ML20040G255

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Forwards List of Outstanding Emergency Preparedness Items That Must Be Accomplished Before Favorable Finding Can Be Made on Emergency Preparedness Status
ML20040G255
Person / Time
Site: Zimmer
Issue date: 01/22/1982
From: Youngblood B
Office of Nuclear Reactor Regulation
To: Borgmann E
CINCINNATI GAS & ELECTRIC CO.
References
NUDOCS 8202120051
Download: ML20040G255 (10)


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PDR JYoungblood LPDR JAN 2 21982 IPeltier NSIC MRushbrook TIC TMcKenna ACRS (16)

Docket No.: 50-358 DEisenhut SHanauer RMattson Mr. Earl A. Borgmann JKramer Vice President, Engineering RVollmer The Cincinnati Gas and Electric Company Post Office Box 960 RHartfield, MPA l

Cincinnati, Ohio 45201 E

Dear Mr. Borgmann:

Subject:

Status of the Emergency Preparedness Review for the Zimer Nuclear Power Station Enclosed is a list of all the items that must be accomplished before a favorable finding can be made on the status of Emergency Preparedness for the Zimmer Nuclear Power Station.

In addition, as part of our continuing review of the Zimmer Emergency Plan, we have additional coments that must be addressed before the Emergency Plan can be found acceptable.

We plan to schedule a meeting with you in the near future to discuss a schedule for completing these items.

If you have questions regarding the enclosed, please contact Tom McKenna (301) 492-4531.

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.y Sincerely, d) 4 original signed by:

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REC 517ED O

q B. J. Your.sblood.

JAN 2 71982>

j B. J. Youngblood, Chief 9-c:e Esmu

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Licensing-Branch No. I Ec Division of Licensing c,

Enclosure:

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As stated

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omy NRC FORM 318 (INQ) NRCM 0240 OFFICIAL RECORD COPY usceo: - - m eeo

Mr. Earl A.. Borgmann Senior Vice President Cincinnati Gas & Electric Company Post Office Box 960 Cincinnati, Ohio 45201 cc: Troy B. Conner, Jr., Esq.

Deborah Faber Webb

' Conner, Moore & Corber 7967 Alexandria Pike 1747 Pennsylvania Avenue, N.W.

Alexandria, Kentucky 41001 Washington, D. C.

20006 Andrew B. Dennistn, Esq.

Mr. William J. Moran 200' Main Street General Counsel Batavia, Ohio 45103

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Cincinnati Gas & Electric Company Post Office Box 960 George E. Pattison, Esq.

Cincinnati, Ohio 45201 Clermont County Prosecuting Attorney 462 Main Street Mr. Samuel H. Porter Batavia, Ohio 45103 Porter, Wright, Morris & Arthur 37 West Broad Street Mr. Waldman Christianson Columbus, Ohio 43215 Resident Inspector /Zimmer RFD 1, Post Otfice Box 2021 Mr. James D. Flynn, Manager U. S. Route 52 Licensing Environmental Affairs Moscow, Ohio 45153 Cincinnati Gas & Electric Company Post Office Box 960 Mr. John Youkilis Cincinnati, Ohio 45201 Office of the Honorable William Gradison David Martin, Esq.

United States House of Representatives Office of the Attorney General Washington, D.

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20515 209 St. Clair Street First Floor Timothy S. Hogan, Jr., Chairman Frankfort, Kentucky 40601 Board of Commissioners 50 Market Street, Clermont County James H. Feldman, Jr., Esq.

Batavia, Ohio 45103 216 East 9th Street Cincinnati, Ohio 45220 Lawrence R.'Fisse, Esq.

Assistant Prosecuting Attorney W. Peter Heile, Esq.

462 Main Street Assistant City Solicitor Batavia, Ohio 45103 Room 214, City Hall l

Cincinnati, Ohio 45220 Mr. Jame's G. Keepler U. S. NRC, Region.III l

John D. Woliver, Esq.

799 Roosevelt Road l

Legal Aid Security Glen Ellyn, Illinois 60137 Post Office Box #47 550 Kilsore Street Bata'via, Ohio 45103 O

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OUTSTANDING EMERGENCY PREPAREDNESS ITEMS FOR THE ZIft!!ER NUCLEAR POWER STATION (1) Submit the final State and local emergency response plans in accordance with 10 CFR 50.33.

This should include the plans for the States wholly or partially within the ingestion pathway EPZ.

(2) Receive and review FEMA findings and determinations as to whether the State and local emergency response plans are adequate.

(3) Correct the deficiencies identified in the November 12, 1981 letter to the applicant and address the enclosed comments to ensure conformance with the standards in 10 CFR 50.47(b).

(4)

Complete an onsite appraisal and correct any deficiencies that indicate the applicant's plan cannot be implemented.

