ML19351F073
| ML19351F073 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/31/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML19351F072 | List: |
| References | |
| NUREG-0746, NUREG-746, NUDOCS 8012290421 | |
| Download: ML19351F073 (35) | |
Text
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Emercency Preaarecness Eva uation for TV
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Metropolitan Edison Company, et al.
Three Mile Island Nuclear Station Unit 1 Docket 50-289 U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement
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i ABSTRACT L
l The Three Mile Island Unit 1 Emergency Plan generally meets the requirements i
of 10 CFR 50.47b and conforms to the guidance found in NUREG-0654, Revision 1 except for several specific items which are identified.
The Licensee must i
conduct an emergency preparedness exercise with the State and county governments to show that the Plan can be implemented satisfactorily.
A finding on the state of preparedness in the environs around the site is due from the Federal 4
Emergency Management Agency.
A supplement to this report, will include this finding and will address the other items that currently need resolution.
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TABLE OF CONTENTS Pa!Le 1.
INTRODUCTION......................................................
I j
II.
CONSIDERATION OF PLANNING STANDARDS...............................
2 A.
Assignment of Responsibility (Organization Control)..........
2 B.
Onsite Emergency Organization................................
5 C.
Emergency Response Support and Resources.....................
7" D.
Emergency Classification System..............................
8 E.
Notification Methods and Procedures..........................
10 F.
Emergency Communications.....................................
12 G.
Public Education and Information.............................
13 H.
Emergency Facilities and Equipment...........................
15 I.
Accident Assessment..........................................
18 J.
Protective Response.........................................
19 K.
Radiological Exposure Control................................
21 L.
Medical and Public Health Support............................
23 M
Recovery and Reentry Planning and Post-accident Operations...
24 N.
Exercises and Drills.........................................
25 0.
Radiological Emergency Response Training.....................
26 P.
Responsibility for the Planning Effort:
Development, Periodic Review and Distribution of Emergency Plans........
28 III. CONCLUSION........................................................
30 4
'?*__*.
I.
INTRODUCTION The Metropolitan Edison Company (hereinaf ter referred to as " Met. Ed." or "the Licensee") filed with the Nuclear Regulatory Commission Revision 2 to the Three Mile Island Nuclear Station Unit-1 Emergency Plan, dated June 10, 1983 (hereinafter referred to as "the Plan") which the Commission's staff has reviewed.
The commitments and modifications to the TMI-I Emergency Plan as expressed in the November 3, 1980 Metropolitan Edison letter to the NRC, were also considered during the emergency preparedness review.
In addition, the staff conducted several site visits to the facility and held a public meeting near the site during the week of September 24, 1979.
In June 1980, the staff issued NUREG-0680, TMI-1 Evaluation Report, which involved an evaluation of the licensee's compliance with the emergency prepared-ness requirements of the NRC Order, dated August 9, 1979.
NUREG-0680 indicated that the Licensee was in compliance with all emergency planning short term items of the Order, with the exception of conducting a test exercise of its emergency plan.
Additionally, NUREG-0680 stated that the staff review of the Licensee's Plan against NUREG-0654, " Criteria for Freparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants", was in progress.
The Review of the Licensee's Plan against the sixteen Emergency Planning Standards set forth in 10 CFR 50.47b and NUREG-0654/ FEMA REP-1 (Revision 1, dated November 1980) has been completed.
This Emergency Preparedness Evaluation Report lists each of the Planning Standards of NUREG-0654, Revision 1 and an evaluation to show the extent to which the Licensee's emergency preparedness meets each of these standards.
At a later date, a supplement will be added to this report describing the findings and determinations of the Federal Emergency Management Agency on the acceptability of the State and local emergency response plans and the NRC staff's overall conclusions on the status of emergency preparedness for the TMI-1 Nuclear Station and related Emergency Planning Zones.
The status and resolution of open items identified in this report will be addressed in that supplement.
The final NRC approval of the state of emergency preparedness for the TMI-1 Station will be made following implementation of the emergency plans to include development of procedures, training and qualifying of personnel, and a joint exercise of the Licensee, State, and local organizations.
II.
CONSIDERATION OF PLANNING STANDARDS A.
Assignment of Responsibility (Organization Control)
Planning Standard Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organiza-tions have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.
Emergency Plan Met. Ed. is responsible for onsite emergency response at the THI Nuclear Station.
To fulfill this responsibility, Met. Ed. relies on governmental and private offsite agencies to provide assistance.
The Commonwealth of Pennsylvania, through its various State, county, and local agencies, is responsible for offsite emergency response and relies on the Licensee to provide necessary information on plant status and radiological releases.
The TMI Unit 1 Emergency Plan describes Met. Ed's methods to satisfy its onsite responsibilities.
The Plan describes the organizations relied on for emergency response, methods for initial accident assessment and notification, resources available for continued monitoring, assessment and dissemination of information, emergency measures to be taken, and procedures to be followed for maintaining emergency preparedness.
Met. Ed. operates and provides technical support for the TMI Nuclear Station.
The Vice President-TMI 1 and Vice President-TMI 2 share overall responsibility for site administration at TMI.
The Shift Supervisor, who is on duty at all times, is the immediate cnsite position of authority.
He will be responsible l
for the initial evaluation of an emergency situation and for directing the l
response.
If an emergency exists, the Shift Supervisor will assume the posi-tion of Emergency Director.
He will initiate appropriate actions, implement procedures, and notify appropriate offsite emergency response organizations.
Based on the provisions of the Licensee's Emergency Plan, we find that the primary responsibilities for emergency response by the Licensee have been assigned.
In addition, as set forth in Section B, we find that the Licensee's principal response organization has the staff to respond and to augment its l
initial response on a continuous basis, l
i Offsite emergency responsibilities are described in the State Emergency Plan,
" Fixed Nuclear Facility Incidents, Annex E to the Commonwealth of Pennsylvania i
Disaster Operations Plan", dated March 28, 1980.
The State Plan as well as the Dauphin, York, Lancaster, Cumberland, and Lebanon county plans for the plume exposure Emergency Planning Zone (EPZ) are being reviewed by the Federal Emergency Management Agency (FEMA).
The Maryland State Plan is also being -
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reviewed by FEMA to determine the effectiveness of emergency preparedness for those areas in Maryland which are located in the ingestion exposure pathway Emergency Planning Zone (EPZ) surrounding THI Unit 1.
The State Plan designates the Pennsylvania Emergency Management Agency (PEMA) as the lead State agency for emergency planning and specifies that the Governor will exercise coordination and control through PEMA during an emergency.
PEMA is authorized to direct the cooperation and assistance of all State agencies and officials, provide emergency direction and control of State and local emergency operations, and to accept aid and coordinate assistance provided by federal agencies.
To provide 24-hour per day, seven day per week response to emergencies, PEMA maintains a duty watch of ficer who is on call during non-duty hours.
We will await FEMA's evaluation of the availability of the duty officer.
PEMA is responsible for communicating with affected counties and State and local governments within the plume exposure and ingestion Emergency Planning Zones.
There are also contingency communications procedures for direct notification of the counties by the Licensee.
The Pennsylvania Department of Environmental Resources (DER) is responsible for gathering, evaluating, and supplying technical information and recommendations to PEMA. Within the DER, the Director of the Bureau of Radiation Protection (BRP) is responsible for dealing with radiological emergencies.
The BRP has made provisions for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, seven day per week interface with PEMA.
The Pennsylvania Department of Education will coordinate with the DER and the Department of Health to develop and conduct an educational program to familiarize the public about nuclear radiation.
The PA. Department of Agriculture will provide for agricultural, dairy and food product control up to 50 miles from the facility.
The PA. Department of Health will activate its emergency medical plan to meet the health care needs of citizens.
This includes the supervision, stockpiling, distributing and administering of thyroid blocking agents.
FEMA will evaluate these offsite aspects.
The PA. Department of Military Affairs will activate its plan to support county and local government in security, traffic control, and evacuation in the plume exposure pathway Emergency Planning Zone.
The PA. Department of Public l
Welfare will provide for the relocation of patients and institutionalized persons.
They will also provide for the care of evacuees needing special ettention and will extend public welfare assistance to the needy. The PA.
Department of Transportation will help the affected counties designate control points, road capacities, and major and feeder routes. The Department will l
also coordinate the marking of evacuation routes and the designation of emergency l
fuel distribution locations.
l l
In summary, we find that the primary responsibilities for emergency response by State Organizations have been assigned. We are unable to conclude at this i
time that the State's principal response organization has staff to respond and to augment its initial response on a continuous basis as these are matters being reviewed by FEMA. L
On the local level, with respect to the Plume exposure pathway EPZ, Dauphin, York, Lancaster, Cumberland, and Lebanon Counties have prepared emergency plans that are coordinated with the State's Disaster Operations Plan and the TMI-1 Plan.
