ML20041B635

Forwards Public Version of Draft Responses to NRC 811221 Ltr Re Facility Emergency Plan.Responses Will Be Incorporated Into Amend to FSAR

ML20041B635
Person / Time
Site:	Perry
Issue date:	02/15/1982
From:	Davidson D CLEVELAND ELECTRIC ILLUMINATING CO.
To:	Schwencer A Office of Nuclear Reactor Regulation
Shared Package
ML20041B634	List: ML20041B635
References
NUDOCS 8202240425
Download: ML20041B635 (96)

Text

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P O. Box 5000 e CLEVELAND. oHto 44101 e TELEPHONE (216) 622-9800 e ILLUMINATING BLDG. e 55 PUBLIC SoVARE Dalwyn R. Davidson viCE PAESICENT SYSTEu ENGINEERING AND CONSTAUCT:ON

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6 February 15,1982[1- .J q y

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'7 Mr. A. Schwencer, Chie* "h[/S;'./0,

Licensing Branch No. 2 y#A f,,,,.g0, %

Division of Licensing ,

g U. S. ?Melear Regulatory Con =ission 9, D

'4ashington, D. C. 20555 fj 5g g w Perry :helear Power Plant Docket Nos. 50 hh0; 50 hkl Response to Request for Additional Infcz=ation -

Energency Plan ___

Dear Mr. Schwencer:

This letter and its attachnent is subnitted to provide draft responses to the concerns identified in your letter dated December 21, 1901, regarding Perry's Energency Plan.

It is our intention to incorporate these responses in a sub-sequent anendment to our Final Safety Analysis Report.

Very 'Druly Yours,

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Dalwyn F.. Davidson Vice President System En61neering and Ccustruction DRD: nlb VO A

DI cc: Jay Silberg, Esq. f John Stefano Max Gildner, IEC Resident Inspector //

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d QUESTION A.1.c. Provide a block diagram illustrating the interrelationships of State, local, Federal and private sector organizations with the Perry Nuclear Power Plant. Figure 5.3 shows only the licensee's organization, not the total effort.

RESPONSE

A.1.c. The requested block diagram will be developed and included in a later amendment to the Emergency Plan. 'Ihe local County Plans are currently being developed. Once these plans are available, the Emergency Plan will be amended to include the requested block diagram.

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QUESTION A.1.d. Identify a specific individual by title that is in charge of the emergency response for each organization, l RESPONSE 4

A.1.d. The title of the individual in charge of emergency response for the Perry Nuclear Power Plant is the Recovery Director.

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i QUESTION A .1. e . Describe the provisions for 24-hour-per-day emergency response manning of communications for offsite organizations.

In addition, explain the meaning of the "Willoughby/ Cleveland and CEI Connections".

RESPONSE

A .1. e . The communications to be used for emergency response are currently being re-evaluated. When the plans are finalized, the Emergency Plan will be amended.

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o QUESTION A.3 Provide written letters of agreement for each offsite support organization. These letters of agreement should include concepts of operation, specific support commitments, authorities, responsibilities, and limits on actions of each, contractor, private organization, and local service support group. In addition:

1. The following letters of agreement are out-dated:

a. Radiation Management Corporation August 4, 1978;

b. Lake County Memorial Hospital May 21, 1974;

c. Painesville Ohio County Sheriff September 24, 1974; and

d. U. S. Coast Guard September 23, 1974.

2. The letter of agreement with the Perry Township ambulance and fire department is not dated.

3. A letter of agreement is needed with: ,

a. The University of Pennsylvania Radiation Medical Center Hospital;

b. NSSS Vendor;

c. Ohio State Agencies;

d. Gilbert Associates Inc.; and

e. General Electric

RESPONSE

A.3 Efforts will be beginning in the near future to obtain new letters of agreement. It is intended that these new letters will contain thd information requested. When the new letters are obtained, they will be included in Appendix B to the Emergency Plan.

9 QUESTION A.4 Provide evidence that each principal organization is capable of continuous (24-hour) operation for a protracted period.

RESPONSE

A.4 The shift staffing of PNPP normally provides 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> operations and as such will continue to operate the plant with normal shift rotation. The augmented staff will have sufficient, trained alternates, for each of the key positions described in the Dmergency Plan (sections 5.2.2 and 5.2.4) to provide continuete coverage for a protracted period.

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QUESTION B.2 Verify that the Plant Manager or his altornate has the authority to unilaterally initiate any emergency actions including providing protective action recommendations to offsite authorities.

RESPONSE

B.2 he Emergency Duty Officer or the Interim Emergency Duty Officer has the authority to unilaterally initiate emergency actions including providing protective action recommendations to offsite authorities. This statement will be added to Section 5.2.4 in the next amendment to the Emergency Plan.

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QUESTION B.3. Describe the line of succession and identify the specific conditions for higher level officials assuming the function i of Emergency Coordinator.

RESPONSE

B.3. The Emergency Coordinator discussed in NUREG 0654 is the Emergency Duty Officer described in the Emergency Plan. The line of succession for the position is:

1. At the onset of an emergency, the Shift Supervisor assumes the position of the Interim Emergency Duty Officer.

2. When the designated Dnergency Duty Officer arrives, i the Shift Supervisor is relieved of this responsibility.

e. When the Emergency Coordinator (as defined in the Emergency Plan) arrives, the responsibility for recommendations to offsite authorities is removed from the Emergency Duty Officer and transferred to the Emergency Coordinator.

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QUESTION B.4. Clearly define the responsibilities of the Plant Manager or his alternate that may not be delegated, i.e., the decision to notify and to recommend protective actions to authorities responsible for offsite emergency measures.

RESPONSE

B.4. The decision to notify and to recommend protective actions to authorities responsible for offsite emergency measures is the responsibility of The Emergency Duty Officer. This responsibility may not be delegated but it does pass from the Dmergency Duty Officer as higher level company officials assume their positions. This line of succession is described in response to Question B.3.

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4 QUESTION l

B.S. Specify how minimum staffing requirements, as per Table B-1 of the criteria, will be established. A total augmentatien plan should also be established showing, the 30 and 60 minute augmentation schedule. Augmentation plans should also address provisions for inclement weather.

RESPONSE

B.S . Section 5.1.3 of the Emergency Plan will be amended to read:

5.1.3 NORMAL PLANT SHIFT STAFFING

, The plant is continuously manned with a minimum shift complement consisting of the following:

1 Shift Supervisor (SRO Licensed) 1 Unit Supervisor (SRO Licensed) ,

2 Supervising Operators (RO Licensed) 1 Perry Plant Operator 1 Perry Plant Attendant 1 Radwaste Technician 1 Health Physics Technician 1 Chemistry Technician 1 I&C Technician 1 Shift Technical Advisor The augmentation schedule is shown in Table 5-1. The times listed in Table 5-1 represent the maximum times expected for augmentation during most conditions. The 30 and 60 minute augmentation times are the goals toward which the augmentation plan described in Section 7.3.2 has been designed.

