ML19345D522

Forwards Evaluation Summary of 801021 Emergency Plan for Facility.Plan Addresses All Required Stds,But Fails to Provide Detail Required to Meet Most of Supporting Criteria

ML19345D522
Person / Time
Site:	Susquehanna
Issue date:	12/11/1980
From:	Matthew Smith Battelle Memorial Institute, PACIFIC NORTHWEST NATION
To:	Chestnut S Office of Nuclear Reactor Regulation
References
NUDOCS 8012150283
Download: ML19345D522 (11)

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OBaHelle Pacific Northwest Laboratories P.O. Box 999 Richland, Washington U.S.A. 99352 Telephone (509) 375-2442 Telex 15-2874 December 11, 1980 .

Mr. Steve Chestnut Emergency Preparedness Licensing Branch ,

Nuclear Regulatory Commission Washington, D. C. 20555

Dear Steve:

THE SUSQUEHANNA NUCLEAR POWER STATION EMERGENCY PLAN REVIEW Enclosed is a copy of our comments on the Susquehanna Emergency Plan dated 10/21/80. The plan is concisely written and addresses all of the. requi,ed s tandards. It fails to provide the detail required to meet most of the supporting criteria. The licensee has established the framework for a good plan, but needs to fill in the blank spots. As a result, the plan partially satisfies most of the standards.

Yours truly,

'Of _0ltY" M. L1oyd Smith Health Physics Consultant MLS/iml Enclosure cc: A. E. Desrosiers, Project Manager F. G. Pagano, NRC File /LB Site File

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EMERGENCY PLAN EVALUATION REPORT ON EMERGENCY PLAN EVALUATION REPORT SUSQUEHANNA STEAM ELECTRIC STATION PENNSYLVANIA POWER AND LIGHT COMPANY EVALUATION

SUMMARY

ThE Susquehanna emergency plan was evaluated against the requirement in NUREG-0654.

The plan satisfied standards L, M, N. The plan partially satisfied standards H, B, C, D, E, F, G, I and J.

The plan does not satisfy the intent of the standard for standards H and K.

The plan as written in substance meets the major objective in each standard but fails -to be complete enough to fill the required details in the criteria.

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EMERGENCY PLAN EVALUATION REPORT ON: Susquehanna FINDINGS ON STANDARDS & CRITERIA The second revision of the Emergency Plan issued by the Pennsylvania Power and Light Company for-their Susquehanna Steam Electric Station was evaluated to determine the extent of Company compliance with the sixteen Emergency Planning standards and associated criteria in Part I,I of NUREG-0654,'" Criteria for Preparation and Evaluation of Radiological Response Plans and Preparedness in Support of Nuclear Power Plants."

The following evaluation report lists each standard in order followed by a summary of planning commitments, overall evaluation and comments on plan deficiencies.

A. Assignment of Responsibility (Organizational Control)

To assure that primary responsibilities for emergency response in nuclear facility operator, State and local organizations within the Emergency Planning Zones have been assigned, that the emergency responsibilities of the various supporting organizations have been specifically established, and that each principal response organization is staffed to respond and to augment its initial response on a continuous basis.

SYNOPSIS: Primary responsibilities for emergency response by the licensee have been established. Federal, State, local and private response organizations and agencies have been identified.

The Onduty shift supervisor has been designated as the Emergency Director and is empowered to unilaterally implement and administer the provisions of the Emergency Plan during an emergency until relieved by the Superintendent of Plant or a designated alternate. The Vice President-Nuclear Operations is the Recovery Manager and is in charge of overall company response including continuity of resources.

EVALUATION: The plan partially satisfies the intent of the standard.

CRITERIA ANALYSIS (1) The plan infers that only individuals assigned to the Technical Support Center (TSC) will either be in attendancc or on call 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day (Section 1.2, Page 13). There is no statement regarding abi.lity to provide 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day response by other company emergency personnel or the capability to provide 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day manning of communication links.

(2) Appendix A containing " Letters of Agreement" from response organizations and agencies is not included in the plan as required by Criterion A3.

