ML20053E901
| ML20053E901 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 05/20/1982 |
| From: | Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Maier J ROCHESTER GAS & ELECTRIC CORP. |
| Shared Package | |
| ML20053E902 | List: |
| References | |
| NUDOCS 8206100192 | |
| Download: ML20053E901 (51) | |
See also: IR 05000244/1981022
Text
.
..
-
-
.
.
.
4
MAY 2 01982
Docket No. 50-244
Rochester Gas and Electric Corporation
ATTN:
Mr. John E. Maier
Vice President
Electric and Steam Production
89 East Avenue
Rochester, New York 14649
Gentlemen:
4
Subject:
Emergency Preparedness Appraisal 50-244/81-22
To verify that licensees have attained an adequate state of onsite emergency
preparedness, the Nuclear Regulatory Commission is conducting special appraisals
at each power reactor site. These appraisals are being performed in lieu of
certain routine inspections normally conducted in the area of emergency prepared-
ness.
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 improve-
ments in NRC requirements and guidance.
During the period of November 2-13, 1981, the NRC conducted an appraisal of
the emergency preparedness program for the R. E. Ginna Nuclear Power Plant.
'
Areas examined during this appraisal are described in the enclosed report
,
50-244/81-22. Within these areas, the appraisal team reviewed selected procedures
and representative records, inspected emergency facilities and equipment,
i
l
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
,
j
are discussed in Appendix A "Significant Emergency Preparedness Findings".
l
Significant findings for which you have made acceptable commitments to resolve
were discussed in the Confirmatory Action Letter dated December 15, 1981. A
copy of the letter is included as Enclosure 5.
l
Other areas needing improvements are discussed in Appendix B, " Emergency
Preparedness Improvement Items."
,
1
0FFICIAL RECORD COPY
Oi
8206100192 820520
PDR ADOCK 05000244
W
O
.
(
.
.
MAY 2 01982
Rochester Gas and Electric Corporation
2
In conjunction with the aforementioned appraisal, emergency plans for your
facility were reviewed by the Emergency Preparedness Licensing Branch, Division
of Emergency Preparadness, 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."
Appendices A, B and C of this letter contain an inclusive listing of all
outstanding emergency preparedness items at your facility at this time. Tnere
are some differences between the enclosed report and the items described in
the enclosed Appendices A and B.
This is principally the result of management
review and the decision to move some items from Appendix A (required) to
Appendix B (recommended), or the reverse.
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) steps
which have been taken, (2) steps 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 Regulaticas.
This is to inform you that if the deficiencies list'ed in Appendix A which were
not included in the December 15, 1981 letter, are not corrected within 120
days from the date of this letter, 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 enclosure
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
persons and therefore are not subject to Office of Management and Budget
clearance as required by PL 96-511.
OFFICIAL RECORD COPY
-
,
.
0M
Rochester Gas and Electric Corporation
3
Should you have questions concerning this inspaction, we will be pleased to
discuss them with you.
Should you have questions concerning the items of
Appendix C, please contact Mr. R. Van Niel, Emergency Preparedness Licensing
Branch at (301) 492-4535.
Sincerely,
Original S16ned BY8
George H. Smith, Director
Division of Emergency Preparedness
and Operational Support
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 Number 50-244/81-22
5.
Confirmatory Action Letter, dated December 15, 1981.
cc w/ encl:
Harry H. Voigt, Esquire
Central Records (3 copies)
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
i
l
State of New York
NRC Resident Inspector
F. P. Petrone, Director, FEMA Region II
i
!
)
i
bec w/ encl:
l
Region I Docket Room (with concurrences)
!
Chief, Operational Support Section (w/o encls)
!
.
!
b
(
'
f
I g
$ RI: EPOS
POS
A
i
- T
Pt wc
r
ker
ny
ith
yn
,18/82
f5
6li
"
i
0FFICIAL RECORD COPY
l
!
1
!
... - - - - - -
--
-
[
.
.
.
APPENDIX A
SIGNIFICANT EMERGENCY PREPAREDNESS FINDINGS
. Based on the results of the NRC's appraisal of the R. E. Ginna Nuclear Power
Plant Emergency Preparedness Program conducted November 2-13, 1981, the following
improvements are required: (References are to sections in the NRC Region I
Inspectinn Report No. 50-244/81-22.)
1.
Develop and implement administrative means to ensure adequate coordination
between onsite emergency organizational elements.
(See Section 1.3)
2.
Establish an emergency organization which provides for all emergency
functions needed during initial, intermediate and final phases of augmenta-
tion.
Revise the Emergency Plan to include a description of the organization,
and update implementing procedures to be consistent with the organization.
The description shall include sufficient detail to define the command
hierarchy; specify its structure, reporting chains and inter-relationships
at any phase of cugmentation; and include supervisory as well as non-
supervisory elements.
(See Section 2.1)
3.
For each functional area specified within the emergency organization
provide a list of personnel trained and qualified to perform the tasks
associated with the area. These lists shall identify the current status
of each individual. Provisions to maintain lists current shall be developed
and implemented.
(See Section 2.1)
4.
Realign the emergency plan training program to be consistent with the
functional areas, requirements, and structure of the emergency organization.
(See Section 3.1)
5.
Develop means to verify that all individuals with emergency duties have
been trained and have attained a minimum level of proficiency. This
shall include, but not be limited to hands-on training and walkthroughs.
(See Section 3.2)
6.
