ML20050D960
| ML20050D960 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 04/06/1982 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| RTR-NUREG-0696, RTR-NUREG-696, TASK-3.A.1.2, TASK-3.A.2.1, TASK-TM TAC-46115, TAC-46116, TAC-46259, TAC-46260, NUDOCS 8204120443 | |
| Download: ML20050D960 (20) | |
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NdEI Mr. J.
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Keppler, Regional Administrator Office of Inspection and Enforcement, ll?
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S. NUCLEAR REGULATORY COMMISSION
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Dear,
Mr. Keppler:
[I DOCKET NOS. 50-266 AND 50-301 EMERGENCY PREPAREDNESS POINT BEACll NUCLEAR PLANT, UNITS 1 AND 2 This letter is in response to your letter of Pobruary 11, 1982, which discussed the NRC January 4 to 15, 1982 emergency preparedness appraisal at our Point Beach Nuclear Plant.
Our letter to you dated February 18, 1982 provides our planned actions for addressing each of the items identified in Appendix A.
The results of our considerations of each item in Appendix B are provided in Attachment 1.
Our response to those items listed in Appendix C are provided in AttacFaent 2.
(
In response to an open item in Appendix D, the Operations Support Center and the Technical Support Center are operational, except for the backup power supply, as of March 8, 1982.
The responses to Appendix B and Appendix C reflect three general completion dates for revisions:
June 1, 1982 EPIP revisions i
August 1, 1982 Emergency Plan revisions October 1, 1982 Emergency Plan Appendix revisions 820412O443 820406 7 N
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PDR ADOCK 05000266 APE D
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t Mr. J.
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Keppler April 6, 1982 Not all Appendix C items will be addressed in the Emergency Plan.
Many items are more appropriately addressed in the Emergency Plan Implementing Procedures.
Your approval is requested for the above schedule, since certain of the affected Appendix C items fall beyond the proposed 90-day due date.
Consistent with the requirements of NUREG-0696 pertaining to Emergency Operations Facility location beyond 20 miles from the plant site, it is hereby requested that NRC review item 7 of Attachment 1 of this letter by May 1, 1982, in order for us to proceed with the associated construction and modifications in a timely manner.
According to footnote 1 of Table 2 of NUREG-0696,
" Specific Commission approval is required for EOF locations beyond 20 miles of the TSC"; since responsibility for Licensee compliance in the emergency planning area has now been transferred to the Region, it is not clear whether approval by NRC Headquarters or the Region is intended.
IIence, your follow and resolution of the matter will be appreciated.
If you have any questions regarding this submittal, please feel free to contact us at any time.
Very truly yours, (y
,/
l Assistant Vice President C. W. Fay Attachments Copics to NRC Resident Inspector II.
R.
Denton 1
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ATTACHMENT 1 RESPONSES TO APPENDIX B ITEMS This attachment addresses the results of our considera-tion of the items listed as suggested improvement items by the NRC after the appraisal of emergency preparedness at Point Beach Nuclear Plant.
The numbering system of each item follows that of Appendix B of the NRC letter to Mr. Sol Burstein, dated February ll, 1982.
1.
The Emergency Planning Coordinator (EPC) has attended a number of conferences on emergency planning given by the State of Wisconsin.
The EPC has also participated in many offsite and licensee training sessions.
When avail-able, appropriate professional development courses in emergency preparedness will be attended.
2a.
Formal selection and qualification criteria for the EPC are listed in the Point Beach Nuclear Plant Administrative Control Policies and Procedures Manual, PBNP 3.7, Section 1.0.
2b.
For implementation of the emergency organization, we will use our present selection and qualification criteria for managerial and technical capabilities in emergency prepared-ness activities, as well as consideration of qualifications achieved by virtue of the performance of normal operational job functions.
The qualification criteria for the operating plant staff are listed in the Point Beach Nuclear Plant Administrative Control Policies and Procedures Manual.
These criteria are also used for emergency organization selection.
This general description will be added to the Emergency Plan by August 1, 1982.
