ML19345E337

Forwards Public Version of Revised Util Emergency Plan

ML19345E337
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	12/28/1979
From:	Counsil W CONNECTICUT YANKEE ATOMIC POWER CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
Shared Package
ML19345E336	List: ML19345E335 ML19345E337
References
NUDOCS 8101130025
Download: ML19345E337 (1)

Text

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-t St Van U *t No

-90055 Mr. Robert L. Tedesco, Ass t stant Director hh

$j h h Division of Licensing i

6 U. 5. Nuclear Regulatory Commission W shington, D.C.

20555

SUBJECT:

Fort St. Vrain Ur*: No Emergency Res:ense D'a, c

REcERENCE:

NRC Letter Jd y 23, 198C

Dear Hr. Tedesco:

We are transmitting herewith three (3) copies o'

our

-e v ' s e::

emergency response plan.

This revised plan incluces enaages as a

result of the May 21, 1980, plant site review seet*og as we':

as certain changes that resulted from comments centa*9ed in y:ur July 23,

1980, letter.

In addition to the rev*sec plaa. we a e providing our response as Attachment A to this letter to address yeue July 23, 1980, letter.

As we indicated in the May 21, 1930, meeting as wei' as 1 va- % s correspondence subeltted as a part of the TMI-2 Lessons Lea-9ed Tasks, tre t:elieve Fort St. Vrain is a ccooletely di'fereat eacta-concept.

This reactor concept coupled with the size o' the

-eact:r negates many of the requirements setfortn by NUREG's 0654 and 06:0 which were developed primarily on the basis of 1,000 %(e) 1*gnt l

water reactor technology.

It is imperative, there' ee, tnat our j

Emergency Plan be evaluated on the basis of our reactor des ga a-c i

size, and that generic requirements be evaluated on.t9e ::as

• 5 o' specific technical, safety, and environmentat di f f e rince s'.

We have had to essentially develop our own criteria for Fort St.

Vrain uttitzing water reactor criteria set 0rth by var *ous Nuctear Regulatory Commission documents.

On t b t ?.

basis awe c-i e-ia $s t

necessarily different from that oublished and we

• ave taae a justifiable exception to the NUREG's.

These er:e:

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supported in various correspondeace (see re'e eace 1 st atta: rec) a-c are further supported by Attachment A of t94 5 Inttee.

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In the key 21, 198t., meeting we were info me: ty tre L :'ea-Regulatoey Commission Mview team that many cf the te 5

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agtter of pclicy, and t+:st the review tear. cic not nave tne a.,t :

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te make exceptions on policy matters rega-cless of tre to:*

a' justifiention.

We cannot 4ccept this 00sition, anc we 'e:aest tsat

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as soon as you have had the opportunity tc review su-

• ev se:

emergency blan and our respohse that we Oc giv?n the Opccetar.* y te meet with you and other personnel who do have the autno-ity ::

evaluate and/or accept our positions on the tests of the te:ar :a' ju3 tift:4 tion provicec.

In the inteatst of time it is requestec tb2t suCP 4 meet ' 95 ::e establishec at the earliest possible case so that we may *?na't:e cu-Dians to meet the various comunitment cates setfoetn we.i :e ava'lable to meet with you at your convenience anc are loceng forwaad to hearing from y,ou shortly.

Very truly yours, S 77 %

Don W. Warembourg Managee, Nuclea-Procu: tion Fort St. Vrain NL: lea

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..o PSC CORRESDCNDENCE LISTING n00 LE~TERS TO NRC INVOLV!WG-gU U

TMI-2/ EMERGENCY PLANNING /E.YERGENCY RESPONSE P PF1tSOU% PRIVACY INFOMATION DELETED IM ACC' ORDANCE WIDI LIE

~ Corr 6spondence nun'DU$ Of INM.MATION ACT

,Numoer

~ Date

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Subject l

1..P-79130'

-du..nt.15,.1979_...~.._

GasecuY 'Ef f1'uent-Meditors

2. ' P-79205"~~---Septemmer.105,,,1979 Emergerfdy "PfiriniiT,~ For.t!

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'St; Vrain

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P-79239

+ : October 17,'1979-- -

Fol.15wup' Action TMI-2..

4.

P-79249 October 29,.'1979

-- Follow,up : Action Resulting

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Trom:NRC Reviews Regarding the TMI-2 Accident

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5.

P-79290 ;." November 30, 1979 NUREG-D610 6.

+-79298...

~ December 12,.1979,-

Fbrt-St..yrain, Unit No..1, TMILe s sons-t. earned

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'Aitit 7.

,P-79299, ' December 12, 1979 Revised. 7.TolloGup

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"RegardYng TMI-2 Acci.d.ent s.

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P-79305 Decernber 18, 1979 SIloplem'enney; Re sp'idse,

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' Item 1/2.1.b,.

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.rearned Ta'sK Force',- TMT-27

9. -P-79312

'.. Oecember"28, 1979 "- ' Addi ti gn'a l -

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Re'gatdbig.

June' 1, Ibl980,

. ; A.ct.f on Tt' ems Res0ltf rid 'f rom

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10.

P-80011,

- January 29, 1980:

.Requst - for.Ev4cGatf 6n' ' '

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P-30028,

- F.ebrua ry 20,.19801...Z.rJd61.t l orial '

Informatior,

.Resul tf.ng. f 6sm TMI-2~.'NRC-

.....7.7 Review. Team ' Site Visit,

..Jan'uary 2'1"22, 1930.'

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Re' quest, -' for...Evacu)ati'on 12.