However, we cannot now reach a conclusion as to whether primary responsi-bilities for emergency response by local organizations have been established or whether the local response organizations have staff to respond and augment initial response on a continuous basis as these are matters being reviewed by FEMA.
Medical support will be available from the Hershey Medical Center, private physicians, and the Radiation Management Corporation to augment the onsite emergency organization.
Ambulance service will be available from the Bainbridge, Union, and Londonderry Township fire companies and Rescue Hose Company No. 3.
Firefighting services will be available from the Bainbridge, Londonderry Township, and Union Hose Companies, and Rescue Hose Company No. 3.
The Pennsylvania State Police and the Middletown Police Department will aid in law enforcement.
Letters of agreement regarding these commitments have been obtained from all the above agencies.
Notification and requests for assistance can also be made to various Federal agencies.
Met. Ed. will notify the Nuclear Regulatory Commission (NRC).
The primary role of the NRC is to conduct investigative activities associated with the incident and to verify that emergency plans have been implemented and the proper agencies notified and to confirm information and protective action recommendations provided by the Licensee.
NRC personnel will, as needed, assist in coordination with Radiological Assistance Teams and provide advisory assistance to the Licensee and offsite organizations.
Resource support can be obtainedbythgStatefromtheFederalEmergencyManagementAgency.
The Licensee, State, or NRC will notify the Department of Energy (00E) as situations warrant.
DOE has a continuously manned Security Operations Center in each of their regions and can provide radiological assistance to State, county, and local governments, nuclear facilities, and other federal agencies.
The U.S. Coast Guard will provide assistance by maintaining traffic control on the Susquehanna River.
They may also keep unauthorized personnel from entering Three Mile Island and adjacent islands during an emergency.
A 24-hour emergency telephone number is maintained by the Coast Guard.
The 56th Ordnance Detachment of the Department of the Army will provide personnel for assistance during bomb threats.
The Federal Avaiation Administration will ensure that air traffic is diverted around the TMI station during an emergency.
The National Weather Service will provide backup metaorological information as necessary.
Lettars of agreement have been obtainec from these Federal agencies relied upon to provide emergency response services.
The TMI-1 Emergency Plan has also identified private sector organizations including utilities, reactor vendor, consultants, and engineering firms (Plan, Table 8) which are not relied upon by TMI-1 emergency Plan, but which represent additional emergency response resources.
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l In summary, we find that responsibilities for support organizations have been specifically established in the Licensee's emergency plan.
Based on our review, and as outlined and discussed above, we find that primary responsibilities for Licenses and State emergency response organizations have been assigned, that the responsibilities of support organizations have been identified, and that each of the Licensee's principal response organizations is staffed to respond and to augment its initial response to an emergency on a continuous basis.
Accordingly, we conclude that the Licensee has met the planning standard for Assignment of Responsibility (Organization Control).
Since the FEMA review of State and local planning is not yet complete, a determination as to whether State and local plans meet this planning standard has not yet been made.
B.
Onsite Emergency Organization Planning Standard On-shift facility licensee responsibilities for emergency response are unambi-guously 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 interfaces among various onsite response activities and offsite support and response activities are specified.
Emergency Plan The normal station organization is shown in the Plan.
The personnel staffing the normal station organization are usually onsite from 8 a.m. to 5 p.m.
during the work week.
The Manager Unit 1 provides operators onsite on a rotating shift basis to provide proper operation of the plant 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 7 days per week.
Personnel from other departments are also assigned to shifts to provide additional capabilities.
The TMI Unit I normal Shift Organization as shown in the Plan has 11 persons associated with operations, 8 with maintenance, 4 with radiation / chemistry and 9 with security for a total of 32.
Table 8 in the Plan shows that the minimum shift for the onsite emergency organization has 9 positions associated with l
operations, 5 with maintenance, and 4 with radiation / chemistry.
Security l
personnel will be provided in accordance with the approved Security Plan.
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These staffing provisions assure that adequate staffing in key areas for initial onsite emergency response will be maintained at all times.
The Vice President-TMI-1 is responsible for assigning personnel to positions in the onsite emergency organization.
This includes the assignment of key Station management personnel to the position of Emergency Director.
The assignments will be made and posted in the TMI-1 Duty Roster to ensure continuous coverage.
Alternates to key positions are pre-designated.
The Shift Supervisor assumes the responsibilities of the Emergency Director and assigns those persons who will carry out assigned actions.
The Duty Section Superintendent relieves the Shift Supervisor of Emergency Director responsibilities after his arrival at the Control Room.
The Emergency Director
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is responsible for the overall onsite emergency response and has the authority to immediately and unilaterally initiate emergency actions, including providing protective action recommendations to authorities responsible for implementing offsite emergency measures.
The Emergency Director may not delegate the responsibility to classify an emergency event, to determine the necessity for onsite evacuation, to authorize emergency workers to exceed normal radiation exposure limits or to make protective action recommendations to offsite emergency response agencies.
The line of succession for the Emergency Director position has been established.
In addition, the functions of the Communicator, Technical Support Center Coordinator, Operations Coordinator, Emergency Maintenance Coordinator, and Radiological Assessment Coordinator, are clearly described in the Plan.
On each shift, there are personnel trained in firefighting.
The fire brigade, under direction of the Shift Supervisor will respond to all fire alarms.
Additional qualified firefighting personnel can be obtained from the normal onsite organization.
Assistance can also be requested from local fire depart-ments if deemed necessary by the Emergency Director.
The Emergency Repair Teams, under the direction of the Emergency Maintenance Coordinator, will assess equipment damage and effect emergency repairs.
In summary, based upon our review of the Licensee's emergency plan as outlined above, we find that onsite responsibilities have been unambiguously defined by the Licensee.
The minimum emergency staff requirements for major functional areas, as described in NUREG-0654, Table B-1, which are available on shift and within 30 minutes and I hour following declaration of an emergency can be met by the TMI-1 emergency organization duty sections.
The entire Onsite Emergency Organization can be available within four hours following the declaration of an emergency.
These capabilities are adequate to assure the timely augmentation of Licensee emergency response.
The major emergency facilities and their general location relative to each other are identified in the Plan.
The Technical Support Center (TSC) is located below the Control Room in the Control Building.
This center contains a remote shutdown panel that can be used to bring the reactor to a safe shutd-The Operations Support Center (05C) is located in the Control Building own.
in the Health Physics area.
It provides an area for shift personnel to meet for duty assignments.
The interim Emergency Operations Facility (EOF) is located in the TMI Observation Center and will receive both plant parameter and radiological assessment information.
It will house the key technical groups of the offsite emergency organization.
The State BRP liaison representa-tive and the NRC representatives will be located here.
The function and staffing of the EOF will be further reviewed against forth coming guidance in NUREG-0696, " Functional Criteria for Emergency Response Facilities," Revision 1.
An Offsite Emergency Support Organization will provide technical and logistics support during an emergency.
This organization will be staffed by personnel from the normal station organization, the normal technical support organization, and consultants.
Its responsibilities are to provide liaison and communications i l w
with the NRC and State and county agencies, provide public relations and news releases, provide for environmental monitoring and security support, procure and dispatch equipment and assign post-accident investigations.
This organiza-tion is shown in the Plan.
The Emergency Support Director is responsible for activating and directing the emergency support organization.
Staffing for this support organization is available in four hours after the declaration of an emergency.
Arrangements for hospital and medical services for injured and/or contaminated site personnel are provided by the Hershey Medical Center, Radiation Management Corporation and two local physicians.
Ambulance service will be provided by the Bainbridge Fire Company, Londonderry Township Fire Company, and Rescue f
Hose Company No. 3.
Met. Ed. will provide radiological control technicians to assist the ambulance services.
If post-accident conditions indicate that recovery operations will be complicated long-term, Met. Ed. will shift from the emergency response organizations to er a long-terrr. recovery organization.
This organization is shown in the Plan.
The long-term recovery organization is based on the normal Licensee organiza-tional structure.
Prior to initiating any recovery operations a more specific organization will be defined based on the particular conditions.
The Office of the President of the Licensee will be responsible for the overall recovery operation, including overseeing the operations of the various functional groups and selection of senior personnel to key positions in the recovery organization.
In summary, based on our review of the Licensee's emergency plan as outlined above, we find that the interfaces among various onsite response activities and offsite support and response activities are specified as required.
Further review of the function and staffing of the Licensee's EOF will be conducted, however.
Based on the provisions of the licensee's emergency plan as outlined and discussed above, we find that onsite responsibilities have been unambiguously deined, provision is made for adequate staffing in key areas for initial response at all times, provision is made for the timely augmentation of response capabilities, and the interfaces among onsite activities and offsite support and response activities are specified.
