ML17340A778
| ML17340A778 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 02/07/1981 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | Robert E. Uhrig FLORIDA POWER & LIGHT CO. |
| References | |
| NUDOCS 8103030330 | |
| Download: ML17340A778 (20) | |
Text
- ~
TRIBUT-I-0 e.
Fil 50-250/251 CParr ish Gray File ACRS (16)
DPerrotti gy67 $8
~lhcket~os.. 50-250, and 50-251 As stated fn paragraph 50.54 (s)()) of the new rule, the NRC will base fts findings of a review of the FENA findings and determinations as to,whether
'State and local'mergency plans are:adequate and capable of being imple-
- mented, and on the NRC. assessment as to whether the lfgensee's emergency plans are adequate and capable of being implemented.
In addition an emergency response. excerkfge with State and local government agencies designed to test the fnhegre'ated cp'jabflftj of the emergency preparedness plans must be conducted as required by the new rule, PIe cie ~eel gg Bo Ae,+usa 0
Rdg Deisenhut RPurple TNovak gg Dr.Dr. Robert E. Vhrfg, Yfce Pr esf dent i
it/pD Advanced Systems'nd Technology Fpgg ~
Florfda Power.and Light Company JHEltemes Post Office Box 529100 OELD Nfamf, Florida 33152 I&E (3)
SVar ga
Dear Dr. Uhrfg:
HGrotenhuis Me have completed our review of the Turkey Point Nuclear Station Radia-tion Emergency Plan dated January. 2, 1981.
Your Plan was reviewed against the criteria set forth fn "Criteria for 'Preparation and Evaluation Sf
'Radiological Emergency Plans and Preparedmess fn Support of Nuclear power Plants,4 Rev.)l, November 1980.
pfs document addresses the stan<<
dards set forth fn the revfaed emergency planning regulations of 10 CFR 50 and Appendfx E thereto which became effective Novenber 3, 1980.
Our review has indicated that addttfonal information and commitments. are required before. we: can conclude that your onsfte emergency preparedness
.program aeets the'smcrfterfa.
Enclose) are our. comments for which reso-lution fs necessary..
These comments supercede the review comments sent to you on January 19, 1981.,
and will bq considered the first round of comments on the upgraded emergency -play.
Your plan should be revised to ad'dress these comments fn accordance with the provisions of the revised 10 CFR 50.
8> 08989359 Enclosure; Steven A. Varga, Chief Operating Reactors Branch No.
1 Dfvfsfa~ of Licensing OFFICE)
SURNAME)
OATE P a
Revfe
~"" ""Radfa cc',
~""""See" n Comments on ion Gnergency xt"page.
uy-; ey, o nt
-'Pl'e'n.'.'"" "- 'RBkl 'DL.
MGrotenhuis; 2/5/81 Q
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NRC FORM 318 (10/80) NRCM 0240 OFFICIAL RECORD COPY
- USGPO: 1980-329 824
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UNITED STATES, NUCLEAR REGULATORY COMMlSSlON WASHINGTON, D. C. 20555 February 7, 1981 Docket Nos.
50-250 and 50-251 Dr.
Rober t E. Uhrig, Vice President Advanced Systems and Technology Florida Power and Light Company Post Office Box 529100 Miami, Florida 33152
Dear Dr. Uhrig':
We have completed our review of the Turkey Point Nuclear Station Radia-tion Emergency Plan dated January 2, 1981.
Your Plan was reviewed against the criteria set forth in "Criteria for Preparation and Evaluation of Radiological Emergency Plans and Preparedness in Support of Nuclear Power Plants,"
Rev. 1, November 1980.
This document addresses the stan-dards 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 requ-r d beforewe can conclude that your onsite emergency preparedness program meets these criteria.
Enclosed are our comments for which reso-lution is necessary.
These comments supercede the review comments sent to you on January. 19, 1981, and will be considered the first round of coments on the upgraded emergency plan.
Your plan should be revised to address these comments in accordance with the provisions of the revised 10 CFR 50.
As stated in paragraph 50.54 (s.)(3) of the new rul,e, the NRC will base its findings of a review of the FEMA findings and determinations as to whether State and local emergency, plans are adequate and capable of being imple-
- mented, 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 excercise'with-State and.local government agencies designed to test the integrated capabi-lity of. the emergency preparedness plans must be conducted as required by the new rule.