P-80041

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P-80083 March l8,~1980 z

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...esponse Plan._._ p, M C-7.,:' - V.

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14.

P-80066 April 1, 1980 i Fo'rt.St." NraTn, 'Orii do.' 'le%"_.-

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.Emergedcy Planning

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DON C# !@CAEAtION ACT '

ATTACHMENT A PSC RESDONSE TO NRC COMMENTS FSV EMERGENCY RESPCNSE PLAN 1.

NPC Question / Comment Plan must be revised to establish a principal and an alternate EOF.

Both facilities should meet the requirements of Darrell G. Eisenhut's letter of April 25,

1980, subject'

" Clarification of NRC Requirements for Emergency

Response

Facilities at Each Site."

PSC Resconse We cannot address the principle and alternata EOF as we have never received the April 25, 1980, letter which you reference.

It is our understanding that new criteria will be published as a part of NUREG-0696.

Upon receipt and evaluation of this document we will modify our emergency plan.

In the interim we' intenc to continue with our plans to utilize the Fort Lupton Municipal Building for the 50F as stated in our letter P-80083.

As we understand the new criteria being developed under NUREG-0696, t distance of approximately 10 miles from the r.eactor would be acceptable for the EOF.

Depending on the critoria specified for the EOF and an alternate EOF we will re-evaluate our position at the time NUREG-0696 is published.

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2.

NRC Ouestion/ Comment Plan must ce revised to take into consideration the plant staffing in Table B-1 of NUREG-0654 There must be some augmentation of on-site personnel within 30 minutes. Must icentify position that will not be filled and provide rationale for not having 10 personnel on shift at all times.

PSC Resconse Conside,ation was given to the plant staffing in our April draft of the RERP.

Figures 5.1-1 through 5.2-6 of tne RERP depict both the normal and the emergency staffing for the plant.

Figure 5.1-2 provides the normal operating staff (9 personnel plus a Lead Security Officer) for the plant and fulfills the on-shift requirements of Table B-1, NUREG-0654, with the exception that we do not have a Rad / Chem Technician on shift.

The on-shift Health Physics Technician has sufficient training to perform the necessary initial surveys anc radiological assessments to protect in piant personnel.

The operating staff has sufficient training and procedures to evaluate the off-site effects. We can see no immediate requirement for the Rad / Chem Tecnnician especially since our accidents develop at a much slower rate than comparable water reactor accicents (sae NRC letter Themis Speis to J. Fuller, March,1980, Acceptance of Category A TMI-2 Recuirements).

.. With eference to the augmentec staff called for in Table 5-1, NUREG-0654, we have justified delaying the response time of the Shift Technical Advisor (STA) (based again on the rate in wnich our accidents develop) from 10 minutes to onc (1) hour (see PSC letters P-79249, October 29, 1979; P-79299, December 12, 1979:

P-79305, December 13, 1979; P-79312, December 28, 1979).

The accicent time frames and the associated response times were accepted by the Nuclear Regulatory Commission by the above referenced letter (Tnemis Speis to J. Fuller, March,1980) in

-the overall acceptance of the Category A TMI-2 recuirements.

Since tne Nuclear Regulatory Commission found the response time of the STA to be acceptable we maintain that the 30 minute augmented staff time called for in NUREG-0654, Table 3-1, is not applicable to Fort St. Vrain.

On the basis of the slow time in which accicents develop and the one (1) hour resonse tima of the Technical Advisor we committed in our RERP (Section 5.2) to have the emergency organization activated within 90 minutes which would include an augmented staff equivalent to Table B-1, NUREG-0654 This staff augmentation is consistent with Technical Advisor response time and is certainly consistent with accident analysis and the accident development time frames.

3.

NRC Cuestion/ Comment The plan must (in addition to otner NUREG-0610 notification requirements) specify that when a " general" emergency is declared that the off-site authorities resconsible for implementation of protective measures will be notified oy the

" Plant Emergency Director" and acvised of recommended protective actions within 15 minutes of the direction of the emergency condition.

The plan must specify the content of this initial messtge to include:

a.

Class of emstgency b.

Whetner a release is taking place c.

Affected areas d.

Protective measures NOTE: The protective measures recommended in the initial message off-site may be "go inside - turn on radio" (30 minutes) proviced a followup message incicating more detail protective measures based on dose projections.

PSC Resconse Per your request the notification time of fifteen (15) minutes after determination that a " general" emergency exists has been acded to Table 4.1-4 of the RERP.

Samole notification messages as well as followup messages have been included in Section 6 of the RERP (see Figures 6.1-1 through 6.1-3).

. 4 NRC Ouestion/ Comment Your plan must descrice the public notification system to include:

a.

The initial off-site contact who will be responsible for notifying the affected population (either the specific organi:ation or individual).

b.

The capability for 24-hour-per-day notification (to off-site authorities).

c.

The physical alerting system to be used:

sirens, NOAA weather of emergency alert, telephone automatic dialers, aircr@ft with loudspeakers (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.)

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Distance

% Notified in 15.M16utes 5 miles 100%

d.

The basis for any exceotions (e.g., for extended water areas with transient boats or remote hi ki ng trails) must be documented.

e.

Every year you must take a statistical sample of the residents of all areas within the 5 mile EPZ to essess the public's awareness of the prompt notification system and the availability of information on wnat to do in an emergency.

Plan must also include a provision for corrective measures to provide reasonable assurance that caverage approaching the design objectives is maintained.

f.

The provisions for use of a public medit system (radio, TV) to provide clear instructions to the oublic.

t a.

Twenty-four hour station - total plume coverage.

b.

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

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

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

. 4 PSC Resconse a.

