ML20032E115
| ML20032E115 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 11/12/1981 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Arnold D IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT |
| Shared Package | |
| ML20032E116 | List: |
| References | |
| NUDOCS 8111190672 | |
| Download: ML20032E115 (29) | |
See also: IR 05000331/1981003
Text
NOV 1121E
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Docket No. 50-331
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Iowa Electric Light and Power
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ATTN:
Mr. Duane Arnold
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President
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IE Towers
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P. O. Box 351
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Cedar Rapids, IA 52406
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Gentlemen:
Subject: Emergency Preparedness Appraisal
1
'To verify that licensees have attained an adequate state.of onsite
emergency preparedness, the Office of Inspection and' Enforcement is
conducting special appraisals of the emergency preparedness programs at
all operating nuclear power reactors. The objectives of these appraisals
are to evaluate the overall adequacy and effectiveness of emergency pre-
paredness and to identify areas of weakness that need to be strengthened.
We will use the findings from these appraisals as a basis not only for
requesting individual licensee action to correct deficiencies and effect
improvements, but also for effecting improvements in NRC requirements and
guidance.
During the period of September 8-16, 1981, the NRC conducted a special
appraisal of the emergency preparedness program at the Duane Arnold Energy
,
Center. This appraisal was performed in lieu of certain routine inspections
normally conducted in the area of emergency preparedness. Areas examined
during this appraisal are described in the enclosed report (50-331/81-03).
Within these areas, the appraisal team reviewed selected procedures and
representative records, inspected emergency facilities and equipment,
observed work practices, and interviewed personnel.
Significant deficiencies for which you have made acceptable commitments
to resolve are discussed in the confirmation of action letter dated
September 22, 1981, enclosed as Appendix A.
The findings of this appraisal also indicate that there are areas for
improvement in your emergency preparedness program. These are discussed
in Appendix B, " Appraisal Improvement Items."
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Iowa Electric Light and Power
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NOV 121901
Company
In conjunction with the aforementioned appraisal, emergency plans for your
facility were reviewed. The results of this review indicate that certain
deficiencies exist in your "Duane Arnold Energy Center Emergency Plan" and
" Iowa Electric Light and Power Corporate Emergency Rerponse Plan." These
are discussed in Appendix C, " Emergency Preparedness Evaluation 5-
vet."
Several areas in your emergency preparedness program were not complete at
the time of this appraisal and therefore were not examined. These items
are identified as Open Items and are listed in the enclosed Appendix D.
These wi.11 be examined by our staff upon complete implementation of the
area involved.
Please notify our office relevant to your completion
schedule of these items for re-examination by our staff.
We recognize that an explicit regulatory requirement pertaining to each
item identified in Appendices A, B, and C may not currently exist. Not-
withstanding this, you are requested to submit a written statement within
thirty days of the date of this letter, describing your planned actions
for improving each of the items identified in Appendix A and the results
of your consideration of each of the items in Appendix B.
This description
is to include:
(1) steps which have been taken; (2) steps which will be
taken; and (3) a schedule for completion of actions for each item. This
request is made pursuant to Section 50.54(f) of Part 50, Title 10, Code of
Fe.2ral Regulations. With regard to Appendit C, within 90 days of the date
of this letter you are requested to provide enanges to tne emergency plan
correcting each deficiency. Copies of these changes are to be submitted
in accordance with the procedures delineated in 10 CFR 50.54(q).
This is to inform you that should the deficiencies addressed in the con-
firmation of action letter of September 22, 1981, not be corrected by the
commitment dates provided, the Commission will determine whether the reactor
shall be shut down until such deficiencies are remedied or whether other
enforcement action is appropriate.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of
this letter, the enclosures, and your response to this letter will be placed
in the NRC's Public Document Room.
If the enclosures contain any informa-
tion that you or your contractors believe to be exempt from disclosure under
10 CFR 9.5(a)(4), it is necessary that you (a) notify this office by telephone
within seven (7) days from the date of this letter of your intention to file
a request for withholding; and (b) submit within twenty-five (25) days from
the date of this letter a written applicstion to this office to withhold such
Section 2.790(b)(1) requir ? thit any such application must be
information.
e
'< -naer of the information which
accompanied by an affidavit executed b'
s
identifies the document or part sou;W. e 4e vithheld, and which contains a
full statement of the reasons wh' a
a*
. bases for the claim that the in-
formation should be withheld from
201
uselosure. This section further
requires the statement to address
ith spccaficity the considerations listed
in 10 CFR 2.790(b)(4). The intormation sought !o be withheld shall be incor-
porated as far as possible into s separate part of the affidavit. If we do
.
.
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Iowa Electric Light and Power
-3-
Company
not. hear from you in this regard within the specified periods noted above,'a'
-copy of this letter, the enclosures, and your response to this letter will
~
be placed in the Public Document Room.
The responses directed by this letter and the accompanying appendices are'not
,
subject to the clearance procedures of theJ0ffice of-Management and Budget as
'
required by the Paperwork Reduct'on Act of 1980, (PL 96-511).
Should you have any questions concerning this inspection, we will be pleased
to discuss them with you'
Should you have any questions concerning the items
.
of Appendix C, please contact Mr. W. L. Axelson,- Chief, Emergency Preparedness
Section at (312) 932-2535.
Sincerely,
.
Original signed by'
A. Ecrt Davis
James G. Keppler
Director
Enclosures:
1.
Appendix A, Confirmation of
Action Letter dtd 9/22/81
2.
Appendix B, Appraisal
Improvement Items
3.
Appendix C,' Emergency
Preparedness Evaluation
-
Report
4.
Appendix D,.0 pen Items
5.
Office of Inspection and
-Enforcement Inspection
Report No. 50-331/81-03
,
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cc w/encls:
D. Mineck, Chief
' Engineer
DMB/ Document Control Desk (RIDS)
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Resident. Inspector, RIII
Regional Director, FEMA, Region V
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Appendix A
Docket No. 50-331
Iowa Electric Light and Power
Company
ATTN:
Mr. Duane Arnold
President
IE Towers
P. O. Box 351
Cedar Rapids, IA 52406
Gentlemen:
This letter is to confirm agreements reached between Mr. Larry D. Root,
Atsistant Vice President, Nuclear Generation, and others of your staff,
and Mr. Carl Paperiello and other members of the NRC staff on September 16
1981, during the management exit interview following the NRC Emergency
Preparedness Appraisal and to a telephone conversation with Mr. K. Meyer
of your staff with the same NRC staff on September 21, 1981.
Immediate corrective actions are required for significant Appraisal find-
ings. The exact nature of the required actions, as well as the agreed upon
dates for such actions, are as follows:
1.
Onsite Emergency Organization
Required Action
,
1
A.
