ML20057C760
| ML20057C760 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 09/23/1993 |
| From: | Quennoz S PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20057C761 | List: |
| References | |
| NUDOCS 9309290361 | |
| Download: ML20057C760 (20) | |
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am m ammmu Portland General BectricCoriipiny
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g James E. Cross Vice President and Chief Nuclear Officer September 23, 1993 Trojan Nuclear Plant Docket 50-344 License NPF-1 U.S.
Nuclear Regulatory Commission Attn Document Control Desk washington, DC 20555
Dear Sirs:
Response to NRC Observations on the Troian Permanent 1v Defueled Emeroency Plan This letter provides Portland General Electric Company's (PGE) response to Nuclear Regulatory Commission (NRC) observations on the proposed Permanently Defueled Emergency Plan (PDEP). These observations were initially discussed during a telephone conversation between PGE and the NRC on September 8, 1993.
Attachment I to this letter contains PGE's response to specific NRC observations. Attachment II to this letter provides a copy of the proposed PDEP (less the appendices) revised to incorporate NRC observations. Additional minor revisions have been made to incorporate comments from the State of Oregon and for editorial purposes. These revisions do not change the conclusion of the previously submitted safety analysis prepared for the PDEP.
Sincerely, y m... _ _
S. M. Quennoz for J. E. Cross Attachments 9309290361 930923 P
PDR ADOCK 05000344 ".
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r Document Control Desk September 23, 1993
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c Mr. Bobby H. Faulkenberry i
Regional'Administrater, Region V U.
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Nuclear. Regulatory Commission Mr. David Stewart-Smith State of Oregon f
Department of Energy Mr. James Melfi NRC Resident Inspector Trojan Nuclear Plant i
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Trojan Nuclear Plant Document Control Desk I
Docket 50-344 September 23., 1993 License NPF-1 Attachment I Page 1 of 17 PGE RESPONSE TO NRC OBSERVATIONS ON THE TROJAN PROPOSED PERMANENTLY DEFUELED EMERGENCY PLAN (PDEP) AND PROPOSED EMERCENCY ACTION LEVELS i
NRC EAL Observation
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Table 4-1, EAL I.1: Need to specify a value instead of 2 times Technical Specification limit.
PGE Response The values that will be used to determine the initiation of this EAL are as follows:
PERM-1, Channel A: 2.22E5 cpm PERM-2, Channel A: 1.05ES cpm PERM-2, Channel C: 9.50E3 cpm Table 4-1 of the PDEP now includes these values.
1 NRC EAL Observation f
t Table 4-2, EAL I.1: Need to add specific values (same comment as above).
Consider adding a 15 minute time frame and base on confirmed sample analysis (as NUMARC has).
PGE Response The values that will be used to determine the initiation of this EAL are as follows:
PERM-1, Channel A: 2.'22E7 cpm PERM-2, Channel A: 1.05E7 cpm PERM-2, Channel C: 9.50E5 cpm l
The release time will also be specified as 15 minutes or longer.
This short period cf time will not allow confirmation by sample analysis so this limitation was not specified.
Table 4-2 has been revised to incorporate these changes.
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g Trojan Nuclear Plant Document Control Desk Docket 50-344 September 23, 1993 License NPF-1 Page 2 of 17 NRC EAL Observation Table 4-1, EAL 11.1: k'ha t is the flood level?
PGE Response The guidance provided in NUHARC NESP-007 states that the Unusual Event initiating condition is natural and destructive phenomena occurring within the Protected Area. A flood level of > approximately 25 ft. Mean Sea Level (MSL) could impede normal access to the plant site via the site access road.
Such a flood Icvel could threaten normal operations at the plant.
Therefore, this EAL was revised to reflect the flood level which impedes access to the site via the Plant access road for initiation of an Unusual Event.
The guidance provided in NUMARC NESP-007 states that the Alert EAL initiating condition is a natural and destructive phenomena occurring within plant Vital Areas.
Also, the EAL for phenomena such as floods, "is intended to address events that may have resulted in a plant vital area being subjected to forces beyond design limits" The design limit for a flood is 45 ft. MSL or grade elevation of the site.
Damage to the Spent Fuel Pool structure would not be expected to occur unless the flood level exceeded site grade elevation.
Therefore, this EAL was revised to reflect the flood level to site grade elevation for initiation of an Alert.
Tables 4-1 and 4-2 have been revised to reflect.this information.