In addition, this selection process will be formalized by the construction of a matrix.
This two-dimensional matrix will list all personnel available to fill positions in the emergency along one axis and all positions to be filled along the other.
Priorities will be set for emergency organization positions ar 'e t21 as for personnel to fill those positions.
This ma'.i ' ( vill allow those responsible for staff augmentat("n 5 s quickly select the most qualified person to fili
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- thest priority job for which that person is quais;1cf This matrix will be completed and made available at eacn cmergency response facility by August 1, 1982.
3.
We will incorporate offsite agencies and contractors into the PBNP emergency plan training and retraining lesson plans where appropriate.
Where contractors or ag?ncies
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require specialized training, lesson plans will be written to organize the training clearly.
These lesson plans will be developed after the completion of the lesson plans listed in our February 18, 1982 letter.
4.
As discussed in our letter of February 18 to Mr. Keppler, we are including an evaluation program in our emergency plan training and retraining which addresses, where appropriate, testing of individuals' understanding of information presented to them.
In some cases, the testing may include completion of a quiz; in other cases, it may consist of an evaluation of performance in drills and exercises.
5.
As part of our overall NUREG-0737 review of control room layout and modifications, we will review and resolve by September 1, 1982, the location of emergency equipment in the control room.
6.
EPIP 6.1,
" Limited Plant Evacuation", will be revised to designate the assembly areas for all personnel by June 1, 1982.
7.
Our letter of June 1, 1981 provided a functional descrip-tion of our emergency response facilities.
To date, we have received no response from NRC.
We discussed the concepts and layouts of these facilities with the emer-gency preparedness appraisal team during the January 4-15, 1982 audit.
The team suggested we discuss our concepts with the NRC Staff in Bethesda.
We have attempted to arrange such a meeting, but have been informed that such r meeting would be unnecessary, since further guidance was forthcoming from the Commission.
However, to our knowledge, no additional guidance has yet been issued.
Therefore, after review of our response times and functional criteria for our emergency response facilities, we will proceed with the following restructuring of our Emergency Operations Facilities currently consisting of the Emergency l
Support Center (ESC) and the Site Boundary Control Center l
(SBCC).
This restructuring will proceed as outlined here unless we receive other guidance frem the NRC by May 1, 1982.
In order to allow us to finalize our emergency planning arrangements and, in particular, to commence construction of the new SBCC before winter, your prompt approval of this matter will be appreciated.
The ESC, now located in the Energy Information Center I
(EIC) one-quarter mile south of Unit 1, will be relocated to the Wisconsin Electric Power Company Corporate head-quarters at 231 West Michigan Street, Milwaukee, Wisconsin.
Staffing of the ESC is provided by senior Nuclear Power Department employees from the Wisconsin Electric Corporate l
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headquarters in Milwaukee, and all activities between the ESC and other agencies or individuals are performed using telephone or electronic communications circuits.
In fact, in our recent exercise, we observed that the physical presence of personnel from Corporate headquarters is unimportant for the successful conduct of the exercise, since all communications involved electronic means. While moving the ESC to Milwaukee will resolve NRC habitability concerns regarding the current locations of our ESC and its backup, there are a number of other advantages to the Milwaukee location.
The manning of the ESC by Corporate headquarters personnel can be done more promptly with the location in Milwaukee since these personnel work and reside in the Milwaukee area, approximately 100 miles from the Point Beach Nuclear Plant. As well as more rapid mobilization, the activation of the ESC is more assured since the travel from Milwaukee to the present ESC location can be delayed or life-threatening during adverse weather or road conditions.
Senior Corporate officers, including the Emergency Director, as well as other headquarters support entities, with whom the Emergency Support Manager communicates, can be better informed without diminishing whatsoever the communications with the Site Manager, Emergency News Center Director, or the State and county emergency agencies.
It should be pointed out that locating a facility for directing or coordinating emergency activities some distance from the scene of an emergency is neither novel nor new.
Typically, utilities have a system control center which directs the dispatching, control, and repair of generation and distribution facilities and personnel within the service area.