The County and the State have the responsibility for noti'ying the affected population.

Additional clarification has been added to Section 6.1 of the RERP.

b.

The capability of 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day notification to off-site authorities is included in Section 7.2 of the RERP.

-c.

and d.

The physical alerting systems proposed both by the Fort St. Vrain RERP and the State RERP is the use of the emergency broadcast system (radio) and the dispatch of County personnel in vehicles and loud speakers to warn the general public.

As indicated in our letter P-80083, March 18, 1980, we have more than adequate time to effect necessary protective actions prior to exceeding any of the Protective Action Guidelines.

During the February 28, 1980, drill we tested the State Emergency Response Plan and determined that the general puolic in the affected zone could be notified within 90 minutes. As indicated in our letter p-80066 we have uc to twalve (12) hours to notify the public criar to exceeding the most restrictive Protective i

Action Guideline (iodine inhalation) at the exclusion area boundary. The plan for public notification includes the use i

of several emergency broadcast bands and the use of television augmented, of course, with dispatched personnel.

On the basis of the time frames associated with our accident analyses and the use of radio and television media we:can see no justification fcr an early warning alert system.

e.

As a part of the public infccmation program a statistical sample of the residents within the five (5) mile EPZ will be taken to assess the public's awareness of what to do in an emergency.

The details of the public information program are still being worked out between PSC and the State. Once this program is defined Section 8.1.1.d of the RERP will be developed to define the program.

f.

Use of the media systems to orovide instructions to the public is the responsioility of State, County, and lecci authorities.

The State RERP which is approvec by PSC a3s provisions for the use of media systems that meet the l

recuirements of NUREG-0E54.

Section 6.4.1.b of the RERP l

addresses this subject.

5.

NRC Ouestion/ Comment Under PSC actions, Table 4.1-1, page 1, the first item, the 2-hour time limit for notification of an occurrence of an l

Unusual Event should be changed to "as soon as ciscoverec.

Similarly, the fourth item under PSC action should include a requirement for a written summary within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

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.. PSC Resoonse Notification of the State for unusual Events was established prior to our receipt of any guidance on TMI-2. We have reached agreement with State (see attached agreement) for notification of Unusual Events, and both PSC and the State are satisfied that this agreement is more than adequate.

Table 4.1-1 of the RERP reflects the requirements of this agreement which has been in effect for some time now (November 16,1979). The agreement has been implemerted on several occasions and appears to be more than sa ti s f acto ry to fulf ril our needs as well as the State's needs. The two. (2) hour notification time was established with ne clock starting at the time of tne incident.

The two (2) hours was adopted to provide time for station operators to bring the situation to a safe condition, properly assess the incident, and make a factual report to the State.

In miny instances the report to the State will be mace much sooner inan the two (2) hours, newever, it must be recognized that in some instances it may take some time to bring the situation under reasonable control and make necessary assessments of plant conditions.

For the Unusual Event category the two (2) hour notification time appears to be more than adequate especially if one considers the Significant Event Notification system for the NRC under I&E Information Notice 80-06.

Reporting criteria under this information notice allows a one (1) hour notification time af ter assessment of situation. Although a two (2) hour notification time has been established it is our intent to notify the State as soon as practicable within the two (2) hour time frame.

With reference to your comment concerning a written summary within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, this has not been a requirement of the State.

Both PSC and the State are satisfied with verbal closecuts. As long as the State and Local authorities are satisfied we can see no reason to incorporate a recuirement for a written closecut witnin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

6.

NRC Cuestion/ Comment Table 4.1-1, page 1, under initiating events.

Initiating event number 3 in the plant should be changed to indicate a fire lasting more than 10 minutes as is expressed in initiating l

examole 10 on page 4 of NUREG-0610.

It is recogni:ed that the technology of a gas-cooled reactor is different from light-water reactor technology. Therefore, some of the initiating examples i

shown in NUREG-0610 may not be applicable to a gas-cooled reactor. Hc*ever, the licensee should explain the basis for not i

including the following initiating examples.

The initiating l

examples in question are found on page 4 and 5 of NUREG-0610.

They are examples 2, 4, 6, 7, 6, 9, 11, 12, 14e, and 15.

pSC Resoonse l

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We purposely did not define the duration for fire, and elected instead to define the fire in terms of the pctential for affecting the health anc safety of the public.

There are many

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6

. areas bo,% within and outsice the plant wnere a fire lasting longer that, ten (10) minutes would have no significant effect on the health and safety of the public.

These types of incidents may arouse public interest or cause some public concern, anc on this basis we have established an information exchange with State (see Item 8 of the attached PSC-State Agreemnt) to ensure that State and Local officials are properly informed prior to releasing any public information.

Item 8 of the State-PSC Agreement, hcwever, is outside the jurisdiction of Table 4.1-1

-and is therefore not involved in the table.

With reference to the other examples cited by NUREG-0610, these examples were not included for the following reasons:

Radiological Effluent Techrical Specification Examole 2 Limits Exceeded.

We consider this item to be covered by Item 1 of Table 4.1-1 in that any gaseous release must be processed by the reactor ventilation system, even for planned radiological releases.

For licuid waste releases, we have no source of nighly contaninated liquids.

Release of any liquids above technical specification limits would result in mixing this release with the cooling tower blowdown with retention of blowcown water in a holding pond on PSC property.

Such a release is reportable to the EPA / State Health Decartment, and sufficient time is available to take corrective action if necessary with the retention time provided by the holding pond.

Abnnormal Coolant Temperature and/or Abnormal Examole 4 Fuel Temperature.