- cerely,
Enclosure:
Review Comments on Turkey Point Radiation Emergency Plan
- rga,
.Operating Reactors anch No.
1 Divisi on of Licens ing I
cc:
See next page
Robert E. Uhrig Florida Pow r and Light Company CC:
Hr. Robert Lowenstein, Esquire Lowenstein,
- Newman, Reis and Axelrad 1025 Connecticut
- Avenue, N-M.
Suite 1214
'i.
Washington, D.
C.
20036 Environmental and Urban Affairs Library Florida International University Miami, Florida 33199 Nr.
Norman A. Coll, Esquire
- Steel, Hector and Davis 1400 Southeast First National Bank'uilding Miami, Florida 33131 Nr. Henry Yaeger, Plant Nanager Turkey Point Plant
- lorida Power and Light Company P. 0.
Box 013100 t~i ami; Fl ori da 33101 1':.". Jac<
Shreve C=-,ice of the Public Counsel
? oom ',
Hol 1 a nd Building Ta 1 1 ahassee, Fl cri Ca 32304 Administrator
.Department o
Envi ronmental Rec lation 2600 5::air Stone Road Tallahassee,
. 1C 1
a 3230:
Res-iden-.
Inspector Turkey Point nuclear Generating Station U. S. Yuclea.
Regu1 atory Cow",i s s i on Post
"-.-, ~ce Box 971277 v'ua i s
n c gn.s Diction z 1 or, 'a
.:.7
EMERGENCY PLAN REVIEl'!
TURKEY POIt'T PLANT UNITS 3 8
4 FLORIDA POVER AND LIGHT COt'lPANY A.
Assi nment of Resoonsibil it Oraanizational Control The Plan does not identify specific individuals, hy title, who are in charge of each oraanization's emergency response.
(A.l.d)"
The Plan does not have written agreements for a'1 support organizations having an emergency response role>>ithin the Emerpenc<<Planning Zones.
(A.3.1 There is no discussion in the Plan of the capatility to provide 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 0
support of the aucrented emergency organizations for an extended
- period, nor the individual responsible for. continuity nf resources.
(A.4.)
F.
Onsite Emergency Oroanization The responsibility of the Emeroency Coordinator to provide protective action recommendations to offsite authorities should be covered explicitly in the Plan.in the listino of responsibilities o< this position and'lso:
in the listing of responsibilities that cannot be delegated.
--(8..2 and B.4)
- Refers to the applicable criterion listed in NUREG-0654, Rev.
1.
There are no conditions given in the Plan for higher level utility officia'ls assuming the function of fmergency Coordinator.
(B.3)
The specific emergency assianments for the plant staff members'hould be described coverino the emeraency functions and tasks described in Table B-l of the criteria.
The minimum capabilities and staffing on-shift and available within 3C minutes and 60 minutes following declaration of an emergency must also be described.
(B.5 and Table B-l)
The Plan does not illustrate, in a hlock diagram, the interfaces between and among the onsite funcitonal areas of emergency activities and offsite
- support, includino the onsite Technical Support Center (TSC), the nearsite Emergency Operations Facility (EOF), the Operations Support Center (OSC),
an" any other emergency centers.
(l'.6)
There is no discussion of logistic support for e...ergency personnel in the Plan.
(B.7.a)
The Plan does not specify ambulance transportation
- support, (8-9)
The Plan does not include copies of agreement letters for services to be provided by all support agencies
( ex; 1!estinahouse, Institute for Nuclear Power Operations, Sou.h Florida Emergency Physicians).
(B.g and C.4)
C.
Emergency
Response
Support and Pesources Althouah the Plan desionates the person who is authorized to reauest RAP A
assistance, it is not made clear where the RAP team would be expected to repor t or with whom they would maintain contact.
Section 2.3.1 of the Plan should be chanoed with 'respect to "onsite" assistance from DOE.
The Federal Emergency k!anagement Aoency (FEI".A), in,the proposed I".aster Plan (See Federal
- Register, Vol. 45, No. '248, December 23, 1980),
has desionated DDE as havina responsilili:y to coordinate all orf-site radiolooical monitoring, assessment, evaluation, and reporting activities of all 'Federal aoencies during the initial phases of an accident.
(C. 1)
The Plan does not orovide for the dispatch of a representative from the licensee to tie pr incipal offsite ~('C.