Complete the installation and testing of equipment in the Technical
Support Center (TSC) to ensure that it will be habitable and functional
and able to perform its intended use during accident conditions.
(See
Section 4.1.1.2)
7.
Provide for an Emergency Operations Facility (EOF) having sufficient and
appropriate equipment to enable the direction, coordination and evaluation
of licensee's activities as demanded by the emergency organization.
(See
j
Section 4.1.1.4)
t
OFFICIAL RECORD COPY
1
!
.
!
i
-~r
w ,~ -
e,,,--
,--...,.-nn.,
,,,ne,
-,,,-._,-,,,--.n,,,.,,,-w,....
....-,,-,,-,n--n.---m,
,
,r--n-.e-
,--
-,
n..
-
-
,
.
.
Appendix A
2
8.
Provide sampling equipment at penetrations-124 and 203; maintain sampling
apparatus ready for prompt connection to-the penetration isolation valves;
and evaluate the need for additional area monitoring equipment at the
sample stations.
(See Section 4.1.1.6).
9.
Evaluate the need for:
retention, transfer, storage, sampling and analysis
of highly radioctive liquid wastes that could be generated as a result of
severe accidents.
(See Section 4.1.1.8)
10.
Evaluate the types of instrumentation needed to rapidly and accurately
measure radiation and radioactive contamination levels based on the needs
of the various functional areas of response during emergencies, and
'
implement their use.
(See Section 4.2.1.1)
11.
Include in the Emergency Plan the current means used for determining the
magnitude of release, and for continuous dose assessment.
(See Section
"
4.2.1.4)
12 .'
Install state and county hot lines from the TSC and complete the installation
of communications equipment within the EOF.
(See Section 4.2.3)
13.
Review general emergency implementing instructions to assure adequate
guidance and necessary detail is provided for the emergency coordinator.
(See Section 5.3)
14. Develop a technique for making protective action recommendations based on
a method which considers: source, elevation, and buildings in the vicinity
of the release; the real-time characteristics of the release and actual
meteorological information.
(See Section 5.4.2)
15.
Identify techniques to compensate for potential uncertainties associated
with plume trajectories, and include the technical basis as an appendix
to the emergency olan.
(See Section 5.4.2)
16.
Re-evaluate provisions to rapidly and accurately detect and measure
airborne radiciodine ur. der field conditions, in the presence of noble
'
gases and develop a method for field determination of plume immersion as
opposed to overhead exposure.
(See Section 5.4.2.1)
17.
Provide means for obtaining gas concentration readings from R-12; provide
criteria for selecting containment air sampling location; and 'qcorporate
data sheets in the procedure.
(See Section 5.4.2.6)
18.
Undertake and complete a review of all emergency plan implementing procedures
1,
and make appropriate revisions or write new procedures as necessary, to:
i
a)
Clarify required actions, and eliminate existing ambiguities, inconsis-
tencies and errors.
!
$
'
0FFICIAL RECORD COPY
1
---
.,..,-.---,,,,._-._,..-..-.-.c
- - - - . - . - , - . - - -
-- --
-~ . - - - - -
--.
-
r
_
.
Appendix A
3
b)
Clarify duties and responsibilities of personnel involved in the
various actions.
c)
Provide specific cross-references to other procedures in the action
steps as needed to detai) and clarify further actions.
For the procedures listed below, specific matters which need to be addressed
in the revision are described in the referenced section of the report.
SC-1.4 (See Section 5.4.1)
SC-1.7E (See Section 5.4.2.2)
SC-1.7G (See Section 5.4.2.2)
SC-1.9 (See Section 5.4.2.3)
SC-1.13 (See Section 5.4.2)
PC-23.1 (See Section 5.4.2.4 and 5.4.2.5)
SC-1.148 (See Section 5.4. 3.5)
SC-1.15 (See Section 5.5.1)
SC-1.ll (See Section 5.4.6)
General (See Section 5.1)
General (See Section 5.4.2.8)
General (See Section 5.4.2.9)
New Procedure (See Section 5.4.2.10)
New Procedure (See Section 5.4.2.11)
New Procedure (See Section 5.4.3.1)
New Procedure (See Section 5.4.3.4)
General (Sea Section 5.4.5)
19.
Include in the Emergency Plan, the method to be used for determining
the magnitude of and for continually assessing the impact of the
release of radioactive materials.
(See Section 5.4.2)
20.
Provide means for reassembling personnel in alternate assembly
areas. (See Section 4.1.2.1)
0FFICIAL RECORD COPY
r
.
APPENDIX B
EMERGENCY PREPAREDNESS IMPROVEMENT ITEMS
Based on the results of the NRC's appraisal of the R. E. Ginna Nur: lear Power
Plant Emergency Preparedness Program conducted November 2-13, 1981, the following
items should be considered for irprovement:
(References are to sections in
the NRC Region I Inspection Report No. 50-244/82-22.)
1.
Assign another individual to assist the EPCs on their emergency planning
duties.
(See Section 1.1)
2.
Establish a specific formal selection criteria for personnel responsible
for emergency planning.
(See Section 1.4)
3.
Preposition sampling and monitoring equipment to detect and measure
airborne and particulate radioactivity in the control room.
(See Section
4.1.1.1)
4.
Provide radiation monitoring and radiation protective equipment and
supplies in the OSC.
(See Section 4.1.1.3)
5.