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0 QUESTION B.6. Specify the interfaces between onsite functional areas of emergency activity, licensee headquarters support, local services support, and State and local government response

organization. Clearly illustrate these interfaces with a block diagram, the block diagram provided does not clearly show the offsite interfaces.

RESPONSE

B.6. Local County Emergency Plans are not as yet completed.

When they are finalized, the requested block diagram will be developed and included in an amendment to the Emergency Plan. l I

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O QUESTION B.7. Identify the corporate management and administrative and technical support personnel, by title, that will augment the plant staff. The plan does not clearly show all the support that will be received.

RESPONSE

B.7. Management support will be provided by the Vice President, System Engineering and Construction. Administrative support will be provided by the Perry Project Services Department Manager. Technical support will be provided by the Nuclear Engineering Department Manager.

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i j QUESTION B.8. Identify the services to be provided by local agencies.

Submit copies of the arrangements and agreements reached.

, These agreements should delineate the authorities, responsibilities and limits on the actions of the contractor, private organizacion and local se.rvices j support groups.

RESPONSE

B.8. Same as A.3.

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O QUESTION C .1.a . Identify specific persons, by title, authorized to request Federal assistance, Section 5.6.6 does not provide this information.

RESPONSE

C .1. a . The Dnergency Plan will be amended to indicate that the Emergency Coordinator is authorized to request Federal assistance.

QUESTION C.1.b. Submit provisions for incorporating the Federal response and capability into emergency operatioas (i.e. , Department of C .1.c . Energy). The plan should specify the Federal resources expected for accident categories in Appendix 1 of the criteria, including expected times of arrival at the site.

Specific licensee resources as needed to support the Federal response should be listed in the plan, e.g. ,

command posts, telephone lines, radio frequencies and telecommunications centers.

RESPONSE

C.1.b. The resources expected and the provisions for incorporating and Federal response capabilities have not yet been determined.

C .1.c . It is currently expected that this will be accomplished by September 1, 1982.

1 QUESTION 4

] C.2.b. Specify the provisions for dispatching a representative to principal offsite government Emergency Operations Centers (EOC), this is not clearly identified in Section 5.2.4 or Figure 6.1.

RESPONSE

i C.2.b. This is considered to be a part of Public Information and Local County Planning and as these plans are not completed, this inf ?rmation is not available now. When the County

, Emergency Plans and the Public Information Program are completed, the provisions for dispatch of a representative to

Offsite Emergency Operations Centers will be clarified in the Emergency Plan. The specific provisions for dispatching a representative will be delineated in Implementing Procedures.

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l j QUESTION C.3. Identify available radiological laboratories, their

capabilities and the response times expected during an emergency (i.e. , vendors , universities, private laboratories, etc.). The information provided for the EOF is insufficient to determine this facility could be j used as a backup laboratory.

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RESPONSE

C.3. Since the last amendment to the Emergency Plan, the plans for a backup laboratory have changed. The Technical Support Center has been designed to include a backup laboratory.

Provisions will be made to enable this laboratory to be expeditiously set up to do analysis if the normal laboratories l become unavailable.

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QUESTION C.4. Provide a copy of the mutual aid agreement with other nuclear facilities.

RESPONSE

C.4. The mutual aid agreement will be included in the next amendment to the Emergency Plan. A copy of this agreement is attached for information.

I MUTUAL ASSISTANCE AGREEMENT BETWEEN CONSUMERS POWER COMPANY.

THE DETROIT EDISON COMPANY, THE TOLEDO EDISON COMPANY, THE CINCINNATI GAS & ELECTRIC COMPANY, AND THE CLEVELAND ELECTRIC ILLUMINATING COMPANY ,

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0.1 The Consumers Power Company, a Michigan corporation; The i

Detroit Edison Company, a Michigan and New York corporation; The Toledo Edison Company, an Ohio corporation; The Cincinnati Gas & Electric Company, an Ohio ~ corporation; and T'he Cleveland Electric Illuminating Company, an Ohio cor-poration,

! WITNESSETH 0.2 WHEREAS, Consumers Power Company and The D'etroit Edison Company own electric facilities, including nuclear generating stations, and are engaged in the generation, transmission, distribution and sale of electric power and energy in Michigan; and 0.3 WHEREAS, The Toledo Edison Company, The Cincinnati Gas &

Electric Company and The Cleveland Electric Illuminating Company own electric f acilities, including nuclear generating stations, and are engaged in the generation, transmission, distribution, and sale of electric power and cnergy in Ohio; and 0.4 WHEREAS, the parties desire to help assure the availability

! of adequately trained and experienced emergency personnel in

> the event of an emergency situation at any of their nuclear generating stations; 0.5 NOW, THEREFORE, in consideration of the promises and mutual covenants herein set forth, the parties agree as follows:

' ARTICLE I DEFINITIONS 1.1 " Alert" shall be defined as a situation in which events are i in process or have occurred which involve an actual or poten-tial substantial degradation of the level of saf ety of the plant.

1.2 " Emergency" shall be defined consistent with the definition of " site area emergency" as set forth in NUREG 0654 as a l situation in which events are in process or have occurred which involve actual or likely major failures of plant func-tions needed for protection of the public.

l 1.3 " Requesting party" shall be defined as any party to this Agreement who, upon the occurrence of an emergency at one of its nuclear generating stations, seeks emergency assistance, pursuant to this Agreement, from one or more of the parties hereto.

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. 1.4 " Responding party" or " responding parties" shall be defined as any party or parties to this Agreement who are presented with a request for emergency assistance pursuant to this Agreement.

ARTICLE II REQUESTS FOR EMERGENCY ASSISTANCE 2.1 In the event of an alert at one of its nuclear generating stations, any party to this Agreement may notify any or all of the other parties that an alert exists and that their emergency assistance may be required.

2.2 In the event of an emergency at one of its nuclear generating stations, any party to this Agreement may request emergency assistance from any or all of the other parties.

2.3 Requests for emergency assistance shal1 beimade between and among the following party personnel: -

Consumers Power Company - Vice President Nuclear Operations The Detroit Edison Company - Vice President Nuclear Operations The Toledo Edison Company - Vice President - Nuclear The Cincinnati Gas & - Senior Vice President Electric Company The Cleveland Electric - Vice President Illuminating Company System Engineering &

Construction ARTICLE III EXCUSED FAILURE TO RESPOND 3.1 Failure to respond to a request for emergency assistance pur-suant to this Agreement shall be excused if, in order to respond, the requested party or parties would be forced in its or their sole judgment or judgments to:

3.1.1 Violate its duties relating to the care and staffing at its own nuclear generating stations; or 3.1.2 Jeopardize the public health or safety at a loca-tion other than the location of the requesting party's emergency.

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ARTICLE IV SCOPE OF ASSISTANCE I 4.1 If requested under this Agreement, the responding party or I parties will provide trained and experienced personnel to perform off-site radiation protection activities to the requesting party as those persons may be available to the responding party up to a maximum of six (6) such persons.