NRC EAL Observation Table 4-1, EAL II.2: Does the tornado have to be confirmed?
PGE Response The guidance provided in NUMARC NESP-007 states that the Unusual Event EAL initiating condition is natural and destructive phenomena occurring within the Protected Area. Also, the EAL, "is based on the assumption that a tornado striking (touching down) within the protected boundary may have potentially damaged plant structures...", that may impact plant safety.. Since a tornado would be a localized phenomenon the Shift Mar,ager will be the final confirmation that a tornado has occurred within the exclusion area boundary.
It will be the Shift Managers' judgment if the meteorological condition is described as a tornado.
In addition, if structural damage is incurred it will be determined by visual observation of the Shift Manager as described in the response on 'high wind' below.
Tables 4-1 and 4-2 have been changed accordingly.
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I Trojan Nuclear Plant Document Control Desk
' Docket 50-344 September 23, 1993 License NPF-1 Attachment I i
Page 3 of 17 NRC EAL Observation l
Tabic 4-2, EAL II.2: How high is 'high winds'?
l PGE Response l
The Category I and Category II structures are designed, as a minimum, for a wind loading of 105 mph at 30 feet above the 45 ft. MSL grade elevation.
The 1
current defueled status of the facility does not require permanently installed system operation to maintain Spent Fuel Fool inventory. The integrity of the building structures supporting the Spent. Fuel Pool maintains water over the j
top of the spent fuel. The concern for high wind damage is to the structures containing radioactive material and the spent fuel including the Fuel, Auxiliary, Control, Radwaste or Containment Buildings. There is sufficient time to visually determine if structural / system damage has occurred and provide alternate Spent Fuel Pool makeup capability. Therefore, confirmation by visual observation of structural damage caused by high winds is adequate.
Table 4-2 has been changed to reflect this response.
NRC EAL Observation
.i Why aren't the following NUMARC EAL initiating conditions addressed in EALs?
- SU7, 1
- SA1, l
SUS (not covered for spent fuel pool leakage),
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- AA3, j
- HAS,
- SU1, SU6 (Table 4-1. EAL III.3 does not cover loss of onsite communication)
PGE Response f
Each item is discussed separately below:
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~i SU7 Unplanned loss of required DC power during Cold Shutdown or Refueling Mode for greater than 15 minutes.
-l The permanently defueled condition of the Trojan facility does not l
require DC power to ensure the safe storage of irradiated spent l
fuel.
Spent Fuel Pool water inventory (water level above the top of the fuel) is all that is required to ensure safe storage of the existing spent fuel. If forced cooling is lost, the operators have over 4 days to take action to_ provide makeup to the Spent Fuel l
Pool and ensure a water level of 5' above the top of the fuel'.
Since DC power is not needed to maintain adequate water inventory i
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Trojan Nuclear Plant Document Control Desk Docket 50-344 September 23, 1993 License NPF-1 Attachment.I Page 4 of 17 T
in the Spent Fuel Pool, SU7 does not. apply to the defueled Trojan
-l facility.
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sal Loss of all offsite. power and loss of all onsite AC power to essential busses during Cold Shutdown or Refueling-Mode, j
The permanently defueled condition of the Trojan facility does'not
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require AC power to ensure the safe storage of irradiated spent fuel, and therefore there are no essential buses.
Spent Fuel Pool
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water inventory (water level above the top of the fuel).is all that is required'to ensure safe storage of the existing spent fuel. The loss of AC power.would. prevent forced cooling, but even with the worst case accident assumptions, the operators have over.
i 4 days to take action to provide makeup to the Spent Fuel Fool and ensure a water level of 5 ft. above the top of the fuel.
The increase in Spent Fuel Fool temperature or decrease in. level will initiate the appropriate EAL Since loss of AC is not directly-a f
concern for safe storage of irradiated spent fuel, SA1 does not apply to the defueled Trojan facility.
L SUS RCS Leakage. (not covered for spent fuel pool leakage)'
l Spent Fuel Fool water inventory (water level above the top of the-
'l fuel) is all that is required to ensure safe storage.of the existing spent fuel. The leakage of water from the Spent Fuel Pool due to liner leakage is monitored and collected.. This leakage is not a concern as long as the water level is maintained within established parameters. The decrease in. level to an established value (< 23 feet in Table 4-1, EAL III.1) will initiate the appropriate EAL.
