ML18139A867

Requests Addl Info & Commitments Re Emergency Plan Submitted 800630 to Complete Onsite Emergency Program

ML18139A867
Person / Time
Site:	Surry
Issue date:	11/13/1980
From:	Varga S Office of Nuclear Reactor Regulation
To:	Ferguson J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
References
NUDOCS 8012030812
Download: ML18139A867 (20)

Text

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e UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 Docket Nos. 50-280 and 50-281 Mr. J. H. Ferguson

• November 13, 1980 Executive Vice President - Power Virginia Electric and Power Company Post Office Box 26666 Richmond, Virginia 23261

Dear Mr. Ferguson:

We have completed our review of your emergency plan submittal dated June 30, 1980 for the Surry Nuclear Plant, Unit Nos. l and 2.

Your plan was re~iewed against the criteria stated in ~UREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Plans and Preparedness in Support of Nuclear Power Plants." This document addresses the standards in the revised 10 CFR 50 which became effective November 3, 1980.

Our review has indicated that additional infonnation and commitments are required before we can conclude that your onsite emergency preparedness program meets these criteria.

Enclosed are our comments for which resolution is necessary.

Your emergency plan should be revised to address these comments in accordance with the pro-visions of the revised 10 CFR 50.

Enclosure:

Comments on Surry l and 2 Emergency Plan cc:

w/enclosure See next page Sincerely,

1

~ Q~

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~te~. a ga~ief Operating Reactors Branch #1 Division of Licensing

Mr. J. H. Ferguson Virginia Electric and Power Company. cc:

Mr. Michael w. Maupin Hunton and Williams Post Office Box 1535 Richmond, Virginia 23213 Mr. J. L. Wilson, Manager P.a. Box 315 Surry, Virginia 23883 Swem Library Co] lege of Wi 11 i am and Mary Williamsburg, Virginia 23185 Donald J. Burke, Resident Inspector Surry Power Stat ion U. s. Nuclear Regulatory Commission Post Office Box 166 Route l Surry, Virginia 23883 November 13, 1980

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SURRY EMERGENCY PLAN {JUNE 30, 1980) GENERAL REVIEW COMMENTS A.

REPORT MECHANICS

1.

Pagination system is inadequate.

Reader cannot easily find a specific section when needed.

In Text references should be to a specific page number where possible.

~::e.

2.

Index pages at the beginning of each section are not properly identi-fied (a title rather than just "Section II is needed).

3.

Index pages do not include the page numbers for the indexed subjects.

4.

Section 1 - Definitions, should be alphabetized.

• B.

GRAPHICS

1.

Graphic matter should be placed in or near the text in which it is referenced.

2.

Many of the graphs, maps, and tables are either illegible or not under-standable due to poor copy quality, cluttered original, or simply poor layout.

C.

ERRORS

1.

Section 5.7 referenced in item A.l.a of the cross reference index does not appear in the Plan.

2.

Page 4.16 (dated 5/1/80) of the Plan is blank.

3.

Section 5~.4.6 {page 5.26-5.27?) is missing from the Plan.

4. Section 5.4.8 has no title in the Plan (page 5.28).

5.

Population distribution map (page 6.2a) is based on 1960 data which is unacceptable.

At least 1970 data shall be used and the general basis for the 1980 projections shall be presented.

Further, the outer two, due east, sections contain no population numbers at all.

6.

Page 7.20 is a duplicate of the instrument list on page 7.19, with the exception of the 3 ea-Eberline E-400 1s.

7.

Figure 7.3 shows no direct line of communications between the Virginia State EOC and the State Bureau of Radiological Health Mobile laboratory.

8.

Section 7.2.3.2 referenced in item F.l.b of the cross reference index, does not appear in the Plan.

9.

Section 8.1.2.j referenced in item 0.2 of the cross reference index, does not appear in the Plan.

10.

NUREG-0654 criteria 0.5 is not addressed in the cross reference index.