B. Onsite Emergency Organization .

To assure that on-shift facility operator responsibilities for emergency response are unambiguously defined, that adequate staffing to provide initial facility accident response in key functional areas is maintained at all times,

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(PAGE: .3 Susquehanna and timely augmentation of response capabilities is available, and that the interfaces among various onsite response activites and offsite support and response activities are specified.

SYN 0PSIS: The shift supervisor is designated the Emergency Director with authority and responsibility to immediately and unilaterally initiate emergency actions including providing protective action recommendations to State and local emergency response agencies.

The onsite emergency plan staff organization for all shifts and its relationship to the duties and responsibilities of the normal shift complement have been satisfactorily addressed. Those persons responsible for functional areas of emergency response activity have been specified by title and major tasks. -

Interfaces between onsite functional areas of responsibility and Company, Federal, State and locai response organizations are shown in Figure 5.4.

EVALUATION: The plan partially satisfies the intent of the standard.

CRITERIA ANALYSES (1) A clear cut line of succession for the emergency director position and the specific conditions for higher level management assuming this function are not identified. Section 5.2.1 states only that the superintendent of Plant or a designated alternate will assume Emergency Director responsibilities. The list of " typical" alternates is unsati sfactory. A firm several step list of alternates should be identified.

(2) The plan does not identify the Emergency Director functional responsibilities that cannot be delegated as required by Criterion B4.

C. Emergen'cy Response Support and Resources Arrangements for requesting and effectively using assistance have been made, that arrangements to accomodate state and local staff at the licensee's near-site Emergency Operations Facility have been made, and other organizations capable of augmenting the planned response have been identified.

SYNOPSIS: The Susquehanna plan provides for representatives of FEMA and DER /BRP at the E0F.

EVALUATION: The licensee's plan does not satisfy Planning Standard C.

CRITERIA ANALYSES:

Criterion 1 is not satisfied. The plan fails to list by title the person who is authorized to request Federal assistance, to document the specific Federal

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Susquehanna resources relied upon, or to document required support for Federal response.

Criterion 2 is partially satisfied. Although the licensee .has made provisions for the receipt of representatives from the Commonwealth of Pennsylvania, there is no prior preparation documentation of provisions preparation for dispatching a licensee representative to the principal offsite E0C.

Criterion 3 is not satisfied. No radiological laboratories are identified.

Criterion 4 is partially satisfied. Although supporting organizations have been identified, no letters of agreement are provided.

D. Emergency Classification System To assure that a standard emergency classification and action level scheme is in use by the nuclear facility operator, including facility system ar.d effluent parameters; and to assure that State and local response organizations, will rely on information provided by facility operators for determinations of initial offsite response measures.

SYN 0PSIS:

The submission by the licensee partially meets the objective. They have adopted the classification scheme from NUREG-0654. They satisfy the requirement for the site, general and analysed accidents emergency initiating conditions.

EVALUATION: The plan partially satisfies the intent of the standard.

CRITERIA ANALYSES:

l l They fail to address the following in Alert classification:

1. Loss of function needed for cold shutdown.

2. Coolant pumpt seizure leading to fuel failure.

3. Ongoing Security compromise.

4. Steamline break.

They fail to address the following in the Unusual Event C?assification:

l 1. Failure of a safety relief valve to close.

2. Loss of offsite AC power or the loss of onsite AC power generation.

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3. Loss of engineered safety features. .

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4. Loss of containment integrity requiring shutdown by task specification.

5. Security threat.

6. Train derailment.

7. Rapid depressurization of the secondary

8. Transportation of injured person to offsite hospital who is contaminated with radioactive material.

E. Notification Methods and Procedures Procedures have been established for notification, by the licensee, of state and local response organizations and for notification of emergency personnel by all response organizations; the content of initial and follow-up messages to response organizations and the public has been established; and means to provide early notification and clear instruction to the populace within the plume-exposure pathway Emergency Planning Zone have been established.

SYNOPSIS: The Susquehanna plan establishes procedures for the notification of response organizations, verification of messages (when appropriate) and mobilization of emergency response personnel. It references a system of prewritten messages consistent with each EAL for providing instructions on grotective action for population of the plume exposure zone.

EVALUATION: The licensee's plan partially satisfies Planning Standard E.

