ML19254F052

Forwards Emergency Planning Review Guideline 1,Revision 1, Emergency Planning Acceptance Criteria for Licensed Nuclear Power Plants

ML19254F052
Person / Time
Site:	Pilgrim
Issue date:	09/07/1979
From:	John Miller Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
Shared Package
ML19254F051	List: ML19254F052
References
FOIA-80-186, RTR-NUREG-0610, RTR-NUREG-610 TAC-46275, NUDOCS 7911050506
Download: ML19254F052 (71)

Text

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UNITED STATES

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NUCLRAR REGULATORY COMMISSION

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SEP 7 19~9 MEMCRMOUM FCR: Ecergency Planning Staff FRCM:

James R. Miller, Acting Assistant Direc:ce for Site and Safeguards SUSJECT:

EMERGENCY PLANNING REVIEW GUIDELINE NUMBER CNE -

REVISION CNE - EMERGENCY PLANNING ACCEPTANCE CRIHRIA FCR LICENSED NUCLEAR PC'n'ER PLANTS Enciesed is Emergency Planning Review Guideline Number One - Revision One - Energency Planning Acce :ance Cri:eria f:r Lf:ensed Nuclear ? ner Plants.

The review guideline super:ades.9eview Guideline Mu= er One da ed Augus: 17, 1979.

TM: review guideline is te be used to review upgraded emergency ;lans for 0;erating plants and near ter: CL's. Tais review guiceiine has been a;creved by NRR =anagecent.

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[4+.ams i.. Milfer, Acting Assistan: Direc cr f:r Site and Safeguares Civisica cf 0;erating Reac::rs E c.lcsure:

As stated 1268 100 gg gb\\nQa' 6

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Emercency Plannine Accactanca Criteria for Licensed Nuclear Pcwer Plants INTRODUCTION Licansees will submit updated facility plans either before or aftar the sita visit by the NRR review taam, together with the acpropriata Stata and local plans, which will be evaluatad cellectively against the requirements of Appendix E to 10 CFR Part 50, the positions sat forth in Regulatory Guide 1.101, and the accep'tance criteria contained herein. The critaria contained herein will be used in conjunction with the afore entioned regulations and guidanca to usure that the fellcwing emergency planning cojectives have been achieved.

(1) Effective coordination of e=argency activities among all organi:ations having a respense role.

(2) Early warning and clear instructicns to the ;cpulation-at-risk in the event of a sericus radiclogical emergency.

(3) Centinued assessment of actual cr petantial consecuencas both ensita anc cffsita.

(4) Effective i=plementation of emergency measures in the envirens.

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(5) Centinued maintananca of an adequata s sta of emergency preparecness.

It sneuld be notac that the planning herein icentified for tae E=argency Planning Iones (NCREG-0395) need act be fully f cismented at whis time in cedar te meet the acca:tance critaria. Evaluatien of the planninc for tae plume ex:csure pat.way snculd ba basec en wnat is feasi e:

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1268 101

2 4f these reviews with firm c:mmitments to extand such provisions throughout the entire Emergene/ Planning Zone by Januar/1,1981. Also, the Cecmission has not yet spoken en the "50 mile" aspect of the Emergency Planning Zone associated with the ingestion pathway. Hence, the usa of the relate'd accept-ance critaria in the. evaluation need not be applied to the full extant implied in NUREG-0396. Hewever, the plans must demonstrate that a' capability exists to pretact the public from exposure via the ingestion pathway.

ACCEPTANCE CRITERIA I.

To assure effective c:crdination of emergency activities among all cegani:stiens having a res;cnsa role A.

Licensee plans will:

1.

Provide for an emergency coordinator at all times, including an individual ansita at the time of an ac:ident, having the authority and responsibility to initiata any emergency actiens within the provisions of the emergency plan, including the exchange of informatien with authcrities res;cnsible for c:ctdinating offsita emer;ency measures.

2.

Provida for the augmentation of the minimum :nsita emergene/

crganizatien within 50 minutas fer all classes of emergencies above the "alertd level.

3.

Identify and define by means of a biccx diagram the intarfacas between and ascng the ensita functi:nal areas of emergency activity, licansee her2:uartars su:xrt, 1ccal sersicas su: pert, anc Stata and local govern =ent res;cesa crqani:athns. The

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1268 102

3 above shall include the ensite technical support canter and the cperational support canter as discussed in NUREG-0578.

4.

Describe the location and role of the ensite tecnnical support canter. See itam 3 of Section 3.3.3.5 of Appendix A ts NUREG20573 (e.g., ccemunications with NRC and the offsita emergenef cperations centar).

5.

Describe the location and role of the ensite cperational sucport See itam 3 of Secticn 2.2.2.c of Appendix A to center.

NUREG-057S.

Provida for the dispatch of a representative to the principal 6.

emergene/ cceratiens cen ar established by the offsite agencies (nct required if licensae's offsita emergenef cperation centar is at.the same locatien as that dascribed in item I.B.4).

S.

Stata/ local plans will:

1.

Identify authorities responsible for coordina-ing offsita

. emergency activities for the Emergency Planning Icnes discussed in NUREG-0395.

2.

Designate tne authority and specific respensibility for eacn cocedinating authority.

Describe the concept of operations frem the perspective of each 3.

official having a coordinating rele, including the cperational intar elationships of all Federal, Stata, and 1ccal organi: 2-tiens previding emergene/ succer. services.

3 1268 103'

4 4.

Identify the predetermined location of the bergency operttiens l

Center to be used for the coordination of all offsita emergency suppcrt activities.

5.

Describe the c:m unication plan for emergencies, including titles and alternates for bota ends of the c:=unication links and the primary and backup means of c:mmunication. Where c:nsistent with the agency function, these plans will include:

a.

Provision for prcmpt and assured activation of the.5 tate / local emergency response network.

a.

Pr: vision for administrative c:ntrol~ metneds f:r assuring effective coordination and c:ntrol of Feceral, Sta a, anc local emergency support activities.

c.

Provisien for c:=unicatiens with c:ntingucus State /lecal governments within the bergency Planning I:nes.

d.

Provision for c:mmunications with Federal emergency res;cnse o~;ani:stiens.

e.

Provision for c:mmunicatiens with the nuclear facility, Stata and/cr local emergency c:eratiens centers, and field assessment teams.

II. To assure early warning and clear instructions :: the ;cpula-1:n-at-risk in the event of a sericus radiological emergency A.

'icansee ;1ans will:

1.

? mvide an emergency classifica:icn senese as set f:rth in Regulat:ry Guide 1.101.

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5 2.

Establish specific criteria, including Emergency Action Levels (EAL) as apprcpriata, for ceclaring each class of emergency.

a.

EALs for declaring a " site emergenc'/ will incidde instrument readings and system status indications carresponding to an airi:orna fission product invent:ry within c:ntair. ment

'which, if released, c:uld result in effsite deses equivalent to the lcwer limit of the EPA Protective Action Guides (PAG) for exposure to airt:cene radicactive materials.

b.

• EALs for declaring a " general emergency" will incluce instrument readings and systam status indicaticas corres:ending to an airborne fissien pr: duct inventory within c:n ainment which, if released, csuld result in offsite doses equivalent to the upper limit of the EPA Protective Action Gufdes (PAG) for exposure to airborne radicactive matarials.

l 3.

Provide a clear and explicit metaccology for relating EALs ts PAGs.

t.

Icentify the onsita capacility and resourcas to prc:erly assess and catagori:e ac:fdents including:

a.

Instrumentation for cataction of inadequata c:re c: cling.

See itam 3 of Section 2.1.3.b of Ap=endix A to NUREG-0573. "

• b.

Radiatien menitors. See itam 3 of Section.2.1.3.b of Appendix A :: NUREG-0573.

5.

Provide for rec:= mending protactive ac:fons to tna accre:ria:a

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Stata and iccal authcrities, basec ;: projected c:se :s tne populatien-at-risk, in acc:rdanca with the rec:mmencation set forth in Table 5.1 of the Manual Of P Otactive Actic l-7gS a 1268 105.

6

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and Protective Actions for Nuclear Incidents, E?A-520/1-75-001.

Upon declaration of a " general emergency", imediate notification shall be made directly to the offsite authorities resjonsible for implementing protective measures within the bergency Planning Zone as discussed in NUREG-0396.

6.

Cescribe the onsita cimmunications capability fer assuring contact with the offsite authorities responsible for implementing protective measures including a primary and backup means of cerxtunications.

7.

Pnvide for periedic disseminatien of educational infor.mation to the public within the plus exposura bergency Planning hne regarding the pctential warning =ecedology in the event of a serious accident.

'-'lecal p1ans will:

L.

'1 'tify authcrities having a respense role within the Sergency 1ing Zone as discussed in NUREG-0396.

'se.ignate the autacrity and specific res;cnsibility for each of the responding authorities.

J.

!rovice for 24 hcurs/ day manning of communication link by authorities res;cnsible for i.olementir.g offsite protective measures.

4.

i. uide an emergency classification sche.ne that is consistent with that established by the licensee.

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5.

Describe : s riscu-r.as tha: will te used if necessary :s provice I

early warning and clear instructicns to the pcpulace witnin toe 1268 106 1%$d e

7 Emergency Planning Zone associated,with the plume exposure pathway (NUREG-0396) within 15 minutas fclicwing notification frem the facility operator (e.g., tcne alert systams, sirens and radic/TV).

6.

Previde for posting information regarding the potential warning

' methodology and expected respense in areas visitad by transients within the Emergency Planning Icne (e.g., recreational areas).

7.

Identify prewritten emergency messages fer respense organi:ations and the public consistent with the classification scheme.

Pro'isiens for testing the overall c:=munications link to 8.

v assure that the critaria specified in itam 5 amove is me. cn a cantinuing basis.

III. To assure c:ntinued assessment of actual or potantial c:nsequences both ensita and effsite A.

Licensee plans will:

1.

Identify the cnstie cacasility and resourcas to previce valid and c:ntinuing assessment thecugneut the ecurse of an accicent including:

a.

Pest.accidant sampling capability. See item 3 of Secticn 2.1.2.s of Ascendix A to NUREG-0573.

b.

In plant iccine instrumentatien. See itam 3 cf Section 2.1.3.c of Apcandix A to NUREG-0573.

c.

Plots snewing tas c:ntain=ent radiation scnit:r reading vs. time fslicwing an ac:ident for incicents involving g\\ h

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1268 107

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100% release of coolant activity,10C% release of gap activity,1% release of fuel invent:ry, and 10% release of fuel inventory.

2.

Ident,1fy the capability and resources for field monitoring in the environs of the plant including the additional dosimetry specified in the revised technical positica issued by the NRC Radiological Assessment Branch 'for the Environmental radiological monit: ring program.

3.

State /lecal plans will:

1.

Idencify the agencias having a radiclogical assessment r:le within the E=argency Planning Zones as discussed in NUREG-03SS, including the lead agency for data coordination.

2.

Designate the specific responsibilities for each agency having an assigned assessment role.

3.

Cascribe the arrangements estaclishec with the Department of Energy Regicnal Cecrd'nating Office for radiological assistance uncer the RAP and IRAP programs.

a.

Cesignate a centrali:ed c:ordina:1cn center for the receipt and analysis of all field monit: ring data.