Expand the onsite emergency response organization to include all
needed management and technical positions necessary to cope with
an emergency. The additional functions to be provided shall in-
clude: Administrative Support, Security Support, and Maintenance /
Engineering Repair and Corrective Action.
Procedures and/or check
lists shall be developed to ensure these functions are implemented.
(Section 2.1) (331/81-03-01)
This shall be completed by December 14, 1981.
2.
Training of Emergency Response Personnel
Required Actions
A.
Develop and implement a formal training program and schedules
for corporate and offsite-agency support personnel including
health physics training for fire department and ambulance per-
sonnel.
(Section 3.2) (331/81-03-02)
B.
Provide specific training to emergency response personnel
on what to expect under unusual plant conditions, such as
components and areas with high radiation levels, magnitudes
-
_
_ _ _ _ - _ - _ -____-
-
Appendix A
-2-
of radiation increases, and changed nuclide composition.
Include specific training for health physics technicians on
plume monitoring techniques.
(Section 3.2) (331/81-03-03)
Both the training program and implementation shall be
completed by February 1, 1982.
3.
Emergency Equipment and Facilities
Required Actions
A.
Obtain sufficient silver zeolite cartridges for replacement
cartridges for post-accident effluent sampling and inplant
air sampling. These cartridges shall be readily available
in the emergency team lockers located in the Operational
Support Center.
(Section 4.1.1.7) (331/81-03-04)
B.
Establish an offsite facility near the plant which has the
capability for:
relocating and monitoring site evacuees;
backup laboratory equipment for environmental and high
level sample analysis; decontamination of personnel; and
supervisory deployment and coordination of field assessment
teams. Laboratory equipment at this facility shall have the
capability _gymeacuringfieldradioiodineairsamplesofat
least 1x10
uCi/cc.
(Sections 4.1.1.9, 4.1.2.1, 4.1.2.3,
4.2.1.1, and 5.4.3.2) (331/81-03-05)
Item A shall be completed by October 28, 1981, and Item B
shall be completed by February 1,1982.
4.
Emergency Plan Implementation Procedures and Interface Procedures
Required Actions
A.
Develop procedures and/or check lists for onsite and corpor-
ate emergency response personnel with major functional rolet
to assure accomplishment of necessary emergency actions.
In
addition, the Emergency Coordinator and Emergency Response
and Recovery Directors shall cach have one position / titled
procedure for their use which orchestrates the implementa-
tion of all actions required of these individuals in the
onsite and corporate energency response organization. The
Emergency Coordinator and Emergency Response and Recovery
Director procedures shall include recommendations to offsite
agencies based on degrading reactor core conditions as well
as radiological release conditions.
(Section 5.3)
(331/81-03-06)
This shall be completed by December 14, 1981.
Appendix A
-3-
B.
Review and revise all necessary plant abnormal operating
instructions, emergency instructions and refueling accident
emergency procedures which do not contain, as a subsequent
operator action, a statement to direct the Reactor Operator
or user to notify the Shift Supervisory Engineer to classify
the emergency in accordance with the DAEC Emergency Plan.
This statement shall be in bold print and bordered. Included
in this review shall be any operating procedures relevant to
the plant operation during a tornado, earthquake or onsite
nonradiological incident such as chlorine gas release.
(Section 5.2) (331/81-03-07)
This shall be completed by the end of the 1982 refueling
outage.
C.
Develop and implement a standing order to all operating
crews informing them of the need to notify and inform the
SSE to classify abnormal operating conditions in accordance
with the DAEC Emergency Plan and Procedures.
(Section 5.2)
(331/81-03-08)
This shall be completed by December 14, 1981.
D.
Develop and implement a procedure to ensure communications
checks with the NRC will be accomplished in accordance with
the requirements specified in 10 CFR 50, Appendix E,
Section IV.E.9.d.
(Section 5.5.2) (331/81-03-09)
This shall be completed by October 28, 1981.
E.
Develop procedures to identify the location and provide for
inventory and operability checks for all emergency communica-
tion equipment.
(Section 5.5.1) (331/81-03-10)
This shall be completed by December 14, 1981.
F.
Develop a procedure for the monitcring teams use to specify
how to collect a representative air particulate and radio-
iodine gas sample minimizing noble gas interference, the
means to determine whether a team is in or near the plume,
the means for labeling samples, the means for documenting
the results of surveys by the teams, and emergency limitations
and precautions for use of the procedure.
(Sections 5.4.2.1
and 5.4.2.2) (331/81-03-11)
This shall be completed by October 28, 1981.
G.
Develop procedures for use by the Control Room Coordinator,
Site Radiation Protection Engineer (SRPE), and Radiological
r
Appendix A
-4-
Assessment Coordinator (RAC) to ensure that operational
and radiological assessment parameters will be collected,
recorded, and trend analysis performed. The procedures
used by the SRPE shall include the prioritization of
sampling vs survey activities for inplant and onsite survey
teams. Procedures shall also be developed to allow the RAC
and SRPE to determine whether PAGs may be exceeded on a
potential release, and assess the offsite consequences due
to an actual release.
(Section 5.4.2) (331/81-03-12)
This shall be completed by February 1,1982.
H.
Develop a technically accurate dose assessment procedure
using the finite plume model for elevated releases and a
dose assessment procedure for ground level releases.
Section 5.4.2) (331/81-03-13)
The ground level release procedure shall be completed by
October 28, 1981, and the finite plume model completed by
December 14, 1981.
I.
Review and revise as necessary, the Radiation Protection
Procedures to be used during an emergency to include pre-
cautions, limitations and guidance necessary under accident
conditions,
i.e., effects of elevated levels of noble gases
on measurement of radioiodine, potential for evolution of
radioactive gases from liquid samples, effect of infusion
of radioactive gases into ion chamber dose rate instruments,
etc.
(Section 5.4.3.1) (331/81-03-14)
This shall be completed by February 1,1982.
J.
Revise Emergency Plan Implementing Procedures (EPIP) 5.1
and 5.2 to indicate the stable plant parameters necessary
to downgrade an emergency classification. These parameters
shall take into account potentials for uncontrolled radio-
logical releases.
(Section 5.4.6) (331/81-03-15)
This shall be completed by December 14, 1981.
K.
EPIP 1.2 shall be revised to include: notification of the
Emergency Response and Recovery Director, full activation of
the onsite organization for any Alert or greater classifica-
tion, and planned messages to offsite agencies including all
information specified in Criterion II.E.3 of NUREG-0654,
Revision 1.
Messages shall include a recommendation on
whether or not to activate the prompt notification system.
(Section 5.4.1) (331/81-03-16)
This shall be completed by October 28, 1981.
r
_
. Appendix A
-5-
15.
