ML20054H749
| ML20054H749 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 06/11/1982 |
| From: | Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Fiedler P GENERAL PUBLIC UTILITIES CORP. |
| Shared Package | |
| ML20054H750 | List: |
| References | |
| NUDOCS 8206240389 | |
| Download: ML20054H749 (37) | |
See also: IR 05000219/1982001
Text
[
e
<
JUN 111982
Docket No. 50-219
GPU Nuclea Corporation
ATTN:
Mr. P. B. Fiedler
Vice President and Director
Oyster Creek Nuclear Generating Station
P. O. Box 388
Forked River, New Jersey 08731
Gentlemen:
-
Subject:
Emergency Preparedness Appraisal 50-219/82-01
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 routinc 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 improvements
in NRC requirements and guidance.
During the period of January 4 - 15, 1982, the NRC conducted an appraisal of
the emergency preparedness program for the Oyster Creek Nuclear Generating
Station. Areas examined during this appraisal are described in the enclosed
NRC Cegion I Inspection Report No. 50-219/82-01. 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
are discussed in Appendix A, "Significant Emergency Preparedness Findings".
Significant findings for which you have made acceptable commitments to resolve
were discussed in the Confirmatory Action Letter dated February 18, 1982. All
significant findings, except Appendix A, Item 18 were addressed in this
letter. A copy of the letter is enclosed (Enc ksure 5).
Significant findings nos. 11 and 14 address your need for equipment which
would allow the sampling of reactor coolant and containment atmosphere under
post-accident conditions per NUREG-0737. The NRC has yet to take a position
concerning your request to postpone the installation of the post-accident
sampling equipment from your next major refueling / maintenance outage
until an outage scheduled for 1984. As was indicated in the Confirmatory Action
Letter dated February 18, 1982, as soon as we resolve the status of your request,
we will inform you when this sampling equipment must be installed.
g(
OFFICIAL RECORD COPY
g
p
a
V
A/
b
rup>
9
8206240389 820611,,
a
--
~
p
-
I
e
r
JUN 111932
GPU Nuclear Corporation
2
Other areas needing improvements are discussed in Appendix B, " Emergency
Preparedness Improvement Items."
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."
Appendices A, B, and C of this letter contain an inclusive listing of all
outstanding errergency 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 finding no. 18, listed in Appendix A, which was
not included in the February 18, 1982 letter, is 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 af
the date of this letter.
Such application must be consistent with the requirements
of 2.790(b)(1). The telephone notification of your '.ntent 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, therefdre, are not subject to Office of Management and Budget
clearance as required by PL 96-511.
OFFICIAL RECORD COPY
]
,e
l
GPU Nuclear Corporation
3
JUN 11 D32.
Should you have questions concerning this inspection, 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,
g Silp*d D8
gg
s . H . S M Tet
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 50-219/82-01
5.
Confirmatory Action Letter, dated February 18, 1982
cc w/encls:
M. Laggart, Licensing Supervisor
J. Knubel, BWR Licensing Manager
Public Document Room (POR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
State of New Jersey
bcc w/encls:
Region I Docket Room (with concurrences and enclosures)
Chief, Operational Support Section (w/o encis)
1
0
R
R
POS
Croc r
Snyd
'G
H.
mith
A.titi!Ac.T
cKC
tJI
a
x
4 ,,
0 FICIAL R CORD COPY
-
.
_.
-
.
=
APPENDIX A
SIGNIFICANT EMERGENCY PREPAREDNESS FINDINGS
Based on the results of the NRC's appraisal of the GPU Nuclear Corporation's
Emergency Preparedness Program 2 the Oyster Creek Nuclear Generating Station
conducted January 4 - 15, 19E
the following improvements are required:
(First parenthetical references are to the pertinent section in NRC Region I
Inspection Report No. 50-219/E2-01.) (Second parenthetical references are the
February 18, 1982 Confirmatory Action Letter (CAL) item which addressed the
specific improvement.)
1.
Complete the development of, and establishment of, a more comprehensive
training / retraining program for all emergency response personnel which is
consistent with the Emergency Plan and Emergency Plan Implementing Procedures.
(Section 3.1) (CAL-3.)
2.
Include training in post-accident sampling and analysis of reactor coolant,
containment air, and stack effluents in the training program after the
implementing procedures and equipment are available. Hands-on, walk-through,
and talk-through training should be a part of this training.
(Section
3.1) (CAL-3.)
3.
Implement an effective training program, and train members of the newly
defined Initial Response (Onsite) Emergency Organization and Full
Mobilization (Offsite) Emergency Organization in the emergency response
functions.
(Section 3.2) (CAL-3.)
4.
Train all personnel who will perform emergency response functions.
(Section 3.2) (CAL-3.)
5.
Relocate the Emergency Control Center away from the control room.
(Section
4.1.1.1) (CAL-1.a.)
6.
Upgrade the present Technical Support Center with a ventilation system
providing adequately filtered air, instrumentation to detect direct
radiation and airborne contamination, a more comprehensive set of plant
drawings, more comprehensive plant parameter data from the computer
terminal, more space for the occupants, and better spacing of the telephones.
Also, provide a copy of the results of the TSC shielding study to Region
I of the NRC.
(Section 4.1.1.2) (CAL-1.b(1))
7.
Resubmit conceptual design information for a suitable TSC which meets the
requirements of the Office of Nuclear Reactor Regulation, February 18,
1981, Generic Letter 81-10 concerning " Post-TMI Requirements for the
Emergency Operations Facility." Also, include a schedule showing milestones
and the date when the facility will be operational. (Section 4.1.1.2)
(CAL-1.b.(2))
,
OFFICIAL RECORD COPY
m
-
-
,
.
