ML19354C315

Forwards TVA Radiological Emergency Plan & Tn multi- Jurisdictional Radiological Emergency Response Plan.Three Cross Refs Encl

ML19354C315
Person / Time
Site:	Sequoyah
Issue date:	06/19/1980
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML19318B442	List: ML19354C315
References
NUDOCS 8006260164
Download: ML19354C315 (60)

Text

400 Chestnut Street Tower II June 19, 1980 Mr. H. R. Denton, Director Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

Dear Mr. Denton:

In the Matter of the Application of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 On May 30, 1980, a meeting was held between TVA and members of the NRC Emergency Planning Branch to discuss the newly revised Radio-logical Emergency Plan for Sequoyah Nuclear Plant. Based on the discussions during that meeting and written comments received from the NRC, TVA is providing additional information for your review. Enclosed are five copies of each of the following:

1. A revised Radiological Emergency Plan (TVA-REP)

2. A revised cross reference between the TVA-REP and NUREG-0654

3. A cross reference between the TVA-REP and the TVA Implementing Procedures Document

4. A copy of the Tennessee Radiological Emergency Response Plan (TRERP) for Sequoyah Nuclear Power Facility

5. A cross reference between the TRERP and NUREG-0654 A copy of each of the above information was given to John Sears on i June 10, 1980. ,

1 Very truly yours, TENNESSEE VALLEY AUTHORITY

. b/ hk L. M. Mills, Manager I Nuclear Regulation and Safety

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Enclosures THis DOCUMENT CONTAINS POOR QUAUTY PAGES 8006260l[l

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SEQUOYAH NUCLEAR PLANT EMERGENCY PLU.NING NUREG-0654 II. Planning Objectives and Evaluation Criteria A. Assir.nment of Responsibility (Orcanization Control)

ACCEPTANCE CRITERIA A.I.a&b NRC COSDIENTS The plan must identify by title the local authorities responsibic for inplementation of protective actions within the plume EPZ and provide a map showing jurisdictional boundaries. The plan must identify all the state level agencies with emergency roles. Des-cribe the concept of your operations and its relationship to the total cffort. Illustrate these interrelationships in a block diagram.

TVA ANSWER See State cross reference.

A.I.e NRC COSCIENTS Specify for each organization with authority and responsibility to implement protective actions within the plume EPZ (A.l.a), the title of the individual who can be direct 1;, cantacted 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day and who has the authority and responsibility to implement the protective actions recommended by the plant in response to a

" general" emergency.

TVA ANSUER See State cross reference.

A.2.a NRC COSDIENTS Specify the functions and responsibilities for major elements (include state and local agencies) and. hey individuals by title

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s; of emergency response to the functional areas listed in this criteria. The' description of these functions shall include a cicar and concisc summary such as a tabic of primary and support-responsibilitics using the agency as one axis, and the functions as-the other.

'TVA ANSWER See State cross reference.

A.3 Provide updated written agreements with the support organizations having an emergency response role within the Emergency Planning Zones. Include agreements with the Bradicy, Hamilton, and Sequatchie County Offices of Emergency Preparedness, City of Chattanooga, City of Daisy, Tennessco Highway Patrol, Tennessee Office of Disaster Services, and the U.S. Department of Energy Regional Coordinating Office. All agreements should be current (i.e., within the last two years). Drey should identify the emergency measures to be provided and the mutually acceptable criteria for their implemen-tation, and specify the arrangements for exchange of information.

TVA ANSWER See State cross reference.

B. Onsite Energency Organization B.1 NRC COMMENTS For emergency situations, specific assignments shall be made for

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all shifts and for plant staff members, both onsite and away from the site. .These assignments shall cover the emergency functions in NUREG-0654, Table B-1 entitled " Minimum Staffing Requirements for-Nuclear Power Plant Emergencies." The minimum capabilitics and staffing on-shift and available within one-half hour following the declaration of the emergency class shall be as indicated in the aforementioned tabic.

TVA ANSWER iSec Appendix E, 2.0. j i

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-n B.4 NRC COMMENTS

~ Identify ~the. functional responsibilities assigned to the Emergency Loordinator and specify which responsibilities may net be delegated to other elements of the emergency organization. Among the respon-sibilitics which may not be delegated is the decision to notify and make recommendations to the authoritics responsibic for offsite emergency measures.

TVA ANSWER The functional-responsibilitics of the Site Emergency Director are outlined in TVA-REP, Appendix E, Section 2.1.2. None of the respon-sibilitics outlined may be delegated although some activitics are carried out by others as directed by the Site Emergency Director.

B.5 NRC' COMMENTS Refer to Comments in B.I.

The qualifications of emergency personnel cust be described. This can be accomplished by-identifying their normal assignments and the cmergency tasks (that are not a part of their normal assignments) for which they will be trained and qualified (tested).

TVA ANSWER The_ qualifications of key emergency personnel are equal to or better than that specified in ANSI 18.1-1971, " Standard for Selection and Training of Personnel for Nuclear Power Plants." Further details on-specific qualifications are found in Sequoyah Nuclear Plant, FSAR, Section 13.1.3.1. In addition,-TVA provides caergency training for all TVA' emergency response personnel. This training is discussed in TVA-REP, Section 8.1.

B.6 NRC COMMENTS Identify.and. define by means of a block diagram the interfaces between and among the onsite functional areas of emergency activity, licensee headquarters support, local services support,-and state and local government response organizations. The'above shall include the onsite technical support-center, the operational support center, and the near-site emergency operation facility. This shall be illustrated in a block diagram.

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,TVA ANSWER See Figure 2, Appendix A.

These functional interfaces are summarized in Section 3.1, TVA-REP,

, and are explained in detail in Sections 4.2, 4.3, and 4.4, TVA-REP,

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and in the appendix for each emergency operations center.

B.7-NRC COMMENTS Describe the framework for long-term augmentation of your emergency organization. The Recovery Organization recommended by the Atomic Industrial Forum in their document " Nuclear Power Plant Emergency Response Plan" dated October 11, 1979, would provide an acceptable framework.

TVA ANSWER See Section 9.0.

B.9 NRC COMMENTS

~ Specify tlic contractor and private organizations who may be requested to provide' technical assistance to and augmentation of the emergency organization.

TVA ANSWER See Appendix E, 3.8.

B.10 NRC COMMENTS Written agreements should be appended to the plan. The agreements

.shall delineate the authorities, responsibilitics, and limits on the actions of the' contractor, private organizations, and local services _ support groups.

TVA ANSWER See Attachment.1, Appendix E.

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.C. Emergency Response Support and Resources C.2 NRC COMMENTS Provide for the . dispatch of a representative to principal of fsite governmental emergency operations centers. These representatives

.must be dispatched for " site" and " general" emergencies. Plan must identify the position title of the station representative to be dispatched to the state and local EOC, criteria for their dispatch, and specify their expected response times.

TVA ANSWER Sec 6.1.2 D. Emergency Classification Systems D.1 & D.2 .

NRC COMMENTS The emergency classification scheme identified in Sections 5 and 6 of the plan must be revised to reficct that identified in NUREG-0610. The initiating conditions for each caergency class shall include the example conditions listed in.NUREG-0610 and all postu-lated accidents in the Final Safety Analysis Report as appropriate to this site. The Emergency Action Levels should be explicit in terms of parameter values, setpoint levels, duration of reading, equipment status indicators, etc.

The immediate actions to be taken by the licensee upon declaration of an emergency must include the " licensee actions" indicated in NilREG-0610 for.cach' emergency class.

The projected dose' rates should be based on such parameters as containment radiation level and pressure, independent of an actual release to the environs.

The assumption used in development of EAL's must be described to 4 include ~the' amount of iodine to be assumed (be realistic).

' 'It must be clearly stated in the plan that the offsite authorities

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responsibic for implementation of offsite protective measures have r reviewed and have concurred in the EAL's.

-TVA' ANSWER (1st paragraph) - See Appendix E, 9.0.

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(2nd paragraph) - See 6.1, 5.1, 11.0.

j (3rd paragraph) - See 5.4.

[ (4th paragraph) - See 5.4.

(5th paragraph) - State and locals have concurred in the emergency measures.

E. Notification Methods and Procedures E.1 NRC COMMENTS Confirm the existence of a message authentication scheme uhen notifying offsite authorities of an emergency.

TVA ANSWER See State cross reference.

E.2 NRC COMMENTS Provide established procedures for notifying, alerting, and mobilizing emergency response personnel.

TVA ANSWER t

See 11.0 E.3 & E.4 NRC COMMENTS Provide a standard format for the initial and follow-up emergency messages which will be used when contacting offsite authorities.

