ML19347C558
| ML19347C558 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 11/30/1980 |
| From: | NRC/IE |
| To: | |
| Shared Package | |
| ML19347C557 | List: |
| References | |
| TAC 12144, NRC-2022-000198, TAC 41023, TAC 46275 NUDOCS 8012310055 | |
| Download: ML19347C558 (24) | |
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t EMERGENCY PREPAREDNESS EVALUATION REPORT BY THE DIVISION OF EMERGENCY PREPAREDNESS OFFICE OF INSPECTION AND ENFORCEMENT IN THE MATTER OF j
TROJAN STATION DOCKET NO. 50-344
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NOVEMBER 1980 I
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INTRODUCTION The Portland General Electric Company (hereinaf ter referred to as the licensee, the Company, PGE) filed, by letter dated May 16, 1980, with the Nuclear Regula-tory Commissien Chapters 1 and 2 of the Trojan Radiological Emergency Response Plan and Procedures Manual (hereinafter referred to as the Plan). Chapter 1 of the Plan is an overview while Chapter 2 is the radiological emergency plan for the Trojan Nuclear reactor site (hereinafter referred to as the plant or site).
The remaining chapters of the Plan are under development and are to be submitted January 1, 1981.
They will include the emergency plans for the State cf Washington, State of Oregon, Columbia County, Oregon, and Cowlitz County, Wadington. On July 1,1980 the licensee filed a draft of Appendix 1-B to the Plan entitled " Description of Public Notification System for the Trojan Nuclear Plant." On October 2, 1980 the licensee filed their responses to the issues identified by the NRC staff review of the May 1980 Plan.
The Trojan reactor is located on the border of Oregon and Washington with the plume exposure emergency planning zone (EPZ) located entirely within Columbia and Cowlitz Counties.
Figure 1:4-1 from the Plan reproduced here as Figure 1 shows the site relative to local jurisdictions.
The plume EPZ includes the area within 10 miles of the site and the entire towns of Longview, Washington and Columbia City, Oregon which border the 10-mile radius.
Chanters 1 and 2 of the Plan, Draft Appendix I-B, and the responses filed on October 2, 1980 were reviewed against the sixteen planning standards in 10 CFR 50.47, the requirements of 10 CFR 50, Appendix E and the specific criteria in NUREG-0654/ FEMA-REP-1 entitled " Criteria for Preparation and
. Evaluation of Radiological Emergency Response Plans Preparedness in Support of Nuclear Power Plants," January 1980.
The staff's review also included a site visit to the facility, a public meeting and observation of an emergency exercise involving PGE, Washington and Oregon State and local agencies during the week of October 22, 1979. The NRC staff conducted a followup visit to the site on July 28, 1980.
l Section I of this Emergency Preparedness Evaluation Report lists each standard in order followed by a summary of applicable portions of the Plan, draft Appendix B-1 or October responses as they apply principally to the standards.
Section II of this report provides our review results and conclusions. The Licensee anticipates that the Plan will be implemented by January 1, 1981, with the exception of the public alerting system.
At a later date an appendix will be added to this report describing the findings and determinations of the Federal Emergency Management Agency (FEMA) on the adequacy of the State and local emergency response plans and the NRC staff's overall conclusions on the status of emergency preparedness for the Trojan Station and related Emergency Planning Zones.
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EVALUATION OF LICENSEE EMERGENCY PLAN A.
Assianment of Resoonsibility (Oroanization Control)
Standard Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones (EPZ) have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each prin-cipal response organization has staff to respond and to augment its initial response on a continuous basis.
Licensee Emercency Plan Evaluation The Shift Supervisor is initially designated as the Emergency Coordinator.
When an abnormal condition arises, it is his responsibility to evaluate whether the abnormality constitutes an emergency.
If, in his judgment, the abnormality meets or exceeds any of the emergency classification action levels specified in the Plan, it is his responsibility to implement the Plan. There is a 24-hour per day communication linkage between the power station and Federal, State, local and private response agencies and organizations to ensure rapid transmittal of accurate notification informa-tion and emergency assessment data.
The Plan describes the functions and responsibilities of each State and local organization with response roles.
The governors' offices in both Oregon and Washington States are responsible for coordinating emergency response action decisions affecting the general public with all state and local governments involved.