Prompt Public Notification
Required Actions
Provide documentation which technically supports whether the prompt
public notification system meets the design objectives of Appendix 3
of NUREG-0654. The licensee's submittal shall clearly indicate when
the system will be '#ully operational.
(Section 6.2.2) (331/81-03-17)_
This shall be completed by December 14, 1981.
If our understanding of your planned actions described above,~is not
in accordance with the_ actual plans and actions.being implemented,.
.please contact this office by telephone and in writing _within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Further, please inform this office, in writing, upon completion of all
the above action items.
Sincerely,
James G. Keppler
Director
cc:
D. Mineck, Chief
Engineer
DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII
1
r-
. Appendix B
APPRAISAL IMPROVEMENT ITEMS
Based on the results of the NRC's appraisal of the Duane Arnold Energy
Center Emergency Preparedness Program conducted September 8-16, 1981, the
following items should be considered for improvement:
Note: These are prioritized in order of importance.
1
1.
The Technical Support Center (TSC) should be placed in an opera-
l
tional state of readiness. The exact location for each individual
who reports to the TSC should be easily identified, and should be
included in the Duane Arnold Energy Center (DAEC) Emergency Plan and
appropriate implementing procedure (EPIP 2.2).
The use of the TSC
for permanent office space should be in accordance with the licensee's
January 3, 1980, submittal.
(Section 4.1.1.2).
2.
All plans and procedures should be distributed both onsite and
offsite in accordance with Administrative Control Procedure (ACP)
1402.4. The controlled distribution list should be maintained by
the Administration Supervisor, who should function with regard to
all Emergency Plans and Procedures as described in ACP 1402.4. The
out-of-date preparedness plans.should be collected and discarded.
Copies distributed to the NRC should not be sanitized to the point
of rendering them useless.
(Section 5.5.3).
3.
An offhours shift augmentatira drill should be conducted to ensure
the duty officer system and procedure call out list meet the design
objectives of Criterion II.B.5 of NUREG-0654, Revision 1.
Records
should be maintained of these drills, which should be conducted
quarterly.
(Section 2.2.1)
4.
.1, Sections 2.0 and 4.5.2 should be reworded to say that
other events not included in these EALs may be classified as an Unusual
Event, Alert, or Site Area Emergency at the discretion of the Emergency
Coordinator or Shift Supervising Engineer, rather than the sentence re-
ferring to man-caused and natural emergencies.
(Sectior 5.4.1)
5.
EPIPs 5.1 and 5.2 should be revised to specify that an "under control"
situation exists when the plant is in a stable state, necessary plant
equipment is functioning properly, and there is no potential for uncon-
trolled radiological releases.
(Section 5.4.6)
6.
Section 3.1 of EPIP 4.1 should clearly specify that the Shift Super-
vising Engineer (SSE) is responsible to sound the evacuation / assembly
alarm for any event classified as an Alert or greater.
(Section 5.4.3.2)
,
J
e
Appendix B
-2-
7.
Walkthrough-training for all SSEs and Health Physics Technicians
should be conducted after correction of identified deficiencies in
Appendix A of this report. Particular attention should be given
to those areas where major changes have been made.
(Section 7.2)
8.
EPIP 5.1 should specify who has the final authority for downgrading /
deactivating emergency classification levels and declaring that a
recovery phase is to be entered.
(Section 5.4.6)
9.
When the duty officer paging system becomes operational, EPIP 1.2
and CPIP 1.2 should be revised to incorporate the use of this system.
(Section 5.4.1)
10.
Emergency Coordinators should be trained in the availability of the
portable chlorine concentration sampler and the conditions under
which it should be used to determine EALs.
(Section 4.2.1.3)
11.
The turbine building exhaust flow monitor should be properly labeled
and the procedure should be changed to ensure proper flow units are
recorded.
(Gection 4.1.1.7)
12.
Fire Brigade leadership should be under the direction of a Senior
Reactor Operator (SRO). The Security Shift Supervisor should be
relieved of this responsibility by July of 1982, when minimum shift
staffing will include two SR0s.
(Section 5.4.8)
13.
CPIP 4.4 should specify who actually performs the audits of the
emergency preparedness program. This description should also specify
that the auditors have no direct responsiblities for implementing the
emergency preparedness program.
(Section 5.5.4)
14.
Predetermined offsite sample / survey points should be selected for
ease in identification of locations.
(Section 5.4.2.1)
15.
Telephones in t.
TSC and Control Room should be located in areas
where assigned functions are to be implemented.
(Section 5.6)
16.
The program of training, drilling, and exercising with the Palo
Fire Department should be strengthened.
(Section 6.1)
17.
Dedicated equipment and supplies in emergency kits for emergency
environmental monitoring should be provided. A limited scope
program for taking and assaying water, soil, vegetation, and milk
samples for quick assessment should be developed.
(Section 4.2.1.1)
18.
Formal training lesson plans should be developed to include specific
,orformance objectives, hands-on practice, and walkthroughs.
'Section 3.2)
(
&
A
Appendix B
- - - 3-
19.
Instrument check sources should be provided in emergency cabinets
to facilitate functional testing of instruments before' use.
(Section 4.2.~1.1)
20.
Emergency supplies should be package in'a suitcase or other easily
transportable container to prevent loss of portions of the supplies-
-
during movement and to aid in transport. .(Section 4.2.1.1)
21.
The licensee should develop procedures for'the onsite administration
of and establish supplies of radio protective drugs and include action
levels for use, storage locations, and control.
(Section 4.1.2.2)
-
22.
The licensee should establish specific assignments for functions
required for radiation protection during emergencies not defined in
the existing emergency plan;
i.e.,
dosimetry, access control, etc.
(Section 5.4.3.1)
23. EPIPs should be reviewed to assure that procedures referenced in the
- EPIPs exist.
(Section 5.4.3.1)
,
24.
Those Radiation Protection Procedures that only address emergency or
accident actions should be reissued as EPIPs.
(Section 5.4.3.1)
25.
The licensee should develop a Letter of Agreement with the Paramount
Theater for use as an alternate Emergency News Center.
(Section 4.1.4)
'
26.
CPIP 1.4 should include provisions that explain how the news media
center will be used by the State, local, federal, and licensee spokes-
persons to coordinate public information activities and conduct media
relations.
(Section 4.1.4)
.
27.
The licensee should update administrative procedures to cover the
existing emergency plan and procedures.
(Section-5.1)
28.
Instructions to radiological survey teams should be provided on
disposition of. survey data sheets, samples, and other pertinent
information.
(Section 5.4.2.3)
,
29.
A description should be included in EPIP 1.2 on the use of the backup
communications available (IWAS and radio) for notifying offsite agencies.
(Section 5.4.1)
30.
