ML19331D331
| ML19331D331 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 08/25/1980 |
| From: | Parker W DUKE POWER CO. |
| To: | Harold Denton, Youngblood B Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19283A602 | List: |
| References | |
| NUDOCS 8009020029 | |
| Download: ML19331D331 (13) | |
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'jT/E' S Duxz POWEN COMPANY Powen Britonwo 422 Sorra Carmen Starrr.CnAntoriz. N. C. asa4a
. w.= o a.==ca. a August 25, 1980 m
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- s.....e*xw 2+>.:n Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Co==ission Washington, D. C.
20555 Attention:
Mr. B. J. Youngblood, Chief Licensing Projects Branch No.1 Re: McGuire Nuclear Station, Units 1 and 2 Docket Nos. 50-369, 50-370
Subject:
McGuire Nuclear Station E=ergency Plan
Dear Sir:
Enclosed are 20 copies of the McGuire Nuclear Station E=ergency Plan. This plan reflects current require =ents in the for= of 10CFR 50 Appendix E and the criteria of NUREG-0654.
It also incorporates our response to the com-
=ents of the NRC review tea = as defined in a letter fro = Mr. Robert L. Tedesco dated July 23, 1980. To help in the review process a cross reference fro:
NUREG-0654 to the E=ergency Plan is ircluded in the Plan and a cross refer-ence to the review tea co==ents is attached to this letter.
With regard to Criterion B.5 and Table B-1, the infor=ation sub=itted with this plan provides for the addition of 26 station staff personnel within one hour rather than 30 =inutes.
This is based first on the consideration that all personnel cannot receive notification and drive to the station within 30
=inutes because of the distance and traffic conditions between their ho=es and the station. Secondly, it is based on the censideration that the personnel on shift are qualified and sufficient in nu=ber to handle e=ergency situations until supple =entary personnel are available.
With regard to Criteria E.6, Duke Power Co=pany has initiated a study of the plume exposure pathway E=ergency Planning Zone around the McGuire Nuclear Station to deter =ine the design of an acceptable early warning syste=.
It is our intention to provide for the purchase, installation and testing of a syste: =ceting the criteria of NUREG-0654 Appendix 3 to be functional by July 1, 1981. The enclosed plan describes the warning syste= arrange =ents which have been =ade pending the availability of this syste=.
8 009 0 2 0Ch771 l#
l Mr. Harold R. Denton, Director August 25, 1980 Page Two
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With regard to Criterion H.8 and the clarification in Appendin 2 the Plan reflects use of presently existing meterological equipment at the site which provides data through chart recorders and the plant computer to the control room and provides data through the plant computer to the Technical Suppcrt Center.
Backup meterological information is available from the National Weather Service office at the Charlotte airport 15 miles from the McGuire Nuclear Station and from the North Carolina Air National Guard facility at the same location. Plans for refinements in the meterological monitoring capability are being made and will be submitted by January 1, 1981.
Meterological data and other data transmission is by telecopier from the Technical Support Center. Duke Power Company is participating in industry-wide development work toward enhanced data transmission capability. This future capability will improve the transmission of meterological and other data.
Included in the plan are procedures for use of a Class A (per NUREG-0654 Appendix 2) type transport and diffusion model for accidental radioactive releases. Work is underway to computerize this model to make it easier to use in an emergency. This program is planned to be available by July 1, 1981. The more detailed Class B model development has been started. No completion date can be assigned at this time.
This plan is currently being used for operator training at the McGuire Station and it will form the basis of our response to the exercise planned with the State of North Carolina and with five counties surrounding the McGuire Station for later this year.
Copies of State /and local plans were sent to the Regional Advisory Committee for their review in early August, 1980.
The copies provided for your review are uncontrolled copies. Upon final approval of the plan, it is our intention to issue a limited number of con-trolled copies to the appropriate regulatory authorities.
It would be helpful if in your approval letter you would identify those persons / organizations with-in the NRC to whom controlled copies should be sent.
It is requested that these plans be reviewed in light of current requirements for emergency planning and that this plan as well as the State and local plans and the scheduled exercise be considered an adequate emergency planning basis for issuance of a full power license for McGuire.
Very truly yours, w
n/
William O. Parker, Jr.
CAC:ses Enclosures (20)
Duke Power Company McGuire Emergency McGuire Nuclear Station Pica S:ction D3finitions 1.
