ML20054F618
| ML20054F618 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 06/11/1982 |
| From: | Defayette R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20054F597 | List: |
| References | |
| NUDOCS 8206170161 | |
| Download: ML20054F618 (10) | |
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NRC ST F ANSWERS REGARDING CONTENTION 1 I-Q.1 Please state your name and position with the NRC.
A.1 My name is Robert Defayette.
I am employed by the Nuclear Regulatory Commission in the Office of Inspection and Enforcement, Division of Emergency Preparedness, Emergency Preparedness Licensing Branch. A copy of my professional qualifications is attached.
Q.2 What is the purpose of your testimony.
A.2 The purpose of this testimony is to respond to, in part, Prairie Alliance Contention 1 regarding the adequacy of the on-site Emergency Plan for the Clinton Power Station, Unit 1.
Q.3 What are the standards in reviewing the adequacy of an emerger.cy plan.
A.3 Title 10 of the Code of Federal Regulations, Part 50, including
%50.47 and Appendix E, sets forth the standards which an on-site and off-site emergency plan must meet before an operating license will be issued. These standards are addressed by specific criteria in NUREG-0654, FEMA-REP-1 entitled " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" Rev 1, November,1980. NUREG-0654 is endorsed by NRC Regulatory Guide 1.101, Revision 2, dated October,1981.
8206170161 820611 PDR ADOCK 05000
Q.4 AsstatedinSubpart(a)(1)toContention1,aretheApplicants required to consider " p]roblems posed in effecting termination of activities at outdoor recreational facilities within the plu'me EPZ and ingestion EPZ."?
A.4 No. Appendix E, Subpart D.3, to 10 C.F.R. Part 50, as well as i
Subpart E.6 to NUREG-0654, require the licensee to demonstrate that administrative and physical means have been established for alerting and providing prompt notification and instructions to the public within the plume EPZ. The Applicants are not required by the applicable regulations to demonstrate an ability to terminate the activities of the public within the plume EPZ.
In addition, the Applicants are not required by the applicable regulations to notify or instruct persons within the ingestion EPZ.
In 5 7.2 of the Plan the Applicants have comitted to ensuring that administrative and physical means will be available to promptly notify the public within the plume EPZ of an abnormal or emergency condition at the Clinton Power Station. Specifically, the system will consist of tone activated radio receivers in areas of low population density and in special facilities, and outdoor warning devices (sirens) in recreational areas and areas of high population density.
Q.5 As stated in Subpart (a)(2) to Contention 1, are the Applicants required to consider " difficulties posed by 'special facilities' vhich, because of the nature of the population, the number of people involved or the means of available communication and transportation, give rise to
especially acute problems in emergency response actions.
Included in this category are uni rsities and other schools, nursing homes, mental health facilities, prisons and jails, children's camps, stat'e parks, industrial parks, and other such facilities located within the plume EPZ and ingestion EPZ."?
f A.5 First, relative to the ingestion EPZ, neither the Applicants' nor the State nor local plans are required by the applicable regulations to consider " difficulties posed by special facilities beyond the plume EPZ."
Protective actions for "special facilities" within the plume EPZ are the responsibility of the local governmental agencies and these plans have not been completed. When such plans are complete they will be evaluated by the Federal Emergency Management Agency and findings transmitted to the NRC.
Q.6 As stated in Subpart (a)(3) to Contention 1, is the Plan i
insufficient because it fails to consider "the severe, but not uncommon, weather conditions, such as heavy snowfalls, sleet, storms, and tornados which occur in the site vicinity and plume and ingestion EPZs througout the year."?
1 A.6 The Applicants do address problems posed by severe weather conditions in their plan.
In section 12.3.2.1 of Appendix 13.b of Amendment 7 to the FSAR, dated September, 1981, the Applicants list l
estimated evacuation times for both normal and adverse weather conditions.
In addition, section 12.5 discusses the emergency response option of shelter versus evacuation and list; several parameters which must be considered in making a reconinendation for one of the two
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protective actions. Two of the parameters are weather conditions and evacuation time esti es.
