencies and Accidents, one microcurie/kg of I-131 will yield 400 cpm. For the FOA Preventive PAG of 0.27 pCi/kg, a GM reading of 100 cpm would be measured. If interference from a passing plume is suspected, the sample can be removed to an area of less. background and measured.

COMMENT: 432.04 Your proposed Emergency Plans include provisions for (3.2.4) evacuating the construction workers at the WNP- 154 site. However, some items were not addressed in your proposed evacuation plan for these workers.

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

a. The emergency action levels at which the construction workers at the WNP-1&4 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.

b. The provision of visual indicators of wind direction at the WNP-154 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-154 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 construction

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workers at the WNP-1I%4 site, you should esta-blish notification criteria (i.e., emergency action levels) that are mutally 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.

e. An annual site evacuation drill during peak construction years which we define as those years when there will be more than 500 con-struction workers on site.

RESPONSE: ,--

a. The WNP-184 construction sites were located within the ex-clusion area boundary of WNP-2. Evacuation of the construction site workers will be conducted for site emergencies and general emergencies. The criteria for a site emergency is a dose potential of 0.1 to 1.0 rem whole body and 0.5 to 5.0 rem thyroid. A General Emergency is declared for dose potentials exceeding 1..0 rem whole body and 5.0 rem thyroid.

The following changes will be made *to the Hanford Site Emergency Plan:

Section 5.1.4 Site Emergency page 5-5 *

3) Provide notification and action criteria to construction sites at WNP-1/4, order evacuation.

• draft page changes to the Emergency Plan pre attached.

Section S. 1.5 General Emergency, page 5-7 *

3) Provide notification and action criteria to construction sites of WNP-1/4. Order evacuation.

b. Presently WNP-1/4 has only one evacuation route away from WNP-

2. When considering the time element that a large release capable of exceeding protective action guides is imminent and the release actually occurs, the travel time of the plume, and the width of the plume, the instructions to workers would be to evacuate by automobile using the road system which would provide the fastest means of exiting the area. The parking lots are adjacent to the construction area and evacuation is expected to take approximately 30 minutes.

c. Evacuation signals at WNP-2 are not designed to be heard at the WNP-1/4 construction area. It is doubtful that with all the construction and machinery noise that a signal at WNP-2

-could be produced l'oud enough to effectively be heard at WNP-1/4 a distance of 1.2 miles away. . Evacuation of WNP-1/4 will be initiated by notifying security at WNP-1/4 who will then notify construction crews to evacuate using the portable radio network.

d. A written agreement is maintained between FFTF and the Supply System which states that direct notification of the other facility will be made if it is determined that the emergency condition may affect the other facility.

I During General Emergencies FFTF, will notify the Supply System's WNP.-2 facility. The Emergency Control Center Coordinator is given this responsibility in the FFTF Emergency Procedures.

• draft page changes to the Emergency Plan are attached.

As stated in the Hanford Site Emergency Plan, Sections 5.1.4 and 5.1.5, FFTF will be notified in the event of a Site or General Emergency.. This notification requirement will be included into the Emergency Plan Implementing Procedures.

e. Dur ing the construction phase an annual site evacuation drill for the MNP-1/4 construction site will be conducted. The response to guestion 432.10 includes this requirement.

fI by main control room, personnel, since act'on levels J

tainly ~

are based on control room instrumentat'on and alarms-'m" mediate notification of the Shift Supervisor on-duty by the person discovering this condition is essential. The Emer-gency Director will initiate the following steps:

1) Evacuation of all plant personnel not assigned to the control room to the Primary Emergency Relocation Center by use of the evacuation sirens and public address system.

2) Activation of the plant emergency organization to report to their assigned locations. Communications will be acti-vated and maintained between the two centers. Plant, emer-gency staff coming to the plant from offsite will be advised as to where to report.

3) Provide notification and action criteria to construction sites'f NNP-1/4 <<~< <+~+~~+

4) Activate NPPSS Eme gency Coordinat'on Center personnel by notification to the Duty Officer on call.

5) Obtain an accounting-of personnel onsite from the Security Station.

6) Directly notify FFTF Control Room and the DOE PEO.

7) Alert the Benton/Franklin Countv Sheriff's if 'there is a potential for the Site Emergency to degenerate into a General Emergency.

