ML19344E930

Forwards Request for Addl Info Radiation Emergency Plan. Requests Response by 800926

ML19344E930
Person / Time
Site:	Summer
Issue date:	09/02/1980
From:	Tedesco R Office of Nuclear Reactor Regulation
To:	Nichols T SOUTH CAROLINA ELECTRIC & GAS CO.
References
NUDOCS 8009120119
Download: ML19344E930 (19)

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.,h,p UNITED STATES a

3 NUCLEAR REGULATORY COMMISSION 3

J WASHINGTON, D. C. 20555 s,,, '*

SEP 0 21980 Docket No. 50-395 I

/

Mr. T. C. Nichols, Jr.

Vice President & Group Executive Nuclear Operations South Carolina Electric & Gas Company g

P. O. Box 764 g

Columbia, South Carolina 29281 l

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION We have reviewed your revised emergency plan for the V. C. Summer facility.

In order to complete our review we need additional information.

The information we require is contained in the enclosure to this letter.

Your responses to the enclosed requests should be provided not later than September 26, 1980.

Please advise us promptly if you are unable to meet this schedule.

If you require any clarification of the enclosed requests i

please contact the staff's assigned project manager.

Sincerely, W

Robert L. Tedesco, Assistant Director for Licensing Division of Licensing

Enclosure:

As stated cc w/ enclosure:

See next page 8009120119

Mr. T. C. Nichols, Jr.

Vice President & Group Executive Nuclear Operations South Carolina Electric'& Gas Company P. O. Box 764 Columbia, South Carolina 29281 cc: Mr. William A. Williams, Jr.

Vice President South Carolina Public Service Authority 223 North Live Oak' Drive Moncks Corner, South Carolina 29461 Troy B. Conner, Jr., Esq.

Conne, Moore & Corber 1747 Pennsylvania Avenue, N. W.

Washington, D. C.

20006 Mr. Mark B. Whitaker, Jr.

Group Manager - Nuclear Engineering & Licensing South Carolina Electric & Gas Company P. O. Box 764 Columbia, South Carolina 29218 Mr. Brett Allen Bursey Route 1, Box 93C Little Mountain, South Carolina 29076 Resident Inspector / Summer NPS c/o U. S. NRC P. O. Box 1047 Irmo, South Carolina 29063 Eb,

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i REQUESTS FOR ADDI',IONAL INFORMATION SOUTH CAROLINA ELECTRIC AND GAS COMPANY VIRGIL C. SUMMER NUCLEAR STATIGN RADIATION EMERGENCY PLAN 1.

Section 1.0, 1.1.14.

News Media Area / Where is it located? This facility should be discussed in Section 7.2 of the plan.

2.

Section 2.0, 2.5.2.

Participating Governmental Agencies / We have a requirement that you notify the offsite officials responsible for the implementation of protective actions within 15 minutes of detecting a (general) emergency condition.

They (offsite officials) are responsible for notification of persons within a 10 mile radius of the site within 15 minutes.

Under the present system, we don't feel that this can be accomplished for the following reasons:

The plan states that the S.C. Emergency Preparedness Division under the Adjutant General's Office, is directly responsible to notify j

local and coordinating governments to warn'the public for the purpose of evacuation. This statement is misleading since evacuation may not be the appropriate protective measure. The appropriate measure may be to instruct the public to remain inside with doors and windows closed, and listen to radio / television for further information, i

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Additionally, it is our position that local government must have the authority to notify persons within the 10 mile radius.

We question whether the 15 minute criteria can be met if the requirement exists for the state to first approve each such notification.

Under the present system, Fairfield County can, in the event of a General Emergency, begin protection action in the low population zone. The requirement, however, is for notification out to 10 miles rather than the 3 miles associated with the low population zone.

3.

Expand your discussion of the function and responsibilities of the Emergency Director, including those responsibilities which may not be delegated to other elements of the emergency oraanization. Additionally, you,hould specify the conditions for higher level utility officials assuming this function.