5.

Descrice the methods and equipment to be ecclcyed in detarmining the magnitude and locatiens of any radiological ha: arcs folicwing liquid er gasecus radicactivity releases.

1268 108

9 IV.

To assure effective implementatien of emergency measures in the eavir:ns A.

1.icenses plans will:

1.

Provide writtan agreements with each Federal, State, and local agency and other support organt:sticns having an emergency response role within thd E=argency Planning Zones as ciscussed in NUREG-0395. The agreements will identify the e=ergency I measures to be provided and the cutually ac:eptacle crita. ia for their fectementation.

3.

Stata/iccal plans will:

1.

Designata protactive action guides and/or other criteria to be used for i=plementing specific protective actions in accordnace with the rec:mmendations of EPA regarding exposure to a esdicactive gasecus ple=e (E?A-520/1-75-001) and with those of HENFCA regarding radioactive c:ntamination of human f:cd and anisal faecs as published in the Feceral Register of Decam:er 15, 1973 (43 FR 53790).

2.

Cesignata the informational neecs (e.g., cose ratas, projected dose levels, c:ntamination lavels, ariberne er watar:cene activity levels) for implementing the pretac:fve acticas icentified in itam 1 above.

3.

Describe the evacuation plan and/or other protactive measures for the E:ergency PTanning 2:ne asso,ciatac witn tne pluce ex;csure pathway (NUREG-0396) inclucing:

1268 109

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10 a.

Ma;s shewing evacuation routes as well as relocation and shelter areas.

b.

Pcpulation and their distribution around the nuclear facility.

'eans for notificatien of all segments of the transient M

c.

and. resident pcpulation.

d.

Plans for ;:rotacting those perscns wncsa =chility may be i= paired due to such facters as institutional ::nfinement.

Provisions for the 'use of radicprotective drugs, particularly e.

for emergency workers, including quantities, stcrage, and

=eans of distribution.

f.

Means of effecting relocation.

g.

Potantial agrass rautas and their projected traf.fic capacities under emergency use.

h.

Potantial is:ediments to use of egress reutas, and ;ctantial contingency measures.

4 Cescribe the protective measures t be used for the Imergency

?lanning Z:ne asscciated with the ingestien pa way (NUF.EG-0255) f aclucing the metaccs for protecting the ;u lic fr:m ::nsum::-icn of c:n'a inazad factstuffs.

5.

Provide for maintaining dose esc:rds of all potentially ex:csed emergency workers involved in rescense activities.

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f 1268 110

11 To assure continued maintanance of an adaquata stata of emergency precaredness

• /.

A.

!.icenset plans wir :

1.

Previde, in addition to the drills and exercises identiffad in Regulatory Guide 1.101, a joint exercisa invciving Federal, Stata, and 1ccal respensa organi:aticos.

The scoge of such an exercise should tast.as much of the emergency plans as is reasonably achievable without involving full public participation.

Definitive performance critaria will be established for all leve'1s of participation to assure an objective evaluaticn.

This jcint tast exercise will be seneduled aucut enca every five years.

3.

State /lecal plans will:

1.

Previde for emergency drills and exercisas to tast and evaluate the res;cnse role of the agency, including provisions for critique by qualified ebservers.

2.

P evice for participation in the joint Feceral, State, locai anc licensee exercise cascribed in A.1 acove.

3.

Describe the training program for.hese indivicuais having an emergency responsa assignment.

4.

Provide for periodic review and ucdating of the emergency respcase ;1ans of the agency.

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1268 111

NRR Lessens learned Task Feree Short-Teri Recommencatiens TITLE:

Instrumentation for Cetecticn of Inadecuate C re C:oline in PVRs anc d'aRs (sectien 2.1.3.3) 1.

INTRCCOCTICN General Casign Criterien 13. " Instr.=untation and Control," of /ppendix A to 10 C.~R 50, requires instramentation to monitor variables "... for accident c:nditions as a;;repriate to assure adequate safety." In the past, GCC

'.3 was,

not intersreted ts require instrumentation to directly e.nitor watar level in the reacts? vessel or the adequacy of core c:oling. The instrumentati:n available en sc=e operating. reactors that c:uld indicats inadequate core c:oling includes core, exit thermocouples, es1d leg and het leg resistance tarnerature detec:ces (RTDs), in-core neutren detectors, ex-core neutron catect:rs, and reactor c:olant pu=c curt Jn.. Generally, such systems were incluced in the reactor casign to perform functions other than monitoring of core c: cling or indication of vessel water level.

Curing tne Tu!-2 ac:icent, a concitien of low water level in the react:r vessal and inace5cate ::re c:oling existed and was ne: ree:gnized for a 1:ng period cf Ofce. Tais probie:s was the result of a c:==ination of factors inc1:.cing an instfficient range of existing instru=enza: fen, inadequate emergency precedures, Inadeqto operator training, unfavorable instrument location (scatterec inf:rmatidn;, and pernaps insufficient instrumentation.

The pur;cse of this rec:=cenda.fon is s provide the react:r cperator with instrumentaI. fen, precedures, and training necessary to readily rec:gni:e and im lement actions to correct or avoid c:nditions of inadequate c:re c cling.

2.

DISCUSSION With the hindsight of TMI-2, it a ; ears that the as-designed and field-

cified instru=entation at Three Mile Island Unit : previcec sufficient inf rmatien to incica,e escuced reactor vessel c:clant level, c:re voiding, and cetarieratec c:re thermal c:nditions.

To preclude the failure to recogni:e such c:nditions in the future, it is.

a:orecriate to.accress the problem in two stages. The first is based :n the estec:1cn of recuced c:alant level er :M existence =f c:re voicing with the existing piant instr.mentatten. This wculd incluce wide range c:re exit nerecc:u les, c:1d leg and het leg RT:s, c:clant inventary c:ntrol, in-c:re a-c ex-c:re :e ac'.:rs, vessel level (5%R), react:r c: clan: pu== :urrent, and

ner incicattens f c:cTant c:nciticas, including c clan: saturation meters C :kR).

The sec:nc stage is stucy and cavale: system accificatices hat

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re:ui e major structural :narges :: One :lant and na: c:ule :e

t e-a: 4-1 iti a.ively a:ic a-.ar :: :r:vi a

.re direct incicati:n nan 134-availt:la wita ;resen. instr.menta.i:n.

These :nanges inchca ~%R

.asIal t el :stact:rs.

A-1*.

1268 112

A numcar of iceas have been discussad for the sec:nd stage by the NRC Division cf Reactor Safety Research.the ACRS, and the reactor venders. Scme of the

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pessibilities incluce pressure differential calls, c:ndue:fvity pec:es, naated thermecaucles, ultrasonic sounding, as well as ga ma and neutron void datact:rs.

H wever, we c:ncluca that detailed engineering evalua-icn is required befers design requirements for a direct levei measurement system can be specified.

3.

POSIT!CN 1.

Licensees shall* develop procedures to be used by the cperat:r to recogni:e inadecuata core ecoling with currently available instru-mentation. The licensee snall provice a cascriptien 'of Me existing instrumentation fer the Operawes c use to recognite these c:nciticas.

A detailed descripcion of the analyses neeced to form the basis for operator training and Trocacure develocment shall be. Rrovidad pursuant to another short-tarm requirement, " Analysis of Off-Neemal Conditions,

Including Natural Circulation" (see Section 2.1.9 cf this appendix).

In. addition, each PWR rhall install a primary coolant saturation meter to'previde en-line irdicatien of c:clant saturation condition.

Operator instructica as to use of this matar shall include consid-eration that is not to be used exclusive of :-her raia ac :lant parametars.

2.

Licensees shall provide a description of any additional instrumenta-tien er controls (primary or backup) proposed for the plant Oc supplement those devices citad in the preceding section giving an unambiguous, easy-ts-interpret indication of inadecuata c:re c: cling.

A description of the functional design requirements for the system shall also be included. A description of the precedures t te used with the propcsad aculpment, the analysis used in caveloping these precedures, and a schedule for installing the equipment shall be provid d.

e 1268 113 4

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3 0

6 NRR Lessens learned Task Force 5nort-Tem sec:=menca:1:ns TITLE:

!=reved Post-Ac:iden: Sam:line Ca:acili w (Section 2.1.3.al 1.

INTACQUCTICN Prcept sampling and analysis of react:r c:olan and cf containment atmos;nere can provide information ic;cr: ant : the efforts t: assass anc c:ntrol the c:urse of an accident. Chemical and radiological analysis of reacter coolan-liquid and gas samples can crevide substantial infomation regarding c:re d.2 mage and c:olant charactaristics. Analysis of c:ntainment a:mos;nere (air';

samples can determine if there is any pr:spect of 'a hycr: gen reaction in c:ntainment, as well.as pr: vide c:rs damage information.

No definitive regulatory requirements exist for cbtaining and analy:ing reac :r-coolant samples follcwing an accident. Standard Review Plan Secticn 9.5, "Pr:cass Sam;11ng System," and Section 11.5, "o : cess and Effluent Radi:'.:qi:al r

Monitoring and Sam; ling Systems," require that reac:Or ceciant sam: ling :r:vi-siens exist; however, no mention of.ac icen c:ncitions is mace anc, n's.:-i: ally, this recuirement has :een underst:cd := a:;1y caly :: normal ::nditiens.

Standarc Review Slan Section 12.5, " Meal:n Physics 3r: gram." s:ecifies ra:i:-

icgical analysis requirements for liquic and gas samples under "r: tine"

nditiens, which cces not include major ac:icents.

Standard Review Plan Sectico 6.2.5, "Cecoustible Gas Centrol in Centaincent,"

requires the cacability to menitor c:ntainment air hycrogen levels uncer accident conditions. It does not, bewever, specifically r.ecuire the ca:a:ility to cetain and analy:a a sam le of containment air. Regula:Ory Guice i.37, "Instrumentati:n to Follow the Course of An Ac:fdent," accressas en-line instru=entation ar.d coes no directly acdress the acquisition and analysis ?

liquid or gas samples.

2.

DISCUSSICH Timely informati:n fr:m reacter c: elan: and c:ntainmen at samoles can :e ine rtant :: reac.or 0;eraters for their assessment of systas c:nci:f ons an:

can influence subsecuent ac kns : maintain the facility in a safe ::n:itic..

Foilewing an ac:icant, significant amounts of fission ;recucts may ::e : resent in the reactor c clant and c:ntainment air, creating annereally hign ractation levels thr:ugecut the facility. These high ractati:n levels may celay :ne

aining of inf:rmation from samples because pec;le taxing anc analy:ing ra sam:les wcule :s ex:: sad : hign levels of radiati:n.

In additica, :ne a:n=rmai';

hign backgr:unc raciation, hign sam:le raciatien, anc hign levels Of air::- e

ntamina-icn may rencer in ;1 ant radi:legical spectrum analysis acui: men; ine: era:Te curing anc after an ac:icent.

4 ~M!-2, all Of the at:ve r:ciams -ere anc:entarse.