All equipment intended for use by the responding personnel, except personal dosimeters and certification documents (such as certifications of Health Physics training, instrument training and dose exposure records), shall be the respon-sibility of the requesting party to provide. The responding party or parties may use their own equipment if agreeable to the requesting party. However, use by the responding party or parties of their own equipment shall in no way alter the duties and obligations imposed upon the parties by this Agreement. -

4.2 Emergency assistance provided by the responding party or parties shall continue until their personnel are relieved by the requesting party, the Federal or State emergency teams, 3 or by the need of the responding party to answer an emergency at its own facilities. In no event shall such assistance be required for a period in excess of two (2) weeks for any one emergency including transportation time to and from the loca-tion of the emergency.

4.3 Exposure to personnel provided by the responding party or parties shall be limited to off-site radiation, and such exposure shall be kept as low as practicable.

4.4 Wages, hours and other terms and conditions of employment applicable to loaned personnel shall be those of the party providing such personnel. .

4.5 Personnel provided by the responding party or parties shall, at all times during the period in which emergency assistance is being provided, continue to be employees of the responding party or parties and shall at no time and for no purpose be deemed employees of the requesting party.

ARTICLE V REIMBURSEMENT FOR EMERGENCY ASSISTANCE RENDERED 5.1 The requesting party shall reimburse each responding party for all costs and expenses incurred by each responding party in providing emergency assistance hereunder. Such costs and expenses shall include.

5.1.1 Salaries and wages paid to loaned personnel (including supervisors) for paid time spent in the

, requesting party's service area, and paid time for travel to and from such service area; 5.1.2 A percentage of the total of such wages and salaries, as determined by the responding party, reflecting expenses incurred for:

5.1.2.1 Compliance with Worker's Compensation laws; 5.1.2.2 Payroll taxes; 5.1.2.3 Hospitalization, surgical and medical coverage; 5.1.2.4 Pensions and life insurance; 5.1.2.5 Vacation, holiday and sick pay; 5.1.2.6 Travel accident insurance; 5.1.3 Transpurtation to and from the requesting party's service area, including the cost of travel accident insurance purchased expressly for coverage during such transportation; 5.1.4 Food and lodging; 5.1.5 Personal expenses specifically agreed to between the requesting and responding parties; 5.1.6 Charges, at the rates internally used by the responding party, for the use of transportation equipaent and other equipment requested; and 5.1.7 Any further costs specifically agreed to between the requesting and responding parties..

c.i All time sheets and work records pertaining to loaned person-nel shall be maintained by the responding party.

5.3 All charges shall be paid by the requesting party to each responding party within ten (10) days after receipt of an invoice, itemized to the satisfaction of the requesting party.

ARTICLE VI INDEMNIFICATION 6.1 The requesting party shall indemnify and hold harmless each responding party from and against any and all liability for loss, damage, cost or expense which the responding party shall incur by reason of bodily injury, including death, to l

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any person or persons, or by reason of damage to or destruc-tion of any property, including the loss of use thereof, arising out of or in any manner connected with the giving of emergency assistance to the requesting party.

6.2 In the event of bodily injury, including death, to any employee of the responding party, or in the event of damage to or destruction of any property of the responding party, the requesting party shall indemnify the responding party for such loss in the following manner:

6.2.1 If such loss is covered by an insurance policy purchased by the responding party from a third party carrier, the requesting party shall make reimbursement to the extent such losses increase the responding party's insurance costs, whether such increase in costs occurs in the form of an increase in premiums, or in the form of a reduction in dividends or premium refunds,.or both; 6.2.2 If such loss is not covered by an insurance policy purchased by the responding party or exceeds such coverage, the requesting party shall make reimbur-sement to the extent of the claims or benefits actually paid or the losses sustained by the responding party.

ARTICLE VII MODIFICATION 7.1 At any time after the date of this Agreement any party, by giving not less than thirty days written notice to the other parties, may from time to time call for reconsideration of the terms and conditions of this Agreement. If such recon-sideration is called for, the authorized representatives of the parties shall meet as promptly as convenient and discuss any of the terms and conditions of this Agreement. No party shall be under any obligation to agree to any modification or supplement not satisfactory to it. Any agreement modifying or supplementing such terms and conditions shall be in writing, signed by all parties, and shall specify the date such modification or supplement shall become effective.

ARTICLE VIII PLAN EXERCISING 8.1 The parties agree to provide, at their own expense, personnel to observe or assist in demonstrating the effectiveness of a nuclear generating station's emergency plan as may be required by that nuclear generating station's NRC approved emergency plan.

ARTICLE IX TERM OF AGREEMENT l

9.1 This Agreement shall be for a term of one (1) year and from year to year thereafter unless and until terminated as pro-vided for in Section 9.2 below.

9.2 Any party, upon sixty (60) days prior written notice to all other parties, may terminate this Agreement at the expiration of any successive one (1) year term.

IN WITNESS WHEREOF, the parties hereto cause this Agreement to be j executed by their duly authorized officers on duplicate original pages attached hereto and made a part hereof.

CONSUMERS POWER COMPANY THE CINCINNATI GAS & ELECTRIC COMPANY By: By:

Title:

Title:

Date: Date:

THE DETROIT EDIS0N COMPANY THE CLEVELAND ELECTRIC ILLUMINATING COMPANY f .') { /

By: By: / .' / %, , , / .~ , m

Title:

Title: A /, ,, 4 "

Date: Date:  : /.? > /-

THE TOLEDO EDIS0N COMPANY By:

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Date:

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ARTICLE IX TERM CT AG.IEEMENT 3.1 This Agreement shall be for a term of one terminated (1) year and from as pro-year to year thereafter unless and until vided for in Section 9.2 below.

9.2 Any party, upon sixty (60) days prior written notice to all other parties, may terminate this Agreement at the expiration

- of any successive one (1) year term.

N WITNESS WHEREOF, the parties heretc cause this Agreement to be executed by their duly authorized of ficers on duplicate original R pages attached hareto and made a part here'of.

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• THE CINCINNATI GAS & ELECTRIC *

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Vice President for Nnal===

• Operations Ef fective Date: Date:

• In case of any conflict between this Agreement and the INPO Fixed Facility Emergency Response

Voluntary Assistance Agreement executed by Cons'umers as of August 1,1981, the INPO Agreement

• • THE CLEVELAND ELECTRIC 8E9EDETROITEDISONCOMPANY ILLUMINATING COMPANY By: By:

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Title:

Title:

Date: Date:

THE TOLEDO EDISON COMP ANY By: -

Title:

Date:

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J ARTICLE IX

, TERM OF AGREEMENT 9.1 This Agreement shall be for a term of one (1) year and from year to year thereafter unless and until terminated as pro-vided for in Section 9.2 below.

9.2 Any party, upon sixty (60) days prior written notice to all other parties, may terminate this Agreement at the expiration of any successive one (1) year term.

IN WITNESS WHEREOF, the parties hereto cause this Agreement to be executed by their duly authorized of ficers on duplicate original pages attached hereto and made a part hereof.