The Oregon State Department of Energy and the Washington State Department of Emergency Services have primary respon-sibility for emergency response planning.
The Oregon State Health Division and the Washington State Department of Social and Health Services have primary responsibility for dose assessments and radiological monitoring.
The Cowlitz County Sheriff and Columbia County Director of Emergency Ser-
' vices are responsible for implementing protective actions in the portions of the plume exposure EPZ in their respective counties.
In the event of a radiological emergency, the plan't will contact the Cowlitz County Communications Center and the Columbia County Central Dispatcher by radio.
Both of these facilities are manned on a 24-hour per day basis.
These facilities in turn contact the Cowlitz County Sheriff and the Director of the Columbia County Office of Emergency Services.
Both of these officials have provided for designees to assure a continuous capabil m for rapid public notification decision making.
The counties will act on PGE protec-tive action recommendations until activation of the State and local operations centers.
The authority, responsibility, and duties of the plant staff personnel for coping with radiological emergencies are clearly defined for both 4
the normal operating staff and the augmented staff.
The operational relationships between the onsite emergency centers and offsite agencies are illustrated in Plan Figures 2:5.2-2 and 1:6-1, reproduced here as Figures 2 and 3.
The Emergency Coordinator is responsible for assuring continuous 24-hour emergency licensee operations.
Written agreements, which are reviewed every two years, with Federal and local support agencies are provided for medical transportation, medical assistance, fire protection, and radiological support during an emergency.
B.
Onsite Emergency Organization Standard Onshift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available, and the inter-faces among various onsite response activities and offsite support and response activities are specified.
Licensee Emeroency Plan Evaluation The Shift Supervisor is designated as the Energency Coordinator until relieved by the Plant General Manager. The Plant General Manager will then function as the Emergency Coordinator from the Technical Support Canter.
The Emergency Coordinator will not delegate the responsibility to imrediately l
implement the provisions of the emergency plan to include offsite notification of protective actions unless he is physically or otherwise unable to exercise this responsibility.
The Plan identifies, by position title, who performs onsite emergency func-tions during the day shift. The relationships between crucial emergency tasks identified in the Plan, backshift staff positions, and augmentation available within one hour is shown.
The Plan does not meet the specific l
staffing requirements expressed in Table B-1 of NUREG-0654 January 1980.
l There is a shortage of one health physics technician and one shift foreman i
for the minimum backshift manning.
The emergency organization will be l
augmented within one hour rather than within 30 minutes as required by l
NUREG-0654, January 1980.
In addition, the staff is augmented to a total of 16 and not 26 personnel ~ as required in NUREG-0654, January 1980.
The licensee will address the manning criteria when finalized by the NRC.
However, PGE does demonstrate how the crucial tasks required during the initial phases of an emergency will be performed with the minimum back-shift staff.
PGE headquarters provides assistance to the onsite organization through the Company Control Center (CCC) located in Portland, Oregon.
The CCC Director has the author,ity to mobilize all required corporate manpower l
and resources and to authorize necessary expenditures.