Action levels for this classification of emergencv are deter-mined by an alarm on one of the following,effluent monitors and verification by observation of an increase in a redundant or related system by direct sampling or measurement:

1) Reactor Building Elevated Release Po'nt Monitor

2) Turbine Building Exhaust Monitor

3) Radwaste Building .xhaust Monitor

e control room instrumentation indicates that the above conditions might exist or are developing, the on-duty Shif" Supervisox will initiate 0he ollowing communications steps to activate the necessary emergency organization:

l) Evacuation of all plant personnel not reauired in r'oom to the Primary Emergency Relocation Center the'ontrol by use of the evacuation si en and public address svstem.

2) Activation of the plant emergency organization to repox'o the Primary Emergency Relocation Center. They will establish communications back to the control room and prepare to rendex assistance. Dispatching emergency mon'toring teams rapidly has high priority. Plant emex-gency staff arriving from offsite will be advised to proceed to the Primary Emergency Relocation Center unless stopped at the Backup Emergency Relocation Center.

3) Provide notification and action criteria to construction sites of NNP-l/4J

4) Activate NPPSS Emergency Coordination Center personnel.

by notification to the Duty Offic r on call.

5) Recuest Secur'ty Guard provide roster of personnel on site for accountability check.

6) Directly notify the PPTP. Control Room and the DOE PEO.

\

The Emergency Coordination Center Director will establish communications back to the NNP-2 Control Room ox Emergency Relocation Center and if it has been established that a General Emergency evists or might develop, will notify the axfected County Sheriff and anv other outside agencies ecruired bv the conditions, who have not already been notif'ed by the Plant Emergency Director.

Although highly improbable, a General"~emergency could be cr ated by release of radioactivity in liauids to the Columbia River. Action levels ar based on dose to downs ream indiviQaal=-

5-7

COMMENT: 432.05 Describe the conservative assumptions you mention in (5.2.5) the first paragraph of Section 5.2.5.1. (Your response to Item 432.2 may be sufficient to satisfy this item.)

RESPONSE

The conservative assumptions for preliminary dose estimates from shor t term accidental airborne releases of radioactivity include:

o Uniform wind direction o No allowances for plume depletion (physical or radio-active) while in transient o Conservative dose conversion factors for monitoring gross radioactivity released

COMMENT: 432.06 You state in Table 2.2-2 of the FSAR that visual approaches by aircraft pass directly over the NNP-2

.facility. Provide your proposed plans for appropriate notifications to those responsible for air traffic control in the vicinity of the MNP-2 facility in the event of a General Emergency (i.e., for a severe event'involving an atmospheric release). Inclusion of these notifications in the State or local warning "fan-out" system would satisfy us.

RESPONSE

Air traffic over the Hanford Site will be restricted by notifying the FAA. For the Hanford Site, the Seattle FAA Duty Officer is the initial contact. The Emergency Plan Implementing Procedure will include instructions for notifying the FAA and the phone number.

The following addition'i(ill be made to the Hanford Site Plan: Section 5.1.5 page 5-7 add"

8) Notify the Coast Guard for river closures and the FAA (airborne releases only) for termination of flights over the Hanford Site.

• See attached draft page.

Qi E control. room 's trumentati- n indicates that the above conditions might exist or are developing, the on-duty Shif" Supervisor will init'ate the following communications steps to activate the necessary emergency organization:

l) Evacuation of all plant personnel not required in the control room to the Primary Emergency Relocation Center by .use of the evacuation siren and public address system.

2) Activation of the plant emergency. organization to repor" to the Primary Emergency Relocation Center. .They will-establish communications back to the control room and prepare to render assistance. Dispatching emergency monitoring teams 'rapidly has high priority. Plant emer-gency staff arriving from offsite will be adv'sed to proceed to the Primary Emergency Relocation Center unless stopped at the Backup Emergency Relocation Center.

3) Provide notification and action c iteria to construction sites of HNP-l)4 I urcLe~ C~+c u.~+

4) Activate NPPSS Emergency Coordination Center personnel by notification to the Duty Offic r on call.

5) Request Secur'y Guard provide rosQer of personnel on site for accountability check.

Directly notify the Control Room and the DOE PEO.