CONSUMERS POWER COMPANY THE CINCINNATI GAS & ELECTRIC COMPANY By: By:

Title:

Title:_

Date: Date:

THE DETROIT EDIS0N COMPANY THE CLEVELAND ELECTR'IC

, ILLUMINATING COMPANY

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J, a By:

Tit 1e. Vic Presiden el- Operationsii tI e :

Date: March 11, 1981 Date:

G l THE TOLEDO EDISON COMPANY By:

Title:

1 Date:

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, ARTICLE IX TERM 0F AGREEMENT 9.1 This Agreement shall be for a term of one (1) year and from year to year thereaf ter unless and until terminated as pro-vided for in Section 9.2 below.

9.2 Any party, upon sixty (60) days prior written notice to all other parties, may terminate this Agreement at the expiration of any successive one (1) year term.

IN WITNESS WHEREOF, the parties hereto cause this Agreement to be executed by their duly authorized officers on duplicate original pages attached hereto and made a part hereof.

CONSUMERS POWER COMPANY THE CINCINNATI GAS & ELECTRIC COMPANY By: By:

Title:

Title:

Date: Date:

THE DETROIT EDIS0N COMPANY THE CLEVELAND ELECTRIC ILLUMINATING COMPANY By: By:

Title:

Ti tl e :

Date: Date:

THE TOLEDO EDISON COMPANY By: '

/R. /P. Crmise b __ _

Title:

Vice President, Nuclear Date: April 1,1981 1

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ARTICLE IX TERM 0F AGREEMENT 9.1 This Agreement shall be for a term of one (1) year and from year to year thereafter unless and until terminated as pro-vided for in Section 9.2 below.

9.2 Any party, upon sixty (60) days prior written notice to all other parties, may terminate this Agreement at the expiration of any successive 0ne (1) year term.

IN WITNESS WHERE0F, the parties hereto cause this Agreement to be executed by their duly authorized officers on duplicate original pages attached hereto and made a part hereof.

CONSUMERS POWER COMPANY THE CINCINNATI GAS & ELECTRIC COMPANY g-By: By: e f( .-

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Title:

Title: Sn.17CE PP.EEEDENT Date: Date: May 26, 1981 THE DETROIT EDISON COMPANY THE CLEVELAND ELECTRIC ILLUMINATING COMPANY By: By:

Title:

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Date: Date:

THE TOLEDO EDISON COMPANY By:

Title:

Date:

QUESTION D .1 . Provide comprehensive parameter values and/or equipment status for all emergency action levels and initiating conditions for each emergency classification. The

following example initiating conditions

Alert: Initiating Conditions 4, 9 and 18(d).

Site Emergency: Initiating Conditions 9, 13(a), 13(b), 16(c).

For site emergency initiating condition 14 and general smergency initiating condition 3, dealing with loss of physical control of the facility, the plan addresses this only as a result of a physical attack.

For those initiating conditions associated with technical specification limits, the plan indicates that the limits will be supplied at a later date, but no committment is given for exactly when they will be supplied. ,

RESPONSE

D .1 . The parameter values and/or equipment status initiating conditions for each emergency action level are currently being re-evaluated with respect to NUREG-0818 Emergency Action Levels for Light Water Reactors. Table 4-1 " Summary of Dnergency Action Levels" will be changed as necessary in the next amendment to the Emergency Plan.

Regarding site emergency initiating condition 14 and General Emergency initiating condition 3, addressing these as a physical attack is consistent with NUREG-0818, therefore these will not be changed.

It is expected that approved technical specifications will be available 3 to 6 months prior to fuel load at which time the Dmergency Plan will be amended to include the approved limits.

- CUESTION D.3 Demonstrate that state and local organi::ations have procedures providing for emergency actions consistent with those recoc: mended by the Perry nuclear facility.

RESPONSE

D.3 This criteria of NUREG-065h is not required to be addressed in the PNPP E=ergency Plan. The State of Ohio Radiological E=ergency Response Plan has been tested twice, and evaluated by the Federal Emergency Management Agency within the requirements of NUREG-0654. In each case, the plan was found to be adequate to provide for the protection of the public health and safety. The offsite emergency response plans for the Local Counties are being prepared, and win be in concert with the state plan, and will be tested to insure that the fundamentals of public health and safety are both in the plan and can be implemented.

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QUESTION E .1 . Describe the procedures for message authentication and verification, this is not clearly specified in Section 6.1.

1 RESPONSI E .1 . The procedures for message authentication and verification have

not been established. When t.he local county emergency plan i

procedures are developed, this procedure is expected to be included.

It is anticipated that verification will be by a return call from the local government to the Shift Supervisor.

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QUESTION E.2. Describe the provisions for followup messages from the facility to offsite authorities, this is not clearly specified in Section 6.1.

RESPONSE

E.2. When section 7.3 of the Emergency Plan is amended to reflect the finalized communications system plans the provisions for followup messages will be specified.

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QUESTION J .

E.3. Provide, in the plan, the established contents of the initial and and followup emergency messages sent from the plant. These i E.4. messages shall contain information about the class of l emergency, whether a release is taking place, potentially

> affected population and areas, whether protective measures are necessary. The basic form and content must be provided in the plan in addition to the implementing procedures.

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RESPONSE

See response to E.2. It is currently intended that the form I E.3.

and for initial and followup messages will be the Emergency Nuclear E.4. Incident Essential Information Form, Figure II-D-4 of the State of Ohio Nuclear Power Plant Emergency Response Plan. A copy of which is attached.

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Figura 4 NUCLEAR POWER STATION Emergency Nuclear Incident Essential Information Part.I:

A. Date: Time: Sheet No.:

B. Time Release started or is expected to start:

C. Wind Direction: to the D. Wind speed: m/sec E. Noble gas release rate: Ci/sec F. Unit vent flow: cc/sec G. Stability class:

H. Expected duration of release:

I. Radioiodine release rate: Ci/sec Part II:

A. Sector (s) are involved out to miles

8. Wind direction persistance:

C. Projected: whole body dose .

thyroid dose Note: Before acting upon the above information, reverify the information and ensure that all assumptions being made are known by the utility, State and local officials.

D. Classification of incident (unusual event, alert, site emergency, or general emergency):

E. Facility recommendations (stay inside or evacuate / distance):

F. Weather conditions (precipitation):

Part III:

A. Plant condition:

B. Cause of incident:

Note: When disseminating information during an actual event, if a space is skipped, insert "will follow" to indicate that there has not been a mistake 2nd that the information will Se forwarded as seca as cossit'e.

Ficure II-D-4

QUESTION E.6. Co==it that a precpt Alerting and Notification System

, meeting the design objectives of NUREG 0654, Rev.1, Appendix 3 will be developed and in place before fuel load. The plan should address the administrative and physical means, and the time required to promptly notify the public of an emergency. The plan should coc:mit to the establishment of such a system and indicate when the system will be operational.

RESPONSE

E.6. A prompt Alerting and Notification system meeting the design objectives of NUREG C654, Rev.1, Appendix 3 will be in place before fuel load at PNPP. The PNPP E=ergency Plan, FSAR Chapter 13, Appendix A, 411 be amended to incorporate this commitment.

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t QUESTION E.7. Provide for written messages intended for the public consistent with the licensee's classification scheme.