7 a licensee -as ::

e: arac :: :::ai an: analy:a i. a.irely mannar.. e aa:::r ::: an; an:

ntai ment air sam::es urcer ac:icen c:nci-i:ns.

he a::uisiti:n of sa:::-

lant ane ::ntairmen; air sam:las.as :ala,e: f:P se'.aral days -ci'a :trs:.- e' raciati:n ;retac-f=n precauti:ns were akan.

ncs ;ne sam:ias '.ers :: at a:.

8 A-31 1268 114

.L there were significant calcys in the r'dioicgical spectrum analysis of ue samoles.

The TMI s:ectra analysis equipment was ine;erable because of high backgr:und radiation; consecuently, the samples had to be packaged anc fic-n to a Ce;artment of Energy (CCE) laceratory for raciclegical analysis.

In summary, tha ractatica at THI caused y ne acciden-delayed accuisi:1:n of information Oc c:nfi m that significant c:re damage hac eccurred.

Prc==:

acquisition and spectrum analysis of reactor c:ciant sac;1as within several hours af tar the initial scram would have indicated that significant c:re damagt had occurred; perha;:s with such information, earlier remedial acticns could have been taken.

Similarly, analysis of an early c:ntainment air sas;ie wculd have 'ncicated the presence of hycr: gen, signif':an core ca: age, and the possibility of a hydrogen explosion in :ne c:ntai.msnt.

3.

70S!T!CN A design and Ocerational review cf the reacter c:clant and c:ntairment.at:cs;nere saraling systems shall be ::erformed to datamina the ca: ability of personnel t: prem ly c: ain (less than 1 heur) a sample uncer accident c:ncitions

• f ucut incurring a' radiation ex:csure to any freivicual in excess Of 3 and 13 3//- Rees 10 the -ncle uccy cr extremities, respectively. Accicen: c:nciti:ns shculd asstaa e Reguia:Ory Guide 1.3 cr 1.4 release Of fissicn ;r:cucts.

f na review indicates tna ;ersennel c:uld no: pr:mptly and safaly c::ain na sacci'es, adciti:nal design features er shielding sncuid be provicec s meet the criteria.

A cesign and' c;erational review of the radic1cgical s;ectra analysis facilities sna11 be perfer-ed to datamine the cacability s peces:1y quantify (less can 2 hcurs) quantify cartain radioiset pes cat are incica:crs of the degree of c:re camage.

Suca radionuclices ara nc:le gases (wnich indicate cladcing Milure), iodines and casiums (wnica incicata nigh fuel tam eratures), and acn vciatile iset: pes (which indicate fuel melting).

The initial reactor c:ciant spectrum snculd corres: enc to a Regula:Or/ Guide 1.3 cr 1.4 releasa.

The review snculd also censicer the effects of direct radiation frem piping and c: penents in ce auxiliary building and ;cssitie contamina: fen anc cirect radiation fr:m air:cene effluents.

If tha review incicates that the analyses recuired cannct be ;erf:rmed in a prem;; manner with existing ecui; ment, tren casign :ccifications or equipment pr:curemen; snail be uncertaken ::

eet :ne critaria.

P acditien ::

':r menitoring reac ce :ncitions.the radiclegical analyses, :ertain chemical analyses are necassary Precacares snail :a pr:vicac :: pe-f: m teren anc cnicrice enemical analyses assu=f ag a hignty racicactive ir.itial samela (Requ'atory Guida 1.3 cr 1.1 source arc.

3c u analysas saali te ca:asie of

eing c:::le ac ;r:::tly; i.e., ne Oce n sa=:le analysis winin an neur anc

.re cnicrice sa :le analysis witnin a sr.1ft.

.=

\\268 \\\\b

A NRR Lessens lear 9ed Task Force Snce:-Tarm Rec:mmenca:1cns TITLE:

Incressad Rance of Radistien Monitors (See:fon 2.1.3.51 1.

INTRCCUCTICN Menitors for radicactive affluents are designed to detsc: anc measure releases ass:ciated wi-h normal resctor operations and anticipated c;eraticnal cccurrancas.

Such ment:crs are required to c;erate in radicactivity c:ncentrations approaching the minimum c:ncentrations detectable with " state-of-the-art" sam le :11ection and detection me neds. These acnitors c:mply with :te critaria of Regulatory Guide 1.21 with respect Oc releases fr:m normai perations and anticipated cperational cc:urrences.

Radicactive gasecus effluent monitors designed td operate under conditions of normal operation and anticipated eperational c'e:urrencas do not have su"icient dynamic range to function uncer release c:nditiens associated with carta,in ty:es of accicents. General Design Critarien 54 of Accendix A t: 10 CFR Part 50 recuires :nat effluent disenarge patas be monit: red 'er racicactivity that may be releaset ' rem ;cstulated a :idents. The gasecus ef'luent meni cring systam 'or TMI was evalua ec curir.g the ifcansing review and was "cund ic te acacuata ':r :aicu11:ad releases 'r== possuia ac ac:icents; newever, the TMI ex:erience gives rise to a new interpretation of ;cstulatac accidents and their asscciatad releases.

The radiatf=n level insida c:ntainment is a parameter closely related := the

ctential for release of radi,cactive matarials in plant effluents.

8equlatory Guide 1.97, "Instrumantatica for Light-Water-Ceclec Nuclear Pcwer Plants is Assess Plant C:nditiens During and Fellcwing an Accident," recuires ('er plants whosa submittais for c:nstruction permit a:plications were decke:ad after 54:: ameer 30, 1977) the cacacility for measuring in-containment radiatien levels up to los rad /hr.

2.'

O!5C"55ICN At TMI-1, One acele g:s secticn of the gasecus radicactive ef'luen: menitor serving'the's.lant vent was designed to measure ef'luent ::ncantratiens up :

10 2 pCf/c: (Xe-123). Curing he initiai paases :" the a :idant, ncble gas radicactive ef'luent readings were ef" scale, wi-3' estimates of actual release c:ncentrations :alculatac to te en :ne creer of 10- gCi/c: :s 1 pC1/c:.

Stailariy, a sectica :" the TM pian: vent gasecus radicac-ive e'"luant s nit:r casignec :: detact anc measure radioiccine reisases, wnila remaining :n sca a, gave an errenaeus 1-dication :f hign racicicci a ::ntent in releases "r:m :na vent ducir.;

?.t i-i-d al :nases of -he ac:ident.

~he indicati n was caused :y

ncantrati:n :" sn:rt-lived n :le gases in -re :..ar::al cartric;e, wita ne

asenca c' e :::a gases :eing read arc er : acus, in arpretad as radi:-

:i e :, - a : ' :r "es::. sy::ac.

I'-i'ar :: c'ti: er'sta: in :ne sectian :' tra ::an

.en m:-it:r :esignac

co ac: an: easure ins =resencs :' :ar-icul a a raci:!::' < e ma:ari al ia w

Tant gasecus effluents. In this case, the presence o' ncble gasas in the gas s

Peam passing through the moniter's particulate 'iltar was sufficient to cause the particulate section cf the m nitor to read off scale and err:necusly indicata c a; large quantities of particula.as were being releasec 'r:m the plant vent.

The problem is c:nsidered to be genaric.

A recent survey o' existing gasecus e'"luent monit: ring capabilities o' cperating piants sness ua: less than 20 percent of operating plants have m:nitors that wculd have stayed en scala under ce conditions of the*THI acefdent.

It can also be snown, newever, uat the potantial releases " rem magnitude higner can was en;c:untered at TMI.cstulated accidants may te several Orders of Uncar suen cir:umstancas, ncne of the effluent menit:rs new in servica at any c;erating plan wculd remain en scale.

A gasecus radiological effluent monitor cat does not pr vide en-scale readings undar

• accident conditiens pr:vides only icwer-bounc info-ati:n en effiuent releases to na envir:nmar.. A requirement for effluen:~ enitors to nave an c: ara.ing range sufficient to pe esit en-scale readings unter ac icen ncitions is neeced t: pr: vide meaningful release infermation ':r c-si a amergency a:ticns.

Three ccmcenents c' gasacus ef'luents are usually ment.orec.

These are (a) nc:le gases (f:r gross activity relative :: xenen-133 calibra-icn); (b) racio-iodines (usually sam: led by ecliecticn on charcoal and detected and measured aither en ne basis of gross gamma activity, which assumes all activity to be iccine-131, er en the basis of a single-enannel sodium iccide gamma stec:remeter centered on the 0.354 Mev peak of I-131); and ( ) particulatas (fer gr:ss activity ecliected :n a paper or fiber fittar rela:ive to a :alibration scurce such as castem-137).

Under n:rmal c;erating c:nditions, a three-::m:enent ef'luent meni,: ring systam is ca:atle s' functioning in acesrdance witn cesign.

Reaceut, uncer ac'rmal : erating concitions, provides de plant 0;erater with a reasena:1y ac: urate.::ntinuous measurement af the a :ual instantaneous reiessa ::ncan:ra:1:n c' ncele gases.

However, One mea:urements of radici: cine cver a given time period are based en the ac:umulatien of air:cene ;articula:as or raciciacine ever a given time pericc in te "il:ar er adser::icn mecia.

!! is.scassary "Or ue plant c;eratar :s separa:aly calculata ce eTuent ::ncantration of interes en the basis of ce time rata of-change o' the m: nit:r raad:ut.

(Ne:a:

Recant im rovements invc1ving ue use Of micr::recassers nave made it cssible :: :::ain instanunecus ef'luent c:ncantra: ices ' cm intagrating-ty:e c.easurement cata by ::ntinu us calculati:n " ne -ime ra a-:'-:. ange using a uit:-in ::m:uting systam.)

~

T e MAC staf" recently ::rcuctad a survey of insu11ec ac:le ;ss af'luent

-' :rt 1. 55 Of :.'.e 65 :s a:!ng m.cisar units.

TMe

1. vay ' :':atas na:

't as:::-* ave e.s

nit:rs -nose ange excascs.*': I' /s a:.

'hase m:-'u rs -cu:: :r::a:iy..a.4 s.ays: :n sca:s :oring u st :' u e M -I ac:ica..

7 a ramtir.*ng react:rs have m: nit:rs na

-cu't ave :eer " s: ale ':r vari:us 14,- ar. s s' un early :ays :' re a :icant.

Tairty-se.an s' u s is rea:::rs a.e.: ' :rs -i n an ::er a.ge na: i s t e i cw '. Ci/sec.