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The afergency Coordination Center Director will establish pnrk?@boy AC 9)r~ I .

communications back to the NNP-2 Control Room or Emergency Relocation Center and if it has been established that a General Emergency exists or might develop, will notify the affected County Sheriff and any other outs'de agencies equired bv the conditions, who have not already been notified'v the Plant Emergency Director.

Although highly improbable, a General Emergencv could be created by release of radioactivity in liquids to the Columbia

'I River. Action levels are based on dose to downstream individua

COMMENT: 432.07 In Section 3.a.(1)(c)l, "Sheriff's Dispatcher,"

(App. III) f o Tab A to Appendi x 8 to Annex G (Ref er 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 instruc-tions 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.

RESPONSE

The Sheriffs of Benton and Franklin County assign an Undersheriff who will act in their absence. The Undersheriff, as well as any Deputy Sheriff, can act for the Sheriff as specified in the following exert from the Revised Code of Washington Title 36:

"36.28.020 Powers of deputies, regular and special. Every deputy sheriff shall possess all the power, and may perform any of the duties, prescribed by law to be performed by the sheriff, and shall serve or execute, according to law, all process, writs, precepts, and orders, issued by lawful authority."

When a call is received by the Sheriff's Dispatcher, the information will be given to the assigned Duty Officer who will notify the Sheriff, if available, or the undersheriff. The Duty Officer is in charge of the sheriff's office and can act in his absence.

CO[MENT: 432. 08 In Section 5.1.4 of your proposed Emergency Plans, (5.1.4) 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. The Sheriff should also be notified in the event that a site evacuation is necessary to, areas outside the Hanford reservation.

RESPONSE

The response to question 432.01 satisfies this question. Since a site evacuation to an area outside the Hanford Reservation would be necessary for a Site Emergency or a General Emergency condition, the Sheriff will be notified.

COMMENT: 432.09 In Table 5.1. 1 of your proposed Emergency Plans, (5.1.1) there are three columns which have the same heading; i.e., "Necessity for Corrective Actions." Revise these headings to remove this ambiguity.

RESPONSE'he corrected Table 5.1.1 is the following:*

Emergency Necessity For Necessity For Degree of Participation Classification Protective Actions Corrective Action by Var ious Organizations Onsite Offsite "See attached draft page;.

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Et1ERGENCY CLASSIFICATIONS AND DEGREE OF IHVOLVEHENT GY PARTICIPATING GROUPS f p4 Emergency Classification

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Necessity for Onsite Offsite Necessity for Corrective Actions Plant ta f b

Degree WPPSS Hea of Participation Various Or anizations uarters Staff Offsite

~A encies Personnel {'ossible Hot Req'id Possible*** Action Req'd Ho Action Req'd No Action Emergency~ Req'd Emergency Hot Req'd Hot Req'd Hot Expected On Alert On Alert Ho Action Alert** Status Status Req'd Plant Possible l{ot Req'd Possible*** Action Req'd On Alert No Action Emergency Status Req'd Site Emergency Probable Possible Probable*** Action Req'd Action Req'd On Alert Status General Probable Probable Probable*~" Action Req'd Action Req'd Action Req'd Emergency

~ For example, 'injury to a plant employee

"* For example, tom'ado alert, potential flood, or a bomb threat

• • • Such action could involve local firemen, police, ambulance, services, and/or medical facilities.

l TAOLE 5.1.1

COMMENT: 432.10 Provide a commitment to conduct an announced emergency (7.1,.2) drill involving State and local agencies and local support services, prior to loading fuel into the WNP-2 facility. Additionally, revise the last sentence in the fourth paragraph of Section 7.1.2 of your proposed Emergency Plans to read"... will be tested to demonstrate that the capability for early warning of the public, is maintained."

RESPONSE

The second paragraph, first sentence of Section 7.1.2, page 7-2 will be replaced with the following:*

"An initial exercise pr ior to fuel load into WNP-2 shall be conducted involving State and local agencies and local support

-services. Thereafter, annual exercises shall be conducted which could result in a Site Emergency or General Emergency including the evacuation of WNP-1/4 during the construction phase."

The requested change to the fourth paragraph will be made such that the last sentence of the fourth paragraph reads: *

"As a minimum, the communication links and notification procedures with offsite agencies will be tested to demonstrate that the capability for early warning. of the public is maintained."