Since Spent Fuel Pool leakage is not directly a concern for safe storage of irradiated spent fuel,
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SUS does not apply to the defueled Trojan facility.
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AA3 Release of radioactive material or increases.in radiation levels within the Facility that impedes operation of systems required to maintain safe
'i operations or to establish or naintain Cold Shutdown.
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The only credible source of radioactive material that may increase exposures to a point of impacting the ability to maintain safe-
-I storage of the irradiated spent fuel is the spent fuel itself;
-A calculation was performed to verify the water level of the Spent Fuel Pool provides adequate radiation exposure protection for j
operator action near the pool down to a le: vel of 5 ft. above the fuel. An increase in Spent Fuel Pool temperature or decrease in level will initiate the appropriate EAL.
Also, Table 4'-1, EAL I.2 and Table 4-2, EAL 1.2 address high radiation in the Fuel Building.
Since the water level and temperature EALs will be reached well before radiation levels are a concern and Fuel j
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Trojan Nuclear Plant Document Control Desk Docket 50-344 September 23, 1993 License NPF-1 Attachment I Page 5 of 17 Building radiation level EALs are established, AA3 does not apply to the defueled Trojan facility.
HA5 Control Room evacuation has been initiated.
The Control Room has.significantly reduced importance for the defueled plant as the limited controls and monitoring instrumentation are also available local to the plant equipment.
Also, certain key operator actions can only be performed outside the Control Room.
Control Room evacuation in conjunction with the worst case accident for safe storage of irradiated spent fuel would not. require any operator action for at least 4 days, under the worst case assumptions. An increase in Spent Fuel Fool temperature or decrease in level will initiate the appropriate EAL.
Emergency communications and operations can be established and conducted from other locations within the Industrial Area if the Control Room is not available.
Since the water level and temperature EALs will be-reached well before. operator. action outside the Control Room is needed to maintain safe-storage of irradiated spent fuel and emergency operations can be conducted outside the. control Room, RAS does not apply to the defueled Trojan facility.
SU1 Loss of all offsite power to essential busses for greater than 15 minutes.
The permanently defueled condition of the Trojan facility does not require AC power to ensure the safe storage of irradiated spent fuel, and therefore there are no essential buses.
Spent Fuel Fool water inventory (water level above the top of the fuel) is required to ensure safe storage of the existing : pant fuel. Under the worst case accident assumptions, the operators have over 4 days to take action to provide makeup to the Spent Fuel Pool and ensure a water level of 5 ft. above the top of the fuel.
The loss of offsite AC power, by.itself, is not a concern as long as the water temperature and level remain within established parameters.
An increase in Spent Fuel Pool temperature or. decrease in level-will initiate the appropriate EAL.
Since loss of offsite AC is not directly a concern for safe storage of irradiated spent fuel, SU1 does not apply to the defueled Trojan facility.
.SU6 Unplannea loss of all onsite or offsite communication capabilities.
(Table 4 1, EAL III.3 does not cover loss of onsite communication.)
The basis for making a loss of all onsite communications'an unusual event, per NUMARC NESP-007, is to recognize a loss of communications capability that defeats the plant operations staff.
ability to perform routine tasks necessary for plant operations.
Normal operations at the defueled Trojan facility involve ensuring
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c Trojan Nuclear Plant Document Control Desk Docket 50-344 September 23, 1993 License NPF-1 Attachment I Page 6 of 17 the Spent Fuel Pool water level and temperature are maintained.
These actions do not require the.same rapid response (where immediate communications are critical) that an. operating plant needs.
Since a loss of all onsite communications would not significantly impair the facility operators ability to perform routine tasks necessary for plant operations, SU6 for loss of onsite communications does not apply to the defueled Trojan facility.
NRC PDEP Observation The State of Washington and Cowlitz County should be notified in an emergency.
PGE Response Section 6.1 of the PDEP has been revised to ensure that the State of Washington and Cowlitz County are notified in an emergency. Additionally, Sections 3.4.3 and 3.4.4 have been added to the PDEP to identify the State of j
Washington and Cowlitz County.
Existing portions of these PDEP sections were l
renumbered to accommodate the insertion of the new information.
The new portions of Section 6.1 read as follows:
(5)
Washington Emergency Management Division Duty Officer via commercial telephone within 30 minutes. Backup communications can be established via the PGE Load Dispatcher through the Blue Band Radio.