.t s : :" tre rea:::Ps

+

sh8 k)

r (59 cut of 55) have cenitors with an u;cer range that exceeds uat of Oe TMI-2 statien vent monitse, wnich was off scale at accut 0.5 Cf/sec. Sased en data sutmitted by plant c; era:ces, ce installed ca:asility exists for monit: ring netle gas releases u; to a cencentratien of a:;r:xt:ately 1x103 pC1/::, wnich is a fac :e of ICs higher inan tne maximum range of the instrumen ation in use of TMI. The Task Forca notes the recent puslication of ANSI N320-H73, "Perfor=ance Specification for Reacter E:ergency Radic1cgical Monitoring Instrumentation," effective Decemcer 5,.1973. ANSI N320-1976 rec mmends an u:per detec*.ica limi; cf 105 wC1/c: for ncele gases released :c c e envirens thr:ugn plant stacks. The staff c:nsicers One u:per detac.icn limi: af 105 pCf/c: for ncele gases :: te tachnical_ly acnievable. Th'e staff understands that tecnnalegical prealems exist in =cnitoring of particulates and radicicdines in ;ctantial plant releases. C::: letely satisfae: cry equipment a;:paren:1y is not currently ava414:le on the :: mercial market. As previcusly discussed, the accident c:nditien.esults in ne presence of c m;aratively large c:ncentrattens,of sncrt-lived ne:le gases, wnich Oe detect:rs of the particulate anc iodine ~ ment:ce ccm:cner:s "see" as ;:ar-icula as anc raciciccices. The preciem is further c:m;cenced by Ne =referen.fal acs:r;;i:n of no:le gases in.ne c ar::al cartridges. Al.cL;n 2 e nc:la

ases are not retained for any suts an.ial perice of time, ue net effect of a c

ntinucus flew of gases througn the enart:al car ridge is a locali:ec c:ncentra-

.tien of nesle gases, which is "seen" by the radiciccine de act:r as radici: dine. Under normal c:erating cunditions, the radiciocine detector is c:erated as a single-channel gamma spectre =eter, f: cussing en the 0.354 'av :eak of I-131 anc rejecting ce ner= ally enesunterec Xe-133 and Kr-85. cacer accident c nditiens, newever, the short-1tved necle gases are present, several of wnich emi gamma :nciens near the 0.354 Mev gamma of I-131, thus teing registared as I-131 on u e monitor read:ut. In acci fcn, accident levels of I-13'. c:ncentrated

n the enar::al cartridge in close prcximity := the detec::r can ac::=ulate to ne extant of saturating the detector.

It has been suggested cat other adsortents may be f:end that would ;:referen-Ofally c ncentrata De raciciccines, but act tne ncele gases. If :nis is found :: te practica:la, this ::uld semewnat alleviate ne raciciccine menit >cu.g cilemma; acwever, n e shcrt-livec naale gases would stfil :e present in c e airstream ;:assing througn the acnitse anc ne monitor wcuic still give false data. A: uts time, :nere are ne demonstrated tecnniques and nc currently avalia:ie ecui::en: cat will previce for :na desired ment:: ring of raciciccines Or :ar-iculates in :lant gasecus effluents under ac:ident =ncitiens.

• • e Task cree u ncludes ina sas:iing Of plant gasecus effi: nts, wiu latera-

y ana*ysis :f sas:les sutsequen: Ic reitase, is tne Only vali :acanicue

• P enit:rir; ac:f centai releases Of radi:f ecines anc particulates.

In the 1:ser: Of /ait: en-line m:ni : ring ca:a:ility fer ac:ican -levei raiessas :f 1:' :' u' rs 17: :t.':ula es. -e stre ;:y '_rge ua: resear:n :s c:a axa-

c: : Q u :ssaI:: su:n ca:a:iiity.

A-33 3768 \\\\S

The Task For a is working with other members of the NRC staff :: urge that :ne NRC promptly acco: ANSI N320-1978 in its entirety, including these provisiens dealing with radiation =easurements in ::ntairaent A cther plant buildings, airectne.radicactivity esasurements wicain the plant, and airterne racicactivity measurements anc radiation ceasurements in the envir:n=ent. I :lementatien of

ne standard saculd taka place as seen as practical ' r these criteria consis ant

.with available equipment. It is furtner urgse tnat resaaren ;r: grams :e established for develo;=ent of instrumentatien and equf; ment to =eet the criteria that cannot be met by currently availacle equi;=ent. The mecnanisms suggested 'or implementation include adeption by referenca cf certain critaria in a revision to Regulatory Guide 1.97 and pre:aration =f cne Or mers additional Regulatory Guidas to implement the remaining critaria. 'At THI-2, the radiation monit:r in c:ntainment had a range ca:acity of los rad /hr, wnich was adequate to meet the conditions of the accident. In reviewing the monit ring capabilities of other plants, however, it is found tha: there are 'tw c:erating plants wi:M instrumentation ca;able of measuring levels in excess c' 10 rad /hr. During the initial ;cs:-a::ican.;erted a. N I, duestions arose as :: the validity of the instr,.:=ent reaceut and to tne ;eratichal enaractaristics of the instrument under the a:cicent envirencent. The Task Ferce censicers that tne in-c:ntai.. ment high-;evel =cnf :ri g instrumentatica at NI-2 was acecuate to measure the existing radia-ion levels; newever, it als: ::nsicers -hat suen instruce.tati:n sacul: c:nsis: Of a-laas: - : nance s, ea:n separatec ;nysically fr m th. ::ner, and ina. ne inst.umen a-icn system saculd be cualified to tne design criteria for safety grace instrumentation. Further=cre, the in-c:ntainment rr.diation =enit:r sneuld be ca:4tle of =easuring radiation up to ICs rad /hr, as cu-rently required in Regulatory Guida 1.57. The Task Force also rec:m=encs that the instrumentation des:ribed abcve be required for all operating piants and for ali piants new uncer c:ns ruc.ica. 3. FOSITICM The requirements associated with this ree::=encation shculd be censicered as .acvanced imclementation Of cer:af n requirements : be inclucec in a revisien to Regulator / Guice 1.97, "Instrumentatien ,.o Follow the Course of an Accicent," wnich nas alreacy been initiatad, anc in other Regulat ry Guides, wnica wil t be promulga:ad in the near-term. 1. Neele gas effluent =cnitors snail be ins alled wi n an extanced range tesigned to ' unction during ac:ident ::nditiens as well as during normal c:erating conditiens; multiple meni ars are c:nsicered to be necessarj :: :ver the ranges of intarest. a. Ncble gas effluent monit:rs with an u::er range ca:acity n' 10s pCf/c: (Xe-123) are censidered :: :e pra:.ical and sneuld be installed in all c: era:feg plants. Ncble gas oiwe-: =cnit: ring shall :e :r:vi: : ':r the ::.ai rarge :' :: :n.- a:!:n ex an:i g fe: ? a -i '. :* 1! ~.31/:: (Xa-133)

• .s a aximum Of 1-8 pCf/:: (Aa-!33).

N:f:le teni :rs are :nsicarec : :a necessarj :: ::ver :ne a gas O' intere - T e range Oa:acity " incivi:ual

rit:rs snali :veria:

"act:r Of tan. A-39 ~ 1268 119

2. Since iccine gasecus affluent =cnitors for the accider.: cencitien are nc censidered tc te practical at this time, cacactitty fer

e.. uen_. monitoring cf radicicdines for ne accident cenci:f cn shall

-e previded wi:n supling cencucted bv adscr;;ien en cha--*al c-other media, fc11cwed by casite labera cry analysis. ~ 3-In-centainment radiatien level meni:ces wi n a maximum range of ,0 rad /hr snail be insta11ec-A Cinimum of twc suen cenitors -*a' are pnysically secart.ted snail be previced. Mcniters shall ""e cesignec and qualified to function in an accident enviren=ent. _268 170 ~ e O e e A-c0 S

9 NRR Lessens Learned Task cete Snce:-Term Rec:mmencattens T*TLE: Imereved !c-31 ant I: dire ?.mstrumenta fe.9 (Sectien 2.1.9.:) 1. INT 50CUCT*CN [0.CFR Part 2O provides criteria for control of ex;esures of incividuals to radiation in restricted artas, including airecrne iccine. Since facine c:ncen-tratas in the thyroid gland, af etorne cancentrations must be kncwn in cr:er te evaluate the ;ctantial dcse : the thyrcid. If the air::rne iccine c:ncantra:icn is overestiaatec, plant ;ersennel may be required to ;erform c:eraticas functions wnile using respiratory equipment, wnich sharply ifmits c =municatien capacility and may diminisn eersonnel perfor:ance during an accident. The purpose of this racemmendation is to improve the accuracy of measurement of airectne f odine cencentrations within nuclear power plants. 2. DISCUSSION The c:ncentration of i: dine in at cs heric air is catareir.ec by ceasuring the a::ivity of i: dine adscr:ed in a car: n fittar :nr:ugn wnien ai-has teen

u=

ac. The enare:ai filtar is rencvec fr:m he ai puco an allcwed to ventilate to ;er.mit the ncbie gasas to diffuse to the at=cs;here. The filter is then counted for radioactivity ::ntent and the re=aining ac;ivity is ascribed to iodine. This precedure is conservative; however, it is ;cssible for sufficient noble gas to be adsor:ed in the char cal sc that the resulting icdins determina-tion may be unduly conservative (high). This was the case at Three Mile Island. Because the icdine concentration was greatly everestimated, plant perscnnel ;erf:r:ed their operations functions using resof ratory acui;=ent when such use was not necessary. Actual 1: dine concantrati:ns a:parently.ere

~ teicw levels requiring such ;retective actions. One ac:apta:la method Oc eliminata nis peccles is :s measure the iodine by gamma energy sce:: rum analysis. Ecuipment for sucn measurements is ::m=arcially availacle. 2. ?CS*T! N = Each licensee snail revide equi: ment anc asse:ia ad training and :r:cecuras for accurataly catarmf r.*ng the air:cene iccine ::ncantration througncut :ne

Tant uncer accident c:nditions.

2-c 1268 121

NRR lessens lear ed Task Ferce Sher -Term Rec:mmenca:icns - TITLE: Onsite Technical Sucee-t Canter (Section 2. 2. 2.51 1. INTRCCUCTICN Eacn accif cant for a c:nstruction permit is requirec by 10 CFR 50.2.*.(a) to incluce in its PSAR a discussicn of preliminary plans f:r c: ping wita emergencies. Each a;;11 cant for an cperating licanse is required ay paragr.apn 50.34(b) to include plans for ccping with emergencies in its FSAR. Acpendix E to 10 CFR Part 50 establishes minimum requirements for emergency plans. Regulatory Guice 1.101 provides more c molete guidance to te used in devel: ping t e emergency plans required in. FSARs for nuclear pcwer 71 ants. These plans are described in the PSAR and are submittad as a part c: the FSAR. They co not c:nsistently esver ce role of tachnical and management personnel curing an emergency. Similarly, there are no detailed regulatery recuirements c:ncarning the need for technical information on plant status and cceration cutsica of tne centrol reem during off-normal events. The ca:acility :c transmi.: and record vital plant data in real-time is also not a curren. requirement, nor is it recuired that as-cuilt plant drawings and upcated rec:rds te availa la :: su:: ort emergency ac.ivities. The ;u:;csa of Of s rec:c=enca:icn is.: establish a cantar cu sice Of ee

ntrol reem that acts in succert of tne c:cmand anc ::ntroi functica anc :

im: rove plant status anc diagnostic informa.icn at this locatien for use by technical and management personnel in sup;cr: cf reacter command and centrol functicns. 2. DISC'J5SION The rec mmendaf.icns given above for the role of the shift su:ervisor, us additien of a shift technical advisor, and the limitation of c:ntrol reca access are to be c:mpiamentad by this rec:mmendatien to require the esta:11sh-ment of an ensita technical su: pert cantar. The activities Of plant engineering and management persennel are an im:crtant part of ce everall station res:ensa

• o an accident and must be pre;erly defined and icgistically su= rtad. These

ecole provide tne in-denth tecnnical su

:crt of c:ntrol reca activities anc typically are res;cnsible f:r ue im lemen.a:icn of emergency precedures.