4.

Do you intend to use any private sector organizations as a part of your emergency organization?- If so, include a description of the concept of operations and relationship of these organizations to the total emergency preparedness effort.

5.

A description of your ability to contact responsible officials or agencies off-site to effect proper emergency response on a 24-hour per day basis must be in plan.

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Letters of agreement-with organizations having an emergency response role within the Emergency Planning Zones must be included in your plan. They should identify the energency measures to be provided, the mutually acceptable criteria for their imp *.ementation, the arrangements for exchange of information, and any limits on the actions of these organizations.

7.

Identify your arrangements to maintain your emergency operations continuously 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day for a protracted period. The individual responsible for assuring continuity of resources shall be specified by title.

8.

Table 3.1.

No mention of warning of the public or evacuation in table for degree of involvement by participating groups.

9.

Section 4.1.2.

Must activate EAL technical support center, on-site operations center and near site E0F.

10. Section 4.1.4.

Identify the confirmatory measurements in the field prior to implementation of evacuation protective action.

11. Section 6.0 (specific measures taken for each class of emergency defined in Section 4.0) must incorporate the following:

Sections 6.1.through 6.4 should be rewritten to reflect NUREG-0610.

The areas of responsibility and actions to be taken should be spelled out similar to the tables in NUREG-0610' 3

Specify for each class of energency, what you are going to do, recommendations, and what offsite authorities are going to do.

12. 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 state.

13. Your plan must describe the public notification system to include:

a.

The initial offsite contact who will be responsible for notifying the affected population (either the specific organization or

-individur.').

b.

The capability for 24-hour per day notification.

(To offsite authorities).

c.

The physical alerting system to be used (sirens, NOAA weather emergency alert, telephone automatic dialers, aircraft with loudspeakers) to alert the public.

(10 db above average daytime ambient background is a target level for design of an adequate siren system.)

Distance

% Notified in 15 Minutes 1

5 miles 100%

5 to 10 miles 90%

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The design. objective for the remaining 10% of the public within 10 mile zone is notification within 45 minutes 2fter no I

of local officials.

d.

The basis for any exceptions (e.g., for cytended water areas with transient boats or remote hiking trails) must be documented.

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Every year, operator must tape a statistical sample of the e.

I residents of all areas within the ten mile EPZ to assess the public's awareness of the prompt notification system ad the availability of information on what to do in an emergency, f.

The provisions for use of a public media system (radio, television) to provide clear instructions to the public:

(1) _ 24-hour station - total plume coverage.

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Include in the plan the messages to be transmitted to the public (cover a range of protective actions).

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The plan must also include a provision for corrective measures to provide reasonable assurance that coverage approaching the design objectives is T

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It is the operator's responsibility to ensure that the means exists for notifying and providing prompt instructions to the public.

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It is the responsibility of the State and local governments to activate the system.

14. Provide a brief description, with State and local governments, of the mutually agreeable basis of notification consistent with your emergency classification scheme. The classification of the State's emergencies-are different than those in 0610.

15.

Provide a standard format for the initial and followup emergency messages which will be used when contacting offsite authorities. The message content should be based on the information requirements specified in Section II.E.3 and 4 of NUREG-0654.

16.

Include in your plan, provisions for written messages intended for the oublic which are consistent with your emergency classification scheme.

These messages should provide sp cific protective actions to be taken by the occupants of affected a'eas. These messages should be located at the media center or near-site Emergency Operations Facility.

17.

Section 6.0 satisfies to some degree the requirement to specify licensee actions (NUREG-0654, App 1, pages 1-3,1-6,1-9 and 1-12). However, the plan does not do an adequate job in the sense of providing the detailed description of licensee action for each EAL in NUREG-0654. There should be a listing of licensee actions in the plan for each of the emergency classes at least as detailed as contained in the pages just cited in NUREG-0654.