I
I
Appendix A
2
8.
Locate the Operations Support Center in the Maintenance Building, as
described in the Emergency Plan. Assure that it has adequate space, a
communications system, personnel protection equipment and supplies, and
other equipment and supplies needed for the performance of tasks during
an emergency.
(Section 4.1. 1.3) (CAL-1.c.)
9. .
Upgrade the Nearsite Emergency Operat.fons Facility located in Building 12
of the Forked River site with equipment and supplies to allow management
and technical personnel to perform energency functions as described in
'
your September 11, 1981, letter to the Director of the Office of Nuclear
Reactor Regulation.
(Section 4.1.1.4) (CAL-1.d.).
10. Provide a Farsite Emergency Operation Facility which has the same capabili-
ties as the Nearsite Emergency Operations Facility, as called for in your
Emergency Plan and in your September 11, 1981, letter to the Director of
the Office of Nuclear Reactor Regulation.
(Section 4.1.1.4) (CAL-1.e.)
11.
Install a system capable of collecting a high activity reactor coolant
sample (up to 10 curies / gram) under post-accident conditions per NUREG-0737
specification.
(Section 4.1.1.5) (CAL-Unresolved.)
12. Define and predetermine conditions under which reactor building access-
ibility for interim-type coolant sampling can be reasonably expected or
precluded.
(Section 4.1.1.5) (CAL-2.b.)
13. Determine reactor coolant radioactivity levels which can be sampled using
interim-type facilities without exceeding appropriate NRC exposure criteria
or EPA protective action guides.
(Section 4.1.1.5) (CAL-2.b.)
14. Provide facilities capable of collecting a containment air sample under
condit Sns specified in NUREG-0737.
(Section 4.1.1.6) (CAL-Unresolved)
15. Define and predetermine conditions under which reactor building access-
ibility for interim-type containment air sampling can be reasonably
expected or precluded.
(Section 4.1.1.6) (CAL-2.b.)
16. Complete the installation and calibration of the new stack and turbine
building vent radiological gaseous effluent monitoring systems.
(Section
4.1.1.7) (CAL-2.a.)
17. Develop an interim-type methodology to collect and analyze high activity
post-accident gaseous, particulate, and iodine samples consistent with
the activity levels identified in Table II. F.1-2 of. NUREG-0737. Consideration
should be given to any restrictions posed by direct radiation exposure
from normal monitoring and sampling equipment which might have been
operating under accident release conditions.
(Section 4.1.1.7) (CAL-2.b.)
.
18.
Incorporate all area and process radiation Emergency Action Levels given
in the Emergency Plan into the Emergency Plan Implementing Procedures.
(Section 4.2.1.2) (This item was not included in the CAL.)
0FFICIAL RECORD COPY
[
,
.
4
Appendix A
3
19.
Perform an engineering study of existing Area Radiation Monitors (ARM's)
and Process Radiation Monitors (PRM's) to determine the upgrading necessary
to the monitoring system to provide adequate accident detection and
classification and post-accident radiation mapping capabilities to meet
ANSI-N320.
Incorporate the results of the study in the Emergency Plan
and the Emergency Plan Implementing Procedures.
(Section 4.2.1.2) (CAL-5.)
20.
Include in the Emergency Plan Implementing Procedures precautions limitations,
and references to other procedures used in the completion of the , emergency
response tasks.
(Section 5.1) (CAL-4.b.)
21.
Incorporate appropriate references to the Emergency Plan Implementing
Procedures in your 500 Series Procedures.
(Section 5.2) ( CAL-4.a.)
22. Complete the revision and expansion of your Emergency Plan Implementing
Procedures so that personnel are specifically directed in the completion
of all required emergency response tasks.
(Section 5.3) (CAL-4.b.)
23. Develop a method to determine offsite doses to the thyroid based on
measured and projected radiciodine concentrations. The method should
document the assumptions used, incorporate appropriate EPA-520 or ICRP
models, and be made consistent with the method used by the appropriate
offsite agencies.
(Section 5.4.2) (CAL-4.c.)
24.
Include all methods to be used in the performance-of the offsite radiological
surveys in Emergency Plan Implementing Procedures.
(Section 5.4. 2.1)
(CAL-4.b.)
25.
Include all methods to be used in the performance of the onsite radio-
logical surveys in the Emergency Plan Implementing Procedures.
(Section
5.4.2.2) (CAL-4.b.)
26.
Include the procedures to be followed for in plant radiological control
under emergency situations in the Emergency Plan Implementing Procedures.
(Section 5.4.2.3) (CAL-4.b.)
27.
Revise your procedures for performing post-accident reactor coolant
sampling using interim-type equipment. This revision should include, but
not be limited to, consideration of the following: personnel radiation
exposure limits, dosimeters to be used by personnel, radiation level of
coolant that may be sampled, points where sampling should be terminated
due to radiation levels, determination of path of travel to and from
sample location, sample size, and sample labeling.
(Section 5.4.2.4)
( CAL-2. b. )
28.
Develop procedures to address the analysis of high activity coolant
samples consistent with criteria detailed in Section II.B.3 of NUREG-0737.
Such procedures should include specific radiation protection provisions
to assure personnel whole body and extremity limits are not exceeded,
should provide for use of adequate shielding from elevated post-accident
background direct radiation exposure rates, and should identify proper
disposition of samples following analysis.
(Section 5.4.2.5) (CAL-2.b.)
0FFICIAL RECORD COPY
f
.
.
O
Appendix A
4
29.