Curing the first.2 days f=11: wing the ac:f dent at ~MI-2, it was cifficult for ( senice gover cent officiais :: establish c:ntact wita senice ;1 ant managemen. I-is an:fei atad uat tan ensita tachnical sue; r: cur.ar will serve as ne f::a1 ;cin. f r such c:mmunication in c e future. There is also an indicatica f em ne events at u!-2 Sat i=:lementa:f =n of amargency plans :y persennel in the centrol r:ce a :a .c ::ngest anc ::nfuse One reacter ::erations ::ntrol activities. The tecn-ical su:: r cantar woul:

r:vica a :Ta:e, in lesa ::mmunica:1:n -ita ne con:rcl r::a se as :: have s.?'t:ian: <,n:wiaega of current an: ;r:Je: a: : ant status, f:r : e Or:ar y

' ::lementa f on Of emergency ;:r::acures. A-57 268 122

Keview of tne TMI-2. accident also snews a lack of relia:le tachnical data, information, anc records en wnien to base accident rec:very decisions. Knew- ~ hdgeable nuclear engineers were unable to undarstand the catails of pian: conditions or plant casign se as to betts - advise tte cperat:rs of a:prepriata actions for accident rec:verf. On many cc:asicas subsequent Oc the March 23 acciden, as-tufi. drawings reflecting the actual c:nfiguration of critical pcrticas cf the plant were either not availacle er centained erronecus int:r=a-f on..This situatica con.riL.,.ed to delays in accidant recovery. Over.the icng tars, ~it will pr:bably be useful to provide plant status monitoring anc rec:rding equipment in tne onsite technical support cantar. The Task Force rec:mmends that requirements in this regard be caveloped in c:njunction with requirements concerning the kind and form cf informatien to be transmitted to the NRC. 3. FCSITION Eacn c:erating nuclear pcwer plan shall maintain an ensite technical su:: rt canter sa:arate f = and in cicse reximity to the c:ntrol r:en that has the ca:a:flity.t: cisplay and t-ansmit plant s atus to these ine'vicuals wnc are c wledgeable of anc res;:nsible for angineering anc manage:an: su:: r cf reacter cperations in the event of an accident. The cen ar saali te ha:itable to the same cegree as the centr:1 reem for pcstulatad ac:idant c:nditions. The licensee snall revise his e=ergency plans as necessary t: ine:rpcra e the role and locaticn of the technical support center. A ccm:leta set f as-built drawings and other recor:s, as cascribed in ANSI N45.2.9-1974., shall be pr:cerly stered and filed at the si e and ac:essible t: the tachnical sup crt centar under emergency conditions. These d:cuments 3 hall include, but not be limited ts, general arrangement drawings, ptIDs, dping system isemetrics, electrical senematics, anc ph:: grapns of c:::enents ins alled without laycut specifications (e.g., fielc-run piping and instrument tucing). 1268 123 A-ia

NRR Lessons Learned Task Force Secre-Term Rec:=merca.icns TITLE: Onsite 0:erational Sue:cet Canter (Sectica 2.2.2.c) 1. INTRCCUCTICN Eaca a;;11 cant for a const-uction pe-mit is required by 1C CFR 50.34(a) :: incluca in its preliminary safety analysis report a discussica of preliminary plans for c:;ing with emergencies. Each applicant for an c;erating license is required by paragrach 50.34(b) to include plans for cecing with emergencies in ~ fis final safety analysis re;ce. Accencix E to 1C CFR Par 50 estaclishes minimum requirements for emergency plans. Regulatory Guide 1.101 provides scre c:mplete guidance to be usad in develcaing the emergancy plans required in 75ARs for nuclear pcwer plants. These plans do not c:nsistently c:ver the role and logistical support for operations support persennel during an emergency. ~he ;urpose of this rec:m.ae,ca. 'on is to es tablish a primary c;erational su:;crt area, to be designatac es the ensita c:erational su;;ce: cer.ar, for saf ft personnel to be in direct c:=municatir.n wita :ne c:nte:1 c::m anc ether c:arations canagers for assignment *: duties in su:;crt cf e ergency 0;erati:ns. .....J e... 1 .a. 6. w.... Caring the TMI-2 accident, cperational sue;ce: ;arsennel (e.g., auxilia y

erators not assigned Oc centrol recm, health ;hysics personnel, and tecP1icians) re

crtad to the centrol recm This contributec to :ne congestion and c:nfusion in the centrol reem. Althcugn these personnel are recuirec for ::eratient cutsice of :ne centrol reem and pernaps a few in the c:ntrol recm, :nere is a nese to restrict their accass to only those specifically requested :y the snift sucervisor to be present in the centrol recs. Thus, tr.ere is a need to establish an area in which shift personnel rtecr. for further instructions fr:m the coerations staff.

3. PCSITICN An area ts :e designated as tne ensite coerational su:ccr. center snail be establisned. It shall be sacarate faem :ne cen: ci reem and snall be the

iace to which the coerations su;cor. ;erscenel will recce

in an emergency situation. C:mmunicatiens with :ne centrol reem shall te ;r vicac.

"e emergency plan shall be revised to reflect tMe existancs of.Me center and to esta:lisa :na metacds and lines of c:m=unica ica and management. %h 1268 124

PILGRIM NUCLEAR POWER STATION EMERGENCY PLAN

GENERAL COMMENT

S 1. Review your plan against the Acceptance Criteria contained in Review Guideline #1 (Enclosed) and Regulatory Guide 1.101. 2. Plan must be inspectable. The plan must contain sufficient detail such that relationship between the commitments in the plan and site procedures. training, equipment, and capabilities is clearly defined. The plan must clearly commit to develop adequate procedures to implement its provisions. 3. A commitment to update the plan must be provided. 4. Provision must be made to assure adequate administrative control during the early phases of an emergency (Who is in' charge? Do all outside groups know who is in cnarge? Have provisions been made for 24 hour operation?). 5. A revised plan which address the Acceptance Criteria, Regulatory Guice 1.101 and these comments must be submitted to the NRC by November 5,1979. 6. The staff has conducted a preliminary -eview of the Pilgrim Nuclear Power Station Unit 1 Emergency Plan (Amendment #38. revision 1 to the FSAR), the State and Town of Plymouth plans for response to nuclear incidents. 1268 i25

. The specific comments are attached and are an illustration of the informa-tion to be provided in the revised plan and should not be addressed specifically. The following are the major points: The planning must be expanded to include the plume and ingestion a. EPZs. b. The emergency classification system must be revised to conform to the one in Draft NUREG-0610 (enclosed) and specific observable and measurable emergency action levels must be cefined for declaration of the various emergency classes. c. Provisions must be made for recommending protective actions to the appropriate state and local authorities, based un projected doses, in accordance with the recommendations set forth in Table 5.1 of the Manual of Protective Action Guides and Protective Actions for Nuclear Incidents. Upon declaration of a General Emergency, provisions must be made for immediate (less than 15 minutes) direg notificatian (including recommendations) of the autnorities responsible for implementation fo the protective measures within the plume EPZ. These authorities must then demonstrate the capability to notify the public within 15 minutes following tneir notification by the Pilgrim site. (Total notification time frem site to cuclic must be less ~ than 30 minutes). 1268 126

-3, d. NUREG-0578 items referenced in the Acceptance Criteria (2.1.3.b, 2.2.2 b and c.) will be reviewed by the TMI lessons learned task force; however, their compatability with the total emergency plan will be reviewed as part of the emergency plan review effort. The individuals who perfor.Ti all the various emergency tasks must be e. identified by job assignment and trained and tested to assure they can perform these tasks. RECIFICCOMMENTS Scope and Applicability (N.2) (1) Define site plume and ingestion EP?s which are consistent with NUREG 396. (2) Define the operational relationship between the Emergency Plan and the Site Contingency Plan when both are in effet.t. (3) List all the agencies responsible for imolementation of protective actions within the plume expost..e and ingestion EPZs. 1268 127

4_ (4) Supply a figure showing the location of the site relative to the EPZs, licensee alternate EOCs, State and local EOCs, press center. The figure must also show the jurisdictional boundaries of the response agencies. SummaryofEmergencyPlanfN.3) Revise this section to reflect other plan changes. Emergency Conditions (N.4) (5) Revise the emergency classes to conform to those contained in Draft NUREG-0610. Where appropriate, measureable the observeble criteria (EALs) for reccgnizing and declaring each emergency class must be established. The specific monitor reading or the degree of the condition used to initiate ar. emergency class must be provided such as " flood level at 15 ft," or " winds above 75 mph." Specific EALs should be estaialished for the " Example Initiating Conditions" contained in Draft NUREG-0610 (Enclosed). The NUREG-0610 " Example Initiation Canditions must be sortec into the appropriate emergency class for tne a Pilgrim site. 1268 128

5-Emercencv # lert (fl.4.1.2) (6) Revise your plan to place these events into the " Unusual Event" or " Alert" Class as appropriate. Plant Emergency (N.4.1.3) (7) Revise you plan to place these events in the " Unusual Event" or " Alert" Classes as apprepriate: Site Emercency (N.4.1.4) (8) Emergency action leveh for de:laring a Site Emergency must be defined in terms of: A. Instrunent readings or alarms that annunciate in the contro1 room, including indications and correboration of: (1) Airborne noble gas fission product inventory within contain-ment, wnich, if released, could result in offiste doses equivalent to the lower limit of the EPA plume exposure protective action guide (1 Rem) for exposure to airborne radioactive materials. (2) Effluent monitors and system status which would indicate that the lower limit of the EPA protective action guide 1268 129

. for exposure to sirborne radioactive material would likely be exceeded offsite in the near term (e.g., 3 nours). (The levels in the current plan are too low.) (3) Fuel Pool accidents or other incidents which could result in fission product inventories outside of containment which, if released, could result in offsite doses equi-valent to the lower limit of the EPA protective action guide. (4) Appropriate " Example Initiating Conditions" from the NUREG-0610 " Site" or " General" classes. B. Results of environmental surveys conducted in response to a Plant Emergency which would indicate that the lower limits of the EPA protective action guides have been exceeded. (9) The specific instrument readings for the instruments listed in Table N.4.1 Mich will signal the occurrence of the events discussed in Section N4.1.4 and, therefore, a Site Emergency must be provided (See question 19) along with corroborating instruments and readings. (10) The concentration (10 x MPC) of Iodine 131 can not be measured in field. 1268 130

. General Emergency (N.4.1.5) (11) Emergency action levels for declaring a General Emergency must be defined in terms of: A. Instrument readings or alarms that annunciate in the control room, including indications and corroboration of: (1) Airborne noble gas fission product inventory within contain-ment which, if released, could result in offsite doses equivalent to the upper limit of the EPA plune exposure protective action guide (5 Rem) for exposure to airborne radioactive materials. (2) Effluent monitors and system status whicn would indicate that the upper limit of the EPA Protective Action Guide for exposure to airborne radioactive material would likely be exceeded offsite in the near term (e.g. 3 hrs). (The levels in the plan are too low.) (3) Fuel Pool accidents which could result in fission product inventories which if released, could result in offsite doses equivalent to the upper limit of the EPA protective action guides. 1268 131

