ML20052H989
| ML20052H989 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 04/28/1982 |
| From: | Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Bayne J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| Shared Package | |
| ML20052H990 | List: |
| References | |
| NUDOCS 8205240278 | |
| Download: ML20052H989 (33) | |
See also: IR 05000333/1982003
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APR 2 81982
Docket No. 50-333
Power Authority of the State of New York
ATIN:
Mr. J. P. Bayne
Senior Vice President
Nuclear Generation
10 Columbus Circle
Gentlemen:
Subject:
Emergency Preparedness Appraisal 50-333/82-03
To verify that licensees have attained an adequate state of onsite emergency
preparedness, the Nuclear Regulatory Commission is conducting a special appraisal
at each power reactor site. These appraisals are being performed in lieu of
certain routine inspections normally conducted in the area of emergency
preparedness.
The objectives of the appraisal at each facility are to evaluate
the overall adequacy and effectiveness of emergency preparedness and to identify
areas of weakness that need to be strengthened. We use the findings from
these appraisals as a basis not only for requesting individual licensee action
to correct deficiencies and effect improvements, but also for effecting
improvements in NRC requirements and guidance.
During the period of February 16 - 25, 1982, the NRC conducted an appraisal of
the emergency preparedness program _for the James A. FitzPatrick Nuclear Power
Plant. Areas examined during this appraisal are described in the enclosed
report (50-333/82-03).
Within these areas, the appraisal team reviewed selected
procedures and representative records, inspected emergency facilities and
equipment, observed work practices and interviewed personnel.
The findings of this emergency preparedness appraisal indicate that certain
corrective actions are required in your emergency preparedness program.
These
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are discussed in Appendix A, "Significant Emergency Preparedness Findings."
Your commitments to correct each of the items were discussed in a confirmatory
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action letter dated April 1, 1982.
A copy of the letter is included as
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enclosure 5.
Other areas for improvement are discussed in Appendix B, " Emergency Preparedness
Improvement Iters."
In conjunction with the aforementioned appraisal, emergency plans for your
facility were reviewed by the Emergency Preparedness Licensing Branch, Division
of Emergency Preparedness, Office of Inspection and Enforcement.
The results
of this review indicate that certain deficiencies exist in your emergency
plan.
These are discussed in Appendix C, " Emergency Preparedness Evaluation
Report."
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Power Authority of the State of New York 2
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Appendices A, B and C of this letter contain an inclusive listing of all
outstanding emergency preparedness items at your facility at this time.
We recognize that an explicit regulatory requirement pertaining to each item
identified in Appendices A, B, and C may not currently exist.
Notwithstanding
this, you are requested to submit a written statement within thirty (30) days
of the date of this letter, describing your planned actions for improving each
of the items identified in Appendix A and the results of your consideration of
each of the items in Appendix B.
This description is to include, (1) actions
which have been taken, (2) actions which will be taken, and (3) a schedule for
completion of actions for each item. With regard to Appendix C, you are
requested to provide to this office within 120 days of the date of this letter,
page changes to the emergency plan correcting each deficiency or provide
written justification as to why you believe a revision should not be made.
Copies of these changes are to be submitted in accordance with the procedures
delineated in Section 50.54(q), Part 50, Title 10, Code of Federal Regulations.
This is to inform you that if the deficiencies listed in Appendix A are not
corrected by the dates agreed upon, the Nuclear Regulatory Commission will
determine whether enforcement action is appropriate.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures
will be placed in the NRC Public Document Room unless you notify this office,
by telephone, within ten days of the date of this letter and submit written
application to withhold information contained therein within thirty days of
the date of this letter.
Such application must be consistent with the
requirements of 2.790(b)(1).
The telephone notification of your intent to
request withholding, or any request for an extension of the 10 day period
which you believe necessary, should be made to the Supervisor, Files, Mail and
Records, USNRC Region I, at (215) 337-5223.
The reporting requirements contained in this letter affect fewer than ten
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persons and therefore are not subject to Office of Management and Budget
clearance as required by P.L.96-511.
Should you have any questions concerning this inspection, we will be pleased
to discuss them with you.
Should you have any questions concerning the items
of Appendix C, please contact Mr. R. Van Niel, Emergency Preparedness
Licensing Branch at (301) 492-4535.
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Sincerely,
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F, y ' & '
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M orge H. Smith, Disector
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Division of Errergena Preparedness
and Operational Support
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Power Authority of the State of New York
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Enclosures:
1.
Appendix A. Significant Emergency Preparedness Findings
2.
Appendix B, Emergency Preparedness Improvement Items
3.
Appendix C, Emergency Preparedness Evaluation Report
4.
NRC Region I Inspection Report No. 50-333/82-03
5.
Confirmatory Action Letter dated April 1,1982
cc w/encis:
L. 'W. Sinclair, President and Chief Operating Officer
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A. Klaussmann, Vice President - Quality Assurance
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!!. C. Cosgrove, Quality Assurance Superintendent
J. F. Davis, Chairman, Safety Review Cocenittee
C. M. Pratt. Assistant General Coensel
F. Petrone Director FEMA Region II
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
State of New York
NRC Resident Inspector
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bec w/encls:
Region I Docket Room (with concurrences)
Chief Operational Support Section (w/o encis)
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APPENDIX A
SIGNIFICANT EMERGENCY PREPAREDNESS FINDINGS
Based on the results of the NRC's appraisal of the James A. FitzPatrick Nuclear
Power Plant Emergency Preparedness Program cenducted February 16 - 25, 1982,
the following improvements are required:
(References are to sections in the
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NRC Region I Inspection Report No. 50-333/82-03).
1.