CRITERIA ANALYSIS:

triteria 1 and 2 are generally satisfied, although it is not clearly indicated who will notify the rail operator or the FAA to restrict access of trains and aircraft, respectively, to the plume EPZ.

Criteria 3 and 4 are not satisfied. There ought to be a standardized notification form devised that meets the requirements of NUREG-0654. Copies of the form should be available at the plant (Control Room and EOF), at the principal county E0C, and at FB4A and DEP/BRP.

Criterion 5 does not apply to the licensee.

Criterion 6 is not satisfied. There is no evidence applied 'that ' indicates that the time requirements described in NUREG-0654 for notification of the population of the plume EPZ can be achieved.

Criterion 7 is partially satisfied. Although provision is made for the broadcast of prewritten messages, there is no documentation of possible protective actions or any clear indication about the basis upon which they would be recommended.

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Susquehanna F. Emergency Communication Provisions exist for prompt communications among response organizations to energency personnel and to the public.

SYN 0PSIS: The Susquehanna plan provides documentation of a reliable communication system that is tested on a routine basis.

EVALUATION: The licensee's plan partially satisfies Planning Standard F.

CRITERIA ANALYSES:

Criterion 1 is partially satisf-ied. The plan fails to clearly indicate that offsite authorities have facilities staffed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> / day for the receipt of notification messages.

Criterion 2 is not satisfied. Although page 5-10 indicates that communication with medical support facilities is addressed in an Implementing Procedure, no satisfactory documentation exists in the plan itself.

Criterion 3 is satisfied.

G. Public Information Information is made available to the public on a periodic basis on how they will be notified and what their initial actions should be in an emergency (e.g., listening to a local broadcast station and remaining indoors), the principal points of contact with the news media for dissemination of information during an emergency, (including the physical 19 cation or locations) are established in advance, and procedures for c3ordinated dissemination of information to the public are established.

SYN 0PSIS: The Susquehanna plan addresses the dissemination of information to the public about radiological emergencies, provides for points of contact and space for the media, and provides a physical basis for timely exchange of information among designated spokespersons.

EVALUATION: The licensee's plan partially satisfies Planning Standard G.

CRITERIA ANALYSES:

Criteria 1 and 2 are partially satisfied. The plan describes means by which information will be disseminated but fails to document the content.

Criterion 3 is satisfied.

Criterion 4 is partially satisfied. No provision is made for coordinated arrangments for dealing with rumors.

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Susquehanna Criterion 5 is not satisfied. There is no mention in the plan of an annual seminar for the news media.

H. Emergency Faci.lities and Equipment To assure that adequate emergency facilities and equiment to support the emergency response are provided.

SYN 0PSIS: The plan satisfies the criteria that emergency centers be established. Discussion of these facilities is adequate except as noted under Criteria Analyses.

The plan provides for a quarterly inspection and inventory of emergency equipment and supplies. Discussion is adequate except as note under Criteria Analyses.

EVALUATION: The plan does not satisfy the intent of the Standard.

CRITERIA ANALYSES:

1. The plan does not indicate when the permanent Emergency Operations Facility (E0F) will. be in servi ~ce.

2. The plan fails to identify or discuss the geophysical phenomena monitors. Section 7.4.3 indicates the " natural phenomena monitors" are identified in Enclosure 7 to Appendix D of the plan. Enclosure 7 is not included in Appendix D.

3. Radiological monitors (Criterion H-5.6) are listed in Enclosure 8 of Appendix D. The listing, however, is not compatible to that given in H-5.b and fails to identify where process and effluent monitors are located.

4. The process monitoring equipment specified in Criterion H-Sc has not been addressed.

5. Section 7, .2 " Fire Detection Systems" indicates these systems are identified in Enclosure ', Appendix D. The enclosure is not in Appendix D.

6. The plan does not provide for acquisition of data from or for emergency access to offsite monitoring and analysis equipment as specified in Criterion H6-a, b, and c.

7. The plan provides for offsite radiological equipment in the plant vicinity (Enclosure 13, Appendix D) but fails to indicate where the equipment will be located. .

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8. Meteorological instrumentation and procedures to satisfy criteria in Appendix 2, NUREG-0654 are not addressed (Criterion H8).