A definition of the Crisis Management Center should be included in the 1.12 plan.
It is suggested that this center be identified as an Emergency Operation Facility (EOF).
Table 2.
Revise plan to show those organization which have 24-hour per day response 2-1 including 24-hour per day manning of communication links.
Show primary and backup means of communication.
4.1,1.
3.
In Section 4.1-1 under the Emergency Action Level notification of an unusual event, line G, the word " prompt" should be placed before
" notification" according to the requirements of NUREG 0610.
4.2,2.
4.
Section 4.2, the Alert Action level, Part 2 of Section 4.2, line 12 in 6.1,b,(7),(b) the section.
In the sentence starting witn " periodic plant status updates," there should be an insertion after updat'es: "(at least every 15 minutes)" accordiig to NUREG 0654, page 1-6, Licensee Action No. 5.
Table 4.5-3 5.
Section 4.3, Site Emergency, Part 3.
Item Letter K in the plan.
Item K ends with three underlined words for actual meteorolocy while page 1-10 of NUREG 0654, example 12a refers to adverse meteorology.
The plan should specify adverse meteorology according to NUPEG 0654.
Table 4.5-3 6.
After Item No. K, there are notes 1 and 2 in the plan.
There is no reference in the text to these notes. How do the notes relate to the initiating examples for this section?
Table 4.5-4 7.
Section 4.4, General Emergency.
There's no discussion of ths FSAR accidents explicitly in any of the emergency action level discussions in the plan.
Arpendix 8.
The table of contents in the plan says that in Section 10.3 of the 10.2 Appendix, plots of containment radiation monitor versus time for each emergency classification is given.
The plots in the Appendix 10.3 are labeled Release of Reactor Coolant Activity. Release of Gap Activity, and the Design Basis Accident.
The plan should make a clear and unambiguous reference to the proper emergency action levels enumerated and annunciated in NUREG 0654.
Each of the plots of containment monitor reading should correspond to source terms as described under Release Potential for each of the emergency classes in NUREG 0610 except for Notification of an Unusual Event.
l 4.4.2 9.
The plan must provide for direct notification of responsible officials within 15 minutes of detecting a " general" emergency condition.
This notification must include the protective actions recommended by the site.
5.2,2.
10.
The plan must designate an individual as emergency coordinator who shall be onsite at all times and who shall have the authority and responsibility I
to immediately and unilaterally initiate any emergency actions, including l
l l
2
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providing protective action recommendations to authorities responsible for implementing cffsite emergency measures.
11.
Among functional responsibilities assigned to emergency coordinator that 5.2,2 cannot be delegated is the decision to notify and make recommendations to authorities responsible for offsite emergency measures.
5.5 12.
Plan must specify the onsite emergency organization of plant staff Table 5.1-1 personnel for all shifts and its relation to the responsibilities and duties of the normal staff in accordance with Table B-1 of NUREG 0654.
Table 5.1-1 13.
Staffing must be available within Y2 following the declaration of an (1 br. vs.
emergency as indicated in Table B-1.
1/2 hr.)
5.0 14.
Plan must speci'y by positions or title the qualifications to be met by the persons assigned to the functional areas of emergency activity.
Appendix 15.
Plan must be revised to resolve the following criterion from Section E 10.5 Notification, Methods and Procedures from NUREG 0654:
Appendix 10.5 Criterion 3, Page 38, NUREG 0654 is a satisfied.
Appendix 10.5 Criterion 4, Page 38, NUREG 0654 is not satisfied.
Appendix 10.6 Criterion 6, Page 39, NUREG 0654.
There's no mention or discussion of the physical mer.ns and the time required in the Emergency ?lan.
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Anoendix 10.5 There's no satisfaction of Cr terien 7, page 39 of NUREG C554, 15.
Plan must be revised to resolve the follcwing Criterien fres Secticn H.
Emergency Facilities and Equip:ent fres NUREG 0554:
Definitions Criterien 2, Page 44, NUREG 0554 There's no discussien of an alternate and EGF.
Is the technical training center within One sile of the staticn?
5.6.1.,(3)
The technical training center is referred to in Sectica 7.1-2a lines 2 and 3.
7.3,a,(4)
Relating to Criterior Eb, ptge 45 in NUREG C554 Oces the desiretry (Ye8) ceet the NRC Radiolcgical Assess:ent Eranch Technical Pcsitica for the Enviror.= ental Radiological Monitoring progras?