Messages to the public giving instructions regarding specific protective actions to be taken by occupants of affected areas should be included in the plan.

RESPONSE

E.7. Due to the fact that the Local County Plans are not as yet completed, the specifics of the Public Infor1 nation Program are not available. It is intended that the Public Information Program will be a cooperative effort of the State, Local Counties and the Licensee. When the information is available it will be provided.

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QUESTION F. EMERGENCY COMMUNICATIONS The provision for communications as described in the pir.a is insufficient to meet the objectives of the criteria. The plan should include information to describe:

F .1 . The organizational titles and alternates for both ends of the communications link.

F.1.a. Specify how State, local and other support groups will be notified 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day (e.g. town sheriff, volunteer fire fighters, local EOC volunteers).

F.1.b. Communications With State / local governments. A figure describing the communications networks would be most helpful.

F .1.c . Communications with Federal emergency response organization.

F .1.d . Communications among the plant, the EOF, EOCs and monitoring teams. A figure is necessary.

F.1.f. Communications with NRC.

F.2. Communications link between the facility and mobile medical support groups.

RESPONSE

F. As was indicated in the response to Question A.1.e., the commt.nications systems for the Perry Nuclear Power Plant are currently being re-evaluated. Once these plans are finalized, the Emergency Plan will be amended to provide a detailed description. Also impacting the response to these questions are the I4 cal County Emergency Plans which are currently in the developmental stages.

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2 QUESTION G. PUBLIC EDUCATION AND INFORMATION e

G. I . The Public Information Program described in the plan does not clearly define what sector of the public will receive periodic information regarding how they will be notified, what their actions should be in an emergency, the agreed upon means of evacuation verification, the location of relocation centers and the use of radioprotective drugs. Purther, the program does not make provisions for the specific needs of the handicapped. Provide this information.

G.2. Provide actual samples of the Public Information Program that will be distributed to the public, for review and evaluation. Specify how the permanent and transient adult population within the plume EPZ will become aware of this information.

G.3.a. Provide designated points of contact and a description and and diagram of the physical location to be used by the G.3.b. news media during an emergency.

G.4.b. Describe how timely exchange of information will be accomplished among the designated spokespersons for the utility and State and local agencies.

G.4.c. Describe the means and methods used by each organization for rumor control.

G.5. - Describe, in detail, the programs that will be conducted annually to acquaint the news media with the emergency plans, information concerning radiation, and points of contact of release of public information in an emergency.

RESPONSE

G. Due to the fact that the Local County Plans are not as yet completed, the specifics of the Public Information Program are not available. It is intended that arrangements and agreements will be reached with State and Local officials regarding the items listed in the questions. Once this information is available, it will be provided.

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. QUESTION H .1. Specify the types of equipment available in the TSC, and EOF, identified in NURE:.,0696, including the types and locations of communications equipment. This information should be j detailed on a scaled drawing and meet the format of NUREG 0814. .

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RESPONSE

4 H .1 . The next amendment to the Emergency Plan will contain an expanded description of the Emergency Response Facilities. l l In addition, a separate submittal will be prepared meeting the format of NUREG-0814. It is currently expected that this submittal will be available by August 1,1982, i

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9 QUESTION H.2. Specify the road distance and travel time between the control room for the permanent nearsite EOF.

RESPONSE

H.2. Road distance is about 1/2 mile. Travel time is approximately 4-6 minutes.

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QUESTION 11 . 4 . Provide for timely activation and staffing of facilities as specified in Table B-1, NUREG 0654.

RESPONSE

11 . 4 . The present plans for timely activation and staffing of Dnergency Response facilities are described in section 7.3.2 of the Dnergency Plan.

t QUESTION H.5.b. Specify what type of instruments will be used as wound and portable monitors.

RESPONSF; H.5.b. The instrument to be used for monitoring wounds is a portable count rate meter with as associated thin end window GM detector.

Other portable instruments are specified in the Emergency Plan.

Table 7-5 Portable Radiation Monitoring Equipment.

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QUESTION H.5., Provide a description of the meteorological instrumentation H.6., and procedures as indentified in Appendir 2 of NUREG 0654, and' Rev. 1 and the provisions to obtain representative real-time H.8. teteorological infor=ation from other sources, me infoz=ation provided is not of sufficieht detail for evaluation.

RESPONSE

H.5., The fonowing paragraphs will be added to Section 7.4.5 in the H.6., next amendment to the Emergency Plan.

and H.8 'Ihe existing meteorological system is qualified to serve as the primary data source to provide meteorological measurements in support of emergency preparedness. The meteorological conditions during onshore flow at the tower will essentially be the same as at the release point and at receptors in nearby terrain: the depth of the air being modified can usua H y be expected to exceed the 60-m tower height at 1.8km or more inlana.

A digital processor win process and validate data. Sufficient instrumentation will be included in order to be able to det-ez=ine an estimate of dispersion meteorology: wind speed, wind direction, and stability classification for horizontal and vertical plume spread. Accuracies of the monitoring system for each parameter win be consistent with those for the main tower.

Multiple routes for communicating data from the tower will be provided to the control room and to the Radiation Protectiou Esta Information System (RPDIS) (for dispersion modeling and dose assessment and enmrmmication tc ERFs). Meteorological data will be updated every 15 minutes. An interrogation capability will be provided.

Agreements and procedures will be made for the acquisition of additional meteorological data on an as-needed backup basis:

these may involve National Weather Service, Federal Aviation -

Administration, or other data sources.

QUESTION H.9. Specify how personnel onsite during the emergency will have adequate protective equipment available to them, i.e.,

protective respiratory devices, emergency lighting, portable radiation monitoring equipment, communications, this

, information provided in inadequate.

RESPONSE-1 H.9. Appendix C to the Emergency Plan will be amended to indicate the storage locations and amounts of protective equipment that will be available onsite.

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O QUESTION H.10. Identify the provisions for inspection, inventory, quarterly operational checks and calibration of both fixed and portable instruments and equipment (protective equipment, communication equipment, radiological monitoring equipment and emergency supplies). Also specify provisions for replacement of materials removed from kits.

RESPONSE

H.10. The Emergency Plan will be amended to add a third paragraph to section 8.4 which will read:

" Surveillance Criteria are established in Health Physics Instructions specifying the frequency of inventory, operational checks, and calibration for all Health Physics related instruments and equipment. These instructions will contain check lists identifying minimum quantities at each location.

Replacement of quantities below minimum levels will be made within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

QUESTION H.11. Provide, in an appendix, a listing of emergency kits and contents, including protective clothing, communications equipment, radiological monitoring equipment and emergency 99pplies.

RESPONSE

H.11. Appendix C of the Emer"ency Plan will be amended to include Radiation Monitoring Team Kits which contain protective clothing, communications equipment, radiological monitoring equipment and other emergency supplies.

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QUESTION H.12. Establish a central point for receipt and analysis of all field monitoring data and coordination of sample media. The information in the plan is not of sufficient detail to evaluate.

RESPONSE

H.12. The Emergency Operations Facility is the central point for receipt and analysis of field monitoring data and coordination of sample media. This will be delineated in the next amendment to the Dnergency Plan.