9. Section 7.1.3 establishes an Operations Support Center (OSC) but fails to discuss capacity, shielding, ventilation, supplies and equipment as specified in Criterion H9.

10. Section 8.3 establishes quarterly inspection and inventory of emergency equipment and instrumentation but fails to address the instrument calibration or adequacy of reserves.

11. Appendix C identifies emergency kit locations rather than by category as specified in Criterion H-ll.

12. The plan fails to establish a central point for reception and analysis of all field monitoring data.

I. Accident Assessment To assure the adequacy of methods, systems and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency. condition.

SYN 0PSIS: The licensee has presented a good clear description of the methods to be used in making the dose assessment. These methods are based on measured input parameter from instrumentation measuring the concentration in the release paths to the environment. The instrument response is used a~s input into the computer system where it is dispersed by the existing neteorological condition and the dose calculated at five distance in the plume pathway. This method is backed up by nomographs and manual calculations and field survey results. A table of instrument response and equivalent concentrations that are used as the source term information and a projection of dose to the environment based on the potential burden in containment.

EVALUATION: The plan partially satisfies the standard.

CRITERIA ANALYSES:

Criteria 4 is not addressed.

J. Protective Response To assure that a range of protective actions is available for the plume exposure pathway for emergency workers and the public, guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in use, and that protective actions for the ingestion exposure pathway appropriate to the locale have been developed.

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Susquehanna SYN 0PSIS: The accountability for personnel is defined, the evacuation assembly areas are defined, and protective apparel is provided. The mechanism for initiating an evacuation and authority are defined. The basis for use of protective drugs is defined.

EVALUATION: The submittal by the licensee partially satisfies the objective.

CRITERIA ANALYSIS:

1. The evacuation beyond the assembly areas is not covered as a part of the licensee plan. A map of evacuation routes for plant personnel to host areas and means of transport for site personnel should be defined.

2. Maps of population distribution in each sector within EPZ are not provided.

K. Radiological Exposure Control To assure that means for controlling radiological exposures, in an emergency, are established for emergency workers and the affected population.

SYNOPSIS: The emergency plan provides for aid to afflicted personnel, emergency exposure control, decontamination and first aid, medical transportation and treatment, emergency exposure criteria and criteria for evacuation of the controlled zone and the exclusion area.

EVALUATION: The plan does not fully fill the requirement of the standard.

CRITERIA ANALYSIS:

Criteria 2 an onsite radiation protection program to be implemented during emergencies is not addressed.

Criteria 3a regiirements for provisions for 24 hour-per-day dose measurement capability ar. not addressed.

Criteria 3b requirements for providing for maintaining emergency dose records are not adddressed.

Criteria Sa requirements for defining the action levels where decontamination is required are not addressed.

Criteria Sb requirements for establishing means of decontaminating emergency personnel are not addressed.

L. Medical and Public Health Support To assure that arrangements are made for medical services for contaminated individuals.

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M. Recovery and Reentry Planning and Post- Accident Operation General clans for recovery and reentry are developed.

EVALUATION: The plan satisfies the standard by providing the organization structure and management assignment by title to implement control of the emergency and reentry.

N. Exercises and Drills To assure that periodic exercises are conducted to evaluate major portions of emergency response capabilities, that the results of exercises form the basis for corrective action for identified deficiencies and that periodic drills are conducted to develop and maintain key skills.

EVALUATION: The plan satisfies the standard by assigning the responsibility to the Supervisor of Emergency Response planning for maintaining Emergency preparedness including periodic drills and exercises at the required frequencies and type.

In addition, provisions are provided for orientation of employees in their responsibilities during emergencies.

O. Radiological Emergency Response Training To assure that radiological emergency response training is provided to those who may be called upon to assist in a~n emergency.

EVALUATION: The licensee's response satisfies the e tandard.

P. Responsibility for the Planning Effort; Development, Periodic Review and Distribution of Emergency Plans To assure that responsibilities for plan development, review and distribution of emergency plans are established and that planners are properly trained.

EVALUATION: The licensee plan meets the standard with the exception of the criterion requiring an independent audit of the emergency preparedness program.

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