Further, such a situation is customary for emergency responsive agencies such as police or fire departments. In all these cases, electronic communications are relied upon.
For all the foregoing reasons, we intend to modify our Emergency Plan to relocate the ESC to the Wisconsin Electric Corporate headquarters in Milwaukee.
We have reviewed our new proposal with reference to NUREG-0696 and have the following notes regarding our proposed modifications:
The ESC will have facilities and responsibilities for:
Management of the overall emergency response, Determination of recommended public protective actions, and Coordination of emergency response activities with Federal, State and local agencies. L
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The NRC Staff and state and local agencies will be provided quarters within the new SBCC near PBNP, as well as at the ESC in Milwaukee.
Security at the restructured ESC is adequate to ensure activation readiness for an emergency.
Upon activation of the ESC, security protection will be further upgraded to restrict access to those personnel assigned to the facility.
The corporate headquarters location provides better functional and availability characteristics than the Energy Information Center. The three functions described above can be carried out more expeditiously because of the greater availability of the facility to personnel assigned to the ESC.
Upon activation, the restructured ESC can be fully functional within one hour.
The Emergency Support Manager (Assistant Vice President, Nuclear Power Department) will be in charge of the ESC activities.
Management of the coordina-tion of radiological and environmental assessment will also be carried out from the ESC; the actual assessment,
i.e.,
monitoring, will be done from the SBCC.
The ESC staff assignments which will be made part of the emergency plan are:
Emergency Support Manager, Radcon/ Waste Manager, Radwaste Technical Support Coordinator, Licensing Support Coordinator, Administrative and Logistics Manager, Design Construction and Planning Manager, Director, Quality Control, and Utility Engineering Director.
Since the location for the ESC is the present location of the Nuclear Engineering Section of the Nuclear Power Department, the working space would be adequate for personnel assigned as well as any NRC, FEMA, State, and local personnel.
The ESC facility in Milwaukee has space adequate for all communications equipment.
Plant records and drawings are already provided.
Separate office space to accommodate five NRC personnel is available.
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Radiological monitoring is not necessary in the restruc-tured ESC. Therefore, no monitoring system is planned.
A communications system is in place which provides manage-ment communications with the manager of the Technical Support Center, the Site Boundary Control Center, and the control room. This system consists of eight dedicated telephone lines for communications between the plant and corporate headquarters. Three of these lines use a micro-wave link through Appleton, Wisconsin; the remainder are leased land lines between Milwaukee and Point Beach Nuclear Plant.
The described communications will provide the capability to manage Wisconsin Electric response resources, to manage the offsite radiological monitoring being done by Point Beach Nuclear Plant personnel during an emergency, and to perform accident dose assessment.
Offsite emergency response coordination and notification, as well as dissemination of information and recommendation of protective actions to the State, can be done with normal land lines.
Initial notification of a classifica-tion change will be done using a NAWAS phone to be installed in the restructured ESC if agreed to by the State of Wisconsin.
The existing NAWAS phone in the TSC will be maintained.
The NRC hotline will be installed in the restructured ESC or in the SBCC, whichever is preferred by NRC.
The health physics network telephone will be relocated from the present ESC to the corporate headquarters, if desired by NRC.
A dedicated telephone for management communications will be provided between the ESC, the TSC, and the SBCC.
Communications to State and local operations centers will be accomplished with the NAWAS phone using normal land lines as a backup, if agreed to by the State of Wisconsin.
Communications with the SBCC, which provides the offsite environmental monitoring support for the ESC, will be accomplished with a dedicated phone line using land lines or one of the eight plant lines as a backup.
The ESC has adequate phones for use by NRC or any other offsite agency.
Facsimile transmission between the location of the restruc-tured ESC, the TSC, and the NRC Operations Center already exists.
I A data display device with accompanying status board will be located in the ESC.
This device will make available:
Plant system variables, In-plant radiological variables, Meteorological information, and Offsite radiological information.
The data display will be operational on a schedule consis tent with our responses to NUREG-0737 requirements, specifically those pertaining to the major new computer system installation.