An alternate atmospheric stability categorizatinn scheme should be
outlined in the offsite dose assessment procedures to obtain stability
i
categorizations based on data from the Cedar Rapids 'FAA facility.
(Section 4.2.1-4)
.
.
31.
When the offsite relocation center is established, it should be
!
designated in EPIP 4.1 with a map of the evacuation routes to be
taken from the site to this area.
(Section 5.4.3.2)
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Appendix B
-4-
32. The licensee's preventative maintenance program for meteorological
measurements should be formalized to represent controlled procedures
for the following activities: operational reviews, surveillance,
and calibration. These procedures should be unambiguous and self-
contained, and should be representative of state-of-the-art practices.
(Section 4.2.1.4)
33.
Radwaste sampling equipment should be obtained and procedures developed
for handling elevated radwaste samples under accident conditions.
(Sections 4.1.1.8 and 5.4.2.10)
34.
EPIP 4.1 should specify that accountability will be accomplished
within 30 minutes, and should clarify the means by which all assembled
personnel will be continuously accounted for thereafter.
(Section 5.4.3.3)
35.
The containment high range radiation monitor should be color coded in
accordance with accident classifications.
(Section 5.6)
36. All EPIPs should be tabbed for quick access.
(Section 5.6)
37.
Changes to EPIPs and CPIPs should be cade upon determination that a
change is needed rather than waiting for the annual review.
(Section 5.5.2)
38.
The licensee should establish a means for allowing public input in
the content of the public information brochure and its distribution.
(Section 6.2.1)
39.
Distribution of the annual emergency information brochure should be
expanded to fully cover the transient population, including signs,
decals, and posted notices as indicated in Section G.2.1 4 of the
DAEC Plan.
(Section 6.2.1)
40.
Implementing procedures should be reviewed to assure consistent use
of titles in assigning responsibilities and actions.
(Section 5.1)
41.
The licensee should provide for timely distribution of Emergency
Plans and revisions to offsite agencies.
(Section 6.1)
42.
The Letter of Agreement with the Palo Fire Department and Ambulance
Service should be improved to describe the capabilities and respon-
sibilities that will be expected in responding to incidents or
emergencies.
(Section 6.1)
43.
The remote switch for the high range noble gas scale should be properly
labeled.
(Section 4.1.1.7)
44. The selection criteria established for emergency planning personnel
should be stated as generic criteria, rather than describing the
qualifications of the current iceabents.
(Section 1)
_
e
Appendix B
-5-
45.
The Emergency Monitoring Log should include a description of the
instrument mode used for the radiation survey results;
e.g., open
window or closed window.
(Section 5.4.2.1)
46. The emergency planning fun tion should also be assigned to a site
individual so that the plaaning function would hrve continual
viability and site specific input.
(Sectica 1)
47. A system for identifying personnel surveyed at asseubly points should
be established to assure that all personnel are surveyed.
(Section 5.4.3.4)
48. The licensee should develop formal provisions for expanded support
facilities (mobile trailers, communications, other resources)
necessary for contractor and nonlicensee augmentation personnel.
(Section 4.1.3)
49. The licensee should develop and implement a formal system for alerting
and training emergency response personnel on significint changes in the
plan and/or procedures between scheduled training sessions. Training
on these changes should be conducted using techniques similar to initial
training to assure individual ability to perform assigned tasks.
(Section 3.2)
50.
The licensee should improve the quality of documentation of training
performed at the corporate level and to offsite agency support personnel.
(Section 3.2)
51.
A procedure should be provided to acsure the operability of emergency
kit equipment and periodic replacement of limited life items such as
batteries.
(Section 5.5.1.)
52.
Face masks of emergency respirators should be bagged to maintain
,
cleanliness and retard deterioration.
(Section 4.2.1.1.)
53. A system should be provided to inform and assure the respirator user
that the respirator has been inspected and surveyed.
(Sectioa 4.2.1.1)
54. The licensee should review the use of the
25% time tolerance allowed
on training and retraining frequency to meet the intent of the require-
ments.
(Section 3.2)
>
-
Appendix C
EMERGENCY PREPAREDNESS EVALUATION REPORT
The following is a list of deficiencies identified in the Duane Arnold
Energy Center (DAEC) and Iowa Electric Light and Power Corporate (IELP)
Emergency Response Plans. These deficiencies are categorized as per the
planning standards of 10 CFR 50.47(b) and Appendix E.
These deficiencies
as well as those listed in Appendix A must be corrected in accordance with
the provisions of 10 CFR 50.54(s)(2):
Planning Standard 50.47 (b)(1) (Assignment of Responsibility)(331/81-03-18)
The DAEC Plan does not include Letters of Agreement from private
.
contractors descrited in the plan (e.g., General Electric, Bechtel,
INPO), nor does it include Letters of Agreement from the Cedar Rapids
Fire Department.
This Plan also stater that "other contractors and
consultants," will be used if needed. Assuming the Appendix 4 list
in the IELP Plan is a complete list of these "other contractors and
consultants," either the IELP Plan or the DAEC Plan must include
Letters of Agreement from the major contractors (e.g., TRC, Hazeltine
Environmental Sciences, Professor D. Mcdonald, and Ecological Analysts).
Further, all Letters of Agreement must identify the emergency measures
ta be provided and the mutually acceptable criteria for their imple-
mentation.
The DAEC Plan does not indicate that all Letters of Agreement will
.
be updated as necessary but at least every two years.
Letters of
Agreement with Mercy Hospital and the University of Iowa State
Hygienic Laboratory are more than two years old, and must be updated.
Planning Standard 50.47(b)(2) (Onsite Emergency Organization)(331/81-03-19)
Section B.2.2 of the DAEC Plan does not address the minimum shift
.
staffing and augmentation to be provided. Criterion II. B.5 of
NUREG-0654, Revision 1, specifies a minimam of ten personnel on shift
at all times, with the capability to augment with an additional 11
personnel in 30 minutes, and 15 additional personnel within 60 minutes.
IELP's res onse dated May 28, 1981, is adequate with respect to 60
minute augmentation capability; however, no provisions are made for an
individual to be on shift to cover the functions of notification and
communication. Further, the response states that the chemist / radio-
chemist function is implemented by the Radwaste Operator on shift, but
the enclosed table indicates that the Radwaste Operator is not a unique
function. The Emergency Plan Implementing Procedures (EPIPs) state that
the notification / communication function will be provided by the Shift
Technical Advisor (STA). This is unacceptable in that:
(1) the STA's
function is clearly defined in NUREG-0737 Task Item I.A.1.1, and (2)
once communication is established with the NRC (upon determination that
an EAL has been exceeded), it must be maintained continuously until the
-
Appendix C
-2-
.
NRC Operations Center determines it no longer must be maintained.