Develop a procedure for performing post-accident containment air sampling
consistent with NUREG-0737 Section II.B.3 criteria. The procedure should
include specific provisions for collecting particulate, iodine, and gas
samples, specific instructions for the safe handling of highly radioactive
samples, a sketch of the sampling location and equipment, and assignment
of responsibility for performance of planning activities consistent with
positions defined in the Emergency Plan organization.
(Section 5.4.2.6)
(CAL-2.b.)
30.
Develop procedures for anald.:ing containment air samples under the post-accident
conditions specified by NUREG-0737 Section II.B.3. and Table II.F.1-1.
Such procedures should incorporate specific personnel radiation protection
requirements.
(Section 5.4.2.7) (CAL-2.b.)
31.
Review and upgrade airborne effluent sampling procedures incorporating
specific radiation protection provisions appropriate for sampling effluent
streams using the design basis criteria of NUREG-0737, Table II. F.1-2.
(Section 5.4.2.8) (CAL-2.b.)
32. Develop procedures for the analysis of high activity airborne stack effluent
samples under post-accident conditions.
Procedures must address analysis
of radioiodines and particulates as a minimum and meet the criteria of
NUREG-0737, Table II.F.1-2.
Specific radiation protection concerns
applicable to high activity sample analysis shall be incorporated into
the procedures.
(Section 5.4.2.9) (CAL-2.b.)
0FFICIAL RECORD COPY
.
.
APPENDIX B
EMERGENCY PREPAREDNESS IMPROVEMENT ITEMS
Based on the results of the NRC's appraisal of GPU Nuclear Corporation's
Emergency Preparedness Program at the Oyster Creek Nuclear Generating Station
conducted January 4 - 15, 1982, the following improvements should be considered:
(References are to sections in NRC Region I Inspection Report No. 50-219/82-01).
1.
Expedite the hiring of permanent staff Emergency Preparedness Planners.
(Section 1.1)
2.
Define the authority of the Emergency Preparedness Supervisor over matters
concerning the implementation of the Emergency Plan.
(Section 1.2)
3.
Require Emergency Preparedness to review documents such as Emergency
Operating Procedures for adequacy from Emergency Preparedness standpoint
prior to the PORC review.
(Section 1.3)
4.
Include in the Emergency Plan Implementing Procedures checklists to
assure that key Initial Response (Onsite) Emergency Organization members
perform required functions.
(Section 2.1)
5.
Move the location of the technical leaders and experts and technical
information from the Parsippany Technical Functions Center to the onsite
(Section 2.2)
6.
Include in the Emergency Plan Implementing Procedures checklists to
assure that key Full Mobilization (Offsite) Emergency Organization
members perform required functions.
(Section 2.2)
7.
Provide consistency among all the documents which specify emergency
response training.
(Section 3.1)
8.
Develop qualification criteria for all members of the emergency response
organization.
(Section 3.1)
9.
Include in the emergency training program the training of bargaining unit
personnel who would be used during an emergency response in appropriate
procedures used under emergency conditions.
(Section 3.1)
10.
Develop comprehensive lesson plans.
(Section 3.1)
11. Perform more hands-on type training with people dressed in the full
protection clothing and wearing respiratory protection.
(Section 3.1)
12.
Provide respiratory protection training for all members of the Radiolo-
gical Monitoring Teams (Section 3.1)
0FFICIAL RECORD COPY
-_
,
.
Appendix B
2
13.
Include more site-specific informtion in the " hazardous conditions"
section of the Mitigation of Core Damage Course.
(Section 3.1)
14. Provide written examinations and performance tests which demonstrate
training of personnel.
(Section 3.1)
15.
Provide retraining of personnel in changes to procedures and equipment
which occur between training periods.
(Section 3.1)
16. Train personnel prior to assigning them on an emergency organization
roster.
(Section 3.2)
17.
Provide Red Cross Standard First-Aid Multimedia Training for Damage
,.
Control Radiological Control Team members.
(Section 3.2)
~
18. Make the updated Emergency Plan and Emergency Plan Implementing Procedures
available in both the control room and in the Group Shift Supervisor's
office. (Section 4.1.1.1)
19.
Provide more space in the area of the control room communications systems.
(Section 4.1.1.1)
20.
Provide a mobile laboratory to perform reactor coolant and other pertinent
analyses during emergencies.
(Section 4.1.1.9)
21.
Provide more room in the First Aid Station for personnel and equipment
and for storage of emergency supplies.
(Section 4.1.2.2)
22.
Provide decontamination facilities at the Berkeley Operating Headquarters
Remote Assembly Area.
(Section 4.1.2.3)
-23.
Provide for replacement clothing in the decontamination facilities.
(Section 4.1.2.3)
24.
Provide emergency equipment and supplies in emergency kits as specified
in procedure EPAP-05, Rev. O.
(Section 4.2.1.1)
25.
Provide proper operable equipment for the offsite monitoring teams by
assuring that scalars are-operable, check sources are available, power
sources for air samplers are available, filter chambers in air samplers
accommodate the filter cartridges, and air samplers can be placed to take
a representative sample.
(Section 4.2.1.1)
26.
Provide either a redundant power supply to the meteorological tower or
develop a procedure for obtaining representative meteorological data if
the tower measurements are unavailable.
(Section 4.2.1.4)
27.
Establish a remote interrogation capability for the meteorological data
for use by offsite agencies.
(Section 4.2.1.4)
0FFICIAL RECORD COPY
. _ _
_
_
_
_
.
.
Appendix B
3
28. Establish a. supplementary meteorological tower or develop procedures to
assess the possible effects of sea breeze circulations on the effluent
plume transport.
(Section 4.2.1.4)
29.
Develop p*ocedures that assure the testing and maintenance of communications
equipment and provide instructions for the use of all communication
systems and equipments.