The new Emergency Support Center already has the following records:
Emergency Plan, Emergency Plan Implementing Procedures, Plant Technical Specifications, Plant operating procedures, Emergency operating procedures, Final Facility Description and Safety Analysis
- Report, Point Beach Nuclear Plant, State and local emergency response plans, Offsite population distribution data, Evacuation plans, Environs radiological monitoring records, and up-to-date drawings, schematics,and diagrams showing plant structures and systems and the in-plant location of these systems.
The current SBCC will be replaced with a new facility one mile southwest of the plant.
This new facility will fulfill all the functions of SBCC as outlined in our earlier letters. The SBCC will serve as the coordination point for radiological monitoring of the environs and as a security and health physics control point for site access during Site and General Emergencies. i
r-The SBCC can also serve as a location for offsite authori-ties to coordinate their offsite monitoring activities.
The SBCC will have a backup if it becomes radiologically uninhabitable.
For security and monitoring team supervi-sion, that backup facility is the TSC.
Non-supervisory monitoring team personnel will be coordinated by radio and will report to a designated area of the Two Rivers Community House (Emergency News Center) when appropriate.
The use of the Two Creeks Town Hall as a backup to the ESC and SBCC Will be discontinued.
The new SBCC will have adequate space for the security and environmental monitoring personnel.
There will also be adequate space and communications systems for those personnel assigned to the site during an emergency.
Radio communications with the mobile monitoring teams will be available at the SBCC as well as the TSC.
8.
Trauma kits will be installed in all stretchers at Point Beach Nuclear Plant.
This will be completed by August 1, 1982.
9.
Our review indicates that EPIP 11.2, " Injured Person's Immediate Care", and EPIP 11.4, " Personnel Decontamination",
adequately address the receiving, transporting, and handling of injured / contaminated personnel.
10.
Search and rescue team drills will be conducted as part of our Emergency Plan training and Emergency Plan retraining programs.
EPIP 15.3, " Drills and Exercises", will be revised by June 1, 1982, to specify those drills.
11.
The Victoreen Thyac survey meter and Mini-Rad survey instrument will be removed from EPIP 11.3, " Hospital Assistance", by June 1, 1982.
j 12.
EPIP 1.4,
" Radiological Dose Evaluation", will be revised to direct the users of the procedure to use the strip l
chart recorders for visually averaging the wind speed and direction over a fifteen-minute trace.
The alternate meteorological data sources to the Point j
Beach Nuclear Plant meteorological monitoring systems will be listed in order of priority in EPIP 1.4.
The EPIP will be revised to reflect these changes by June 1, 1982.
EPIP 1.4 will also reflect a conservative assumption for plume release duration and meteorology during a release i
with unknown duration. Since the maximum evacuation time estimate for any segment of the population is eight hours during adverse weather conditions, a release duration of eight hours will be assumed.
A constant wind direction l L
will also be assumed over the eight hours.
Protective actions, if warranted, will be recommended for a 90*
sector centered on the average wind direction observed at the time of the recommendation. Wind speed, wind direction and release rate will be monitored and any change resulting in the need for a revised protective action recommendation will result in a revised recommendation.
EPIP 1.4 will be revised to reflect these changes by June 1, 1982.
15.
We will formalize meteorological data review and meteoro-logical system operability review.
This review program will be operational within six months of the operability of the meteorological measurements system.
16.
NRC can reach the individual responsible for dose calcula-tions by obtaining the unlisted number for a phone dedicated to the Chemistry and Health Physics Supervisor (in the TSC), or the Radcon/ Waste Manager (in the ESC).
This number can be obtained from the red phone communicator.
17.
The technical bases for the dose calculation methodology will be inserted as an appendix to the plan by October 1, 1982.
18.
All half-face respirators used for radiological protection at Point Beach Nuclear Plant will be replaced with full-face respirators by January 1, 1983.
19.
Procedural control of communication system checks have been implemented in EPIP 14.1 to ensure that the require-ments of Appendix E to 10 CFR 50 are met.