(C.2.b)
The Plan does not include letters o
aoreenen for tile additional support oroanizations identified in the Plan, page 2-".
(Ce4) 0.
Emergency Classification S stem 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 exav pie conditions, as applicable, found in Appendix 1, Section 1.4 of the Plan, page 1-8, which states "The Unusual Event class is not a emergency",
must be changed in order to comply with Appendix l to NUREG-0654 and the reporting requirements of 10 CFR 50.72, in order
to be consistent with the notification actions described in Sections 2.1.4
.and 4.4.1 of the Plan.
As it currently stands, the Plan commits to notifying dition, which does not include the Unusual Event class.
(D.l, 2)
The references to Technical Specifications in the Emergency Action Level Classification
- scheme, Tables 3-1, 3-2 of the Plan, should be converted to direct instrument readings, and the appropriate Technical Specifications included.
(0.1)
E.
Notification Methods and Procedures There is no discussion in the Plan of the means for verification.of
- messages, other than the Florida Bureau of Disaster Preparedness procedure to authenticate emergency messages from Turkey Point Plant.
(E.l)
The Plan does not include in the initial messages'nformation regarding potentially affec:ed population and areas, and whether protective measures may be necessary.
(E.3)
The Plan fails to acknowledge the requirement that notification of offsite authorities and the population of the plume exposure pathway EPZ is sub-ject to.a," 1 5 minu.e time constraint.
There is, moreover, no documenta-tion of specific prior arrangements that have been made to use public~
communications media (e.g.,
radio stations) for issuing emergency instructions to the public.
(E. 6)
'he Plan does not describe the provisions for followup messages from the facility to offsite authorities which contain information including projected dose rates and integrated dose at the projected peak and at 2, and 10, miles; recommended'mergency
- actions, including protective measures; request for any needed onsite support by offsite support organizations; and prognosis for worsening or termination of event.
(E.4.i, 1, m, n)
The Plan does not indicate that an Early t'arning System meeting the desian objectives of Appendix 3 of the criteria has heen developed.
The Plan should.address the adr inistrative and physical
- means, and the tin e reouired to promptly notifv the public of an emergency.
The Plan should commit to the estab'lishment of such a system and indicate when the system will be implemented.
(E.6)
F.
Emeraenc Communications The Plan does. not specifically state that provision for 24'-hour per da ur per ay notification and actavation of the State/local energency response network including 24-hour per day manning of "communication links" (that initiate emergency
-response ac%io'ns')
are establishe" fc.
the "Unusual Event" and "Alert".categories.
(F. l.a)
The Plan does not contain provisions for communication:
between the various ROC's and the radiological monitoring tear.s.
~F.l.d)
The communications plan does not'nclude organizational titles and alternates for both ends of the communication links.
(F.l)
. There are no provisions in the. Plan for a coordinated communication link for fixed and motile medical support facilities.
(F.2)
O'.
Public Information The Plan does not provide public recardinc
~ow they for annual disser.ination of information to the viHl be notifie~ and uP at their actions should in ar emergency, This inforration sho>>ld in~lude,.t.ut
. u no necessarilv be li. it d to:
a.
educational in on:ation on radiation.:
contact for additional in ormation; c,
protective measures, e.g.,
evacuation routes and reloca'tion centers shel terino, respiratory proteciton, radionrotective druas and d.
soecial needs of the. handicanoed";
G~n '
The Plan does not provide for a public information program which provides the permanent and transient. adult population within the plume exposure path~ay EPZ an adequate opportunity to become aware of the information annual ly.
(G. 2)
H.
Emeraenc Facilities and E ui ment The Plan does not address
.the funcitonal criteria of NUREG-0696 for the onsite
- TSC, the nearsite EOF, the Nuclear Data Link and the Safety Parameter Display System.
(H.1)
There is no discussion in the Plan of the time reouired to staff the cerate,s except page 2-41 of the Plan which specifies two hours for the OSC.
Criterion 4, page 5." of NUREG-0654 requires timely staffinc.
There is no discussion in the'lan of'hydrologic or seismic monitors onsite and offiste, that are to be used to initiate,,emergency measures in accordance with Appendix 1 to NL~REG-0654, (H.5.a, H.6).
There is no discussion
'in the Plan of wound and portable monitors.
The Plan does not describe the provisions for offsite radiological.
monitoring equipment in the vicinity of 'the'nuclear.-facility.