.The message content should be based on the information requirements specified in these two sections of NUREC-0654.

TVA ANSWER See 6.1.2; 6.1.2.1.

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NRC COMMEt.TS

' Describe.a'dministrative and physical means and the time required for notifying and providing prompt instructions to the public within the plume exposure pathway EPS. " Prompt" as used in NUREG-0610 is defined as 15 minutes. It is the operator's responsibility to ensure that such means exist, regardless of who impicments this requirement. The total public alerting system must be described in the plan in complete detail.

TVA ANSWER TVA is currently evaluating various alternatives.to ensure that the capability exists for notifying and expeditiously providing instructions to the public. Details will be provided in the TVA-REP when this evaluation has been completed.

E.7 NRC COMMENTS The initial protective measure recommended may be prearranged to be sheltering throughout the plume EPZ with continued monitoring of TV or radio provided further instructions (within 30 minutes) are forthcoming indicating more detail protective measures. The concept of awaiting actual offsite measurements before impicmenting protec-tive measures is unacceptable. If the public notification system is'to be administered by state or local officials it must still be described in the plan.

TVA ANSWER

.See 11.0.

F. -Emergency Communications F.1 NRC COMMENTS Expand the discussion of your communicatiens systems to include the criteria specified in the section of NUREG-0654. Assure that your communications are consistent with the concept'of operations des-cribed in Appendix 5 of NUREG-0654 covering the onsite' technical

. support center,jthe operational support center, and the near-site

.- emergency operations facility.

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The communications system must be revised to identify the TSC as the~ primary communications interface with the Control Room. The

. titles of the contacts at both ends of offsite communication links must be identified in the plan.

TVA ANSWER i

4 It is not understood what is meant by "the TSC as the primary com-

! munications interface with the Control Room." Figure 4 shows that

- communications exist between the TSC and Control Room, TSC and TVA corporate EOC, and the Control Room and TVA corporate EOC.

The titles of the contacts at both ends of offsite co=munications links are identified in TVA-REP, Appendix E, Section 2.6.2; Appendix E, Section 2.1.2; Appendix B, Section 3.1.1; Appendix D, Section 3.2.1.2; and ^.ppendix C, Section 3.1.

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4 NRC COMMENTS The plan must commit to conduct tests of the entire alerting system

, to-include the system used to alert the public. Specify the test

period.

4 TVA ANSWER j 'Sec 7.2.1-and the answer to E6..

1 G. Public Information G.1 -

NRC COMMENTS Describe the means to be employed for periodic dissemination of.  ;

_ information to the public regarding how they will be notified and  ;

' I what'their actions should be.in an emergency.

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If the public~information program is to be administered by local ,

officials it must still'be described in the plan. j 1

TVA ANSWER 4.

I- .oec 10.0.

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a G.3/ A & B NRC COMMENTS

- Identify the physical locations for use by the news media during an emergency. Note the interface with near-site emergency operations facility discussed in Section G38 and Appendix 5 of NUREG-0654.

. Designate a spokesperson who will have access to all necessary information and describe the arrangements for timely exchange of information among the designated spokespersons for each principal

-organization.

TVA ANSWER See 10.0 11 . Emergency Facilities and Equipment 11 . 2 NRC COMMENTS Each operator shall establish a principal and an alternate operators near-site EOF. In most cases, the principal operator's near-site  ;

EOF should be within one mile of the reactor. A map showing its l location must be provided along with a floor plan indicating the areas to be used by state and local officials. Provisions for backup power must be provided if required for communications or dose projections.

The alternate EOF must be located beyond the area where evacuation is most probable. The plan must describe the provision made to assure that the command / control functions are transferred without interruption if the primary EOF must be evacuated (include communi-c'ations).

TVA ANSWER Provisions have'bcen made.at_the TVA Training Center for accomodating the press. TVA's Emergency Operations Facility to be used as the emergency control center is located in downtown Chattanooga, Tennessee.

This centralized EOF allows for more rapid response than a near-site EOF and eliminates the need for an alternate EOF. ~ Details of TVA's central EOF and. corresponding activities and communications are des-

.cribed in the TVA-REP.

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H.4 NHC COMMENTS Identify the staffing and time required to activate the near-site EOF, the'TSC and t..a onsite operational support center.

TVA ANSWER Staffiag and activation times of the CECC, DNPEC, Technical Support Center, and Operations Support Center are addressed in TVA-REP, Appendix A,.Section 3.1; Appendix B, Section 3.1; Appendix E, Section 2.17; and Appendix E, Section 2.18, respectively.

H.9 NRC COMMENTS Describe your provisions for onsite operations' support cent r (assembly area) which shall have adequate capacity, shielding, ventilation, and inventory of supplies, including for example, respiratory protection, protective clothing, portable lighting, and

, communications equipment.

TVA ANSWER See Appendix E, 3.11.

H.10 NRC COMMENTS Plan should indicate that there are sufficient reserves of instru-ment /cquipment to replace those which are removed from emergency kite for calibration or repair. Calibration of equipment shall be at intervals recommended by the supplier of the equipment.

TVA ANSWER -

See Appendix E, 3.5, and Attachment 2.

H.ll-NRC COMMENTS

- An ' appendix to the plan shall provide an inventory of emergency kits by general category (protective equipment,' communications t equipment,Jradiological monitoring equipment and emergency supplies).

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I.3 NRC COSDIENTS - ,

The source term requirement should be met by containment radiation monitor readings for the following accident conditions:

a. release of coolant activity

b. . release of gap activity

c. fuel melt Describe in the plan the assumptions used in meeting this require-ment to include containment leak rate and meteorological conditions.

TVA ANSWER See S.4.

I.4 & I.6 NRC COSBIENTS The methodology to be used to project offsite doses including

. iodine using realistic meteorolc ical data must be described in the plan in sufficient detail to assure adequacy. This must include che equations, graphs, etc., used to relate doses to plant parameters

- using realistic meteorological, data and release location. Job aids used to. perform these calculations such as fill-in-blank forms could be supplied to meet.this requirement. It must be demonstrated that offsite dose projections and related recommended actions can Ebc determined to allow for recommendations of fsite within 30 minutes.

This must include the methods to:

a. Determine meteorological parameters

.windspeed

. wind direction

. atmospheric stability

.what will be used if instruments are inoperable

'b. Estimate dose , based on effluent monitors

c. Estimate doses based on field monitoring data

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d. Estimate doses based on containment monitor reading and Icak rate data

c. Estimate doses when effluent monitors are offscale or inoperabic (1.6)

r TVA A*;SWER See Appendix E, Attachment 2.

11. 1 2 NRC COM.4ENTS Establish a central point (preferably associated with the operator's near-site Emergency Operations Facility), for the receipt and analysis of all field monitoring data from both state and the licensee's monitorit.g efforts. The provisions to feed back moni-toring results as they affect plant operations and protective action determinations must be described.

TVA ANSWER See 3.1.2.3 and Appendix D, 1.0. See also State cross reference.

1. Accident Assessment I.1 NRC COMMENTS Refer to D.1 and D.2 TVA ANSWER See Appendix E, 9.0.

1.2 NRC COMMENTS Describe how the NUREG-0578 requirements will be incorporated into the emergency conditions.

TVA ANSWER TVA's capability for post-accident sampling, radiation and effluent monitors, inplant iodine instrumentation, and containment radiation monitors, is addressed in formal responses to SRC on NUREG-0578.

Whenever committed-to capabilities are provided, appropriate revisions will be made to the caergency plan.

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sr TVA ANSWER-see 5.4 and111.0.

1.5 NRC COMMENTS The provision to access meteorological information in the EOF, TSC, and Control Room must be described.

TVA ANSWER See Appendix E, 3.3.

J. Protective Response J.1

'NRC COMMENTS Specify-the tLne required to warn or advise onsite individuals not having emergency assignments who may be within the site boundary at.

the' time'of an accident.

TVA ANSWER See Appendix E, 4.0. .

J.2 NRC COMMENTS Identify the evacuation routes and transportation for onsite. individuals to some suitable offsite location, including alternatives for inclement weather, high traffic density, and specific radiological

. conditions. -The plan must describe how evacuees will'be informed-to.reassembic if-further monitoring or decontamination is required.

TVA' ANSWER See Appendix'E, 4.0.

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e J.4' 1 NRC COM'fENTS The plan must describe provisions for extra clothing and individual decontamination,with particular attention given to Iodine skin contamination. -Specify the instruments used to monitor evacuces and instrument readings requiring action.