Based on the above, the May 28,1981, letter is unacceptable in
meeting Criterion II.B.5 with respect to on shift staffing. The
DAEC Plan must include the minimum on shift staffing and augmenta-
tion requirements as shown in Table B-1 of NUREG-0654,-Revision 1.
Section B.2.2 of the DAEC Plan states that the details regarding
.
assignments and responsibilities of the minimum shift staff and
augmentation personnel are addressed in the Emergency Plan Imple-
menting Procedures. This is unacceptable. The Plan must specify
assignments and responsibilities of all personnel required in a
format similar to Table B-1 of NUREG-0654, Revision 1.
Only the Emergency Coordinator and Site Radiation Protection
.
Coordirator responsibilities, assignments, and lines of succession
are spe.cified in the Plan. This has not been done in the same format
for other critical positions specified in the Plan; e.g. , Control
Room Supervisor, TSC Supervisor, and OSC Supervisor.
Other key functions required during an emergency such as security,
.
administrative support, composition of the technical staff, and
maintenance support are not addressed in this section of the DAEC
Plan. These must also be addressed in the P14a.
Planning Standard 50.47 (b)(3) (Emergency Response Support and Resources)
(331/81-03-20)
Section C.2.4. of the DAEC Plan states that mutual aid arrangements
.
with nearby nuclear facilities are expected te be in place; however,
the Plan does-not include the names of these facilities. The Plan
must include the names of these facilities, what optcific services
will be provided, and the expected response time for these services.
These mutual aid arrangements must be documented by formal Letters
of Agreement. Further, these agreements must be appended to the
plan and updated at least every two years.
Planning Standard 50.47(b)(4) (Emergency Classification System) (331/81-03-21)
The DAEC Plan does not adequately provide Emergency Action Levels
.
(EALs) qs per Appendix 1 of NUREG-0654, Revision 1, in the following
areas:
-
UNUSUAL EVENT
(a) Any ECCS actuation that results in water being discharged
to the reactor vessel should be an Unusual Event.
(A10)
(b) Specify the Reactor Coolant Leak Rate value,
e.g., GPM, that
corresponds to a rate greater than Technical Specification
Limits.
(A1)
Appendix C
-3-
(c) High offgas activity at air ejector monitor must be in-
cluded (greater than 500,000 uCi/sec or an increase of
100,000 uCi/see within a 30 minute time period).
If the
Technical Specification trip setting is to be used, this
value must be less than the above and the value specified
in the plan.
(A6)
(d) Specify what the Main Steam Line Technical Specification
limit is.
(AS)
(e;
Specify the radiological effluent readings (or alarms) that
indicate effluents greater than Technical Specification limits
for both airborne (A2 and A3) and liquid (A4) effluents.
(f) Any onsite release of toxic or flammable gases should be an
Unusual Event.
(A23)
(g) The actual value of the reactor coolant activity (e.g., uCi/ml)
greater than Technical Specifications must be specified.
(A7)
(h) The Plan does not address significant loss of assessment or
communication capability (e.g., plant process computer failure,
complete loss of meteorological instrumentation, etc.).
These
conditions riould be Unusual Events.
(i) The Plan does not address all events that require plant shut-
down under a Technical Specification action statement. These
events are all Unusual Events.
-
ALERT
(a) A primary coolant leak rate of greater than 50 GPM is vat
specified in the Plan. This is an Alert.
(B1)
(b) The Plan does not address sustained winds in excess of 60
MPH as an Alert.
(c) The Plan should specify that evacuation of the Control Room
with control of shutdown systems established due to any cause
is an Alert.
(B18)
(d) The Plan does not classify uncontrolled entry of toxic or
flammable gases into the facility environs as an Alert.
Control Room evacuation is not required for this event to
be an Alert. The concentration level for detection and
classification of this EAL must be included in the Plan.
(e) The Plan does not address turbine failure with casing
penetration as an Alert.
Appendix C
-4-
(f) Alert Class B17 should state the loss of most or all alarms,
irregardless of operational state.
(g) Failure of the RPS to initiate and complete a scram is suf-
ficient for an Alert, regardless of whether a manual scram
failure also occurred.
(BIO)
(h) The Plan does not address a fuel handling accident that
results in fuel damage with the release of radioactivity
to either the containment or fuel handling buildings.
This type of an event is an Alert.
(i) Area Radiation Monitor (ARM) reading EALs which indicate a
severe degradation in the control of radioactive materials
(e.g., increases over normal readings by factor of 1000 in
direct ARM reading within the facility). The reading of
greater than 1000 alarm setpoints should be reworded to state
greater than 1000 times normal, and should be expressed for
each ARM.
(B19)
(j) Radiological effluent reedings (B3, B4, and B5) are not
included to indicate effluents greater than ten times
Technical Specification limits, or in the case of airborne
effluents, equivalent to 1 mR dose if averaged over a two
hour period. These readings shall be indicated in the Plan.
(k) The Plan does not address a Main Steam line break with MSIV
malfunction causing leakage as an Alert. This could occur
anywhere along the line between the turbine and containment.
(B2)
(1) The Plan does not adequately address a severe loss of fuel
cladding. The initiating EALs for this event should be either
reactor coolant activity results greater than 300 uCi/cc
equivalent I-131 or air ejector offgas monitor readings
greater than 5 Ci/sec, corresponding to 16 isotopes decayed
30 minutes; it should not be ten times Technical Specification
limits.
(B7)
(m) The Plan does not address the complete loss of any function
needed for plant cold shutdown (e.g., loss of essential
service water, etc.).
(n) The DAEC Plan does not address other plant conditions that
exist warranting precautionary activation of the TSC and
placing the EOF and other key emergency personnel on standby.
,
Appendix C
-5-
SITE EMERGENCY
-
(a) Site Emergency EAL C10'should state " earthquake greater'than
SSE levels" rather.than OBE levels.
(b) CAL C17 should state " loss of most or all ' alarms for more
than 15 minutes and plant not in cold shutdown, or loss of
most or all alarms and plant transient initiated or in
progress" rather.than requiring a 15 minute wait during a
transient-to declare this EAL.
(c) The Plan does not address a transient requiring operation
of shutdown systems with a failure to scram (continued power
~
generation but no core damage immediately evident).
(d) The Plan does not address major damage to spent fuel in
containment or fuel handling building; however, it does
'
address major damage to the spent fuel pool.
Both of
these events should be included as.a Site Emergency.
(e) The Plan does not address the entry of uncontrolled
flammable gases into vital areas, nor does it. address the
entry of uncontrolled toxic gases into vital areas where
lack of access to the area constitutes a safety problem.
In both of these instances the gas concentrations which
are hazardous must be included as part of this EAL.