Evaluate need for additional permanent shielding in the counting room and
Nuclear Sample Room.
(See Section 4.1.1.5)
6.
Develop improved remote sample bandling equipment.
(See Section 4.1.1.5)-
7.
Perform a study to determine the number of detectors (ARMS) with sufficient
high range to provide in plant post-accident radiation measurements
useful to accurately detect and classify emergency conditions.
(See
Section 4.2.1.2)
8.
Establish a mechanism to assure that a continuous record of meteorological
information is available in the CR, the TSC and EOF.
Include, as a
minimum, a hard copy' listing of 15 minute averaged values or a continous
trace of wind direction and speed and an estimate of atmosphere stability.
(See Section 4.2.1.4)
9.
Revise the Emergency Plan, and procedures (e.g. RD-14 and CP-250) to
ensure they are consistent with the equipment currently in place.
(See
Section 4.2.1.4)
10.
Identify an alternate source of meteorological data.
(See Section 4.2.1.4)
0FFICIAL RECORD COPY
.
.
.
. -
,
.
,
t
Appendix B
2
i
.
Evaluate present SCBA refilling air facilities to ensure tnat SCBA refilling
11.
.
'
capabilities will be available under the most severe accident scenarios.
1
(See Section 4.2.2.1)
12.
Provide means to ensure that at least one emergency vehicle would be
available to perform offsite monitoring functions under severe weather
conditions.
(See Section 4.2.6)
13.
Review E0Ps to incorporate clear and concise instructions for the user to
l
link emergency action levels and emergency classifications.
(See Section
5.2)
14.
Provide augmented notifications to local authorities comparable to that
given the state authorities.
(See Section 5.4.1)
15.
Provide offsite dose projections for abnormal releases and link them to
EPA recommended protective action guides.
(See Section 5.4.1)
16.
Rectify the Specialized Call List (SC-1.12C) distribution error.
(See
Section 5.4.1)
17. Develop means to minimize distribution errors in emergency procedures,
and to verify that vital lists would be readily available to the elements
responsible for making the notification.
(See Section 5.4.1)
18.
Provide instructions for obtaining keys for air sample stations.
(See
Section 5.4.2.1)
'
19.
Reconsider the value of TLD placement against plume tracking by air
sampling and direct radiation measurements.
(See Section 5.4.2.1)
20.
Review the sample analysis areas of PC-23.2 to upgrade radiation protection
guidance consistent with activity levels and source terms specified in
(See Section 5.4.2.7)
,
,
21.
Develop a method to ensure that only currently authorized procedures are
i
present in the procedure binders.
(See Section 5.5.3)
22.
Provide administrative means to ensure that letters of agreement with
off-site agencies are updated on an annual basis.
(See Section 6.1)
i
23.
Implement means of public information other than the dissemination of
I
brochures (e.g. posters in public place, media announcements, notices in
the Yellow Pages of the Telephone Directory, etc.) (See Section 6.2)
i
24. Provide annual training for news media representatives, to familiarize
'
them with emergency plans, radiation, points of contact for release of
'
,
public information, locations and equipment to be used during emergencies.
'
(See Section 6.3)
i
4
0FFICIAL RECORD COPY
,
m
_ _
., . . . , . . . _
. _ . , _ - -
,, _
,
- . - _ . , _ . . . . , - _ - _ - , - - . , _ . _ - _ _ .
-
- - - - .
-
-
Appendix B
3
25.
Evaluate current post-accident plant vent sampling facilities to assure
that a representative sample can be collected, transported, and analyzed
such that whole body and extremity doses would be as low as reasonably
achievable.
(See Section 4.1.1.7)
26.
Re-evaluate EALs to assure that initiating conditions are defined as far
as practicable in terms of specific, observable parameters (e.g. measured
effluent release rates) which are readily available in the control room.
(See Section 5.3)
27.
Provide for early assessment of plume pathway so that instructions aboJt
the location of the plume will be given to offsite survey teams.
(See
Section 5.4.2.1)
28.
Evaluate the need for maintaining a supply of selected damage control,
and corrective action equipment and supplies, and for positioning the
same so that it will be accessible for use during emergencies.
(See
Section 4.2.4)
OFFICIAL RECORD COPY
1
,'.
,.
APPENDIX C
Ef1ERGENCY PREPAREDNESS EVALUATION REPORT
BY THE
DIVISI0tl 0F EMERGENCY PREPAREDNESS
OFFICE OF INSPECTION AND ENFORCEMENT
U.S. HUCLEAR REGULATORY COMfilSSION
IN THE MATTER OF
GINNA NUCLEAR STATION
DOCKET NO. 50-244
MARCH 1982
.
J
,
INTRODUCTION
The Rochester Gas and Electric Corporation filed with the Nuclear Regulatory
Commission revisions to the Ginna Emergency Plan dated September 11, 1981 and
November 30, 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 Preparation and Evaluation of Radiological Emergency Response Plans
and Preparedness in Support of Nuclear Power Plants," November 1980,
which is endorsed by Revision 2 of Regulatory Guide 1.01.
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 plan 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.
.-
.
-
-
-
. _ _
.-
.
EVALUATION
A.
ASSIGNMENT OF RESPONSIBILITY (ORGANIZATIONAL CONTROL)
Planning Standard
Primary responsibilities for energency response by the neulear facility licensee,
and by State and local organizations within the Emergency Planning Zones have
been assigned, the energency responsibilities of the various supporting organi-
zations have been specifically established, and each principal response organi-
zation has staff to respond and to augment its initial response on a continuous
basis.
