ML19309H094
| ML19309H094 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe, Vermont Yankee |
| Issue date: | 04/14/1980 |
| From: | Ziemann D Office of Nuclear Reactor Regulation |
| To: | Kay J, Rich Smith VERMONT YANKEE NUCLEAR POWER CORP., YANKEE ATOMIC ELECTRIC CO. |
| References | |
| NUDOCS 8005080365 | |
| Download: ML19309H094 (37) | |
Text
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' UNIT ED sT ATES - g 005 080 hhf yi
-, y,g NUCLEAR REGULATORY COMMISSION 5.f '
C W ASHINGTON, D. C. 20555 April 14, 1980 Docket Nos. 50-29 and 50-271 Mr. James A. Kay Mr'. Robert L. Smith Senior Engineer-Licensing Licensing Engineer Yankee Atomic Electric Company Vermont Yankee Nuclear Power 25 Research Drive Corporation Westborough, Massachusetts 01581 25 Research Drive Westborough, Massachusetts 01581 Gentlemen:
We have reviewed your rev.ised Emergency Plans for the Yankee Nuclear Power Station (Yankee-Rowe) and the Vennont Yankee Nuclear Power Station (draft versions January 1980) and found the need for you to address the conments described in the enclosure to this letter.
The results,of our reviews were discussed with you by our Emergency Preparedness Review Team No. 4 in conjunction with fact finding visits to the Yankee-Rowe site and its environs during February 12-15 and to the Vermont Yankee site during February 19-20, 1980.
You are requested to submit by June 30, 1980, your final revised Emergency Plans that a'ddress all our comments.
'ncerely, j hwO Dennis L. Ziemann, hief Operating' Reactors Branch #2 Division of Operating Reactors
Enclosure:
Conments cc w/ enclosure:
See next page 9
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!!r. James A. Kay
-2 April 14, 1980 Mr. Robert L. Smith l
cc w/ enclosure:
Ms. J. M. Abbey John R. Stanton, Director Vernont Yankee fluclear Power Radiation Control Agency Corporation Hazen Drive 77 Grove Street Concord, flew Hampshire 03301 Rutland, Vennent 05701 John W. Stevens fir. Donald E. Vandenburgh, Conservation Society of Vice President Southern Vermont Vermont Yankee fluclear Power P. O. Box 256 Corporation Townshend, Vermont 05353 Turnpike : cad, P,oute 9 Westboro, Massachusetts 01581 Dr. Mars Longley, Director Occupational & Radiological Health John A. R'tsher, Esauire 10 Baldwin Street Ropes & Gray Montpelier, Vermont 05602 225 Frantiin Street Boston, Mu,sachusetts 02110 New England Coalition on Nuclear Pollution Laurie Eurt Hill and Dale Farm Assistant Attorney, General West Hill - Faraway Road Environr.er,tal Protection Division Putney, Vennont 05346 Attorney 'ieneral's Of fice Cne Ashburtcn Place, 19th Floor Public Service Board Bw.cn t'n sachusetts 02108 State of Vermont 120 State Street I:omid J. Wilson Montpelier, Vermont 05602 310 1,tn Itreet, N. W.
Suite 807.
W. F. Conway, Plant Superintendent Washington, D. C.
20006 Vennont Yankee Nuclear Power Corporation Honorable M. Jerome Diamond P. O. Box 157 Attorney General Vernon, Vermont 05354 State of Vermont 109 State Street Mr. Charles Sheketoff Idvilion Office Building Assistant Director Montpelier, Vermont 05602 Vennont Public Interest Research Group, Inc.