Item 2 of Table 4.1-1 is intended to fulfill the requirements of Example 4.

Coolant temperature and reactor pressure are controlled by Technical Specifications with conservative limits to ensure fuel

(

integrity.

We can see no reason for reporting conditions to the State that have no safety imolications when these conditions are within established Technical Specification limits.

The prima ry concern is the increase of circulating l

activity which would result from abnormal coolant temperatures and therefore we have defined this parameter for initiating the Unusual Event.

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. Examole_6 - Failure of a Safety or Relief Valve to Close.

As written example 6 could include any safety or relief valve from the domestic water system to the reactor coolant system wnich in most cases would lead to unnecessary *eporting and/or notification.

Any safety or relief valve of significance at Fort St.

Vrain (i.e., the PCRV relief valve) that would lead to the release of radloactive materials would b& reported under Item 1 of Table 4.1-1.

Less of Off-site Power or loss of AC Power Examole 7 Capacility.

Short term losses of off-site power or a loss of AC power capability have no immediate safety imolications at Fort St.

Vrain.

As discussed in various correspondence our accidents develop slowly with long periods of time being available for operator action.

Var ous accident conditions were discussed in our d

letter P-79305 and on the basis of this letter the loss of outside power and on-site AC power cacability was included in the alert classification and was not included in the Unusual Event category.

Examole 8 - Loss of Containment Integrity Requiring Reactor Snutcown.

We ce not nave the conventional containment building that is associated witn lignt water reactors.

Our containment is an integral part of the PCRV. Any minor containment leakage that could result in a release of radioactive materials would be reported to the State under ne provisions of Item 1 of Table 4.1-1, wnether the release resulted in a reactor shutdown or not.

We feel this approach is conservative and encompasses Example 8.

Loss of Engineered Safety Feature or Fire Examole 9 Protection System Function Requiring Shutdown by Tecnnical Specificaitons.

There are several limiting conditions of operation (LCO) in the Technical Specifications that would require a plant shutdown.

As long as the plant is brought down in an orderly manner under the provisions of the Technical Specifications we can see no reason for initiating Unusual Event Notification to the State for the above examples or the many other LCO's.

Problem areas that result in plant shutdowns are reported for the State under the provisions of Item 8 of the attached State-PSC Agreement.

Items under this category are consicered to be informational in nature and are tnerefore not incluced in tne Table 4.1-1 and the Unusual Event category.

~

. Indication or Alarms on Process Effluent Examole 11 Monitors Not Functional.

See response to Example 9 above.

Examole 12 - Security Threats or Attempted Sabotage.

Security threats are handled separately with Weld County, the local governmental authority.

Procedures are in place for security threats and attempted sabotage wherecy Weld County, who is the response agency, is promptly informed.

Any State assistance or notification of the State is accomplished by Weld County authorities as may be appropriate. We do not therefore consider this to be i part of the Unusual Event category.

Examole 1{e - Turbine Failure We interpreted this item to be a physical turbine l

failure such that the turbine was physically damaged.

Since the secondary side, specifically the turbine at Fort St.

Vrain does not have the potential for radioactive release we did nct include this item in the Unusual Event category.

Again these types of informational notices would be cade under Item 8 of the State-PSC Agreement.

Examcle 15 - Other Conditions.

This category is so broad and all inclusive, it would be impossible to establish sufficient reporting guidelines for the operator to follow.

Again information tyce reporting to the State is handled under Item 8 of the State-PSC Agreement. We have purposely avoided placing undefined ambiguous requirements in the Unusual Event category. Such reporting serves no useful purpose to the State or PSC and only serves to confuse the more important reporting requirements.

7.

NRC Cuestion/ Comment Initiating event number 5 is similar to initiating event 7 on page 7 of NUREG-0654. The 30 minutes mentioned in initiating event number 5 in the plant should De discussed and justified.

PSC Resoonse The tnirty minute time frame was established on :ne basis of the accident analyses for Fort St. Vrain wherein the operator has up to thirty minutes to restore forced cooling without any core or component damage (see P-79305).

Since the ultimate end result of the loss of off-site and on-site AC power would be the loss pw,.

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of force

circulation we feel justified in establisning tne 30 minute time frame.

8.

NRC Ouestion/ Comment Table 4.1-2, page 1, under the column listed PSC actions, item 5, corresponds with licensee action number 5 on cage 6 of NUREG-0610 and the updates in that item are required at least every 15 minutes; therefore,' this requirement is requested to be put in the plan.

PSC Resconse The requirement for fifteen minute upcates has been incorporated into Taole 4.1-2.

9.

NRC Ouestion/ Comment Item 7 uncer PSC action corresponds witn item 7 on page 6 under licensee actions of NUR'G-0610.

The licensee action 7 in the criterion asks for a written summary within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> rather than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

PSC Response The written summary within eight (8) hours has been incorporated into Table 4.1-2.

10. NRC Ouestien/ Comment Table 4.1-2, page 2,

under the column entitled initiating events, initiating event number 6 corresponds with initiating event number 8 on page 7 of NUREG-0610.

Initiating event numeer 6, however, in the plan gives a time interval of up to 30 minutes. This interval should be discussed and justified by the licensee.

pSC Resconse The thirty (30) minute time frame is based on the Fort St. Vrain accident analyses.

See response to question 7 above.

11. NRC Ouestion/ Comment Table 4.1-3, page 2,

under PSC actions.

The second item requires PSC to terminate or recommenc reduction of emergency class verbally at FCP followed by a written summary within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. An eight hour time interval is given in NUREG-0610, page 9, under licensee action item number 9.

pSC Resconse The eight (8) hour written summary has been incorporated into Table 4.1-3.

i L

. 12.

