ML20031E165

Forwards Comments Re Amend 40 to PSAR for Facility.Fema Will Be Asked for Status Rept on State of Offsite Planning to Support NRC Testimony.Draft Transmittal Ltr to Licensee Encl

ML20031E165
Person / Time
Site:	05000471
Issue date:	02/27/1981
From:	Pagano F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	Miraglia F Office of Nuclear Reactor Regulation
Shared Package
ML19247D013	List: ML20031E156 ML20031E165 ML20031E168 ML20031E171 ML20031E173 ML20031E176
References
FOIA-81-283 NUDOCS 8110150163
Download: ML20031E165 (6)

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CRVan Niel dP bgt,p SSchwartz ft BKCrimes FPagano EDDRANDUM FOR Frank Miraglia, Acting Chief SWelch Licensing Branch #3 -

All Tuam Leaders

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Division of' Licensing, NRR Frank G. Pagano, Chief FROM Emergency Preparedness Licensing Branch Division of Emergency Proparedness, I&E COISIENTS ON PILGRIM STATION UNIT 22, PSAR, Al'END!ENT 40

SUBJECT:

We have completed our initial review of the subject document against Within 30 days after re-the requirement of 10 CFR 50, Appendix E.

ceiving licensco's response vs will provids our evaluation report on the adequacy of the onsite emergency preparedness.

While we do not believe that a statutory or regulation requirement exists for the NRC to consult with FCIA or rely on their findings for CP issuance, we believe it would be appropriate to support NRC staff testimony by asking FE!A for a status report on the state of offsite planning fc,r Pilgrim 2.

We vill make our request of FEMA shortly.

A draft transmittal Picase transmit the enclosed cors ents to the licensee.

letrer is enclosed for your consideration.

If you have any questions, piense contact Tom McKenna (492-7939).

Frank G. Pagano, Chief Energency Preparedness Licensing Branch Divis*on of Emergency Preparedness, I&E

Enclosures:

Con =aents on Pilgrim Station Unit #2, PSAR, Amendma'st 40 P aft Letter l

8110150163 910827 PDR FOIA SHOTWE1.91-283 PDR

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DRAFT Docket No. 50-471

==Dear

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We have completed our review of the Pilgrim Unit 2 PSAR Amendment 40, dated October 10, 1980 against the requirements of 10 CFR 50..

Please recall that these comments were informally discussed with members of your staff and a draft copy was furnished to you in late December 1980.

Our review has indicated that additional informatTonand commitments are required before we conclude the PSAR meets the requirements.

Enclosed are our comments for which resolution is necessary. An amend-ment to the PSAR which addresses these counnents should be submitted by l

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REVIEW COMMENTS 4

ON PILdRIM STATION UNIT 2 PSAR SECTION 13.3, AMENDMENT 40 (50-471)

PSAR SECTION COWINT 13.3.2.2.1 Discuss how sufficient onsite emergency personnel and aug-mentation capability will be provided in acebrdance with the requirements of NUREG-0654, Table B-1.

Figure 13.3-4 Show the interface with Federal, State and local response l

agencies.

I 13.3.2 The principal Rhode Island State office or agency with responsibility for ingestion pathway protective actions must be identified and an agreement providing for noti-fication criteria, protective action criteria and estab-lishment of notification system provided.

13.3.3.2 Reclass'.fy, events involving offsite treatment or transpor-tation of contaminated injured persons as unusual events.

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13.3.5.4.2; Letters of agreement or State and loca.1 plans that provide 13.3.4.2; for " prompt" (15 minute) protective action decision-making l

13.3.2.1.1 on a 24-hour basis by offsite agencies must be provided.

This must include a description of the decision-making chain, times required, and provisions for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> avail-ability of decision-makers and communications. Backup com-munications not vulnerable to loss of normal power or over-load by public use must also be provided to each individual in the decision-making process (see NUREC-0654, Appendix 3).

Describe in general the system proposed to alert and provide an information message to the plume EPZ public within 15 minutes in accordance with NUREG-0654, Appendix 3.

Pro-visions for special instructions to special populations (e.g.

schools) should be discussed along with provisions for summer beach and boat populations.

13.3.5.1 Commft to develop EALs in accordance with NUREG-0654, l

Criterion I.1 and Appendix 1.

The EAL recegnition methodology,

for site and general emergencies must not include performance t

l of any calculations, personnel actions, etc., that can not be completed in*15 Binutes during the backshift.