TVA ANSWER See Appendix'E, 4.0.

J.5 NRC' COMMENTS Describe your capability to account for all individuals onsite at the time of an cmergency and the names of missing individuals within~30 minutes of the start of an emergency.

TVA ANSWER See Appendix E, 4.0, and 6.4.1.

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' NRC CO>DIESTS Describe the provisions for the use of radio-protective drugs (e.g., individual thyroid protection) for onsite personnel.

TVA ANSWER

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Sec 11.0 and Appendix E, 7. 0. - -

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. NRC CO> DENTS The plan must indicate that a specific individual (B.2) shall, if a

" general" emergency is declared, directly notify.the offsite officials responsibic for protective action implementation within the plume EPZ. The' plan-must specify that this notification will'be accom-plished with.15 minutes. The plan must describe how the recommended

. protective actions will be determined'in a timely manner-based on factors such as:

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a. . plant status

b. local protective factors for typical residential units (J.15.m)

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c. weather conditions

d. evacuation times

c. release potential

f. projected or potential doses The plan must commit that the provisions for recommended protective actions ~will be reviewed biannually by the implementing authorities.

This review must be documented.

TVA ANSWER Sec 6.1.2.4; Appendix E, 2.1.2; and 6.4.2.

J.8 NRC COBE4ENTS Include'as an appendix to your plan the time estimates for evacuation within the plume exposure EPZ. Discuss how this information is used to determine protective actions reco= mended offsite.

TVA ANSWER See State cross reference.

J.10 a,b,c.

NRC COMMENTS Provide the following as part of-your planning interface with offsite authorities for the' implementation of protective measures with respect to the plume exposure pathway:

a. > bps showing evacuation routes, sectors, relocation centers in host areas, shelter areas, hospitals, and other medical facilities

b. Population distribution-around the' nuclear facility using the format specified in Table J-1 of NUREG-0654

c. -Means of notifying all segments of the transient'and resident

. population within the plume exposure EPZ -

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r TVA ANSWER See State cross reference.

K. Radiological Exposure Control K.1 NRC COMMENTS Specify the specific exposure guidelines (do not reference a pro-cedure).

TVA ANSWER See Appendix E, 7.0.

K.2 NRC COMMENTS Describe your radiation protection program to be implemented during emergencies including the individuals, by pcsition or title, who can authorize emergency workers to receive doses in excess of 10 CFR Part 20 limits. Your description should confirm the existence of predetermined procedures for permitting onsite volunteers to roccive radiation exposure in the course of carrying out lifesaving activities, including provisions for expeditious decision making.

TVA ANSRER See Appendix E, 7.0.

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NRC CO:IMENTS

. Describe in the plan the provisions for 24-hour dose determination and the records to be maintained for emergency workers to include offsite individuals (NRC, State Officials) who are to arrive onsite or at the EOF. Who performs these functions during an emergency?

TVA ANSWER See Appendix E, 7.0.

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.o K.5 NRC COMMENTS Specify your action Icvels for determining the need for decon-tamination and the means for decontaminating etergency personnel, supplies, instruments and equipment, and waste disposal.

TVA ANSWER See Appendix E, 7.0.

K.6 NRC COMMENTS Describe onsite contamination control measures to include area access control, drinking water and food supplies, and the criteria for permitting return of areas and items to normal use.

TVA ANSWER See Appendix E, 7.0.

K.7 NRC COMMENTS Describe your capability for decontaminating relocated onsite personnel, including provisions for extra clothing and decontami-nants suitable for the type of contanination expected.

TVA ANSWER See Appendix E, 4.0 and 7.0.

M. Recovery and Reentry Plannint,and Postaccident Operations M.1,2,3,4 NRC COMMENTS Expand your description of recovery cperations to confirm that general plans are or will be developed for recovery and reentry including the following:

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a. The means by which decisions are reached to relax both onsite and offsite protective measures.

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b. The position / title, authority, and responsibilities of individuals who will fill key positions in the facility recovery organization,

c. The means for informing members of the response organizations that a recovery operation is to be initiated, and of any changes in the organizational structure that may occur.

d. The method for periodically estimating total population exposure.

TVA ANSWER Paragraph (a), (b), and (c) - See 9.0.

Paragraph (d) - See 6.2.2.3 and 11.0.

N. Exercises and Drills N.2 NRC COMMENTS Plan must provide fcr the following drills and describe each drill and its frequency:

a. communications drill

b. fire dri.0 TVA ANSWER See 7.2 and 8.2.3.1.7.

N.3 NRC COMMENTS An objective is measurable and observable. An objective for cach major action to be accomplished must be provided. Using objectives, how will the exercise be scored? Describe arrangements for observers'and their qualifications.

TVA AUSWER See 6.2.2.3.

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. N.4 NRC COMMENTS Plan must provide qualified observers to critique the exercises and describe the provisions for a critique.

TVA ANSWER See 8.2.2.3.

O. Radiological Emergency Response Training 0.1, 0.2, 0.3, 0.4, 0.5 NRC COMMENTS Provide a detailed description of your training program for per-sonnel who will implement radiological response plans. Your des-cription shall include the specialized initial training and periodic retraining programs (including the scope, nature and frequency) for each of the nine categories of personnel listed in (0.4). As appropriate to the category, the following shall be included in the program:

a. Training for members of the onsite emergency organization shall include drills in which each individual demonstrates ability to perform the assigned function.

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b. Training for individuals expected to perform first aid shall include courses equivalent to Red Cross Multi-Media.

c. Training for hospital personnel, ambulance rescue personnel, police and fire departments shall include the procedures for notification, basic radiation protection, and their expected roles.

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d. Training for local services support personnel who may enter the site shall include site access procedures and the identity by position /titic of the individual in your organization who will control their onsite activities.

TVA ANSWER Sec 8.0 and Appendix E, 6.0.

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,P. Respons}bility for the Planning Effort: Development, Periodic Review and Distribution of Emercency Plans P.l.

NRC COMMENTS Describe the training provided for, and/or the qualification of, the personnel responsible for your c=crgency planning effort.

TVA ANSWER See Preface. ,

P.6 NRC COMMENTS Plan must include.a list of all supporting plans (state, local, federal, other).

TVA ANSWER Sec 2.1.5.

P.7-NRC COMMENTS Plan shall contain as an appendix listing, by title, procedures required to implement the plan. The listing shall include the section(s) of the plss to be implemented by each procedure.

TVA ANSWER See attached listing and 11.0, P.8 NRC COMMENTS Index of plan must cover any state and-local plans attached. If the format of NUREG-0654 is not used, provide a cross reference between your. plan and each criteria in the NUREG document.

TVA ANSWER See table of contents and attached listing.

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-NUREG 0654 TVA REP

~ Evaluation Criteria References (s)

Ala 4.3.3, 4.3.4, 4.4 Alb 3.0; App. A, 1.0; App. B, 1.0; App. C, 1.0; App. D, 1.0;' App. E, 1.0; 4.4; State Plan Alc . App. A, page 4 Ald App. A, 3.1; App. E, 2.0; 11.0 Ale' App. A, 3.2.1; App. B, 3.1, App. E, 2.0 A2a App. A, 3.0; App. B, 3.0; App. C, 3.0; App. D, 3.0; App. E, 2.0; 4.4 A2b State Plan A3 4.3.3; 4.3.4, App. E A4 App. B, 3.1.5; App. D, 3.2.6.1; App. E, 2.1.4 B1 App. E, 2.0 B2 App. E, 2.1.2 B3 App. C, 2.0; App. E, 2.1.3 B4 App. A, 1.0; App. E, 2.0 B5 App. E, 2.0; App. D, 6.2.2 B6 4.0; Figure 2, App. A; App. D, 3.2.1 B7 9.0; App. E, 5.0 B8 4.0; App. A, 3.0; App. B, 3.0; App. C, 3.0; App. D, 3.0 B9 State Plan B10 App. E, 3.6, 3.7; Attachment 1 to App. E Cla 4. 3. 4 -

C1b 4.3.4 C1c 6.2.2 C2 N/A C3 6.2.2.3 C4 4.3 D1 5.1; 6.1; 11.0 D2 App. E, 9.0' D3 State Plan El 6.0; 11.0 E2 6.0; 11.0 E3 6.1.2; 11.0 E4 - 6.1.2.2; App. A, 3.2.1; App. D, 3.2.1.2 E5 State Plan E6 State Plan E7 6.2.2; State Plan F1 7.2; App. A, 4.1; App. B, 3.1.1, 4.1; App. C, 2.2, 3.1; App. D, 4.1.1, 3.2.1.2; App. E, 3.9, 2.6.2, 2.1.2 F2 7.2; 11.0 G1 10.0 G2 10.0 G3a 10.0 G3b 10.0 C4 10.0 G5 10.0 HI 3.1.1; App. E,.2.3. 3.9.3.5, 3.9.3.6 11 2 N/A H3 State Plan 11 4 _6.1;' App. A, 3.1; App. B, 3.1; App. E, 2.17; App. E, 2.18 11 5 7.3.1