Pc. J. E. Griffin, President 26 State Street Vennont Yankee Nuclear Power Montpelier, Vermont 05602 Corpora-ion 77 Grove Street Brooks Memorial Library Ru tl ar.c, '.'ermont 05701 224 Main Street Brattleboro, Vennont- 05301
Mr. James A. Kay April 14, 1980 Mr. Robert L. 9nith cc w/ enclosure:
Mr. Janes E. Tribble, President Yankee Atomic Electric Company 25 Research Drive Westborough, Massachusetts 01581 Greenfield Community College i
1 College Drive Greenfield, Massachusetts 01301 Chai rma n Board of Selectmen 3
Town of Rowe Rowe, Massachusetts 01367 Energy Facilities Siting Council 14th Flocr One Ashburton Place Boston, Massachusetts 02108 Director, Tecnnical Assessment Division Of fice of Radiation Programs (AW-459)
U. S. Environmental Protection Agency Crystal Mall #2 Arlington, Virginia 20460 U. S. Environmental Protection Agency Region I Office ATTil:
EIS COORDINATOR JFK Federal Building Boston, Massachusetts 02203 f
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Enclosure YANKEE R0WE/ VERMONT YANKEE NUCLEAR POWER STATION EMERGENCY PLAN REVIEW NRC and FEMA have published a criteria (NUREG 0654) for use in evaluating emergency plans which incorporates all the previous guidance.
The Yankee Rowe and Vermont Yankee plans were reviewed for compliance using this document.
The plans were found in general not to contain sufficient detail to allow the staff to determine if the criteria were adequately addressed.
Comments on selected criteria and their relationship to these plans are attached.
The review team did not attempt to identify and comment on every area not covered in sufficient detail.
The plans must be revised to address all the applicable NUREG 0654 criteria and resubmitted in accordance with the schedule discussed in the rover letter.
The comments that follow are directed at both plans except where noted.
The review indicated the following major deficiencies:
1.
The classification system and immediate actions identified in the plan are not consistent with NUREG 0610.
2.
The specific instruments and readings (EALs) which if exceeded will initiate an emergency condition were not specified in the plan.
3.
The plan does not provide for direct notification of responsible officials within 15 minutes of detecting a " general" emergency condition.
This notification must include the protective actions
.1
.- initially recommended by the site.
In addition, the plan does not provide for recom11ending more detailed protective measures based on actual plant and meteorological conditions within 30 minutes.
4.
A system for providing early warning.(15 minute) and clear instruc-tions (Radio /TV) to the public within the plume EPL was not described.
5.
A public education program was not described.
6.
The plan does not contain sufficient detail to allow the staf f to determine if it complies with NUREG 0654.
The plan must be expanded to provide a level of detail consistent with that contained in the criteria.
7.
The plant emergency organization as described in the plan is confusing and contains conflicts in roles and interfaces (e.g., "On-Site Assistance Team" as shown in Figures 5.2.2 and 5.3.1).
The role of the corporate offices is not clearly defined.
8.
Since the state'and local planning efforts were incomplete at the time of the review there, interfaces with the site plan could not.be examined.
-, Detailed Comments Defijtions f
(Rowe) 1.
The definition of " site" conflicts with the diagram of the site, which shows only the exclusion area (i.e., Figure 2.1.1 does not show an area of 1862 acres).
This may lead to confusion over "off site".
2.
The plan must provide a map showing the plume EPZ, population centers, ECC, alternate ECC, special populations, state and local EOCs and jurisdictional boundaries (See acceptance criteria A.1.a comment).
The plan must provide a map showing the ingestion EPZ jurisdictional boundaries.
3.
The plan must provide maps and or diagrams showing the locations of the 00SC, TSC, ECC, alternate ECC, RC and PC.
4.
Define AARM, REMVEC, M00, and YNSD.
. i NUREG 0654 PLAN Acceptance Criteria Commment A.1.a The plan must identify by title the local authorities responsible for implementation of protective actions within the plume EPZ and provide a map showing jurisdictional boundaries.
The plan must identify all the state level agencies with emergency roles.
A.I.c.
Figure 5.5 - Rowe; 5.4.1 - Vermont must be revised to show all the local officials and state agencies with emergency roles and interfaces.
The figures in the plan (e.g., 5.2.2, 5.3.1) must also be revised to reflect functional responsibility (who is in charge of plant operators?, who is in charge of total response?) and to resolve conflicts with other diagrams and duty descriptions found in Section 5.2 and 5.3-(e.g., "Offsite-Assistannce Team is shown reporting to different individuals in Figures 5.2.2 and 5.3.1.)
-.3
5-A.I.e' Specify, for each organization with authority and responsibility to implement protective actions within the plume EPZ(A.1.a), the title of the individual who can be directly contacted 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day and who has the authority and responsibility to implement the protection actions recommended by the plant in response to a " general" emergency.
i A.2.a Provide a summary showing the relationship of state and local agencies to the functional areas listed in this criteria.
