ML20082Q912
| ML20082Q912 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/30/1983 |
| From: | Matthews D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20079F427 | List:
|
| References | |
| FOIA-84-35, TASK-3.A.1.1, TASK-TM NUDOCS 8312120445 | |
| Download: ML20082Q912 (36) | |
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4 UNITED STATES i'
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WASHINGTON, D. C. 20555 V,,.
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MEAORAI40VM FOR:
GeorgeKnighton,Ch'ief Licensing Dranch f3 Division of Licerning 7,
Office of Nuclear Reactor Regulation ah FROM:
' David B. Matthews, Actifig Chief Emergency Preparedness Branch Division of Emergency Preparedness 5:-
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and Engineering Response Offica of Inspection.and Enforcement
SUBJECT:
EMERGENCY PREPAREDNESS INPUT FOR SHEAR 0H HARRIS SER Enclosed is our input to'the Shearon Ha~rris' Safety Evaluation Report, consisting of tha Emergency Plan Evaluation Re~ port. (EPER) and our responses'to the TMI Action Items concerning emergency preparedness.
Thi.s constitutes formal sub-mission of materiais transmitted. to the Project Manager on November 1-7, 1983.
This material was discussed with the applicant at a meeting on November 28, 1983, at which time CP&L committed to revising the plan as suggested.
Please direct any questions concerning this material to Jerry Simonds (X24870).
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- 9. add David B. Matthews, Acting Chief Emergency Preparedness Branch Division of Emergency Preparedness and Engineering Response Office of. Inspection and.nforcement
Enclosure:
Shearon Harris EPER 666 TMI Action Items p%
cc w/ encl.:
E. L. Jordan, IE J. G.'Partlow, IE S. A. Schwartz, IE C.. R. Van Niel, IE F. Kantor, IE '
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13.'3 Emergency Preparedness Evaluation 13.3.1 Introduction m
O-The Carolina Power and Light Company (CP&i..) (the applicant) filed with the NRC the Emergency Plan for the Shearon Harris Nuclear Power Plant (SHNPP) dated March 1983,.and Revision I of the plan dated September, 1983.
The 2 - acceptance criteria used as the bas,1s fbr ou'r review of the Emergency Plan are specified in Section 13.3, " Emergency P1a' nning,"_of the Standard Review Plan, HUREG-0800[ dated July 5981, and include the planning ::t:ndcrds of Section 50.47(b) of 10 CFR Part 50, the requirements of Appendix E to CFR Part 50, and the specific criteria,.of NUREG-0654/ FEMA-REP-1, Revision 1,
" Criteria of Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," dated November, 11980.
The criteria of NUREG-0654 have been endorsed in Regulatory Guide 1.101, Revision 2, " Emergency Planning and Preparedness for Nuclear Power Reactor," dated October 1981, and thus have the same status as a regulatory
_ guide.
Evaluation of the state of emergency preparedness for the SHNPP fEcility also involves the review of State and local radiological emergency response plans by the Federal Emergency Management Agency (FEMA).
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However, ao NRC or FEMA findings and determinations concerning the state of adequacy of offsite emergency preparedness are required prior to issuance of an operating licepse authorizing only fuel loading and low power operations up to 5% of rated' power.
The' findings and..determ'ina' tion of FEMA on the adequacy 6
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of the' State and local emergency response ~ plan's and tiie o'verall conclusion of the NRC on the state of emergency preparedness for the operation of Shearon P
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- Harris Nuclear Power Plant at power levels above 5% of rated power will be presented in a future supplement to this Safety Evaluation Report.
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Section 13.3.2 of this report lists each planning standard of 10 CFR Part 50.47(b) followed by an evaluation of the applicable portions of the Plan that relate principally to the particuTar standard.
Section 13.3.3 of this p-Nportprovidesthestaff'sconclusions.
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13.3.2 Evaluation of the Emergency Plan 1
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13.3.2.1 Assignment of Responsibility (Organization Control) l Standerd Priuary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the emergency planning zones'have b;en 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-l continuous basis.
2
Evaluation The plan identifi,es the various North Carolina State agencies who are expected to take part in the overall St, ate.,'respo' hse Eo "an edergency at SHNPP, with the c,
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Division of Emergency Management of the North Carol'iria, Department of Crime Control and Public Safety designated as the lead response agency within the r
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State Government.
The Radiation Protection Section of the Departnent of g;
Human Resources is the lead agency in the collection and analysis of radiation monitorinp repdfts and of-enviror.nienta-1 air, foliage, food, and water samples.
The plan ~also discusses the response expected of the-counties of Chatham, (Dept. of Emergency Operations), Harnett (Emergency Managenment Agency),
Sanford ~ Lee (Emergency Management Agencf), Rake (Emergency Management Agency) and the city of Raleigh.(Communications).
Federal agencies responding are b.....
Department of Energy-Savannah River Operations Office, Interagency Radiological Assistance Plan (IRAP), Federal Emergency Management Agency (FEl%), Nuclear Regulatory Commission (NRC), and the National Weather Service.
Other agencies identified are Southern liutual Radiological Assistance Plan (SMRAP) signatories, Institute of Nuclear Power Operation (INPO), Westinghouse, Daniel Construction i
Co., and EBASCO.