4 (6)
Cowlitz County Emergency Management 911 Dispatcher via commercial-telephone within 30 minutes.. Backup communications can be established via the PGE Load Dispatcher through the Blue Band l
- Radio, j
i' New Section 3.4.3 reads as follows:
3,4.3 - STATE OF WASilINGTON j
PGE notifies and provides updates to the Washington Emergency Management Division in the event of an emergency (including prior notification of.
Columbia River closure).
PGE coordinates public information news i
releases with the State of Washington, via the State of Oregon, or.
directly, if requested.
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, : r Trojan Nuclear Plant Document Control Desk Docket 50-344 September 23, 1993 License NPF-1
-Attachment I
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Page 7 of 17 New Section 3.4.4 reads as follows:
i 3.4.4 - COWLITZ COUNTY l
PGE notifies Cowlitz County in the event of an emergency. _PGE coordinates public information news releases with Cowlitz County.
PGE also provides updates on the status of the emergency (including prior notification of Columbia River closure).
i NRC PDEP Observation 4
The NRC reviewer had a poor quality reproduction of Figure 3-1.
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PGE Response i
4 PGE will provide legible copies of Figures with the approved PDEP.
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t NRC PDEP Observation l
It is not clear how PGE Corporate Communications communicates with state and local government to coordinate news releases prior to release. A description' should be provided of how this interface is accomplished.
PGE Response Section 5.2 of the PDEP has been revised to read as follows:
Corporate Communications provides support to the Media Representative in preparing and coordinating public information news releases.
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.I The PGE Load Dispatcher, located at the World Trade Centet in Portland, j
provides notifications support in the event of commercial. telephone system failure.
Section 6.4, Public Information, has been added to the PDEP to. provide a
-description of how public information is handled.
Section 6.4 reads as follows.
News releases containing information regarding plant conditions and PGE -
response activities are developed and coordinated with state and local government agencies prior to the information being released.
The i
primary PGE point of coordination is the Oregon State public information l
representative. Washington and Cowlitz County may choose to coordinate information with Oregon, or work directly with PGE's Media Representative. The Media Representative communicates with Oregon State
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t Trojan Nuclear Plant Document Control Desk Docket 50-344 September 23, 1993-License NPF-1 Attachment I Page 8 of 17 and other designated public information representatives at predetermined I
locations via commercial telephone.
NRC PDEP Observation j
The State of Washington and Cowlitz County should be added to the discussion regarding state and local governmental response.
PGE Response l
Section 5.3 has been revised to include a discussion of Washington State and Cowlitz County responses and now reads as follows:
There is no assistance expected from state and local government l
agencies.
In most situations, state and local government response is expected to be limited to recording the notification of the emergency, periodically receiving updated information on the emergency, and coordinating public information news releases, if any (see Sections 6.1 and 6.4).
An ODOE representative may respond to the CR during i
emergencies.
I If required, provisions exist for Oregon and Columbia County-agencies to halt traffic on the Columbia River Highway and county roads within the exclusion area when_ advised by PGE.
The EC has the authority to request such support if it is needed.
In the case of a potential or actual release of radioactive material, the following actions may be taken: (1) Oregon State Health Division, l
Radiation Control Section, may dispatch a field monitoring team to survey for radiological releases and to monitor environmental impact, including ingestion concerns to verify additional actions are not
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required to protect the health and safety of the public; (2) Columbia
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County may activate its emergency operations center to coordinated with j
TNP and Oregon State Health Division any necessary response actions.
j Columbia County's response actions may involve road blockades, traffic control, route alerting, precautionary evacuation or relocation,' food control and security patrols. Other response measures may include l
activities to support communications and public information.
l The State of Oregon and Columbia County may issue press releases as necessary. These press releases are coordinated with the appropriate offsite agencies a.'d with TNP.
NRC PDEP Observation
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Trojan Nuclear Plant:
Document Control Desk Docket 50-344 September:23,-1993 License NPF-1 Attachment I Page 9 of 17 i
The anticipated Federal Government support role should be clearly explained ECE Response Section 5.4 has been revised to read as follows:
r There is no anticipated federal support which would be provided to TNP in the event of a declared emergency. 1However, if required, the l
authority exists for the U.S. Coast Guard to regulate activities on the j
Columbia River within the exclusion area when necessary to prevent harm to persons, property, and the environment in or on those waters.
The EC
'l has the authority to request such support should it be needed.
This change was made to clearly state.that federal support is not anticipated but Coast Guard assistance is available if needed.