• See attached draft pages.

4) Emergency First Aid and Rescue Teams - This training includes basic medical first aid, cardiopulmonary resuscitation, and use of personal protective equip-ment. This group includ'es all personnel directly involved

. with the ope ation or maintenance of NPPSS nuclear plants ~

5) Emergency Medical Support Training' Attempts will be made to conduct training exercises with the agreement hospitals for'he handling of contaminated will be done as hospital work load and schedule per-patients'his mit, and will be done in cooperation with Richland Opera-tions Office, DOE. Hanford Environmental Health Foun-dation personnel are specialists in handling radiation emergencies, trained by their own staf f .

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6) Emergency Support Agencies 'Training >> This t aining will be conducted on an annual basis and will include a dis-cussion of: reasons for the need of an emergency plan, explanation of the organization, detailed study of related phases of the plan, areas of responsibility stressed, emergency equipment. demonstrated, and basic radiation pro-tect'ion as required.

7) WPPSS Headquarters Support Personnel T aining - Designated headquarters personnel will be provided training in response and specific duties during a plant emergency.

7.1.2 Drills All members of the staff must be familiar with their duties and responsibilities in relation to the WPPSS Emergency Plan.

This section provides a means for periodic review and exer-cise of the .Emergency Plan from plant-wide as well as an indi-v'dual standpoint.

.~intt-Plans for the scenario will be sufficiently detailed such that simulated locations and ext nt of damage

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III are described fully enough to enable simulated corrective actions to be taken. Subsequent. to the initial planning, meetings will be held with members of each department to review their specific responsibilities. This exercise drill will be expanded to incorporate pertinent comments derived during these discussions.

After incorporation of all commerits, the finalized exercise will be presented to the plant staff to provide all members with an overall appreciation of the exercise and to point out individual areas of responsibilities. Segments of the plan may be ex'ercised for this purpose in'ome cases.

After final approval by the Plant Superintendent, appropriate offsite agencies will be contacted to confirm their level of participation and their agreement upon the date and time of the exercise. As a minimum, the communications links and notification procedures with offsite agencies will be tested.V<

pka+ M cc.grjih+ 4rr ~> ~*Ikq o+ +W/~<lii The responsible individual will assure that, during the con-duct. of the exercise, an adequate number of observers are stationed at strategic locations to provide information as necessary to drill participants '(e..g., radiation and conta-mination levels) and to evaluate individual, and group perfor-mance. Evaluation will also be made of the extent and proper employment of emergency equipment including audibility of the evacuation alarms. Equipment not used during the exercise will be. inventoried and checked for operability.

I Evaluation of personnel performance during the exercise will be conducted in two phases. At the conclusion of the exercise,,

the responsible individual will meet with all observers to compile and summarize observations and criticisms. This compi-lation will be reviewed in detail in a meeting with plant management. A general summary of the critique will then be presented to the staff, emphasizing areas of strength and 7~3

COMMENT: . 432.11 I'n Section IV.B of Appendix IX of your proposed (App. IX) 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.

Provide a line of succession of authority from the Managing Director for the purpose of pro-viding news releases which are coordinated with State and local agencies, to the public in the event of an emergency.

RESPONSE

The following change will be made to Section IV.B of Appendix IX page ;*

~Plannin Maintains current information on methods t b e use d in releasing news stories and participate in coordinated drills with state and local agencies."

I See the following chart for. the line of succession.

• See attached draft page.

3 0

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ORGANIZATION CHART MANAGING DIRECTOR MANAGEMENT SERVICES ASSISTANT DIRECTOR COMMUNICATIONS DIVISION MANAGER

'OMMUNICATIONS COORDINATOR (INFORMATION OFFICER)

Ensures that a periodic review of emergency plans, staff assign-ments and supplementary instructions are made to maintain them in a current state.

Ensures that all members of the Headquarters Staff and site emer-gency staff are properly trained and cognizant of their duties.

Provides for a realistic and comprehensive annual drill of the emergency plan.

Performance Ensures that the Headquarters Staff has been notified.

Receives reports from the Plant Emergency Director and Headquarters Staff, Evaluates and makes recommendations to the site as nec-essary.