(f) The Plan does not address other plant conditions exist
that warrant activation of emergency response facilities
and monitoring teams or a precautionary notification to
the public near the site.
(g) EAL C2 must specify the actual rad monitor reading that
would relate to the lesser of a degraded core with possible
loss of coolable geometry or radiation level in containment.
with leak rate appropriate for existing containment pressure
to result in site boundary dose in excess of 50 mR/hr for
hour or 500 mR/hr for two minute whole body dose.
(h) The Plan does not address a complete loss of any function
needed for plant hot shutdown.
(i) EAL C1 should specify decreasing reactor vessel level
indication rather than no reactor vessel level indication.
If no reactor vessel level is indicated, it should be a
General Emergency.
-
GENERAL EMERGENCY
(a) EAL D2 and D3 are too conservative, and do not adequately
address the loss of two out of three fission product
____
.
. .
..
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ . _ _ _ _ _ _ _ - _ _ _ .
_ _ _ - _ _ _ _ _ .
Appendix C
-6-
barriers with the potential loss of the third barrier.
The containment radiation monitor reading (specify reading)
that corresponds to a loss of primary coolant boundary
with cladding failure should be used in conjunction with
situations that would lead to a potential loss of contain-
ment (e.g. , loss of essential service water, loss of
containment cooling, increasing containment temperature or
pressure, increasing torus temperature or pressure, etc.).
Other indicators regarding loss of cladding should include
coolant activity sample results or instrument readings.
(b) EAL D1 is too liberal in that it requires a loss of the
ECCS. This EAL should state a LOCA with no reactor vessel
level indication regardless of whether ECCS is operating
(corresponds to complete continued uncovering of the core).
(c) The Plan does not address classification of EALs based on
field measurement results (e.g., 1 R/hr WB at the site
boundary is a General Emergency, five times this for thyroid).
(d) EALs have not been calculated for those BWR sequences which
could lead to a core melt and likely failure of containment
(See page 1-18 of Appendix 1 of NUREG-0654, Revision 1).
(e) EAL D5 is too conservative in that this will not necessarily
lead to a loss of containment by itself.
See discussion under
General Emergency Section (a) above regarding loss of two out
of three fission product barriers with potential loss of the
third.
In this regard, the coolant activity need only to
exceed 300 uCi/cc.
For all EALs in the Plan, the specific value corresponding to the
.
parameter must also be included in the Plan (e.g., 0.01g for seismic
monitor, 6000 R/hr for containment radiation monitor, etc.).
Planning Standard 50.47(b)(5) (Notification Methods and Procedures) (331/81-03-22)
30 specific mention is made in the DAEC Plan of the time required for
.
notifying and providing prompt instructions to the public within the
ten mile EPZ. The Plan should address the administative means and the
time required to promptly notify the public of an emergency.
The message formats described in Section E.2.3 are inadequate in that
.
they do not contain information regardiag:
(1) whether or not a release
is taking place, (2) potentially affected population and areas, and (3)
whether protective measures may be necessary.
_ _ _ _ _ _ _ _ _
_
_ _ _ ,
Appendix C
-7-
Planning Standard 50.47(b)(7) (Public Education and Information) (331/81-03-23)
Although the DAEC Plaa states that the public information program is
.
further described in the IELP Plan, no such description exists.
Appendix 3 of the IELP Plan is titled "Public Information Materials,"
but in fact it does not contain any such material. This brochure will
be reviewed by the NRC and FEMA to determine that it meets the planning
standard.
The DAEC Plan does not describe how the public information brochure
.
will be distributed to the public, but rather how it may be distributed.
A description of whr.t actually will be done must be specified in the
plan.
Planning Standard 50.47(b)(8) (Emergency Facilities and Equipment) (331/81-03-24)
The DAEC Plan does not adequately describe the habitability of the
.
TSC with regards to radiological conditions;
i.e., ventilation systems,
air filtration, and shielding factors.
The DAEC Plan does not describe how timely activation and staffing of
.
the facilities and centers described in the Plan will be accomplished;
i.e., EOF will be functional within one hour with a Senior manager
in charge as per the positions of Table B-1 in NUREG-0654. The means
for ensuring that this will be accomplished including a description
of the duty officer and pager system implemented to meet the design
objectives of Table B-1 must be included in the plan.
The Plan makes no reference to the existence of equipment designed
.
to measure hydrological and seismic parameters.
The DAEC Plan does not provide a map showing the locations of fixed
.
radiological monitoring equipment (i.e., air samplers and TLDs) and,
as a minimum, must meet the NRC Radiological Assessment Branch
Technical Position for Environmental Radiological Monitoring.
.
The Plan makes no provisions to include backup laboratory facilities
either fixed or mobile for handling high level radioactive samples
such as primary coolant or containment atmosphere in the event the DAEC
counting laboratory is lost due to loss of power or inhabitability.
The Plan does not commit to and provide for meteorological instrumenta-
.
tion which satisfies the requirements specified in NUREG-0737, Task
Item III.A.2.
The Plan does not specify how realtime representative
meteorological information from other sources will be obtained.
1
Appendix C
-8-
The DAEC Plan layout of the TSC does not specify where emergency
.
response personnel are located; e.g., Emergency Coordinator, Site
Radiation Protection Coordinator, TSC Supervisor, engineering and/or
technical staff members, and NRC representatives.
When commitments are fully implemented as required, the DAEC and IELP
.
Plans must be revised to reflect these char.ges;
e.g.,
installation of
post-accident monitoring and sampling, process monitors, high range
containment monitor, etc.
Planning Standard 50.47(b)(9) (Accident Assessment) (331/81-03-25)
Figure I-1 (Core Damage assessment graph) in the DAEC Plan has not
.
been developed. This must be done so that assessment of the degree
of core damage and potential radiological releases can be determined.
Section 2.4.1.b of the DAEC Plan does not address offsite dose rates
.
based on containment monitor readings and a potential for loss of
containment;
e.g.,
release of airborne containment activity due to
containment failure.
Planning Standard 50.47(b)(10) (Protective Response) (331/81-03-26)
The DAEC Plan does not specify the offsite locations for reassembly
.
if an evacuation of all non-essential personnel from the site is
required, such as during any Site Area or General Emergency. These
reassembly areas must be outside of the area occupied by any potential
radiological plume.
The DAEC Plan does not provide for radiological monitoring of people
.
evacuated from the site at the " designated reassembly area," or de-
contamination if required.
The DAEC Plan does not adequately describe when radioprotective drugs
.
such as potassium iodide (K1) will be administered. The Plan does not
state how or when a licensed physician will be contacted, or the means
by which onsite narsonnel who may be exposed to high airborne radioiodine
levels will rreelve KI.