Establish a centralized training / retraining program which assures coordination
and control of all emergency preparedness training activities.
Develop
selection and qualification criteria for instructors.
(See Section 3.1)
2.
Evaluate facilities, equipment, and procedures for post-accident containment
sampling and analysis to determine maximum concentrations that could be
handled and analyzed under accident conditions.
Provide a written report
of the results of the evaluation to the NRC Region I Office.
(By letur
to Mr. Harold Denton, Director, Office of Nuclear Reactor Regulation,
dated January 11, 1982, the licensee requested an extension of time to
implement post-accident sampling requirements.) (See Section 4.1.1.6)
3.
Develop a plan and schedule for modifying the vent sampling and analytical
system to permit collection, transport, and analysis of post-accident
samples of noble gases, radioiodines and particulates using NUREG-0737
source terms as the basis.
(See Section 4.1.1.7)
4.
Develop plans and procedures for post-accident sampling and analysis of
liquids from systems known to be contaminated or normally contaminated
with radioactive material.
The procedures should contain guidance re.lating
to:
1) whether the liquids can or should be transferred to other suorage
facilities, processed or discharged; 2) those precautions to be taken
during sampling; and 3) those immediate actions required to evaluate the
radiation levels of the liquids.
(See Sections 4.1.1.8, 5.4.2.10, and
5.4.2.11)
5.
Develop procedures for accurately detecting and measuring radiciodine
concentrations of 10 7 uCi/cc in the presence of noble gases.
(See Section 4.2.1.1)
6.
Develop unambiguous Emergency Action Levels (EALs) which provide prompt
and accurate incident classification.
These are to be based upon control
room and plant instrumentation and actual plant conditions, and
include appropriate references to the Emergerev Operating Procedures and to
the appropriate emergency classification scheme in the Emergency Plan.
Update the Emergency Plan and implementing procedures.
(See Section 5.2)
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APPENDIX B
EMERGENCY PREPAREDNESS IMPROVEMENT ITEMS
Based on the results of the NRC's appraisal of the James A. FitzPatrick Nuclear
Power Plant Emergency Preparedness Program conducted February 16 - 25, 1982,
the following items should be considered for improvement:
(References are to
sections in the NRC Region I Inspection Report No. 50-333/82-03).
1.
Provisions of written agreements with contractors for health physics
support for emergency conditions beyond 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
(Section 2.2)
2.
Include more hands-on training; correct inconsistencies existing among
various documents containing training requirements and criteria; provide
training for local support personnel in radiation protection and site
access; develop a mechanism to assure that all members of the emergency
response organization and local support personnel review and are trained
in procedural changes; and provide site specific training for non-licensee
personnel.
(Section 3.1)
3.
Designate a central repository for all onsite and offsite emergency
training record s.
(See Section 3.2)
4.
Provide for unrestricted space in the TSC " staffing area" to accommodate
all assigned personnel including support staff, contractor representatives,
and NRC personnel as well as provide ventilation for the TSC which will
be comparable to the control room.
(Section 4.1.1.2)
5.
Provide for an adequate means of receiving and displaying plant parameter
and meteorology data at the E0F and AEOF as well as provide for necessary
protective clothing, respiratory protection and dosimetry for EOF personnel.
(Section 4.1.1.4)
6.
Re-evaluate reactor coolant sampling and analytical facilities for adequacy
assuming a 10 Ci/ml post-accident reactor coolant source term.
(Section
4.1.1.5)
7.
Develop an alternate sampling capability for the radwaste building
ventilation eff! cent.
(Section 4.1.1.7)
8.
Evaluate the number of assembly areas if experiences based upon drills
and exercises indicate administrative and logistical support problems in
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the areas of personnel accountability, radiation protection, and
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decontamination support.
(Section 4.1.2.1)
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9.
Include the Nine Mile Point decontamination facilities in the mutual
support agreement and establish an alternate onsite decontamination
facility in the event primary facilities are inaccessible.
(See Section
4.1.2.3)
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Appendix B
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10.
Finalize installation of telephone communications for media representa-
tives.
(See Section 4.1.4)
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Perform an engineering study of the ARM system and upgrade the system
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based on the study.
In addition, complete installation and testing of all
monitors.
(See Section 4.2.1.2)
12.
Develop an action plan to implement appropriate recommendations contained
in the environmental study.
(See Section 4.2.1.2)
13.
Establish an alternate stability class determination scheme for use when
the primary information source cannot provide the parameter; include the
characteristic wind direction traces to determine atmospheric stability
class in procedure EAP-4; and formalize the prever.tative maintenance
program.
(Section 4.2.1.4)
14.
Provide assurance that the necessary respiratory protection is available
for personnel in the EOF and that SCBAs will be available for each emergency
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team.
(Section 4.2.2.1)
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15. Develop written agreements with other utilities or agencies for obtaining
additional supplies and equipment for damage control / corrective actions.
(See Section 4.2.4)
16.
Provide reliable transportation to support the emergency planning effort.
(Section 4.2.6)
17.
Re-evaluate emergency and routine procedures to determine if sufficient
emergency response information has been included.
(Section 5.1)
18.
Reference all routine procedures necessary to complete assigned tasks in
the implementing procedures.
(See Section 5.3)
19. Clearly indicate in procedure EAP-1 when supporting groups would be
notified based on the level and type of emergency as well as the conditions
for issuance of follow-up and close-out messages.
(Section 5.4.1)
20.
Provide assurance that implementing procedure checklists will be adequate
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for orchestrating the emergency under changing emergency conditions as
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well as the assumptions used for the Dose Estimate Calculator are correct.
(See Section 5.4.2)
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21.
Develop procedures clarifying survey instrument usage; the collection
media for radioiodine sampling; and alternate locations for survey
instrumentation.