SPECIFIC COMMtNTS ON THE S:URRY, EMERGENCY-PLAf( CJ-UNE"30, 1980 T NUREG - 0654 CRITERIA A. l a&b A. l.c A.2.a A.3 r.~MMENT/QUESTION

• The Surry Emergency Plan (hereafter called either "the Surry Plan or "the Plan 11 J does not properly address the use or private organizations as part of the overall response organization even though such organizations are identified in the Plan (e.g. page 5.13 - Radiological Count Laboratories, etc.).

Nor are the concepts of operation~ of these organizations and their interfaces specified. Fur-ther the Plan does not contain letters of agreement with such organizations as private laboratories, hospitals or Federal, agencies such as FEMA, NRC, EPA, FAA, NOAA, and other appropriate bodies.

The Surry Plan shall contain letters of agreement and specific concepts of operations/interfaces for all organizations which VEPCO will rely upon for speci-fic services/aid during an accident at the Surry Plant.

• The Surry plan depends heavily upon the provisions for assistance contained in other emergency plans (Such as the Commonwealth of Virginia's Plan).

The Plan shall be a stand alone document.

While it is acceptable to incorporate, by reference, other emergency plans)the specific nature of the services and assistance expected from other organi-zations must be presented in the Surry Plan to a degree which enables the reader to determine what functions will be performed by which organizations.

Due to omissions as indicated above, the block dia-grams (see figure 5.3, 5.3A thru C) illustrating the interrelationships of the response organizations are not complete and must be corrected.

The Surry Plan does not ful-fill this criteria. The plan shall be corrected tp provide a "clear and con-cise summary" of the "primary and support responsi-bilities" as well as the "major elements and ~ey in-dividuals by title".

The Surry Plan does not fulfill this criteria.

As previously indicated, a number of letters of agree-ment are missing.

Further, the letters provided in Appendix 10.1, in many cases do not contain a level of detail which would make them meaningful (e.g.

Virginia Department of Health, Virginia Office of Emergency and Energy Services, Sheriff's Department, etc.). The letters-from the City of Williamsburg, and James City County are unacceptable as they do not make any commitments.

NUREG - 0654 CRITERIA B.1 B.5 B.7 8.8.a-d B.9 B. 10 e

SECTION - B ONSITE EMERGENCY ORGANIZATION

~OMMENT/QUESTION

.The Surry Plan generally fulfills this criteria, however, figures 5.1, 5.la and 5.lb are not easily understandable and need improvement.

The Surry Plan does not fulfill this criteria. The Plan lacks the 30 minute augmentation as required by Table B-1 of NUREG-0654.

Further, no provision is made for an on shift chemistry technician and the number of personnel to act as H.P. Technicians and First Aid Team members is one too few for each case.

The Surry Plan does not fulfill this criteria in that the VEPCO Corporate Emergency Response Plan (Appendix 10.14) was not submitted with the Surry Pl an.

The Surry Plan does not fulfill this criteria to an acceptable degree.

The information is buried in Section 5 of the Surry Plan but a much better treat-ment is found in the VEPCO Corporate Plan lwhich was not included in the 6/16/80 Surry Plan) (see comment on A.2.a).

The Surry Plan does not fulfill this criteria (see comment to criteria A.l.a-c).

The Surry Plan does not fulfill this criteria. Sec-tion 6.5.3 is vague and addresses only medical trans-port. Section 6.6 addresses local fire department support but the question of local police support is not addressed.

Nor are the letters of agreement (See Appendix 10.1) sufficiently detailed.

SECTION C - EMERGENCY RESPONSE SUPPORT AND RESOURCES NUREG - 0654 CRITERIA C.2 C.3 C.4 COMMENT/QUESTION The Surry Plan does not fulfill this criteria. If the necessary information is contained in Appendix 10.11, then the ap~endix should be included and an indication of which individuals will be sent where, shall be included in the basic plans, as well as in the appendix.

(Note that Appendix 10.ll covers only one county, additional provisions must be made to co-ver the other State and County EOC's).

The Surry Plan does not fulfill this criteria. While the pla,n does identify radiological laboratories and their response times on page 5.13, no indication is given as to agreements made with these labs for assi-stance during an accident nor the specific equipment, personnel, or capabilities of these labs.