A.3/B.10 The legal instruments need not be addressed in the plan.
The written agreements with offsite response agencies attached to the plan must be I
reviewed to insure _they address the following areas as' applicable:
1.
implementation criteria 2.
measures to be provided
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. 1 3.
information exchange 4.
authorities and responsibilities 5.
limits of action 6.
point of contact at site.
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. l If the state and local plans are used i
to meet this requirement, the agencies covered by these plans must concur in the plans (be a signatory).
A.4 List the job title (s) of the individ-ual(s) responsible for 24-hour man-power planning.
B.1 Show in the plan the relationship between normai assignments (position titles) and emergency positions.
It is acceptable to associate several normal organization positions to an emergency position to allow flexi--
bility.
The plan must clearly indicate who is responsible for direction of the. total site emergency response and. include the primary interface with'of fsite of f icials.
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. (See Comment on criteria A.1.c) The plan must also indicate how the various responsibilities for plant emergency response are transferred to newly arrived personnel.
The authority and responsibility of Plant Emergency Director, Emergency Coordinator, and Recovery Manager l
must be more clearly described to assure there are no conflicts.
The authority and responsibilities of B.2 the Plant Emergency Director must be revised to state that he/she will recommend protective measure offsite in the case of a general emergency within 15 minutes of its detection to the authorities responsible for_their implementation.
(A.1.e) -The plan mest also state that_ emergencies will be declared and actions taken in accordance with the provisions of the plan.
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. B.3 Provide the line of succession for the Plant Emergency Director, Recovery Manager and Emergency Coordinator and state the criteria for transfer (up and down).
B.4 The plan must state that the Plant Emergency Director will not delegate the responsibility for initiation of offsite notification.
The plan must be revised to assure that the Plant Emergency Director will not perform any duty (e.g. Fire Brigade Supervisor) which could interfer with his/her initial coordination and notification functions during the backshift.
B.5,B.8 The plan must indicate which member of the minimum operational crew would be assigned to perform the major functions outlined in Table 6-1 of NUREG 0654 during-the initial phased of an emergency before the shift statf could be augmented (all shifts).
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What is the basis for the following remark found in Section 5.2, "The operating group, figure 5.2.1, on-site at the time of the emergency, will be self-reliant for a sufficient time for staff personnel to assemble and integrate smoothly into the emergency organization designated in Figure 5.2.2."
The plan must identify the number of additional personnel available to perform the functions and tasks identified in Table B-1 as a function
)
of time (immediately available and as augmented during the backshift).
The qualifications of emergency personnel must be described.
This can be accomplished by identifying their normal assignments (B.1) and the
?mergeacy tasks -(that are not part of their normal assignments) for which they will-be trained and qualified (tested).
Note:
The minimum staffing requirement shown in this criteria is going out for comment and an implementation schedule will be developed at a later date.
B.6 Figure 5.2.2 must be revised to identify the duty stations (as appropriate e.g., ECC, Technical Support Center etc.) of all the emergency staff (e.g., Recovery Manager, Public Information Directors).
In addition the figure must be revised to show the press center and Recovery center.
The plan must clarify the role of corporate offices (Nuclear' Services Division).
Is there a corporate plan?
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6 How do the corporate offices become involved with an interface with the emergency response? The plan is scoped_to cover plant operations put corporate offices are shown in
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Figure 5.2.2 as having a major role.
This role must be defined.
C.2 The plan must indicate what provisions including communication have been made at the ECC to support representation from the offsite agencies.
The plan must identify the position title of the station representatives to be dispatched to the state and local E0C, criteria for their dispatch, and specify their expected response times. It is acceptable to dispatch site representatives at the request of offsite officials provided i
offsite agencies send representatives to the site ECC.
These represent 6-tives must be dispatced for " site" and
" general" emergencies.
C.3 The expected response time of the laboratory support discussed in
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Section 7.3.2 of the plan must be provided.
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. 01&2 The emergency classification scheme identified in Section 4 of the plan must be revised to reflect that identified in NUREG 0610. The specific instrument (don't reference FSAR) and readings or other observables (EALs) which will initiate an emergency condition must be listed in the plan for each initiating conditions in NUREG 0610 (as appropriate to this site) and the accidents analyzed in the FSAR.