(Section 4.2.3)
30.
Identify communicators with regard to technical background, and train and
qualify the communicators prior to assignment.to the emergency organization.
(Section 4.2.3)
31.
Provide a back-up power supply system for all communications equipment
identified for usage during an emergency.
(Section 4.2.3)
32. Designate in the procedure (EPIP-14) where damage control teams would
acquire specific equipment required to perform their function.
(Section
4.2.4)
33.
Formalize responsibility for the control of vehicles designated for
emergency use, revise the Pnergency Plan Implementing Procedures to
reflect this vehicle control, and assure the vehicles are maintained in a
state of readiness for emergency use.
(Section 4.2.6)
34. Reexamine all Emergency Action Levels (EALS) to determine if the information
is readily available to control room personnel.
(Section 5.3)
35. Address the. limitations on the use of normal operating procedures under
emergency conditions in the normal operating procedures. (Section 5.3)
36.
Simplify and consolidate the notification requirements in EPIP's 1-5.
(Section 5.4.1)
37. Define the responsibility for dose assessment in the procecure.
(Section
5.4.2)
38.
Provide additional training in dose assessment.
(Section 5.4.2)
39.
Implement computer analysis for dose assessment at the TSC and control
room.
(Section 5.4.2)
40.
Develop qualification requirements for Offsite Monitoring Team members.
(Section 5.4.2.1)
41.
Define a central collection and storage location for environmental samples.
(Section 5.4.2.1)
42. Develop qualification requirements for Onsite Monitoring Team members.
(Section 5.4.2.2)
0FFICIAL RECORD COPY
.
.
Appendix B
4
L
43. Define the emergency organization responsible for providing in plant-
radiological control, including in plant radiological surveys, during-
emergencies. (Section 5.4.2.3)
44. Develop qualification requirements for in plant monitoring team members.
These requirements should include respiratory protection training and a
-respirator fit test.
(Section 5.4.2.3)
i
45.
Incorporate sketches of sampling facility location and equipment set up
in the sampling procedures.
(Section 5.4.2.8)
d
46.
Delete the references to the non-existent procedure 804.38, Post-Accident
'
Sampling, or develop such a procedure.
(Section 5.4.2.8)
47.
Develop a procedure or plan documenting methods and philosophy for the
storage and handling of large volumes of contaminated water.
(Section
5.4.2.10)
48.
Determine the need; and, if required, develop a procedure for post-accident
sampling of torus water, incorporating specific radiation protection
criteria.
(Section 5.4.2.10)
49. Assess the impact of elevated background radiation levels which could
'
result from direct radiation from the reactor building or stack under-
major release conditions on the normal analytical laboratory procedures.
Based on the assessment results, either revise the normal procedures or
develop new procedures.
(Section 5.4.2.11)
,
50. Make the emergency exposure criteria for emergency workers consistent-
with'the EPA Emergency Worker and Lifesaving Activity Protective Action
Guides given in EPA-520/1-75-001.
(Section 5.4.3.1)
51.
Require the monitoring and decontamination of personnel assembled at the
Monitor and Control Area prior to evacuation, if possible.
(Section 5.4.
3.4)
52.
Specify action levels which require further assessment of personnel
radiation exposure and/or contamination, and define the assessment techniques
to be used.
(Section 5.4.3.4)
53.
Develop specific security procedures and/or checklists which consolidate
the security organization emergency duties.
(Section 5.4.4)
54. Develop a procedure for the security organization which addresses the
manner in which the security system should be left should the security
'
force be ordered to evacuate.
(Section 5.4.4)
55. Address emergency repair / corrective actions in the Emergency Plan and the
training program.
(Section 5.4.5)
f
0FFICIAL RECORD COPY
..
,- ..
i
.
Appendix B
5-
56.
Develop appropriate Emergency Plan Implementing Procedures (EPIP's) which
address repair and corrective actions under emergency conditions.
These
EPIP's should specify the location of tools, radiation detection instruments,
and communication equia-
, and should address personnel radiological
protection.
(Section 5.4.a)
57.
Integrate the Emergency Public Information Plan into the Emergency Plan
and prepare and include appropriate public information procedures in the
Emergency Plan Implementing Procedures. _ Include the Communications
personnel in the appropriate Emergency Response Organizations, and train
the personnel in their emergency response functions.
(Section 5.4.7)
- t
58.
Develop a mechanism to assure that all emergency response personnel
participate in drills or exercises and that some of the drills or exercises
are started during the off shifts.
(Section 5.5.2)
59.
Establish the quarterly review and updating of telephone numbers used in
the Emergency Plan Implementing Procedures.
(Section 5.5.3)
60. Address emergency actions to be taken concerning that portion of the 10
mile radius surrounding the Oyster Creek Nuclear Generating Station -
comprised by the Atlantic Ocean.
In particular, reach an agreement with
the U. S. Coast Guard for their support during an emergency.
(Section
6.1)
61.
Expedite the final preparation, printing, and distribution of the emergency
information pamphlet to the public.
(Section 6.2)
62.
Perform the exercises and drills in accord with the program described in
the Emergtncy Plan, especially Table 8.2 and EPAP-16.
(Section 7.1)
63.
Expedite the accomplishment of needed improvements in energency prepared-
ness as indicated by the critiques of the drills and exercises.
(Section
7.1)
e
3
0FFICIAL RECORD COPY
..
-
-
.
.
l
!
,
.
s
APPENDIX C
r
EMERGENCY PREPAREDNESS EVALUATION REPORT
BY THE
DIVISION OF EMERGENCY PREPAREDNESS
OFFICE OF INSPECTION AND ENFORCEMENT
U. S. NUCLEAR REGULATORY COMMISSION
IN THE MATTER OF
GYSTER CREEK NUCLEAR GENERATING STATION
DOCKET NO. 50-219
MARCH 1982
1'
..