The Surry Plan does not fulfill this criteria. The subject of outside 11 nuclear and other facilities, or-ganizations, or individuals which can be relied upon in an emergency to provide assistance 11 is not address-ed nor are there any letters of agreement for such assistance.

NUREG - 0654 CRITERIA

-0. l & D2 D.3 e

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SECTION D - EMERGENCY CLASSIFICATION SYSTEM COMMENT/QUESTION

• The Surry Plan does not fulfill this criteria.

Throughout the plan reference is made to the Virginia two classification system (Red/Yellow).

While this is acceptable on an interim basis only, until the State and local plans are up-graded, the licensee should be aware that such a system will not be acceptable in the January 1981 required submittals, at which time the four levels of classification will be required (see NUREG-0654 Appendix 1).

• The Plan does not address all of the applicaole examples of initiating conditions as specified in NUREG-0610 nor are specific instrument, para-meter or equipment status indications given for the emergency action levels {initiation conditions).

• Table 4.1 A thru D should be moved to the point in the text where they are discussed, thus, Table 4.1 A should be moved to between pages 4.5 and 4.6, etc.

• In many cases the EAL's refer to Tech. Spec. re-quirements.

These should be converted to/direct instrument readings where possible and the appro-priate Tech. Specs. should be included in the Plan.

While this criteria does not pertain directly to the operator, it i~ quite evident that the State and local plans must be upgraded to be consistant with the Surry Plan (e.g. the two classification system used by the State and local governments must be upgraded to the four cl a*ss system as described in NUREG-0610).

NUREG - 0654 CRITERIA E.2 E.3 E.6 e

SECTION E - NOTIFICATION METHODS AND PROCEDURES

~OMMENT/QUESTION The Surry Plan does not contain information suf-ficient to make this determination as State and County plans were not all included in the Plan.

The Surry Plan generally fulfills this criteria.

However, the wording and content of the messages (see *Form 6.1 thru 6.6) shall be checked and joint-ly approved by VEPCO and State and local officials.

The Surry Plan commits to the installation of a public notification system which will fulfill this criteria by July 1, 1981, however, no indication is made that the State and local officials will be re-sponsible for the activation of such a system nor is the responsible official designated.

Further, the Plan does not identify the administrative procedures which will be used to initiate or recommend the initiation of the public notification system.

NUREG - 0654 CRITERIA F. l.b F. l. c e

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SECTION F - EMERGENCY COMMUNICATIONS COMMENT/QUESTION The Surry Plan does not fulfill this criteria in that no provision is made to contact the State of North Carolina in the event of an emer-

=

gency at the Surry Plant.

The Surry Plan does not fulfill this criteria.

With the exception of DOE and NRC, no provision is made to communicate with other Federal agencies which could respond during an emergency {e.g; FEMA, FDA, EPA, Coast Guard, etc.).

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.e SECTION G - PUBLIC* INFORMATION NUREG - 0654 CRITERIA COMMENT /QUESTION G.2 The Surry Plan does not fulfill this criteria in that samples of the educational material to be provided to the public were not included in the Plan and cannot therefore be evaluated for content and scope.

G.3.b The Surry Plan does not fulfill this criteria in that no provision is made for space which may be used by the news media in the near~site EOF,

NUREG - 0654 CRITERIA H.1, H.2 & H.4 e

SECTION H - EMERGENCY FACILITIES AND EQUIPMENT COMMENT/QUESTION

• The Surry Plan does not fulfill this criteria in that the information provided in the Plan (Section 7.1) is not sufficient to make a positive finding as to the acceptability of the Surry emergency facilities.

VEPCO should refer to the require-ments of NUREG-0696 (July 1980) and the NRC letter to licensees dated 10/30/79 for further guidance.

• A much more extensive treatment of this area i~ in order as these facilities and their capabilities will play a very large part in the overall capabil-ity of the licensee being able to effectively re-spond to and recover from an accident at the Surry Plant.

• The location of the near-site EOF does not meet the criteria contained in NUREG-0696.