(See Section 5.4.2.1 and 5.4.2.2)
22.
Provide a means of recording in plant survey data in procedure EAP-6 as
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well as assurance that preprograr?<.d analysis routines will work with all
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anticipated samples (charcoal versus silver zeolite cartridges). (Section
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Appendix B
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23.
Revise procedure RTP-31 to include provisions for a detailed checklist;
diagram of sample location and set-up; and precautions for transporting
reactor water samples.
(Section 5.4.2.4)
24.
Provisions for an alternate counting facility and methods to count highly
radioactive samples within procedure RTP-31 as well as provisions for
transmitting original data sheets to the organizational element responsible
for assessment.
(Section 5.4.2.5)
25.
Inclusion of data sheets and specification of reporting requirements to
the element of the emergency organization responsible for dose assessment.
(Section 5.4.2.7)
26.
Provisions of a schematic in procedure RTP-30 for each sample location;
define the purpose of the procedure to reflect its post-accident vent
sampling capabilities; and provide sequential action steps for handling
and transporting high activity samples.
(Section 5.4.2.8)
27.
Provide sequential action steps and cross references between procedures
for handling and analyzing highly radioactive silver zeolite, particulate,
and noble gas vent samples.
(Section 5.4.2.9)
28.
Revise procedure EAP-8 to include a firm commitment to the 30 minute
requirement of NUREG-0654.
(Section 5.4.3.3)
29.
Revise applicable procedures to include provisions for recording the
names and brief status of all individuals surveyed for contamination;
special considerations for skin contaminated with radiofodine; ensuring
that collected data are provided to the organizational element responsible
for radiation protection during emergencies; and recording the serial
number of the instrument used to conduct the survey.
(Section 5.4.3.4)
30.
Perform an evaluation to determine if radiological and environmental
services personnel can reasonably provide radiological support to the
various emergency teams; personnel monitoring and decontamination services
at restricted areas; and the fifteen primary assemtly areas.
(See
Section 5.4.3.4)
31.
Provide a procedure fc- addressing emergency planning contingencies,
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i.e., physical barriert, alarm systems, access control, etc., and possible
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interface for security and local law enforcement personnel.
(Section
5.4.4)
32.
Revise procedure EAP-13 to include references to the use of Work Activities
Control Procedures (WACPs) during emergency conditions.
(Section 5.4.5)
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33.
Revise the Emergency Plan to include an annual audit.
(Section 5.5.4)
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Revise procedure SAP-1 to indicate how exercise and drill improvement
items will be corrected.
(See Section 7.1)
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APPFNDIX C
EMERGENCY PREPAREDNESS EVALUATION REPORT
BY THE
DIVISI0t4 0F EMERGENCY PREPAREDNESS
OFFICE OF INSPECTION AND ENFORCEMENT
U.S. NUCLEAR REGULATORY COMMISSION
IN THE MATTER OF
JAMES A. FITZPATRICK NUCLEAR POWER PLANT
DOCKET NO.
50-333
MARCH 1982
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INTRODUCTION
The Power Authority of the State of New York filed with the Nuclear Regulatory
Commission a revision to the James A. FitzPatrick Emergency dated April 1,1981.
The plan was reviewed against the sixteen planning standards in Section 50.47
of 10 CFR Part 50, the requirements of Appendix E to 10 CFR Part 50, and the
criteria of NUREG-0654/ FEMA-REP-1, Revision 1 entitled " Criteria for Prepara-
tion and Evaluation of Radiological Emergency Response Plans and Preparedness
in support of Nuclear Power Plants," November 1980 which is endorsed by
Regulatory Guide 1.101, Revision 2.
This evaluation report follows the format of Part II of NUREG-0654 in that
each of the Planning Standards is listed and followed by a summary of the
applicable portions of the plans and the deficiencies that relate to that
specific standard.
The final section of this report provides our conclusions.
A separate report will be issued describing the findings and determinations of
the Federal Emergency Management Agency on the State and local emergency
response plans.
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EVALUATION
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A.
ASSIGNMENT OF RESPONSIBILITY (ORGANIZATIONAL CONTROL)
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Planning Standard
Primary responsibilities for emergency response by the nuclear facility
licensee, and by State and local organizations within the Emergency Planning
Zones have been assigned, the emergency responsibilities of the various
supporting organizations have been specifically established, and each
principal response organization has staff to respond and to augment its
initial response on a continuous basis.
Emergency Plan:
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The Federal, State, local and private sector organizations that are in-
tended to be part of the overall response organization for Emergency
Planning Zones are identified.
Federal support is provided by the U.S.
Coast Guard and U.S. Department of Energy.
The role of the State of
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New York is described and reference is made to the New York State Radio-
logical Emergency Preparedness Plan.
Local aid is available through the
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Oswego County Office of Emergency Preparedness.
Private sector support
is provided by the Niagra Mohawk Corporation (Nine Mile Point Station)
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and the General Electric Company.
The concept of operations and its relationship to the total effort are
described and a block diagram showing the interfaces between and among
the principal response organizations is provided.
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The Shift Supervisor shall assume the role of Emergency Director until
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relieved by the Resident Manager or his designated alternate. The
Emergency Director shall have full responsibility for the imple-
mentation and administration of the Emergency Plan.
The Licensee will provide for 24-hour per day emergency response, in-
cluding 24-hour per day manning of the communication links.
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Written agreements developed between Federal, State, and local agencies
and other support organizations having an emergency response role within
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the EPZ's are included. Organizations included are: U.S. Coast Guard,
U.S. DOE Brookhaven Area Office, New York State Department of Health,
Oswego County Office of Emergency Preparedness, Oswego Hospital, State
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University of New York Medical Center, Scriba Volunteer Fire Corporation,
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and the Niagra Mohawk Power Corporation.