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QUESTION I .1. Identify, in the plan, the plant system and effluent parameter values characteristic of a spectrum of off-normal conditions and accidents, and other information which corresponds to the example initiating conditions of Appendix 1, NUREG 0654, Table 4-1 does not provide this information.

RESPONSE

I .1. The Emergency Plan, Table 4-1, Sumary of Emergency Action Levels, is being re-evaluated in light of NUREG-0818 " Emergency Action Levels for Light Water Reactors". Any change found necessary by this re-evaluation will be included in the next amendment to the Emergency Plan.

QUESTION I.2. ,

Provide a complete description of the plant post accident sampling capability.

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RESPONSE

I.2. The planned post accident sampling system will be able to sample the following points from a panel to be located on the 577' elevation of the Intermediate Building:

Liquid Samples Reactor Water Recirc System (jet pump) (2 points)

Residual Heat Removal System (2 points)

Reactor Water Cleanup System (3 points)

Gaseous Samples

- Drywell Atmosphere Containment Atmosphere

- Suppression Pool Atmosphere

- Annulus Atmosphere The sample panel will also provide the following grab samples:

Dilute Reactor Water Undiluted Reactor Water

- Dilute Off Gas Sample of Reactor Water Non Accident Liquid The vendor that will supply this system and the amount of automatic analysis capabilities has not has yet been determined.

QUESTION I.3. Provide a description of the methods and techniques for determining source terms and release magnitude.

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RESPONSE

I.3. We will have a method whereby the High Range Containment Monitor readings and Effluent Monitor readings will be correlated to a source term. The instrumentation available to determine release magnitudes is described in section 7.4.1 of the Emergency Plan.

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QUESTION

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I.4. Establish the relationship between effluent monitor readings and onsite and offsite exposure and contamination for various meteorological conditions.

RESPONSE

I.4. The relationship between Effluent Monitor readings and onsite and offsite exposure is determined by the Emergency Dose Projection System which is part of the Radiation Protection Data Information System. The system is a multi-user, computer based

- data information system. The system contains redundant computers to provide system reliability. Af ter receiving inputs from the site meteorological system and release point radiation monitors, the system produces real-time estimates of plume location and dose intensity for both liquid and gaseous releases. System information is displayed in the Technical Support Center (TSC) and th'e Emergency Operations Facility (EOF).

Release calculations are made on the basis of a meteorological model presently being developed by NUS Corp. The model will use 15 minute average meteorological data to provide calculations of relative concentrations and transit times within the plume exposure EPZ. Atmospheric diffusion rates are based in atmospheric stability as a function of site-specific terrain conditions.

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QUESTION I.S. Specify how you intend to comply with the criteria set forth in Appendix 2, NUREG 0654. The information provided by the plan is insufficient to evaluate. The information to be provided should be the level of detail expressed in NUREG 0814.

RESPONSE

I.S. See response to Question H.S., H.6., and H.8.

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QUESTION I.6. Describe the methodology to be used for determining release rates and projected doses if the instrumentation used for assessment were to go off scale or become inoperable. This methodology must be described in the plan.

RESPONSE

I.6. The high range instrumentation to be used for release assessment has not as yet been specified. It is currently intended that the design of these instruments will have provisions for determining the release rates should it become inoperable or go off scale. When this information is available, the Emergency Plan will be amended to provide a description of the methodology to be used.

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I.7. Describe the capability and resources for field monitoring and within the plume exposure EPZ. Methods, equipment, and I.8. expertise to make rapid assessments of the actual or

, e potential magnitude and locations of any radiological hazards through the liquid or gaseous pathways should i be described. The description should address activation criteria, means of notification, field team composition, transportation, communication, monitoring equipment, and for additional information as to the level of detail needed see Section 5.0, NUREG 0737, Subsection 5.4.2 Assessment Action.

RESPONSE

I.7. The provisions for field mon,itoring within the plume exposure and EPZ are described in the Emergency Plan Sections 5.2.4, 7.4.1, I.8. 7.4.8.2, and Table 7-4. Also, see the response to question H.11.

Please note that we have not been able to determine what the reference in the question is.

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- - .. m QUESTION I.9. Describe your methods and capability to detect radiciodine concentrations in air as low as 10 pd uCi/cc measure under field conditions.

RESPONSE

I.9. reocedures for the methodology for Iodine Analysis described in NUREG/CR 0314, "An Air Sampling System for Evaluating the Thyroid Dose Conunitment Due to Fission Products Released From Reactor Containment" are currently being prepared and the necessary equipment procured. This methodology is determined to be able to detect approximately 5 x 10~g uci/cc minimum under Iodine concentration field conditions.ofA paragraph describing this method and its capability will be added to section 7.4.8.2 in the next amendment to the Emergency Plan.

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I QUESTION I.10. Describe, in the plan, the means for relating measured field contamination levels to dose rates for key isotopes and gross radioactivity measurements. Also describe the provisions for estimating an integrated dose for comparison with Protective Action Guides.

RESPONSE

I.10. The methods described in NUREG/CR-1021, PNL-3108, Models Selected for Calculation of Doses, Health Effects and Economic Costs due to Accidental Radionuclide Releases from Nuclear Power Plants, are being evaluated as a means for relating field measurements to dose rates for key isotopes.

The provisions for estimating an integrated dose for comparison with Protective Action Guides are in the dose projection system described in response to Question I.4.

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QUESTION J.l. Specify the time required to warn onsite individuals of an emergency (i.e. persons having emergency assignments, visitors, contractor / construction personnel and individuals in the excession area.)

RESPONSE

J.l. By using the Plant Public Address System and the Exclusion Area Paging System it is expected that all onsite individuals could be warned in less than 5 minutes.

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QUESTION J.2. Describe your provisions for evacuatica in adverse weather specify the selection of alternative routes and the methods of evacuation that will be used during inclement weather.

RESPONSE

J.2. The evacuation plans for PNPP and surrounding area are currently under development. When these plans are completed, this information will be provided.

QUESTION J.3. Describe the provisions for evacuation of non-essential onsite and personnel, including e*acuation routes, transportation personnel J.4. monitoring and decontamination capabilities. On a diagram, O show the location of decontaminated facilities.

RESPONSE

J.3. It is expected that non-essential personnel on site will and evacuate via nortnal plant access routes in personal vehicles.

J.4. Monitoring and decontamination of personnel exiting the Radiological Control Area will be conducted at the RCA control point and decontamination room as during normal operations.

There will also be provisions in the Emergency Operations Facility for monitoring and decontamination of site evacuees who have not been monitored at the RCA Control Point. Evacuees from the protected area will be monitored while exiting the protected area through the guard house and will be decontaminated ,

at the RCA Control Point or the EOF depending on the circumstances.

A diagram showing the location of the deconmtamination facilities will be provided in the next Emergency Plan amendment.

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QUESTION J.5. Describe your methods of accounting for all individuals onsite and ascertaining the names of the missing individuals within 30 minutes.