. (4) Appropriate " Example Initiating Conditions" from the NUREG-0610 " Site" or " General" classes. B. Offsite contamination levels identified during a environmental survey in response to an apparent Plant or Site Emergency which would indicate that the upper limits of the EPA protective action guides have been exceeded, or that the lower limit could not be exceeded. Site and General (12) The Site and General emergency action levels must include corroborating evidence from two independent sources that provide input to the control room such as activation of engineered safety features, redundant readings or pressure or temperature parameters inoicating a LOCA. (13) The use of " rapid surveys" to identify a General Emergency is not acceptable (must be based on control room i.,dicators). (14) The plans must describe a clear and explicit methodology for relating the EPA Protective Action Guides with the EALs (Site & General). The assumption used in these calculations must be stated. (15) The levels for a General Emergency must indicate credetermined protective actions. The concept in N.4.1.5 is consistent with a Site and not a 3eneral Emergency. 1268 132

c. (15a) EALs for Site & General Emergencies based on coolant and gap activity in containment should also be considered (See question 11). (15b) EALs that will utilize the instrumentation discussed in items 2.1.3 and 2.1.8 of NUREG 0578 must be included as soon as possible and a cormiitment to do such must be provided. Provisions to estimate offsite doses before the lessons learn items are implemented must be described to include pre calculated conversions and other job aids to be used. Postulated Accidents (N.4.2.1) (16) Specify the location and the specific reading (EALs) for the instru-mentation associated with a accidents analyzed in the SAR which could result an alert or Site emergencies along with the corroborating evidence. (Revise Table N.4.1.) Manoower Reauirements (N.4.2.2) (17) Identify the tasks performed (steps) to immediately identify, assess and corroborate Site and General Emergencies, and to determine offsite protet.tive measures and notify the appropriate offsite agencies and who performs eacn step. This must include the time to man the site EOC and time require to pass througn the sect.rity barrier. Resconse Times (N.J.2.3) (18) It r..ust be demonstrated that offsite notification can be accomplished within 15 minutes following detection of a General Emergency. This can be accomplished by presenting the ~information ecuested in question 17 in a CPH or similar format wnicn presents the time j}Q }33 recuired for a=ch steo.

.. Table N.4.1 (19) Specific EALs (reading, levels, etc.) must be provided for each instrument which is used to indicate an emergency condition. In addition, the combination of instruments and their locations used to corroborate Site and General Emergencies must be identified. Normal Plant Organization (N.5.1) See question 27. Direction and Coordination (N.5.2.1) (20) Confirm that the emergency coordinator (Emergency Director) or his designee will be on site at the initiation of an emergency and has the authority and resconsibility tc alert directly the offsite agencies responsible for implementation of protective action within the plume EPZ and be uvailable at all times (not necessarily o n-site) to exchan.ge information with authorities responsible for coordi-nating offsite emergency measures. (21) Describe the tasks to be performed by the emergency coordination (Emergency Director) during the early phase of a site or general emergency. It must be clear that he or sne can dir ect the site response, and make the necessary notifications. (This can be done when responding to questions 17 & 18) The use of the " Watch Engineer" to direct firefighting appears to be in conflict with this concept. k 0

11 (22) The plan must clearly indicate that the emergency coordinator (Emergency Director) will initiate the emergency classes in accord-ance with the appropriate criteria and EALs as stated in the plan. It must also be clearly stated that a General Emergency will be declared if the emergency ccordinator (Emergency Director), based on his or her engineering judgement, determines that an incident has the potential to result in the near term offsite doses equal to the upper limit of the EPA PAGs even if the EAls have not been reached. (23) Provile in terms of job assignments the specific line of succession of th! emergency coordinator (Emergency Director) if the watch engineer is disabled or as additional personnel arrive on site. Plant Staff Emergency Assionments (N.5.2.2) (24) Provisions for continuous (24-hour) operations for an indefinite. period must be described to include manpower planning to permit such continuous operation. The individual in the emergency organization who will be responsible for implementing the manpower planning considerations should be specified. Emergency Security Coordinator (N.5.2.2.5) (25) The section of the plant contingency plan whicn address the inter-face with the emergency plan must be referenced. The control of the security organization during an emergency must be clearly defined. 1268 135

, It must be clear that offsite response, plant evacuation and reentry are compatible with the plant securi ty system. (See question 2) Emergency Teams (N.5.2.2.6) (26) If no permanent statiion personnal' are preassigned to fire fighting or first aid the plan must specify that _all personnel must be trainea and qualified to perform these tasks. The leaders of these teams must be identified. (See question 27). question 27.) (27) The emergency plan must provide a clear structure on which more detailed emergency procedures, training and qualification require-ments can be established. The plan also forms a structure which assures adequate manpower loading. This requires that the indivi-duals who perform tasks crucial to implementation of the emergercy plan be identified. Therefore, the plan must identify, by job assignment title, the personnel who perform all the emergency functions, duties or tasks identified in the plan. This includes the conmand and control functions discussed in Section 5, and the assessment, notification, corrective and protective functions dis-cussed in Section 6. The number of personnel (by assignment title) available to perform these functions must also be identified for the all shifts and within 60 minutes (as augmented). The following list is a summary of some of the functions, duties or tasks identified in the plan and criteria. If the individuals are to be organized into groups (i.e., Decontamination Team) the team leader must be identified. 1268 136

. (Special attention must be given to the back shift.) A. Emergency Coordination 1. Immediate Assessment of situation 2. Direction of site response B. Protective action determination C. Notification of response agencies D. Plant systems operation E. Radiological surveys, monitoring and analysis 1. Core coolant sampling 2. Chloride chemical analys's 3. Airborne iodine surveys 4. Meterological monitoring 5. Radiological monitoring (Personal honitoring Team Yellow / Brown) 6. Precipitation, water, vegetation sampling (Environmental Monitoring Teams Red / Blue) 7. Radiological survey data collecton, reduction, analysis, and reporting. 1268 137

. F. Technical support G. Decontamination and First Aid Team H. Security and access control, (emergency security coordinator) 1. Repair at damage control J. Personnel accountability K. Record keeping (control room event recorder) L. Communications M. Interface with offsite agencies - (to include recommending of protective actions) N. Press relations 0. Logistics coordination P. Site representation at State or local EOC Q. Onsite Emergency evacuation notification 1268 138

. R. Re-entry & Rescue Team S. Accompaning patients to hospitals (28) The plan must confirm that a:: cess to the control room will be restricted during an emergency to only those personnel required to perform the control function. The plan must identify the individual responsible for control room access and the criterion used. Ficure N.5.2.-1 (29) Expand the figure to show the interface between the Federal, State, and Local governmental organizations (to include those responsible for implementation of the protection action within the plume EPZ), the Technical Support Center, Site Emergency Operations Center, Operations Support Center, State and Local Emergency Operations Center, and Press Center. Boston Edison Comoany Support (N.5.3.1) (30) The job assignment titles of the personnel who will augment the onsite emergency organization within 60 minutes must be identified for each class of emergency along with their function or duty anrj response period (See question 27). Any eouipment that will be available from offsite must also be identified 3 a function of time. 1268 139

.. Local Services Supoort (N.5.3.2) (31) Provisions must be made for actions in addition to access control at property line d2 ring a General Emergency. (32) The plan must be provided for the dispatching of a representative to the principle Emergency Operation Center established by the offsite agencies. (See Question 27) (33) The duty stations of all the onsite emergency personnel during an emergency must be identified as a function of time and emergency class. The manning of the following must be identified: (A) Technical Support Center (B) Licensee Emergency Control Center (primary and alternate) (C) Control Room (D) Operational Support Center The manning must not be in conflict with the roles of these centers which are: Technical Succort Center provide technical support to the control room and emergency coordination. (See ouestien 55.) 1268 140

. Control Room - Operation of the plant Operational Succort Center - Area to which non-assigned operational support personnel report for dispatch. Emergency Ooerations Center - total control of onsite emergency response, coordination with offsite response agencies and press. Coordination with Participating Acencies (N.5.4) The emergency plans of the state and local agencies which will af (34) Therefore, it during an emergency are a natural extension of site plans. is the responsibility of the licensee to work with these agencies to The state assure that a total emergency response capability exists. and local planning process must be expanded to include the plume and The planning process must include considera-ingestion pathway EPZs. tion of the general population and groups or facilities that will The following is a sample list require special protective actions. of the population s in the area of the site that must be considered. Town of Plymouth Town of Ouxbury Tcwn of Kingston Myles Standish State Forest and Park (summer and winter) Long Beach 1268 141

, Ouxbury Beach Gurnet Point /Stardish Neck Clarks Island Jordan Hospital State or local Correctional Instituations Critical facilities that moy be requiring manning during an evacuation (i.e., communication facilities or navigaton aids) Bay Schools A. Identify and designate the specific responsibilities of the authorities and agencies having the responsibility for imple-menting protective measures to include providing warning and instructions to each segment of the population within the EPZs. This must include the authority and responsibility to immediately implement uoon their direct notification by the Pilgrim Nuclear Station that a General Emergency exists the predetermined protective actions discussed in questions 45 and 61. B. Designate predetermined protective actions for general population, sensitive population and areas of special concern within the plume EPZ which are consistent with the EPA and HEW reccmmenda-tions and the agree.ents with the nuclear 'scility. This must include the criteria for their implementation, the information needed for implementation of the and the role of the facility 1268 142

. provided information. Use of protective actions which are limited to downwind sectors must be justified based on plant site meteorological history. C. The protective measures must be described for each segment of the population including: 1. Maps showing evacuation plans as well as relocation and shelter areas as related to the site, plume EPZ, and local jurisdictional boundaries. 2. Population and their distribution around the nuclear facility. 3. Means for notification of all segments of the population to include transients (i.e., Beach, Parks) and residertt population. (See question 340.) 4. Plans for protecting those persons whose mcbility may be impaired due to such factors as institutional confinement or hospitals. 5. Provisions for the use of radioprotective drugs, including that for emergency workers. 1268 143

. 6. Means of effecting relocation. 7. Effective evacuation planning to include: A. Egress routes and their projected traffic capacities under emergency use. B. Method to control traffic flows to include all necessary materials, equipment, and personnel and its state of readiness. C. Potential impediments to use of egress routes and contingency measures to include Boston rush hours or summer Cape Cod traffic. 8. The protective measures to be used for the Emergency Planning Zone associated with the ingestion pathway including the methods for protecting the public from consumption of contaminated foodstuffs. 9. Provide for maintaining dose records of all potentially exposed emergency workers involved in response activities. O. Provide for warning and clear instructions to all segments of the population within the plume EPZ (see introduction) within 15 minutes following notification by the facility cf a General Emergency (e.g. warn by sirens and give clear instructions by 1268 144

. radio). This must include a description of the system to include its communications links (to radio station etc.), letters of agreements as appropriate (radio station), and each step in the process (who performs it and the time required). E. Identify prewritten emergency messages for notification of response organizations and each segment of the population which requires a different protective action. E. Provide for posting information regarding the potential warning system and expected response in areas visited by transients and for whom direction will not be available (e.g., parks, beaches). Indicate the date at which all this information will be posted. F. Provide for testing communication system used to provide early warning and clear instructions to assure that the criteria specified in question 340 (15-minute notification) can be met on a continuing basis. H. Describe the communication plan for emergencies, including titles and alterantes for both ends of the communication links and means of primary and backup communications. The backup communication must not be vulnerable to loss of normal power or overloading by the public during an emergency. The agencies with key coordination or respcnse roles must be included to include: 1268 145