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The Licensee is capable of continuous (24-hour) operations for a pro-
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tracted period. The individual responsible for assuring continuity of
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resources is the Senior Vice President, Nuclear Generation.
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DEFICIENCIES
The Plan requires revision and/or additional information as follows:
1.
All existing agreements should be reviewed and updated.
The content
of the letters of agreement should be changed to specifically identify
the emergency measures to be provided and the mutually acceptable cri-
teria for their implementation.
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B.
ONSITE EMERGENCY ORGANIZATION
Planning Standard
On-shift facility licensee responsibilities for emergency response are
unambiguously defined, adequate staffing to provide initial facility
accident response in key functional areas is maintained at all times,
timely augmentation of response capabilities is available,
and the inter-
faces among various onsite response activities and offsite support and
response activities are specified.
The onsite emergency organization of plant personnel and its relation
to the responsibilities and duties of the normal staff complement are
addressed.
The Emergency Director is designated as the individual with the authority
and responsibility to immediately and unilaterally implement and
administer the Emergency Plan, i uluding providing protective action
recommendations to appropriate c+fsite authorities.
The Shift Super-
visor will initially function as Emergency Director until relieved by
the Resident Managar or his designated alternative.
The line of succession for the Emergency Director position is identified
and provision is made in the plan for the Recovery Manager (the Senior
Vice-President, Nuclear Generation or his designated alternative) to
assume primary control from the Emergency Director during a site or
general emergency, with the Emergency Director taking on a coordination
role within the Recovery Organization.
The functional responsibilities of the Emergency Director are addressed.
The responsibility for recommending off-site protective measures may be
delegated.
The interfaces between and among the FitzPatrick Station, local services
support, and State and local government response organizations are
identified.
Corporate personnel who will augment the plant staff are specified for the
areas of logistics support, technical support for planning and reentry /
recovery operations, and for the release of information to news media.
The contractor and private organizations who may be requested to provide
technical assistance to and augmentation of the emergency organization
are specified.
The services to be provided by local agencies for handling emergencies,
including fire-fighting and medical services are identified.
Copies of
letters of agreement are appended to the plan.
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DEFICIENCIES
The plan requires revision and/or additional information as follows:
1.
It appears that the plan, including the appended PASNY policy statement,
provides for the transfer of the authority and responsibility for " major
decisions and commitments" from the Emergency Director to upper PANSY
management. Also the plan states that 'the Emergency Director will be
moved from a position of primary control to one of coordination....".
Since the foregoing may apply during the emergency, prior to the recovery
phase, it appears that a potentially ambiguous and confusing situation
may arise as to the individual responsible for the overall direction and
control of the emergency, and the criteria for the transfer of such
authority and responsibility.
Revise the plan and policy statement to
correct the above.
It is also recommended that the title of " Emergency
Director" transfer to the individual together with the authority and
responsibil'Ly for overall direction and control, particularly during the
emergency phase of the accident.
2.
The description of the emergency organization does not meet the criteria
set forth in Table B-1 of NUREG-u654.
Revise the plan accordingly.
If
the minimum onshift complement and the 30 and 60 minute staffing requirements
are deficient with respect to the aforementioned table, provide a commit-
ment to meet the minimum staffing requirements in accordance with the
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schedule set forth in evaluation criteria B.5 of NUREG-0654.
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3.
It is not clear how-the management level interface with governmental
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authorities is handled during an emergency.
In Section 9.1 of the plan,
a progression is described whereby tha Recovery Manager takes over from
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the Emergency Director after the initial response phase, and concerns
himself primaril3 "with. . .public and press relations, State 'and local as
well as Federal emergency organization interaction, logistics, offsite
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emergency measures and outside technical assistance." When the emergency
situation is resolved, the focus shifts from response to recovery and it
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is within the Recovery Organization that ore finds specific titles of
different corporate level personnel taking care of logistics, technical
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support and release of information to the public. At that point in the
plan, the description of the role of Recovery Manager does not include
the function of interface with governmental authorities.
Identify the
individual by position in the management organization who will have the
responsibility for interfacing with governmental authorities.
4.
The various support services to be provided by the private sector should
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be supported by written agreements and appended to the plan.
These
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agreements should contain the information set forth in criteria B.9 of
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C.
EMERGENCY RESPONSE SUPPORT AND RESOURCES
Planning Standard
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Arrangements for requesting and effectively using assistance resources have
been made, arrangements to accomodate State and local staff at the licensee's
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near-site Emergency Operations Facility have been made, and other organizations
capable of augmenting the planned response have been identified
Eiergency Plan:
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The Emergency Director is authorized to request assistance from the
DOE-Brookhaven Radiological Assistance Program. This DOE assistance
may also be requested by the State or Counties.
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The assistance to be provided by the DOE-Brookhaven Radiological
Assistance Program is described in the plan.
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Provision is made for State and local staff at the licensee's near-site
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EOF.
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Radiological laboratories available during an emergency are identified at
the Nine P.ile Point Station and the Radiation Management Corporation.
Nuclear and other facilities which can be relied upon to supply assistance
in an emergency are identified in Appendix F of the plan.
DEFICIENCIES
The plan requires revision and/or additional information as follows:
1.
The plan does not address the specifics of Federal resources expected,
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their times of arrival or the licensee, State and local resources needed
to support the Federal response.
It is noted in Section 9.4.2 of the plan
that logistical support services "may be needed" for an influx of personnel
from support agencies including such services as air transportation, ground
transportation, field sanitation facilities, and office facilities. The
plan states that the details of these arrangements are described in the
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Headquarters Emergency / Recovery Plan.