20.
The interim OSC and TSC are no longer in use.
Control measures for inventory seals on emergency equipment cabinets are in place.
21.
Check sources have been ordered for those pieces of radiological monitoring equipment designated for emergency use.
These sources are expected prior to September 1, 1982.
22.
Emergency operating Procedures (EOP's) will be revised to direct the EOP user to a specific Emergency Plan Imple-menting Procedure where appropriate.
This revision will be completed during the scheduled revision of the Point Beach Nuclear Plant Emergency Operating Procedures.
23.
The State of Wisconsin Division of Emergency Government, with aid from the Department of Health and Social Services, is responsible for radiological assessment and protective actions.
Meteorological data and protective action recommendations are provided to the Division of Emergency ;
Government on a timely basis.
If a significant change in meteorological or release conditions occurs, the Division of Emergency Government is notified of those changes.
The Division of Emergency Government can, and during exercises has, contacted the Radcon Waste Manager in the ESC whenever any question arises. Review of this matter will be complete by June 1, 1982. Any necessary revisions to the EPIP's will be made by August 1, 1982.
24.
Radiological dose assessment training is part of the Emergency Plan Training program.
This training with its evaluation technique will assure accuracy and timeliness of the dose assessment.
The Retraining Program, which has been approved and for which lesson plans are being developed, will be implemented in 1982.
All appropriate personnel will be trained or retrained prior to January 1, 1983.
25.
A new Emergency Plan Implementing Procedure has been written to provide a simplified methodology of initial dose calculation.
This procedure is being reviewed and will be issued in the Emergency Plan Implementing Procedures by June 1, 1982.
26.
In those areas where exposure to radiciodine would be possible, 130 mg potassium iodide capsules have been placed in the emergency equipment cabinets.
27.
Responsibility for an audit of the Point Beach Nuclear Plant Emergency Plan and Implementating Procedures is currently assigned to the Offsite Review Committee by Technical Specification 15.6.5.3.8 on the basis of at least once per two years.
The Emergency Plan Implementing Procedures will be revised by June 1, 1982, to specify an annual audit frequency.
The scope and depth of the audit will vary on a two-year cyclical basis.
28.
EPIP 1.4, " Radiological Dose Evaluation", has been compared to the State of Wisconsin Division of Emergency Government methodology and has been found compatible.
29.
Letters of agreement with offsite agencies will be updated l
in those cases where letters already exist.
Letters of l
agreement will be sought from those agencies willing to provide aid but not having a formal letter of agreement.
This will be accomplished by October 1, 1982 (see item 1 of Attachment 2).
In response to this item, we have reviewed the level of detail in our letters of agreement.
As evidenced by FEMA's recent emergency exercise critique, the various responding agencies in Wisconsin have an excellent working relationship with each other and with the Licensee.
In view of this spirit of cooperation, we have concluded that no further specification of their
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already self-evident duties and responsibilities is
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appropriate.
Such additional specification could be detrimental to the good relationship via the potential appearance of " telling the professionals how to do their job".
Our review of this item, therefore, conclt ded that sufficient documentation of response is provided in the State, County and Licensee Emergency Plans and ir, the existing format of the letters of agreement.
30.
Offsite agency training is addressed in the Emergency Plan training program and Emergency Plan retraining program...
ATTACHMENT 2 RESPONSES TO APPENDIX C ITEMS This attachment addresses our consideration of the items listed as deficiencies by the NRC appraisal team after review of the Point Beach Nuclear Plant Emergency Plan.
These comments are presented in the order used in Appendix C to the NRC letter to Mr. Sol Burstein of February ll, 1982.
Not all items in Appendix C are appropriate for location in the Emergency Plan, therefore some will be located in the Emergency Plan Implementing Procedures or in other documents as noted.
A.3 Letter of Agreement Those letters of agreement which appear in the Emergency Plan Appendix and are more than two years old will be updated.
No letters of agreement will be sought from the Wisconsin Department of Natural Resources, the Wisconsin Department of Agriculture or the Wisconsin Department of Military Affairs.