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18. Page 13A-48.

Emergency Action Levels should be given for Table 4-2 according to NUREG-0654, page 36, Criterion 1 and 2, in the same way that they were provided in Table 4-1 of the plan.

19. Page 13A-32, Table 4-1, Initiating. Condition 11. The phrase, "within the control, fuel auxiliary, turbine, or reactor buildings which may affect safety-related equipment" should be removed from the initiating condition to be consistent with NUREG-0654, App 1, page 1-4, Initiatir_g Condition and Example No.10.

20. Page 13A-33, Table 4-1, Initiating Condition 15e. The phrase " causing casing penetration" should be removed in accordance with example Initiating Condition 14e on page 1-5 of NUREG-0654.

21. Page 13A-34, Table 4-1, Initiating Condition 18.

Between " shutdown" and " increased", the words "and requiring" should be inserted for clarity.

22. Page 13A-36, Table 4-1, Initiating Conditions No. 7 and 8.

The phrase "less than 15 minutes" should be removed from these initiating conditions to make them in accordance with example and initiating conditions 7 and 8 on page 1-7 cf dUREG-0654.

23. Page 13A-37, Initiating Condition No. 13.

It should read like Initiating Condition 13 on page 1-7 of NUREG-0654 which reads " fire, potentially

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affecting safety system."

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24. Page 13A-37. Initiating Condition No. 14. The Initiating Condition should be revised by removing the phrase, "and plant computer lost" in accordance with Initiating Condition No. 14, page 1-7 of NUREG-0654.

25. Page 13A-38, Initiating Condition No.16 The phrase " involving a physical attack on the facility" should be renioved from the Initiating Condition in accordance with example Initiating Condition No. 16 on page 1-7 of NUREG-0654.

26. Page 13A-38, Initiating Condition No. 17, Table 4-1.

A flood should be added to the list of severe natural phenomenon in accordance with Initiating Exam; e 17 on page 1-8 of NUREG-0654.

27. Page 13A-39, Initiating Condition No.18d should read " entry into the facility environs of toxic or flammable gases" as given on page 1-8 Initiating Example 19d of NUREG-OoS4.

Initiating Example 18e should be added to the plan.

28. Page 135-42, Initiating Condition No. 9.

The word " defeating" should be changed to "affecting" as shown in Initiating Condition No.10, page 1-10 of NUREG-0654.

29. Page 13A-43, Initiating Condition No. 13.

Initiating Condition should also list flood in accordance with Initiating Example 14b, page 1-10 of NUREG-0654.

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30. Page 13A-44, Initiating Condition 14c. This Initiating Condition should be modified by removing "above toxic or explosive levels" to be like Initiating Condition 15c on page 1-11 of NUREG-0654.

31. Page 13A-45 is rotated 180 degrees from the orientation of the other pages in the book and should be turned around.

32. Page 13A-47, Initiating Condition 8.

The word " imminent" should be changed to " potential" as shown in Initiating Condition No. 2, page 1-13 of NUREG-0654.

33. Page 13A-36, Initiating Condition No. 5 should be like Initiating Condition No. 5 on page 1-7 of NUREG-0654. At the present time, the Initiating Condition No. 5 on page 13A-36 and Initiating Condition No. 1 on page 13A-40 are the same.

34. Criterion 1, page 37 of NUREG-0654. There is no mention of verification means in the Plan as required and requested in the Criterion.

35. Criterion 3, Page 38 of NUREG-0654. There is no satisfaction of Criterion 3 in the Plan.

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36. Criterion 4, Pages 38 and 39 of NUREG-0654. There is no satisfaction of Criterion 4 in the Plan, t

37. Section 5.0.

Expand your description of personnel assignments to the l

various functional areas of emergency activity. Sepcific assignments 9

shall be made for all shifts and for plant staff members, both onsite and away from the site. Those assignments shall cover the emergency functions of NUREG 0654, Table B-1, Minimum Staffing Requirements for Nuclear Power Plant Emergencies. The minimum capabilities and staff on-shift and those available within one-half hour following declaration of an emergency shall be as indicated in Table B-1,

38. Provide a description of the procedures you will employ to notify your emergency response personnel.

Include an estimate of the time required to notify response personnel following classification of an emergency.