.
_ _ _ _ _ _ _ _
.
.
Appendix C
2
INTRODUCTION
The GPU Nuclear Corporation filed with the Nuclear Regulatory Commission
revisions to the Oyster Creek Emergency Plan, dated January 29, 1982.
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 1.101.
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.
f
f
.
m.
~
_ _ __ _ _ _
.
.
.
Appendix C
3
EVALUATION
A.
ASSIGNMENT OF RESPONSIBILITY (ORGANIZATIONAL CONTROL)
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.
The Federal, State, and local organizations that are intended to be part
of the overall response organization for Emergency Planning Zones are
identified.
Federal support is provided by the U. S. Department of
Energy.
The role of the State of New Jersey is described, and reference
is made to the New Jersey State Radiological Emergency Preparedness Plan
Local aid is available through the Ocean County Emergency Management
Agency.
The concept of operations and its relationship to the total effort are
described.
The Group Shift Supervisor shall initially assume the role of Emergency
Director.
The Emergency Director is identified as the individual who
shall be in charge of the emergency response.
The licensee will provide for 24-hour per day emergency response, including
24-hour per day manning of the communication links.
Written agreements have been established with the following support
l
l
organizations: Lacey Township First Aid Squad, Bayville First Aid Squad,
i
Community Memorial Hospital, Forked River Volunteer Fire Company, and the
i
Radiation Management Corporation.
The licensee is capable of continuous (24-hour) operations for a protracted
period.
The Emergency Support Director is vested with the authority to
expend corporate funds and utilize manpower and equipment as necessary to
i
mitigate or terminate the emergency situation.
l
l
DEFICIENCIES
The Plan requires revision and/or additional information as follows:
l
l
1.
Expand the section entitled, " Coordination with Government Agencies" to
include the role of the U. S. Coast Guard and the Ocean County Emergency
Management Agency. Also include the arrangements made with private
sector organizations such as General Electric and other utilities whose
assistance may be requested in an emergency.
,
i
l
'
_
_.
.
.
Appendix C
4
2.
Provide a block diagram depicting the interrelationships of the Oyster
Creek emergency response facilities with the offsite organizations having
a primary emergency response role.
Include all Federal, State, local,
and private sector organizations.
3.
Provide agreements with the New Jersey Department of Environmental Protection,
Bureau of Radiation Protection; New Jersay State Police, Office of Emergency
Management; Ocean County Emergency Management Agency; U. S. Coast Guard;
U. S. Department of Energy; General Electric Corporation; and any other
organizations whose services may be relied upon during an emergency.
4.
Explicitly identify the individual, by normal organizational title, who
will be resporisible for assuring continuity of resources during an emergency.
I
i
,
.
.-.
.-
.
-
__
.
.
Appendix C
5
\\
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 interfaces 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 initiate any emergency
actions, including protective action recommendations to offsite author-
ities.
The position of the Emergency Director will initially be filled by the
Group Shift Supervisor until relieved by the on-call Emergency Director.
The functional responsibilities of the Emergency Director are specified.
The responsibility for recommending off-site protective measures may not
be delegated.
Personnel titles and major tasks to be performed by persons assigned to
the functional areas of emergency activity are specified in the plan.
'
The contractor and private organizations who may be requested to provide
technical assistance to and augmentation of the emergency organization
,
l
are identified.
l
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.
DEFICIENCIES
The plan requires revision and/or additional information as follows:
!
1.
The role of the Emergency Director is somewhat ambiguous, following the
l
arrival of the Emergency Support Director.
It appears that the latter
assumes the authority and responsibility for the overall control and
direction of the emergency response.
Upon arrival of the Emergency
Support Director, it-is not clear what functions, if any, remain with the
,
Emergency Director.
Resolve this apparent ambiguity to clearly define
'
who is in charge of what at the time when both the Emergency Director and
the' Emergency Support Director are present.
Depending on the resolution
of the above, it may be in order to transfer the title of Emergency
l
!
_.
_ __.
.
______-__ ___-_-______________________ _ ___ _ __-_ _ -_ _ _
- _ _ _ - _ _ -
.
.
Appendix C
6
Director to the individual having the overall control and direction of
the emergency response, and eliminate the title of Emergency Support
Director.
2.
Specify by title the individuals, including members from the corporate
staff, qualified to assume the position of Emergency Director and Emergency
Support Director.
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 cannot 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 evaluation
criteria B.5 of NUREG-0654.
4.
Provide a figure depicting the interrelationships of Oyster Creek Station
with the various response org:nizations.
Include the technical support
center, operational support center, emergency operations facility, and
headquarters support.
5.
The various support services to be provided by the private sector (e.g.,
General Electric Corporation) should be supported by written agreements,
and the agreements should be appended to the plan.
These agreements
should contain the information set forth in criteria B.9 of NUREG-0654.
l
.
..
-
_ . _ - _ _ _ _ _ _ _ _ _ _
..
.
.
l
Appendix C
7
C.
EMERGENCY RESPONSE SUPPORT AND RESOURCES
Planning Standard
Arrangements for requesting and effectively using assistance resources have
been made, arrangements to accommodate 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.
The Emergency Director is indicated as the person authorized to request
Federal assistance.
The assistance to be provided by the Department of Energy and the Nuclear
Regulatory Commission is described in the plan.
The provision of support services needed to maintain Federal radiological
assistance is addressed in the plan.
Radiological laboratories available during an emergency are identified at
the Three Mile Island Nuclear Generating Station, and the Radiation
Management Corporation.