Accordingly, we conclude that the planning standard for the onsite Emergency Organization is met with the exception of the function and staffing of the EOF for which further review is required.
C.
Emergency Response Support and Resources Planninq Standard Arrangements for requesting and effectively using assistance resources have been made, arrangements to accommodate 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.
Emergency Plan The interim Emergency Operations Facility (EOF) will be housed in the TMI Observation Center.
The Bureau of Radiation Protection (BRP) will send a representative to the EOF to provide face-to-face liaison.
The NRC will locate representatives at the EOF as well as the TSC and Control Room.
It is not planned that TMI will send representatives to the State and county emergency operations centers. We understand that the Licensee will be prepared to send a representative should this be requested. This decision is based on factors unique to TMI's location, including its proximity to the permane ; State E00 in Harrisburg.
The Licensee has the ability to communicate with the EOC through direct lines and an auto-dialing telephone system.
Based on our review of the Licensee's emergency plan, we find that arrangements have been made to accommodate State and local staff of the EOF.
Requests for assistance from the DOE Radiological Assistance Program (RAP) will be initiated by the Licensee's Emergency Director, Radiological Assessment Coordinator or Emergency Support Director.
DOE has established a continuously manned Security Operations Center at each of their 8 field offices.
For the Region in which the TMI Station is located, the Security Operations Center is at the Brookhaven National Laboratory, Upton, New York.
When notified of an energency, 00E will respond with equipment and personnel as required by the RAP.
The resources available include portable radiation survey instrumentation, mobile laboratory facilities, and environmental monitoring teams.
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Radiological laboratory support can be obtained from several offsite agencies.
Mobile labs are available from DOE, within 12-24 hours; BRP, within I hour; and Babcock and Wilcox; within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
Portable radiation monitoring instru-ments are available from the Radiation Management Corporation within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
Additional emergency resources are available from vendors and consultants as specified in Table 8 of the Plan.
In summary, based on our review of the Licensee's emergency plan, we find that the Licensee has identified other organizations capable of augmenting the planned response and has made arrangements for requesting and using assistance resources.
Based on our review and as outlined and discussed above, we find that arrange-ments exist for requesting and using assistance resources, arrangements have been made to accommodate State and local response organization staff at the E0F, and that organizations capable of augmenting the Licensee's response have been identified.
Accordingly, we conclude that the planning standard for Emergency Response Support and Resources has been met by the Licensee.
D.
Emergency Classification System Planning Standard A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.. - -.
Emergency Plan The Plan establishes a classification system of four classes of Emergency Action Levels covering the entire spectrum of possible emergency situations.
These classes are:
(1) Notification of Unuseal Event, (2) Alert, (3) Site Emergency, and (4) General Emergency.
The Notification of Unusual Event and Alert classes are to provide early and prompt notification for minor events which could lead to more serious consequences or which might be indicative of more serious conditions where some significant releases are likely or are occurring, but where a core melt situation is not indicated based on current information.
The General Emergency class involves actual or imminent substantial core degradation or melting with the potential for loss of containment.
All of the events hypothesized in the Final Safety Analysis Report (FSAR) fall into one of the four emergency classes outlined above.
Approximately one-half fall into the Alert, Site and General Emergency categories.
Each of the four classes are characterized by emergency action levels.
These action levels consist of plant parame'.ers which will be used to initiate emergency class designation, notification, and emergency organization mobiliza-tion.
In a letter to the Licensee, dated September 9, 1980, the NRC staff requested that the Licensee's plan provide additional plant parameter values and plant conditions which would correspond to the various accidents and abnormal conditions to be used in conjunction with the emergency action level scheme.
The Staff has reviewed the Licensee's draft response and revised Emergency Action Levels; however, the Staff is awaiting the Licensee's formal response prior to determining whether additionai emergency action level modifi-cations are necessary.
In summary, based on our review of the Licensee's emergency plan, we fino that a standard emergency classification and action level scheme, based on facility system and effluent parameters, is in use by the Licensee.
However, the fincl, acceptable Emergency Action Levels must be formally submitted by the Licensee and the adequacy of those EALs cannot be finally determined until such formal submittal is made.
Once declaration of an emergency class requiring possible protective action occurs, dose assessments will be made.
The dose assessment values and other plant status assessments will be reported to offsite agency officials.
The relationship of these dose assessment values to the Environmental Protection Agency (EPA) Protective Action Guides (PAGs) will also be reported.
The whole body and thyroid exposure action levels of the four classes have been related to the EPA PAGs.
Specific values are given in the Plan for the fractions of a PAG needed to declare an emergency class.
These fractions are more conservative than those called for in NUREG-0654 and would result in declaration of an emergency classification under conditions less severe than the criteria of NUREG-0654.
The Licensee will be required to conform these more closely to Appendix 1 of NUREG-0654 to assure consistency of reporting with other facilities.
The Licensee may recommend, and the State may choose, however, to take actions beyond those specified in NUREG-0654 for particular emergency classes.
Based on this information, the Emergency Director will provide offsite officials with recommendations for protective actions for the public. -
The Pennsylvania Emergency Management Agency's Disaster Operations Plan, Annex E; the Department of Environmental Resources, Bureau of Radiation Protec-tion Plan; and all five county plans contain the same emergency classes as those used in the Licensee's Plan.
The State has adopted the EPA PAGs for planning purposes.
The State emergency plan places reliance on information provided by the Licensee for determination of initial offsite responses.
Based on our review and as outlined and discussed above, we find that a standard emergency classification and action level scheme based on facility system and effluent parameters is in use by the Licensee (although the adequacy of final emergency action levels remains to be determined) and that the State emergency plan calls for reliance on information provided by the Licensee for determina-tions of initial offsite response measures.
Accordingly, we find that, contin-gent upon the adequacy of the final Emergency Action Levels to be formally submitted by the Licensee, the planning standard for the Emergency Classification System will have been met.
E.
Notification Methods and Procedures Planning 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 has been established; and means to provide early notification and clear instruction to the populace within the plume exposure pa'.hway Emergency Planning Zone have been established.
Emergency Plan After the Shift Supervisor has classified and declared an emergency, he must ensure that all required notifications are made including those to offsite emergency response organizations.
Initial messages will be issued to provide information concerning the emergency class, af fected populace and areas, and type and magnitude of any actual or potential release.
The Bureau of Radiation Protection, after receiving notification from PEMA that an emergency exists, will verify the origin of the message.
If an emergency situation requires implementation of the TMI 1 Emergency Plan, l
and if the accident falls within the Notification of Unusual Event, Alert, or Site Emergency categories, the Shift Supervisor will notify the Dauphin County l
EOC, PEMA duty officer, NRC office in Bethesda, Maryland, the Duty Section l
Superintendent, the unaffected Control Room, and the Public Affairs representative.
The PEMA duty officer will then immediately notify the five counties within the plume EPZ.
If the accident falls into the General Emergency class, the notification sequence will be the same except that all five counties within the plume exposure Emergency Planning Zone will also receive direct notification from the TMI-1 site.
Upon being informed of an emergency, the Duty Section Superintendent wi'i determine to what extent the offsite and onsite emergency organizations will be activated.
For an Unusual Event, all or part of the Duty Section will be -
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1 activated as necessary.
For an Alert, the Duty Section and all or portions of the onsite emergency organization will be activated.
The Technical Support Center and the Operations Support Center will be activated.
For a Site Emer-gency, the entire onsite emergency organization will be activated, and all or most of the offsite emergency organization will also be activated.
For a General Emergency the entire onsite and offsite emergency organizations will be activated.
The Duty Section Superintendent will then assume the position of Emergency Director, relieving the Shift Supervisor.
PEMA will notify the BRP immediately after receiving notification of an emer-gency at TMI.
As appropriate, PEMA will notify the following:
Dauphin, York, Lancaster, Lebanon and Cumberland Counties, other affected States, selected State agencies such as the Department of Environmental Resources, Department of Agriculture, Department of Health, State Police and Department of Transporta-tion, and selected Federal agencies.
In summary, based on our review of the Licensee's emergency plan, we find that procedures have been established for notification by the Licensee of State and local response organizations.
To ensure that offsite authorities are kept informed of the emergency status, the Emergency Director will provide followup messages containing the following information if it is known and appropriate:
location of incident and name and telephone number (or communications channel identification) of caller, date/ time of incident, class of emergency, type of actual or projected release and estimated duration / impact times, estimate of quantity of radioactive material released or being released and the height of release, chemical and physical form of released material, including estimates of the relative quantities and concentration of noble gases, iodines and particulates, prevailing weather, actual or projected dose rates and projected integrated dose at site boundary, projected dose rates and integrated dose at about 2, 5 and 10 miles, estimate of any surface radioactive contamination, emergency response actions underway, recommended emergency actions, including protective measures, request for any needed onsite support by offsite organizations, and prognosis for worsening or termination of event based on plant information.