NRC Cuestion/ Comment Tacle 4.1-4, page 1, under the column initiating events. There should be some discussion of initiating events 3 and 4 on page 15 of NUREG-0610 regarding possicle relevance and applicability to Fort St. Vrain.

PSC Resconse

- Exampl e 3 involved transients requiring operation of shutdown systems and failure to scram which could lead to core camage and acditional failure of core cooling makeup which would lead to a core melt. Various reactivity scenarios have been addressed in the Final Safety Analysi s Report and all of the accident scenarios are enveloped by Design Basis Accidents #1 and #2.

Uncer the conditions of DSA-1 or DBA-2 we do not release sufficient quantities of radicactive materiais to get to the radiological conditions set forth by NUREG-0610 for a General Emergency. With the slow rate at which the core heats up tne operator has adequate time to initiate the reserve shutdown system on a failure to scram. Tne reserve snutdown system is cesigned to bring the reactor suberitical with no control rods in the core. Given the slow core heat up characteri stics,

the ceramic core configuration wnich crecludes a core melt, and tne fact that our shutdown systems are in normal operation Example 3 is not considered to be applicable to Fort St. Vrain.

Example 4 involves failure of off-site and on-site power along witn the total loss of emergency feecwater makeuo capability which would lead to a core melt.

Loss of off-site and on-site power is addressed in Section 10.3.2 of the Final Safety Analysi s Report.

Again the ultimate worst consequence of this incident would be enveloped by the loss of forced coolant accident, DBA-1.

As mentioned previously doses from this permanent loss of forced circulation are orders of magnitude lower than 10CFR100 limits and are considerably lower than the I

one (1) rem per hour whole body or five (5) rem per hour tnyroid i

specified as the threshold for " General Emergency" by NUREG-0610. On the basis of the emergency action levels Example 4 does not get us beyond the " Site Emergency" category and j

therefore this example was not considered in Table 4.1-4 Both Examples 3 and 4 were downgraded to Table 4.1-3 because of the accident effects.

13.

NRC Ouest1on/ Comment Table 4.1-4, page 2, under the column entitled PSC actions, the last item which says,

" Terminate or recommend reduction of erergency class by briefing authorities at the FCP, followed by written summary within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />." NUREG-0610 on page 12, item 9, recuests a written summary within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

. PSC Rescense Table 4.1-4 has been revisec to incorporate the eight (S) hour written summary.

14 NRC Ouestion/Cemment The sample emergency message of Figures 6.1-1 and 6.1-2 need to be developed.

PSC Comment Sample emergency messages are inclucec in the emergency plans as Figures 6.1-1 tnrougn Figure 6.1-3.

15.

NRC Ouestion/Cemment Criterien 8,

page 46.

What other sources of real time meteorological information are there?

The plan mentions the Stapleton Airport on.page 7-6.

Is this the only alternative source of meteorological information?

PSC Resoonse At the present time Stapleton Airport is an alternate scurce along with the NCAA weather tower located near Erie, Cclorado.

We are presently working with the National Weather Service on additional and/or alternative sources. As seen as our plans can be finali:ed we will amend our emergency plan to reflect final arrangements for alternative meteorological infermation.

16. NRC Ouestion/Cemment Criterion 10, page 46 of NUREG-0654.

Criterion 10 requires the operational cnecking of the emergency equipment at least each calencar quarter and after each use and also calibration of equipment at intervals recommended by the supplier. There is no provision evident in the plan to satisfy this criterion.

PSC Rescense Section S.3 of tne emergency plan accresses cperational checking of emergency equipment and meets the recuirements of Criterion 10.

17. NRC Ouestion/ Comment Criterion 11, uage 46 of NUREG-0654. Appendix 2 in the plan was intended to satisfy this criterien; however, Appendix E is blank. When will it ce available for insertion in tne plan?

. PSC Resconse Appendix E is now complete anc has been incluced in the plan.

18. NRC Ouestion/ Comment Criterion 12, page 46 of NUREG-0654. There is no discussion in the plan of a central point for the receipt and analyses for all j

fielc monitoring data.

PSC Resconse Section 5.2.1.b.1 and Section 5.2.2.a discuss tne emergency function of the Technical Support Center and assign the Technical Support Center director as the central point for plant and on-site information. Off-site data is controlled through the Forwa rd Command Post (EOF in NRC terminology) in which OSC has a corporate officer assigned in adcition to technical representatives, and tne State and local authorities have representatives (see Section 5.4.1.a).

The Colorado Health Department radiological monitoring teams are cispatched and controlled from the Forward Command Post.

Information from the Forward Command Post is forwarded to Camo George West (State EOC) and to the PSC Executive Command Post (ECP) in Denver as may be appropriate.

PSC has technical personnel assigned to Camp George West to provide technical assistance and guidance to the State and the Governor.

Section 5 of the emergency plan describes the emergency organi:ation and functions.

19. NRC Ouestion/ Comment i

Criterion 1,

page 47 of NUREG-0654 Are the parameter values and One corresponding emergency class in the facility emergency procedures as required in criterion I?

l PSC Resconse l

PSC's internal emergency procedures are being developed in accordance with the emergency plan requirements.

Parameter values and emergency classes will be incorporated into these implementing procedures.

20. NRC Ouestion/ Comment i

Criterion 2,

page 47 of NUREG-0654 relates to eage 7-3 of the plan. Will the containment monitor go to 108 D.

per hour, or remain on scale for every conceivable accident sequence?