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The emergency response concept of operations is summarized in the SHNPP plan for each of the support organizations and the relationship to the total effort is suggested in Tab'le 4.0-1, Offsite Agency Support Summary, which gives primary and support responsibility for onsite and offsite functions. ' The only block diagram which includes the offsite support agencies is the Emergency Response Manager Organization which seems to be concerned mostly with details
of corporate organization.
The plan identifies the specific individual and his successors who shall be in charge of the emergency response.
The comu-nication links be, tween SHNPP, each of the counties, and State are identified as having,-24:.ho'ur~-per-day..mann,ingi-
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The plan includes written agreements with the Apex Volunteer Fire Department, the Holly Spring Rural Fire Department, Apex Rescue, Rex Hospital, an) the s.;
City of Raleigh Comunications Center.
The plan indicates that agreements are to be negotiated with Wake Memoria4. Hospital...N.C. Memorial Hospital,
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Chatham County Comunications Center, Lee County Comunications Center, Harnett County Comunications Center, and at least two doctors in the g-vicinity.
.TheplanspecifiesthattheSIt'5 Emergency Coordinator is responsible for~
assuring 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> functional continuity of the control room, the TSC, and the OSC when activated.
The Emergency Response Manager is responsible for managing and dirccting all emergency operations involving the facil.ity upon activation of the EOF.
The responsibilities and objectives of this position, and a description of his staff are contained in the Corporate Emergency Plan.
The following items require resolution:
1.
The plan identifies, in a general L.r the State, local, Federal, and private sector organizations, that are intended to be part of the overall response organization.
The plan should specifically identify-each organization, contact point, location, approximate response time after notification and who is the primary notification agent.
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2.
The interrelationship of these organzations with the applicant and with each other needs to be specified.
A block diagram should be used illustrpte these interrelationships.
3.
The plan mentions the Emergency Response Manager:,(ERM) who assumes overall responsibility for the response effort upon activation of u
n the EOF, and states that the ERM is a corporate person, instead of a plant person as are his EOF staff.
The plan further states that the corpofite' emerg'ency respdose organ.ization.and operatio s centers are discussed in the Corporate Emergency Plan.
Since the ERM and the EOF staff are so closely tied, operationally, to the plant emer-
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gency response effort, that por, tion' of 't'he Corporate Plan that describes the ERM.and.his staff should be included in the plant emergency p1an (summariz[d if necessary).
4.
Annex A of the plan lists 12 organizations with written agreements with the utility.
Only 5 written agreements are included.
The plan does not include agreements or signature pages for Federal response organizations (such as NRC, DOE, etc.) or industry organizations, y-
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13.3.2.2 On' site Emergency Organization Standard a.
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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 augmen-
, tation of responsive capabilities is available, and the interfaces among various onsite fes'ponse "activit'iei;and-offsite support and respodse activities
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are specified.
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Evalvation L
... n The Shift Foreman for Unit 1, or the Shift Operating Supervisor for Units 1 & 2 will assume the postion of Site Emergency Coordinator until relieved by the Plant General Manager, with authority to act on behalf of the company.
Upon activation of the EOF the Emergency Response Manager assumes the
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responsibility for overall emergency response, and the Site Emergency Coordinator concer.trates his activities ~on on-site response.
The Site Emergency Coordinator / Emergency Response M.anager will not delegate the responsibility to notify and recommend protective actions to offsite autho-rities.
The Site Emergency Coordinator may not delegate the responsibility to determine the classification of the emergency.
The duties and respon-sibilies of these two positions are clearly defined and the line of succession for each is specified in terms of normal staff positions.
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Station staff personnel have been assigned emergency positions with respon-sibilities and duties corrensurate with their normal activities.
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The on-shift emergency staff and the augmented emergency staff appear to comply with guidelines of Table B-1 of the Planning Standard, but contains ambiguities that, interfere with proper review of the plan.
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The fo'llowing items rcquire resolution:
1.
The transfer of authority from Shift, Foreman Site Emergency Coordinator (SEC) to the Plant General Manager (PGM) is not defined, and the transfer to the Emirge'ncy Response Mariager:.happens when the EOF is activated. The plan lacks sufficient detail of the necessary conditions to be met for transfer of any authority.
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The description of Table 2.'2-1 in the plan is ambiguous, in that
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it is described as " normal on-duty operating shift" and also as "the fully augmented plant emergency organization."
Tables 2.2-1 and I
2.2-2 should be revised to be more compatible with Table B-1 of '
y 3.
The plan does not have sufficient information to clearly identify the interfaces between and among the onsite functional areas of TSC, OSC, and near-site EOF, and the offsite support agencies of applicant head-quarters support, local services support, State and local government response agencies, and Federal response agencies.
Figures 2.2-1 and 2.4-1 and Table 4.0-1 should t,e revised as appropriate.
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13.3.2.3 Emergency Response Support and Resources Standard e
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A~r' rang'ements for req'uesting and effec..tively using assYsta*nce resources have
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been made, arrangements to accommodate State and local staff at the licensee's
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near-site emergency operations facility have been made, and other organiza-g.s tions capable of augmenting the plan response have been identified.
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i Evaluation Federal and State assistance will be requested by the Site Emergency C' ordinator or, when the EOF is activat'ed, by the Em.ergency Response Manager.
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The specific serv' ices to be p'r'oYided by IRAP via DOE-Savannah River Operations are given in detail, and travel times by air and auto from various depots are listed.