Provide sufficient information in
the emergency plan to enable evaluation against criteria C.1.b and c of
NUREG-0654, including the specific resources which are available to support
the Federal response.
Examples of such resources are given in criteria C.1.c
of NUREG-0654.
2.
Describe the provisions for dispatching a licensee representative to the
principal offsite governmental emergency operations centers.
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D.
EMERGENCY CLASSIFICATION SYSTEM
Planning Standard
A standard emergency classification and action level scheme, the bases of which
include facility system and effluent parameters, is in use by the nuclear facility
licensee, and State and local response plans call for reliance on information
provided by facility licensees for determinations of minimum initial offsite
response measures.
Emergency Plan:
The licensee has established an emergency classification scheme using
the four emergency categories set forth in Appendix 1 to NUREG-0654.
The licensee has established various initiating conditions for events that
could initiate one of the four energency classes.
Some of the specific
initiating conditions listed in Appendix 1 to NUREG-0654 have been
addressed.
DEFICIENCIES
The plan requires revision and/or additional information as follows:
1.
Establish Emergency Action Levels (EAls) for each initiating condition
specified in Appendix 1 to NUREG-0654.
The EAls should be observables
(e.g., instrument readings, equipment status indications, alarm
annunicators) which are both necessary and sufficient to explicitly and
uniquely characterize each initiating condition.
It is recommended that the
format be in tabular form for each of the four emergency classes which
lists the initiating conditions and specifies the EALs for each condition.
In addition, the initiating conditions should include all postulated
accidents described in the facili.y FSAR.
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E.
NOTIFICATION METHODS AND PROCEDURES
Planning Standard
Procedures have been established for notification, by the licensee of State
and local response organizations and for notification of emergency personnel
by all response organizations; the content of initial and followup messages
to response organizations and to the public has been established; and means
to provide early notification and clear instruction to the populace within
the plume exposure pathway Emergency Planning Zone have been established.
Emergency Plan:
Procedures for alerting, notifying and mobilizing emergency response
personnel are established.
The procedures include means for verification
of emergency messages.
The contents of the initial emergency messages to be sent from the plant
are established.
Followup messages from the facility to offsite authorities, containing
appropriate information, are established.
DEFICIENCIES
The following requires revision and/or additional information as follows:
1.
Provide a complete description of the administrative and physical means
for prompt alerting and notification of the public within the plume ex-
posure pathway EPZ.
Sufficient detail should be provided for evaluation
against the criteria set forth in Appendix 3 to NUREG-0654.
2.
Provide copies of the written messages intended for release to the public
in the event of a serious emergency.
If these are still in the process of
being developed, provide a schedule for their completion.
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F.
EMERGENCY COMMUNICATIONS
Planning Standard
Provisions exist for prompt communications among principal response organi-
zations to emergency personnel and to the public.
Emergency Plan:
24-hour notification to and activation of the State / local emergency re-
sponse network are provided.
Communications with State / local governments within the EPZ's are provided.
Communications as needed with Federal emergency response organizations are
provided.
Communications between the nuclear facility, State and local EOC's and
radiological monitoring teams are provided.
Provisions are made for alerting or activating emergency response personnel.
Communication by the licensee with NRC headquarters and the NRC Regional
Office is provided.
Provision is made for a coordinated communication link between the licensee
and the fixed and mobile medical support facilities.
Periodic testing of the communications links is provided.
DEFICIENCIES:
1.
Specify the organizational titles and alternates for both ends of the
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communication links which would be involved in initiating emergency
response actions.
2.
Identify the provisions for communications with the U.S. Coast Guard since
they are a primary response organization within the plume exposure EPZ.
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G.
PUBLIC EDUCATION AND INFORMATION'
Planning Standard
Information is made available to the public on a periodic basis on how they
will be notified and what their initial actions should be in an emergency
(e.g., listening to a local broadcast station and remaining indoors), the
principal points of contact with the news media for dissemination of information
during an emergency (including the physical location or locations) are estab-
lished in advance, and procedures for coordinated dissemination of information
to the public are established.
Emergency Plan:
j
A coordinated yearly dissemination of information to the public regarding
how they will be notified and what their actions should be in an emergency
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is provided.
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Written material that is likely to be available in a residence during an
emergency is provided and updated annually.
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The points of contact and physical locations for use by news media during
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an emergency (News Center) are designated.
The Special News Center Director (Plant Information Officer) has the
overall responsibility for public information.
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DEFICIENCIES:
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The plan requires revision and/or additional information as follows:
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1.
Provide a sample copy of the emergency preparedness information which will
be provided for both the resident and transient population around the site.
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2.
Indicate in the plan that the information to be included in what is dis-
tributed to '.he public will include the special needs of the handicapped.
3.
Discuss the provisions for briefing a limited number of the news media at
the EOF.
4.
Discuss the coordinated arrangements made for dealing with rumors during
emergency conditions.
5.
Discuss the provisions for an annual program to acquaint the news media
with the emergency plans, information concerning radiation, and points
of contact for release of public information in an emergency.
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H.
EMERGENCY FACILITIES AND EQUIPMENT
Planning Standard
Adequate emergency facilities and equipment to support the emergency response
are provided and maintained.
Emergency Plan:
A Technicel Support Center (TSC) and Operational Support Center (OSC) have
been established. The Emergency Operations Facility (EOF) is located out-
side the security fence at the Energy Information Center. This facility
will also be used as the Recovery Center.
The EOF will be used for the evaluation and coordination of response
activities and will be the point for the receipt and analysis of field
monitoring data.