39. Sections 5.2 through 5.4.

Specify the extent and conditions of assistance to be provided by local agencies (police, ambulance, firefighting). Describe your provisions for transportation of contaminated injured personnel.

Describe your arrangements for support with the Department of Energy (DOE)

Regional Coordinating Office responsible for implementing the DOE Radio-logical Assistance Plan (RAP) and Interagency Radiological Assistance Plan (IRAP) including the following:

Specify persons authorized to request RAP /IRAP assistance; a.

b.

Make arrangements for using RAP /IRAP teams and equipment; and Identify the available RAP /IRAP resources relied upon.

c.

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40.

Identify the radiological laboratories, nuclear facilities or organizations, their capabilities and expected response times, which can be used in an emergency.

41. Criterion No. 2, Page 44 of NUREG-0654 Is the Emergency Operations Facility (EOF) onsite or offsite? The Emergency Operations Facility is-discussed on page 13A-92 in Section 7.2 of the Plan.

42. Criterion Sa, page 45 of NUREG-0654. There is no discussion of hydrologic geophysical monitors in the plan.

44 Criterion 6b, Page 45 of NUREG-0654 There should be 40 TLD sites, instead of 18 sites, according to the technical position for the environmental radiological monitoring program of the NRC Radiological Assesstent Branch.

45. Criterion 8, Page 46 of NUREG-0654 requires that the instrumentation for meteorological measurements should comply with the criteria in Appendix 2 of NUREG-0654. There is no discussion regarding redundant power sources for the meteorological equipment as required in Appendix 2, Page 2-2, Item 1.C(4) in NUREG-0654.

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46. Can the backup meteorological system provide information relating to the seven category A-G estimator of atmospheric stability as required in Item 2.C, Page 2-2 of NUREG-0654?

47. Criterion 9, Page 46 of NUREG-0654. There is no mention of shielding, capacity, ventilation, inventory of aupplies including respiratory protection, protec"tive clothing and portable lighting and communications equipment at the Onsite Operations Support Center in the plan.

48. Criterion 10, Page 46 of NUREG-0654.

Plan, Page 13A-126, Section 8.4.

There is no requirement in the Plan to operationally check equipment after each use.

There is no discussion of equipment reserves in the plan.

There is r.o discussion of calibration in.the plan as required in Criterion 10, Page 46 of the NUREG-0654,

49. Section 7.1.1.

Comments on Technical Support Center. Must be habitable to the same degree as the control room.

If not habitable, must provide a backup TSC which does meet the habitability requirements.

Parameters transmitted by a nuclear data link installed to meet future NRC requirements should be available for display in the TSC and the E0F.

50. Section 7.2.

Comments on Emergency Offsite Activities.

EOF must have the capability to display the same plant data and radiological information as will be required for transmittal to the NRC.

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EOF must have sufficient space to acconnodate representatives from the Federal, State and local governments, plus facilities for NRC representatives (10).

Management of resources including recovery operations shall be managed from this facility.

Must provide for facilities for about 20 press personnel.

EOF should be substantial structure, providing significant shielding factors from direct radiation. Filtration systems (at least HEPA filters) shall be provided in g structures.

51 Criterion 1, Page 47 of NUREG 0654. Are the parameter values and the corresponding emergency class in the appropriate facilit,y emergency procedures as required in Criterion 1?

52 Criterion 3, Page 47 of NUREG 0654. There is no satisfaction of Criterion 3 in the Plan.

53 Criterion 4, Page 48 of NUREG 0654.

There is no satisfaction of Criterion 4 in the Plan.