Resources available to support the Federal responses include the Raleigh-Durham Airport and space and communications facilities at the North Carolina Emergency Operations Center (NCEOC) in Raleigh to assist the IRAP teams to establish a command post and communications center.
c The plan provides a representative of CP&L to the State Emergency Response Team (SERT) Headquarters in Raleigh, and lists his duties and responsibilities.
The plan identified several fixed and mobile laboratories that are available for support of rediation monitoring and analysis eff0rts.
These laboratories are the on-site (SHNPP) laboratory, the Shearon Har'ris Energy and Environmental Center (SHEEC), the H. G. Robinson Plant near Hartsville, S.C., and the P
Brunswick Steam Electric Plant near Southport, N.C.
A mobile environmental
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monitoring laboratory installed in a van can be dispatched from SHEEC to perform environmental monitoring, and act as back-up to SHNPP labs.
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13.3.2.4 Emeraency Classification System s
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Standard a
A standard emergency classification and action level scheme, the bases of '
which include fac,ility system and effluent parameters, is in use by the nue. lear facility licensee, and. State anti local response plans call for reliance on information.provided by fac.ility" licensees for determinations
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of ninimum initiaY offsite re5pc~nse measures.
Evaluation The four standard emergency classes have been established by the applicant.
The Shift Foreman (Site. Emergency Coordinator) wi.11 declare any one of the r
four classes where, in his judgement, EALs have been exceeded or the status of the plant warrants such a declaration.
The plan states that EALs are specific sets of plant conditions, instrument readings, and events which correspond with the conditions associated with one of the four emergency classes.
The EALs are outlined in Fig. 4.1-1 of the plan, and will be detailed in the Plant Emergency Procedures (PEP's) including specific instrument readings, plant system and effluent parameters, and equipment status t
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indications characterstic of a spectrum of off-normal conditions and accidents corresponding to initiating conditions of each emergency class.
e The following iteins requires reshl'utuon':
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1.
The plan does not specify instrument readings, plant parameter values, or equipment status for the EAL's in each emergency class.
Thehlan states that this will be done in the PEP's. - This criterion will be eval-
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uated whenithe PEPs are rece.tveds -
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The plan should be revised to clearly indicate the function of the Shift
. Foreman's (or S.S.) judgement. in U1assffying an emergency where the status 2=..
and the trend of the plant warrant.If such declar.ation.
The predetermined
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set of EAL's are not sub[e'$t to judgements.
13.3.2.5 Notification Methods and Procedures
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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 the public have been established and means to provide early notification and clear instructions to the populace within the plume exposure pathway emergency planning zone have been established.
Evaluation The Site Emergency Coordinator (SEC), immediately upon declaring an emergency,
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activates the emergency pl,an ind.initia'tgs the' procedures for notification
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of'on-site eme'rgency' organization. 'The SEC also fill's'out the "Immediate
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Notification Form," contained in Annex F of the plan, and provides it to the Emergency Comunicator.
Using the Automatic Ring Down (ARD) phone, the
. _y Emergency Communicator will read the message simultaneously to all counties
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within the EPZ and the State warnt99 pqint within.15 minutes for all cer-gency classifications, except for the Unusual Event class which is one hour.
The. information to be reported.to the offsite agencies is predetermined by
.the use of the form in. Annex F and is,,i,n accordance with the guidelines of
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Thef'ormprovideEYorverificationoftheauthenticityofthe-message with code words and call-backs.
The SHNPP plan states that the North Carolina Emergency Response Plan (NCERP) will, when issued, describe procedures for State and local officials to make a public notification decision promptly (within about 15 minutes) on being informed by the plant of an emergency decision.
CP&L will-. provide the,. State and local governments with appropriate information necessary for a decision to be made co,ncerning public protection measures.
Public warning, when deemed necessary, will be accomplished as described in the NCERP.
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13.3.2.6 Emergency Comunications Standard
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- v P'rovis' ions exht for' prompt comunic'..a'tions amon' g pr'inc'ipal. response
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tions to emergency personnel and to the public.
su Evaluation u.
Primary and backup communications links will be provided with the Federal, State, and local emergency response organizations.
Provisions exist for
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24-hour per day notification to and actbati6n of these organizations.
Offsite comunications systems.inc.1,ude commgrc/a1 telephone private telephone lines, dedicated telephone lines, radi5 systems, and a mferowave system.
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Communications with the State and local governments will be tested monthly,
=and communications with Federal response organizations, the State and local emergency operations centers, and field monitoring teams will be tested annually as part of comunication dri-11s.
The plan provides for primary and backup telephone lines between the Control Room, TSC,_ EOF, and OSC; and. radio comunications (separate from plant radios) with the mobile and portable units of the Environmental Monitoring Teams; Rescue vehicles have mobile comunications with the Raleigh Comunication Center (RCC) and local hospitals.
SHNPP can comunicate with mobile medical units by phone line (911) to the RCC and via a phone patch to the mobile radio base-station.
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13.3.2.7 Public Information Standard n
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Information is'made available to the public o~n'a pe'rfo'dic basis on how they will be notified and what their initial actions should be in an emergency; the principal points of contact with the news media for dissemination of g
.s information during an emergency (including physical location or locations)
O-are established-in advance;.and procedures. for coordinated dissemination of information to the public are established.
Evaluation
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The North Carolin'a Department"of Crime Control and Public Safety, Division of Emergency Management, has cverall responsibility for maintaining a continuing disaster preparedness public ec'ucation program.