Commits and coordinates the support efforts of Headquarters. Any needs which cannot be fulfilled from within.MPPSS shall be re-quested through prearranged contacts.

Provides assistance as requested by local, State or Federal agencies in movement and evacuation of the public.

8. Information Officer

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Performance Compiles data regarding geographic boundaries affected, general type and cause of accident, approximate restoration time, number of emergency people involved and any unusual conditions.

COMMENT: 432. 12 Oescribe the steps you will take to provide infor-(7.I. I) mation to plant visitors and to construction workers regarding the notification procedures of your Emergency Plans. Indicate how they can expect to be advised on what to do in the event of an emergency.

RESPONSE

All plant visitors and construction workers will be under escort while at WNP-2. The escort will be a Supply System Employee designated as an escort who is familiar with the proper response for emergencies, the plant alarms, and the location of the assembly area. In addition, each employee, visitor, and construction worker will be driven a small card which provides instructions on what to do if an emergency occurs.

COMMENT 432. 13 Revise your proposed Emergency Plans to include a (7.I.I) description of the specialized initial training and the periodic retraining programs to be provided for each of the categories of 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.

RESPONSE

Section 7.1.1, pages 7-1 and 7-2~ wi'il be revised as follows:*

7.1.1 Training Selected plant operations, technical and maintenance personnel are trained in emergency procedures and monitoring duties. It is the intent of this training to provide an adequate number of emergency personnel sufficiently familiar with nuclear facility emergency planning and procedures so that, in the event of an emergency, the individual can render effective assistance.

The training is divided into seven categories and will be initiated prior to fuel load to prepare Supply System personnel for participation in the pre-fuel load drill. Annually, training classes will be offered as refresher courses and will include review of the initial training course and changes made in the emergency plan or imple-menting procedures.

The seven categories of emergency training are as follows:

1) Emergency Director Training - This training is oriented to supervision of emergency teams and interpretation of data.

The course will review the Hanford Site Emergency Plan and plant Emergency Plan Implementing Procedures, the plant and headquarters emergency organizations, offsite as'sistance, emergency supplies and facilities, and emergency action dose limits. This course will be given to directors and coordinators of the plant emergency organization, personnel responsible for accident assessment including control room personnel, selected headquarters support personnel, and,emergency team leaders.

2) Emergency Monitoring Training - This training includes operation of portable radiation survey instruments and air sampling equipment, air sampling techniques, "field" air activity determination, emergency action dose limits, and familiarization with the plant emergency monitoring procedures. This course will be given to radiological monitoring teams.

3) Emergency Fire Brigade and Damage Control Training - This training includes operation of installed fire protection systems, portable fire extinguishers, life support systems, and techniques employed to limit the damage caused by an incident. This course will be given to fire control team members and repair and damage control teams.

4) Emergency First Aid and Rescue Training - This training includes medical first aid, cardiopulmonary resuscitation (CPR), and rescue techniques. Medical first aid and CPR training is given to members of the plant. staff and security organization to ensure that there are always adequate personnel on site who are qualified in these skills. Members of the First Aid and Rescue teams are given this training and additional training in rescue techniques.

5) Emergency Medical Support Training - Attempts will be made to conduct training exercises with the agreement hospitals for the handling of contaminated patients. This will be done as hospital work load and schedule permit, and will be done in cooperation with Richland Operations Office, DOE. Hanford Environmental Health Foundation personnel are specialists in handling radiation emergencies, trained by their own staff.

6) Emergency Support Agency Training - This training will be offered to support agencies who would assist during an emergency.

Topics covered include reasons for an emergency plan, the emergency organization, areas of responsibility, emergency equipment demonstrated, and basic radiation protection as required.

7) The Supply System Headquarters Support Personnel Training-Designated headquarters personnel will be provided training in response and specific duties during an emergency at a Supply Sy'tem nuclear plant.

• See attached draft pages.

4) Emergency Pirst Aid and Rescue Teams - This training includes basic medical first aid, .cardiopulmonary resuscitation, and use of personal protective equip-ment. This group includes all personnel directly involved with the ope ation or maintenance of HPPSS nuclear plants.

5) Emergency Hedical Support Training - Attempts will be made to conduct. training exercises with the agreement hospitals for. the handling of contaminated patients.