7.3,1.,b,(1)
Page 45, NUREG 0554, Criterian 8.
There is no previsica acticed in the plan for providing alternative =eteoro'cgical infor:ation fres Other sources as required for Criterien 8.
Do the prececures and equip: ant satisfy the criteria expressed in Appendix 2?
5.3,3.
Criterien 9, Page 45, NUREG 0554 There's no discussica cf ventilatien and shielding for the ensite cperatienal sup;crt center er a full discussion of the equipment to be centained in it.
8.3,2.
Page 45, NUREG 0554, Criterien 10.
The plan d es net previde for the inventory, inspection and operational checking after each use as specified in the Criterien.
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Appendix 10.4 Criterion 11, Page 46, NUREG 0654.
Communication equipment is not mentioned in the Appendix 10.5 general category list.
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5.3,2.
Page 46 of NUREG 0654, Criterion 12.
Plan gives no detailed discussion 5.6.1.,(3) of a central point for the receipt and analysis of all field monitoring data.
17.
Plan must be revised to resolve the following criterion from Section I.
Accident Assessment from NUREG 0654:
Yes Relating to Criterion 1, page 47 of NUREG 0654.
Are the parameter Table 4.5 values and corresponding emergency class in the emergency procedures as required in Criterion l?
Design and Criterion 2, Page 47, NUREG 0654.
Do the post-accident sampling capability, Procurement Underway radiation and effluent monitors, inplant instrumentation, and containment radiation monitoring conform with the requirements spelled out in NUREG 0578 with regard to extended range, discrimination from noble gas, noise, ete?
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T;31e 4,5 _
Page 47 and 48 of NUREG 0654, Criterions 3 and 4.
There is not really Appendix 10.2 clear correlation between curves in Appendix 10.2 and specific instrument readings.
No magnitude of the release of radioactive materials based on 1
plant system parameters and effluent monitors is given in the plan.
Page 48 of NUREG 0654, Criterion 5.
Do the meteorological data and equipment meet the criteria of Appendix 2? Are there readouts for the 5
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5.3,2.
meteorological information at the nearsite Emergency Operations Center,
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Ti;nnical Support Center, the Control Room, and for the offsite NRC Center?
Appendix 10.2, Page 48 of NUREG 0654, Criterion 6.
There's no discussion of the Note for methodolo'gy for determining the release rate of projected doses if the projected dose "l -
Y instrumentation used for assessment is off scale or inoperable.
- 6. 2,1. (d) (1)
Page 48 of NUREG 0654, Criterion 7.
In the plan, there's no mention of the capability to measure radio iodine concentrations in the air in the
-8 vicinity of the site as low as 5 x 10 micro curies per cc under field conditions in any kind of weather regardless of the interference from the presence of radioactive noble gas and background radiation.
6.2,1.,(d),(1) Page 49 of NUREG 0654, Criterion 9.
There's no mention of communication equipment or the estimated deployment times.
Appendix 18.
Must establish procedures which describe mutually agreeable bases for 10.5 notification of offsite authorities consistent with Nr.1EG 0610.
These procedures must include means for verification of messages.
Appendix 19.
Must establish the contents of the initial emergency messages to be 10.5 sent from the plant.
20.
Your plan must describe the public notification system to include:
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6.6,3.,a.
a.
The initial offsite contact who will be responsible for notifying the affected population.
(Either the specific organization or individual.)
6.6,1,,a.
b.
The capability for 24-hour per day notification.
(To offsite authorities.)
Appendix 10.6 c.
The physical alerting system to be used, sirens, NOAA weather of Note 10.6,1,(a),(2) emergency alert, telephone automatic dialers, aircraft with loud-Letted encl.
speakers.
(Which will be used to alert public.)
(10 db above average daytime ambient background is a target level for design of an adequate siren system.)
Distance
% Notified in 15 Minutes 5 miles 100%
5 to 10 miles 90%
The design objective for the remaining 10 of the public within 10 mile zone is notification within 45 minutes after notification of local officials.
d.
The basic for any exceptions (e.g., for extended water areas with Appendix 10.6,3,1 transient boats or remote hiking trails must be documented.
Every year, operator must tape a statistic.al sample of the residents
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e.