Such a program, prepared by the state of North Carolina, with the cooperation of local governments and CP&L, is intended to ensure that members of the public are:
(a)awareofthe potential threat of a radio.ogical emergency; (b) able to recognize radiological i
emergency notification; r.nd (c} knowledgeable of the proper, immediate actions (e.g., return to home, close windows, and turn on radio) to be taken.
This program includes education on protective actions to be taken if shelter is
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prescribed, and the general procedures to follow if an evacuation is required.
It also includes general education information of radiation and how to learn more about emergency preparedness.
This program will be described in the l
North Carolina Emergency Restonse Plan in Support of SHNPP.
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CP&L will conduct-a public information program for persons living in the plume exposure Emergency Planning Zone for SHNPP.
The program will be accom-plished by yearly, dissemination of brochures containing educational information on emergency preparedness. nuklear power _and radiation, and how to contact CPal
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(o'r moire information; establishment'.. --of an emer'genci phpa' redness Spea
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Bureau allowing qualified plant personnel to address civic, religious, social, and occupational organizations in the' SHNPP vicinity and preparation of news p
material for TV, radio, and the press and the general public.
Carolina Power
& Light Companyis working with-bqth State. and local governments 'to ensure that all public education efforts will be consistent and complementary.
Carolina Power & Light Company, the Public Information Staff of the State 5fnergency Response Team, and Public,Information Offi.ces of local government will jointly make available a'n'a*nnual program to acquaint the news media with the Plan, information concerning radiation, nuclear power plants, and official points of contact for releases of public information.
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-ihe following item requires resolution:
1, The plan provides for yearly distributYon educational brochures to the l-public, but a sample brochure is not provided with the plan.
A public information brochure should be provided for review.
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o 13.3.2.8 Emergency Facility and Eouipment Standard
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ency fscilities and equ. ipmentto'supp~ofEthitemergencyr
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Adequate emerg.
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are provided and maintained.
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ib in Evaluation Emergency facilities to support an emergency response have been establishe'd as fallows:
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- s The Control Room (,CR),contains thqse controls,, instruments, and communi-a.
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cations faci 11 ties necessar'y for' operation of the plant under both normal and emergency conditions.
The ventilation system, shielding, and structional integrity are designed to permit continuous occupancy during postulated accidents.
Storage is provided for food and water sufficient for seven days.
b.
The Technical Support Center (TSC) is Io'cated within the plant protected area in the Fuel Handling ~ Building approximately 400 feet walking distance from the CR., Traffic between TSC & CR is entirely within buildings equiped with HEPA and Chercoal filters, built to seismic Category I, tornado wind, and missile safety related criteria, with radiation pro-tection equivalent to the CR.
The TSC will have all the necessary equipment and supplies when fully functional to operate as the command center for,the Site Emergency Coordinator and his staff.
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The Operational Support Center (OSC) is located in the Service Building c.
inside the protected area and functions as an assembly and dispatch area for all emergency teams.
',t D-di-The Fmergency O'perations FaciTity'(EOF),'rs lofst'e'd i'n the Snearon Harris Emergency and Environmental Center ( SHEEC) approximately two miles from the plant with space for approximately 70 people including 10 NR'C personnel.
TheEOFisd'esignedtoIavethesamehabitabilityastheCR, and will.bg. provide 4 with inclustr_ia1. security te maintain ieadiness and
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to restrict access during'~an emergency.
The EOF is activated by the Emergency ResponIe Manager (ERM) when adequately staffed, to perform
,, off-site notificatio.n, eovironment'al monitoring, and dose protection.
The EOF has emergency equipment and supplies to perform as the comand
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center for the ERM with p' tant system drawings, 3 Emergency Respon'se -
Facility Information System (ERFIS) consoles displayin'g plant data, Safety Parameter Display System (SF05), Radiological Monitoring System k
(RMS), and dose projections, all pertinent emergency plans, te,lecop.ies, photocopies, and maps.
ThePlaitMediaCenterisalsolocated'TttheSHEEC. The Site Public e.
Information CooYdinator directs the activities of the Center to provide a controlled point of contact and physical l'ocation near the plant for the news media, and to provide immediate access to accurate emergency information generated by all involved agencies.
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The Corporate Emergency Operation Center (CEOC) and the Corpotate Headquarters Media Center are located at the Corporate Hea'dquarters and Civic Center in Raleigh, approximately 16 miles N.E. of SHNPP on 1
Highway 1.
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The North Carclina State Emergency Operations Center ( SEOC) is also b
located in Raleigh at the Division of Emergency Management HeadqI)arters, g,;
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The ERF's appeati to be ad.equately.; staffed,.and thg response timds designated for'the various staffing leve agree with the guidelines of Table B-1 of
!;UREG-0654.
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The ERF's were evaluated as interim facilities in accordance with applicable portion of 10 CFR'.50 and NUREG 46'54 and found to be adequate.
Applicant has, stated in a letter dated April 15, 1983 in response'to Generic Letter 82-33 that the final facilities will be completed prior to fuel load, after which time they will be evaluated in accordance with Supplement 1 to NUREG-0737.
The plan states that equipment and syst. ems for seismic monitoring, radiation monitoring, meteorological instrumentation, fire letection, gross failed fuel, loose parts monitoring, and security systems will be installed.