54 Criterion 5, Page 48 of NUREG 0654. Criterion 5 requires that there should be provisions for access to the meteorological information by at least the Nearsite Emergency Operations Center, the Technical Support 13

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Center and the Contki Room, and the Offsite NRC Center. There is no discussion of these readouts cited in the Plan.

55.

Criterion 6, Page 48 of NUREG 0654. There is no discussion of Criterion 6 in the Plan.

56 Criterion 7, Page 48 of NUREG 0654.

There is no mention of the capability of measuring down to 5x10-8 microcures per cc of radioiodine in the Plan.

57 Criterion 9, Page 49 of NUREG 0654.

There is no discussion of the field team composition, the transportation means or the estimated deployment times in the Plan.

58 Criterion 10, Page 49 of NUREG 0654. There is no detailed discussion of the requirements of Criterion 10 in the Plan.

59. Criterion 2, Page 50 of NUREG 0654. There is no discussion of transportation of onsite individuals in the Plan as required in this criterion.

60.

Criterion 3, Page 50 of NUREG 0654. There is no discussion of the material required in Criterion 3 of the Plan.

61. Criterion 4, Page 51 of NUREG 0654. There is no discussion of the requirements of Criterion 4 in the Plan.

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6& Criterion 5, Page 51 of NUREG 0654. There is no discussion of requirements of Criterion 5 in the Plan.

El Criterion 6, Page 51 of NUREG 0654. There is no discussion of Criterion 6c in the Plan.

64 Criterion 8, Page 52 of NUREG 0654. There is no Appendix J in the Plan which was reported in the Table of Contents to give evacuation time estimates.

65 Criterion 10, Page 52 of NUREG 0654. Relating to Criterion 10, there is no satisfaction of Criterion a and b, and there is no discussion of Criterion 10c or m in the Plan.

66 Plan, Page 13A-86, Section 6.5.1.

A person by position and title should be specified who can authorize emergency workers to receive doses in excess of 10 CFR Part 20 limits, as required in Criterion 2, Page 56 of NUREG 0654.

67 Criterion 3, Page 57 of NUREG 0654.

There is no adequate discussion of the elements in Criterion 3.

68. Criterion Sa, Page 57 of NUREG 0654. There is no discussion in Section 6.5.2 of the Plan, Page 13A-87 of the Action Levels for determining the need for contamination.

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69. Criterion 6, Page 57 of NUREG 0654. There is no discussion of Criterion 6 parts b and c in the Plan.

70 Criterion 7, Page 58 of NUREG 0654. There is no discussion of Criterion 7 in the Plan.

71. Criterion 1, Page 60 of NUREG 0654. There is no detail regarding the means by which decisions to relax protective measures are reached in the Plan, Section 9, 8 age 13A-131.

72 Criterion 3 and Criterion 4, Page 60 of NUREG 0654. There is no satisfaction of these criteria in the Plan.

73. Section 7.3.2, Page 13A-93. Clarify statement: "When the Governor determines that personnel and resources of State government are needed to support disaster operations of affected local governments, authorization is given by the Governor to activate the State Emergency Operations Center."

74 Section 7.5.

Expand the discussion of your communications systems to include the criteria specified in Section II.F.1 of NUREG 0654. Assure that your communications are consistent with the concept of operations described in Appendix 5 of NUREG 0654 covering the onsite technical sup-port center, the operational support center, and the near-site Emergency Operations Facility (EOF).

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4 Describe the provisions and frequency for testing your connunications 4

i system.

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75. We need letters of agreement and M00's with State, local governments, medical, fire, ambulance service, etc.

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76. Add a map to Appendix I which shows the locations of the ten areas used in your evacuation time estimates.

The Summer Emergency Plan should contain maps showing evacuation routes, sectors, relocation centers, inhost areas, shelter areas, hospital and other medical facilities in the plans to implement protective measures within the plume exposure pathway.

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