NUREC 0654 WA REP Evaluation Criteria Reference (s) 11 6 ' 7.3 117 Under Consideration H8 Under Consideration 11 9 App. E, 3.9.3.6 111 0 8.4 Illi 11.0 H12 3.1.2.3; App. D, 1.0 Il- 5.2; App. E 12 Addressed in TVA's response to NUREG-0578 13 5.3; 5.4 14 6.2.2; 5.4; 11.0 15 7.3.1.1 16 5.3; 5.4; 5.5 17 6.2.2.1 18 6.2.2.1 19 6.2.2.1 110 6.2.2.3 J1 6.4.1 J2 6.4.1; App. E, 4.0 J3 6.4.1; App. E, 4.0 J4 6.4.1; App. E, 4.0 J5 6.4.1; App. E, 4.0 J6 6.4.1; App. E, 5.0 J7 6.4.1 J8 State Plan J9 State Plan J10 State Plan J10(m) 6.4.2

'J11 State Plan K1 6.4.1; 11.0 K2 App. E, 7.0; 11.0 K3 App. E, 7.0; 11.0 K4 State Plan K5 App. E, 7.0 K6 , 11.0 K7' 11.0 K8 State Plan

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e NUREG 0654 TVA REP Evaluation, Criteria Reference (s)

N3 8.2.2.2 N4 8.2.2.3 N5 8.2.2.3 01 8.1.1; App. E, 6.0 02 8.0; App. E, 6.0 03 8.1.1 04 8.1.1 05 8.1.1 P1 8.1.1 P2 Preface P3 Preface P4 8.3 P5 8.3.3 P6 2.1.3 P7 Table of Contents P8 Table of Contents P9 8.5

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II. Plantiing Objectives and t voluotion Criteria A. Ic.signment of Responsibility (Organization Control)

Planning Objective fo assure that primary responsibilities f or emergency response in nuclear facility operator, State and local orijasiizations within the Emergency Planning Zones have been assigned, that the emergency responsi-bilities of the various supporting organizations have been specifically established, and that each principal response organization is staf fed to respond and to augment its initi., response on a continuous basis.

Applicability and Cross Evaluation Criteria Reference to Plans Operator State Local Annex B, Direction & Control 1.a. Each plan shall ideritify the State, III3. State Depts., Bureaus, Diva.,

local, Federal and private sector organiza- A6encies & Private org. pp.40-42 tions (including utilities), that are Basic Plan (pp.10-16) intended to be part of the overall response organizat ion for Emergency Planning Zones. X X X pp.360-372 Annex B, III3, Appendix 4, Taba A-J,

b. Each organization asid suborganization Para. II in each. Appendices 5,6,7 havinij on operational ro'e shall specify pp. 48-68 its concept of operat toris. and its relation-ship to the total effort. X X X Appendix 1 thru 7, Annex 3

c. Each plan shall illustrate these pp. 66-68 interrelationships in a block diagram. X X X IIIC. pp. 41-42

d. Each organization shal' identify Part II, App. 1, Tab .- Pua. 2 a specific individual by *itle who shall p. 354 be in charge of the eeriergt" icy response. X X X IIIC; I.D.; I.E. & Annex G

e. Each organization Jia urovide pp. 41-42; 38-39; 173-177 f or 24-hour per day easierJeris.y response, including 24-hour per day siiarin'ng of communicat ions 1 ink s. X X X I

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A. Assignment of Responsibility (Organization Control) (continued)

Applicability and Cross Evaluation Criteria Reference to Plans Operator State Local 2.a. Each organization shall specify the Functions: App. 4, Taba A- J, f unctions, and responsibilities for major Para. I in each. pp. 48-65 elements and key individuals by title, of emer- Key Individuals: III C pp. 41-42 gency response including the following: Command Annex B, App. 3, Tab A pp. C-46 and Control, Warning, Notifit ation Consnuni-Cations, Public Information, Accident Assess- Sm:7 Table of Primry/ Support:

ment, Public Health and Sanitation, Social App. 3, Tab A. pp. 45-46 Services, Fire and Rescue, Traf fic Control, Emergency Medical Services, Law Enforcement, PartII, App.I,TabG(Local)

Transportation, Protective Response (i ncluding Incl. 1 & 2 pp. 373-374 duthority to request Federal as ,istance and Part II, App. II, Tab G to in : tate other protective actions), and pp. 452-456 Radiological Exposure Control. The descrip-tion of these functions shall include a clear and Concise summary such as a table of primary and support responsibilities using the agency as one axis, and the function as the other. X X X

b. Each plan shall describe the legal Pacic Plan Parn. II p. 5 PartII,4g1) p. 219 basis for such authorities. X_ _ _

3. Covered in Eacic PLin; Each plan shall include written agree- Hot repeated in Annex 3.

ments referring to appropriate legal instru- pp. 22-26; 1P3A-193 ments such as legislation, among Federal, State, ard local agencies and other support organizations having an emergency response

., role within the Emergency Planning Zones.

The agreements shall identify the emergency measures to be provided and the mutually acceptable Criteria for their inplementa-tion, and specify the arrangements for exchange of information. X __

X X ,

Annex B

4. Each emergency organization shall be III C. pp. 41-42 capable of continuous (24-hour) operations for a protracted period. The individual in the emergency organization who will be responsible for assuring continuity of resources (technical, administrative, and material) shall be specified by title. X X X

C. Emergency Response Support and Resources Planning Objective To assure that arrangements for requesting and ef fectively using assistance resources have been made, that arrangements for State and local staf fing of the operators near-site Emergency Operations Facility have been made, and that other organizations capable of augmenting the planned response have been identified.

Applicability and Cross Evaluation Criteria Reference to Plans Operator State Local

1. Each State and operator shall make arrangements for support with the U.S.

Department of Energy (DOE) Regional Coordi-nating Of fice responsible for inplementing the DOE Radiological Assistance Plan (RAP) and the Interagency Radiological Assistance Plan (IRAP) as follows:

a. speCify persons Juthorized to request R AP/lRAP assistance; X X

b. mdke arrangemt*nts for using RAP /IRAP resources (teams and equipment); and X X Annex F, App. 9, p.153

. c. identify tne available RAP /lRAP resources relied upon. X X

III B; App. 5, 6, & 7

2. Each principal organization shall plan p. 40, 67 pp. 153-155 to dispatch representatives to the operators

_ near-site Emergency Operations Facility.

The operator shall provide for the dispatch of a representative to principal off site governmental emergency operations centers. X X X l

C. Emergency Response Support and Resources (continued)

Applicability and Cross

Reference to Plans J

Evaluation Criteria Operator _ State Local Annex F, App. 2, Tab A & App.11, Each organization shall identify radio- pp. 141, 158 3.

logical laboratories and their capabilities and expected response tines whicn can be X X used in an emargency. p. 153, 156, l Annez F, App. 9 & 10 j 157

4. Each organization shall identify nuclear j

and other f acilities, organizations or individuals which can be relied upon in an X X X

i energency to provide assistance.

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D. Energency Classification System -

Planning Objective To assure that a standard emergency classification and action level scheme is in use by the nuclear f acility operator, including f acility system and ef fluent parameters; and to assure that State and local response organizations, will rely on information provided by facility operators for determinations of initial of f-site response measures.

Applicaoility and Cross Evaluation Criteria Reference to Plans Operator State Local

1. An emergency classification and emergency action level scheme as set forth in NUREG-0610 must be established by the f acility operator.

(See Appendix 1.) The specific instruments, parameters or equipment status shall be shown for establishing each emergency class, both in the in-plant emergency procedures and in the plan itself. X ,

2. The initiating conos tions shall include the example conditions found in NUREG-0610 and all postulated accidents in the Final Safety Analysis Report (FSAR). X Part I pp. 210-213

3. Each State and local organization shall establish an emergency classification and emergency action level scheme consistent with that established by the f acility operator. X X

s L. Notification Methods and Procedures Planning Objective To assure that procedures have been established for notification, by the facility, of State and local response organizations and for notification of emergency personnel by all response organizations; to assure that the content of initial and followup messages to response organizations and the public have been established; and to assure that means to provide early Wdrning and Clear Instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established.