The plan further states that additional information can be found i.n noted sections of the FSAR.
A summary of the FSAR information should be included in the Emergency Plan to assist the emergency plan to stand as an independent document.
The fixed and mobile laboratory facilities available for support of SHNPP are discussed under Planning Standard C.-
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The Radiological Assessment Branch reports that they have reviewed applicant's radiological monitoring program, and they conclude that it meets the Branch Technical Positio,n.
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A permanent meteorological monitoring statiort contad,ing, wind speed, direction A
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and temperature differential instrumentation is located onsite.
Provision have been made to acquire back-up meteorological data from the National Weather Service at the Raleigh-Durham Airport, a first' order station operating
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24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day,.Meteoclog'ica-1 and Effluent Treatment Branch (METB) has reviewed the meteorological pr5 gram and reports that is satisfies the Planning Standard on an interim basis, and will be evaluated during the Emegency Pre-par.e,dness Implementation.Analy, sis.
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The plan provides' in the impl A 'ing procedures a resource list for Ihe -
inventory and calibration of slugency equipment and supplies.
The plan also specifies the frequency of inventory and the calibration.
The following items require resolution:
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1.
The plan does not indicate if arrangmiiifs have been made to obtain or have access to seismic and hydrologic data from offsite sources.
i 2.
The plan implies that the OSC has the capacity to handle assigned l
personnel and equipment but fails to address the subject. Table 3.1-1 does not indicate the availability of portable lighting or cameras in I
the OSC emergency supply kits.
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3.
The plan d6es not discuss in any detail which emergency facility will be established as the central point for receipt and analysis of all radio-logical samples.
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,t 13.3.2.g Accident Assessment 6
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Standard 1
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Adequate methods, systems, and equipment for assessing and monitoring actual
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or, potential offs,ite consequences of a radiological emergency are in use.
2 Evaluation
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The plan identifies the four emergency classes and discusses basic tests or criteria that must be considered in classifying the emergency, such as, radioactivity release, core damage, plant degradation.
Theclassificationoftb.eeventsis.i.mp,1,ementedphroughEmergencyAction
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Levels (EAL's'), which are specific sets of'pTant conditions, instrument readings, and events coinciding with the initiating conditions associated with one of the Emergency Classes. The EAL's are outline.d in Fig. 4.1-1, and will be discussed in detail in the Plant Emergency Procedures, including specific instrument readings, plant system and effluent parameters, and equipment status indications corresponding to the initiating conditions of 4
each emergency class.
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The plan provides the onsite capability and resources to provide-initial values and continuing assessment for the duration of an emergency such as the post accident sampling system (PASS) and radiation monitoring systems.
The details of these systems.,suc,h as, types,, rinses,: and location of monitors, a.
and the PASS are discussed in appropriate sections of the FSAK.
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Annex B of the plan describes the technical basis of the dose projection program, including calculation of Source Terms, Dose ' Conversion Factors,
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Atmospheric Disp,ersion, and.' assumptions.and limitations.
The methodology and techniques for determing sicurce terms and dose assessments will be de, tailed in Plant Emergency Pro'cedure 361.
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p-Meteorological data from the onsite stition is presented to the Control Room,
-the TSC, and the' EOF via comp'u'ter.
In case of offscale or inoperable instrumentation, the cross reference in Annex B refers to PEP 361.
There is no discussion of this contingency in the plan.
The plan provides Environmental Monitoring Teams that will be activated in V,
accordance with appropriate PEP's, e,guip.ed with company vehicles and sampling
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equipment, capable of tracking the plume, oblain ng and analyzing air samples,
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also sampling liquid effluents. The field monitoring equipment has the capability of measuring radiciodine in the vic0iity of the plant site as low I
as 5x10-8 u ci/cc.
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The following items require resolution:
1.
The capability and resources necessary to provide initial values and continuing assessment throughout an emergency are not adequately i
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descrbed or discussed in the plan.
A condensed version of the infor-mation in the FSAR should be included in the plan.
e 2.
The. plan f~ ails to identify t,he accys,s t,o gnsite meteorological data by
'. ". offsite kRC centers aiid a'pprop'riat'e State'.agen'ci.its', '.
3.
A discussion oflthe methods and techniques that will be used for deter-
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mining release r, ate dose projection if the requisite irstrumentation is offscale or inoperable should be. included.in the plan. '-
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4.
The plan should include the means of relating the various measured
. parameters and gross. activity measurements to the key isotopes listed
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in Table 3, page 18, fjuREG-0654.,
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V 13.3.2.10 Protective Response Standard l
F-A range of pr'Otective actions have been deveToped for the plume exposure j
pathway emergency planning zone for emergency workers and the public.
Guidelines for the choice of protective actions during an. emergency, con-sistent with Federal guidance, are developed and in place, and protective actions for the injestion exposure pathway emergency planning zone appro-priateto the locale have been developed.
t 21
Evaluation The plan establis,hes the means and times to alert and notify on-site personnel of an emergency,- and ident,1fies the ass'embif-aYeas adjacent to each of the e monNo' red foEcont5bilii5ti'on at the assembly gite houses.
Personnel w 1
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If it is necessary to evacuate further, evacuation routes and means of area.
transportation are identified.
Holding areas for additional decontamination s.
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will be identified if necessary.