In addition EALs must be established for:
1.
Use of the containment and effluent monitoring equipment discussed in NUREG 0578 (II.I.2).
2.
Containment radiation monitor readings developed in response to acceptance criteria I.3.a.
3.
Conditions when the effluent monitors are offscale.
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. 4.
EPA GAGS (lower limit 1/5 Rem for a general).
The assumption used in development of EALs must be described to include the amount of iodine to be assumed (be realistic).
Note:
General Emergency EALs are to be established for plant conditions indicators and not just projected doses.
i It must be clearly stated in the plan that the offsite authorities responsible for implementation of I
offsite protective measures have reviewed and have concurred in the EALs.
The immediate actions to be taken by the licensee upon declaration of an emergency must include the " licensee actions" indicated in NUREG 0610 for each emergency class.
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. E1&2 The plan must (in addition to other NUREG 0610 notification requirements) specify that if a " general" emergency is declared that the offsite authori-ties responsible for implementation of plume protective measures (A.l.e) will be notified by the " Plant Emer-gency Director" and advised of the recommended protective actions within 15 minutes of the detection of the emergency condition.
The plan must specify the content of this initial message to include:
1.
class of emergency 2.
whether a release is taking place 3.
affected areas 4.
recommended protective measures Note:
" Prompt" as used.in NUREG 0610 is defined as 15 minutes.
Note:
The initial protective measure recommended may be prearrangeil to be sheltering throughout the plume EPZ' l
. with continued monitoring of TV or radio provided further instructions (within 30 min.) are forthcoming.
indicating more detail protective measures.
The concept of awaiting actual offsite measurements before implementing protective measures (Section 4.1.5) is unacceptable.
E.4 Indicate in the plan what information would be supplied to the various offsite agencies (by agency).
E.6, Appendix 3 The plan must describe the total.
public alerting system to include.
ertingSystes)i P
Offsite (Officials)
(Alert
-[dio/Th/brtet Public Instructions
- 1.
The initial offsite contact (A.1.e) 4,
. 2.
The physical alerting system.
(sirens, EBS, NOAA etc.) (E.6) 3.
Provisions for use of a public media system (Radio, TV) to provide clear instruction to the public. (Appendix 3) a.
24-hour capability - total plume EPZ coverage b.
Interstate coordination of messages (Precoordinated)'
4.
.The messages to be transmitted to the public (cover a range of protective actions) (E.7).
5.
A description of how the perform-ance objective specified in NUREG 0654, Appendix 3 are met.
6.
A description of.the ppblic education program to' include-
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. information to be provided and means of distribution. (G.1 &
G.2) 7.
A statistical survey to verify that public awareness and the corrective measures to be taken i
if deficiencies are found (Appendix #).
Note:
If the public notification system is to be administered by state or local officials it must still be described in the plan.
f.1 Revise Figure 7.1 (7.2 ?) to indicate the type of primary and secondary (Rowe) communications links (not vulnerable to normal power loss and diversified).
The figure must be expanded to. include the local response authorities, alternate ECC, press center and
. response center.
The communication system must be revised to identify i
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identify the TSC as the primary com-munication interface with the control room (See NUREG 0654, Appendix 5).
i The Titles of the contacts at both ends of offsite rammunication links must be identified in the plan.
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Describe the " Yankee Management" referenced in Section 3.0 as part of the communication network.
t f.2 The plan must commit to conduct tests 1
l of the entire alerting system to l:!
include the system used to alert the.
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public.
Specify the test period.
G.1 Note:
If the public information program is to be administered by local-officials it must still be described
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in the plan.
(See E.6, E.7) i G.3 & 4 The plan.should identify a' press center, at or near-the ECC which coulil be used during an emergency..lhe t
. interface of this facility with the-ECC must be described and how the Public Information Director, local and state government representative will
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interface and how information will be exchanged.
G.5 The Provision for inviting the local media must be described in'the plan to include the general topics to be discussed and who is to be invited.
This training must include:
1.
alerting system 2.
classification system 3.
protective measures 11.2 The ECC must be further described in the plan.