. Massachusetts State Police Massachusetts Department of Public Health Nuclear Incident Advisory Team Officials with responsibility for implementation of protec-tive actions for each segment of the population within plume EPZ (to include local EOC). No Direct Communication link to the Town of Plymouth was identified. U.S. Coast Guard I. Any agency communications link between the Pilgrim facility and the authorities responsible for implementing the protective actions (e.g., Town of Plymouth) within the plume EPZ must be provided with back up communications and be manned 24 hours a day. The communication network must also provide for alerting of the agencies responsible for implementation of the protective actions within 1 hour during a Site Emergency and within 15 minutes during a General Emergency. (Is tne Mass. DeparTent of Health link manned 24 hours a day?) J. Comments must be clearly provided for direct notification of the authorities responsible for implementation fo the protective action in the plume EPZ by the nuclear facility if a General Emeroency is declared. 1268 146

. K. The resources of the Department of Public Health for collection and assessment of all radiological data collected within the EPZs must be more clearly defined. This should include pro-visions for a centralized coordination center (possibly located beyond plume EPZ) for the receipt and analysis 'of all field monitoring data. A listing of all agencies providing informa-tion must be identified, along with the communications links. L. Describe the methods and equipment to be employed in determining the magnitude and locations of any radiological hazards for the areas within the EPZ following a liquid or gaseous release. The interface of these resources witn the agency co'lection and analyzing data and site effects must be described. M. Provide for emergency drills and exercises to tes and evaluate the response role of the agency, including provisions for critique by qualified observers. The criteria for a successful drill must be based on predetermined performance objectives (observable, measurable). N. Provide for participation in the joint Federal, State, local and licensee exercise discussed in question 93. Describe the training for those individuals having an emergency response assignment to include the training performance objectives (action, standard, condition) to be met. 1268 147

. 0. Provide for periodic review and updating of the state and local emergency response plans. This must include an audit of all plans to insure the plan actually reflects local conditions and that the elements required for their implementations are in place (e.g., signs required during evacuations etc). P. Revise the state emergencies classification system be make it computable (show relationship) with the Draft NUREG 0610 system. Emergency Measures (N.6) General Comment Section 6 must describe the actions (tasks, duties or functions) to he performed by the emergency organization. To assure adequate training and qualification, procedure development, and inspect.cbility the capacities in these areas must be described. This must include a definition of the task to be performed (in observable terms) who performs the task or duty (job assignment title) (Section 5) and a standard of performance (to include a time standard where appropriate. The equipment or job aids to be used in performance of these tasks must be defined in Section 7. Condition Detection and Immediate Assessment (N.6.2.6.3.6.4) (35) The plan must define by emergency condition or EAL (cue) and job assignment the immediate actions (tasks) to be . ken when an 1268 148

. emergency condition is detected by an individual holding any of the normal station positions discussed in Section 5 (question 17). The iramediate actions must demonstrate: A. Prompt notification of the individual rerponsible for assessment and initiation of the emergency response (Emergency Director). B. Taking of any immediate actions appropriate to correct or mitigate the situation. (fire fighting, isolation of area etc). (36) The emergency classes and the criteria or EALs associated with the emergency classes must be revised as discussed in Section 4. (37 & 38) Deleted Site and General Emergencies (N.6.4) (39) The plan must define the immediate assessment actions to be taken to include instruments used to confirm the emergency, and cetermine its extent and how the recommended protective actions are to be determined. This must include who performs this assessment (normal job assignment). the time required, and job aids used. It must be demonstrated that detection, assessment and notification of offsite agencies can ce accomplished within 15 minutes. (See questions 17 and 18.) 1268 149

, The licensee should have provisions for determing the release rate / projected doses under conditions where the instrumentation used for assessment are offscale until the modification discussed in question 85 have been implemented. (See question 153). (40) The actions to be performed for Site and General Emergencies are not similar. (41) As an aid to the Emergency Coordina. tor in identifing situations requiring offsite emergency response, plots showing containment radiation monitor readings (in control room) vs. time following an accident for incidents involving 100% release of coolant activity, 100% release of gap activity, 1% release of fuel inventory, and 10% release of fuel inventory must be provided in the control room and he placed in the plan along with a description of how they will be utilized. (See question 15A.) (42) The site must provide for detection and location of the offsite plume. The method to be used (i.e., aircraft) and when the capabi-lity will be available along with any appropriate letters of agreement must be provided. This must include who will perform the monitoring, equipment to be used, and the communicaton link to the site, and alternate EOC. 1268 150

. Activation of the Emergency Organization (N.6.4.1) (43) The plan must define Site or General Emergencies the communication steps tak'en to alert or ac*ivate the appropriate emergency personnel. Each step from initiation of the emergency to final contact with emergency response personnel must be specified to include who conducts each step (by assignment), the primary and backup means of communica-tions, the individual being contacted (by assignment or group heading such as "all on-site personnel"), the immediate actions to be taken by the individual contacted and the time required to make the notification (consideration of the time required to supply all the information required by each agency must be given). The immediate action must be compatible with the protective and corrective actions discussed later and it must be indicated that on-site operational support personnel not directly involved with response will report to the operational support center for further assignment. The immediate actions following notification of the offsite response agencies must include message authentuation. The notification of the following as appropriate to the emergency class must be demonstrated: 1. Offsite primary r scense sqencies who have resoonsibility for implementing protective action within the EPIs. (D1rsct noti-fication during a General Emergency.) 1268 151

. A. Town of Plymouth P.O. 8. Town of Ouxbury P.O., C. Myles Standish S.P. ranger D. Beaches, etc. 2. Offsite agencies responsible for support or coordination A. Massachusets Department of Public Health, B. State Police 3. Federal agencies, IRAP, NRC and 00E. 4. Local support agencies (medical, fire, etc.) 5. Company personnel (off site) who have been assigned to augment on site personnel (as detailed in Section 5). 6. Onsite personnel. (44) Predetermined message formats for notification of all offsite agencies must be provided to decrease notification time. Particular attention ntust be given to the format used to transmit the recommended protective actions (for all segments of the population). (45) Upon declaration of the General emergency it must be confirmed tnat notification shall be made directiv to the of fsite agency responsible 1268 152

. for implementing protective actions within the EPZs (plume and ingestion). (e.g., Towns of Plymouth, Town of Kinston, etc.) (See question 34 & 61.) The time required from detection of the General Emergency situation (EALs) to notification of the offsite primary response agency must be less than 15 minutes. Upon declaration of Site Emergency it must be demonstrated that the offsite agencies responsible for implementation and coordination of the protective action within the EPZs will be notified immediately and that notification to the agencies responsible for implementntion (question 34I) (e.g., Town of Duxbury) will require less than 1 hour. (46) The plan must decribe the method used to assure clear instruction to the site response or onsite personnel alerted. Referencing of written procedures by the individual alerted is acceptable provided they are available on the duty station and provided the situation allows the use of such aids (tin.e, circumstances). This should answer the question, "How do the people onsite or offsite response people know what to do when alarted?" Assessment Actions (N.6.4.2) (47) (Deleted) 1268 153

'. The personnel to conduct the sar 'ing and analysis discussed in item 2.1.8a of *!UREG 0578 must be identified by job assignment (Section 5) along with and the time required to obtain the sample. (51) The licensee must provide for display in the site EOC of real-cime meteorological information obtained at the site and a specified source of' timely weather forecasting information be incorporated in accident assessli.ent and protective action determination. The indivi-dual required to monitor and analysis this data must be identified by job assignment (question 27). 1268 T54 ~ i

, Meteorological instrumentation should be supplied by vital bus or provisions should be to obtain representative real-time meteoro-logical information from other sources in the event of power failure. s (52) The licensee must provide for timely dispatch of radiclogical moni-taring teams to assess direct radiation exposure pathways from plant and ground deposition sources within the site bounoary and outside the site boundary at least tha icw population zone boundary. The members of these teams must be identified by job assignments (ques-tion 27) along with the criteria for their deployment and the time required to dispatch the team (s). Capabilities to detect and measure radioiodine concentration in air that indicates the lower limits of the EPA FAGS must be demonstrated under field conditions (any kind of weather). Providions should be made to record survey results. Appropriate. survey forms should be developed te include: the names of the individuals making the survey; the date of the survey; the location of the survey; the serial number and type of instrument used; the instrument mode applicable to the survey (i.e., window open/ closed); and, if appropriate, the distance from the source being surveyed. This system must be compatable with tnat to ce used by the state (see question 34K & 54). 1268 155

, (53) The licensee must provide for taking precipitation, water, and vegetation samples within the site boundary and outside at least to the low population zone boundary and their analysis to assess poten-tial ingestion exposure pathways. The identified individuals who takes these samples by job assignment (question 27) and the time required. The criteria for requiring these surveys must be also provided. The ability to detect the HEW /PDA response levels must be demonstrated. (54) The licensee must provide the collection, reduction and analysis of the data collected (question 52 and 53) along with other sources. The individuals to perform this analysis must be identified by job assignments (question 27). The time requi. red to establish this capability must be stated. The interface of the site data collection and State effort (question 34K) must be described. (55) The licensee must provide for an going technical and management personnel in support of reacter command and control. The individual to provide the technical and management support must be identified by job assignment along with their qualifications (See questions 27 & 33). The facility must be activated within 60 minutes of notificatien. The Technical Support Center will be discussed in question 73, 74, and 75. 1268 156

., The authorities, responsibilities, limits and individuals in the emergency organization to whom the technical support personnel will report should be specified. Corrective Actions (N.6.4.3) (56) The licensee must provide for fire control and damage control teams. The personnel assigned to these teams must be identified by job assignment,(question 27). Protective Actions (N.6.4.4) (57) The emergency plan must provide for timely relocation for each emergency condition (Local, Site, General) of onsite personnel in order to prevent or minimize exposure to radiation. (Ses questions 43,46.) The plan must specify: 1. The action criteria (levels, reading, etc.) 2. Means and time required to notify (including personnel in exclusion area): (a) Poloyees not having emergency assignments. (b) Working and nonworking visitors (c) Contractors and construction personnel (d) Other personnel who may, be within the conclusion area 1268 157

l 3. Evacuation route, transportation of personnel and reasembly areas, including alternates for inclement weather and high traffic density. 4. Accountability 5. Missing personnel person checks 6. Rescue 7. Radiological monitoring of 8. Decontamination The personnel (question 27) required to perform the notification (1) transportation, (2) missing persons checks, (3) radiological man.i-toring, and (4) accountability must be identifed along with the time required to perform the evaucation. (58) Acountability of personnel should initially provide the capability to account for all individuals onsite, or ascertain the names of missing individuals within 45 minutes from the declaration of an emergency for which accountability is required. Subsequent to intial accountability there should be provisions for continued acccuntatrility of all persons on site. 1268 158