Supervisors will account for all persons evacuated from-within the protected ars_a at; th'e as,sembly area ahd. report u--
missingpersonstoappropriatesupervisionwithin30 minutes.
Security search procedures will be implebnted to locate missing persons.
The plan pro.v, ides individual respi.ratory protecNon, protective clothing, and 3._
giHysician-supervised radioprotective dr,iigs for the emergency workers.
The applicant will pr'dvide the St' ate:and local governments with appropriake
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information necessary to make a decision concerning public protective measures.
The applicant will also provide an independent recommendation for protective actions for the population at risk based on the Protective p
Action Guides provided in Table 4.5-1 for plume exposure and Table 4.5-2 for injestion EPZ.
The.information in.these tables is consistant with EPA 520/1-75 b01 and FDA Guidelines on Con 6diInation of Human Food and
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Animal Feed.
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The plan provides for prompt notification of State and local authorities.upon declaration of an emergency.
Alerting, warning, and notification of the popu-lation-at-risk will be accomplished by sirens and supplemented by radio and television announcements, sound trucks, bullhorns, and knocking on doors.
l L
22
. Aircraft and patrol boats will alert people on Lake Jordan and the.SHNPP raain reservoir.
Public warning will be accomplished per the NCERP Uhen the State and local governments deem it appropriate.
--n O-THe pian incTudes a ' map showing loc'a'l emefgedcy plahYrig 2ones, population by zones, and evacuation routes, but does not show radiological sampling or monitoring potrits, or relocation and shelter areas.
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Applicant has committed to supplying the, evacuation time study liy December 31, 1983.
This study will be eva 9ated when it is received, and the results of the. staff.eview will be reported in a subsequent supplement to this report.
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Tne following items require resolution:
1.
The plan does not specify the method or time required to notify individuals within the applicants controlled area but outside the protected (fenced) area.
a 2.
The plan does not specify what methodology will be used to contir.uously l
l account'for onsite persennel after the lvacuation and initial account-l l
ability.
i 3.
The plan does not include Evacuation Time Estimates.
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'4.
The' plan does.not include radiological sampling and monitoring points.
l-A summary of the information contained in the FSAR should be provided in the plan.
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5.
The plan does not included me.ps showing relocation centers, and shelter a reas.
This criterion will be addressed in the NCERP information and should be in,corporated into the IHNPP plan when received.
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5.
The plan does not address the 'Nical drotfe'etiorISYier'ed by local residential units or other shelters.
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b-13.3.2.11 Radiological. Exposure : Control..
Standard e
Adans for controlling radi,ological expp.liures, in an emergency, are established I
for emergency wor'kers. The MEES for controlling radiological exposures shall include exposure guidelines consistent with Environmental Protect'on Agency Emergency Workers and Lifesaving Activity Protective Action Guides.
l Evaluation l
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L The plan provides for 3 radiation protectioE' program for controlling radio-l l
logical exposures in the event of an emergency.
Emergency exposure guidelines, consistent with EPA Emergency Workers and Lifesaving Activity Protective Action Guides, are specified for several categories of emerger.cy workers.
The plan specifies that the Plant General Manager or the Radiological Control Director may authorize emergency exposures in excess of 10 CFR 20 limits.
In their absence the Site Emergency Coordinator may grant such approval. 'The L
.lan provides for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day radiation safety controls to contain the
-.24
spread of loose' contamination and to monitor personnel exposure.
Dose records will be maintained automatically utilizing the computerized Radiological Information Management System (RIMS).
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N-Adtion levels for de'termining the need"for d'i,c'ontamiNitio'n are summarized in Table 4.6-1,of the plan from the Plant Operations Manual Procedure ERC-101.
f' The applicant will establish the means for radiological decontamina'ti'on of L...
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emergency personnel wounds, supplies, instruments, equipment, and for waste k_
. disposal in the.. Plant Emergency Pqocedyre.393.
The following items require resolution:
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1.
The plan does not contain the meth'odology for decontamination of
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supplies, in'struments, ah'd> equipment.
2.
The plan does not discuss the measures that will be taken to control access to potentially or actually contaminated onsite potable water. and fcod supplies.
3.
The plan' does not discuss provisions-f6Y extra clothing, and decontaminants suitable for th'e type of contamination expected, especially radiciodine contamination of the skin.
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13.3.2.12 Medical and Public Health Support Standard Arrangments are made'for medical se dices and~contastn'a'ted and injured
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individuals.
3 6
Evaluation
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The applicant has made arrangeinents, confirmed in writing, for a specially designated emergency area to be maintained in readiness at Rex Hospital for treatment of contaminated. pati.ents.., SNeuld' Rex Hospital be unavailable, Wike Memorial Hopital will., serve as, backup medical f cility (agreement to 3
benegotiatedin/ writing).
Fir' patients who have received large doses of.
radiation, the primary medical facility wiill be North Carolina Memorial Hospital.
The plan provides for f*rst aid teams, trained in Multi-media First Aid on all shifts, two first aid rooms, first aid kits, and additional equipment and. supplies.
The plan cantains a written agreement with' tee Apex Volunteer Rescue Squad l
for transportation of any patient including ones who may be contamined.
In cases not involving severe injury, a plant vehicle may be used to transport injured individuals.
Contaminated injured personnel will be accompanied to the medical facility by a member of the Personnel Protection and Decontami-nation Team.
26
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13.3.2.13.