(5)

Correct the deficiencies identified during the November 18, 1981-exercise.

(6) Provide supporting information for the evacuation time estimate study.

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COMt!ENTS ON ZIlttiER NUCLEAR POWER STATION EMERGENCY PLAN Protective Action Decisionmaking In accordance with 10 CFR 50, Appendix E. IV, (D)(2)' the Plan must demonstrate that State / local officials have the capability to make a public notification decision promptly (within 15 minutes for situations requiring urgent action). The Plan must identify each step in the protective action decisionmaking chains, the authority of the decision makers, their backups, provision for backup communication, and the basis on which they will make decisions to demonstrate that the requirements of 10 CFR 50, Appendix E are addressed.

This description must be reflected in the appropriate State and local plans or be supported by letters of agreement.

NUREG 0654-Table B-1 Specify all of the functions to be performed by the CAS operator as

" Communicator" and discuss why these functions will not interfer with the performance of his normally assigned duties.

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. Public Notification System In accordance with the revision of 10 CFR 50, Appendix E. IV(D)(3)

[46 FR 63032] the applicant must conduct a test of the prompt notification system and correct any deficiencies identified. Provide, along with the description of the system in the Plan, the results of this test that denonstrates that the design objective of the system has been met.

Emergency Information Handbook (Circle of Safety)

The handbook should be expanded to include: a discussion of methods of improvised respiratory protection, site specific evacuation maps, and a discussion of the physical form of releases (e.g., gas) and its relationship to recommended protective actions that demonstrate the improtance of taking the actions recommended.

Dose Assessment Specify the assumptions on which the offsite dose projection metheds will be based.

Describe the job aids that will be used to perform offsite dose projections and alternates 1, 2, 3, and 5 discussed on page 6-5 of the Plan.

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. EALs Revise, clarify, and supplement the EALs in Section 4 of the Plan or provide a rational for not taking these actions in order to address the following comments:

General Address the comments concerning the following EALs found in NUREG-0818, " Emergency Action Levels for Light Water Reactors" Unusual Event 1, 2, Alert 2, 7, 11, 12, Site Area 2, 6, 10, 11, 14, 15 and General 3

Provide CAls for the following NUREG-0654, Appendix 1, Example Initiating Conditions:

Unusual Event 4,

Alert 4, 16, Site Area 8, and General Energency Example BWR Sequences 6.b. 6.c and 6.d Discuss the method used to present the EAls to the Control Room staff to demonstrate that a system has been established that allows rapid accurate classification of events.

This should include a description of the job aids used and provisions to

s s have the system tested by the Control Room staff to demonstrate workability.

Specific Comments on Plan EAls Alert 5 Can any of the specified DC systems be considered vital if so change the operator (s) to an "or".

Revise this EAL to address the condition specified in Alert 9 NUREG-0654.

Clarify the following:

Alert 10 "Some spurious annunciation may occur".

Clarify the use of the "and/or" operator.

Alert 11 Site Area 1 -

Clarify how the EALs specified (1, 2, and 3) are used -

provide "and", "or" operators.

Site Area 9 - Provide the assumption used to develop Figure B1 and its relationship to the specified dose rates.

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Provide EALs that relate to the lower limits of the EPA PAGs based on effluent monitor reading, and field monitor resul ts. This must include the default release duration to be used in calculation of dose.

General 1 -

What are the assumptions used to' develop Figure B-1?

Provide EALs for the upper limits of the EAP PAGs.to include a default relene duration' to be.used in

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calculation of dose.

's Provide EAls for field monito'~ri f [sults.

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General 2 -

Provide an EAL for Loss of Containmenf-and Lots 'of

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Primary Coolant Bo~undary.

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Provide an EAL based on rea,ctor water level (below /

b for X minutes). ',.

I Address all containment failure modes (steam explosion, 1

failure to isolate).

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EAL 1 All transients should be addressed, not just loss o'f'AC.

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EAL'2 Specify the. indicators that containment cooling is-not functioning (pressure /

temperature) in addition' to activation of-the system.

Address failure of the ECCS (e.g., water level below h for X minutes).

Address failure of the containment sufficiently to affect long term operation of the ECCS.

EAL 3 What is the relationship of Alert 8 to a General Emergency Condition?

ATWS must be specifically addressed.

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Emergency Response Facilities The Zimmer Emergency Response Facility (ERF) design plan is still under review.

However, the evaluation to-date indicates that

' inadequate infonnation has been provided for the ERF design with regard to: L The Technical Support Center,~ including layout, information systems a.

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The Operational Support Centers overall description and features.

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The' Emergency Operations Facility, including location, structure, layout and features, d..

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The interface of emergency functions with the Control Room.

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The hardware and software specifications, data set, layout, r#

communications and syst'em operations for the data acquisition h

s syster for the ERF's.

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