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.I h I C. Emergency Response Sucaort and Resources Standard l Arrangements for requesting and effectively using assistance res'ources have been made, that arrangements to accommodate for 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. Licensee Emergency Plan Evaluation The Trojan Emergency Operations Facility (EOF) (Emergency Control Center (ECC) in Plan) will be activated at the " Alert" or higher classification. Once activated, Oregon State Health Division and Washington State Department of Social and Health Services representatives will be dispatched to the ECC to monitor the situation. The State representative in the EOF will i direct offsite dose assessment and will make recommendations for offsite protective action as appropriate. The PGE director in the EOF acts to coordinate communications between the Emergency Director in the EOF and the other emergency organizations. PGE dispatch'es a licensee representative to the principal State (Oregon) EOC. A licensee representative will be sent to Washington State EOC if requested. The function and staffing of the EOF will be reviewed by the NRC staff against the revised criteria found in NUREG-0696, Revision 1, and changes by the licensee may be required. In addition to inplant laboratory facilities, TLDs can be analyzed by the PGE Central and Lower Columbia Environmental Laboratories within 24 and 12 hours of an accident respectively. Environmental air samples can be collected and analyzed within 48 hours by the Eberline Instrument Company. The Oregon State Health Department laboratory located in Portland, Oregon, will analyze air samples, soil, water and vegetation samples in support of plant operations if necessary. i Request for support under the Intergency Radiological Assistance Plan (IRAP) will be coordinated through the Oregon Health Division. An updated IRAP/ Trojan Response Agreement has been completed. Industry technical support provided by the Institute for Nuclear Power Operations, Westinghouse Emergency Response Plan, Bechtel Emergency Response Plan, and the Washington Public Power Supply System are coordinated through the CCC. These organiza-t tions can be contacted 24 hours per day. D. Emeroency Classification System \\ l Standard A standard emergency classification and action level scheme, the bases of i which include facility system and effluent parameters, is in use by the nuclear facility lit ensee, and State and local response plans call for i i I 8 I
reliance on information provided by facility licensees for determinations of minimum initial offsite response measures. Licensee Emergency Plan Evaluation 4 The four standard emergency classes (i.e., Notification of Unusua Event, Alert, Site Area Emergency, and General Emergency) have been established - by the licensee and State and local agencies. Observable and measurable emergency action levels (EALs) which, if exceeded, will initiate each emergency class consistent with NUREG-0610 (Appendix 1 to NUREG-0654/ FEMA REP 1) criteria have been established. EALs are provided in the Plan using specific instrumentation and parameters for each of the following: 1. plant system indicators, 2. containment source terms, 3. process radiation monitors, and 4. field monitoring results. The licensee will continue to refine the EALs to incorporate NRC comments, modularize the indicators to assure fuller response to serious indicators and to take into consideration operator experience gained in their utiliza-tion. Oregon and Washington States recognize the four emergency classifica-tions established by NUREG-0610 (Appendix 1 to NUREG-0654) and have made them part of their Radiological Response Plans. E. Notification Methods and Procedures Standard 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 followup messages to response organizations and the public have been established; and means to provide clear instructions to the populace within the plume exposure pathway Emergency Planning Zone have been established. Licensee Emergency Plan Evaluation The Plan establishes and describes a notification and verification system which is consistent with NUREG-0610 (Appendix 1 to NUREG-0654). The system provides for notification of Columbia County Central Dispatch and Cowlitz Communication Center within 15 minutes of detection of Alert, Site Emergency, or General Emergency conditions and State and local officials have agreed to an initial notification time of 1 hour for Unusual Events. Revision 1 to NUREG-0654 'FEFm REP-1 calls for notification of offsite authorities within 15 minJtes for the Notification of Unusual Event Class, and the Trojar. plan will require revision in this regard. 9
The General Emergency notification responsibilities are shown in Plan Figure 2:6.1-4 reproduced here as Figure 4. The Information to be provided in the initial notification to the County authorities will include: 1. name of caller, 2; class of emergency, 3. type of release, 4. wind direction, 5. form of precipitation, 6. recommended protective action, and 7. offsite assistance requested. The Plan identifies the initial and followup information to be provided to the NRC, Coast Guard, State and local governments, and emergency centers. A siren public alerting system designed to essentially complete the initial notification of the public within the, lume exposure pathway EPZ within 15 minutes is described. The current schedule for the siren system as proposed by the licensee is as follows: Order date - 9/15/80 Delivery - 11/15/80 - 12/15/80 Installation - 11/01/80 - 03/01/81 Testing - 03/01/81 - 03/15/81 FEMA will conduct on evaluation of the effectiveness of the public notifica-l tion system. F. Emergency Communications Standard l Provisions exist for prompt communications among principal response organiza-tions to emergency personnel and to the public. Licensee Emergency Plan Evaluation Primary and backup communication links are provided with all agencies, teams, and centers with a primary response role during an emergency. A 24-hour link is provided with the primary local offsite response agencies. The emergency communications system is illustrates in Plan Figure 1:9-1, reproduced here as Figure 5. 1 l 10