Emergency Plan:
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
New York is described and reference is made to the New York State Radio-
logical Emergency Preparedness Plan.
Local aid is available through the
Monroe County Office of Energency Preparedness and the Wayne County Office
of Disaster Preparedness.
Private sector support is provided by IMPO,
Westinghouse, Helgeson Nuclear Services, and the New York Power Pool.
2
_ - _ _ -
_
_.
- - - -
_
,.
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.
The Shift Supervisor shall assuae the role of Dnergency Coordinator until
relieved by the Plant Superintendent or a specially trained staff member.
The Emergency Coordinator 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.
Written agreenents referring to the concept of operations developed be-
tween Federal, State, and local agencies and other support organizations
having an emergency response role within the EPZ's are included.
Organi-
zations included are: U.S. Coast Guard, U.S. DOE Brookhaven Area Office,
New York State Department of Health, Wayne County Sheriff, Ontario
Volunteer Emergency Squad, Rochester General Hospital, Ontario Fire
Company, and the Radiation Management Corporation.
The Licensee is capable of continuous (24-hour) operations for a pro-
tracted period.
The individual responsible for assuring continuity of
resources is the Vice President of Electric and Steam Production.
3
-
.
-
-
.
_
-
,
DEFICIENCIES
,
The Plan requires revision and/or additional information as follows:
,
1.
The block diagram dipicting the interrelations of the Ginna Station
with the various response organizations should be expanded to
include all supporting organizations which may provide a primary
response role such as the county sheriff's departments and private
sector contractors.
2.
Provide agreements with the Wayne County Office of Disaster Preparedness,
the Monroe County Office of Emergency Preparedness, and the Monroe
,
i
County Sheriff's Office.
3.
All existing agreements should be reviewed and certified current on
i
an annual basis.
-
l
.
1
4
"
-
.
__
.
_ _ , _ - _ _ _ _ _ _ _ _ _ - _ _ _ . , . . _ _ - - .
.
_ . . . _ _ _ . _ _ _ _ _ _ . -_
_
_ . _ , - - - .
. _ . . .
..
_
.
, , ,
,.
B.
ONSITE EMERGENCY ORGANIZATION
Planning Standard
l
On-shift facility licensee responsibilities for emergency response are unam-
higuously defined, adequate staffing to provide initial facility accident
response in key functional areas is maintained at all times, timely augmen-
l
tation of response capabilities is available, and the interfaces among various
onsite response activities and offsite support and response activities are
s peci fied.
The onsite emergency organization of plant personnel and its relation to
the responsibilities and duties of the normal staff complement are addressed.
The Emergency Coordinator is designated as the individual with the respon-
sibility and authority to direct and coordinate emergency actions.
The position of the Emergency Coordinator will initially be filled by the
Shift Supervisor until relieved by a specially trained member of the staff
and ultimately by the Plant Superintendent.
The functional responsibilities of the Emergency Coordinator are addressed.
The responsibility for recommending off-site protective measures may not
be delegated.
5
-
,
The interfaces between the Ginna Station, local services support,
and State and local government response organizations are
identi fied.
The corporate management, administrative and technical support personnel
'
who will augment the plant staff are specified.
Logistics support is
provided by the Vice President of Employee Relations; technical support
is given by the Assistant Chief Engineer of Design and Construction;
management level interface with governmental authorities is provided by
the Vice President of Steam and Electric Production; and release of
information to the news media is coordinated under the Senior Vice Presi-
dent of General Services.
The contractor and private organizations who may be requested to provide
technical assistance to and augmentation of the emergency organization
are specified.
Organizations listed include INPO, Westinghouse, Helgeson
Nuclear Services, and the New York Power Pool.
The services to be provided by local agencies for handling energencies,
<
including fire-fighting and medical services are identified.
Copies of
letters of agreement are appended to the plan.
'
6
.
.
DEFICIENCIES
The plan requires revision and/or additional information as follows:
1.
Provide a block diagram of the onsite emergency organization which covers
the major functional areas identified in Table B-1 of NUREG-0654 and
identifies the positions from the normal staff complement which fulfil
these functions.
2.
Specify by title the individuals, including members from the corporate
staff, qualified to assume the pcsition of Emergency Coordinator.
3.
The description of the emergency organization staffing in the plan differs
so greatly from that set forth in Table B-1 of NUREG-0654, that a valid
comparison between the two cai.not be made.
Provide a revised format
equivalent to Table B-1 of NUREG-0654.
If the minimum on-shift complement
and the 30 and 60 minute staffing requirements are deficient with respect
to the aforementioned table, provide a commitment to meet the minimum
staffing requirements in accordance with the schedule set forth in eval-
uation criteria B.5 of NUREG-0654.
4.
The figure dipicting the interrelationships of the Ginna Station with the
various response organizations should include the technical support center,
operational support center, emergency operations facility, and licensee
headquarters su port.
r
7
.-
.
-
,,
,
.
5.
The various support services to be provided by the private sector (Westing-
i
house, Helgeson Nuclear Services, New York Power Pool, INPO) should be
supported by written agreements and appended to the plan. These agreements
,
should contain the infomation set forth in criteria B.9 of NUREG-0654.
d
!
\\
\\
l
l
8
i
1
.
C.