These agencies have no association directly with Point Beach Nuclear Plant.
They all respond at the direction of the State Division of Emergency Government under agreements with and in response to the authority of that agency.
A letter of agreement with the Wisconsin Department of Transportation already exists via an agreement with the Wisconsin State Patrol which is the responding part of the Department of Transportation.
Manitowoc County, Kewaunee County, Bechtel Power Corpora-tion and Westinghouse Electric Corporation have signed letters of agreement with Wisconsin Electric which will be inserted into the Plan.
The Two Rivers ambulance service agreement will be formalized in a letter of i
agreement with the City of Two Rivers.
These letters will be updated and inserted into the Plan by October 1, 1982.
B-2 NCREG-0654, B-2 The authority and responsibility to immediately and unilaterally initiate emergency actions rests with the Duty Shift Supervisor.
Appro*eriate EPIP revisions have been made.
Protective actior, recommendations must be made by the Emergency Suppor t Manager.
The Duty Shift Supervisor also has the authority to authorize exposure in excess of 10 CFR 20 limits (see EPIP 12.1). This information will be inserted in the Emergency Plan by August 1, 1982.
B-4 Appendix A - Nondelegatable Responsibilities Appendix A will be revised to address that responsibility which cannot be delegated.
The Emergency Support Manager may not delegate the responsibility of making the decision to recommend protective actions to authorities responsible for offsite emergency response.
This revision will be complete by October 1, 1982.
B-5 NUREG-0654, Table B-1 See our February 18, 1982 letter to NRC.
B-7b Reentry / Recovery Operation Planning The Point Beach Nuclear Plant Emergency Plan Implementing Procedures have been revised to list the Maintenance Supervisor as having the responsibility for planning of reentry / recovery operations (see EPIP 12.1).
This will be inserted as part of the Emergency Plan by August 1, 1982.
B-5 Shift Augmentation See our February 18, 1982 letter to NRC.
C-1 DOE Radiological Assistance The Plan will be revised to reflect that the Emergency Support Manager will be responsible for requesting assist-ance from DOE.
This revision will be complete by August 1, 1982.
It should be noted, however, that the State may also request DOE assistance at its own initiative.
C-2b Offsite Liaison The Point Beach Nuclear Plant Emergency Plan stipulates that "i f requested, the Company will send representatives to the appropriate State and local emergency operations center."
Requests and communications with offsite agencies occur from the Emergency Support Center.
The Emergency Support Manager will determine what type of person is appropriate to fill the requested liaison position.
The criterion for this liaison appointment is any request from State or local government rather than any predesig-nated emergency classification.
E-2.
Alerting and Mobilization This will be added to the Emergency Plan by August 1, 1982. <
E-3 &
E-4 Initial Notification Procedures Copies of the initial notification and followup message forms are readily available to personnel in the control room, Technical Support Center, Emergency Support Center, Manitowoc County Sheriff's Department, Kewaunee County Sheriff's Department, Algoma Police Station and State of Wisconsin Division of Emergency Government office.
E-6 Prompt Notification System A description of the new prompt notification system will be included in the Emergency Plan by August 1, 1982.
An estimate of time required to notify and provide informa-tion will be included in the revised evacuation estimates in Appendix J to the Emergency Plan by October 1, 1982.
F-1 Communication Links Specification of organizational titles and alternates for both ends of emergency communications will be made part of the Emergency Plan by August 1, 1982.
A description of the actual location of the Manitowoc and Kewaunee County EOC's will also be put into the Plan by August 1, 1982.
F-2 Medical Facility Communications Telephone communications exist between Point Beach Nuclear Plant and the Two Rivers Community Hospital.
Radio communications exist between the plant and the Point Beach first aid vehicle.
A radio relay link via the Manitowoc County Sheriff can be used to reach the hospital as a backup communication method.
This information will be added to the Emergency Plan by August 1, 1982.
F-3 Communications System Testing Frequency The frequency of testing for the communication systems within the plant, as well as outside the plant, is set down in EPIP 14.1, " Testing of Communications Equipment".