• The licensee should provide maps or graphic dia-grams depicting the locations lboth principal and alternate) of:

Nearsite Emergency Operation Facility (EOF)

Emergency Operations Center (EOC) {both state and local).

Onsite Technical Support Center TSC)

Control Room {no alternate)

Onsite Operational Support Center (OSC)

Two maps or diagrams shoula be provided - one of onsite location, and one of offsite location showing location of state/local EOC 1s.

The licensee should provide monitoring, either port-able or permanent, for both direct radiation and airborne radioactive contamination at the TSC.

(NRC letter 10/30/79).

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NUREG - 0654 CRITERIA H.5.a H.6.a thru c H.7 & H.8 H.10 H.11 e

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SECTION H - tCONINUEOJ COMMENT/QUESTION

• The TSC should be large enough to accomodate 25 people.

(NRC letter - 10/30/79)

The licensee should provide a permanent ventilation system which includes particulate and charcoal fil-ters at the TSC.

(NRC letter - 10/30/79)

The Surry Plan does not fulfill this criteria in that the plan makes no provision for hydrological monitoring.

The Surry Plan does not fulfill these criteria. The information contained in the plan regarding this area is vague and inadequate to make a safety finding.

Section 7.3.1.2 (page 7.13) should be expanded and clarified re. offsite radiological monitoring capabilities.

The criteria for determining the acceptability of the Surry Meteorological program is still under development.

VEPCO should refer to the proposed revision l to Regulatory Guide 1.23 and Appendix 2 of NUREG-0654 for additional guidance.

The Surry Plan does not fulfill this criteria in that no provision is made to inspect the emergency equipment after each use, nor operationally check the equipment.

Further, there is a commitment to periodically calibrate only portable survey instru-mentation and count room equipment at least bi-annually.

Calibration or safety checks shall be provided for all calibratable or checkable emer-gency equipment at intervals recommended by the supplier of the equipment (e.g. DOT hydrostatic testing of air tanks, etc.).

The Surry Plan does not fulfill this criteria in that the referenced Appendix* (Appendix 10.5) did not provide an inventory by general category.

NUREG - 0654 CRITERIA I. l I.2 I. 3 a&b and I.4 I. 5 I.6 I. 7 I. l 0 i,1 SECTION I - ACCIDENT ASSESSMENT COMMENT/QUESTION The Surry Plan does not fulfill this criteria. The referenced section (6.2.3) does not contain suffi-cient information *on which to base a finding.

The Section further references the EPIP's which were not included in the plan.

The Surry Plan does not fulfill this criteria in that the subject of in-plant iodine monitoring capability is not explicitly treated in the plan.

I The Surry Plan does not fulfill these criteria. While these criteria are mentioned in Sections 6.2.6 of the plan, no explicit treatment of this area is evident.

The reason for this criteria is to ensure that the licensee can develop effective radiological assess-ment tools based on a1wide varity of types of avail-able data (e.g. plant parameters, field measurements, etc.).

i See comment on Critetia H.8.

The Surry Plan does hot fulfill this criteria. The treatment of this subject in the plan is inadequate to make a safety finding.

See comments on Criteria I.3.a&b and I.4.

See Comment on Criteria I.2.

The Surry Plan does ~ot fulfill this criteria. While section 6.2.6 f of the plan (page 6.16) states that such relationships will be developed, they are not evident in the plan.

NUREG - 0654 CRITERIA K.2 K.4 K.6.a thru c K.7 e

SECTION K - RADIOLOGICAL EXPOSURE CONTROL COMMENT/QUESTION The Surry Plan does not fulfill this criteria.

There is no indication that a unique onsite radi-ation protection program has been developed spe-cifically for implementation during an emergency.

Further the decision-making process and reasonable consideration of relative risks for permitting on-site volunteers to receive radiation exposures in excess of 10 CFR 20 guidelines during emergencies is not evident (EPIP 1s were not included with the plan).

This criteria is addressed specifically to State and local authorities, however, the Surry Plan addresses the concept in Section 6.5.1.d the Plan. Additional bases shall be provided for de-parture from the EPA PAGS for whole body gamma doses received during lifesaving activities (i.e. the Surry lOOrem value vs the 75 rem EPA PAG).