EMERGENCY RESPONSE SUPPORT AND RESOURCES
Planning Standard
Arrangements for requesting and effectively using assistance resources
ha"e been made, arrangements to accomodate State and local staff at the
licensee's near-site Emergency Operations Facility have been made, and
other organizations capable of augmenting the planned response have been
identified.
Emergency Plan:
The Emergency Coordir.ator is authorized to request assistance from
the DOE-Brookhaven Radiological Assistance Program.
This DOE assistance
may also be requested by the State or Counties.
The assistance to be provided by the DOE-Brookhaven Radiological
Assistance Program is described in the plan, and it is stated that
the assistance could be on site within four hours of a request.
The provision of support services needed to maintain Federal
radiological assistance is addressed in the plan.
The Emergency Coordinator will assign a competent representative to
the County emergency operating center.
9
1
_
_
- ._
i
, . .
.-
Radiological laboratories available during an emergency are identified at
the Ginna Station, the Nine Mile Point Station, and the Radiation Managemert
Corporation.
Nuclear and other facilities which can be relied upon to supply assistance
in an emergency include INPO, the New York Power Pool, the laboratories
of the Nine Mile Point nuclear facility of Niagara Mohawk Power Corporation,
and the Radiation Management Corporation.
DEFICIENCIES:
The plan requires revision and/or additional information as follows:
1.
Identify the specific resources which are available to support the Federal
res ponse.
Examples of such resources are given in criteria C.1.c of
10
-. . _ .
-
- _ _ _ . _ .
-
.
.
.
D.
09ERGENCY 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 energency classification scheme which in-
cludes 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 emergency classes.
Most 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.
It appears that the plan identifies a " Plant Radiation Emergency" as one
of five energency categories.
This is inconsistent with the intent and
guidance set forth in NUREG-0654 to establish a uniform emergency classi-
fication scheme throughout the nuclear power industry.
As appropriate,
11
.
.
,
the evants identified in this fifth category should be incorporated under
one of the four emergency classes defined in Appendix 1 to NUREG-0654.
In
addition, the " purpose", " licensee actions", and "offsite agency actions"
should be clearly stated for each of the four emergency categories.
.
2.
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 char-
acterize 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 facility FSAR.
12
.
.-
_.
.
.
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 org6nizations 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 energency response per-
sonnel are established.
The contents of the initial energency messages to be sent from the plant
are established.
Followup messages from the facility to offsite authorities, containing
appropriate information, are established.
The licensee states that a public alerting system will consist of sirens
together with a mix of tone alert radios and mobile loud speakers.
13
__
-
..
.
DEFICIENCIES:
The following req"4
revision and/or additional infonnation as follows:
1.
Since the onsite plan provides for five categories of emergencies, whereas
the offsite plans only use four such categories, describe the mutually
agreeable bases for notification of the response organizations consistent
with the emergency classification and emergency action level scheme set
forth in Appendix 1 to !!UREG-0654.
The use of predetermined EALs in
establishing an emergency class should minimize the need for subjective
judgment at the time of an actual emergency.
2.
The plan discusses the existence of message verification for site area
emergencies only.
The verification procedures should be expanded to
all emergency classes involving notification of the offsite response
organizations.
3.
Expand the content of the initial emergency message to offsite authorities
to include, where appropriate, the potentially affected population and
whether protective measures may be necessary.
4.
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.
5.
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.
la
'
, . .
.
F.
EMERGENCY COMMUNICATIONS
Planning Standard
Provisions exist for prompt communciations among principal response organi-
zations to emergency personnel and to the public.
Emergency Plan:
-
24-hour notification to and activation of the State / local energency 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 E0C'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.
15
._ _- _
-
.
.
.
Provision is made for a coordinated canmunication link between the licensee
and tf e 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
communication links which would be involved in initiating emergency re-
sponse actions.
2.
A diverse means of communication, such as a radio system, should be avail-
able between the site and the primary offsite response agency.
It is not
f
clear that such radio communications are available with the Wayne County
and Monroe County Emergency Operations Centers.
3.
Identify the provisions for canmunications with the U.S. Coast Guard since
they are a primary response organization within the plume exposure EPZ.
16
__
.
.
G.
DUBLIC 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 energency (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:
A coordinated yearly dissemination of information to the public regarding
how they will be notified and what their actions should be in an emergency
is provided. The appropriate information is included.
Written material that is likely to be available in a residence during an
emergency is provided and updated annually.
The points of contact and physical locations for use by news media during
an emergency (Emergency Information Center) are designated.
Space will be provided at the licensee's Emergency Information Center for
media briefings.
17
. -
.
.
_ _ _ .
-
-
.
,.
The Senior Vice President of General Services has the overall responsibility
for public information.
A technical spokesperson will be available to the
media for briefings and questions.
Arrangements for timely exchange of information among designated spokes-
persons are established.
The Emergency Information Center includes facilities for rumor control.
Annual programs to acquaint news media with the emergency plans, information
concerning radiation, and points of contact for release of public information
in an energency are provided.
DEFICIENCIES:
The plan requires revision and/or additional information as follows:
1.
Provide a sample copy of the emergency preparedness information which will
be provided for both the resident and transient population around the site.
2.
Describe the provisions made for ensuring that the transient population
within the plume exposure EPZ will have access to appropriate information
in advance that would be helpful in the event of a serious emergency.
18
-
.
H.