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The offsite communication links consist of: 1. commercial telephone. 2. a oedicated voice circuit, on the company owned microwave system, which can be switched to the commercial telephone system in Portland. 3. base station radio to the corporate offices in Portland. 4. base station radio to the county response organizations. 5. three dedicated telephone circuits--one with automatic ringing, one with selected station signaling, and one for hard copy data transfer to the State and local response organizations and centers. The auto-matic ringing circuit will ring all stations when the receiver is picked up. 6. dedicated telephone circuit to the NRC. The systems are provided with battery or emergency generators. The communication system to State and county governments will be tested monthly, and the system to Federal response organizations, county EOCs, and field monitoring teams will be tested annually as part of the communi-cation drills. G. Public Information Standard Information is made available to the public on a periodic basis how they will be notified and what their initial actions should be in an emergency; the principal points of contact with the news media for dissemination of l information during an emergency (including physical location or locations) l are established in advance; and procedures for coordinated dissemination l of information'to the public are established. Licensee Emeroency Plan Evaluation The licensee in cooperation with Columbia and Cowlitz Counties will institute a public education program of the public within the plume emer-gency planning zone. This program will consist of public meetings, Press briefing, annual mailouts, a continuing education program, and surveys to i determine the effectiveness of the programs. The first survey will be completed by June 1981. The program will be designed to ensure that the population will be: 1. aware of the potential threat of a radiological emergency, 2. able to recognize radiological emergency notification (e.g., sirens), and 13 I
3. knowledgeable of the proper, immediate actions. A copy of the initial public education brochure will be submitted to the NRC by January 1, 1981. The PGE Press Center has been established in St. Helens, Oregon (see Figure 1), with sufficient space to accommodate 100 people and with facilities to install approximately 25 telephones. A licensee press representative will be sent to this center and provisions for exchange of information between the center and the Emergency Coordinating Center (ECC) have been provided. PGE has co witted to make provisions to hold press briefings at the ECC. Public information will be provided at three levels, namely the County EOC, State EOC, and PGE Press Center. Only one level will operate as the official source at any one time. H. Emergency Facilities and Eouioment Standard Adequate emergency facilities and equipment to support the emergency response are provided and maintained. Licensee Emeroency Plan Evaluation Emergency facilities needed to support an emergency response have been established to include: 1. Emergency Operations Facility (Emergency Control Center (ECC) in Plan). The ECC is currently located in the Visitors Center which is 0.5 mile from the plant. The ECC role involves: a. advising State and local governments, b. receiving, reducing, and interpreting all plant and offsite monitoring data, coordinating exclusion area control, c. d. personnel accountability, and providing updates to State and local emergency centers. e. 2. Alternate. Emergency Control Center. If the ECC becomes uninhabitable, an alternate will be established in St. Helens, Oregon (see Figure 1), approximately 13 miles south. The Alternate ECC has the same communication capabilities as the ECC. Provisions have'been made to ensure that communications can be trans-ferred to the Alternate without interruption. l 14
3. Company Control Center (CCC). The CCC will be established in the PGE offices in Portland, Oregon (see Figure 1). The role of the CCC is to assist the ECC staff by coordinating and directing offsite corporate assistance. 4. Technical Support Center (TSC). The TSC is located in the Plant Administrative Building on an interim basis until a permanent TSC is established. The role of the TSC is to: a. provide the primary communication link for data flow between the control room and ECC, b. provide offsite dose assessment until the ECC is activated, and c. provide technical assistance to ECC and Control Room staffs. The Emergency Coordinator will be located at the TSC. The TSC will provide: a. space for 25 key personnel, b. closed-circuit TV of control room instrument and control boards, c. drawings and technical data, and d. communications and portable monitoring equipment. 5. Operational Support Centers (OSC). The OSCs are located in the rack and access control areas. The OSCs are where plant emergency teams can assemble to combat the emergency. 6. Press Center. This center is discussed in Section D "Public Information" of this report. 7. Unified Dose Assessment Center (UDAC). The UDAC will be established in the ECC to coordinate and direct all (State, local, and plant) field monitoring teams and subsequent.recom-mendations of protective actions. The UDAC will be directed by the Plant Radiation Protection Supervisor until arrival of the Oregort State Health Department representative. (This does not obviate the licensee's continuing responsibility to make recommendations for protective actions for the public to offsite authorities, but should assure that both onsite and offsite organizations agree on those projected dose l'evels which are based on plant effluent release values and field monitoring.) l 15