A map showing its-location must be.provided along with a floor
. plan indicating the areas to be used by state'and local officials.
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Provisinns for backup power must be provided if required for communica-tions or'. dose projections (met, data).
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20-The alternate ECC must be located
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beyond the area where evacuation is most probable.
The plan must describe the provision made to assure that the command / control functions are trans-ferred without interruption if the primary ECC must be evacuated (include communications).
A initial point for federal assistance interface (ECC?)
for both states must be identified in the plan.
H.4 The staffing of these centers and response time should be addressed in response to criteria B.5/8.
H.5/6 The specific instruments associated with EAls (plant and field monitoring) must be specified in the plan. (See Dl, '2)
- 11. 8 The Appendix 2 requirements will be issued-for comment and are not a requirement at this time.
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. 11. 9 Provide a further description of the 00SC to include the supplies contained at this location.
11.10 The plan must be expanded to explicitly meet this requirement.
11.11 The inventories must be provided in the plan.
I 11.12 Identify and show appropriate communi-cations links with a centrai monitoring data collection and anal-ysis point.
This must be the central point for the analysis of eld moni-toring data from both states and the licensee's monitoring efforts. The d
provisions to feed back monitoring results as they affect plant opera-1 tions and protective action determination must be described.
l.l-See 0.1, 0.2
. 1.2 Describe how the NUREG 0578 require-ment will be incorporated into the emergency operations.
(B 5/8, D 1/2)
- 1. 3. a The source term requirement should be met by Containment radiation monitor readings for the following accident conditions:
a.
release of coolant activity b.
release of gap activity c.
fuel melt Describe in the plan-the assumptions -
used in meeting this requirement to include containment leak rate and meteorological conditions.
- 1. 4/I. 6 The methodology to beLused to project offsite_ doses including iodine using realistic r.eteorological data must be
'desc.ibed in the plan'in sufficient' detail to assure adequacy.
This must include the equations, graphs, etc.,
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! used to relate doses to plant parameters e
using realistic meteorological data J
and release location (elevated in the case of Vermont Yankee).
Job aids used to perform these calculations such as fill-in-blank forms could be-l supplied to meet this requirement.
It must be demonstrated that offsite dose projections and related recommended actions can be determined to allow for recommendations offsite within 30 minutes (See El & 2 comment).
This must 2
include the methods to:
a.
Determine meteorological parameters J
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, Wind direction
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Atmospheric stability-
- What will be used if instruments are inoperable, b.
Estimate doses based on effluent monitors
- c.
Estimate doses based on field monitoring data d.
Estimate doses based on contain-ment monitor reading and leak rate data, e.
Estimate doses when effluent monitors are offscale or inoperable.
(I.6) i
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I.5 The provision to access meteorological information in the ECC, TSC and Control Room must be described.
1.8 Describe in the plan the extent of dependance of state officials on 1
licensee offsite monitoring and the licensee's ability and willingness to provide such assistance and how this assistance is requestea and coordi-s.
nated.
I.9 The plan must specify the.following information about the offsite monitor-ing teams:
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notification methods 2.
composition (numbers titles, qualifications)(B.5) 3.
transportation 4.
communications 5.
monitoring instruments (Note: EAL must be estab-lished for) 6.
deployment times 7.
detection capabilities.
.The time req' aired to deploy the teams across'the river for the Vermont Yankee must be specified for all shifts.
In addition a means for plume location must be described _(e.g., aircraft).
J.2 The plan must further describe the provision for plant evacuation ~ showing the routes relative to the site, ECC, alternate-ECC and plume EP7..ihe plan must describe how evacuees will be informed to reassemble-if further; monitoring or' decontamination is required.
. J.3/J.4 The plan must describe provisions l
for monitoring evacuees and for decontamination onsite/offsite.
The provisions for extra clothing and individual, decontamination with particular attention given to Iodine skin contamination must be described.
Specify for the instruments used to monitor evacuees instrument readings requiring action.
J.5 The plan must describe the provisions for accountability (don't reference a procedure) and commit in the plan to complete this function within-30 minutes.
J. 7 The plan must indicate that a speciiic individual (B.2) shall, if a." general" emergency is declared, directly notify the offsite officials responsible for
' protective action impimentation within.
the plume EPE.
