ML19207A492

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Attachment 3: NUREG-0849 Standard Review Plan Assessment
ML19207A492
Person / Time
Site: Vallecitos Nuclear Center, Vallecitos
Issue date: 07/01/2019
From:
GE Hitachi Nuclear Energy
To:
Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML19182A197 List:
References
Download: ML19207A492 (12)


Text

Attachment 3 NUREG-0849 Standard Review Plan Assessment Page 1 of 11 NUREG-0849 Standard Review Plan Assessment

1.0 INTRODUCTION

PLANNING STANDARD The plan should briefly introduce the type of reactor, the reactors purpose, where it is located, and the purposes of the emergency plan. The purpose of the introduction is to provide a general orientation and common understanding about the reactor and the objective of the plan for those members of the reactor organization, the public, and local and federal agencies that will read and study the plan.

VNC Evaluation Items Reference

1. The emergency plan should include the following:
a. A description of the reactor including authorized power level. 1.4
b. A description of the location of the reactor facility including 1.3 access routes.
c. Identification of the owner/operator. 1.3
d. A definition of the objective of the emergency plan. 1.1 2.0 DEFINITIONS PLANNING STANDARD Terms unique to the reactor facility or that have a special meaning when used in the plan should be defined in the plan.

VNC Evaluation Items Reference

1. The emergency plan should include definitions of words or phrases 2.0 with meanings specific or unique to the plan or reactor.

Page 2 of 11 NUREG-0849 Standard Review Plan Assessment 3.0 ORGANIZATION AND RESPONSIBILITIES PLANNING STANDARD Responsibility for planning and implementing all emergency measures within the site boundary rests with the owner/operator of the reactor facility. The plan shall describe the emergency organization that would be activated to cope with radiological emergencies that includes the on-site emergency organization and any augmentation from off-site groups. Persons or groups that will fill positions in the emergency organization should be identified by their normal everyday title.

VNC Evaluation Items Reference

1. The emergency plan should describe the following organizational considerations:
a. The functions as applicable to emergency planning of Federal, 3.2 State, and local government agencies and the assistance that they would provide in the event of an emergency.
b. The emergency plan should describe the reactor's emergency 3.1 organization, including augmentation of the reactor staff to provide assistance for coping with the emergency situation, recovery from the emergency, and maintaining emergency preparedness. 10.2
c. The emergency plan should describe the arrangements and 3.3 agreements, confirmed in writing with local support organizations that would augment and extend the capability of the facility's emergency organization.
d. The emergency plan should describe a block diagram that Figure 3-1 illustrates the interrelationship of the facility emergency organization to the total emergency response effort. Interfaces between reactor and other onsite emergency organization groups and offsite local support organizations and agencies should be specified.
e. The emergency plan should describe capability of the emergency N/A VNC organization to function around-the-clock for a protracted period NTR of time following the initiation of emergencies that have or could have radiological consequences requiring around the clock emergency response.
f. The emergency plan should describe the identification by title of 3.1.1 the individual in charge of directing emergency operations, including a line of succession, and responsibilities and authorities and those responsibilities which may not be delegated (such as notification and protective action decisions).

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g. The emergency plan should describe the identification by title of 10.2 the individual, including a line of succession, and authority and responsibilities for coordinating emergency preparedness planning, updating emergency plans and procedures, and coordinating plans with other applicable organizations.
h. The emergency plan should describe the identification by title of 3.1.1 the individual, with a line of succession, responsible for relating information about the emergency situation to the news media and the public.
i. The emergency plan should describe the identification by title of 3.1.3 the individual, with a line of succession, in charge of radiological assessments including his/her responsibilities and authority for onsite and offsite dose assessments and recommended protective actions.
j. The emergency plan should describe the identification by title of 3.1.1 the individual, who may authorize reentry into the reactor building or portions of the facility that may have been evacuated during the emergency.
k. The emergency plan should describe the identification by title of 3.1.1 the individual authorized to terminate an emergency and initiate recovery actions and be responsible for informing the emergency organization of planned organizational actions or changes.
l. The emergency plan should describe the identification by title of 3.1.1 the individual, who may authorize volunteer emergency workers to incur radiation exposures in excess of normal occupational limits.

Page 4 of 11 NUREG-0849 Standard Review Plan Assessment 4.0 EMERGENCY CLASSIFICATION SYSTEM PLANNING STANDARD The emergency plan should describe several classes of emergency situations covering the spectrum of emergency conditions that involve the alerting or activating of progressively larger segments of the emergency organization. To provide for improved communications between the licensee, Federal, State and local agencies and organizations, the most severe accidents are standardized in four classes of emergency conditions which group the accidents according to severity of offsite radiological consequences. Each emergency plan should include only those standard classes appropriate for dealing with accident consequences determined be credible for the specific facility. Most research reactors have potential emergency situations which may occur (e.g., personnel injury with contamination, fire, etc.) that have less severe offsite consequences than the least severe standard class, "Notification of Unusual Events."