Finally, figure 12-4 is a decis on diagram for use in determining a particular protective response. One of the items to be considered is protective action time which is related to the evacution time estimates in section 12.3.2.1 of the Plan.
e Q.7 As stated in Subpart (c) to Contention 1, does the Clinton emergency plan lack sufficient detail in the area of emergency preparedness training.
A.7 No, the Applicants are not required by the applicable regulations to include detailed training programs in the emergency plan.
Detailed training procedures are inspected during the two week pre-operational emergency preparedness implementation appraisal inspection. These detailed procedures are part of the Applicants' emergency preparedness program.
Section 17 of the Plan refers to certail implementing procedures; specifically; OAP 1102.32N, (Emergency Plan Training);OAP 1102-33N (Security Plan Training); OAP 1102-34N, (Fire-Fighting Training); and 0AP 1102-35N, (First Aid Training).
Section 17 also discusses the training program and lists the various groups that will receive training.
In addition, reference is made to a training supervisor who is responsible for coordinating training.
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Q.8 As stated in Subpart (d)(1) to Contention 1, does the plan fail to identify the special qualifications of non-Illinois Power personnel who will be utilized i emergency training operations or recovery?
I-A.8 As stated in Chapter 17 of the Emergency Plan, the only non-IP employees who will be used in training operations will be medical f
consultants from RMC Corporation.
RMC is a well-known consultant which has been involved in emergency preparedness with reactor operators for a number of years. Therefore, it is not necessary to identify their special qualifications.
In regard to recovery operations, the Applicant specifically mentions the General Electric Company and Sargent & Lundy as organizations which would be called upon for assistance. General Electric supplied the nuclear steam supply system and Sargent & Lundy was the architect engineer for the Clinton Power Station. Therefore, it is not necessary to identify their special qualifications.
Q.9 As stated in Subpart (d)(2) of Contention 1, does the Plan fail to identify the criteria for determining the need for notification and participation of local, State and Federal agencies?
A.9 No. Section 6 of the emergency plan sets forth the emergency classification system. That system describes five classes of emergencies; 1) transportation accident, 2) unusual event, 3) alert,
- 4) site emergency and 5) general emergency. The section then states that off-site agencies will be notified when such emergencies are declared.
Section 6.3 entitled " Alert Classification", Section 6.4 entitled " Site Emergency" and Section 6.5 entitled " General Emergency", each contain a
. subsection which describes state and/or local actions following the declaration of that e rgency. Tables 6.1, 6.2, 6.3 and S.,4 give example initiating conditions that would trigger the classification'of an
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accident under one of the five categories.
e Q.10 As stated in Subpart (d)(3) to Contention 1, does the plan fail to identify or describe an analysis of the time required to evacuate or provide other potective measures for various sectors and distances within the plume exposure and ingestion EPZs for both transient and permanent populations?
A.10 No. The Applicants are not required by applicable regulations to provide such information for the ingestion EPZ.
10 C.F.R 50.47(b)(10), as expanded in NUREG-0654, Rev 1,Section II.J.8 and Appendix 4, only requires that evacuation time estimates be determined for the plume EPZ. The Applicants have addressed evacuation time estimates for both transient and permanent populations.
In Table 4-1 of the Illinois Power Evacuation Time Estimate, dated December 22, 1981, evacuation time estimates are identified by sectors and distances for the permanent population.
In addition, Table 4-6 identifies the peak day evacuation time estimates for the transient population in the three major recreational areas within the plume EPZ.
Q.11 As stated in Subpart (d)(4) of Contention 1, has the plan failed to identify sufficiently the persons who will be responsible for making off-site dose projections?
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A.11 No. Section 4.5 of the Emergency Plan describes a series of emergency assignments According to Guide 4.2, the Assistant Power Plant Manager-0perations, has as one of his responsibilities the assessment and evaluation of any radioactivity which has been released.
t Q.12 As stated in Subpart (d)(5) of Contention 1, does the Plan fail to identify or describe how off-site dose projections will be made and how the results will be transmitted to appropriate government entities?
A.l? Although the plan does not set forth in detail infonnation on off-site dose projections, the Applicants are not required by applicable regulations to provide detailed information in the Emergency Plan on off-site dose projections.