RESPONSE

J.S. A procedure will be developed to provide accountability of individuals, which will be basically as follows:

Initiation of personnel accountability will be by the Shift Supervisor. Mustering of individuals will be directed by Plant Public Address Announcement. Security will provide a list of individuals on site which will be checked against the muster lists to account for all individuals. A search will then be conducted by security personnel to ascertain the location of and the reason for any missing individuals. A description of this procedure will be included in a later amendment to the Emergency Plan, t

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1 QUESTION J.6. Describe the use of radioprotec*;ive drugs by onsite personnel.

6 Specify who decides when they are used, and by whom. Specify the amount available onsite.

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RESPONSE

J.6. Section 6.5.2 of. the Dnergency Plan will be amended when the guidance for use of radioprotective drugs by onsite personnel is developed.

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J.7. Describe the recommendations for protective measures that may be given to the public based on measured or calculated dose rates. Recommendations should be keyed to the emergency classifications and action levels described in Appendix 1 of the criteria.

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RESPONSE

i J.7. Recommendations for protective actions are discussed in the Emergency Plan Section 6.4.

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QUESTION J.10. Discuss provisions for protecting the health and safety of mobility-impaired persons.

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RESPONSE

J.10. NUREG-0654 does not require these provisions to be discussed j in the Licensee's Emergency Plan. It is expected that they I will be discussed in the local County Emergency Plans which are being developed.

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QUESTION J.10.c. Specify how local government personnel will be advised to take protective actions.

RESPONSE

J.10.c. Local government personnel will be advised to take protective actions through the Emergency Communications channels in t' ,

at the time.

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QUESTION J.10.e. Describe provisions for individual respiratory protection,

protective clothing and the use of radioprotective drugs by onsite emergency workers.

RESPONSE

J.10.e. The cited criteria is not required to be addressed by the Licensee's Emergency Plan. However, in the response to the text of the queltion is:

The provisions for individual respiratory protection and protective clothing are discussed in response to question H.11.

The provisions for use of radioprotective drugs by onsite workers are discussed in section 6.5.2 of the Dnergency Plan.

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J.10.f.' Discuss provisions by State and local organizations for administering radioprotective drugs to the general public.

l RESPONSE J.10.f. This criteria is not required to be addressed in the Licensee's Emergency Plan by NUREG-0654. However, the provisions for use of radioprotective drugs by the general public are described in the State Plan and are expected to be discussed in the Local County Plans.

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QUESTION J .1 1.a . Submit a map showing evacuation routes to be used by onsite and offsite personnel, which identifies relocation centers, medical facilities and shelter areas.

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RESPONSE

J .1 1. a . The cited criteria is not required to be addressed in the Licensee's Dmergency Plan by NUREG-0654. However, the response to the text of the question is:

Appendix D to the Dnergency Plan contains a map (Figure V-1 )

showing the expected evacuation routes. The identification of relocation centers, medical facilities, and snelter areas will be conducted as a part of Local County Planning. When this information is available from the local counties, a map containing the requested information will be developed and added to the Dnergency Plan in an amendment.

1 QUESTION K .1 . Describe the basis for the emergency exposure levels of 100 Rem Life Saving and 25 Rem Correction Action. These should be consistent with EPA / PAG's. Also, specify established guidelines for the following tasks: assessment actions, performing firstaid, performing personnel decon-tamination, providing ambulance service and medical treatment services.

RESPONSE

K .1 . The basis for the emergency exposure levels of 100 Rem Life Saving and 25 Rem Corrective Action is NCRP 39, Basic Radiation Protection Criteria, paragraphs 258, " Life Saving Actions" and 259, " Actions in Less Urgent Emergencies". For other activities, the normal Health Physics Radiation Exposure guidelines will be used.

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QUESTION K.2. Submit information regarding the personnel-training progra.4.

that will allow volunteers to make rapid decisions based upon knowledge of potential risks.

RESPONSE

K.2. The Radiological Controls Training Program-includes the " Risk from Occupational Radiation Exposure" module which addresses the risk, possible effects, and theories of radiation exposure, thus allowing each potential volunteer to base his decisions on his personal training and knowledge.

QUESTION K.3.a. Specify the 24-hour-per-day provisions to determine the doses received by emergency workers.

RESPONSE

K.3.a. Personnel radiation exposure records are maintained on computer records. These records are updated on a daily basis. In the event of a computer system loss, the latest copy would be manually updated and maintained until the computer system is returned to service and updated.

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QUCSTION K.3.b. Specify the methods used to ensure that dosimeters are read at appropriate frequencies (specify these frequencies) and the methods used to provide for maintaining records.

RESPONSE

K.3.b. Procedures will be prepared specifying the frequency with which dosimetry is processed, including the reading and logging of self reading dosimeter results.

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QUESTION K.5.a. Specify action levels for determining the need for decontamination

RESPONSE

K.5.a. An areg with removable contamination greater than 1000 dpm/

100 cm are classified and posted as " Contaminated Area".

Such areas are decontaminated as the need and time allow.

Areas are decontaminated with the following priorities:

1. Areas outside of the Restricted Area.

2. Areas outside of the Radiological Control Area (RCA).

3. Offices, laboratories, and corridors within the RCA.

Equipmentortoo}swithremovablecontaminationgreaterthan 1000 dpm/ 100 cm are classified and labeled as " Contaminated".

Such items that are utilized outside of the Restricted Area are decontaminated prior to continued use or stored until decontamination can be accomplished.

Equipment or tools within the gCA that have removable contamination 1 greater than 1000 dpm / 100 cm are utilized only in Contaminated Areas or stored until decontamination can be accomplished.

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, QUESTION K.5.b. Specify the means for radiological decontamination of emergency personnel.

RESPONSE

, K.5.b. Decontamination of personnel can be accomplished in two ,

j separate locations:

1) Personnel Decontamination Facility, 599 elevation Control Complex

2) EOF Personnel Decontamination Each facility contains a shower facility and wash basin i to be utilized during the decontamination process.

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• QUESTION 4

K.6.

Provide a description of onsite contamination control measures

including drinking water, food supplies, criteria for permitting return of areas and items to nomal use, i

i RESPONSE i^

K.6. All eating facilities are outside of the Radiological Control Area (RCA). Personnel frisk themselves and Health Physics personnel monitor all equipment leaving the RCA to minimize the

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spread of contamination.

Areas are returned to nomal use in accordance with limits ,

specified in response to K.S.a.

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f QUESTION

! K.7. Identify the locations and specify the capability for decontaminating relocated onsite personnel, and providing I

extra clothing.

j RESPONSE K.7. Decontamination facilities are avilable at:

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1) 599 elevation, control Complex 1

2) EOF Personnel offsite or at the EOF would be decontaminated at 4

the EOF facility. Personnel onsite would be decentaminated in the Control Complex facility.

Supplies of coveralls will be maintained near each decontamination I

faiclity and in other storage facilities on site.

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O QUESTION L .1 . Provide letters of agreement with appropriate hospitals. They should specify what services will be provided by the hospital.

RESPONSE

L .1 . See response to question A.3.