G-4 Emergency News Center Director A revision of the Emergency News Center Director function and responsibility statement in Appendix A to the Emergency Plan will be issued prior to October 1, 1982. A provision for rumor control during an emergency is part of the Wisconsin Electric Crisis Communications Plan for the Communications Department.
This Plan also contains the description of the responsibilities of the Emergency News Director and his assitants.
e G-S Media Training The existing annual media training program includes specific details regarding the Emergency Plan information and contact points for release of public information.
These specifics will be documented in a lesson plan addressing media training after completion of our lesson plans listed in our February 18, 1982 letter.
H-1 TSC/ EOF Activation
- to our February 18, 1982 letter to you on Table B-1, Shift Complement, discusses the staff augmen-tation in 30-60 minutes and the EOF activation within one hour.
Our restructured Emergency Support Center, as discussed in Attachment 1 to this letter, will result in j
an improved activation time for the Emergency Support Center (EOF).
This timely activation information will be put into the Plan by August 1, 1982.
I-3 Source Term Release Information Estimation of the contents of the containment is based on sampling and analysis (EPIP 7.3.3).
Upon completion of the installation of high-range containment monitors, a
procedure will be written to allow such estimates based on monitor reading.
In addition, EPIP 1.7, " Estimation of Core Damage", will be completed by June 1,1982, and will further enhance the ability to estimate various primary system contents.
The magnitude of a release (source term for dose calcula-tion method) based on plant effluent monitors is addressed in EPIP 1.3, " Estimation of Source Term".
1-4 Offsite Exposure Procedure EPIP 1.4,
" Radiological Dose Evaluation", addresses a calculational method of relating effluent monitor read-ings and offsite exposures for various meteorological conditions.
I-5 Meteorological Data Availability See item 16 of Attachment 1 to this letter.
The ESC will receive its data via a data transmission system with telephone as a backup.
The State Division of Emergency Government will receive its data in the initial and followup notification messages, as well as direct communi-cation over a pre-arranged phone line with the ESC or Technical Support Center.
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I-6 Inoperable Monitoring-Release Rate and Exposure In addition to the added installation of a new wide-range monitoring system which meets or exceeds the requirements of NUREG-0737, EPIP 1.3 currently allows effluent estimates based on direct readings with hand held instruments in the event plant monitors are offscale or inoperative.
I-8 Radiological Plume Assessment Procedures EPIP 7.2.1,
" Activation of HP Facilities at Site Boundary Control Center", EP 7.2.4,
" Health Physics Communications", EPIP 7.2.5,
" Control and Use of Vehicles",
EPIP 7.1.1,
" Chem and HP Group Personnel Notification and Initial Response When Chem and HP Personnel are on-Site",
and EPIP 7.1.2,
" Chem and HP Group Personnel Notification and Initial Response When Chem and HP Personnel are Off-Site", address the criteria described in NUREG-0654, Revision 1,Section I.8.
I-10 Accident Assessment a.
EPIP 1.4,
" Radiological Dose Evaluation", relates various measured parameters to dose rates for key isotopes and gross radioactivity measurements.
Review of the procedure and its use will be made to determine the adequacy for estimating integrated dose.
Revisions, if required, will be made by October 1, 1982.
b.
EPIP 1.5,
" Protective Action Evaluation", addresses comparing the data in EPIP 1.4 for appropriateness of recommending protective actions.
J-5 Accountability During unannounced drills involving a plant evacuation using procedures EPIP 6.2,
" Plant Evacuation", and EPIP 8.1, " Personnel Assembly and Accountability", the longest time required for accountability for Point Beach personnel was ten minutes.
The longest time required to account for contractor personnel was twenty-two minutes.
By i
June 1, we will revise the Emergency Plan Implementing Procedures to reflect an accountability time goal of thirty minutes.
J-7 Protective Action Recommendation Notification The recommendation of protective action is provided to the State of Wisconsin Division of Emergency Government in the same manner (telephone) as any other message.