P NRC PDEP Observation Figure 5-1 identifies maintenance personnel; however, Tables 5-1 and.5-2 f
identify Emergency Teams.
The wording should be revised to be consistent between Figures and Tables.
PGE Response
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Figure 5-1 and Tables 5-1 and 5-2 have been revised so that the identification of personnel and positions are consistent.
P NRC PDEP Observation A discussion should be added explaining that the ODOE Technical Advisor is a non-ERO position.
PGE Response A ncte was added to revised Figure 5-1 to explain that the ODOE Representative is a non-ERO position.
The Note reads as follows:
i NOTE: Plant Management and the ODOE Representative are not ERO positions, but are only shown to illustrate their interfacing i
relationship with the ERO.
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T.Tojan Nuclear Plant Document Control Desk l
Docket 50-344 September 23, 1993 i
License NPF-1 Attachment I Page 10 of 17 NRC PDEP Observation i
A discussion should be added to Tables 5-l'and 5-2 for positions shown in f
Figure 5-1 but not listed in the Tables (e.g. clerical, RP/ Chemistry, Security, Plant Manager).
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i PGE Response The following revisions were made to Table 5-1:
The title " Corporate Communications Media Representative" was changed to
" Media Representative" The tile " Emergency Teams" was revised to " Operations Personnel".
The title " Security Supervisor" was changed to " Security Coordinator".
" Security Personnel" were added to the Table.
t The Following Revisions were made to Table 5-2:
The title " Administrative Assistant" was changed to " Logistics Coordinator".
I The title " Corporate Communications Media Representative" was changed to
" Media Representative" The title " Emergency Team Coordinator" was changed to " Maintenance Coordinator" The tile " Emergency Teams" was revised to " Operations, Maintenance, RP/ Chemistry Personnel".
Field Monitoring (radiation surveys and air sampling) was added to the
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responsibilities for Operations, Maintenance and RP/ Chemistry Personnel.
The title " Security Supervisor" was changed to " Security Coordinator".
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" Security Personnel" were added to the Table.
NRC PDEP Observation No provisions are stated for the line of succession for the Shift Manager / Emergency Coordinator.
It is not clear whether the Shift Manager remains in control when the Plant Manager is present.
Also, describe what is meant by " local evacuation" in Table 5-2.
j Trojan Nuclear Plant Document Control Desk l
Docket 50-344 September 23, 1993 License NPF-1 i
Page 11 of 17 PGE Response Section 5-.1, Emergency Response Organization, was revised to read as_follows:
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The ERO is composed of a shift organization, augmented by predesignated ~
Plant personnel.
(A description of the normal plant operating organization is shown in the Trojan Technical Specifications.) The ERO is capable of responding to an emergency and augmenting its response on a continual basis.
l The minimum shift organization required for emergency response consists
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of the Shift Manager, an operator, a security supervisor, and security personnel (the Shift Manager and operator are not assigned Fire Brigade duties).
These personnel provide the initial response to an emergency.
The shift organization is augmented by additional personnel _who are called out upon declaration of an Alert or earlier, if necessary (see
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Figure 5-1).
The goal of the ERO is to be fully activated within two hours of an Alert declaration.
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5.1.1 EMERGENCY COMMAND AND CONTROL The Shift Manager assumes Emergency Coordinator (EC) duties upon declaration of, and for the duration of, an emergency (Unusual Event or i
Alert).
The Emergency Coordinator is the person onsite in charge of the emergency response. The EC has authority over onsite activities and personnel, and is responsible for assuring continuity of resources.
An operator assumes EC duties if the Shift Manager becomes incapacitated or is otherwise unable to perform these duties.
f 5.1.2 - UNUSUAL EVENT ERO TASKS During an Unusual Event, the ERO tasks include:
(1)
Notifying offsite agencies.
(2)
Monitoring, evaluating, and correcting the initiating condition, j
(3)
Terminating the emergency classification.
The task assignments are outlined in Table 5-1.
5.1.3 - ALERT ERO TASKS The tasks to be performed during an Alert remain the same as those for an Unusual Event, with the exception that the ERO may decide to enter l
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5 Trojan Nuclear Plant Document Control Desk
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Docket 50-344 September 23, 1993 License NPF-1 Attachment I Page 12 of 17 into a recovery phase based upon Plant conditions.
The task assignments ~
are outlined in Table 5-2.