Detailed requirements on data transmission, staffing, and physical facili-ties for the various emergency centers are contained in NUREG-0696, " Functional Criteria for Emergency Response Facilities (For interim use and comment)." The NRC will establish an implementation schedule following comment on this criteria. The current and planned arrangements,are adequate in the interim. It is highly desirable to change the designation of the ECC to an Emergency Operations Facility (EOF) to assure uniformity nationwide with other govern-ment and industry response organizations. The functions of this facility will also need to be revised to reflect overall strategic control of the plant operation. The ECC, TSC, CCC and OSC will be activated for Alerts, Site Area Emergencies, and General Emergencies. The Plan describes the following used to initiate and assess emergencies: 1. meteorological instrumentation, 2. radiological monitors to include field survey monitors, 3. process monitors, 4. fire detection devices, 5. an environmental radiological monitoring program consistent with the NRC Radiological Assessment Branch Technical Position, and 6. laboratory facilities. The description of the instrumentation identified in the emrgency action 1evels (EALs) includes location, type, alarms setpoints, range, and other information. Provision for interim use of an area radiation monitor to j determine containment radiation levels have been provided. Meteorological-instrumentation is located on a 500-ft tower south of the Plant and on a 33-ft tower. Meterological data is recorded in the control room and provided in the interview to the ECC by telephone or radio. The 33-ft tower (backup) records wind speed and direction. The NUREG-0654 criteria for meteorological instrumentation and data trans-mittal is to be addressed following finalization.of the criteria. (The final requirements in this regard have now been transmitted to licensees and are reflected in Appendix 2 of NUREG-0654/ FEMA REP-1, Revision 1.) The Plan provides for quarterly calibration and maintenance of emergency l equipment. The Plan contains a summary of emergency equipment and supplies and an inventory of the radiological monitoring equipment. 16
I. Accident Assessment Standard Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences or a radiological emergency condition are in use. Licensee Emergency Plan Evaluation The Plan contains specific instrument readings and other observable and measurable parameters which, if exceeded, will initiate an emergency as discussed in Section I.D of this report. The containment radiation levels associated with release of coolant, gap and volatile fission products into containment are calculated. These levels when considered with containment pressure are one basis for offsite dose projections. Two channel NaI detectors are provided to determine I-131 concentrations in air. The Plan describes the process for determining the projected plume exposure doses using plant process radiation monitors, containment monitors, and field monitoring results for the following: 1. inside the exclusion area, 2. at the exclusion area boundary, and 3. beyond the exclusion area. Provision to project doses based on key isotopes is also provided. Methods for projecting ingestion pathway doses for liquid releases have been specified. A process of using a set of assumptions and observations is provided to estimate dispersion if the meteorological instruments are inoperable. Portable instruments will be used to determine containment radiation levels and offsite releases when the inplace instrumentation is offscale or inoperable. l The dose projections and their relationship to the Environmental Protection l Agency (EPA) Protection Action Guides (PAGs) are used as part~of the accident classification systems (EAls). Licensee field monitoring teams can be dispatched within one hour during the backshift. Airborne monitoring is available utilizing either the PGE l helicopter or an Oregon National Guard helicopter. Later airborne monitoring assistance is available from the DOE Aerial Monitoring System (AMS). 17