This will be done as hospital work load and schedule per-mit, and will bh on in cooperation with Richland Opera-tions Office, DOE. ford Environmental Health Foun-dation personnel a specialists in handling radiation emergencies t aUi.ned by thei own staff.

')

Emerg n Support Agencies Training - This t aining will be c n cted on an annual basis and will include a dis-cus i n of: reasons for the need of an emergency plan, xplanation of the organization, detailed study of related phases of the plan, areas of responsibility stressed,

. emergency equipment demonstrated, and basic radiation pro-tection as required.

7) NPPSS Headquarters Support, Personnel T aining - Designated headquarters personnel will be provided training in response and specific duties during a plant emergency.

7.1.2 Drills E

All members of the staff must be familiar with their duties and responsibilities in relation to the WPPSS Emergency Plan.

This section provides a means for periodic review and exer-cise of the Emergency Plan from plant-wide as well as an indi-v'dual standpoint.

At least: annually, the Operations Services Security and Emer-gency Planning Analyst and plant management will devise a simu-lated accident which, we e 'it to occur, could result in a General Emergency. Plans for the scenario will be sufficiently detailed such that simulated locations and extent of damage 7~9

COMMENT: 432. 14 Your criterion in Section 5.1.5 (Page 5-8) of your (5. 1.5) 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 parti-cular criterion has been accepted by cognizant offsite agencies. (Refer to page G-8-19). Further, since the Maximum Permissible Concentration (MPC) of tritium is much larger than those for most other radionuclides, consider 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.

RESPONSE

A liquid release from WNP-2 will require several hours travel time until released into the Columbia River. Several more hours are required for the liquid plume to reach nearest potable water intake.

This time element allows isotopic analysis of the water as it leaves WNP-2. The projected dose will be calculated and approp-riate actions taken according to the criteria provided for question 432.01. In the. extreme case in which isotopic analysis cannot be performed and only the gross activity reading is available from the liquid effluent monitor, an assumption shall be made that the total activity is due to I-131. The Emergency Plan Implementing Procedures shall include the necessary equations for evaluating the release.

The last paragraph of Section 5.1.5 (page 5-8) will be modified by deleting the following: *

"Assuming the lowest allowable river flow of 36,000 cubic feet per minute and.... action level used for notification of offsite agencies."

And will be replaced with the following:

"Several hours are available from the time the radioactive liquid leaves WNP-2 and reaches the Columbia River. This allows for time to obtain the isotopic. composition of the.

release and project the dose to individuals. from the drinking water. Based upon the projected dose, a Site or General Emergency may be declared according to the PAG's and approp-riate protective actions initiated."

• See attached draft page

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and recommendations to offsite agencies to restrict the intake of contaminated water into domestic systems (Richland, Pasco, and possibly other downstream users).

5.2 Assessment Action 5.2.l Surve'llance of Inst umentation The emergency procedures designate specific personnel to main-tain watch on inplant and effluent radiological monitors, as well as meteorological instrumentation. Continuous readout and recording is provided in the Control Room for the following instruments:

l) Meteorological - Wind speed, direction, and temperature at the 245 ft. level and the 33 ft. level. This infor-mation is also available at the meteorological tower, which is the Backup Emergency Relocation Center site.

This data is accumulated and applied in the emergency pro-cedures for determination of the affected area and'agni-tude of the problem in the event of an uncontrolled release of radioactivity from the plant to the environs.

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COMMENT: 432. 15 In Section 5.2.1 of your proposed Emergency Plans, (5.2.1) you state that you will provide for continuous monitoring and recording of particulates, halogens and gases inside the primary containment. 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.

RESPONSE

Section 5.2.1 of the Emergency Plans was in error when it referred to continuous monitoring and recording of particulates, halogens, and gases inside the primary containment. Actually, only particulates and gases are continuously monitored and halogens are continuously

~sam led unless containment isolation has taken place. A description of the monitoring system follows:

"The primary containment monitoring system has two redundant subsystems each having two detectors to individually monitor particulate and noble gas activity. Additionally a charcoal sample cartridge is provided to trap halogen gases. The detectors are housed in divisionally separated cabinets located in the reactor building sample room. The cabinets have incorporated blowers and flow controls to withdraw gas samples from the primary containment atmosphere via stainless steel sampling lines and vent back to the containment. The environment in which the local cabinets are located is main-tained to limit upper temperature excursions that may occur in the reactor building during an accident. Associated radiation monitors and recorders are mounted in the main control room along with alarm annunciators.