PSC Resconse In our response to TMI-2 Lessons Learned (see P-79312) :he radiation monitoring capabilities were addressed to indicate that our monitcrs will remain on scale for DBA-1 and CBA-2 accicents.

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-_- 21. NRC Ouestien/ Comment Criterion 3a, page 47 of NUREG-0754 Is there a correlation between the containment monitor reading and the source term?

PSC Resconse We do not have containment as such, however, the range and response capabilities of ali radiation monitors were acdressed in P-79312.

Radiation monitor readings can be related to the source term.

Considering that the PCRV is in reality a part of our containment we must rely on primary coolant sample analysis to cetermine a potential source term should the release of primary coolant occur to the confinement builcing.

Releases from the confinement building are made via the reactor plant exhaust system which is monitored for noble gas and iodine anc these radiation monitor readings can be correlated to the source term for off-site releases.

22.

NRC Ouestion/ Comment Criterion 5,

page 48 of NUREG-0654, Are there meteorological readouts at the near-site emergency operations center, the technical support center, and the off-site NRC center?

PSC Resconse At the present time we do not have the provisions for meteorological readouts in the EOF, the interim Technical Support Centt, or the off-site NRC center.

The interim Technical Support Center is adjacent to the control room ano meteorological

'nformation is readily available. We are still working on meteorologd:al sources and transmission of meteorological data.

We anderstand that NUREG-0696 is being developed to provide further guidance on this matter. When this document is published and our plans are finalited, our emergency plan will be revised accordingly.

23. NRC Ouestion/ Comment Criterion 7,

page 48 of NUREG-0654.

Does the iodine instrumentation have a caoability of reading as low as 5 x 108 microcuries per cc under field conditions in any kind of weather, in spite of the presence of a radioactive noble gas background?

Is there any intention to use silver :eolite cartridge 3?

PSC Resconse We have on order seme new air samolers which will accomodate a silver zeolite cartridge. At the present time we are utilizing i

air sampiers with a cnarcoal filter and are utili:ing a multicnannel analyzer to count the collection filter (see l

P-79312 and P-79299). The existing method of utilizing charcoal l

filters in conjunction with a multichannel analyzer, and the new

. samplers wnich are on ord2r that will accomodate a silver teolite cartridge will provide tne capability of readings down to SE-8 microcuries per cubic centimeter. We cannot, however, address the collection efficiency of tne air samplers using either tne charcoal filters or the silver :eolite in all weather conditions. The Brooknaven report whicn specified the SE-8 cacability utili:ing silver :eolite did not address collection efficiencies and possible adverse effects under all field conditions.

We are still of the opinion that tnere is no

-instrumentation being marketed tocay that can meet ne 5E-8 criteria under all field conditions.

24 NRC Ouestion/ Comment Criterion 9,

page 49 of NUREG-0654 There is no discussien in the plan of the transportation and communication equipment and estimated deployment times.

PSC Resconse Section 6.2 of the emergency plan has been revised to adcress this area.

25. NRC Ouestion/ Comment Criterion 1,

page 50 of NUREG-0654 There is no time estimate given in the plan as required in Crite-ion 1 for warning on-site indi,iduals.

PSC Resconse On-site individuals are warned and repcrt to emergency stations by a system of sirens and announcements on the plant public address system (see Section 6.4.1.a).

We did not provide a time l

estimate for warning these people as the warning takes place immediately ucon discovery of conditions that warrant emergency action.

Road blocks are set up at tne main route entrances to the plant site to prevent any ingress of the public at the exclusion area coundary.

Based on past drills these road blocks b e been estaolished within 15 to 20 minutes of initial accident assessment.

The Visitor's - Center, which may have members of tne general public in attendance, is nc*:fied at the onset of any incident as a part of the operator's call list.

Internal implementing procedures require the Visitor's Center ventilation system be shut off and the personnel be evacuated to Fort Lupton if conditions warrant such action. Again, based on past drills this notification nas been accomplished within 10 to 15 minutes of the initial incident assessment.

Section 6.4.1.a has been revised to respond to Criterion 1 on page 50 of NUREG-0654 l

l l

l i

. 26.

NRC Ouestion/ Comment Criterion 2,

page 50 of NUREG-0654.

No transportation of on-site personnel is discussed or pr0vided in the plan.

PSC Resconse Section 6.4.1.a.3 has been revised to indicate that transportation is provided by private vchicles.

C7.

NRC Ouestion/ Comment Criterion 6c, Page 51 of NUREG-0654 There is no mention of radio protective drugs in tne clan.

PSC Resconse We did not address the use of radio protective drugs in our plans. As indicated in our '.e ter P-79205 nere is clearly no authority on the part of the Licensee for acministering these crugs along with the proolems of storage, expected snelf life, etc.

From all we can gather tni s subject is still being discussed internal to the NRC and there appears to be some disagreement between various organi:ations in tne NRC, the ACRS, and the Commissioners concerning the use _of_ radio protective drugs.

We have turned this matter over to the State Health Decartment as it appears that the Health Department is the only organi:atten with necessary authority to administer drugs.

If and when further guidance is received we will amend our plan accordingly.

23.

NRC Ouestion/ Comment Criterion 10m, page 55 of NUREG-0654 There is no discussion of the bases for the choice of recommended protective actions from l

the plume exposure pathway during emergency conditions. No j

specific references to bases documents are given in the plan.

DSC Resconse Section 6.4.1.6 indicates our intent to utilize the PAG's tempered, of course, with other circumstances in determining I

recommended protective actions with reference to achieving a l

maximum of dose avoidance to the general public.