The DAEC and IELP Plans do not address protective action recommendations
.
to offtite authorities based on potential radiological releases. Those
protective action recommendations specified in NUREG-0654, Appendix 1,
page 1-17 as a minimum must be included in the Plan regardless of whether
a release offsite is actually taking place.
The DAEC and IELP Plans do not establish a mechanism for recommending
.
protective actions to offsite authorities with regard to the ingestion
exposure pathway (50 mile EPZ). These recommendations should be con-
sistent with those of HSS/FDA regarding radioactive contamination of
_ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Appendix C
-9-
human food and animal feeds as published in the Federal Register of
December 15,1978 (43 FR 58790).
Procedures to assess this pathway
must be developed (i.e., public water intake restrictions, milk pathway
restrictions, and crop usage restrictions). See also Section 5.4.2.12
of the report.
The DAEC Plan does not include a map of preselected radiological
.
monitoring and sampling points.
This map must identify these sampling
and monitoring points in accordance with Table J-1 of NUREG-0654,
Revision 1.
The DAEC Plan is ambiguous in that it is not clear that all nonessential
.
. personnel will be evacuated to an offsite reassembly area for any Site
Area or General Emergency unless radiological conditions prohibit.
The basis for the choice of recommended protective actions;
e.g.,
.
sheltering vs. evacuation, have not been specified. This shall include
expected local protection afforded in residential units, as well as
evacuation time estimates.
Planning Standard 50.47(b)(11) (Radiological Exposure Control) (331/81-03-27)
Section K.2.1 of the DAEC Plan is unacceptable in that it contradicts
.
the EPA Emergency Worker and Lifesaving Activity Protective Action
Guides (EPA 520/1-75/001). This section of the Plan states that 12
rem may be received by participating individuals for any emergency
and 75 rem may be received to mitigate the consequences if there may
be a severe effect on the health of the public. Although the Plan
indicates emergency exposures may be received for recovering dead,
there is no such guideline (e.g., 10 CFR 20 requirements apply).
Only volunteers may receive exposures in excess of 10 C1'R 20 require-
ments during an emergency as follows:
(1) 75 rem for the saving of
human life, and (2) 25 rem for mitigating damage to vital equipment
or protecting the health and safety of the public. These emergency
exposure levels must be correctly described in the Plan. Further,
no emergency dose limits to the thyroid have been included. These
must also be included in the Plan.
Section K.2.5 is inadequate in that it does not describe the location
.
of the offsite decontamination centers. These centers would be neces-
sary if contamination were incurred during a site evacuation.
It is not
evident that the referenced Radiation Protection procedures, supplies,
extra clothing, etc.
are located at the offsite decontamination centers.
Planning Standard 50.47(b)(13) (Recovery and Re-entry Planning and Post-
accident Operations) (331/81-03-28)
Sections D.3.2 and D.4.2 of the IELP Plan specifies various functional
.
activities which are to be performed at the EOF; however, the individual
responsible for actually completing each activity has not been specified.
_ _ _ _ _ _ _ _ - _ _ _ _ - _
Appendix C
- 10 -
Section M.2.3 of the DAEC Plan does not adequately address the method
.
for periodically estimating total population exposure. The Plan should
describe the methodology used to determine the total man-rem exposure
based on releases or actual environmental measurements thru all path-
ways (i.e., ingestion pathway, submersion dose, ground dose, direct
exposure dose, drinking pathway, milk pathway, etc.).
Planning Standard 50.47(B)(14) (Exercises and Drills) (331/81-03-29)
Although Section E of the IELP Plan states that drills will be con-
.
ducted, no frequencies for these drills are given. The frequency for
each type of drill must be specified in this Plan.
Planning Standard 50.47(b)(15) (Radiological Emergency Response Training)
(331/81-03-30)
Section 0.2.1 of the DAEC Plan does not specify that onsite training
.
for offsite emergency response organizations will be offered at least
annually.
The DAEC Plan does not address indoctrination / training of site per-
.
sonnel responsible for the transmission of emergency information and
instructions (dedicated communicators), nor does it address the
training of all site personnel who do not have an emergency function.
These should be addressed in the Plan and provided at least annually.
Planning Standard 50.47(b)(16) (Responsibility for the Planning Efforts
Development, Periodic Review, and Distribution of Emergency Plans) (331/81-03-31)
The DAEC and IELP Plans do not specify that they will be updated as
.
needed, but rather specify every two years. This must be changed to
correct Plan deficiencies as they are identified rather than waiting
every two years.
Section P.2.9 of the DAEC Plan is aaibiguous in that it does not specify
.
who will conduct the independent review (audits), what management con-
trols will be implemented to correct audit findings, and who in the
IELP management will receive the results.
In addition, this section
does not specify that the results of the audit of the interface with
offsite agencies will be provided to those agencies in accordance with
10 CFR 50.54(t) requirements.
The DAEC Plan does not include in Appendix 5 a listing by title of all
.
procedures required to implement the Plan. Procedures regarding post-
accident sampling and onsite radiation protection although referenced
in the Plan are not included in Appendix 5.
All procedures, including
Radiation Protection Procedures that are referenced in the Plan must
also be included in this Appendix, and submitted to NRC in accordance
with 10 CFR 50, Appendix E requirements.
r-i.
Appendix'C
- 11 -
Planning Requirements of Appendix E,Section IV.E.9.d (331/81-03-32)
Neither Section F nor Section N.2.2.1 of the DAEC Plan, nor Section E-
.
of the IELP Plan addresses the requirement to test communications with
the NRC Headquarters and Region III Operations Centers from the TSC,
EOF, and Control' Room on a monthly basis.
Planning Requirements of Appendix E Section V'(331/81-03-33)
Implementing Procedures submitted to the NRC must be complete.(e.g.,
.
no pages left blank) with a statement indicating that material on the
appropriate pages is proprietary.
It is unacceptable to submit pages
marked proprietary without also including the material on the page
that is proprietary.
.
Appendix D
~
OPEN ITEMS
The following is a list of Open Items identified in the area of Emergency
Preparedness which must be re-examined and completed in accordance with
schedules set-forth in NUREG-0696 or NUREG-0737.
1.
Installation and testing of all needed assessment equipment such
as the Safety Parameter Display System (SPDS) and Reg.
Guide 1.97-
parameter displays must be complettd at the permanent Technical
Support Center (TSC).
(Section 4.1.1.2) (331/81-03-34)
2.
Installation and testing of the SPDS, dedicated communications
channels, and assessment equipment must be completed in the per-
manent Emergency Operations Facility (EOF).
(Section 4.1.1.4)
(331/81-03-35)
3.
Installation and testing of the post-accident primary coolant and
containment atmosphere sampling system is required.
(Sections 4.1.1.5
and 4.1.1.6) (331/81-03-36)
4.