Applicability and Cross Evalisation Criteria Reference to Plans Operator State Local

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1. Each organization shall establish proced-ures which describe notually agreeable basis for notification of response organizations con-sistent with the emergency classification and action level scheme set forth in NUREG-0610.

These procedures shall include means for verification of ness ages. X X X Part I, Tub A, 3, & C pp. 210-218

2. Each organization shall estabitsh proced- Annex C, App. 5, Tab A, 3, C ures for notifying, alerting, and mobilizing p emergency response 'personen:1 I_p. 69-79 X X

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E. Notification Methods and Procedures (continued)

Applicability and Cross Reference to Plans Evaluation Criteria Operator _ State Local

1. projected dose rates and integrated dose at about 2, 5 and 10 miles, including X _

sector (s) affected;

j. estimate of any surf ace radioactive X contamination; X

k. emergency response actions underway;

1. reconenended emergency actions, including X protective measures;

m. request f or any needed onsite support by X offsite organizations; n, prognosis f or worsening or termination X of event based on plant information. _

Annex B hra. III 3.; pp. 39_45 State and local government organizations Anner D, Annex G S.

pp.80-116, pp.173-187 shall establish a system f or disseminating the inf ormation contained in initial and X _

X _

followup messages received from the operators.

Anne: D; hrt II, App. 1' o Eacn organization shall establish admin- pp.80-116, 300, 280-283 0.

istrative and physical means, and the time required f or notifying and providing prompt instructions to the public within the plume exposure pathway Emergency Planning Zone.

(See Appendi x 3.) It snall be the operator's responsibility to ensure that such means exist, regardless of wno implements this requirement. It shall De the responsibility of the State and local governments to actt- X X X vate such a system. '

Each organization shall provide written p 7_ j pp 7g )

7. pp. 305-312 '04 messages intended for the public, consis-tent with the operator's classification scheme. In particular, messages to the ,

public giving instructions with regard to specific protective actions to be taken by occupants of affected areas snall be prepared and. included as part of the state and locai l

plans. Such uessages 3nould include tne appropriate aspects of sheltering, thyroid X X blocking or evacuation. .

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F. Emergency Communications _

Planning _ Objective lo assure that provisions exist for prompt communications among principal response organizations, to emergency personnel and to the public.

Applicability and Cross Refereate to Plans Evaluation Criteria Operator State Local Annex G

1. The conmunication plans for emergencies shall include organizational titles and alternates f or both ends of the ConMJniCation l i nk s. Each organizatior shall establish reitable primary and backup means of conmunica-tion for operators, local and State response organizations. Such systems should be selected to be compatible with one another. Each plan shall include:

a. provision f or 24-hour per day notification III. A.1. & Chart 1 A to and activation of the State / local emer- p.174,178,184 gency response network including 24-hour X X X

, per day manning of conounication link; Annex G

b. ' provision f or conamnications w th III. A. 2. & Charts 13 & 3 contiquous State /loca.1 governments p. 174,179,131 X X within the Emergency Planning Zones; _X__

Annex G III. A. 4. & Chart 4. p.173,182

c. provision for connunications with X X X Federal emergency response orgnizations; _,

Annex G

d. provision for communications between III. A.1. & Charts 1 A & 6.

the nuclear facility and the operators p. 174,178,104 near-site Emergency Operations Facility, State and local emergency operations X X X

centers, and field assessment teams; Annex G  ;

e. provision for alerting or activating III. A. 2. & Charts 1 A & 2 '

emergency personnel in each response p, 174,170,130 X X X

organization; and i

f. provision f or coniunication by the operator with NRC headquarters and NRC Regional Of fice Emergency Operation Centers and the operators near-site Emergency Operations Facility and radiological monitori.ng team assembly X area. \

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F. Emergency Conununicat ionis (continued )

Applicability and Cross Reference to Plans Eva ltiat ion Criteria Operator State Local

- PP.176-177

2. Each organizatiori shall conduct periodic X X X testing of the connunications system.

G. Public Informatton Planning Objective To assure that accurate and timely information is provided to the public on how they will be notified and what their initial actions should be; to assure that the principal points of contact with the news medi a for di s-semination of information (including physical location or locations) are established in advance; and to establish procedures for coordinated dissemination of information to the public.

Applicability and Cross Evaluatiun Criteria Referer.ce to Plans Operator State Local Annex D

1. Each organization shall provide for periodic dissemination of information to the public re-garding how they will be notified and what their actions should be in an emergency. This infor-mation shall include, but not necessarily be limi ted to: X X X Annex D.

a. educational information on radiation III 3 - p. 80,201-3c5-312

b. contact for additional information III,3.2 p. 80_a1

c. respiratory protection III.B.3 p. G1,300 p. 305-312

d. shel teri ng III.B.4 p. 81,310

e. evacuation routes III.3 5 p. 81,310 Means for accomplishing this dissemination Annex D pp.80-116 may include, but are not necessarily limited Part II pp. 305-312, to: infornation in the telephone book; periodic p. 407 information in utility bills; posting in public areas; and publications distributed on an annual basis.

2. The public information program describing Annex D this system is acceptable i f the permanent and Part II, App. 1, Tab 3, Para. I2, transient adult population within about 10 p. 280 miles of the site is provided an adequate Annex G, III. A. & Chart 4, 5 opportunity to become aware of this informa- p.173,182,103,302,406 tion annually. The program should include provision for written material that is likely to be available in a residence during an emergency. X X X

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G. Public Information (continued)

Applicability and Cross Evaluation Criteria Reference to Plans Operator State Local 3.4. Annex D - p. 83 Each organization shall designate the principal points of contact and physical locations for use by news media during an ene rgency . X X X

b. Each operator shall provide space for the news media at the nearsite Energency Operations facility. X 4.a.Lach principal organization shall desig- nneX - P. 62-83 nate a spokesperson who should have access to all necessary infornution. _X X X Annex D - p. 83

b. Each organization shall establish arrange-ments for timely exchange of information among designated spokesoersons. x x x

5. Each organization shall conduct programs Annex D at least annually to acquaint news media with V. C - p. 85,201 the emergency plans, inf ormation concernir.g radiation, and points of contact for release of public information in an emergency. X X X 4

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H. Emergency Facilities and Equipment Planning Objective To assure that adequate emergency facilities and equipment to support the emergency response are provided.

Applicability and Cross Evaluation Criteria ___ Reference to Plans Operator State Local

1. Each operator shall establish a technical support center and an onsite operational support center (assembly area) .e m.ccrdance witn NURE6-0578 and in the NRC let'.7r to all power reactor licensees dated October 30, 1979. X _

2. Each operator shall establish a principal and an alternate operators nearsite Emergency Operations Facility from which evaluation and coordination of all licensee activities related to an emergency is to be carried out and from which the licensee shall provide information to Federal, State and local authorities responding to radiolocal emergencies. In most cases, the principal operators nearsite Emergency Operations Facility should De within one' mile of the reactor. This f acility shall have suf-ficient space to accommodate representatives from ,

Federal, State and local governments, as appro-X priate.

Each organization shall establish an p. 33

3. Anner. 3,I.I.D. 3. &&E.C. ((State emergency operations center to carry out Local pp. 33-39 X X response functions.

Anner 3, I. B. & C. p. 38

4. Each organization shall provide for acti- I. D. & E. pp. 38-39 vating and staf fing the f acilities and centers X X

in a timely manner. X _ ,__ , _ _ , _ _ _ _

S. Each operator shall identify and E stabli sh onsite mon- '.ori ng systems that are to be used to in t' ate emergency uleasures in accordam e with NUREG-0610, as well as those to be usec *or continuing X

assessment. ___

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11 . Emergency Facilities and Equipment (continued)

Applicability and Cross Evaluation Criteria Reference to Plans Operator State Local The equipment shall include:

a. geophysical phenomena monitors, (e.g., meteorological, hydrologic, X

seismic);

b. radiological monitors, (e.g., process, area, emergency, effluent, and portable monitors and sappling equipment); X

c. process monitors, (e.g., reactor coolant system pressure and temperature, containment pressure and temperature, liquid levels, flow rates, status or lineup of equipment components); X

d. fire and combustion products detectors. X

6. Each operator. shall make provisions for offsite monitoring equipment including:

a. geophysical phenomena ironitors; X

b. radiological monitors including ratemeters -

and sampling devices. 00sinetry shall be provided and shall meet, as a minimum, the NRC Radiological Assessment Branch Technical Position for the r ovironmental Radiological Monitoring Program. X

c. laboratory f acilities, fixed or mobile. X

7. Each organizaj. ion shall provide for Annex F, App. 2, V, p. 139; of f site radiological monitoring equipment App. 6 - p. 143 .

and shall identify'ot+ ite meteorological Part II, App. 1, Tab E - p. 350 capability in the vic ilty of the nuclear App. 2, Tab E - y. 441 X 4 X

facility. _ _ _ ,

li . Emer_gency Facilities and Equipment tcontinued)

Applicability and Cross Evaluation Criteria _ , Reference to Plans Operator State Local

8. Each operator shall provide meteorological instrumentation and procedures which satisfy the criteria in Appendix 2, and provisions to obtain representative real-time meteorological inf ormation f rom other sources. X _,_

9. Each operator shall provide for an onsite Operations Support Center (assembly area) wnich snall have adequate capacity, shielding, ven-tilation and inventory of supplies, including, for exampie, respiratory protection, protec-tive clothing, portable lighting and consnuni-Cations equipment. X ,

10. Each organization shall make provisions Anne: F, App. 14 to inspect, inventory and operationally check p. 163 emergency equipment / instruments at least once each calendar quarter and af ter each use.