For some research reactors, no credible accidents are postulated which result in consequence matching the least severe class. However, planning for onsite emergencies is important. Preparedness for the onsite emergencies should be accomplished by identifying them and including in the plan those elements of this standard commensurate with the postulated emergency situations.

Each class of emergency should be associated with particular emergency action levels and with particular immediate actions to provide appropriate graded response.

VNC Evaluation Items Reference

1. The emergency plan should contain:
a. An emergency classification system consistent with the planning 4.0 standard. 5.0
b. In an Appendix to the plan, a listing by title of implementing REP procedures for each class of emergency. Appendix 2 (new SEPs to be developed after approval)

Page 5 of 11 NUREG-0849 Standard Review Plan Assessment 5.0 EMERGENCY CLASSIFICATION SYSTEM PLANNING STANDARD Because of the wide diversity in research reactors (power level, engineered safety features,' site. environment, etc.), those conditions which might initiate or signal a radiological incident having particular offsite consequences will vary widely among facilities. Action levels may be specified for effluent monitors or other plant parameters for which the dose rates and radiological effluent releases at the site boundary can be projected. To establish effluent action levels, facilities that have meteorological information available-may base the action levels on actual Meteorological conditions; otherwise, the criteria for downwind concentration, Section 4 of ANSI/AHS 15.7-1977, R1986 (withdrawn) "Research Reactor Site Evaluation," should be used. Each emergency plan should establish emergency action levels appropriate for the specific facility and consistent with Appendix I. The emergency plan should include emergency action levels to initiate protective actions for members of the general public onsite. The protective action guide (PAG} shall be 1 rem whole body or 5 rem thyroid.

VNC Evaluation Items Reference

1. Each licensee's emergency plan should contain:
a. Emergency action levels which are appropriate to the specific 5.0 facility and consistent with Appendix I. To the extent possible specify effluent monitors used to project dose rates and radiological effluent releases at the site boundary.

6.0 EMERGENCY PLANNING ZONE (EPZ)

PLANNING STANDARD As part of emergency planning, the reactor owner/operator of a facility that identifies radiological emergencies which result in offsite plume exposures exceeding 1 rem whole body or 5 rem thyroid should identify an emergency planning zone (EPZ). The postulated radioactive release from credible accidents provides the basis for determining the need for an EPZ. The size of the EPZ should be established so that the dose to individuals beyond the EPZ is not projected to exceed the PAG. As an alternative to performing such calculations, the EPZ sizes in Appendix II may be adopted according to the power level.

VNC Evaluation Items Reference

1. Ensure that the emergency plan identifies the EPZ. 6.1
2. If the EPZ is not consistent with Appendix II, the plan shall include an 6.2 acceptable basis for the EPZ.

Page 6 of 11 NUREG-0849 Standard Review Plan Assessment 7.0 EMERGENCY RESPONSE PLANNING STANDARD Emergency response measures should be identified for each emergency. These response measures should be related to the emergency class and action levels that specify what measures are to be implemented.

VNC Evaluation Items Reference

1. The emergency plan should cover the following notification information for emergency response:
a. The actions to notify and mobilize the emergency organization 7.1.1 and the applicable offsite support organizations for each 7.1.2 emergency class.
b. The location{s) of current notification lists. 7.1.1 3.1
c. Describe the contents of initial and follow-up emergency 7.1.3 messages to the NRC and, when applicable, to offsite authorities. To the extent known, these messages should include the following:

(1) Name, title and telephone number of caller, and the location of the incident and the emergency class.

(2) Description of emergency event.

(3) Date and time of incident initiation.

(4) The type and quantity of radionuclides released or expected to be released.

(5) Impact of releases and recommended offsite emergency actions.

d. A method is established to insure that offsite authorities have 7.1.3 received the initial message and that it is authentic.
2. The emergency plan should cover the following notification assessment considerations:
a. A description of methods for gathering and processing 7.2 information for assessment actions.

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3. The emergency plan should provide a summary description of those 7.3 actions that could be taken to mitigate or correct the problem for 4.1 - 4.3 each emergency class.
4. The emergency plan should describe protective actions appropriate for the emergency class. The emergency plan should include the following:
a. Conditions for either partial or complete onsite evacuation, 7.4.1 evacuation routes, and primary and alternate assembly areas.
b. Methods to ensure personnel accountability and the segregation 7.4.1 of potentially contaminated personnel. 7.4.2
c. Protective measures and exposure guidelines for emergency 7.4.4 personnel.
d. Provisions for isolation and access control of facility areas to 7.4.2 minimize exposures to radiation and the spread of radioactive 7.4.4 contamination.
e. The methods for monitoring radiation dose rates and Onsite contamination levels, both onsite and offsite, including provisions 7.4.2 for transmitting collected information and data to the element of 7.4.4 the emergency organization responsible for accident Offsite assessment.