EMERGENCY FACILITIES AND E0VIPMENT
Planning Standard
Adequate energency facilities and eouipment to support the emergency response
are provided and maintained.
Emergency Plan:
A Technical Support Center (TSC) and Operational S'Jpport Center (OSC) have
been established.
An Emergency Operations Facility (EOF) will be
established outside the security fence.
This facility may also be used
as the Recovery Center.
In addition an Emergency Survey Center has been
established to collect, assess and report field monitoring data; provide
backup laboratory facilities and act as a repository for emergency in-
struments for offsite monitoring.
An onsite meteorological system including instumentation, data collection
and transmission to the Control room and/or turbine bay basement is in
place.
Remote interrogation of meteorological data will be established at
.
Functional use of onsite radiological and process monitoring systems are
discussed.
Provisions have been made to obtain offsite meteorological data from the
Rochester-Monroe County Airport on a 24-hour per day basis in case of
j
failure of onsite equipment.
19
._ _
-
-
,
Offsite radiological monitors including ratemeters and sampling devices
have been provided.
Emergency instruments and equipment are checked monthly and replaced if
in need of repair.
Calibrations are performed according to manufactures
recommendations.
DEFICIENCIES
The Plan requires revision and/or additional infonnation as follows:
1.
The plan fails to describe the TSC in sufficient detail to determine if
the facility is in close proximity to the control room, if ventilation
and shielding is adequate and if there is intent to provide a facility
that meets the NUREG-0696 criteria. The plan does indicate the TSC can
be operational in about 30 minutes.
The plan states that the OSC will be
used after radiation levels have reduced to a point where occupancy is
feasible and personnel can be transferred from other locations.
This is
not compatible with NUREG-0696 criteria.
The OSC should be immediately
available to emergency personnel.
There is no indication if the OSC or
other assembly locations contain or have immediate access to the kinds
i
of emergency equipment necessary to repair, control, or mitigate the
consequences of an accident.
Respiratory protection, protective clothing
and portable lighting are the only items mentioned.
Provide a detailed
description of the TSC, including its location, and a commitment to meet
the criteria set forth in NUREG-0696.
20
-
-
.
.
.
2.
The plan states that a Recovery Center /E0F will be established outside the
protected area.
There is no discussion of its location in reference to
the plant of if the facility is or will be designed to meet NUREG-0696
criteria.
Provide a more detailed description of the EOF including a
commitment to neet the criteria set forth in NUREG-0696.
3.
The Plan indicates that the E0F will be activated and staffed within
eight hours.
The criteria for timely activation of this response
facility is discussed in NUREG-0696 which indicates that the EOF should
be fully functional within one hour.
Describe how this criteria will be
met.
4.
Identify the onsite monitors for obtaining seismic and hydrologic in-
formation which may be used for initiating emergency measures in accordance
with criteria H.5.a of NUREG-0654.
5.
Identify the onsite radiological and process monitoring systems in accordance
with criteria H.5.b and H.5.c of NUREG-0654
The monitors identified should
include 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.
6.
Identify the fire and combustion products detectors which may be used
for initiating energency measures in accordance with criteria H.5.d
of NUREG-0654.
1
21
1
---
..
.
w
7.
Describe your provisions for obtaining offsite information regarding
hydrologic and seismic data as specified in criteria H.6.a of NUREG-0654.
8.
The plan describes the offsite radiological monitoring system and states
that placement information is contained in implementing procedures.
Pro-
vide an area map showing the location of rate meters, sampling devices
and TLDs in relation to the plant as part of the plan.
Also indicate
if the dosimetry provided meets the minimum requirements of the NRC
Radiological Assessment Branch Technical Position for the Environmental
Radiological Monitoring Program.
9.
Although the plan disusses the onsite meteorological instrumentation,
it is insufficient to 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.
10.
Indicate that the Operations Support Center t.nd equipment will include
that specified in criteria H.9 of NUREG-0654.
11.
Indicate that there are sufficient reserves of instruments / equipment
to replace those that are removed from service for maintenance and/or
calibration.
22
. _ - . _
-__
.
__
>
.
,
I.
ACCIDENT ASSESSMENT
.
Plannirg Standard
'
Adequate methods, systems and eauipment 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 te,'m 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 meteorological
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
EPZ is described.
23
.
.
.
,
The plan states there is capability to determine particulate and iodine
concentrations in the field as low as 10 9 FCi/cc and 4 x 10 9 pCi/cc
respectively.
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
detennining the source tenn of releases of radioactive material within
plant systems.
As an aid in assessing the extent of potential core
damye inclu
lots which show the containment radiation monitor
readir.g vs. time following release of gap activity,1% release of fuel
inventory, and 10% release of fuel inventory.
24
.
.
,
4.
Indicate the meteorological infonnation that will be provided to an
offsite NRC center and made available to State agencics for their
use.
5.
Indicate how and when field monitoring teams will be activated; their
composition; means of communication and transportation; the kinds of
monitoring equipment that will be used and how soon monitoring teams
can be deployed offsite.
.
1
6.
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
25
,
, . , . , _ _
_
, , . _
_,
_ , . _ . _ , , _ - . _ .
. _ _
.
_
_
.
I
J.
PROTECTIVE RESPONSE
Planning Standard
A range of protective actions have been developed for the plume exposure path-
way EPZ for emergency workers and the public.
Guidelines for the choice of
protective actions during an energency, 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 Emergency Survey Center located in the Brookwood Science Information
Center has been established as the decontamination facility for evacuated
onsite personnel .