There.shall be sufficient reserves of instru-ments/ equipment to replace those which are removed f rom emergency kits for calibra. tion or repair. Calioration of equipment shall De at intervals reconsnended by the supplier X

of the eqtJipment. X X

11. Each plan shall, in an appendix, provide Annez F, App. 2 f or an inventory of emergency kits by general p. 132 category (protective equipment, consnunica-tions equipment, radiological monitoring equipment and emergency supplies). X X X

12. Each organization shall establish a central Anner 7, App. 2 l point (preferably associated with the operators p. 132 near-site Emergency Operations Facility),for tne receipt and analysis of all field monitor-X X ing data.

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1. Accident A_ssessment (continued) .

Applicability and Cross

- Evaluation Criteria Reference to Plans Operator State Local __

4 Each operator shall estaolish the relation-ship between ef fluent monitor readings and onsite and off site exposures and contamina-tion for various rieteorological conditions. X _ , _

5. Each operator shall have tne capability of acquiring meteorological information sufficient to meet the criteria of Appendix 2. There shall De prov1sions for access to meteorologi-Cal inf ormation by at least the nearsite Emergency Operations Center, the iechnical Support Center, the Control Room and an X

of f si te NRC center. ,,,,,

6. Each operator shall establish the methodology for determining the release rate / projected doses if the instrumentation used for assessment are of f scale or inoperable. X , , _

7. Each organization shall nave a capabi- Annex F, App.15 lity to detect and measijre radiciodine con- p. 164 centrations in air in the vicinity of the site as low as 5 x 10 E-08 uC1/cc (micro-curtes per cubic centimeter) under field conditions in any kind of weather. Inter-ference from the presence of noble gas and background radiation shalI not decrease the stated minimum. detectable activity. X X

1

1. Accident Assessment (continued)

Applicability and Cross Evaluation Criteria _ Reference to Plans Operator State Local

8. Annex F, App. 2, App. 8, App. 9 Each organization shall describe the capa- App. 10 bility and resources for field monitoring within pp. 132, 151, 153, 156 the plume exposure Emergency Planning Zone X X X

9. Part II Each organization shall provide methods, equipP 't and expertise to make rapid assess- Annex F; App.13, App. 21, App. 2 ments , the actual or potential nugnitude and pp. 132, 162, 172 locations of any radiological hazards through liquid or gaseous release pathways. This shall i nclude activatiori, notification iieans, field team composition, transportation, coirritunication, monitoring equipment and estimated deployment times. X X

10. Each organizatiori shall establish neans for Anner F, App. 21 relating the various measured parameters (e.g. . p. 172 contamination levels, water and air activity levels) to dose rates f or key isotopes and gross radl uactivi ty measurements. Provisions shall ne made for estimating integrated dose from the projected and actual cose rates' and for com-paring these estimates with the protective.

action guides. X X

e A

J. Protective Response (continued)

Applicapility and Cross Evaluation Criteria Reference to Plans ,

Operator State Local

8. Each Operator's plan shall contain time estimates for evacuation within the plume exposure EPZ. These shall ne in accordance with " Request for Evacuation Time Estimates f or Areas Nea,' Nuclear Power Plants", ( Appen-X dix 4).

9. Each State and local organization shall Part II establish a capability for implementing pro- V.A. and V.B.

tective measures based upon protective action pp. 222- 223 guides and other criteria. This shall be con- Tab C - pp. 259-276 sistent with the recommendations of EPA re-garding exposure resulting from passage of Appa. 1 pp. 277-462 radioactive airborne plumes, (EPA-520/1-75-001) and with those of HEW /FDA regarding radioactive contamination of human food and animal feeds as published in the Federal Register of Decemoer 15, X X

1978 (43 FR 58790). __

10. The organization's plans to implement protective measures f or. the plume exposure pathway shall include: Part II App. 1 & 2, Tab 3 pp. 298,39G app. 3, 4, 5 pp. 457-462

a. Maps showing evacuation routes, sectors Annex E - p.130 (see Table J-1), relocation centers in host areas, shelter areas, hospital and other X X X

• medical f acilities;

b. Population distribution around the Part II, Tab A1. p. 231 nuclear f acility. This shall ne in a X X X f ormat described in Table J-1; ,

Annex G,p. 173

c. Means for notifying all segments of Part II, . 227 the transient and resident population; X _ _ _

X Part II, App.1 & 2, 4c

d. Means for protecting those persons pp. 278-476 whose mobility may be impaired due to such X X factors as institutional confinement; __

Anner F, App.12,16

e. Provisions for the use of radio- pp.159 and 165 protective drugs, particularly for emer-gency workers, including quantities, X X

storage, and means of distribution; _

J. Protective Response (cuntinued)

ApplicaDility and Cross Reference to Plans Evale: tion Criteria Operator State Local

10. (Continued)

f. State and local organizations' plans Annex F, App.12 snould include the method by which decisions p. 159 by the State Health Department for administer-ing radioprotective drugs to the general population are made during an emergency and the predetermined conditions under which such X drugs may be used uy of f site emergency workers;y X Part II, App.1, Tab B pp. 321-325 X X

g. Means of relocation; App. 2, Tab 3 p. 413

h. Relocation centers in host areas which are at least 5 miles, ano preferably 10 miles, beyond the boundaries of the plume exposure X X emergency planning zone;

i. Projected traf fic capacities of evacua- X X tion routes under emergency conditions;

j. Control of access to evacuated areas 4 and organizational responsibilities for X X such control; Identification of and means for dealing App. 2, Tab 3 p. 398 k.

with potential impediments to use of evacua- X A tion routes, and contingency measures; Part II, App.1, Tab D pp. 321-325

1. Time estimates for evacuation of App. 2, Tab 3 n. 413-various sectors and distances based on a dynamic analysis (time-motion study under various conditions} f or the plume exposure pathway emergency planning zone. X x (See Appendix 4.)

1/ See OHEW Federal Register notice of December 15, 19 78 ( 4 J F et 5a /'3o )

entitled " Potassium lodide as a Thyroid-dlocking Agent in a Radiation Eme rgency ." Other guidance concerning the storage, stockpiling, ano unun conditions for use of this drug by the general public, is now development by the ilureau of Drugs, UHEW.

J. Protective Response (continued)

Applicability and Cross Evaluation Criteria Reference to Plans Operator State Local

m. The bases for the choice 0+ recommended Part II, Tab C - pp. 259-276 protective actions f rom the plume exposure pathway curing emergency condi tions. This j Shall include expected local protection afforded in residential units f or direct and inhalation exposure, as well as evacuation time estinutes. X X

11. Each State shall specify the protective measures to be used for the ingestion pathway. Annex F, App. 12, Tab A inc'; ding the methods for protecting the pp. 159-161 puu $ c f rom consump tion of contaminated food-s tu

• t s. This shall include criteria for de- Part III ciding whether dairy animals should be put on PP. 463-553 stored feed. The plan shall identify pro-cedures f or detecting contamination, for estimating the dose conmi tment consequences of uncontrolled ingestion, and for imposing protection procedures such as impoundment, decontami nation, processi ng, decay, product oiversion, and preservation. The plan shall include maps f or recordi ng su-vey and moni-toring data, key land use cata (e.g. f arming),

dairies, food processing plants, water sheds, water supply intake and treatment plants and reservoirs. The maps shall start at the

• f acility and include the areas which process f ood products origi.nating in *be ingestion

,pataway Emergency Planning 'un- (EPZ). X I# 4

'e rollowing reports may be considered in detennining protection af forced.