We find that the Licensee has established the content of initial and followup messages to response organizations as required.
Early warning to the affected population is accomplished by PEMA and the affected county emergency' management organizations.
Several methods to warn the population-at-risk can be used.
The possible methods of notification include the Emergency Broadcast System, a Siren Alert System, and vehicles with loud speakers which can be dispatched to broadcast warning messages.
Each county can notify its local Emergency Management Coordinators and each county has central dispatching manned on a continuous basis with police and fire department radio communications.
The Licensee has let a contract to Federal Signal Corporation to perform an engineering study of a radio-controlled outdoor siren alerting system for TMI.
The purpose of this study is to design an alerting system which would satisfy the requirements in NUREG-0654 and FEMA REP-1, Rev. 1, Appendix 3.
The Licensee m-
has received the Federal Signal report and is analyzing its conclusions.
The Licensee will be required to satisfy all applicable regulatory requirements concerning alerting in accordance with the implementation schedule promulgated by 10CFR50 Appendix E.
Thus, while efforts are underway to establish physical and administrative means for prompt notification and clear instruction to the populace within the plume exposure pathway EPZ, those efforts are not complete and this matter remains unresolved at this time.
In conclusion, based on our review and as outlined and discussed above, we find that Licensee procedures for notifying State and local response organiza-tions have been established.
We also find that the content of initial and followup messages to response organizations has been established.
Accordingly, these portions of the planning standard for Notification Methods and Procedures have been met.
As yet, the administrative and physical means to provide prompt notification and instruction to the populace within the plume exposure pathway EPZ in accordance with Appendix 3 of NUREG-0654 have not been established and this remains an open and unresolved matter.
F.
Emergency Communications Planninc Standard Provisions exist for prompt communications among principal response organizations to emergency personnel and the public.
Emergency Plan The lead State agency for the coordination of radiological response plans (PEMA), exercises authority over organizations having an emergency response role within the plume exposure and ingestion EPZs.
PEMA maintains a duty watch officer as discussed in Section II.A above.
The Bureau of Radiation Protection has made provisions for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, 7 day per week interface with PEMA.
The Dauphin, York, Cumberland, Lebanon and Lancaster County Emergency Operations Centers are the locations of the County dispatchers for police, fire, and rescue services and are continuously manned.
The " Operational Line" is a telephone in the Shift Supervisor's Office that has dedicated lines connecting it with the Babcock & Wilcox Company in Lynchburg, Virginia, the TMI Technical Support Center, and the EOF.
This line permits an unimpeded flow of plant parameters, system status data, reactor core conditions and other information needed in accident mitigation.
The Communicator is responsible for establishing and controlling this line.
The " Radiological Line" is located in the Control Room and has dedicated lines connecting it to BRP, and the EOF.
This line permits transmission of plant conditions, dose projections, offsite monitoring results, and liquid effluent release data to all parties involved in accident assessment.
The Radiological Assessment Coordinator is responsible for establishing and controlling this special line.
The Control Room has a National Warning System (NAWAS) telephone as does the PEMA operations center in Harrisburg, Pennsylvania.
This connection provides an alternate means for prompt notification of en emergency and the subsequent exchange of information. - -.
I The Shift Supervisor's Office has a telephone equipped with an auto dialing system.
The auto log lists the numbers of the PEMA duty officer, the five county EOC's, St;te Police, DOE RAP Team, Hershey Medical Center, NRC, Harrisburg Hospital, and the Licensee's duty supervisors and essential staff members.
The line allows rapid notification of all essential parties and organizations in the emergency response network.
The Control Room is equipped with a device that triggers a signal that will result in the Dauphin County EOC radio scanner locking into the TM' operations frequency.
Radio Communications can then proceed with TMI transmitting on the operations frequency and receiving the Dauphin County EOC frequency on a radio scanner.
The NRC Emergency Not.ification System (ENS) hotline connects TMI with NRC headquarters in Bethesda, Maryland.
The ENS hotline phones are located in the Control Room, the Technical Support Center, and the EOF.
In the event of a Site Emergency, the Health Physics Network Line (HPN) will be activated by the NRC Operations Center in Bethesda.
This network includes all nuclear power plants, the NRC Regional Office and the NRC Headquarters in Bethesda.
This system is dedicated to the transmittal of radiological information by NRC personnel onsite to personnel at the Bethesda and Regional Office.
HPN phones are located in the Shift Supervisor's Office and Emergency Operations Facility.
Field radiological assessment teams will receive emergency kits containing portable radios.
The communication links with the State and local governments within the plume exposure oathway EPZ will be testeo at least once per month.
The communication links with Federal emergency reponse organizations and States within the ingestion EPZ will be tested at least once every 12 months.
The communication links between the nuclear facility, State and local emergency operation centers and field assessment teams will be tested at least once every 12 months.
As to prompt communication to the public, we have previously identified the establishment of physical and administrative means for notifying the populace within the plume exposure pathway EPZ as an unresolved matter.
Based on our review and as outlined and discussed above, we find that provisions exist for prompt communications among principal response organizations to emergency personnel and that the planning standard for Emergency Communications is met in this regard.
Provisions for prompt communications to the public are not yet in place and that matter remains unresolved.
G.
Public Information Planning Standard 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 location or locations) are estab-.o.
lished in advance, and procedures for coordinated dissemination of information to the public are established.
Emergency Plan The Commonwealth of Pennsylvania Disaster Operations Plan, Annex E, provides for the periodic dissemination of information to the public.
The State will assist PEMA in developing material for emergency public information packages, radio and television releases, and provide for the annual dissmination of information to the public within 10 miles of the site.
This information will include educational information on radiation, whom to contact for additional information, respiratory protection, sheltering, and evacuation routes. The Plan does not provide details of the schedule or the precise methods for dissemination of public information, as this program is still under development.
Drafts of educational information regarding radiation hazards and public protective response options will be reviewed by the NRC staff and FEMA prior to restart.
Nevertheless, under the provisions of the State emergency plan, information will be made available to the public on a periodic basis on how members of the public will be notified and what their initial actions should be during an emergency.
During an emergency, information flows from the affected Control Room to the Emergency Operations Facility where the Licensee Public Affairs Manager and the Public Information Writer are assigned.
The Licensee Public Affairs Manager will assure that the latest approved Licensee statement is promptly distributed to the media.
For the more severe emergency classes, copies of the Licensee's statements will be first provided to the State and NRC.
The Public Affairs Manager or the Public Information Writer will accept requests for interviews by Press representatives visiting the Information Trailer, located next to the Observation Center / EOF.
Approved statements will also be transmitted to the Media Center at Crawford Station, where it will be distributed to media representatives.
If the emergency becomes long-term, it will be the responsi-bility of the Community Relations Manager and the Director-Governmental Affairs to plan and arrange briefings and determine the possibility for tours.
At least annually, the Emergency Public Information Plan Coordinator will conduct programs to acquaint the media with the Emergency Public Information Plan, radiation information, and points of contact for releases of public information during an emergency.
In summary, the principal points of contact with the news media during an emergency have been established, and procedures have been established for coordinated dissemination of information to the public.
Based on our review and as outlined and discussed above, we find that provisions have been established for making information available to the public on a periodic basis on how it will be notified and what its initial actions should be, that principal points of contact with the news media have been established, and that procedures for coordinated dissemenation of information have been established.
However, the details of the State's public information program remain to be developed and reviewed..
4 H.
Emergency Facilities and Equipment Planning Standard Adequate emergency facilities and equipment to support the emergency response are provided and maintained.
Emergency Plan The Technical Support Center (TSC) is an area located below the Control Roo-on the 322' elevation of the Control Building.
It contains the controli needed to bring the reactor to a safe shutdown.
A display unit and pe' h board provide access to over 100 plant parameters which may be useu
- suon-ment of accident conditions.
Records and drawings describing the WWin conditions and layouts of structures and system are inside the TSC.
TN purpose of the TSC is to provide an area outside of the Control Room inat can accommodate personnel to support the comand and control functions by supplying more in-depth diagnostic and correctiv6 engineering assistance. The TSC is activated during an Alert, Site or General Emergency, or when directed by the Emergency Director.
The Operation Support Center (OSC) is located in the area of the Health Physics Access Control Point on the 306' elevation of the Control Building.
The secondary location for the OSC is in the Instrument Control Shop and Instrument Supervisor's Office which are adjacent ~to the Control Room.
The purpose of the OSC is to provide an area for personnel to meet for duty assignments in support of emergency operations.
Emergency equipment and supplies located in this area include dosimeters, various survey meters, protective clothing, respirators and/or masks, air samplers, portable lanterns and/or flashlights, a copy of the Implementing Document, decontamination chemicals, self-contained breathing apparatus, and resuscitator iad first aid kits.