The term " local evacuation" used in Table 5-1 has been changed to " localized evacuation", and is discussed in Section 6.3.1, Industrial Area Control.
Section 6.3.1 reads as follows:
The EC may authorize specific protective measures be taken within the Industrial Area to limit the potential for personnel injury or i
radiological exposure.
These actions could include, but are not limited to the exclusion of visitors from the Industrial Area, evacuation of Plant personnel from all, or portions of, the Industrial Area and requiring personnel accountability measures to be taken.
NRC PDEP Observation Discuss the back-up to the pager system for notifying members of the Emergency Response Organization.
PGE Response f
The backup to the paging system is the commercial telephone system.
Item (2) of Section 6.1 was revised to reflect this, as follows:
(2)
ERO via paging and commercial telephone systems.
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NRC PDEP Observation l
Add the State of Washington and Cowlitz County to the list of personnel or agencies that will be contacted regarding emergency classification, termination or other notifications.
PGE Response New items (5) and (6) were added to Section 6.1 to add the State of Washington i
and Cowlitz County to the list or personnel or agencies that will be contacted regarding emergency classification, termination or other notifications. New items (5) and (6) read as follows:
(5)
Washington Emergency Management Division Duty Officer via commercial telephone within 30 minutes.
Backup communications can be established via the PCE Load Dispatcher through the Blue Band Radio.
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Trojan Nuclear Plant-Document Control Desk Docket 50-344 September 23, 1993 License NPF-1 Attachment I Page 13 of 17 1
(6)
Cowlitz County Emergency Management 911 Dispatcher via commercial telephone within 30 minutes. Backup communications can be established via the PGE Load Dispatcher through the Blue Band Radio.
i Subsequent numbered items in the list were renumbered to accommodate these changes.
I NRC PDEP Observation Include requirements for inventory and operational checks of emergency equipment after its use.
PGE Response Item (6) in Section 9.5 was revised to read as follows:
r (6)
Emergency equipment inventories and operational checks to be conducted semi-annually and after equipment use.
t NRC PDEP Observation Clearly identify the Emergency Coordinator position as the position in charge and able to commit company resources, etc. during an emergency (see NUREG 0654, Item A.I.d).
l PCE Response l
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A new Section 5.1.1, Emergency Command and Control, was added to address this
-j observation.
Section 5.1.1 reads as follows:
The Shift Manager assumes Emergency Coordinator (EC) duties upon declaration of, and for the duration of, an emergency (Unusual Event or j
Alert).
The Emergency Coordinator is the person onsite in charge of the
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emergency response.
The EC has authority over onsite activities and personnel, and is responsible for assuring continuity of resources. An l
operator assumes EC duties if the Shift Manager becomes incapacitated or is otherwise unable to perform these duties.
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Trojan Nuclear Plant-Document Control Desk Docket 50-344 September 23, 1993 License NPF-1 Attachment I _
Page 14 of 17 NRC PDEP Observation Discuss around the clock staffing capabilities including initial and protracted coverage.
PGE Resnonse Section 5.1, Emergency Response Organization, was revised as follows to address this concern:
The ERO is composed of a shift organization, augmented by predesignated Plant personnel.
(A description of the normal plant operating organization is shown in the Trojan Technical Specifications.) The ERO is capable of responding to an emergency and augmenting its. response on-a continual basis.
The minimum shift organization required for emergency response consists of the Shift Manager, an operator, a security supervisor, and security personnel (the Shift Manager and operator are not assigned Fire-Brigade duties).
These personnel provide the initial response to an emergency.
The shift organization is augmented by additional personnel who are called out upon declaration of an Alert or earlier, if necessary'(see Figure 5-1).
The goal of the ERO is to be fully activated within two hours of an Alert declaration.
NRC PDEP Observation There is no discussion of, or provisions for, field survey teams (see NUREG 0654, Item I.7).
This should be added to the Plan.
PGE Resnonse Field Team duties were added to the Operations, Maintenance, RP/ Chemistry Personnel responsibilities listed in Table 5-2, Alert ERO Responsibilities This section now reads as follows:
OPERATIONS. HAINTENANCE. RP/ CHEMISTRY PERSONNEL In addition to duties detailed on Table 5-1:
Conduct surveys.
Perform decontamination activities.
Perform field monitoring (radiation surveys and air sampling).
In addition, pcrtable radiation survey and air sampling equipment were added to Section 8.3, Equipment Locker and Equipment.