Provisions have been made for respiratory protection devices, protective
clothing and radioprotective drugs for onsite emergency personnel.
-
,
Provision has been made for the evacuation of non-essential onsite
personnel and accounting for all personnel onsite at the time of
emergency within 30 minutes.
26
_,
. . _ .
.
_ _ _ _
__
__
'
.
Prompt notification will be made directly to State and local authorities
responsible for implementing protective measures by the Emergency Co-
ordinator when an accident cculd actually or potentially affect individ-
uals within the plume exposure EPZ.
The plan contains maps and tables showing population distributions around
the plant.
The bases for the choice of recommended protective actions for plume
exposure pathway is shown in Table 5.1 of the plan.
DEFICIENCIES:
The plan requires revision and/or additional information as follows:
1.
The plan establishes the means to warn or advise onsite employees
and visitors.
Describe the means used to warn or advise contractor /
construction personnel or those individuals who may be outside the
protected area but inside the owner controlled area.
Also, specify
'
the time required to notify individuals who might be beyond the range
of the onsite emergency signals.
2.
The plan states that the evacuation route will be detemined by the
emergency coordinator based on wind direction at the time of the accident.
Discuss the means that will be used to transport people to the off-
site assembly location (s), other than the Brookwood Science Information
27
-_
.
.
Center, and alternative routes that could be used for various wind
directions or in case of inclement weather.
Provide a map chowing
the alternate evacuation routes from the plant site.
3.
Indicate if locations other than the Emergency Survey Center are
available for decontamination of evacuated personnel in case the
center is uninhabitable.
4.
Provide a copy of the evacuation time assessment study as an appendix
to the emergency plan.
5.
The plan refers to the Wayne and Monroe County plans for the infomation
required in criteria J.10.a of NUREG-0654.
The two county plans contain
maps showing evacuation routes, evacuation areas, and relocation and
shelter areas.
There are no maps showing radiological sampling and
monitoring points.
Previde a map as part of the plan, showing the
information required in the aforementioned criteria.
6.
Provide a more 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.
7.
Discuss the consideration given to the local protection afforded by
residential units and other shelters as part of the bases for selecting
recommeded protective actions for the plume exposure pathway during
emergency conditions.
28
,
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 Buergency Worker and Lifesaving
Activity Protective Action Guides.
Emergency Plan:
Dasite exposure guidelines have been established for corrective and
assessment actions, and life saving activities.
.
An onsite radiation. protection program has been established for ener-
gency situations including methods to implement exposure guidelines.
The plan identifies the Emergency Coordinator as the person authorized
to approve emergency workers to exceed 10 CFR Part 20 exposure limits.
The facility has 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day capability to determine radiation doses
received by emergency workers.
Provisions have been made for dosimeter
distribution, processing and record maintenance.
Contamination control measures have been established for area access.
Provisions have been made for decontaminating relocated onsite personnel.
29
.
_
'
.
.
DEFICIENCIES
The plan requires revision and/or additional infonnation as follows:
1.
Section 5.4.4.1 of the plan indicates that perscns potentially per-
froming life saving actions may receive up to 100 rems whereas Table 5.1
of the plan indicates 75 rem.
Provide consistency in the plan and
with EPA Emergency Worker and Lifesaving Activity Protective A'etion
Guides (EPA 520/1-75/001).
2.
Specify emergency exposure guidelines' for perfoming first aid, personnel
decontamination, ambulance service, and medical treatment services.
3.
The plan states that " Radiation exposures in an emergency shall be
'
evaluated on a risk-benefit basis."
Procedures for such expeditious
decision making and consideration of relative risk should be in place
in advance.
Identify these procedures by number and title in Appendix
E ta the plan, or as an alternative provide a synopsis in the plan
itsel f.
4.
The plan discusses decontamination in very general terms.
Specify the
action leve.ls for determining the need for decontamination, and the specific
capability for decontamination of emergency personnel wounds, supplies,
instruments, and equipment.
30
.
_
-
.
5.
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.
6.
Although the plan discusses the capability for decontamination at the
Emergency Survey Center, indicate the decontaminants available for
radiofodine contamination of the skin.
.
l
d
31
.
..
.. ._
_
.
.-
-_ .
. _ .
..
_
_
-
.
-
'
.
.
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 medicai
services having the capability for handling ccataminated individuals,
-
and for the evaluatic.i 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.
.
.
32
- - - -
. .. .
.
.
_
.
-
-
-
.
M.
REC 0VEP.Y AND REENTRY PLANNING AND POSTACCIDENT OPERATIONS
Planning Standard
General plans for recovery and reentry are developed.
,
I
Emergency Plan:
General plans and procedures for reentry and recovery are developed and
the means are described by which decisions are reached to relax protective
measures.
The structure, functions and membership of the facility recovery organization
are described.
Means are specified for infonning members of the response organizations
that a recovery operation is to be initiated.
A method for periodically estimating total population exposure is
established.
- <
33
-
.
.
,
- - - - - - - -
-.
. - ~ - , -
4-
_y
, - - -
- - - - - -
.__- ..,
,,--y
,-y
.-- , , , .--
-- -
-
.
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 land maintain key skills, and deficiencies identified as a result of
exercises or drills are (will be) corrected.
-
_
-An annual preparedness exercise that simulates an emergency that
results in offsite radiological releases which would require response
by offsite authorities is provided.