Recovery and Reentry Planning and Postaccident Operations I
Standard e
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Gen. erat plans for rec ~overy and reentry are developea.'g;.
Evaluation
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The applicant has-developed. general plans.for reentry and reco ery, and specifies tha criteria to be used in deciding to de-escalate or terminate the emergency condition.
The plan describes the.reepyery organiz'ation including a block diagram, and I~
lists the personn'a'l and alteria't'es by position / title who are designated f6r.
the key positions.-
The plan states that notification of on-site and off-site organizations of the activation of the Recovery Organization will be initiated by the Emergency Response Manager and will follow plant emergency,. notification procedures.
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plan includes provisions for updating the total population exposure. in coope-i
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ration with the North Carolina Radiation Protection Section (RPS), Department cf Human Resources, who is the lead State agency in the collection and analysis
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of media monitoring.
The RPS will be assisted by personnel from SHNPP and ShEEC.
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The following item requiries resolution:
1.
The plan sho,uld expand and clarify the means for informing the response /
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support orgaMzations,'tha,t af,recov'ery ope'tation is to be initiated, and
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....r of any changes in the organizational structure that may occur.
m 13.3.2.14 Exercises and Drills
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Standa rd Per. iodic exercises are (will be) co.n... ducted tb evaluate major portions of w..
emergency response capabilities, per.jodic drills are (will be) conducted to develop and maintain key skill's','and deficiencies identified as a result df..
exercises or drills are (will be) corrected.
Evaluation The plan states that exercises that test the integrated capability of major
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response organizations and simulates the cffsite release of radioactive materials requiring response by'offsite authorities will be conducted annually.
The exercises will be critiqued by Federal and State evaluators / observers.
The. scenerio will be varied from year to year so that all major elements 'of the site, county and State plans and emergency organizations will be tested within' a 5 year period, and that once every six years an exercise will start between 6 p.m. and midnight, and another between midnight and 6 a.m.
Every fifth year the exercise will be expanded to involve the Federal response
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N Communications ilrills, fire drills; medical emergency drills, onsite and
.offsite radiological monitoring drills, health physics drills,' analysis of implant liquid sa,mples with actual clevaied radiation levels will be onducted.
The frequency o~f these d.ri,.11s,is.specif'i.ed in the. plan.
L.
The SHNPP plan states that the Corporate Emergency Plan Implementation Procedure, CEPIP-18, prescribes polices and procedures for drills and m
exercises.
CEPIP-18 states that exercises will be conducted in accordance with NRC and FEMA rules, that exercise.g. wil.1 be co.nducted under various
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weather conditions, and some unannounced, that the exercise scenerios will' be written to allow freeplay decisionmaking, and the rtesponsibility is assi.gned -for corrective actions.
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The following iteiii requiries Ms'ol'ution:
1.
-The SHNPP emergency plan should incorporate the information from CEPIP-18 in sufficient detail to allow evaluation of the specific plan.
13.3.2.15 Radiological Emergency Response Training Standard Radiological emergency response training is provided to those who may be called upon to assist in an emergency.
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Evaluation The Emergency Plap Training Program, as described in corporate Emergency Plan Implements. tion 'Pr'ocedures, 'CEP,EP.19,' as'tp_rei t}aihing of indiviuals who may
...y, be called on to assist in an emergency.
Initial train..ing and annual retraining is provided., Provisions have been made to train offsite response organizations such as hospital ambulances, police and fire personnel, who may be called
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,upon to provide assistance.
Training will include site access procedures and the identity by *positionYtitle of4the person in the SHNPP orga$ization who will control the suppport activitiy.
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The plan provides specialized-training-Tor ihdividuals assigned specific responsibilities in the emergency plan.,'such' as Red fross Multi-media training for first aid team memb'ers.
The followings items require resolution:
l 1.
The plan should incorporate the information from CEPIP-19 in sufficient detail to allow evaluation of the. plan.
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.2.
The Damage Control Teams, described in Section 2.4.4 of the SHNPP plan as part of the emergency organization are not listed as receiving any training in the SHNPP plan or in CEPIP-19.
The specific training and l
retraining needs for this group should be detailed in the plan.
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13.3.2.16 Res6cnsibility for t.'1e Planning Effort:
Development, Perodic Review, and Distribution of Emregency Plans, 9
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Standard.
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Responsibilities for plan development and review and for distribution of emergency plans are established and planners are properly trained.
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The plan provides training for the individuals responsibile for the emergency planning effort.
The Assistant to the 11ane General Manager is the SHNPP mergency Planning Coordin.ator, respon,iible for coordinating on-site and
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<=lected off-site' radiological'elergency response planning.
He is also rasponsible for coordinating with the Director of Emergency Preparedness of the Corporate. Technical Services Department the following planning functions:
Interface with Federal, State, county and local planners.
Revise and update the plan annually.
Coordinate the annual exercises and the periodic drills Identify off-site training needs and arrange for training to meet those needs.
Identify corrective actions following an exercise, assign responsibility for implementing those actions, specify a schedule for completion, and evaluating the results.
Negotiate and maintain agreements with response / support organization.
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The Emergency Planning Coordinator will coordinate the updating of'the emergency plan, PEP's and supporting agreements as needed, and review and certify them to be current on an annual basis.
Approved changes to the plan will be distritiut'ed in acgordjince with'the Bis'trib0 tion list contained in the g
Emergency phone listings and personnal listings as found in the PEP's, shall 5
be updated at least quarterly.