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PSAR SECTION COMMENT 13.3.5.4, Describe the methodology used to determine the protective 13.3.5.4.1 action' recommended offsite to include:

1.

Development of EALs corresponding to plant conditions (core, containment, ESF),

2.

Use of evacuation time estimates for conditions at the time of the accident and for special populations, 3.

Use of the protection factors for homes, schools, etc.,

4.

Consideration of special populations and facilities, and 5.

Consideration or EPA, PACS.

The State and local protective action decision-makers must agree in principle to rely on information provided by the site for determination of minimum initial offsite response.

Provide the protection assumed to be provided by local homes, schools, places of work, etc. in accordance with NUREC-0654, Criterion J.10.m.

13.3.5.4.2.1 Commit to develop a method to account for site personnel within 30 minutes.

13.3.5.5.2 Describe the provisions for the devel pment of specific criteria (action Icvels) to b'e used to implement onsite protective measures.

Discuss the need and provisions for onsite corrective actions under accident conditions.

13.3.7.2 Describe the provisions to have each onsite individual who may be required to perform a task crucial to impicmentation of the emergency plan demonstrate annually their ability to perform these tasks.

13.3.5.1 Describe how real time dose projections will be provided using the instruments required by Reg. Guide 1.97.

13.3.6.1 Describe the provisions to provide protective action inf$rmation to the public in accordance with NUREG-0654, Criterion G.I.

Describe how information will be provided to transient populations such as boaters and beachgoers.

(See NUREC-0654, criterion G.2.

O PSAR SECTION COMMENT 13.3.2.3 Provide the location and preliminary information on the emergency response facilities and data systems in enough detail to demonstrate that they will provide an adequate basis for identifying the seriousness and potential scope of emergency situations, for assessment of information, and recommendations for protective actions and disseminating information to the public. Relate your response to the guidance provided in NUREG-0696.

13.3.7.1.2.4 Communications with the State organizations within the in-gestion EPZ uust be tested quarterly and monthly communica-tions drills must be conducted with the monitoring teams and emergency centers.

13.3.5.1 Revise the general description of the dose projections methodology to conform to NUREG-0654, Appendix 2.

This description should include the cencepts of the Class A model, incorporating site specific conditions and a meteor-ological measurement system as described in proposed Revision 1 to Reg. Guide 1.23.

Figure 13.3-1; Provide a map showing the plume EPZ in sufficient detail to Appendix 13.A, define the boundaries of the zone, hospitals, relocation centers and special populations in accordance with NUREG-0654, Appendix 4.

Appendix 13.A.

Describe in more detail the process used to obtain the comments Section 1 from local town officials and the current status of this effort.

Letters should be included from the towns contacted cu=mariz-ing their comments.

r Appendix 13A, Discuss the use of alternative protective actions at specisi Section 6.1 facilities. This should include the shelter factors assumed, evacuation times for those facilities and a discussion of how the protective measures to be recommended for these facilities will be determined (see comment on Section 13.3.5.4).

Nursing homes, schools and camps should be considered as j

special facilities.

Appendix 13.A.

Include consideration of the effects of " spontaneous" evacuation of people from Cape Cod when calculating the Section 6.4 l

" Case 6" evacuation times. Two evacuation routes terminate l

(Nodes 800 and 801) in the area of the Sagambre Bridge Circle and the evacuation study should be expanded to determine the time requircJ to evacuate those people down Route 6A.

7 Discuss how access to Route 3 was modeled (No nodes are shown).

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PSAR SECTION COMMENT Appendix 13.A Provide the basis for the automobile occupancy factors.

B.3 Appendix 13.A.

Provide the Roadway characteristics as described in Section 3.2 NUREC-0654, Appendix 4-III B (pg. 4-6).

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Appendix 13.A, Provide a further description of tha algorithm used in Annex A the Model. Describe how highway capacity was determined and how the dynamic route loading is conducted.

Appendix 13.A.

Discuss esticated evacuation time for the public thao Section 5 must use public transportation in accordance with NUREG-0654, page 4-9.

13.3.5.5.4 Provide the proposed location (show relation to emergcncy centers) and physical layout of the first aid and per-sonnel decontamination facilities.

13.3.6.2.3 Provide a more detailed list of the State and local support agencies to be invited to onsite training.

Provide for training of these personnel on the functions they may be required to perform or condi-tion they may encounter onsite that are not part of their normal (offsite) duties / training. Describe the proposed length of this training and type.

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