N/A VNC 8.0 EMERGENCY FACILITES AND EQUIPMENT PLANNING STANDARD The emergency plan should briefly describe the emergency facilities, types of equipment and their location.

VNC Evaluation Items Reference

1. The emergency plan should describe an emergency support center 8.1 (ESC).
2. Representative types of monitoring and sampling equipment to be used for accident assessment and their location. These should include:
a. Portable and fixed radiological monitors. 8.2
b. Sampling equipment. 8.2 Page 8 of 11 NUREG-0849 Standard Review Plan Assessment VNC Evaluation Items Reference
c. Instrumentation for specific radionuclide identification and 8.2 analysis.
d. Personnel monitoring equipment. 8.2
e. The plan should also describe non-radiological monitors or indicators that may provide pertinent information; for example:

(1) Reactor instrumentation. N/A VNC NTR (2) Fire detectors, earthquake sensors, etc. 8.2 (3) Source of meteorological data representative of facility 8.2 location.

3. The emergency plan should identify those measures that will be used to provide necessary assistance to persons injured or exposed to radiation. The capabilities for decontamination, administering first aid, transporting injured personnel, and arrangements for medical treatment should be described. The following items should be included:
a. Facilities for personnel decontamination. N/A VNC NTR
b. Methods for handling and transporting contaminated injured 8.3 personnel.

3.3.2

c. Written agreements with hospitals to ensure that medical services are available and the staff is prepared to handle radiological emergencies.

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4. The emergency plan should adequately identify the emergency 8.4 communications systems that will be available to communicate instructions and information both onsite and offsite through-out the course of an emergency.
5. Facilities planning for a site area emergency should establish reliable N/A VNC means of communication, e.g., public telephone and radio, that is NTR compatible with local offsite support groups.

9.0 RECOVERY PLANNING STANDARD This element of the emergency plan should describe the criteria for restoring the reactor facility to a safe status including reentry into the reactor building or portions of the facility that-may have been evacuated because of the accident. The operations to recover from most severe accidents will.be complex and depend on the actual conditions at the facility. It is not practicable to plan detailed recovery actions for all conceivable situations.

VNC Evaluation Items Reference

1. The emergency plan should specify:
a. That recovery procedure(s) will be written and approved as 9.1 needed.

Page 10 of 11 NUREG-0849 Standard Review Plan Assessment 10.0 MAINTAINING EMERGENCY PREPAREDNESS PLANNING STANDARD The emergency plan should describe the elements necessary for maintaining an acceptable state. of emergency preparedness. A description should be provided of how the effectiveness of the emergency plan will be maintained, including training, review and update of the emergency plan and associated implementing procedures, and maintenance and inventory of equipment and supplies that would be used in emergencies.

VNC Evaluation Items Reference

1. The emergency plan should describe an initial training and periodic 10.1.1 retraining program designed to maintain the ability of emergency response personnel to perform assigned functions for the following:
a. Personnel responsible for decision-making and transmitting 10.1.1.1 emergency information and instructions.
b. Personnel responsible for accident assessment. 10.1.1.2
c. Radiological monitoring and analysis teams. 10.1.1.3
d. First aid and rescue personnel. 10.1.1.4
e. Medical support personnel. 10.1.1.5
f. Police, security, ambulance and fire-fighting personnel. 10.1.1.6
2. The emergency plan should provide for:
a. Annual onsite emergency drills, to be conducted as action drills. 10.1.2
b. Provision for critiques of all drills, including timely evaluation of 10.1.3 observer comments and correction of identified deficiencies.
c. Development of written scenarios for conducting annual action 10.1.2 drills.
3. The emergency plan should provide for a biennial review and update 10.2 of the emergency plan and implementing procedures and agreements with offsite support organizations and agencies including:
a. Reviews and approvals by those responsible for emergency 10.2 planning.
b. Incorporation of modifications resulting from action drills *or 10.2 changes in the facility or environs.

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c. Timely forwarding of approved amendments to the plan, 10.2 agreements, and implementing procedures to authorized individuals, agencies and support organizations.
4. The emergency plan should describe the provisions to ensure operational readiness of emergency communications and emergency health physics equipment by including:
a. Required maintenance and minimum calibration frequency. 10.3
b. Functional testing including minimum frequency. 10.3
c. Minimum frequency of inventory for equipment and supplies. 10.3