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Annex E of the plan contains a listing of Plant Emergency Procedures (PEP)'
and designates the plan section that each implement.
The supporting plans are. listed in Section 1.9.of the plan as; CP&L Corporate Emergency Plan, t
m NCERP, and NUREG-0728,,NRC., Incident, Response Plan.
The plan contains a detailed table of' contents, aid'il cross reference to the specific criterie..
of NUREG-0654.
The Corporate Quality Assurance Department will conduct an independent audit of the plan every year for conformance with 10 CFR 50.47, 10 CFR 50.54, and 10 CFR Appendix E.
Written reports of the findirigs of-these audits and reviews will be provided to corporate management.
Each i.
report will specifically. address the.. adequacy of interfaces with State and local governmer.ts, of drills and exercises, and of emergency response capabilities and procedures.
The reports will be retained for five years.
Corrective actions deemed necessary from the audit will be implemented in accordance with Section 5.1.2 of the plan.
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13.3.3 Conclusions Based on our revi,ew of the Shearon Harris fluclear Power Plant (SHNPP)
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Emergency, Plan fo'r conformance wi.th the':.specif'ic criteria in NUREG-0654/
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FtHA-RfP-1 which addresses each of the planning standifds'of Section 50.47(b) of 10 CFR Part 50, and with the requirements of Appendix E to 10 CFR Part 50, we conclude that the SHNPP Emergency Plan, upon satisfactory correction of
- g. w those items requiring resolution and those items requiring comm tment by
" = -
CP&L as identiffed in Section 13.322 ot this repor.t. will provide an adequate planning basis for an acceptab1e state of emergency preparedness.
2-After reviewing the findings and p,terminatibns made by FEMA on the adequacy of
- State and local emergengy r.esponse plaps, and after reviewing the revisions
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to the applicant's' Emergency PTan, a supplement to this report will provide.
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our overall conclusions as to whether the state of onsite and offsite emergency preparedness provides reasonable as.surance that adequate protective neasures can and will be taken in the event of the radiological emergency.
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9
TMI ACTION ITEss III.A.1.1 IMPROVING EMERGENCY PREPAREDN SS - SHORT TERM
..The ob".fecti,ve of this 'tasli was/ o pFomptly upgrade. licensee emergency 2.
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prep'redn'ess by requiring improvements in p1ans'and "p$c'ed'ures, facilities a
and equipment, and offsite support.
Guidance documents were developed,
. licensee emergency. plans were upgraded, and special NRC emergency plahning review o
J., teams visited each. site.
The' guidance to ~ emergency re'sponse organizations was completed with the issuance of NUREG-0654/ FEMA-REP 1 Revision'1.
Efforts t-under this item Gere superseded Qith the. issuance of the amended final rule on emerge'ncy planning, effective da'te November 3, 1980 (45 FR 55 402). This ' item is considered complete.
k.E-ILI.A'.1.2 QUPGRADENERGENCY SOPPORT!FACTLITI'ES
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Supplement 1, to NUREG-0737.,."Requir'ements for Emergency Response. Capability" issued via Generic' Letter No. 82-33, dated December 17, 1982, states that '
i the NRC will not conduct preimplementation reviews of emergency response-facilities (ERF's), and provides all licensees and applicants with the recuire-j-
ments and. guidance against which the ERF's will be evaluated in a postimolemen-tation appraisal, Generic letter No. 82-33 requ6sted that by April' l'5, i983, each licensee and applicant dev'elop and submit to.the NRC its own plant-specific..
.. sch:dule for completion o.f. the ERF's,. including a description of the plans for phased imolemehtation and integration of al1~emer$ency response activities.
Final staff evaluation.of the operational capability of completed ERF's (i.e.,
TSC, OSC,'and. EOF) will be conducted as part of the postimplementation review of emergency response.:apabilities against the requirements contained in L
Supplement 1 to NUREG-0737.
Accordingly, the schedule for.the postimplementation l
appraisal cf the ERF's will be ' established after these fa'cilities have been l
completed.
l-III,A,2vlfPRhlhkMERGENCYPREPAREDNESS'-~LONG' TERM i
The ob,jective of this item was for each nuclear facility licensee to upgrade its emergency planning effort in order to provide reasonable assurance that
' adequate protective measures con and will be taken in the event of a radiological
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emergency.
Performance of this task involved three phases:
(1,)submittalof upgraded emergency plans, consistent with the revised emergency planning regulations effective November 3,1980 and the guidance of NUPEG-0654, FEIM-RE.C 1, Revision 1; (2) s'utimittal.of'implenientin'g pro.ce'.dureis, and (3) implementation g
[,,of 'r,'adiological response plans." Parde'u189, einphasiif%.this task was given to the upgra,de of meteorological measurements capabilities.
The previous guidance on meteorology found in Appendix 2 to NUREG-0654 and in Revision 1 to Regulatory Guide 1.23 has.been superse_ded by Supple. ment 1 to NUREG.0737.
Review efforts under this task will be conducted in accordance with the
- 5 final rule on emergency planini,ng, the guidance in NUREG-0654, ahd Supplement 1 3
to NUREG-0737 The results of -this: review will be reported in'Section 13.3 of the SER.
The capability of iicensees to implement their emergency plan's will be assessed during an onsite appraisal as part of the preoperational insoection.
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