An onsite meteorological system including instrumentation, data
collection and transmission to the Control Room and/or turbine bay
basement is in place.
The meteorological data will also be available
Functional use of onsite radiological.and process monitoring systems are
discussed.
Provisions have been made to obtain offsite meteorological data from the
Hancock International Airport in Syracuse in case of failure of onsite
equipment.
Offsite radiological monitors including ratemeters and sampling devices
have been provided.
Emergency instruments and equipment will be inventoried and checked each
quarter and after each use. Sufficient reserves are on hand to replace
those removed for maintenance or calibration.
DEFICIENCIES:
The Plan requires revision and/or additional information as follows:
1.
Insufficient information is given to enable evaluation of the TSC, OSC,
and EOF against NUREG-0696.
Expand the discussion of these facilities,
and provide a commitment to meet the criteria set forth in NUREG-0696.
2.
The plan is silent with respect to the time required to activate and staff
the TSC. Also, it is indicated that the EOF will be activated within one
hour and fully staffed within 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />.
The criteria for timely activation
of these facilities is discussed in NUREG-0696 which indicates that the
TSC and the EOF should be fully functional within 30 minutes and one hour
respectively.
Describe how this criteria will be met.
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3.
Identify the onsite monitors for obtaining seismic and hydrologic in-
formation which may be used for initiating emergency measures in
accordance with criteria H.S.a of NUREG-0654.
4.
Identify the onsite radiological and process monitoring systems in
accordance with criteria H.S.b and H.5.c of NUREG-0654. The monitors
identified should incit.de those used for obtaining Emergency Action
Levels for the appropriate initiating conditions listed in Appendix 1
to NUREG-0654.
Include instrument identification, location, and range.
5.
Identify the fire and combustion products detectors which may be used
for initiating emergency measures in accordance with criteria H.5.d
of NUREG-0654.
6.
Describe your provisions for obtaining offsite information regarding
hydrologic and seismic data as specified in criteria H.6.a of NUREG-0654.
7.
Indicate if the dosimetry provided meets the minimum requirements of the
NRC Radiological Assessment Branch Technical Position for the Environ-
mental Radiological Monitoring Program,
8.
Although the plan discusses the onsite meteorological instrumentation,
it is insufficient te determine compliance with the criteria set forth
in NUREG-0654. Provide detailed information which explicitly addresses
the criteria in Appendix 2 of the aforementioned document.
9.
Indicate that the Operations Support Center and equipment will include
that specified in criteria H.9 of NUREG-0654.
10.
Specify the frequency of instrument calibration or a commitment to do
so at the intervals recommended by the supplier.
11.
Identify the emergency kits by category and location in an appendix
to the plan.
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I.
ACCIDENT ASSESSMENT
Planning Standard
Adequate methods, systems and equipment for assessing and monitoring actual
or potential offsite consequences of a radiological emergency condition are
in use.
Emergency Plan:
Availability of resources to provide initial and continuing assessment
throughout the course of an accident is discussed in general terms.
Methods and techniques for determining the source term of releases with-
in plant systems and the magnitude of the release of radioactive materials
is addressed in general terms.
The relationship between effluent monitor readings and onsite and
offsite exposures and contamination for various meterorological
conditions is discussed.
The methodology for determining the release rate / projected doses if
assessment instrumentation is inoperable or offscale is addressed.
Capability and resources to provide field monitoring within the plume
exposure EPZ are described.
The plan states there is capability to determine radioiodine concentration
in the field as low as 10 7 uCi/cc.
DEFICIENCIES
The plan requires revision and/or additional information as follows:
1.
Identify the plant system and effluent parameter values for each of
the initiating conditions listed in Appendix 1 to NUREG-0654.
2.
As part of the description regarding onsite capability and resources to
provide initial and continuing assessment throughout the course of an
accident, include post-accident sampling capability, radiation and
effluent monitors, in plant iodine instrumentation, and containment
monitoring.
Provide sufficient detail to enable evaluation against
clarification items II.B.3, II.F.1, and III.D.3.3 in NUREG-0737.
3.
Provide detailed information on the methods and techniques used for
determining the source term of releases of radioactive material within
plant systems. As an aid in assessing the extent of potential core
damage include plots which show the containment radiation monitor
reading vs. time following release of gap activity, 1% release of
fuel inventory, and 10% release of fuel inventory.
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4.
Indicate the meteorological information that will be provided to an
offsite NRC center and made available to State agencies for their
use.
5.
Although the plan refers to the licensee's ability to determine internal
dose commitments from key isotopes via water or airborne pathways it
fails to specifically relate the various measured paramenters to the
key isotopes. Describe the means for relating measured field contamination
levels to dose rates for applicable isotopes listed in Table 3 of NUREG-0654.
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J.
PROTECTIVE RESPONSE
h1anningStandard
A range.of protective actions have been developed for the plume exposure path-
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way EPZ for emergency workers and the public. Guidelines for the choice of
protective actions during an emergency, consistent with Federal guidance. are .
developed and in place, and protective actions for the ingestion exposure path-
way EPZ appropriate to the locale have been developed.
, Emergency Plan:
The means used to warn plant employees and visitors that an accident has
occurred have been established.
The Remote Assembly Area at the Niagara Mohawk Service Center has been
established as the relocation facility for evacuated onsite personnel.
Radiological monitoring for evacuated personnel will be provided at both
the site and the remote assembly area.
Provisions have been made for respiratory protection devices-and protective
. clothing for onsite emergency personnel.
Provision has been made for the evacuation of non-essential onsite
personnel.
Prompt notification will be made directly to State and local authorities
responsible for implementing protective measures by the Emergency
.
Director when an accident could actually or potentially affect
individuals within the plume exposure pathway EPZ.