Gas from the containment atmosphere enters the system at about 3.0 cfm encountering a moving filter ( 1"/hr) collector assembly for removing particulates. A beta scintillation type detector is positioned near the moving tape with a sensitivity range of about 2 x 10 pCi/cc to 5 x 10 pCi/cc (i.e.,

determined from Cs-137 gamma and 2 mr/hr background). The 6

count rate meter has a logrithmic scale from 1 to 10 cpm.

The count rate reading will not decrease upon saturation of the system.

The gas then enters a charcoal cartridge consisting of two cylindrical charcoal cartridge in series each with a size of 2 1/4" in diameter and 1" in thickness. These cartridges remove halogens from the gas stream and are subsequently removed for laboratory analysis.

The gas, following removal of particulates and halogens, passes in front of another beta scintillation type detector providing continuous monitoring of noble gas activity. The noble gas counting system is similar to the counting system for particulates. The sensitivity range is about 4 x 10 pCi/cc to 1.2 x 10 qCi/cc for 85 Kr in the presence of a 2 mr/hr, background."

In Section 5.2. 1 paragraph 2) page 5-9, the second sentence is changed to the following *

"Continuous readout and recording is also provided for parti-culates and gases inside containment."

• See attached draft pages.

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2) Radiological - Noble gas monitors are provided for the reactor building elevated release point, the post treat-ment offgas discharge, turbine building effluent, and radwaste building effluent. Continuous readout and and gases inside containment. In addition to the conti-nuously monitored gaseous effluents, samplers for pax'ti-culates and halogens are operated in the same locations andi can be used for assessment of releases. The liquid effluent discharge line is also continuously monitored.

In plant continuous air and radiation monitors are also provided in addition to the effluent monitors. These consist of the Area Radiation Monitoring System and air particulate monitors located in each building. Data from this instrumentation is also continuously recorded in the control room and can be used for assessment of inplant conditions and as backup to the effluent monitors.

V Continuous air particulate monitors are provided at the Primary Emergency Relocation Center, located in the Ser>>

vice Building and for the Backup Center. Designated per-sonnel will maintain surveillance of these instruments to determine habitability of the emergency centers.

'5.2.2 Surveillance of Containment Integrity Leakage from the reactor vessel ox piping into the primary containment structure can be detected by several means. Re-dundant air monitors continuously sample the primary contain-ment atmosphere. Humidity detectoxs in'side containment are constantly monitored. Temperature and pressux'e variables are also constantly monitored and recorded in the mann con-trol room. In addition, leakage to the sumps from this area is routinely. measured. All of these means are available for assessment functions.

5-9

COMMENT: 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.

RESPONSE

Qu'estion 372.8 discusses dust storm climatology and visibility. The igrotective'actions employed during a severe dust storm to minimize exposure to people following an uncontrolled release of radioactive material would be consistent with the present proposed actions.

However, because of the rapid movement of the plume during high winds, evacuation of people downwind would likely be abandoned in favor of notifying people to seek shelter until the plume has

. passed. Evacuation of people from the impacted area may follow depending on the amount of plume deposition which has occurred.

The offsite dose impact for radioactive material releases during a severe windstorm would be less than lX maximu~ impact, postulated for releases occuring during stable conditions and low wind speed, since the downwind concentration is inversely proportional to the product of the wind speed (p); the standard deviation of the vertical plume growth (az), and the standard deviation of the horizontal plume growth (ay) (Vizo x/Q (1/u) (1/az)(l/ay)). As the wind speed increases, the particulate burden of the air (dust) increases proportionally. However, the downwind radionuclide concentrations wouId become significantly less because of changes in p, a z, and ay.

The calculated individual dose during a dust stoem would be dependent on the X/g value and the radionuclides released. Noble gases would likely comprise the majority of any significant acci-dental release. The dispersion of these nuclides would be dependent on the air movement which is described by the wind speed and plume growth characteristics for a given stability class as described above.

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