(H.7)
The Plan does not meet the meteorological pr ogram of. Appendix 2 of NuREG-0654, (H.e)
There is no discussion in the Plan of inspecting, inventorying and operationally checking emergency equipment!instruments at least once each calendar ouarter and after ach use.
(H. 10)
The Plan does not include, in an appendix, identification of emergency kits by general category (protective eouipment, communications eouipment, radiological monitoring equipment and emergency supplies).
(H. 11)
The Plan 'does not discuss a central point <or the receipt and analysis of all field monitoring data and coordination of sample media.
(H. 12)
Accident Assessment he Plan does net address the methods and technioues (procedures) to he used for determinino the source term of releases o~ radioactivity material fror. th> stea.
'et air eiectors, the stea~
dump val'ves, the cain stea~
sa;ety valves, and the l'nit 3 scent uel pit.
The Plan does not identify steam-driven aux i 1 iary boil er feed pu:"p extiaus t as a source of potentially contar inate". air.
(1.3)
The Plan does not specify the capabilitv of acquiring and evaluatino meteorological information sufficient to meet the criteria of Appendix 2
to t'URE6-C654.
There shall be provisions for access to meteorolooical --'"
information by at least the nearsite
Poom and an offs.ite.HRC center.
(I.5)
The Plan has not established the methodology for determining the release rate/projected doses if the instrunfentation used for assessment are offscale or operable.
(I.6)
The Plan does not describe, the capability and resources for field monitorina within the plume exposure pathway EPZ;,
( I,7)
The Plan does not,describe the methods, equipment and expertise to make rapid assessmen'ts 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.
(1.8)
The Plan does not 'describe tie capability to detect and measure radioiodine 0
- concentrations in air in the plume exposure pathway EPZ as low as 10 micro-
.curies per cubic centimeter under field conditions.
(I.g)
The Plan does not describe the means for estimating integrated dose from the projected and actual does rates and for comparing these estimates with the protective action guides.
( I. 10)
J.
Protective
Response
The Plan does not discuss eyacuati'on routes. and transportation for individuals onsite including alternatives for inclement weather, high
density 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)
The Plan does not describe the provisions for radiiological monitoring of people evacuated from the site, n'or is the decontamination capability at the assembly ar ea for evacuated personnel described in the Plan.
(J.3 and J.<)
There is no commitment in the Plan for the time 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..)
There is no explicit discussion in the Plan of providing individuals remaining or arriving onsite during an emeroency, individual respiratory protection, protective clothing and use of radioprotective drugs.
(J.6)
The Plan does not contain the time estimates for evacuation within the plume exposure pathway EPZ, in accordance with Appendix 4 to NUREG-0654,
('J. 8)
The Plan does not contain maps showino population distribution around the nuclear facility, nor does the Plan describe the means-for notifying all segments of the transient and resident population.
(J. 10.b and c}
~
The Plan does not describe the bases for the choice of recommended actions from the plume exposure pathway dur'ing emergency conditions.
(J.10,m)
K.
Radiological Ex osure Control The Plan does not describe onsite exposure guidel.ines consistent with EPA Emergency Worker and Lifesaving Activiti'es Protective Action Guides (EPA 520/1-7S/001) for providing ambulance service and'edical treatment services.
(K.l'.f and g)
The Plan does not specify that procedures shall be established, in advance, for permitting onsite volunteers to receive radia",ion exposures in the course of carryina out lifesaving and other e;.ergency activities.
(K.2)
The Plan does not provide for.assurance tnat dosineters are read at appropr iate frequencies.
(K.3. h)
The Plan does not specify action levels nr deterr'inina the need for decontamination of personnel who have become contaminated in the course of an emergency.
(K.5.a)
The Plan has not clearly established provisions or onsite contamination control measures for. drinking water and food supplies, and criteria for
';permitting return of areas and items to normal use.
(K.6.b and c)
The Plan does not describe the capability for decontaminatino relocated onsite oersonnel, includino provisions for extra clothina and decontam-inants suitable for the ty, e of contamination
- expected, witt particular attention give.", to radioiodine contamination of the si.in.
(K.7}
L.
Vedical and Public Health Su ort The Plan does not identify the primary offsite support group for transportinc victims of'adiological accidents to medical support facilitic~.
(L.4)
Recover v.and f!eentr v Planninc and Postaccident Operations There is no discussion in the Plan o.
the ke'osit~ons in the facility recoverv pla< >t~er thar the imeroency."or,.rol Cfficer..