Evacuation time estimates for the population within the plume exposure
pathway EPZ are provided in the Oswego County emergency plan.
The bases for the choice of recommended prttective actions for the plume
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exposure pathway is shown in Figure 4.2 of the plan.
DEFICIENC{jS
The plar, requires revision and/or additional information as follows:
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1.
The plan establishes the means to warn or advise onsite employees
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and visitors.
Describe the means used to warn or advise contractor /.
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construction personnel or those individuals who may be outside the
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protected area but inside the owner controlled area.
Also, specify
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the ti.ne required to notify individuals who might be beyond the range
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of the onsite emergency signals.
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2.
Discuss the means that will be used to transport people to the offsite
assembly location (s), and alternative routes that could be used for
various wind directions or in case of inclement weather.
Provide a
map showing the alternate evacuation routes from the plant site.
3.
Indicate the provisions for decontamination of evacuated personnel
at the remote assembly area.
4.
Indicate that the accountability for onsite personnel can be accomplished
within 30 minutes from the start of an emergency
5.
Describe the availability of radioprotective drugs for onsite emergency
personnel.
6.
Provide maps as part of the plan which c1carly show the information
described in criteria J.10.a and b of NUREG-0654.
7.
Provide a complete description of the early warning system in
accordance with Appendix 3 of NUREG-0654 which could be used for
notifying all segments of the transient and resident population.
Identify the specific offsite authorities by position who have the
authority and responsibility to activate the aforementioned system.
8.
Discuss the consideration given to the local protection afforded by
residential units and other shelters as part of the bases for selecting
recommended protective actions for the plume exposure pathway during
emergency conditions.
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K.
RADIOLOGICAL EXPOSURE CONTROL
Planning Standard
Means for controlling radiological exposures, in an emergency, are established
for emergency workers. The means for controlling radiological exposures shall
include exposure guidelines consistent with EPA Emergency Worker and Lifesaving
Activity Protective Action Guides.
Emergency Plan:
Onsite exposure guidelines cuasistent with EPA Emergency Worker and Life
Saving Activity Protective Action Guides have been established.
An onsite radiation protection program has been established for emer-
gency situations including methods to implement exposure guidelines.
The plan identifies the Emergency Director as the person authorized
to approve emergency workers to exceed 10 CFR Part 20 exposure limits.
Contamination control measures have been established for area access.
Provisions have been made for decontaminating onsite personnel.
DEFICIENCIES:
The plan requires revision and/or additional information as follows:
1.
The plan indicates that the methods and conditions for perm'tting personnel
to receive emergency radiation exposures, including the prctisions for
expeditious decisions in such cases, is described in the implementing
procedures.
Identify these procedures by number and title, or as an
alternative provide a synopsis in the plan itself.
2.
Describe the capability for providing 24-hour a day determination of
radiation doses to emergency workers, distribution and reading of
dosimeters, and maintenance of dose records.
3.
The plan discusses decontamination in very general terms.
Specify the
action levels for determining the need for decontamination, and the
specific capability for decontamination of emergency personnel wounds,
supplies, instruments, and equipment.
4.
Identify the onsite contamination control measures for food and potable
water supplies, and the criteria for permitting the return of areas and
items to normal usage.
5.
Although the plan discusses the general capability for decontamination,
indicate the decontaminants available for radiciodine contamination of the
skin for relocated onsite personnel.
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L.
MEDICAL AND PUBLIC HEALTH SUPPORT
Planning Standard
Arrangements are made for medical services for contaminated injured individuals.
Emergency Plan:
Arrangements have been made for local and backup hospital and medical
services having the capability for handling contaminated individuals,
and for the evaluation and treatment of radiation exposure and uptake.
Onsite first aid capability is provided.
Arrangements have been made to transport victims of radiological accidents
to medical support facilities.
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M.
RECOVERY AND REENTRY PLANNING AND POSTACCIDENT OPERATIONS
Planning Standard
General plans for recovery and reentry are developed.
Emergency Plan:
General plans and procedures for reentry and recovery are described, and
criteria are specified for declaring an emergency situation resolved.
The structure, functions and membership of the facility recovery organization
are described.
Means are specified for informing members of the response organizations
that a recovery operation is to be initiated.
A method for periodically estimating total population exposure is
established.
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N.
EXERCISES AND DRILLS
Planning Standard
Periodic exercises are (will be) conducted to evaluate major portions of
emergency response capabilities, periodic drills are (will be) conducted to
develop and maintain key skills, and deficiencies identified as a result of
exercises or drills are (will be) corrected.
Emergency Plan:
An exercise to test the integrated capability and a major portion of the
basic elements of the emergency plan will be conducted annually, and
will include mobilization of State and local personnel and resources to
verify their capability to respond.
The scenario for the annual exercise will be varied from year to year to
assure that the major elements of the plan and the preparedness
organizations are tested at least once in a five year period.
Some
exercises will be unannounced, and periodic participation by Federal
response organizations will be included in the exercise. Observers
from Federal, State and local organizations, as appropriate, will
evaluate the annual exercise.
Monthly communications drills will be conducted with State and local
governments within the plume exposure pathway EPZ. Annual communication
drills will be conducted between the licensee, State and County emergency
operations centers, field survey teams, Federal emergency response
organizations, and States within the ingestion pathway EPZ.
Fire drills are conducted in accordance with the plant procedures.
Provisions are made for an annual medical emergency drill, involving
a simulated contaminated individual, which requires participation by
the local support services.
An annual radiological monitoring drill including the collection and
analysis of sample media together with provisions for testing communications and
record-keeping is provided.
A semi-annual Health Physics drill will be conducted to test the response
to and analysis of elevated airborne and liquid samples. Once a year,
the analysis of in plant liquid samples will be included in the drill.