Nuclear and other facilities which can be relied upon to supply assist-
ance in an emergency are identified for fire fighting, ambulance, and
medical services, and radiological assessment.
DEFICIENCIES
The plan requires revision and/or additional information as follows:
1.
Indicate the expected on-site arrival time for requested DOE assistance
under the Federal Radiological Monitoring and Assessment Plan.
2.
Identify the specific resources which are available to support the Federal
response.
3.
Describe the provisions for dispatch of a company representative to the
principal offsite governmental emergency centers.
. _ . .
.
.
Appendix C
8
0.
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.
The licensee has established an emergency classification scheme consist-
ent with the four emergency categories set forth in Appendix 1 to NUREG-0654.
The licensee has identified various initiating conditions and their
associated emergency action levels 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 Emergency Action Levels (EALs) associated with initiating
events having potential offsite dose consequences have been established
on a very conservative basis with respect to NUREG-0654 recommendations.
As a result, these conservative EALs run counter to the objective of
achieving uniformity and consistency throughout the industry with respect
to emergency classification. .For example, it appears that a " General
Emergency" could result from events involving fuel handling and off gas
system accidents because of the conservative EAL values.
However, it is
doubtful that such accidents could realistically produce offsite doses in
excess of EPA Protective Action Guides (PAGs).
Normally, it is considered
that accidents leading to or involving at least core degradation are
necessary to produce conditions justifying the declaration of a " General
i
Emergency."
It is requested that you reevaluate that portion of your
I
emergency classification scheme based on projected dose consequences in
.
light of the recommendations set forth in NUREG-0654.
!
i
2.
Establish Emergency Action Levels (EALs) for each " General Emergency"
initiating condition specified in Appendix 1 to NUREG-0654.
The EALs
should be observables (e.g., instrument readings, equipment status indications,
l
alarm annunicators) which are both necessary and sufficient to explicitly
and uniquely characterize each initiating condition. Also insure that
,
!
the EALs specified for all of the initiating conditions leading to the
remaining three categories of emergencies are both necessary and sufficient
'
to uniquely characterize the event.
l
l
- -
--
-
-
- _.-
- - _ .
.
.
.
.
__
. _ -
.
.
Appendix C
9
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 (EPZ) have been established.
Notification procedures have been established, consistent with the emergency
classification scheme.
Provisions have been made for verification of
emergency messages.
Procedures for alerting, notifying, and mobilizing emergency response
personnel are described in the plan.
The contents of the initial and followup emergency messages to be sent
from the plant conform with the recommendations set forth in NUREG-0654.
The message format to be used is included in the emergency plan implementing
procedures.
An early warning system has been provided for alerting the population-at-risk
within the plume exposure pathway EPZ.
The system includes fixed sirens
together with the Emergency Broadcast System and supplemented by vehicles
with mobile loudspeakers. When required, the siren system will be activated
by the Ocean County Emergency Coordinator.
DEFICIENCIES
The following requires revision and/or additional information as follows:
1.
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.
-
_ _ - _ - _ _ - _
..
.
.
_ _ .
. _ _ _ _ _ -
.
.
Appendix C
10
F.
EMERGENCY COMMUNICATIONS
Planning Standard
Provisions exist for prompt communications among principal response organiza-
tions to emergency personnel and to the public.
24-hour notification to, and activiation of, the State / local emergency
response 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 Emergency
Operation Centers (E0Cs), 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.
DEFICIENCIES
1.
Specify the organizational titles and alternates for both ends of the
communication links which would be involved in initiating emergency
response actions.
2.
A diverse means of communication, such as a radio system, should be
available between the site and the primary offsite response agency.
It
is not clear that such radio communications are available with the Ocean
County Emergency Operations Center.
3.
Identify the provisions for communications with the U. S. Coast Guard,
since they are a primary response organization within the plume exposure
pathway EPZ.
4.
Describe the provisions for coordinated communications involving the
plant, ambulance service, and the hospital support facilities.
--_
_ _ _ _ _ - _ _ _ .
.
.
Appendix C
11
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 informa-
tion during an emergency (including the physical location or locations) are
established in advance, and procedures for coordinated dissemination of information
to the public are established.
.The points of contact and physical locations for use by news media during
an emergency (Media Center) are designated.
The Manager-Communication Services has the overall responsibility for
public information.
He will designate a spokesperson who will be available
to the media for briefings and questions.
Arrangements for timely exchange of information among designated spokespersons
are established.
Annual programs to acquaint news media with the emergency plans, information
concerning radiation, and points of contact for release of public information
in an emergency are provided.
DEFICIENCIES
The plan requires revision and/or additional information as follows:
1.
Describe the program to be provided for a coordinated yearly dissemina-
tion of information to the public regarding how they will be notified and
what their actions should be in an emergency.
Include the specific items
addressed in evaluation criteria G.1 of NUREG-0654.
2.
Provide a sample copy of the emergency preparedness information which
will be provided for both the resident and transient population around
the site.
. .$.
3.
Describe the provisions made for ensuring that the transient population
~
within the plume exposure pathway EPZ will have access to appropriate
information in advance that would be helpful in the event of a serious
j
emergency.
l
4.
Describe the provisions for accommodating a limited number of the news
media at the nearsite Emergency Operations Facility (EOF).
S' .
Describe your coordinated arrangements for rumor control during emergencies.
I
,
_
_,
-.
a
_
.
.
Appendix C
12
H.
EMERGENCY FACILITIES AND EQUIPMENT
-
Planning Standard
Adequate emergency facilities and equipment to support the emergency response
.
are provided and maintained.