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QUESTION L.2. Specify what firstaid treatment facilities are available onsite. This should be accomplished by both a narrative description of the facility and a diagram showing the firstaid area's relationship to the rest of the site.

RF3PONSE L.2. The narrative description of the onsite firstaid facility is contained in Section 7.6 of the Emergency Plan. A diagram showing the first aid areas relationship to the rest of the site of the size necessary to fit in the Emergency Plan would not

have a level of detail sufficient to be of any use. An I uncontrolled copy of the architectural drawing showing the location of the medical aid room is attached for information.

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QUESTION L.3. Provide a letter of agreement with an ambulance service.

Specify whether a Health Physics Technician from the site will. accompany the contaminated injured person (s). Specify what type of comunications will be available between the i ambulance, the site and the hospital.

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RESPONSE

L.3. A letter of agreement for ambulance service will be obtained i

as indicated in the response to Question A.3.

3 Section 5.5.2.2.5 of the Emergency Plan discusses accompanying contaminated injured person (s). Comunications are discussed j in response to Question F.

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i QUESTION M .1 . Describe the means by which decisions are reached to relax both onsite and offsite protective measures during the

recovery period following an emergency.

RESPONSE

M .1 . The means for reaching decisions to relax protective measures are described in the Emergency Plan Section 9.0.

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QUESTION M.2. Specify by position / title the authority and responsibilities and who will fill key positions in the facility recovery organization.

RESPONSE

M.2. The authorities and responsibilities for facility recovery operations are described in Section 9.0 of the Emergency Plan.

QUESTION M.3. Describe the means for informing members of the response organizations that a recovery operation is to be initiated, and identify those changes in the organizational structure that may occur.

RESPONSE

M.3. Notifying response organizations that recovery operations have been initiated will be handled through the Emergency Communications channels. Beyond the designation of overall authorities and responsibilities, no specific recovery organization has been deliniated. It is expected that once the recovery phase has been initiated, the normal organization will be utilized.

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QUESTION ,

M.4. Describe the method (s) established for periodically estimating total population exposure.

RESPONSE

M.4. Total population exposure will be estimated periodically as follows:

DR x PET x PPA = Man Rem Where:

DR = Dose Rate in Rem /Hr PET = Projected Exposure Time or Actual Exposure Time if known in Hr.

PPA = Population in Plume Area d .

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O QUESTION N.1.a. Verify that all exercises and drills will be conducted according to established NRC and FEMA criteria.

RESPONSE

N.1.a. Drills and exercises will be conducted in accordance with NUREG-0654, FEMA-REP-1 as described in Section 8.1.2 of the Emergency Plan.

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I QUESTION N.1.b. Provide the mechanism for critique by Federal and State observers / evaluators.

t RESPONSE 4-N.1.b. Section 8.1.2 of the Emergency Plan indicates that a critique will be held. The specifics of such a critique will be developed as a part of exercise preparations.

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QUESTION N.2.a. Verify that in addition to quarterly communications drills with other agencies, monthly communications checks will be conducted with the NRC.

RESPONSE

N.2.a. The next amendment to the Emergency Plan will contain the following as a change to Section 8.1.2.c.

C. Communications Testing:

i Emergency Communications Systems shall be tested as follows:

1. Communications with the State and Local Counties will be tested monthly.

2. Communications with Federal Response agencies will be conducted annually.

3. Communications among the Control Room, Technical Support Center, Emergency Operations Facility, the State and Local Emergency Operations Centers, and Radiation Monitoring Teams will be tested annually.

4. Communications with the NRC from the Control Room, Technical Support Center, and Emergency Operations Facility will be tested monthly.

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QUESTION N.2.e. Section 8.1.2.d should be modified to state that Health Physics drills shall be conducted semi-annually using implant liquid samples with actual elevated radiation levels.

RESPONSE

N.2.e. NUREG-0654 requires that actual elevated samples be j analyzed annually. Analysis of elevated samples at a j higher than necessary frequency is not consistent with d

the ALARA concept.

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6 QUESTION N.3 Verify that exercise and drill scenarios will be designed to allow free play for decision:r.aking.

RESPONSE

N.3 Exercise and drill scenarios win be designed to allow free play for decision-making by participants.

QUESTION N.3.a. Verify that advance materi als will be provided to official observers.

RESPONSE

N.3.a. Advance materials will be provided to official observers.

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QUESTION

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o .1. Additional information is required concerning the training program for personnel who will implement the radiological emergency response plan. The description should include the specialized training and periodic retraining programs (include scope, nature and frequency) for each of the nine categories of personnel listed in Section II.O.4. of NUREG 0654, Rev.1.

RESPONSE

i O .1.

The scope, nature and frequencies of Emergency Plan training are diccussed in Section 8.1.1 of the Emergency Plan and shown on Tables 8-1 and 8-2.

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CtESTION 0.2. Identify where the for=at training program includes training and detez=ine individual qualifications, and specify the 0.4 mini =um level of competence established for each position assigned an emergency response role. Training and retraining programs, qualifications testing and competence for State and local officials should also be included.

RESPONSE

0.2. The minimum level of competence for each individual assigned and an essrgency response role is established by the job description 0.4 of 1, nor=al position held by the individual. Emergency Plan Training is only intended to provide guidance on the emergency aspects of each position. Training of local officials

is expected to be discussed in the Local County Plans which are being developed.

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QUESTION O.3. Specify the type of training and retraining received by firstaid personnel, and how they are tested annually.

RESPONSE

O.3. The training of firstaid personnel is described in Table 8-1 of the Emergency Plan.

QUESTION O.5. Specify the training given by each organization that provides for the training and retraining of personnel with emergency response responsibilities.

RESPONSE

0.5 . Training and retraining of personnel with emergency response responsibilities is discussed in Table 8-1 of the Emergency Plan.

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j P .1. Verify that each organization shall provide for the training of individuals responsible for the planning effort. ,

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RESPONSE

1 P .1. Training is provided for the Perry Dnergency Planning 7 Coordinator. Training of State Planners is discussed in the State plan.

Training of County Planners is expected to be discussed

, in the Local County Dnergency Plans which are being developed.

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QUESTION P.2. Identify the individual with overall authority and responsibility for emergency response planning.

RESPONSE

P.2. As stated in Section 8.0 of the Emergency Plan:

"The Perry Plant Department Manager has been assigned overall responsibility for emergency planning as related to the PKDP."

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, QUESTION P.5 clearly specify how emergency response plans and approved and changes to the plans shall be forwarded to all organizations P.9 and specify who will conduct independent' reviews of the emergency preparedness program at least every 12 months.

RESPONSE

P.5 Changes to the Emergency Plan and Implementing Procedures and will be distributed to Controlled Copy document holders in P.9 accordance with PNPP Administrative procedures.

The individual or group who is to perform the independent review of the Emergency Preparedness program has not been identified. The Emergency Plan will be amended to include f

this information when it is available.

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O O QUESTION P.10. Provide for at least quarterly updating of telephone numbers in the emergency procedures.

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RESPONSE

P.10. Section 7.3.6 of the Emergency Plan provides for updating telephone numbers on a quarterly basis.

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