The OSC is normally within the Auxiliary Building Ventilation System; however, on detection of airborne activity, the OSC is isolatec from the remainder of the Auxiliary Building Ventilation System and can be placed in a recirculation mode of operation through a charcoal filter system.
The TMI observation center will house the primary Emergency Operations Facility (EOF).
This facility normally functions as a public relations center and is a permanent structure with adjacent parking areas.
The EOF will house the key technical groups of the offsite emergency organization. The EOF will also provide space for a BRP liaison representative and the NRC representatives.
The alternate location for the EOF is at the Crawford Station, which is about 3 miles north of the TMI site.
The Duty Section Superintendent, after being informed of an emergency, will determine to what extent the Licensee offsite and onsite emergency organiza-tions and personnel should be notified in accordance with emergency implementing procedures.
Meteorological information is obtained from a 150 ft weather tower maintained at the north end of the island.
All information is recorded on strip charts in the meteorological building adjacent to the weather tower.
The Control Room is provided with remote strip charts of wind speed, direction, temperature,.
and a measure of atmospheric stability.
The mini-computer system located in the meteorological building is able to make real-time estimates of atmospheric effluent transport and diffusion following an accidental airborne radioactive release from the TMI plant.
The National Weather Service (NW5) will provide backup meteorological information from the Capital City Airport, Harrisburg International Airport and State Turnpike Authority, Harrisburg.
The NWS will provide air stability determinations upon request.
Mobile radiological labs are available from Babcock & Wilcox, Pennsylvania Powe*
Bioassay laboratories are available from the Radiation Maygement Corp within 3 hrs and the Hershey Medical Center within 30-45 min.
Ground motion and structure vibrating response caused by an earthquake in the area are measured by strong motion recording systems at the station. A cassette magnetic tape recorder located in the Unit 1 Control Room receives data supplied by sensor units mounted on the Reactor Building.
If ground acceleration exceeds the setpoints, a control room annunicator will actuate.
The radiation monitoring system detects, alarms, and initiates emergency actions when radiation levels or radionuclide concentrations exceed preset values.
The radiation monitoring equipment is designed so that each rotation has adjustable, high trip, low trip, and power supply failure alarms and solid-state circuitry.
Each radiation monitor can be checked periodically using solenoid check sources. An alarm is initiated when failure occurs anywhere in the channel.
The area radiation monitoring subsystem is composed of channels which use an ionization type detector with a remote controlled check source.
One channel is used to monitor the high level of radiation that would be characteristic of the post-accident atmosphere in the containment. The control room readout modules are located in the radiation monitoring panel.
The atmospheric radiation monitoring subsystem is composed of fixed and movable monitors.
Samples may be obtained by placing a sampling head into a ventilation duct.
Movable atmospheric monitors on carts are used in the spent fuel handling area during refueling operations and in the radiochemical laboratory during laboratory sample preparations.
Visual high-radiation alert / low-level alarms are provided for each channel for all monitors.
The liquid radiation monitoring subsystem consists of monitors composed of a sampler, scintillation detector, and control room ratemeter module.
They indicate in the control room on the individual ratemeter modules and two common recorders.
Process monitors measure appropriate parameters, displayed in the control room, that are indicative of the status of various plant systems and the reactor.
Fire protection at TMI is provided by 3 systems:
the fire service water system, the halogenated fire suppression system and the CO fire extinguishing 2
syster.
The systems are actuated either manually or automatically in response to signals from detectors in the protected area.
The detectors used include thermostats, embryonic explosion detectors, temperature rise detectors, fusible links, flow detectors, and smoke and vapor detectors.
A Radiological Environmental Monitoring Program (REMP) has been established by Met-Ed for the TM1 Nuclear Station.
Its objectives include fulfilling the obligations of the radiological environmental surveillance sections of the Environmental Technical Specifications, determining any increase in the concen-tration of radionuclides in critical pathways, detecting any buildup of long-lived radionuclides in the environment or change in ambient gamma radiation levels, and verifying that radioactive releases are within allowable limits.
Sa ples are taken from the aquatic, atmospheric and terrestrial environments.
The locations of the thermoluminescent dosimeters (TLDs) are listed in the Plan.
Offsite radiological monitoring teams can be dispatched by the Emergency Director.
These teams will consist of one or two persons who are trained in the use of portable radiation monitoring equipment. When dispatched, the teams will go to the onsite Processing Center where they will pick up emer-gency kits containing portable monitoring equipment and portable radios.
They will report all readings to the Radiological Assessment Coordinator.
The plant is able to dispatch two teams and receive initial information within one-half hour of the emergency situation.
To insure that emergency equipment is maintained and available, readiness checklists have been developed and are part of the administrative procedures.
These checklists provide for inventory and calibration of equipment in emergency kits.
Inventory will be performed on a quarterly basis.
Equipment and supplies with shelf-lives will be checked and replaced as necessary.
A report of each inventory and inspection, including deficiencies, will be given to the Emergency Planning Coordinator who will ensure that identified deficiencies are promptly corrected.
A typical emergency kit inventory is provided in the Plan.
The Environmental Assessment Command Center manned by Licensee personnel will
~
be located at the Harrisburg (Olmsted) Airport. The Center will be responsible for the assessment of all offsite radiological impacts including offsite dose calculations, offsite monitoring of releases via all major pathways, and the dissemination of data from offsite emergency teams to the Environmental Assess-ment Coordinators.
Based on our review of the Licensee's emergency plan and as outlined and discussed above, we find that the Licensee has provided adequate emergency facilities and equipment to support its emergency response and has established procedures for maintaining emergency equipment.
Additional upgrading of the TSC and EOF will be required in accordance with NUREG-0696, Rev 1; however with the exception of further review of the EOF functions as mentioned in section II.B of this report, the planning standard is met with respect to restart.
I.
Accident Assessment Planning Standard Adequate methoas, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.
Emergency Plan The Plan identifies the plant systems and effluent parameters that will be used to assess potential accidents and which serve as the basis for emergency action levels.
The identification of emergency action levels and key plant parameters which are indicative of abnormal conditions will aid in the rapid accident classification and threat assessment.
For each analyzed accident, the Plan cross-references key parameters, emergency action levels and emergency and operating procedures to aid emergency response decision makers.
Engineering analyses are in progress to determine the design, technical feasibi-lity and installation requirements for the following equipment required by NUREG-0578:
instrumentation for detection of inadequate core cooling, high range effluent monitors, in plant iodine instrumentation and post accident sampling capability.
These equipment modifications have not yet been made and this remains as an unresolved item.
The Plan describes actions for accident assessment.
For assessing gaseous releases, the first step is to estimate the noble gas and the iodine source release terms in curies per second.
To estimate these source terms, the radiation monitoring system readings for all the monii.ored gaseous effluent release paths are factored into source release terms for noble gas and iodine by applying the appropriate ventilation flow rates, meter conversion factors and containment building design leak rate.
We conclude that more exact assump-tions should be made with regard to containment leak rate as a function of measured containment pressure in using this calculational technique.
Using the appropriate meteorological dispersion factor (X/Q) for a specific loca-tion, whole body dose rates and iodine concentrations are projected.
- Then, radiation monitoring teams can be sent to the location of interest to take l
readings to confirm the projection.
I For liquid release assessment, the radionuclide concentration at any downstream location is determined by taking the radiation monitoring system reading on the plant liquid effluent monitor and applying the effluent flow rate, river l
volumetric flow rate and a meter conversion factor.
The calculation techniq;e is included in the Emergency Plan Implementing Procedures.
If the projected concentration is above the level stated in the procedures, downstream users will be notified.
Effluent monitoring data is input to a computer in Rockville, Maryland, which also receives direct meteorological data from the site's meteorological tower l
for use in making dose calculations and projections and supplements the func-l tions of the Environmental Assessment Center discussed in the proceeding section. The effluent monitors will be directly tied into a computer with the meteorological data.
Dose calculations and plume projections can be recalled i
1 :
through the Environmental Assessment Center's CRT unit.
The software package with this system, MIDAS (Meteorological Information and Dose Acquisition System), provides the following functions:
collection and storage of meteoro-logical data, plant effluent monitor data, and off site radiation monitor data; retrieval and processing of historical data for effluent reports and environmental dose calculations; and remote interrogation by government agencies for display of results.
If the instrumentation used for radiological assessment is off-scale or inopera-tive, the Plan provides for use of contingency dose calculation procedures.
The calculation methods use dose release factors which are based on expected plant source terms for several accident classifications.
The Radiological Assessment Coordinator first selects the accident class that fits current plant conditions.
He then applies the X/Q for the location of interest to the dose release factor to project whole body and child thyroid exposures.