I

29. NRC Ouestion/ Comment i

Criterion 5a, page 57 of NUREG-065'. No specific action levels for decontamination are given in tne plan.

PSC Resconse 6.4.3 and 6.5.2 address action levels for l

Sections decontamination.

. 30.

NRC Ouestion/Commert Criterien 4,

page 60 cf NUREG-Oc54 The plan coes not provice for periodically estimating total populatici execsure.

PSC Rescense Section 4.2 indicates that responsibi'ity for periodically estimating total population exposure rests with the State.

PSC,

-of course, will provide technical assistance as may be required.

31 NRC Ouestion/ Comment Qualification for persennel assigned to functional ares of emergency activities must be icentified.

PSC Resconse The function areas of tne emergency organi:ations were assigned by job title with assignments being made to those jobs in which the emergency responsibility is in the area of normal job Vice responsibilities (i.e., Corportte Emergency Director

? resident of Precuttien, Manager of Technical Support - Vice Presicent Engineering, Manager Media Relations - Vice President of Public

Affairs, etc.).

The emergency crgani:atien assignments were selected very carefully t-ensure that personnel with precar authority within the Ocmpa.1y were assigned to areas within their authority and normal areas of responsibility.

Qualifications for these jobs are centained in written job descriptions wnich are available for inspection.

In addition personnel qualifications for PSC persennel available for emergency response are contained in our letter P-79233.

We can see no point in n'cluding this type of voluminous information in the emergency plan.

32.

,NRC Ouestion/ Comment Plan states that the C rporate Emergency Director wne is located in the Executive Ccmmand Post, which is not operational for 90 minutes after an alert is decalred, is respons!ble for notification of State and local agencies concerning recommended protective actions.

Pleast clarify that State and local officials must be notified directly from site with EAL time constraints.

PSC Resconse The Corporate Emergency Director (Vice President of Production) is not located in the Executive Command Post, but is located at the Forward Command Post (see Figure 5.2-2).

The Executive Command Post which is in Denver is headed by the Company President and Chief Executive 0fficer. As indicated in Section E.2.1 the overall direction and coordination of the emergency remains with the Shift Supervisor / Control Rocm Director until the various emergency ergani:ations can be staffed.

Initial

.=

_ = - - -

- -. _ _ ~

_ = - _ _, -

_ = _ _ _ - _ _

_ _ =._ _-.

,. notification and initial assessment and protective actions are l

provided to the State fr0m the Control Room. Once tne Tecnnical Support Cente-is estaclisnec the flow of information is from the Technical Supcort Center to the Forward Command Post (FCP).

The functions listed for the Corporate Emergency Director are functions to be accomolished after the emergency organi:ations i

are staffed.

Reference is also made to Section 6.1 wnich should serve to clarify your concern.

I 33.

NRC Ouestion/ Comment Plan must specify the contractors who are to provide tecnnical j

succort.

PSC Resconse I

Table S.3.1 lists the contractor supcort. Appendix A has now 4

been completed and includes letters of commitment from various organi:ations that would be available for emergency response assistance.

34 NRC Ouestion/ Comment Plan must be revised to resolve the following communication concerns:

a.

Technical Support Center shows no communications with the NRC.

I b.

Figure 7.2-1 shows communications from the Technical Support Center to Personnel Control Room, Section 7.1 does not.

l c.

Personnel Control Center does not show communications with the Control Room or Forward Command Post.

I PSC Resconse a.

Figure 7.2-1 provices tne communication links within the emergency organi:ations. This figure has been modifiec to I

indicate the existing NRC hotline from the Technical Support Center to the NRC.

i b.

Section 7.1 was clarified to indicate communications from the Personnel Control Center to the Technical Supprot Center.

c.

The Personnel Control Center does not have a communication link witn the Forward Command Post.

This is intentional.

]

The intent of the on-site emergency organi:ation is to recort centrally to the Technical Support Center.

The I

Tecnnical Support Center is the gathering point of all on-site information which in turn passes this information te tne Forward Command Post.

We feel it is essential to maintain central on-site control to avoid report i

duplication, erroneous reports and confusion.

1

'. 35.

NRC Ouestion/Cemment Expand your plan to provice for periodic dissemination of information to the public regarding how they will be notified and what their actions should be in an emergency. This should incluce:

a.

Educational information on radiation l

b.

Contact for additional information c.

Sheltering l

d.

Evacuation routes Means for accomplishing this dissemination are:

i a.

Information in telepnene books b.

Periodic information in utility bills l

c.

Posting in public areas l

Information program is acceptable if the permanent and transient adult population within the 5 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, snis must be stated in the plan.

1 I

PSC Restonse I

PSC is presently working with the Sette on a Public Information Brochure. We are near finalizing tnis brochure along with our plans for dissemination of the brochure. We have not as yet, however, finalized the many details of the public information program. As soon as these details are finalized Section 8.1.1.d of the emergency plan will be submitted, l

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,J:

STATEMENT OF AGREEMENT _

NOTIFICATION OF U'iUSUAL EVE'iTS i

j 1

FCRT SAINT VRAIN NUCLEAR CENERATINC STATION The need for improved co=munications concerning operation of For:

Sain: Vrain Nuclear Generating Station is recognized by the S: ate of 2

Colorado (State) and Public Service Company of Colorado (PSC). Certain agreements have been established between the State and PSC, as well as other agencies, cencerning emergency response to radiological inciden:s.

i While these agreements set forth certain notification and response require-ments for major incidents that =ay occur during the design lifetime of Fort Sain: Vrain, it is mutually agreed that it would be beneficial to the Sta:e and PSC to establish additional ec==unica:1ons in the form of a notification system for certain abnormal or un':sual conditions that I,

may occur outside the guidelines of the existing agreemen:s.