The Surry Plan does not fulfill these criteria.

While Section 6.7 of the plan commits to having procedures for onsite contamination control, these procedures are not included in the plan.

The Surry Plan does not fulfill this criteria in that no provision is made to determine radioiodine contamination of the skin.

NUREG - 0654 CRITERIA J.2 J.5 J.8 J.1 O.a J.10.b SECTION J - PROTECTIVE RESPONSE COMMENT/QUESTION

• The Surry Plan does not fulfill this criteria in that an alternate offsite assembly area is not ad-dressed.

The Surry Plan does not fulfill this criteria. in that no provision is made to ensure that personnel account-ability can be performed within 30 minutes of the start of an emergency.

The Surry Plan does not fulfill this criteria. The basis for the evacuation time estimates is not pro-vided in the plan and the population estimates are based upon 1960 data in some areas (see general com-ment E. 5).

The Surry Plan does not fulfill this criteria. Maps showing evacuation route, sectors, relocation centers, shelter areas, or hospitals and other medical facili-ties are not included in the plan.

The Surry Plan does not fulfill this criteria. Popu-lation distributions for the outer sections due east of the site are not given.

NUREG - 0654 CRITERIA L. l e

SECTION L - MEDICAL AND PUBLIC HEALTH SUPPORT COMMENT/QUESTION The Surry Plan does not fulfill this criteria.

No provisions have been made for local and backup hos-pital and medical services. The only capabilities identified in the plan are those of the Medical College of Virginia (MCV) which is 75 minutes away from the Surry Plant.

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SECTION M - RECOVERY AND REENTRY PLANNING AND POSTACCIDENT OPERATIONS NUREG - 0654 CRITERIA M.1 M.2 COMMENT/QUESTION The Surry Plan does not fulfill this criteria. While the plan does address the means which will be used to relax protective measures (see Section 9.1), the plan does not provide the general plans and pro-cedures for recovery operations, merely a commit-ment is made to produce such procedures and plans.

The Surry Plan does not fulfill this criteria. The referenced document (Appendix 10.14) was not included in the Plan.

NUREG - 0654 CRITERIA N.l.a&b N.2.a e

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~ECTION N - EXERCISE AND DRILLS COMMENT/QUESTION The Surry Plan does not fulfill this criteria.

The licensee has confused the periodic requirements for "Exercise" with the requirements for "Drills" (See Section 8.1.2). The Surry Plan shall be cor-rected and a clear distinction made between the re-quirements for" "exercise" and 11drilin.

The Surry Plan does not fulfill this criteria in that telephone communications to the State and local governments within the plume exposure path-way EPZ are not tested monthly.

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SECTION O - RADIOLOGICAL EMERGENCY RESPONSE TRAINING NUREG - 0654 CRITERIA

0. l.a and 0.4.d & g COMMENT/QUESTION The Surry Plan does not fulfill these criteria.

No provision is madi to train police which may be called upon to provide assistance.

Further, no provision is made for training local personnel who may be called up-on to aid in the off-site radiological assessment dur-ing an emergency.

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NUREG - 0654 tRITERIA P. l P.&

P.7 P.8

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e SECTION P - RESPONSIBILITY FOR THE PLANNING EFFORT COMMENT/QUESTION lhe Surry Plan commits to providing training for those individuals responsible for Radiological Emergency Plan-ning but provides no information as to how the training.

will be provided or what the scope and content of the training will be.

The Surry Plan does not fulfill this criteria. A detailed listing of all supporting plans is not pro-vided nor is there a specific point of contact pro-vided as a sourec for those supporting plans.

The Surry Plan-rloes not fulfill this criteria. The referenced appendix does not list the implementing procedures nor provide a determination of which section of ~he plan are to be implemented by each of the EPIP's.

The Surry Plan does not fulfill these cirteria. A detailed and specific table of contents is not pro-vided nor is an index provided. It should also be noted that the >>surry Emergency Plan, NUREG-0654 Cross Referenced Index>> (page I-1 thru 3) contains numerous errors and omissions.