A Technical Support Center (TSC) and Operational Support Center (OSC)
have been established. An Emergency Operations Facility (EOF) will be
established on the Forked River site.
In addition, an Environmental
,
Assessment Command Center has been established for the analysis of field
monitoring data and for direction of the offsite radiological monitoring
teams.
-
An onsite meteorological system including instrumentation, data collect-
ion, and transmission to the control room is in place.
A general description of the onsite radiological monitoring system is
provided.
Provisions have been made to obtain offsite meteorological data from the
National Weather Service in case of failure of onsite equipment.
Offsite radiological monitors including ratemeters and sampling devices
have been provided.
Emergency instruments and equipment are checked quarterly.
Sufficient
reserves are provided to replace those removed from service for mainten-
ance and/or calibration.
DEFICIENCIES
i
The plan requires revision and/or additional information as follows:
1.
In addition to the Technical Support Center (TSC), the plan describes an
Emergency Control Center (ECC) for the purposes of " initial assessment
and coordination of corrective actions for all emergency conditions."
It
appears that the ECC is in conflict with the functional objectives established
for the TSC from the standpoint of both its purpose and location in the
area of the reactor control room.
It is recommended that the functions
proposed for the ECC be handled from the TSC.
Expand the discussion of
the TSC in sufficient detail to enable evaluation against the criteria
set forth in NUREG-0696.
2.
It appears from the description of the offsite emergency response facilities
that the functions of the EOF have been spread among the nearsite EOF,
farsite EOF, and the Parsippany Technical Functions Center.
Reevaluate
the functions of these three facilities in light of the criteria in
NUREG-0696, and resubmit a detailed description of the E0F for evaluation
against the aforementioned criteria.
__
.
.
Appendix C
13
3.
Identify the onsite monitors for obtaining seismic and hydrologic information
which may be used for initiating emergency measures in accordance with
criteria H.5.a of NUREG-0654.
-
4.
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 ider.tification, location, and range.
5.
Identify the fire and combustion products detectors whicn 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.
As part of your description of the offsite radiological monitoring program,
provide 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.
8.
Although the plan discusses the onsite meteorological instrumentation, it
is insufficient to determine compliance with the criteria set forth in
Provide detailed information which explicitly addresses the
criteria in Appendix 2 of the aforementioned document.
- .-
_
-.
.
- .
. - .
--
.
.
.
Appendix C
14
-
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.
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 within
plant systems and the magnitude of the release of radioactive materials
is addressed in the Emergency Plan Implementing Procedures.
The relationship between effluent monitor readings and onsite and offsite
exposures and contamination for various meteorological conditions is
provided in the procedures.
The methodology for determining the release rate / projected dose if assessment
instrumentation is inoperable or offscale is addressed.
The capability to provide field monitoring within the plume exposure
pathway EPZ is described.
DEFICIENCIES
1.
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.O.3.3 in NUREG-0737.
1
'
2.
Provide detailed information in the plan 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.
3.
Indicate the meteorological information that will be provided to an
offsite NRC center and made available to State agencies for their use.
4.
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.
__-
.
.
.
. .
.
.
Appendix C
15
5.
Describe your capability to detect and measure radiciodine concentrations
in air in the plume exposure pathway EPZ as low as 10-7 pCi/cc under
field conditions.
6.
Describe the means for relating measured field contamination levels _to
dose rates for applicable isotopes listed in Table 3 of NUREG-0654.
.
___
_ _ _ _ _ _ _ _
__
_ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _
_ _ _ - _ _ -
_.
.
.
Appendix C
16
J.
PROTECTIVE RESPONSE
Planning Standard
A range of protective actions have been developed for the plume exposure
pathway 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
pathway EPZ appropriate to the locale have been developed.
The means used to warn plant employees and visitors that an accident has
occurred have been established.
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.
The plan contains maps and tables showing population distributions around
the plant.
The plan describes the early warning sjstem which could be used for
notifying all segments of the transient and resident population in the
event of a serious accident.
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.
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.
_ _ _ _ _ _ _ _ _ _ _ _ _ _
.
..- _
.
.
..-
,
_ _ _
._ _
._-
. .
.
<
Appendix C
17
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 a discussion of the decision making process, including the bases,
to be used by the Emergency Director in arriving at a choice of recommended
offsite protective actions in the event of a serious emergency. Discuss
the consideration given to the local protection afforded by residentist
units and other shelters as part of the bases for selecting recommended
protective actions for the plume exposure pathway during emergency conditions.
.
d
4
.
w
r
-
.
M'
-
""
v
n-'
wan
-w4m.
e-
m
--
-~-
,,,,
_,.,e
--,
- - _ . , .
-
_ _ -
-
- . _ _
.
.
Appendix C
18
K.
RADIOLOGICAL EXPOSURE CONTROL
planning Standard
Means for controlling radiological exposures in an emergency are established
for emergency workers.
The means for controlling radiological e'xposures shall
include exposure guidelines consistent with EPA Emergency Worker and Lifesaving
Activity Protective Action Guides.
Onsite exposure guidelines consistent with the recommendations of the
National Council on Radiation Protection have been established for emergency
workers.
An onsite radiation protection program has been established for emergency
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.
,
The means for radiological decontamination of emergency personnel and
disposal of contaminated waste have been established.
OEFICIENCIES
The plan requires revision and/or additional information as follows:
1.
The plan indicates that the methods and conditions for permitting personnel
to receive emergency radiation exposures, including the provisions for
expeditious decisions in such cases, is described in the implementing
procedures.
Identify these procedures by number and title or, as an
alternath e, 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.
i
3.
Identify the onsite contamination control measures for area access control
and for food and potable water supplies.
4.