J. Protective Resoonse Standard A range of protective actions have been develop d for the plume exposure pathway EPZ for emergency workers and the public. Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been developed. Licensee Emergency Plan Evaluation The Plan establishes guides for determining when protective actions are required onsite to include evacuation, distribution of potassium iodide (KI), and the use of respiratory protection. Monitoring and decontami-nation of plant evacuees will be conducted at the ECC. Visitors in the public access area will be evacuated to an offsite check point established by the State police. These check points will be established beyond where radiation doses are projected to exceed 1 rem whole body and 5 rem thyroid. The storage locations for protective clothing, respiratory equipment, and potassium iodide are indicated. Personnel accounting will be performed at the ECC within 30 minutes of activation of the ECC. Shelter of the public within the EPZ will always be immediately recommended if a General Emergency is declared. Specific recommendations for phased plume EPZ evacuation based on projected doses and core and containment conditions are provided. Evacuation time estimates for various conditions and typical shielding factors will also be used in determining the protective actions to be recommended. Phased evacuation is provided to allow for the most effective use of local emergency response personnel (e.g., traffic direction, etc.). The licensee has committed to evacuate nonessential personnel during Site and General Emergencies. The evacuation time estimates were not included in the submittal; however, a draft was submitted to the NRC on Januarj 31, 1980. These estimates are undergoing refinement by the local governments and will be added to the Plan by January 1, 1981. In addition PGE is revising the evacuation l time estimates to address periods of volcanic activity. Evacuation routes (maps) for the general public will be contained in individual county emergency response plans. K. Radiological Exposure Control Standard l Means for controlling radiological exposures, in an emergency, are estab-lished for emer:ency workers. The means for controlling radiological exposures shall include exposure guidelines consistent with EPA Emergency i Workers and Lifesaving Activity Protective Action Guides. i 18
Licensee Emergency Plan Evaluation The Emergency Coordinator will authorize any potential personnel exposure exceeding the occupational limits of 10 CFR 20 and the Plan identifies onsite exposure guidelines consistent with EPA guidelines for er.ergencies. The Plan provides for personnel decontamination facilities and {dentifies the action levels requiring decontamination. The Plan provides for 24-hour determination of doses received by onsite emergency workers and offsite response personnel and appropriate recordkeeping. Distribution of TLDs and self-reading pocket dosimeters and maintenance of dose records for in plant emergency workers will be performed at the OSC. This will be accomplished at the ECC for contractors and other offsite response personnel (State, local, Federal). L. Medical and Public Health Sucoort Standard Arrangements are made for medical services for contaminated and injured individuals. Licensee Emergency Plan Evaluation PGE has made arrangements with the Good Samaritan and St. Vincent Hospitals in Portland, Oregon, to provide medical assistance to site personnel injured or exposed to radiation and/or radioactive material. Radiation victims requiring long-term hospital care will be transferred to the Hanford Environ-mental Health Foundation Hospital in Richland, Washington. An agreement has been made with the Columbia Hospital District Health Center to transport injured persons. First aid team members have at least a basic first aid certificate. M. Recovery and Reentry Planning and Postaccident Operations Standard i General plans for recovery and reentry are developed. Licensee Emergency Plan Evaluation The Plan describes the provisions for relieving operating crews when their whole body exposure reaches 1 rem. Recovery phase begins when 1. the plant reaches a benign cold shutdown condition, and 2. radiation levels within the unrestricted area do not exceed the limits of 10 CFR 20.105 and 20.106. i i 19 I l
A recovery plan is currently under development. In the interim, the Executive Vice President has the authority and responsibility to create an emergency recovery organization encompassing all required aspects of engineering, construction, operations, and functional support. Such a plan would be along the lines of the Nuclear Powet Plant Lnia gency Response Plan prepared by the Emergency Response Planning Subcommittee of the AIF Policy Committee on Followup to the TMI Accident. Such an organization may be needed sooner than indicated by the PGE criteria and to conform to the function of the licensee's near-site Emergency Operations Facility as described in NUREG-0696. N. Exercises and Drills Standard Periodic exercises are (will be) conducted to evaluate major portions of emergency response capabilities, periodic drills are (will be) conducted to develep and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected. Licensee Emercency Plan Evaluation An emergency exercise will be conducted annually and will be based on an accident scenario postulating at least a Site Area Emergency. The scenario will be varied from year to year such that all elements of the plant, county, and State emergency plans are tested within a 5 year period. One exercise shall start between midnight and 6:00 a.m. and another between 6:00 p.m. and midnight once every 6 years. Every fifth year, the exercise will be expanded to involve the Federal response organizations in addition to the State and local organizations. The frequency of exercises with State and local organizations will be required to conform to the requirements of 10 CFR Part 50 of the Commission's regulstions. The scenarios for emergency exercises will be prepared by the PGE Generation Licensing and Analysis Department (GLAD) in conjunction with the Plant training staff and the Oregon Department of Energy. Each exercise and drill scenario will include: 1. the basic objectives, 2. date/ time, 1 3. simulated events and schedule, 4. narrative summary, and 5. arrangements for qualified observers. Each annual exercise will include a list of specific performance objectives and expected response. The Plan summarizes the tasks to be tested. 20