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'I Trojan Nuclear Plant Document Control Desk Docket 50-344 September 23, 1993 License NPF-1 Attachment I Page 15 of 17 NRC PDEP Observation i
The_ Plan should include a discussion of site evacuation, personnel accountability and visitor /non-essential personnel actions during an emergency.
t PGE Response i.
Discussions of full and partial Industrial Area evacuation and of personnel accountability were added to Section 6.3, Onsite Protective Measures.
Section 6.3 now reads as follows:
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6.3.1 - INDUSTRIAL AREA CONTROL The EC may authorize specific protective measures be taken within the Industrial Area to limit the potential for personnel injury or radiological exposure. These actions could include, but are not limited to the exclusion of visitors from the Industrial Area, evacuation-of Plant personnel from all, or portions of, the Industrial Area and requiring personnel accountability measures to be taken.
6.3.2 - EXCLUSION AREA CONTROL Several measures can be initiated to control traffic through and access l
to the exclusion area. Members of the general public making recreational or other casual use of the non-restricted portions of the exclusion area can be evacuated.
Roadblocks can be established as required at the junction of the highway with the northern and southern boundaries of the exclusion area, thereby restricting road travel through the site.
Railroad traffic can be restricted over the rail' right-of-way through_the exclusion area.
River traffic can be closed off from the portion of the river within the exclusion area.
t NRC PDEP Observation t
The Plan should include a discussion of provisions made for personnel dosimetry.
PGE Response A new section 6.3.4, Dosimetry Issue, was added to address personnel dosimetry.
This section reads as follows:
l Dosimetry, such as thermoluminescent dosimeters' (TLDs) and digital-alarming dosimeters (DADS), is issued to emergency teams and other emergency personnel as warranted by existing or expected conditions.
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i Trojan Nuclear Plant Document Control Desk Docket 50-344 September 23, 1993 j
License NPF 1 Page 16 of 17
.NRC PDEP Observation The Plan frequently relies on reference to Emergency Plan Implementing Procedures rather than providing in-Plan discussion.
1 PGE Response 4
The number of Plan references to the EPIPs has been reduced and replaced with in-plan discussions.
NRC PDEP Observation The Plan should include a discussion of the emergency drill and exercise program, including a discussion of the types of drills and exercises to be' conducted, drill and exercise critiques and programs to correct identified deficiencies.
PGE Response i
Section 9.1, Drills and Exercises, was changed to address this observation.
The section now reads as follows.
t Periodic drills and exercises are conducted to develop, maintain and demonstrate emergency response capabilities and skills. A formal critique is conducted as part of the drill'or exercise.
Routine testing of Blue Band Radio communications is conducted in-accordance with the TNP Security Plan.
i The following drills and exercises are performed at the specified interval:
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9.1.1 - FIRE DRILL l
Fire drills are conducted in accordance with the TNP Fire Protection Plan.
9.1.2 - MEDICAL DRILL i
A medical drill conducted annually to test the ability of the ERO to respond to an injured and radiologically contaminated person.
Drill l
includes transport offsite by RRFD and patient assessment and initial care at St. John's Medical Center, i
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Trojan Nuclear Plant Document Control Desk.
Docket 50-344 September 23, 1993 License NPF-1 Attachment I
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Page 17 of 17 9.1.3 - ANNUAL EXERCISE An exercise is conducted annually to test the adequacy of timing-and content of implementing procedures and methods, test emergency equipment and communications networks, and ensure that ERO-personnel are familiar with their duties.
State and local government agencies may participate in the annual exercise.
l NRC PDEP Observation Add audits to Section 9.4, Corrective Actions.
PGE Response Section 9.4 was revised to read as follows; f
Responsible for taking actions necessary to correct items identified during training, drills, audits and/or exercises.
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NRC PDEP Observation Add Emergency Plan Implementing Procedures to Section 3.3, Related Plans and l
Procedures.
i PGE Response Item (6), TNP Emergency Plan Implementing Procedures (EPIPs) was added to-l Section ~ 1 i
HEC PDEP Observation Provide a statement regarding the' availability of backup communications equipment in case access to the Control Room'is lost.
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PGE Response l
The following statement was added to Section 8.1, Control Room Area.
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I offsite notifications can also be made via telephone from other locations within the Industrial Area.
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k Trr.ian Nuclear Polant Document Control Desk Docket 50-344 September 23, 1993 License NPF-1 Attacment II 38 Pages l
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