(l'.2)
There is no discussion in the Pla-nf pcpv',a-.ion exposure estir ates.
,t:.
Exercises and Pr ills The Plan does not include varyinc scenarios
-ro." year to year so that all the r ajor elements -of the Plan are test
"=
~; -,"in a five-year period.
(N. 1. b) 12
There is no discussion of communications between the nuclear facility, State and local EOC's and the field assessment teams being tested annually.
(N.2.a)
There is no discussion in the Plan of radiological monitoring drills which involve collection and analysis of offsite vegetation and soil.
(N.2.e}
There 'is no discussion in the Plan of Health Physics. drills involving analysis of inplant liouid samples with actual elevated radiation levels, including the use of the post-accident sampling system.
(N.2.e(2))
The Plan does not describe scenarios which will include the simulated events; a time schedule, of real and simulated initi'atina events; a
narrative summary describing the conduct of the exercises; and a descrip-tion of the arranoements for and advance materials to be provided to official observers.
(~.3; c, d, e
and f)
G.
>adiolooical Fmeroencv
Response
Traininc Except for offsite utility personnel, the Plan does not describe the training to be provided fot those.offsite emergency oroanizations who may be ca'iled upon 'to provide assistance in the event of, an emergency.
(0. 1.a)
The Plan does not'include on-the spot"correction of -erroneous performance during, drills as part of the overall" training program.
(0.2) 13
The Plan does not describe the program for training and retraining of personnel in the following categories:
a.
Police and fire fiohting personnel; b.
Local support services personnel including Civil Defense/Emergency Service personnel; c.
t'edical. sup ort personnel; d.
Licensee's hea"ouarters support'personnel (the Plan addresses only the Emeroency Control Officer, the Er ergency Information Officer, and the Emergency Technical Officer'.,
e.
Personnel resocnsihle ior transmission o'cogency information anU instructions.
(O,4.c, c, h, i and ')
P.
Pesoonsibilit for t~e Plannino
. fort:
"eve'.potent periodic Review and Distribution of Emergency Pla~s The Plan does not provide for training o: individuals responsible
+cr the planning effort.
(P.'.)
The Plan does not specify thai the plan and agre'en.'ents'ill be updated as
- needed, reviewed and certified current"'o'n'an annual basis.
(P.4)
Revised pages of the Plan, dated 1/2/81, are not marked according to Criterion P.5.
4 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 impl emented by each procedur e.
(P. 7)
The Plan does not contain a specific table of contents which is cross-referenced to the criteria contained in NUREG-0654.
(P.S)
The Plan does not provideQr updating telephone numbers in emeroency procedures at least quarterly.
(P. IP.)
f'iscellaneous Comments
.Paoe 1-3 of the Plan erroneously shows the abbrev ation of the Fmer aency News Center as (ENS).
Page 1-6 of the Plan erroneously states tha the FPL Emergency
Response
Organization is shown on Fioure l-l. It should be Figure 2-1.'n page 2-31 of the Plan, the reference to Appendix, E should be, change to Appendix F.
Figure 2-6, paoe 2-33 of the Plan does not show location of the Operations Support Center.
Table 2-3, page 2-35 of the Plan is blank.
Appendix J is missing.
Figure 4-1, Turkey Point Plant Initial Notification Flow, does not include notification of unusual event to offsite agencies.
Is the beeper
- system, described on page 4-11 capable of reaching beepers in those'ortions. of monroe. County which lie within the plume exposure pathway EPZ?
If so, this should be included in the Plan.
Is the reference to Technical Support Center on the bottom of page 5-4 supposed to read interin Techn ica1 Support Cente ?.
The June 16, 1980 version of the Plan described the Dade County meteoroloaical
- tower, on page 5-6, as having a height of 30C,t.
The new plan paco. 5-6 describes the same tower as being 60 meters (approx.
180 ft.),
Which is correct?
The second paragraph of Section 5.2.1, on paoe 5-9 of the Plan, states that control room personnel* are in an isolated environment arid need pro-tective 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 wi th 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.
16
Are there any inhabited islands without ground transportation within the 10-mile EPZ?
Include in your response to reviewer's comment (J.8) on page 10 of this attachment, alfie documentation justifying the exclusion of the area of ex-tended water-way east of the plant from the plume EPZ (10-mile).
17