4
-
-
Scenarios which would be varied from year to year and test all major
elements of the plan within a five-year period, and the provisions for
qualified observers are addressed.
. .
Periodic testing of the communication links is addressed.
Fire drills are conducted in accordance with the plant technical
specifications.
/,
Prr, visions are made for an annual medical emergency drill which involves
local; support services.
l
/
/
>
.
34
_
.
-
- - -
,-.
-
.
An annual radiological monitoring drill (onsite and offsite) is addressed.
Semi-annual health physics drills which include sampling and analysis of
simulated high activity post accident samples both in-plant and from the
environment are addressed.
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.
The Plant Operating Review Committee and the Plant Supervisor will review
the drill and exercise evaluation reports to ensure that necessary
corrections to the plan are implemented.
DEFICIENCIES
The plan requires revision and/or additional information as follows:
1.
Provide consistent use of the terms " drills" and " exercises" in accordance
with the definitions set forth in Sections N.1 and N.2 of NUREG-0654.
In-
dicate that the drills will be supervised and evaluated by a qualified
drill instructor.
l
35
,
,
2.
The plan states that an annual radiation emergency drill (sic) will be
coordinated with participating off-site agencies, testing at a minimum
the communications links.
This is insufficient.
Provide a commitment
to perform an annual exercise in accordance with the reouirements set
forth in Section IV.F. of Appendix E to 10 CFR Part 50.
3.
Identify the specific communications drills to be conducted and their
frequency in accordance with criteria N.2.a of NUREG-0654.
Note that
communications with the NRC shall be tested mcnthly 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.
4.
Expand the discussion of the medical emergency drill to include the
simulation of a contaminated individual.
5.
Expand the discussion of the radiological monitoring drill to include
collection and analysis of all sample media.
,
6.
Include in the health piijsics drills, the analysis of inplant liquid
samples with actual elevated radiation levels including use of the
post-accident sampling system.
7.
Discuss the mix of structured and less structured aspects of the program
which will allow free play for decision making during drills and exercises.
8.
Indicate that the drill and exercise scenarios will include all of the
elements described in criteria N.3 of NUREG-0654.
36
-
,
,
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
Emergency Plan:
Site specific training is offered to offsite emergency organizations
particularly hospital, ambulance / rescue and fire departments.
Onsite emergency groups receive formal as well as practical training
during drills.
A formalized training program has been established to
ensure that all personnel who actively participate in a radiation
emergency maintain familiarity with their responsibilities.
A specialized training program has been established for the following
organizational categories: a) emergency coordinators; b) Technical
Support Center personnel; c) radiation monitoring teams; d) fire
fighting; e) first aid and rescue; f) medical sup' port personnel;
g) recovery support personnel.
The licensee has provided for annual retraining of personnel with
emergency response duties.
37
.
DEFICIENCIES
The plan requires revision and/or additional infomation as follows:
1.
Include provisions in your training program for on-the-spot correction
of erroneous performance during drills and a demonstration of the
proper perfomance by the instructor.
2.
Indicate that the first aid training for plant personnel includes
Red Cross Multi-Media or equivalent.
3.
The description of the training program lacks specificity regarding
the scope, nature, and frequency of training for the ten categories
of emergency response personnel listed in criteria 0.4 of NUREG-0654.
In particular, the following are not addressied: personnel responsible
for accident assessment, police and security personnel, repair and
damage control teams, local county authorities, corporate support
personnel, and personnel responsible for transmission of emergency
information and instructions.
38
.
.
l
P.
RESPONSIBILITY FOR THE PLANNING EFFORT:
DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION OF EMERGENCY PLANS
Planning Standard
.
Responsibilities for plan development and review and for distribution of
emergency plans are established, and plancers are properly trained.
Emergency Plan:
.
The individual with overall authority and responsibility for radiological
emergency response planning is the Superintendent, Nuclear Production.
An Emergency Planning Coordinator with the responsibility for development
and updating of the emergency plans, and for coordination of the emergency
plans with other responsible organizations is provided.
The Emergency Plan and implementing procedures will be reviewed by the
Plant Operations Review Committee annually in conjunction with their
review of the exercise.
,
l
l
l
l
Procedures for implementing the Emergency Plan are listed by procedure
l
[
number, procedure title, and the section of the Emergency Plan which
l
they implement.
l
l
l
l
,
39
l
- - .
- - -
'
.
The plan contains a detailed table of contents and a cross-reference
to the evaluation criteria in NUREG-0654.
The emergency plan, its implementing procedures, equipment and training
are audited by the Nuclear Safety and Audit Review Board.
Audit documents
are retained for 5 years.
,
Periodic review and updating of emergency telephone numbers is addressed
in the plan.
DEFICIENCIES
The plan requires revision and/or additional information as follows:
1.
Describe the training provided for and/or the qualifications of the
Emergency Planning Coordinator.
2.
Provide a synopsis of administrative procedure A-602 which assures
that criteria P.5 of NUREG-0654 is met regarding changes to the emer-
gency plan.
3.
Indicate that the independent review of the emergency preparedness program
will be conducted at least every 12 months.
The review should include the
interfaces with the State and local government authorities.
4.
Indicate that the telephone numbers in the emergency procedures will
be updated quarterly.
40
-
- -
'
3
,
,
.
CONCLUSION
,
Based on our review, we conclude that the Ginna 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
Ginna Site will be made following 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.