At the same time, radiation monitoring teams sent to the location take actual field measurements to refine the projections and correlate projected and actual results.
The calculational techniques are included in an Emergency Plan Implementing Procedure.
The Radiological Assessment Coordinator is responsible for coordinating the activities of emergency response teams which are part of his emergency response organization.
The teams will consist of one or two persons.
They will have emergency kits containing portable monitoring equipment and portable radios and will serve to confirm Licensee's dose projections.
Based on our review of the Licensee's emergency plan and procedures and as outlined and discussed above, we find that adequate methods, systems and equipment for the assessment and monitoring of actual or potential offsite consequences are in place with the exception of modifications and equipment required by NUREG-0578 and improvement of certain dose estimation tools.
J.
Protective Response Planninc Standard A range of protective actions have been developed 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.
Emergency Plan When an emergency is declared, an announcement is made on the public address system to everyone onsite.
This announcement will include the classification of the event and any casite actions.
Plant personnel will then proceed to their emergency stations.
All non-essential onsite personnel will be accounted for at a predesignated area.
If a Site Emergency or General Emergency is declared, or at the Emergency Director's discretion, all non essential personnel will be evacuated from the site by private vehicles to the Crawford Station.
Site security personnel will check all buildings, trailers, and other onsite areas to ensure that all persons have assembled and evacuated.
Rescue operations will be implemented to locate any missing persons.
If the Crawford Station is inaccessible due to plume passage, the 500 kV substation east of the site will be used.
Inclement weather may increase evacuation time but will not affect the direction of the traffi: flow.
Once at the Crawford Station, all personnel will be accounted for and monitored for radioactive contamination and decontaminated if necessary by trained personnel.
Measures taken to prevent the spread of contamination will include isolating affected areas, and decontaminating persons, their clothing and equipment prior to release.
For contaminated persons onsite, decontamination facilities will be at the Health Physics Control Access Point.
If this area is not accessible, the Crawford Station will be used.
The I.icensee has made provisions to protect onsite individuals from contamina-tion.
Protective clothing and respirators and/or masks will be available in or near the Control Room and the Operations Support Center.
The Licensee has investigated the use of radioprotective drugs for onsite workers.
The criteria for administering the drug are still under development by the Food and Drug Administration, so the Licensee has postponed its decision regarding the use of KI while awaiting further direction from regulatory authorities.
We will require stockpiling of thyroid blocking drugs for individuals remaining or arriving onsite.
The Licensee should use the guidance in NCRP-55 with regard to distribution until further FDA guidance is released.
In summary, we find that a range of protective action for Licensee's emergency workers for the plume exposure pathway EPZ have been developed.
The remainder of the planning standard for Protective Response involves matters which are currently under review by FEMA.
The prima"y responsibility for protecting persons in offsite areas rests with the Commonwealth of Pennsylvania.
The Department of Environmental Resources, Bureau of Radiation Protection (BRP) is responsible for recommending to PEMA what protective actions should be taken.
The BRP can recommend actions such as evacuation, sheltering and thyroid prophylaxis.
The appropriate protective l
action will depend on the magnitude of the release, duration of the release, l
wind speed, wind direction, time of day and transportation constraints.
The l
Licensee will provide protective action recommendations to State officials.
l An evacuation map for the Three Mile Island plume exposure EPZ is shown in the l
The Plan also shows the population distribution around the nuclear facility.
The Licensee has not provided with its Emergency l
Plan an acceptable Evacuation Time Estimate Study to be used by response personnel charged with recommending and deciding upon protective actions during an emergency.
The Licensee has committed to providing acceptable evacuation time estimates which meet the requirements of NUREG-0654, Rev. 1, Appendix 4.
Completion of this study is expected in January 1981.
Alerting and notification to the population-at-risk is accomplished by PEMA and the affected county emergency management organizations.
Several methods l
l !
I
- h..
can be used, including the Emergency Broadcast System (EBS), and a siren alert syster Each county can notify its local Emergency Management Coordinators by teleph:.ne and each county has 24-hour central dispatching.
Vehicles with loudspeckers can be dispatched to broadcast informational messages.
The current alerting and notification systems and procedures are not capable of warning the population located in the plume exposure EPZ within the time limits of 10 CFR Part 50, Appendix E.
TMI has committed to ensuring that an upgraded notification system meeting all required notification system standards will be installed in accordance with the dates promulgated by 10CFR50 Appendix E.
FEMA will conduct an evaluation of the effectiveness of the public notification system.
We find that a range of protective actions for Licensee's emergency workers for the plume exposure pathway EPZ have been developed and that this portion of the planning standard for Protective Response is met with the exception of stockpiling of thyroid blocking drugs. However, FEMA's review is continuing as to non-Licensee offsite matters addressed by this planning standard so that the following remain to be determined:
(1) the adequacy of the protective actions for the plume exposure pathway EPZ for the public and for emergency workers other than those of the Licensee; (2) the adequacy of the guidelines, developed and in place, for the choice of protective actions during an emergency; and (3) the existence of appropriate protective actions for the ingestion exposure pathway EP2.
K.
Radiological Exposure Control Planning Standard Means for controlling radiological exposures in an emergency are established for emergency workers.
The means for controlling radiological exposures shall include exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protective Action Guides.
Emergency Plan Emergency personnel involved in removal of injured persons, undertaking corrective actions, performing assessment actions, administering first aid, performing decontamination, providing ambulance service, and providing medical treatment will have their exposures controlled to comply with the limits specified in l
l 10CFR20 for radiation workers.
However, emergency measures may warrant above-I normal radiation doses.
Life saving measures to avoid substantial exposures l
to populations or preservation of valuable installations may be sufficient cause for above normal exposure.
The exposure guidelines for a life saving action are 100 Rem whole body and no thyroid limit.
The exposure guidelines l
for a corrective action are 25 Rem whole body or 125 Rem thyroid.
These are l
consistent with EPA Emergency Worker and Lifesaving Activity PAGs.
The Emergency l
Director is the only person who can authorize emergency workers to receive doses in excess of 10CFR20 limits.
These workers must be volunteers and the Emergency Director must balance the risks from such exposure against the benefits to be gained. l l
l
At least two health physics technicians are assigned to each shift to provide continuous coverage. These technicians are qualified to determine doses received by workers and methods of dose reduction.
They will perform radiation surveys and monitor personnel in accordance with existing health physics precedures.
They are also responsible for maintaining records of personnel exposures.
The Group Leader-Health Physics Support will be responsible for all aspects of health physics and environmental assessment support.
This support includes providing a member of the Health Physics Department to the Group Leader-Administrative Support to assist in issuing personnel monitoring devices to emergency response personnel needing site access and personnel dosimetry.
All personnel leaving the protected area will be checked for containation by using portal monitors, and/or hand and foot counters, and/or friskers.
Onsite contaminated personnel will undergo decontamination by radiological controls personnel at the Health Physics Control Access Point.
Measures will be taken to prevent the spread of contamination, such as isolating affected areas, placing contaminated persons in protective clothing before moving, and decon-taminating affected personnel, their clothing, and equipment prior to release.
Personnel evacuated from the site will be checked for contamination at Crawford Station.
Equipment for decontamination will be in emergency supply kits which include absorbent material, scrub orushes, soap, shanpoo, decontaminant chemicals, wash bottles, applicators, and surgical gauze.
Gloves, protective clothing, and other equipment will be available for decontamination and waste control.
Portable survey instruments are available and kept calibrated for use in decontamination operations.
All land within the exclusion area is owned by the Licensee and will be con-trolled.
In plant Contamination control will be executed in accordance with approved radiological controls procedures.
In the event of a contaminant release, in plant potable water systems will be secured to prevent contamination. Water and food supplies for onsite emergency personnel will be brought in using sealed containers and will be monitored prior tr, use or consumption and then on a routine basis.
The Emergency Director and the Emergency Support Director will consider an emergency under control when certain guidelines are met. These guidelines include the following:
radiation levels in all in plant areas are stable or are decreasing with time, releases of radioactive materials from the plant are under control or have ceased.
The radiation exposure limits of 10CFR20 will apply during recovery operations.
Based on our review of the Licensee's emergency plan and procedures and as outlined and discussed above, we find that the Licensee has established means for controlling the radiological exposures of its emergency workers during an emergency and those means are consistent with EPA Emergency Worker and Life-saving Activity Protective Action Guides.
Accordingly, we conclude that the Licensee meets the planning Standard for Radiological Exposure Control.
~ 22 -
L.
Medical and Public Health Support Planning Standard Arrangements are made for medical services for contaminated injured individuals.
Emergency Flan Trained shift personnel will be available on-site on a 24-hour per day basis to give emergency first aid and medical treatment to injured personnel.
First aid stations are located at several places within the plant.