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(1) "Public Protection Strategies for Potential Nuclear Reactor Acciaents:

Sheltering Concepts w th Existing Public and Private Structures" (SANO i

7/-1725).

(2) " Examination of Of f si te Radiological Emergency Measures for Nuclear Reactor Accidents involving Core Melt" (SAND 78-0454).

(3) " Protective Action Evaluation Part II, Evacuation and Sheltering as Protective Actions Against Nuclear Accidents involving Gaseous Releases" (EPA S20/1-78-001B '

E t

K. Radiological Exposure Control (continued )

Applicability and Cross Evaluation Criteria Reference to Plans Operator State Local 3.a. Each organization shall make provision Annex F, App.12 - pp.159-161 f or 24-ho ar-per-day capability to determine the doses received by emergency personnel involved in any nuclear accident, including volunteers. Each organization shall make provisions for distribution of dosimeters, both sel f-reading and pennanent record devices. X X X

b. Each organization shall provide for pp. 352-353 pp. 443-444 maintaining dose records. X X X

4. Each State and local organization shall Annex F, App.16 - p.166 establish the decision chain for authorizing App.18 - p.168 emergency workers to incur exposures in excess of the EPA General Public Protective Action Guides (i.e., EPA PAGs for emergency workers and lifesaving acti vities). X X S.a. Each organization shall soecify action Annex F, App. 20 - p.170-171 levels for determining the need for decon-X X tamination. X

b. Each organization sh.i' establish Annex F, App. 20 - p.17C-171 the means for radiologica' 'Mcontamination of emergency personnel, suoi e,, instru-ments and equipment ,- arid 'o* waste disposal. X X X

6. Each Operator shall p eside onsite contamination control measfree including:

area access control; X a.

b. drinking water and fooc supplies; X

c. criteria for permitti,9 return of X

areas and items to normal use.

K. Radiological Exposure Control (continued)

Applicability and Cross Evaluation Criteria Reference to Plans ,

Operator State Local i

7. Each Operator shall provide the capabi-lity for decontaminating relocated onsite personnel, ' including provisions' for extra clothing and decontaminants suitable for the type of contamination expected, with

particular attention given to radiolodine contamination of the skin. X Ihrt II, App.1, Tab C - pp. 326-338

8. Each organization shall describe the 2, Tab C - pp. 414-427 i means for registering'and monitoring of 3, - pp. 457-458

evacuees at relocation centers in host 4, - pp. 459-460 1

areas. X X 5, - pp. 461-462 4

Anne:c F, App. 20 - p.170 f

i k

, e < - -- - . ,ee

L. Medical and Public Health Support Planning Objectives To assure that arrangements are indde for medical services for contaminated individuals.I .

Applicability and Cross Evaluation Criteria Reference to Plans Operator State Local 1 an A5:cecent - p. 193A

1. Each organization shall describe '"""* ' APP.1 - P.189-191 arrangements for local and backup hospital and medical services and the capability for evaluation of radiation exposure and uptake, including assurance tnat persons providing these services are adequately prepared to X X X handle contaminated individuals.

4. Each Operator shall provide for onsite X

f i rs t ai d capability.

3. Each State shall develop maps showing the physical location of all public, private Annex H, App.1 - Tab A - p.192 and military hospitals and otner emergency Tab Al- p. 193 medical services facilities within the State or contiguous States considered capable of providing medical support f or any victims of a radiological accident. Tnese emergency 4 medical services should be aole to radio-logically monitor contaminated personnel, and have f acilities and trained personnel able to care for victims of radiological accidents. X ,

4. Each organization snali describe arrange-ments f or transporting victims of radiologi- Y 4 b , % *.l 1[ T N f- p. 367 372 cal accidents to medicai support faciitties. x f a 1/ The avaiidbilit/ ~oT ~in ~1ntegrated emergency medical services system ano

~ ' ~

a public health emergency plan serving the area in which the f acility is located and, as a mintitum, equivalent to the Public Health Service Guide f or Qeveloping Health Disaster plans,1974, and to the requirements of an emergency meatcal services system as outfined in the Emergency Medical Services )ystem Ac t of 1973 ( P.L. 93-l'24) , snou o be a part of and consistent with overall State or local aisester control plans and should be compatible witn tne specific overall emergency response plan for the f acility.

i M. Recovery and Reentry Planning and Postaccident Operations Planning Objective 7

To assure that general plans for recovery and reentry are developed.

Applicability and Cross Evaluation Criteria __ Reference to Plans Operator State Local

1. Each organization shall develop general plans and procedures for recovery and describe Part I7 - pp. 554-556 the .neans by which decisions to relax protective measures are reached. This process should con-

] sider both actual and potential conditions. X X X

2. Each operator plan shall contain the position / title, authority and responsibilities of individuals who will fill key positions in Part IV - pp. 554-556 the f acili ty recovery organizat ion. This organi-zation shall include technical personnel witn responsibilities to develop, evaluate and direct recovery and reentry operat ions. The recovery organization recommended by the Atomic Industrial i

Forum's " Nuclear Power Plant Emergency Response Plan" dated October 11, 1919, is an acceptable f ramework . X

-3. 'Each operator and State plan shall specify means for informing members of the response Annex D, App. 2. Incl. 7 p. 94 organizations that a recovery operation is to Annex G, Chart 1A - p. 178 be initiated, and of any changes in the organi-zational structure that may occur. X X

4. Each plan shall establish a method for Ibrt IV, Tab A - p. 557 periodically estimating total population Annex F, App. 21 - p. 172 exposure.

X X l

N. Exercises and Orills Planning Objective 10 assure that periodic exercises are conducted to evaluate major portions of emergency response capabilities, that the results of exercises f orhi the basis for corrective action for identified deficiencies and'tnat periodic drills are conducted to develop and maintain key skills.

Applicability and Cross Evaluation Criteria Reference to Plans Operator State Local ,

A""** I l.a. An exercise is an event that tests the integrated capaoility and a major portion of V.C. '

the basic elements existing within emergency P* 'O preparedness plans and organizations. Each organization shall conduct an emergency response e sercise prior to ac eption of the Plan (and prior to issuance of an Operating License (OL))

and at least once every 12 months (plus or minus 3 months) thereaf ter to demonstrate the ef fec-ttveness of the Plan. 1/,2/,3/ X X X

~ ~ ~

f7' Each State snafl conduct'~it'iedst one exercise within eacn 12-month period. The number of exercises needed to assure adequacy l of State response c ".'904 t i ty for those States with more thail one l nuclear f acility st ie is open and under review by NRC and FEMA. Both agencies solicit pub't; connents on this point.

I 2/ NRC and FEMA urge the organizations to invite participation ny volunteers and members of the public whenever possible. i J/ The organizattoru should invite participation in exercises by Federal response organizations periodically. The requi red f requency for joint exercises with Federal responst organization is yet to be established; both NRC and FEMA solici' pubitc coninent on this question.

Ap,,.icability and Cross Evalua_ tion Criteria Reference to Plans Operator State local

b. An exercise shall include mobilization of Annex I State and local personnel and resources ade- V.C.2,3A quate to verify the capability to respGnd C.4 to an accident scenario requiring response. C.5 fhe organization shall provide for a critique pp, 20c_201 of the annual exercise by federal and State observers / evaluators. The scenario should be varied f rom year to year such that all major elenents of the plans and prepared-ness organizations are tested within a five-year period. [ach organization shall make provisions to start an exercise between 6:00 p.m. and midnight, and another between midnight and 6:00 a.m. once every si c years. X X X

2. A drill is a supervised instruction period aimed at testing, developing and maintaining

• skills in a particular operation. A drill is often a component of an exercise. A drill

<* 11 be evaluated by the drill instructor.

h organization shall conduct drills, in uddition to the annual exercise at the fre-r quencies indicated below

a. Communication Drills

.. Commuriscations with State and local governments hI within the plume exposure pathway Energency Y 3 1 - P 199 l Planning Zone shall be tested monthly. Co'm- App. 2 - p. 206-209 munications with Federal emergency response organizations and Statec within the ingestion pathway shall be tested annually. Connunica-ttons between the nuclear facility, State and

local emergency operations centers, and field assessment teams shall be tested-annually. X X X

.. N. Exercises and Drills (continued)

Applicability and Cross Evaluation Criteria '