10 C.F.R 50, Appendix E, Part V, however, requires that this information be set forth in the implementing procedures.
In section 11.3 on page 11-6 of the Emergency Plan, the Applicants have committed to have the capability to determine the source term and magnitude of releases. Assessments will be made in accordance with implementing procedure OAP 1890.15N, " Emergency Dose Off-Site Assessment."
In addition, the Applicants have a procedure to transmit the results of dose assessments to the appropriate government entity.
This procedure is OAP 1890.02N " Emergency Plan Notification".
Q.13 As stated in Subpart (d)(6) of Contention 1, does the Plan fail to identify the means for yearly dissemination to the public of basic emergency planning information?
A.13 First, the Applicants are not required by applicable regulations to provide such information to the public within the
j ingestion EPZ.
10 C.F.R. 50.47(b)(7), as further described in NUREG-0654, Rev 1, Part II, G.2, only requires this information be provided to the popula ion within the plume EPZ.
In that regard, section I'
9.0 of the emergency plan describes plans for periodic dissemination of information to the public which will include 1) educational information e
on radiation, 2) how to obtain additional information, 3) sheltering, 4) evacuation routet, and 5) special needs of the handicaped.
Q.14 As stated in Subpart (d)(7) of Contention 1, does the Plan fail to identify appropriate state and local government officials within the EPZs which will require notification under accident conditions?
A.14 No. The Applicants have committed in section 7.1 to provide a procedure (OAP 1890.02N, " Emergency Plan Notification") to accomplish this purpose. Section 7.1.4 states that the procedure will include call lists which will include the name, title, and telephone number of both primary response organizations and key individuals.
Q.15 As stated in Subpart (e) of Contention 1, are the Applicants required to assure isolation of people in the ingestion EPZ in case of an off-site or general emergency?
A.15 No. The Applicants are not required by applicable regulations to provide for isolation of people within the ingestion EPZ. Also, centrary to Subpart (e) of Contention 1, there is no Section 5.4.3.1 in the emergency plan as submitted in amendment 7, Appendix 13b, of the FSAR, dated September, 1981.
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Q.16 As stated in Subpart (f) of Contention 1, has IP failed to provide adequate emerg ncy support facilities for the CPS?
A.16 No. Section 10.1.1.1 of the Plan describes the TS'C, section 10.1.1.2 describes the OSC, section 10.1.2 describes the Primary E0F, and Section 10.1.3 describes the Backup EOF. Safety Parameter t
Display Systems and Nuclear Data Links are not regulatory requirements.
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ROBERT W. DeFAYETTE MSPhysicIlChemist*y,IowaStateUniversity,,1959
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Education:
Experience:
1/82-Present Member of the Emergency Preparedness Licensing Branch; review. licensee emergency preparedness programs and prepare input to SERs; team leader for onsite emergency preparedness appraisals; participate in exercises to evaluate licensee per formance.
10/80-1/82 Reactor safety engineer in the Emergency Preparedness Development Branch in the Office of Inspection and Enforcement; coordinated the development of the Emergency Preparedness Implementation Appraisal package (TI-2515/55); partici-pate in exercises to evaluate licensee performance during required annual exercises; revised the Standard Review Plan for emergency planning; training coordinator for Division of Emergency Preparedness; represent NRC on an inter-agency task force on training; lecture at FEMA training courses (lectures cover such topics as accident categories and licensee monitoring requirements);
consultant to interagency task force developing emergency preparedness guidance for transportation accidents involving radioactive materials.
1/80-10/80 Temporarily deiuiled to f&e to ossist that cgency ist i;.plcr..cnt ing iis rcspcas i-bilities in assisting State and local governments in developing emergency plans in support of nuclear power plants; managed radiological emergency preparedness training programs and assisted in writing a report to the President on the status of emergency preparedness.
7/74-1/80 Reactor Safety Engineer in the Office of State Programs at NRC; lectured at University short courses on emergency planning; developed guides and policies relating to State and local government emergency preparedness in support of nuclear power plants and transportation accidents involving radioactive materials; developed and managed a technical training program for State and local government radiological emergency response personnel; testified on emergency preparedness issues at State legislative hearings.
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