The i
Emergency Support manager is trained and responsible for this recommendation.
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J-10a Radiological Monitoring and Sampling Points Wind direction, wind speed and stability class cannot be predicted or preselected. Hence, the selection of radio-logical monitoring and sampling points during an emergency will be based on the prevailing release path and meteoro-logical parameters.
Nonetheless, whenever practicable, sampling locations will be those used for the routine radiological environmental monitoring program.
A reference to the program will be added to the EPIP 7.3.1, and extra copies of sampling maps will be provided in the SBCC by June 1, 1982.
K-1 Thyroid Exposure Guides EPIP 1.6, "Radioiodine Blocking and Thyroid Exposure",
provides thyroid exposure guides.
L-4 Letter of Agreement See item 1 of this attachment.
M-4 Total Population Exposure EPIP 1.4, " Radiological Dose Evaluation" predicts dose to the population on a person-by-person basis.
By consulting Figure 1 of Appendix J to the Point Beach Nuclear Plant Emergency Plan, a total population exposure can be derived.
We will revise this procedure by June 1, 1982.
N-la Exercise Planning Correspondence Projected dates, draft scenarios, and other appropriate exercise material will be provided to offsite agencies regarding proposed major exercises.
The Emergency Plan Implementing Procedures will be revised to provide for this correspondence by June 1, 1982.
N-lb Exercise Timing l
Weather conditions cannot be planned.
However, drills and exercises will not be postponed due to weather unless the weather is such that to conduct the exercise or drill would endanger the health or safety of the participants or public.
Drills and exercises are unannounced where the response time and equipment deployment is a part of the drill or exercise.
We will revise the Emergency Plan Implementing Procedure to specify unannounced drills and to provide for varying the season and time of day for exercises by June 1, 1982. _ - _
b N-2a Communication Test Frequency EPIP 14.1, " Testing of Communications Equipment", provides for a test frequency that conforms with NUREG-0654, Rev. 1, Section N.2.a. criteria.
The Emergency Plan will be revised to reflect these requirements of NUREG-0654 by August 1, 1982.
N-2c Ambulance Services Drill We have included the Two Rivers Ambulance Service in our medical drill in the past under the understanding that they not respond in a drill situation with their last available vehicle and crew.
This has always resulted in good response.
By June 1, 1982, the Emergency Plan Implementing Procedures will be revised to include the Two Rivers Ambulance Service in the drill schedule.
N-2d Monitoring Drills During drills of offsite or onsite monitoring, the forms required to tabulate the results are used.
Communication are always an integral part of these drills.
N-3 Drill Critiques Although no requirement for a description of how a critique is to be used as formal evaluation appears in NUREG-0654, Rev. 1, the use of drills as an evaluation technique will be part of some lesson plans for the Emergency Plan training plan and the Emergency Plan retraining program.
O-3 First Aid Training The assembly of a search and rescue team by procedure EPIP 12.2, " Personnel Exposure and Search and Rescue Teams" provides that at least one of the people making up the search and rescue team be trained in first aid.
The training program used at Point Beach is the Red Cross Multi-media training program.
P-4 Plan Review Section 8.3 of the Point Beach Nuclear Plant Emergency Plan provides for an annual review and update of the Plan.
P-8 Review Cross-Reference NUREG-0654, Rev. 1, Section P.8, suggests the provision of a cross-reference for use during the review process.
The Point Beach Nuclear Plant Emergency Plan is not in 4
the developmental or review process, since the Emergency Plan was fully implemented on April 1, 1981.
However, a,
r specific table of contents is provided as noted in the same item of NUREG-0654.
P-9 Off-Site Agency Interface Audit As part of the annual review of the Plan, an audit of the offsite interfaces will be done.
As a part of normal procedures, any significant review findings will be relayed to the affected agencies.
P-10 Telephone Number Updates Telephone numbers are reviewed on a regular basis, often more frequently than quarterly. A revision of the Plan reflecting a quarterly update of the numbers (if required) will be completed by August 1, 1982.
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