Although the plan discusses the general capability for decontamination,
indicate the decontaminants available for radioiodine contamination of
the skin for relocated onsite personnel.
.
=
n
e
-
-
-
..
..
_
_
,
.
Appendix C
19
L.
MEDICAL AND PUBLIC HEALTH SUPPORT
Planning Standard
!
Arrangements are made for medical services for contaminated injured individuals.
Arrangements have been n.ade 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.
.
~
i
i
!
.
--
_
-
_ _
. - , .
_
_-
.
__ .
.
.
Appendix C
20
M.
RECOVERY AND REENTRY PLANNING AND POSTACCIDENT OPERATIONS
Planning Standard
General plans for recovery and reentry are developed.
General plans and procedures for reentry and recovery are developed, and
i
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 informing members of the response organizations
that a recovery operation is to be initiated.
A method for periodically estimating total population exposure is established.
.
.
1
,
.
.
,
- . , . _ _
a-
-
. -.
--
- ,, _ -
_.
.__
.
.
Appendix C
21
N.
EXERCISES AND DRILLS
Planning Standard
Periodic exercises are (will be) conducted to evaluate major portions of
emergency response cabilities, 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.
An annual preparedness exercise that simulates an emergency that results
in offsite radiological releases which would require response by offsite
authorities is provided.
The scenario for the annual exercise will be varied from year to year to
assure that the major alements of the plan and the preparedness organizations
are tested at least once in a five year period.
Monthly communications drills will be conducted with State and local
-
governments within the plume exposure pathway EPZ. Quarterly communica-
tions drills will be conducted with Federal emergency response organiza-
tions and States within the ingestion pathway EPZ. Annual communication
drills will be conducted between the licensee, State and County emergency
operations centers, and the field survey teams.
Fire drills are cunducted in accordance with the plant Fire Protection
Plan.
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, is provided.
A semi-annual Radiological Controls drill will be conducted to test the
response to and analysis of simulated elevated airborne and liquid samples.
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.
The Supervisor-Emergency Preparedness is responsible for implementing
corrective actions based on observer and participant comments on the
exercise or drill.
.
v
.
,
n
_
.
.
Appendix C
22
DEFICIENCIES
The plan requires revision and/or additional information as follows:
1.
Indicate that the drills will be supervised and evaluated by a qualified
drill instructor.
2.
Communications with the NRC shall be tested monthly in accordance with
paragraph E.9.d of Appendix E of 10 CFR Part 50. Also, the communications
drills should include the aspect of understanding the message content.
-
3.
Annually include in the Radiological Controls drill the analysis of
inplant liquid samples with actual elevated radiation levels, including
use of the post-accident 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.
>
f
4
4
1
,
.
Appendix C
23
0.
RADIOLOGICAL EMERGENCY RESPONSE TRAINING
Planning Standard
i
Radiological emergency response training is provided to those who may be
called on to assist in an emergency.
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.
First aid personnel receive Red Cross Multi-Media training.
A specialized training program has been established for the various
categories of emergency perstnnel responsible for the implementation of
the plan.
,
The licensee has provided for arinual retraf ning of personnel with emergency
response duties.
DEFICIENCIES
The plan requires revision and/or additional information as follows:
1.
Describe the site specific training available to those offsite response
organizations whose assistance may be required in the event of an emergency.
Training for hospital personnel, ambulance crews, police, and fire departments
should include the procedures for notification, basic radiation protection,
and their expected roles.
For those support organizations who may be
brought onsite, training should include site access procedures and the
identity of onsite personnel who will control the organizations' activities.
2.
Include provisions in your training program for on-the-spot correction of
erroneous performance during drills and a demonstration of the proper
performance by the instructor.
3.
In order to obtain a better understanding regarding the scope of the
training program, provide the number of classroom hours for each of the
personnel categories identified in Table 8.1 of the plan.
_ _ _ - _ _ _ _ _ _ _ _
.
.
,
,
Appendix C
24
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 planners are properly trained.
The individual with overall authority and responsibility for radiological
emergency response planning is the Vice President, Nuclear Assurance.
The Supervisor-Emergency Preparedness has the responsibility for development
and updating of the emergency plans, and for coordination of the emergency
plans with other responsible organizations.
The Emergency Plan and its implementing procedures will be reviewed
annually.
Procedures for implementing the Emergency Plan are listed in procedure
number and title.
The plan contains a detailed table of contents and a cross-reference to
the evaluation criteria in NUREG-0654.
,
DEFICIENCIES
j
The plan requires revision and/or additional information as follows:
1.
Describe the training provided for the individuals responsible for the
emergency planning effort.
2.
Identify in Appendix B the section of the plan to be implemented by each
procedure.
3.
In accordance with paragraph 50.54(t) of 10 CFR Part 50, indicate that an
independent review of the emergency preparedness program shall be conducted
every 12 months. The review shall include an evaluation for adequacy of
interfaces with State and local governments, drills, exercises, capabilities,
and procedures. Also identify the management controls to be used for
evaluation and correction of the review findings.
4.
Indicate that the telephone numbers in the emergency procedures will be
updated quarterly.
.
4
..
-
,
--
-
,
. . _ .
,
.-
-
--
__
-
.
i
Appendix C
25
CONCLUSION
Based on our review, we conclude that the Oyster Creek 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 Nu-lear Power Plants," November 1980.
The NRC evaluatior. _n the overall state of emergency preparedness for the
Oyster Creek site will be made following review of the findings and determina-
tions made by FEMA on the State and local emergency response plans, and the
i
review of the joint exercise held to demonstrate the capability to implement
i
the onsite and offsite plans.
.. ,
_
.
.
-.
-.
.
_
. _ _ .
.
.. .
-
_-
- -.