Installation and testing of the post-accident gas, particulate, and
radioiodine effluent sampling system is required.
(Section 4.1.1.7)
(331/81-03-37)
5.
Installation, calibration, and development of EALs for the high
range containment radiation monitor is required.
(Section 4.2.1.2)
(331/81-03-38)
6.
Procedures must be developed and training conducted in regard to
the sampling and analysis of post-accident reactor coolant, station
effluents, and containment atmosphere using the systems described in
Sections 4.1.1.5 through 4.1.1.7.
(Sections 5.4.2.4 through 5.4.2.9)
(331/81-03-39)
7.
Establish and Implement a news media training program prior to
April 1, 1982, as outlined in Section G.2.5 of the DAEC Emergency
Plan.
(Section 6.3) (331/81-03-40)
!
,
-
CONTENTS
Page
1.0 ADMINISTRATION OF EMERGENCY PLAN .................................... 2
2.0 EMERGENCY ORGANIZATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
2.1 Onsite Emergency Organization .................................. 3
2.2 Augmentation of the Emergency Organization ..................... 5
2.2.1
Onsite Emergency Organization ........................ 5
2.2.2
Offsite Emergency Organization ....................... 6
3.0 TRAINING a nd RETRAINING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
3.1
Prog ram Es tablis hment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
3.2 Program Implementation ......................................... 9
4.0 EMERGENCY FACILITIES AND EQUIPMENT .................................. 10
4.1 Emergency Facilities ........................................... 10
4.1.1
Assessment Facilities ................................ 10
4.1.1.1
Co nt ro l Ro om . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
4.1.1.2
Technical Support Center (TSC) ............. 11
4.1.1.3
Operations Support Center (OSC) ............ 12
4.1.1.4
Emeegency Operations Facility (EOF) ........ 13
4.1.1.5
Post-accident Coolant Sampling and
Analysis ......................... ......... 14
4.1.1.6
Post-accident Containment Air Sampling
a nd Ana lys i s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
4.1.1.7
Post-accident Gas, Particulate, and Iodine
Effluent Sampling and Analysis ............. 14
4.1.1.8
Post Accident Liquid Effluent Sampling ..... 16
4.1.1.9
Offsite Laboratory Facilities .............. 17
4.1.2
Pro te c tive Fa cili ties . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
4.1.2.1
Assembly / Reassembly Areas .................. 17
i
,
4.1.2.2
Medical Treatment Facility ................. 18
4.1.2.3
Decontamination Facilities ................. 18
'4.1.3
Expanded Support Facilities .......................... 18
4.1.4
News Center .......................................... 19
4.2 Emergency Equipment ............................................ 20
4.2.1
-Assessment ........................................... 20
4.2.1.1
Emergency Kits and Survey Instrumentation .. 20
4.2.1.2
Area and Process Radiation Monitors ........ 21
-
4.2.1.3
Non-radiation Process Monitors'.............
21
4.2.1.4
Meteorological Instrumentation ............. 22
4.2.2
Protective Equipment ................................. 23
4.2.2.1
Respiratory Protection
.................... 23
4.2.2.2
Protective Clothing ........................ 24
4.2.3
Emergency Communications _............................. 24-
4.2.4
Damage Control / Corrective Action and Maintenance
Equipment and Supplie s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
4.2.5
Reserve Emergency Supplies and Equipment ............. 25
4.2.6
T ra nspo r ta tio n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
5.0 EMERGENCY IMPLEMENTING PROCEDURES ................................... 25
5.1
Ge ne ra l Conten t a nd Fo rma t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
5.2 Emergency, Alarm, and Abnormal Occurrence Procedures . . . . . . . . . . . 26 -
5.3 Implementing Instructions ...................................... 27
5.4 Implementing Procedures ........................................ 28
5.4.1
Notifications ........................................ 28
5.4.2
Assessment Actions ................................... 30
5.4.2.1
Of fsite Radiological Surveys . . . . . . . . . . . . . . . 32
5.4.2.2
Onsite Radiological Surveys . . . . . . . . . . . . . . . . 32
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5.4.2.3~
In plant Radiological Surveys .............. 33.
5.4.2.4 - Post-accident Primary Coolant Sampling ..... 33
5.4.2.5
Post-accident. Primary Coolant Analysis ..... 33
5.4.2.6
Post-accident Containment Air Sampling ..... 33
5.4.2.7
Post-accident Containment Air Analysis ..... 33
5.4.2.8
Post-accident Stack Effluent Sampling . . . . . . 34
5.4.2.9
Post-accident Stack Effluent Analysis . . . . . . 34
5.4.2.10 Liquid Effluent Sampling ................... 34
_
5.4.2.11
Liquid Effluent Analysis ................... 34
5.4.2.12 Radiological Environmental Monitoring
Prog ram (REMP) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
5.4.3
Protective Actions ................................... 35
5.4.3.1
Radiation Protection During Emergencies .... 35
5.4.3.2
Evacuation of owner-controlled Area ........ 36
5.4.3.3
Personnel Accountability ................... 37
5.4.3.4
Personnel Monitoring and Decontamination ... 37
5.4.3.5
Onsite First Aid / Rescue .................... 38
5.4.4
Security During Emergencies . . . . . . . . . . . . . . . . . . . . . . . . . . 38
5.4.5
Repair and Corrective Actions . . . . . . . . . . . . . . . . . . . . . . . . 38
5.4.6
Re c ov e ry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 9
5.4.7
Pu blic Info rma tion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
5.4.8
Fire Protection ...................................... 40
5.5 Supplemental Procedures ........................................ 41
5.5.1
Inventory, Operational Check, and Calibration of
Emergency Equipment and Supplies ..................... 41
5.5.2
Drills and Exercises ................................. 41
5.5.3
Review, Revision, and Distribution of Emergency Plan
and Procedures ....................................... 42
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F
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e
'5.5.4
Audit ................................................ 43
5.6- Human Factors Engineering .......................................44-
6.0 COORDINATION WITH OFFSITE GROUPS .................................... 45
6.1 O f f s i te Agenc ie s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
6.2' General Public and Transient Populations ....................... 47
-6.2.1
Information Distribution ............................. 47
6.2.2
. Prompt Notification of the Public .................... 48
6.3 News Media ..................................................... 49
7.0 DRILLS, EXERCISES, and WALK-THROUGHS ................................ 49
7.1 Drills and Exercises ........................................... 49
7.2 Walk-throaghs of Emergency Response Personnel .................. 49
8.0 LICENSEE ACTION ON PREVIOUSLY IDENTIFIED ITEMS RELATED TO
EMERGENCY PREPAREDNESS .............................................. 51
9.0 PERSONS CONTACTED ................................................... 51
10.0 EXIT INTERVIEW ...................................................... 52
iv