Official observers from Federal, State, or local governme'nts will critique each exercise. A written description of their observation in relationship to the specific performance objectives will be prepared by each observer. The Emergency Planning Coordinator or his designee will determine the corrective actions to be taken and the implementation schedule.' Drills are supervised instruction periods aimed at testing, developing, and maintaining skills. The following drills are provided for: 1. communication drill--initial plant contact with State and county governments will be tested monthly. Communications with Federal response agencies, offsite emergency centers, and field assessment teams will be tested yearly, 2. quarterly fire drills, 3. annual medical emergency drills, 4. annual radiological monitoring drills, and 5. semiannual in plant radiation protection drills. An exercise was conducted at the Trojan Nuclear Plan in October 1979, and Federal observers reported that it adequately exercised the PGE, State, and local plans. This included the use of emergency action levels (EALs) and directly recommending protective actions to local response organizations. O. Radiological Emergency Response Training S_tandard Radiological emergency response training is provided to those who may be called upon to assist in an emergency. Licensee Emergency Plan Evaluation The Plan provides for training and qualifying all personnel on the emergency tasks for which they are responsible as specified in the Plan. The super-visors of the emergency teams are responsible for the emergency response training of each member of their teams. The Generation Licensing and Analysis Department'is responsible for the inital training and periodic retraining of the PGE headquarters support personnel. PGE provides training to the following nonlicensee organizations every 12 months, consistent with their emergency functions: 1. local response agencies (if training can not be provided by the State) a.
- fire, l
21 e
1 b.
- police, c.
emergency service personnel, 2. ambulance / rescue, 3. Coast Guard, (if required) and 4. local press. The training provided to nonlicensee organizations will include, where appropriate: 1. role responsibility and authority on site, 2. possible accidents and their relationship to protective actions recommended, 3. implementation of protective actions, 4. emergency action levels, 5. notification procedures, S. site security procedures, and 7. basic radiation protection. The licensee has committed to qualify personnel on their assigned crucial tasks annually by having them demonstrate their ability to perform the task to a specified standard. P. Responsibility for the Planning Effort: Development, Periodic Review, and Distribution of Emergency Plans Standard Responsibilities for plan development, and review and for distribution of emergency plans are established, and that planners are properly trained. Licensee Emeroency Plan Evaluation The Emergency Planning Coordinator has the authority and responsibility for licensee emergency response planning. Changes to the Plan are reviewed for safety and submittal to the Plant General Manager for his approval and the approval of the Plant Review Board. The Plan provides for updating all external copies. Revised pages are marked to show where changes were made. The Plan is reviewed annually by the Trojan Emergency Task Force, which consists of representatives of PGE, FEMA, Columbia and Cowlitz Counties, and the States of Oregon and Washington. I 22
CONCLUSIONS ON LICENSEE EMERGENCY PLAN Based on our revie.i against the criteria in "Criteriu for Preparation and Evaluation and Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (For Interim Use and Comment)," NUREG-0654, January 1980, we conclude that the Trojan site emergency plan, when revised in accordoce with the commitments in the October 2, 1980 PGE letter provides an adequate planning basis for an acceptable state of emergency preparedness and will meet the requirements of 10 CFR 50 and Appendix E thereto. However, the Trojan Emergency Plan must be revised to address the final criteria and implementation schedule for the emergency centers and their functions, emergency manpower levels, and meteorological systems which are detailed in NUREG-0554, Revision 1, and NUREG 0696, Revision 1. PGE has been requested to explicitly address protective action determination and implementation during a volcanic eruption in the revised site plan. In addition, FEMA has been requested as part of their review of State and local emergency plans to review the planning efforts for the areas around the site to assure that protective actions to be recommended by PGE during volcanic eruptions could be implemented and are adequate. After receiving the findings and determinations made by FEMA on State and local emergency response plans, and after reviewing the revised site plan from PGE, a supplement to this report will provide the staff's overall conclusions on the status of emergency preparedness for the Trojan Power Station and related Emergency Planhing Zones. The final NRC approval of the state of emergency preparedness for the Trojan site will be made following implementation of the emergency plans to include development of procedures, training and qualifying of personnel, installation of equipment and facilities, and a joint exercise of all the plans (site, State and local). 23 -}}