., (59) The plan must provide for evacuation from the site of non essential personnel during a Site or General Emergency. It a General Emergency is declared provision to evacuate beyond the plume EPZ must be made. Notification of all personnel must be made within 15 minutes. Therefore. the provision to evacuate only to Rock Hill road during a General Emergency must be revised. (60) The plan must provide for periodic public education of the public on the threat and the immediate actions to be taken (e.g., Turnar radio) when a General Emergency is called and the means of notification (e.g., sirens). The method used by the site to assure understanding by the public must be identified (i.e., surveys, etc.) and how the level of understanding is to be maintained. (61) The site must immediately recommend upon notification of offsite response agencies of a General Emergency (see question 45) protective actions for each segment of the population in accordance with the EPA and HEW /FDA protective actions. These actions must be based on the immediate assessment (question 39) and be provided along with information on plant status, time required to implement tha action and environmental condition in accordance with the agreements with these agencies. Protective action must be established for all segments of the population within the EPZ (See question 348). (62) Initial notifications to state / local agencies should consist of pre planned, standard message formats, the content and meaning of 1268 159

e 5 which have been coordinated. Notifications shoulo be in accordance with agreements between the licensee and state / local agencies and these must be placed in the plan. (63) (Deleted) (64) The site or offsite agency responsible for implementation of the HEW /FDA protective actions within the ingestion pathway EPZ must maintain a list of the locations of diary cows, major water sources, food or milk processing plants etc. within ingestion EPZ along with a point of contact. (65) The use of the telephone to keep the MOPH informed must be provided with a backup (see other questions). Protective Equioment and Supplies (N.6.4.4.2) (66) For each item of protective equipment measure that is to be used, a description must be given of: 1. Criteria for issuance and responsible individual (if any) 2. Location of items, 1268 160

.. 3. Means of distribution, and 4. The job assignments of the individuals who will use the equipment. 5. The job assignments required for distribution (id any). 6. Description of equipment at include capacity (type of filter, etc.) (67) Are TLDs to be issued to personnel? Contamination Control Measures (N.6.4.4.3) (68) The plan must provide for implementation of protective actions within the exclusion area (may be responsibility of local govern-ment) which are consistent with the EPA Recommended Protective Action for a Site or General Emergency to incluce isolation and area access control. The action to be taken must be described for eacn emergency class to include the personnel (job assignment title) and time required. (See question 57.) (69) Upon detection of HEW /FDA response level by the.tonitoring teams the site must provide for orotective actions consistent with HEW /FDA ingestion pathway protective action. 1268 161

- 3R - Emergency Personnel Exposure Criteria (N.6.5.1) (70) The licentee must provide for: A. Designation of the administrative dose limit (s) to be observed by emergency workers. 8. Designation of the individuals by job assignment (Section 5) who may authorize emergency workers to exceed the administra-tive dose limits established above. C. Provisions for controlling access to areas within the facility and for logging entries into areas. Decontamination and First Aid (N.6.5.2) (71) Is the Health Physics available on ite at all times to administer first aid and to accompany patients (as in agreements). (72) Describe in more detail the capacities of the site decontamination facilities to include: A. The type of instrument to be used. B. Specification of contamination limits which will require further evacuation, i.e., bicassay, dose assessment etc. l2bb lb2

. C. A means for recording the names of individuals found to be contaminated, the extent and location od contamination on the individual, and results of decontamination efforts to include followup; D. There should be a facility offsite for decontamination of personnel. This facility should be equipped with extra clothing, decontaminants suitable for the type of contamination expected, water, etc. Particular attention should be given to the under-standing of radioiodine decontamination. An alternate facility should be specified. E. The number of personnei that can be decontaminated must be specified. F. The job assignments of the personnel to perform this function (see question 27) must be identified. Emergency Facilities and Equioment (N.7) (72A) Analyze the role of the Site EOC (ECC) to insure it is equiped with the necessary equipment (e.g., communication questions 82, 83; meteorological etc.) and other rescurces to meet its role. The provisions for security at the ECC must be described. 1268 163

.40 (73) The plan must provide for and describe the role of an onsite Technical Support Center from which the technical support discussed in question 55 can be provided. The Center must be activated at the " Alert" level, and provisions for use of the Control room as a backup must be described. (NUREG 0578, 2.2.2.b) 1268 164

s (76) The licensee must provide an Operational Support Center (NUREG 0578, 2.2.2.c) separate from the Control Room, Technical Support Center or other areas vital during an emergency (i.e., decontamination station) for and describe its role (question 43).

(77) The Operation Support Center must be provided with bakup communica-tion which is not vulnerable to loss of normal power or overloading by the public to the Control Room, Technical Support Center and Site Emergency Operations Center. (78) A press center must be provided in the area of the plant (e.g., Plymouth at which arrangements (written agreement) have been made for hookup of about 25 telephones and backup communications with the site and state EOC. The time following a declaration of an emert;ency at which the center can be activated must be specified. (79) Describe the equipment and facilities of the alternate EOC. Communication (N.7.2) (80) Communication which is not vulnerable to loss of normal power must be established for the notification of the Emerger.cy Coordination (Emergency Director) by the individual who would detect a Site or General Emergency EAL (if other than Emergency Director). 1268 165

... (81) The communications link to the monitoring, rescue, and damage control teams must be described and its interface with offsite (state & local) monitoring activities. (82) The plan must describe the system which will provide a primary and backup form of communications (which is not vulnerable to loss of normal power or overload by public use) for the communication links used to alert or activate the following emergency personnel or agencies: A. Offsite primary.aesponse agencies who have responsibility for implementation fo orotective actions within the plume EPZ. (Town of Plymouth, etc.) 8. Offsite agencies responsible for suppon and coordination (MDPH, State Police, etc.) C. Federal agencies (IRAP, NRC) O. Onsite personnel (83) A primary and backup communications system , also be provided between: 1268 166

.., Control Room Technical Support Center Site EOC and Alternate Operational Support Center State and Local EOC (84) Primary and communications back up must be provided between the Site EOC and the Press Center. Assessment Facilities (N.7.3) (85) The specific instrumentation required for assessment (questions 19, 39, and 42) to provide meteorological information (question 51), to be used by the radiological monitoring team (Question 52) and to be used to process the data (Question 54) must be described. (86) The radiation monitors required to meet the "equirements of Section 2.1.8.b of NUREG 0578 must be described as part of the EALs. The plan include an implementation schedule. (See questions 15A & 41) (87) Identify the capability and resources for field monitoring in the environs of the plant including the acditional dosimetry specified 1268 167

. in the revised technical position issued by the NRC Radiolcgical Assessment Branch for the environmr'tal radiological monitoring program which follows: " Forty tations with two or more dosimeter or one instrument measuring and recording dose rate continuously to be placed as follows:

1) an inner ring of stadoqs in the general area of the site boundary and an outer ring in the four to five mile range from the site with a station in each sector of each ring (16 sectors x ? rings = 32 stations).

The balance of the stations, eight, should be place in special interest areas such as population centers, nearby residences, schools, and one to three in an area (s) to serve as a control station (s)." Notes to the above: Film badges should not be used for measuring direct radiation. The 40 stations is not an absolute number. Thie n'>mh+ may be reduced according to geographical limitations, e.g., at an ocean site, some sectors will be over water so that the number of dosimsters may be reached accordingly. Protective Facilities (N.7.4) (88) The protective facilities and equipment must be cescribed to include shelter and assembly areas. An estimate of the number of personnel 1268 168

4. to be protected must be given along with a description of ventilation, and supplies such as respiratory protection; clothing, portable lighting or communication. First Aid Facilities (N.7.5) (89) A summary of the onsite first aid supplies and capabilities must be provided. Damage Control Facilities (89) A summary of the onsite damage control equipment and supplies should be provided. Training (N.8.1.1) (91) Individuals who t ; forni any emergency task, function or duty identified in the plan (Section 5 or Section 6) must be trained and qualified to perform those tasks (question 27). The plan must commit to identify the tasks performed by each job assigr: ment (job analysis) and the standards of performance. A commitment must also be made to train and qualify the personnel to perform these tasks to the standaras specified. The qualification must be based en valid (i.e., content valid) tests. Records of qualification test and tt>:;7 r, lationship to the tasks performed must be maintained. 068 169

.. e (92) Provisions for t n ning offsite response agencies must be provided. Inviting offsite agencies to attend training sessions is acceptable, provided the licensee has made an attempt to acccmmodate the schedule of the offsite agencies. Where mutual aid agreements exists between local agencies such as fire, police and ambulance / rescue, the training should also be offered to the other departments who are me;nbers of the mutual aid district. Training for hospital personnel, ambulance / rescue, police and fire departments should include the procedures for notification, basic radiation protection, site access procedures, their expected roles, and who is in charge for overall operations while or site. Drills (N 8.1.2) (93) The provisions for drills must be expanded to include a joint exercise involving Federa, State and local response organization (once every five years). (94) At least once each calendar year (and no sooner than 9 montns or later than 15 months from the last drill) the licensee should conduct a radiation emergency drill having a scope of response at least equivalent to a Site Emergency. This drill should be in "real-time and unannounced as to time or scenario. 1268 170

. At least once every three years this drill should be conducted on a different (back) shift. A medical emergency drill should also be conducted at least once each year and involve the actual transport of a "p'atient" and acti-vation of the offsite medical support facility. If the offsite medical facility supports severa? other nuclear facilities, the involvement of the medical facility may not be necessary each year. In such cases, notification to and verification of their response role should be ascertained. The procedure (s) governing the conduct of drills should include a means to evaluate observer and participant comments and establish a method for assigning responsibility for implementing corrective actons, specifying times by which corrective actions should be complete and for evaluation the adequacy of such corrective actions. (95) Definitive performance objectives must be precetermined for each drill to assure objective evaluation. The objective must include a measurable and observable action to be demonstrated, the conditica at the time of the demonstration (equipment, job aids allowed, cues, emergency conditions, etc.) and the observabie/ measurable criteria (standard) to be used to determine successful complation of the actions. The crucial tasks performed in the following functional areas must be tested such as: 1268 171

.t . A. Condition recognition and reporting (EAL recognition) B. Assessment C. Offsite notification (information/ time) Company offsite personnel Protective action determination and offsite ratification D. Offsite response Site personnel argumentation E. Site response coordination Communications Logistics Center Manning Information gathering and analysis Coordination with offsite. F. Corrective actions G. Protective actions H. Records 1268 172

... 1. Monitoring J. Plant Operation Emergency Eouipment and Supplies (N.8.3) (96) Emergency equipment / instruments should be inspected, inventoried, operationally checked and calibrated at least once each calendar quarter and after each use. Sufficient reserves of equipment / instruments should be available to permit replacement of instruments / equipment which are removed from emergency kits for calibration or repair. Recovery (N.9) (97) The position / title of individuals who will fill positions of authority in the licensee's mcovery organization should be specified (question 27). The authority and responsibility of eacn should be specified. Provisions should be made for informing members of the emergency organization that a recovery mode is to be assumed and of any changes in the organizational structure that will occur. Decision points upon which a shift to a recovery mode will occur should be specified as clearly as possible. these decision points should consider both actual and potential operational and radiolcgi-cal conditions. 1268 173

.e. s Provisions should be made for informing the NRC, State and local agencies of an intended shift to a recovery mode. The criteria used to allow reentry of the population into an evacuated area or the criteria to reduce the level of emergency must be identified along with the decision maker and information used. 1268 174}}