These stations are equipped with the following supplies for the needs of 100 employees:
stretchers, inflatable splints, blankets, plastic sheets and 100 employee-size first aid kits.
An unmanned room is located in Unit 1 at the 305' elevation in the Service Building and is outfitted to support the aid that can be given by personnel with multi-media level Red Cross training.
A special medical facility is located in the Unit 1 Health Physics Area for the treatment of contaminated / injured personnel.
Ambulance service for the site will be provided by local fire departments and rescue squads.
Met. Ed. will provide annual training to the squad members in the care of contaminated individuals.
Met. Ed. will also provide radiological control technicians to assist the rescue squads.
Arrangements for hospital and medical services for injured or contaminated personnel have been made with the Hershey Medical Center, Radiation Management Corporation (RMC) and two local physicians.
The Hershey Medical Center receives contaminated and injured personnel in an area designated the Radiation Emergency Area.
The Center has detailed plans and procedures for the decontamination and treatment of personnel.
The Radiation Emergency Area at the center includes the following equipment:
GM and ion chamber instruments, respirators, dosimeters, anti-contamination clothing, radioactive waste containers, portable shielding, decontamination table, decontamination kits, sample taking kits, and thermo-luminescent dosimeters.
The Hershey Medical Center's staff includes a certified health physicist, a master's level health physicist and radiation protection technologists to provide medical services support.
Radiation Management Corporation's facilities and services include a radiation chemistry laboratory, exposure evaluation services, a radiation emergency medical team and a van designed to transport contaminated patients.
RMC has access to and use of the hospital of the University of Pennsylvania special emergency medical accident plan facility which includes a radiosurgery decon-l tamination suite. The RMC staff is composed of 150 people skilled in health physics, radiation measurement, radio-chemistry, environmental sciences, l
biology and ecology.
l Based on our review of the Licensee's emergency plan and as discussed and outlined above, we find that arrangements have been made for medical services for contaminated injured individuals.
Accordingly, we find that the Licensee has met the planning standard for Medical and Public Health Support.
M.
Recovery and Reentry Planning and Post-Accident Operations Planning Standard General plans for recovery and reentry are developed.
Emergency Plan The Emergency Director and Emergency Support Director share the responsibility of determining and declaring when an emergency situation is stable and has entered the recovery phase.
The emergency will be considered under control and in the recovery phase when the following conditions are met:
radiation levels in all in plant areas are stable or are decreasing with time, releases of radioactive materials from the plant are under control or have ceased, containment pressure is at normal levels, reactor plant is stable and in a long-term safe shutdown condition, and any fire, flood or other emergency condition is controlled or has ceased.
When post-accident conditions indicate that recovery operations will be com-plicated or will extend over a long period of time, Met. Ed. will shift from the emergency response organization to a long-term recovery organization. The organization will be dependent upon the nature of the accident, post-accident conditions and other factors at the time.
The basic organizational structure is shown in the Plan.
The Office o' the President of the Licensee is responsible for the overall recovery operation, including overseeing the operations of the functional groups and ensuring that all activities receive proper analyses and coordination.
The responsibilities of the several recovery managers are set forth in detail in the plan and have been reviewed.
The Emergency Director will be responsible for notifying all applicable agencies when an emergency has entered the recovery phase.
Estimates of total population exposure will be periodically made.
The Licensee has established a complete Radiological Environment Monitoring Program (REMP) for the Three Mile Island Nuclear Station.
The objectives of REMP include l
determining if any significant increase occurs in the concentration of radio-l nuclides in critical pathways, to detect any buildup of radionuclides in the l
environment, to verify that radioactive releases are within allowable limits, i
and that plant operations have no detrimental effects on the health and safety
(
of the public or on the environment.
Samples for the REMP are taken from the l
aquatic, atmospheric and terrestrial environments.
Sampling locations are l
determined from site meteorology, Susquehanna River hydrology, local demography l
and land uses.
Control samples are collected at locations which are believed to be unaffected by plant operations.
Fluctuations in the level of i u ionuclides and direct radiation at indicator stations which are expected to monitor plant effects are evaluated with respect to fluctuations at control stations.
Based on our review of the Licensee's emergency plan provisions as outlined and discussed cbove, we find that general plans for recovery and reentry have been developed. Accordingly, we find that the planning Standard for Recovery and Reentry Planning and Post-Accident Operations is met.
l N.
Exercises and Drills Planning Standard Periodic exercises are (will be) conducted to evaluate major portions of emergency response capabilities, periodic drills are (will be) conducted to develop and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected.
Emergency Plan Drills and exercises will be conducted to observe the overall state of emergency preparedness.
These drills and exercises will serve to verify the adequacy of the Emergency Plans and procedures, test emergency facilities and equipment, and test and train emergency response personnel to respond to accident conditions.
A major exercise appropriate to a Site or Genera.1 Emergency will be conducted at least once a year.
The exercise will include mobilization of both onsite and of fsite emergency personnel and resources to verify the capability to respond to an accident.
Communications with State and county agencies will be included.
The exercises will be varied from year to year so that all major elements of the plan and preparedness organizations are tested within a 5 year period.
The times of the exercises will be varied so that some will start between 6:00 p.m. and midnight or between midnight and 6:00 a.m.
At least once per month the communication link with State and local governments in the plume EPZ will be tested.
At least once per year the communication links with Federal emergency response organizations and States within the ingestion EPZ will be exercised.
The Licensee will be required to conduct tests of these communications links at least quarterly, however, to conform with NUREG-0654, Revision 1.
The communications links between the nuclear facility, the State and local emergency operations centers and field assessment teams will be exercised at least once every 12 months.
At least one fire drill will be conducted every 3 months.
Every year at least one fire drill will involve at least one, if not all, of the local fire departments.
These drills will be in accordance with plant Technical Specifications.
l Every year, at least one medical emergency drill will be conducted.
The drill will involve simulated cases of contaminated personnel and the participation of some, if not all, of the local medical support personnel and organizations.
At least one radiological monitoring drill will be conducted every 12 months.
The drill will include collection and analysis of sample media from onsite and offsite locations.
Health Physics drills will be conducted semi-annually.
The drills will involve response to, and analysis of, simulated elevated airborne and liquid samples l
and direct radiation measurements in the environment.
Analysis of inplant liquid saniples with simulated elevated activity levels will be included in the drills.
The Licensee has not agreed to use of in plant samples with actual elevated activity levels in the Health Physics drills.
Drills and exercises will be conducted to simulate as closely as possible, actual emergency conditions.
They may be scheduled so that one or more drills -.
or exercises can be conducted simultaneously.
Drill scenarios will be prepared which involve participation of several emergency teams and all or parts of the i
onsite and offsite emergency organizations.
The scenarios will include the basic objective of each drill and exercise, dates, places and times of partici-pating organizations, simulated events and a time schedule of real and simulated initiating events.
The scenario will also include a' narrative summary describing the conduct of the exercises or drills including such things as simulated casualties, offsite fire department's assistance, rescue of personnel, use of protective clothing, deployment of radiological monitoring teams, and public information activities.
The Emergency Planning Coordinator will arrange for qualified observers and will notify the offsite emergency response organizations at least 30 days in advance of the scheduled date of a drill or exercise.
After a drill or exercise is finished, a critique will be scheduled and held as soon as possible.
Observer and participants comments will be given to the Emergency Planning Coordinator.
He will be responsible for coordinating proposed revisions to the TMI Emergency Plan and upgrading emergency equipment and supplies. The Emergency Planning Coordinator will submit recommendations to the Vice-President TMI-1 for review and incorporation of the recommended changes into the Emergency Preparedness Program.
Based on our review of the Licensee's emergency plan and as outlined and discussed above, we find that provision has been made for the conduct of periodic exercises to evaluate major portions of emergency response capabilities, for the conduct of periodic drills to maintain key skills, and for correcting deficiencies identified as a result of the exercises and drills.
Accordingly, we conclude that the planning Standard for Exercises and Drills has been satisfied.
It must be noted, however, that the major exercise prior to restart ordered by the Commission in its August 9, 1979 order on restart has not yet been conducted and remains as a matter that must be undertaken before the facility is authorized to restart.
O.
Radiological Emergency Response Training Planning Standard Radiological emergency response training is provided to those who may be called on to assist in an emergency.
Emergency Plan All personnel at the Three Mile Island Nuclear Station will participate in a formal training program directed by the Manager-Training TMI-1, who is responsible for ensuring that personnel in each department receive appropriate training.
All Three Mile Island staff personnel, except Operations Department personnel, are required to attend the General Employee Training Program at least once per year.
New employees and contractor personnel are required to attend the Health Physics Training Program before being permitted unescorted access onsite.
These programs are designed to familiarize personnel with the TMI Emergency Plan and Implementing Document, to teach the general duties and responsibilities assigned to all TMI personnel and to maintain a high degree of preparedness at all levels of organization. -
f PEMA conducts a training program throughout the State and assists the counties in developing training policy.