The plan must specify that this' notification will'be accom-plished within 15 minutes. 'The-a
-. provision described in Section 4.1.5 which indicate that protective action recommendation may await confirmatory offsite monitoring, is not acceptable.
The plan must describe how the recommended protective actions will be determined in a timely manner based on factors such as:
a.
plant status b.
local protection factors for typical residential units (J.10.m) c.
weather. conditions d.
evacuation times e.
release potential f.
projected or potential doses The plan must commit that the provi-sions for recommending protective actions will be reviewed'bi-annually
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by the implementing authorities.
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review must be documented.
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. J.8 This information must be placed in 4
plan and the plan must discuss how it is used to determine protective-actions recemmended offsite. (J.7).
J.9 The plan must provide for recommending ingestion pathway protection action offsite.
Describe the procedure, the time required and who is contacted.
The plan must describe ti.e provisions for implementation of the plume 4
protective measures recommended and the time required.
In the case of a
" general" the public must be notified of the initial action to be taken (can be prearranged) within 15 minutes.
The provisions described in Section 5'.6 under which offsite
.officals would not take protective action until they have conducted their assessment are unacceptable.
J.10 a,b,c.
At a minimum, the licensee's plan must cross reference the appended state.
and/or local plans.
e 1
. K.1 Specify the specific exposure guidelines (don't reference a procedure).
K.2 The plan must identify the member of the emergency organization who can authorize doses in excess of Part 20 and how his/her authorization will be obtained during an emergency.
K.3.a, b Describe in the plan the provision for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> doses determination and the.
records to be maintained for emergency worker to include offsite individuals (NRC,. State officials) who are to arrive on site or at the ECC.
Who performs these functions during an emergency?
L.1 Specify that a radiation monitor would-accompany a contaminated individual during the back. shift.
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. M.1, 3
. Describe the; procedure used to relax an emergency condition toJinclude who d
, would make the decision at the local level.
Describe in the plan the method used M.4 to estimate total population dose during accident conditions (coordinate with state and local agencies).
4 The plan must provide for the following N.4 drills and describe each drill and its frequency:
1.
communication drill,
'2.
fire drill, i
3.
medical emergency drill, 4.
radiological monitoring drill,-
5.
health physics drill.
The plan must describe the information N.3 to'be provided in the drill scenarios to include:
i 1.
basic objective at-the i
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drill - an objecilve is 4 -
. measurable and observable; an objective for each major action to be accomplished must be provided.
List the tasks / function for which objectives will be established.
i 2.
date, time, place (s) 3.
simulated events 4.
time schedule 1
5.'
narrative summary J
6.
arrangements for observers-1 and their qualifications 7.
how the exercise wil1 be scored (use objectives).-
1.
The' plan must provide'qualificif, N.4 observers to icritique the exercises and describe the provision for a l
critique.
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4 N.S The plan must describe how the results of the exercise requiring plan changes will be handled and who (Plant Operations Review Committee ?) has management control?
0.1/0.2 The training must be described to include the provisions for-identifying the emergency tasks performed by onsite plan personnel and how they will be tested to assure they can perform these tasks. (8.5/8.8) 0.3 The plan must specify that the Red Cross multi-media course will be given to personnel who may be assigned to first aid duties.
0.4/5 The categorios listed in this criteria i
must be addressed in the_ plan.
The emergency tasks performed under each category must be listed along with who is assigned to perform them and the frequency of training and qualifica-tion.
The offsite agencies who report
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I 33-to the site need only to beftrained on areas that are not part of their' normal duties (i.e., fire fighter -
would receive training on security and i
radiological procedures).
Training i
and qualifications must be conducted i
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annually.
't Identify the individual responsible P.3/2 4
for planning.
The plan must commit to provide P.5 i ~
updated copies of the plan when appropriate-to all holders of the plan, and that. revised pages will be I
marked as required.
i The plan htust include a list of all P.6
. supporting plans (state, local, federal, other).
l The plan must describe between plant operating and emergency procedures to 1
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include.how the staff transfers from i
i one to the other.
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.. P.8 The Index must cover the attached state and local plans.
P9 The plan must describe provision to meet this requirement to include who performs the audits and the management controls.
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