I: is the purpose of this letter of agreement to set forth the guidelines and certain definitions necessary for improved communications to establish a notification system wherein the State will receive timely notification of unusual events as defined in Attachme:

A.

1.

In the event of inciden:s described in A::achment A, PSC shall assess the situation and shall no:1fy the State, utilizing the Notification Form in Attachment 3.

Calls will be made firs: to 279-8855 (State Emergency Numb 6r) and then 837-8350 (Governor's Mansion).

2.

Notification shall be made promptly upon comple: ion of the situation assessment. 1: is an:icipa:ed that no:ifi-4 ca:icn can be made within two (2) hours of the initiating event.

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3.

The notification shall serve to keep the state informed and/or to establish an alert status. This notification is dot cause for initiating the Radiological Emergency Response Plan.

4.

Upon receipt of the notification, the State shall verify the authenticity of the call by calling the return number specified in Item 11 of the Attachment B.

5.

In most 1nstances, the State vill receive follow-up communications once plant ranagement has assessed the situ-ation. Further communications contact concerning ter=ination of the event, press releases, etc., vill be established at this time.

We the undersigned hsreby concur with the p,rovisions of this agreement, ar.d the parties hereto will perform or cause to be perforced the require-ments set forth by this agreement to the best of our ability.

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State of Colorado Public Service Company of Colorado M

N D Sigied

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Signed

/

Richard D. Lamm R.F. Walker, President Governor and Chief Executive Officer

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o ATTACllMENT A CONDITION 3/ EVE *IS AT FORT SAINT VRAIN

• WICH MAY NOT REOUIRE IFITIATION OF A RADICLOGICAL EMERCENCY RESPONSE BUT WHICH REOUIRE TIMELY NOTIFICATION OF THE STATE OF COLOPJLDO

.s viv The following general categories of events are established as requiring prompt notification ot the State of Colorado by Public Service Company of Colorado, ouner and operator of Fort Saint vrain Nuclear Generating Station.

Notification shall be made in a timely fashion utili:ing Attachment B.

Such notification shall serve to inform the State of unusual events, and/or to alert the State of the potential of more serious conditions that could develop, which may subsequently require initiation of the Radiological Emergency Response Plan.

1.

Any unplanned radiological release to the reactor building or to the reactor building ventilation system.

2.

An indication of fuel failure represented by a 25% increase in circulating activity from previous equilibrium conditions.

3.

Serious fire at the plant, which could lead to substantial degradation of plant safety systems, or which could result in the release of radiological or toxic materials.

l 4.

Natural phenomena that may be experienced or threatened that represent risks beyond normal levels.

l A.

Earthquakes B.

Floods j

C.

Tornadoes D.

' Extremely high winds P

- (

A::achment A Page Two 1

1 1

i l

5.

Unusual Ha:ards Experienced.

A.

Aircraf crash on-site or near the site that is subjee: to public concern becaus4 of possible

I

detrimental effect on the planc.

7 4

1 B.

On-s!ce explosirns or near on-site explosions

[

that may be subject to public concern because I

of possible detrimental effect on the plant.

i j

C.

On-site or near on-site plan: related accidents that could result in the release of toxic =a:erial 1

or spills of flam=able materials.

6.

Any serious radiological exposure of plant personnel or the transporta: ion to off-site facilities of contaminated personnel 1

that may have been injured.

7.

Accidents within the State that may involve plant spent fuel shipments or plant radioactive waste shipments.

8.

Incidents censidered to be of a nature by the PSC to require

.I a public information release (as soon as the decision is made i

to issue a release.)

i I

i Notifica:1on of the above events shall consist of a description of the event, :he :ime of the event, accions :aken, and the existing condi-

ions with reference to the control _of the situation and the potential ha:ards.

j I

l

~- - - - - - -

ATTACH.ENT 3 INITIAL NOTIFICATION UNL'SUAL EVEN*, FORT S A!!C VRAIN STATION NOTIFICATICN BY PUBLIC SERVICE C09ANY OF COLORADO NUM3ER WILL RING AT !!iE STATE CALL (1) 279-8855 NL?SER WILL RING AT THE COLORAI)0 EOC OFFICE DURING NOPS.AL WORK-(2) 837-8350 STATE PATROL DISFATCHER DURING INC HOURS.

OFF NORMAL HOURS.

1.

Nane and Identity of Caller 2.

Da:e of Inciden:

Time of Inciden:

3.

General Category of Incident Unplanned radiological release Fire fuel Feilure Spen: Fuel Inciden:

Natural Phenomenon Earthquake Flood Tornado

'.*in d s Unusual Hazard Aircraf:

Explosion Toxic Material Other 4

Descrip:icn of Incident:

l 5.

Actions Taken:

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Attechm:nt D Page Twc 6.

Sts:us:

Under control by on-site staff, no off-site assistance an:1cipated. Final report.

Under control by on-st:e staff. Will keep Sta:e advised.

!Off-site ass. stance may be required. Will advisa.

(See ite: #7.)

4 Off-site assistance required.

(See item #7.)

If off-site assistance is anticipated or required, describe assis-7.

tance that has been or may be requested:

8.

Does the inciden: involve off-site releases or the potential for off-site release that would affect the general health and safety of the public as the result of Fort Saint Vrain conditions?

Yes No 9.

If yes, provide a general description:

BELOW FOR USE BY RECI?IENTS:

10.

Received by Date Time 11.

Verification of call to be made to 571-7436.

Call verified by Date Time esgyem sess eine.

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