PEMA and the Dauphin, York, Lancaster, Cumberland and Lebanon County Emergency Management agencies will be invited, on at least an annual basis to participate in a training program at TMI.
The BRP will be invited, at least on an annual basis, to participate in a training program.
Both these programs will include a review of the TMI Plan and Implementing Document with emphasis on classification of emergencies, reporting requirements, assessment, protective and corrective actions, and communications networks.
The State Police will be invited, on at least an annual basis, to a training program which will include applicable parts of the Plan with emphasis on classification of emergencies, communications, and specific areas of responsi-bility.
The Licensee will provide orientation and training to local support organizations to ensure a high state of emergency preparedness and response capability.
Such training will be provided for the Middletown Police Department, local fire and rescue companies, the Hershey Medical Center, and local physicians.
The Licensee's TMI Station and Station support organization personnel assigned specific duties in the emergency organization will receive specialized training for their assignments.
The Plan delineates which personnel will receive specialized training, and the type and minimum required frequency of training.
When a major drill or exercise is performed, the Emergency Planning Coordinator will critique the results of the drill, assign personnel to correct any defi-ciencies, ensure that deficiencies are corrected and prepare and submit documen-tation to the Training Department for recordkeeping.
Reactor Operators and Senior Reactor Operators receive periodic on-the-job and continuous formal training including a comprehensive review of the TMI Emergency Plan and Implementing Document.
Personnel responsible for accident assessment receive training on the TMI Emergency Plan at least once per year.
This training includes the use of the dose projection techniques.
Radiation Protection personnel receive a training course and later receive instruction on new methods and equipment.
On at least an annual basis, instruc-tions will be given on classification of emergencies, personnel protection, location and use of emergency equipment determination of radiation exposure /
l contamination, decontamination, monitoring techniques and communications.
1 Security personnel will receive training on at least an annual basis.
This training includes personnel accountability, personnel and vehicle access control during emergencies, evacuation control and interfaces with offsite support organizations.
Fire Brigade training is provided on at least a semi-i annual basis.
The training will include the type of fires and their hazards, equipment for each type of fire, the installed fire detection and protection systems, portable fire-fighting equipment, respiratory protection and radiological hazards during fire emergencies.
l The training program for Emergency Repair Team personnel will include availability of equipment, responsibilities during an emergency, radiological considerations and interfaces with other emergency teams.
Training will be conducted at least annually.
First Aid and Rescue Teams will receive the Standard Red l l r-
Cross Multimedia First Aid Course.
A refresher course will be available annually.
leam members will be instructed on the availability of onsite medical treatment facilities, equipment and supplies, radiological hazards existing during personnel related emergencies, and interfaces with local medical support personnel.
Based on our review of the Licensee's emergency plan and as outlined and discussed above, we find that the Licensee has provided for radiological emergency response training for its personnel who will be involved in emergency response.
Accordingly, we find that the planning standard for Radiological Emergency Response Training is met for Licensee personnel.
The provisions of State and local emergency plans for radiological emergency response training for State and local emergency response personnel are currently being reviewed by FEMA and no finding has yet been made as to State and local personnel training.
P.
Responsibility for the Planning Effort:
Development, Periodic Review and Distribution of Emergency Plans Planning Standard Responsibilities for plan development and review and for distribution of emergency plans are established, and planners are properly trained.
Emergency Plan The TMI Emergency Plan will be reviewed and updated on at least an annual basis.
The Quality Assurance Department is responsible for auditing the TMI Emergency Plan and Implementing Document to verify compliance with the Operational Quality Assurance Plan, the Fire Protection Program Plan, internal rules, federal regulations, and operating license provisions.
The Emergency Planning Coordinator will provide an ongoing review of the Plan.
He will ensure that all members of the emergency organization are informed of the TMI Emergency Plan, the Implementing Document, and any revisions.
The Emergency Planning Coordinator will also familiarize himself with any changes in federal regulations and guidance that impact emergency planning activities.
Other emergency plans which support the TMI Plan are contained in the appendices of the Plan. Appendix A of the Plan is the Emergency Plan Implementing Document Table of Contents.
The Emergency Plan Implementing Procedures for each emergency class are listed in the Plan.
Appendices D through I contain the Commonwealth of Pennsylvania Disaster Operations Plan, Dauphin County Action and Response Plan for Emergency Personnel and Citizens, York County Evacuation Plan for the Three Mile Island Nuclear Power Plant, Lancaster County Emergency Evacuation Plan, Cumberland County Emergency Evacuation Plan, and Lebanon County Emergency Operations Plan.
Based on our review of the Licensee's emergency plan provisions and as outlined and discussed above, we find that the Licensee has established responsibilities for plan development and review, for distribution of emergency plans, and for proper training of Licensee planners.
Accordingly, we find that the Licensee _..
meets the planning Standard for Responsibility for the Planning Effort: Develop-ment, Periodic Review and Distribution of Emergency Plans. The provisions of State and local emergency plans with regard to responsibility for the planning effort are currently under review by FEMA and a determination as to adequacy of State and local plans has yet to be made.
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III.
CONCLUSIONS Based on our review against the requirements of 10 CFR 950.47b, 10 CFR Part 50, Appendix E and the criteria in NUREG-0654, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" Revision 1, we conclude that the Three Mile Island Unit 1 Emergency Plan, when revised to correct the deficiencies noted below, will provide an adequate planning basis for an acceptable state of Licensee's emergency preparedness and will meet the requirements of 10 CFR 50 and Appendix E thereto.
In order to rectify existing deficiencies and conform with the required planning standards, the following Plan modifications or commitments are necessary:
PLANNING STANDARD REQUIRED CORRECTIVE ACTION E.
Notification Methods and Establish physical and administrative means Procedures for providing prompt warning and instructions to the public within the plume exposure pathway Emergency Planning Zone in compliance with Appendix 3 of NUREG-0654.
G.
Public Education and Provide the NRC staff with details of the Information public information program regarding how the public will be notified and what their actions should be in an emergency.
Drafts of this information and the means of dissemination should be provided to the staff prior to restart.
I.
Accident Assessment Specify the instrumentation for accident assessment required by NUREG-0578 as required by the Commission's Restart Order of August 9, 1979.
Determine more exact assumptions for contain-ment leak rates used in dose projection.
J.
Protective Response Provide time estimates for evacuations with-in the plume exposure EPZ which conform with the requirements of NUREG-0654, Appendix 4.
i Establish provisions for stockpiling thyroid blocking drugs for distribution to onsite i
emergency workers.
N.
Exercises and Drills The frequency for tests of communication links with States and Federal response i
organizations within the ingestion EPZ.
should be changed to at least quarterly l !
l e.
Satisfactory response to the emergency planning deficiencies listed below is also required.
These deficiencies were identified in a letter dated September 9, 1980, from Robert Reid of the NRC staff, to the Licensee.
The Licensee has provided the staff with draft responses to these deficiencies which are generally acceptable. The staff is awaiting the final response to these items prior to determining their acceptability.
PLANNING STANDARD REQUIRED CORRECTIVE ACTION I.
Accident Assessment Provide expanda cmergency Action Levels which will be used to declare each of the four emergency classifications, including those applicable example initiating conditions in Appendix 1 to NUREG-0654 and postulated accidents of the FSAR.
E.
Notification Methods and Describe in the Plan, contingency plans or Procedures procedures to notify the counties within the plume EPZ if PEMA fails to contact them within 15 minutes of declaration of an Alert, Site Emergency, or General Emergency.
B.
Onsite Emergency Identify by title or position, personnel Organizations manning the Licensee's onsite and offsite emergency organizations.
O.
Radiological Emergency Describe periodic training of chemistry Response Training personnel, including sample measurements.
Additional changes to the TMI-1 Emergency Plan may be required as a result of the TMI-1 Restart hearings currently in progress, or as necessary to address the final criteria and implementation schedules for emergency centers and their functions which will be detailed in the forthcomming NUREG-0696, "Func-tional Criteria For Emergency Response Facilities, Revision 1."
f After receiving the findings and determinations of the Federal Emergency Management Agency on State and local emergency response plans, a supplement to this report will provide the staff's overall conclusions on the status of l
emergency preparedness for the Three Mile Island, Unit 1 Nuclear Station.
l Additionally, the THI-1 Restart Order requires that satisfactory emergency l
preparedness be demonstrated in a joint exercise of Licensee, State, and local l
emergency plans prior to restart and prior to final approval of the Licensee's emergency preparedness.
The final NRC approval of the state of emergency preparedness for the TNI-1 site will be made following implementation of the emergency plans to include development of procedures, training and qualifying of personnel, and satisfactory completion of the joint exercise.
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