Appendix 10.6,2, (B) (7) of all areas within the ten mile EPZ to assess the public's 7
awareness of the prc:p2 notification system and the availability of infor ation on what to do in an e:ergency.
Appendix Plan must also include a previsicn for corregtive measures to 10.6.2,(b)(7) provide reascnable assurance that coverage apprcaching the design objectives is =aintained.
Appendix 10.6 f.
The provisiens for use of a public media system (Radio, T.V.) to provide clear instructions to the public.
a.
24-hour station - total ple=e coverage.
b.
Include in the plan the cessages to be trans:itted to the Appendix 10.5 public (cover a range of protective actions.)
Appendix 10.6 It is the cperators responsibility to ensure that tt:e =eans exists see note under for notifying and providing prc:pt instructions to the public.
- 10. 6,1., (a) (2)
It is the respcasibility of the State and lccal goverr. ents to activate the systes.
21.
Plan must be revised to resolve the follcwing criterica frc: Sectica J.
Protective Response frc: NUREG C554:
6.4,1. a, (2), (s)
Criterion 3, Page 50 of NUREG 0554 There's no discussica of providing for the radiological =cnitoring of pecple evacuated frc: the site in the Plan as requested and required in this criterien.
S
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6.4.1.,a,(2)(B)
Page 51 of NUREG 0654, Criterion 4.
There's no discussion of decontamination at or near the offsite location in the area of the Plan that describes evacuation of onsite personnel in the event of a site or general emergency.
6.4,1,a,(2)(a)
Page 51 of NUREG 0654, Criterion 5.
Plan does not provide for accountability of individuals within 30 minutes.
New Appendix Page 52 of NUREG 0654, Criterion 10.a, b, and c are not provided for in 10.8 the Plan.
Appendix 10.7 Appendix 10.5/10.6 22.
Plan must be revised to resolve the following criterion from Section K.
Radiological Exposure Control:
- 6. 8.1. a, (1), (a) Page 57 of NUREG 0654, Criterion Sa.
No specific action levels for determining the need to decontaminate are given.
6.4,1.,b.(2)(b)
Criterion 5b.
Few details are given about the means for radiological decontamination onsite or offsite, but especially with regard to the offsite capabilities.
6.8,1.,a.
Page 57 of NUREG 0654, Criterion 6.
Regarding 6a, no details are given
- 6. 8,1. b. (1) (d) relating to area access control.
Regarding 6b, no details are given 6.3.2a regarding the treatment of drinking water and food supplies.
Regarding 6.5,1,a.
- 6. 8,1,a, (1) (c) 6c, no specific criteria for permitting the return of areas or items to normal use are given.
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6.4.1,a, (2), (b) Page 58 of NUREG 0654, Criterion 7.
There's no discussion in the Plan of the capability for decontaminating relocated onsite personnel.
23.
Plan must be revised to resolve the following criterion from Section M.
Recovery and Re-entry Planning and Post-Accident Operations frort NUREG 0654:
9.0,3n Criterion 1, Page 60, NUREG 0654.
There's no discussion of the means to relax protective measures in the plan.
9.0,2.
Page 60, NUREG 0654, Criterion 2.
Insufficient detail of the organization is given in the plan.
There are just one or two key positions that are discussed.
9.0,1.
Page 60, NUREG 0654, Criterion 3.
No discussion is given in the plan of the means for informing members of the response organizations that a recovery operation is to be initiated.
Page 60, NUREG.0654, Criterion 4.
The plan does not establish a method 9.0,3,1.
for periodically estimating total population exposure.
7.6 24.
Annual exercise must include both State and local personnel.
Must 8.2,1.
conduct independent audits of the emergency preparedness program at least every two years.
Results must be documented and retained for a period of five years.
l 10 l
6 25.
Expand your plan to provide for periodic dissemination of information 8.1.1.g.
to the public regarding how they will be notified and what their actions should be in an emergency, this should include:
a.
Educational information on radiation b.
Contact for additional information c.
Sheltering d.
Evacuation routes Means for accomplishing this dissemination are:
a.
Information in telephone books b.
Periodic information in utility bills c.
Posting in public areas Information program is acceptable if the permanent and transient adult population within the 10 mile EPZ is provided an adequate opportunity to become aware of this information annually.
If the public information program is to be administered by local officials this must be stated in the plan.
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