Reference to Plans Operator State Local

b. Fire Drills Fire drills shall be conducted in accordance with the plant (nuclear f acility) technical specifications. X

c. Medical Emergency Drills A medical emergency drill involving a simulated contaminated individual which conto'os provisions for participation by the loca ' >upport services agencies (i .e. ,

ambulance and offsite medical treatment f acilit.y) shall be conducted annually. s The offsite portions of the medical drill may be performed as part of the required Annex I annua! exercise. X X7.E.2 App. 2

d. Radiologic /.1 Monitoring Drills Plant erivirons and radiological monitoring drills (onsite and offsite) shall be conducted annually. These drills shall include collec-t ion and analysis of all sample media (e.g., ~

Annex I water, grass, soil and air). X X Y.3.3 App. 2

p. 199 - pp. 206-209

e. Health Physics Drills (1) llealth Physics drills shall be

. conducted semi-annually which involve response to, and analysis of, simulated elevated airborne and 8 tquid samples and +

d' rect radiation measurements in the Annex I envi ronnent . X X Y.3.4 App. 2 p.199 - pp. 206-209 (2) Analysis of inplant liquid samples wit h actual elevalec radi ation levels shall be included in llea.th Physics drills by operators. X

'i

. . f N. Exercises and Orills (continued)

Applicability and Cross Evaluation Criteria Reference to Plans Operator State local I

3. The scenarios for use in exercises and drills shall include but not be limited to, the following:

a. The basic objective (s) of each drill Annex I and exercise. X X V.C,39 X

p. 200

b. The date(s), time period, place (s) a nd part icipat ing organizat ions. X X__y,g,3g X

p. 200

c. The simulated events. X X V ,q139 X

p. 200

d. A time schedule of real and simulated initiating events. X X V.C,3c X

p. 200

c. A narrative summary desribing the conduct of the exercises or drills to include such things as sinulated casu-alties, offsite fire department assist-ance, rescue of personnel, use of proteC-t ive clothing, deployment of radio-logical monitoring teams, and public inf ormation act ivities. X X V.C.jc X

p. 200

f. Arrangements for qualified observers. X X V.C,39 X

p. 200 4/ The NRC and FEMA are developing a series of scenarios which can be used in exercising the plans. The organizations will be able to select an exercise scenario from this list on a rotating basis.

fl . Exercises and Drills (continued)

Applicability and Cross ,

Evaluation Criteria Reference to Plans Operator State local

4. Qualified observers f rom f ederal, State or local governments will observe and. critique the required exercises. A critique shall be scheduled at the conclusion of the exercise '

2 to evaluate the ability of organizatioris to responil as called for in the plan. The criti-que shall be conducted as soon as practi-cable after tile exercise, and a formal evalua- Annex I tion should result from the critique. 5/ X .!7.C.5abe X

5. Eacti organizatiori shall establish means

! .for evaluating observer and participant comments on areas needing improvement, including emergency plan procedural changes, and for assigning responsibility for imple-menting corrective actions. Each organiza-tion shall establish management control used to ensure that corrective actions are implemented. X X V.C.7 X P.199 J

1 I

f 5/ NRC and FEMA will publish guidance for use by observers in evaluating

-exercises.

1 9

w - ,, , . -

O. Radiological Emergency Response Training Planning Objective 10 assure that radiological emergency response training is provided to those who may be called upon to assist in an enerjency.

Applicability and Cross Evaluation Criterta Reference to Plans Operator State Local

1. Each organization shall make provisions Anne: I f or the training of appropriate individuals X X _7,4, X , , _ _ ,

pp. 197-190

a. Each facility to which the plan applies shall provide site specific emergency response training for those off site energency organiza-tions who may be called upon to provide assist-ance in the event of an emergency.1/ X , , ,

b. Each offsite response organization shall participate in and receive training. Where mutual aid agreements exist between local agencies such as fire, police and ambulance /

rescue, the training shall also be offered to the other departments who are members of the App. I mutual aid district.' X _Li, X pp. 204-205

2. The training program for members of the onsite emergency organization ',nall include .

practical drills in which eacn individual demonstrates ability to perform his assigned

• emergency function. During the practical drills, on-the-spot correction of erroneous performance shall be made and a demonstra-t ion of the proper performance offered by the instructor. X T7 Training for hospital personnel, ambulance / rescue, police and fire l departments shall include the procedures for notification, basic radiation l protection, and their expected roles. For those local services support j organizations who will enter the site, training shall also include site <

access procedures and the identity (by position and title) of the

~

l individual in the onsite emergency organization who will control the organizations' support activities.

4 ._

O. Radiological Emergency Response Training (continued)

Applicability and Cross Evaluation Criteria Reference to Plans Operator State Local

3. Training for individuals assigned to operator first aid teams shall include courses equivalent to Red Cross Multi-Media. X

4. Each organization shall establish a train-ing program for instructing and qualifying personnel who will implement radiological energer.. f response ' plans. 2/ The specialized initial training and periodic retraining programs (including the scope, nature and f requency) shall be provided in the f ollow-ing categories:

a. Directors or coordinators of the Annex I response organizatiorts; X X X

b. Personnel responsible for accident

assessment; X X Y.A.3a

• p. 193

c. Radiological nioviitoring teams; X X V.A. 3a,b= p. 190

d. Police and fire fighting personnel; X

• V.A1__ X n.197

e. Repair and damage control teams (onsite); X

f. First aid and rescue personnel; X

• V.A.1. X p.197 9 Local support services personnel including Civil Defense / Emergency Service

~*

personnel;. X X V. A1,2 - pp.197-198

-h. Medical support personnel; X X V.A.1 X p. 195 Y.A.3b p. 198

1. Operator's headquarters support personnel; X S. Each organization shall provide for the initial and annual retraining of personnel V & VA - pp.196-190 with emergency response responsibilities. X X App. _;L X pp. 206-209 77If S' tate and local io'vernments lack the capability and resources to accom-

~~

plish this~ training, they may look to the Operator and 'the Federal government for assistance in this training.

• NRC and FEMA encouroge State and local governments which have these capabi-lities to continue to nclude theni in their training programs.

P. Responsibility for the Planning Ef fort : Development, Periodic Review and Distribution of Emergency Plans Planning Objective To assure that responsibilities for plan development, review and distribution of emergency plans are established and that planners are properly tra ined.

Applicability and Cross Evaluation Criteria Reference to Plans Operator State Local Annex I

1. Each organization shall provide for the V.A.2. - pp. 199-200 training of individuals responsible for the planning effort. X X X Anner B, Append 1r 4,_

2. Each organization shall identify by Taba A-J, Para. V.1 - pp. 46-o5 title the individual with the overall Part II, App.1, Para. 4C (3) authority and responsibility for radio- pp. 288 & 373 Incl. Tab G logical emergency response planning. X X X 3.

Anner 3, Appendiz 4, Iten 3 Each organization shall designate an Taba A-J, Pam. V.2 Emergency Planning Coordinator with Basic, Para. 4 EE* 4G63 responsibility for the development and updating of emergency plans and coordina-tion of these plans with other response organizations. X X X

4. Anner B, Appendix 4, Iten 3 Each organization shall update its plan Tabs A-J, Para. V.3 as needed, review and certify it to be Basic, Para.4-Para?E7 current on an annual basis. The update shall take into account changes identified by drills and exercises. X X X

5. The emergency response plans and approved First tuo paces of Plan changes to the plar's shall be forwarded to (ie cover letter & record all organizations and individuals with ofchances) responsibility for implementation of the plans. Revised pages shall be dated and ma d to show where changes have been mace. X X Same X

6. Each plan shall t.catain a detailed listing of supporting plans and their source. X None X X

69-P. Responsibility for the Planning Effort: Development, Periodic Review and Distribution of Emergency Plans (continued )

Applicability and Cross Evaluation Criteria ___ Ref arence to Plans Operator State Local

7. Each plan shall coritain as an appendix Basic Plan - p. 16 listing, by title, procedures required t implement the plan. The listing shall Anne: 3 - p. 39-47 include the section(s) of the plan to be impleaented by each procedure. X X X

8. Table of Contents - pp. i-xi

_ach platt shall contairi a specific Subject Index - Ihch pace of Plan table of contents and an index. X X X

9. Each operator shall arrange for and conduct independent audits of the emergency preparedness program at least every two yea rs. The audit shall include the emer-gency plan, its implementing procedures and practices, training, readiness testing, and equipment. Management coritrols shall be implemented for evaluation and correction of audit findings. The result of the dudit shall be. documented, reported to appr0priate nrganizational mdnagement and retained for a period of f ive years. X l

- ._