The scenarios to be developed for the drills and exercises will contain
the elements outlined in NUREG-0654.
Provision is made for a critique of the exercise as soon as practical
after it is held, in which the actions and interactions of response
organizations can be evaluated.
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The Plant Operating Review Committee (PORC) will review the drill and
exercise evaluation reports. Corrective actions recommended by the
PORC will be implemented by licensee management.
DEFICIENCIES
The plan requires revision and/or additional information as follows:
1.
The annual exercise scenario thould simulate an offsite radiological
release of sufficient magnitude to delcare a " General Emergency".
Provisions should be made for staring an exercise between 1800 and 2400
hours, and another between 0000 and 0600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> one every six years.
Exercises should be scheduled such that v?rious weather conditions are
encountered.
2.
Communications drills with the Federal response organizations and the states
within the ingestion pathway EPZ should be tested quarterly rather than
annually.
The communications with the NRC shall be tested monthly in
accordance with paragraph E.9.d of Appendix E to 10 CFR Part 50. Also,
the communications drills should include the aspect of understanding the
message content.
3.
Include in the health physics drills, the analysis of inplant liquid
samples with actual elevated radiation levels including use of the
post-accidenc sampling system.
4.
Discuss the mix of structured and less structured aspects of the program
which will allow free play for decision making during drills and exercises.
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O.
RADIOLOGICAL EMERGENCY RESPONSE TRAINING
Planning Standard
Radiological emergency response training is provided to those who may be
called on to assist in an emergency.
Radiological Plan:
Site specific training is offered to offsite emergency organizations.
Onsite emergency groups receive formal training in addition to practical
training during drills. A formali;ed training program has been establisheo
to ensure that all personnel who actively participate in a radiation emer-
gency maintain familiarity with their responsibilities.
First aid personnel receive Red Cross Multi-Media or equivalent training.
A specialized training program has been established for the various
categories of emergency personnel responsible for the implementation of
the plan.
The licensee has provided for annual retraining of personnel with
emergency response duties.
DEFICIENCIES:
The plan requires revision and/or additional information as follows:
1.
The abbreviated approach given to the treatment of the radiological
emergency response training program lacks a substantive base upon
which to perform an evaluation.
The program is essentially summarized
in a single figure in the plan. Although the description appears
comprehensive, it lacks a certain depth and scope to enable a re-
assuring finding.
Expand your discussion of the program regarding
the specific nature of the specialized training for each category
identified in criteria 0.4 of NUREG-0654, and include some detail
regarding the scope of the training such as the number of classroom
hours provided for each category.
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P.
RESPONSIBILITY FOR THE PLANNING EFFORT:
DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION OF EMERGENCY PLANS
Planning Standard
j
Responsibilities for plan development and review and for distribution of
emergency plans are established, and planners are properly trained.
>
Emergency Plan:
)
Training for the Emergency Planning Coordinator is provided via Emergency
.
Planning Workshops conducted with other utilities, attendance at NRC,
FEMA and at other government-sponsored Emergency Planning seminars, and
participation in specific licensee training programs related to emergency.
'
preparedness.
Emergency planning coordination is the responsibility of the Radiological
.
and Environmental Services Superintendent.
The Emergency Planning Coordinator has the overall responsibility for the
'
coordination and planning of emergency response planning efforts, and for
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review and updating of the Emergency Plan and Implementing Procedures.
The licensee's plan will be updated as needed, taking into account changes
identified by drills and exercises, and will be reviewed and certified to
be current by the Plant Operations Review Committee on an annual basis.
Procedures for implementing the Emergency Plan are listed by procedure
number and title.
.
An independent audit of the emergency preparedness program will be
conducted and documented by the Quality Assurance Department and/or
an independent contractor. The Resident Manager and the Senior Vice
President, Nuclear Generation will review the results of the audit
and decide on any action to be taken.
The results of the audit will
be made available to involved local, State and Federal organizations,
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and the audit results will be kept for a period of at least five years.
'i
DEFICIENCIES
The plan requires revision and/or additional information as follows:
4
1.
Identify the individual by position who has the overall authority for
radiological emergency response planning.
2.
The letters of agreement should be reviewed'and certified current on an
annual basis rather than biennially as stated in the plan.
3.
Provide a synopsis of the administrative procedures which assures that
criteria P.5 of NUREG-0654 is met regarding changes to the emergency
plan.
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4.
Provide a detailed listing of supporting plans and their source.
5.
Identify in Appendix A the section of the plan to be implemented by each
procedure.
6.
Provide a cross-reference between the plan and the evaluation criteria
in NUREG-0654.
7.
In accordance with paragraph 50.54(t) of 10 CFR Part 50, the independent
review of the emergency preparedness program shall be conducted every 12
months rather than every two years as stated in the plan.
The review
shall include an evaluation for adequacy of interfaces with State and local
governments, drills, exercises, capabilities, and procedures.
8.
Indicate that the telephone numbers in the emergency procedures will
be updated quarterly.
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CONCLUSION
Based on our review, we conclude that the F1t: Patrick Emergency Plan, upon
satisfactory correction of the previously identified deficiencies, will
meet the planning standards set forth in NUREG-0654, Revision 1, " Criteria
for Preparation and Evaluation of Radiological Emergency Response Plans
and Preparedness in Support of Nuclear Power Plants," November 1980.
The NRC evaluation on the overall state of emergency preparedness for the
James A. FitzPatrick Site will be made folowing review of the findings and
determinations made by FEMA on the State and local emergency response plans,
and the review of the joint exercise held to demonstrate the capability to
implement the onsite and offsite plans.
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