ML20084E430

Forwards Rev 3 to Emergency Plan for Perry Nuclear Power Plant, Including Mods Resulting from NRC Comments Outlined in Sser 4.Certificate of Svc Encl

ML20084E430
Person / Time
Site:	Perry
Issue date:	04/28/1984
From:	Edelman M CLEVELAND ELECTRIC ILLUMINATING CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20084E433	List: ML20084E430
References
NUDOCS 8405020276
Download: ML20084E430 (14)

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P.O BOX 5000 - CLEVELAND, OHIO 44101 - TELEPHONE (216) 622-9800 - ILLUMINATING BLDO - 55 PUBLIC SQUARE Serving The Best Location on the Nation MURRAY R. EDELMAN VICE F.1ESIDENT NUCLE A R April 28, 1984 PY-CEl/NRR-0105 L tir. Ila rold R. Denton Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555 Perry Nuclear Power Plant Do c.ke t Nos. 50-440; 50-441 Emergency Plan-0!!-ISA Revision 3

Dear Mr. Denton:

Enclosed are three (3) signed originals and thirteen (13) copies of the revised chapters of the Perry Nuclear Power Plant Emergency Plan, CEl Report No.

Ort-I S A . This revision includes the modifications which resulted from the NRC review comments as outlined in SER Supplement 4, section 13. (See also January 11, 1984 and January 17, 1984 !;RC letters forwarding staff comments on the Emergency Plan.) A cross-reference between the SER comments and the PNPP responses is attached. This submittal should resolve all of the concerns expressed in the SER supplement.

The enclosed pages replace in entirety those currently in the plan. This revision is in a format designed to keep current the license application and the Emergency Plan.

Very truly yours, Murray R. Edelman Vice President Nuclear Group MRE:kay Enclosures cc: Jay Silberg, Esq.

John Stefano [

Max Gildner p 8405020276 840428 PDR ADOCK 05000440 F PDR

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1 Murray R. Edelm d who, being duly sworn, deposed and said that (1) he is Vice President, Nuclear Group of The Cleveland Electric Illuminating Company, (2) he is duly authorized to execute and file this report on behalf of The Cleveland Electric Illuminating Company and as duly authorized agent for Duquesne Light Company, Ohio Edison Company, Pennsylvania Power Company and the Toledo Edison Company, and (3) the statements set forth therein are true and correct to the best of his knowledge, information and belief.

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MurrayVR. Edelman 4

Sworn to and subscribed before me, this f fM day of ,

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UNITED STATES OF AMERICA ,

NUCLEAR REGULATORY COMMISSION l

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In the Matter of Duquesne Light Company, Ohio Edison Company, Pennsylvania Power Company, The Cleveland Electric Illuminating Company The Toledo Edison Company, Perry Nuclear Power Plant, Units 1 & 2 Docket Nos. 50-440 and 50-441

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CERTIFICATION OF SERVICE This is to certify that a copy of_ Revision No. 3 to the Emergency Plan, CEI Repo~rt No. OM-15A for Perry Nuclear Power Plant, Units 1 and 2, dated April 28, 1984, has been served on the following Federal, State and Local Officials, by deposit in the United States Mail, addressed as follows:

Federal Activities Branch

• Honorable Robert V. Orosz, Mayor U.S. Environmental Protection. Agency Village of North Perry Region V Off, ice North Perry Village' Hall 230. South Dehrborn Street 4778 Lockwood Road Chicago, Illinois 60604 North Perry Village, Ohio 44081 Ohio Department of Health Mr. Arthur Warren, Chairman Attn: Radiological Health Program Perry Township Board of Trustees Directory 4169 Main Street

,P.O. Box 118 Perry, Ohio 44081 Columbus, Ohio 43216 Honorable Laurence Logan, Mayor Village of Perry 4203 Harper Street Perry, Ohio 44081 s

Mr. Jim Williams Mr. Dale Wedge, Director Nuc1 car Preparedness Officer Geauga County Disaster Services State of Ohio Disaster Service's Agency Agency ODSA, Adjutant General Department 13281 Painesville-Ravenna Road 2825 West Granville Road Geauga County Safety Center Worthington, Ohio 43085 Chardon, Ohio 44024~

Mr. Michael Wheeler, Emergency Coordinator Al Stewart, Director Ashtabula County Disaster Services Agency Lake County Disaster Services 25 West Jefferson Agency .

Jefferson, Ohio 44047 39 Fairdale Street Painesville, Ohio 44077 s

. ,h Murray R. Ed'elman

, Vice President

• Nuclear Group i .

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CROSS-REFERENCE BET 11EEN SER SUPPLEMENT 4 COfEENTS AND PNPP EMERGENCY PLAN SER Supplement 4 Comment PNPP Plan Section

'13.3.2.2 (1) -

Table 5-1; *

(2) 5.2.2.4; 6.1.3 - '

(3) 5.2.2.1; 5.2.2.3; 5.2.2.4 (4) 5.~2.1 ; 5.2.2.1 ; 5.2.2.3 ; 5.2.2.4 ; 6.1.2 13.3.2.3 (1 ) 5.4.4 (2) 7.3 9 .

(3) 7.3.9 13.3.2.4 (1) Table 4-1; *

(2) ,

8.2 (3) 4.1.4; 6.4.3;

• 13.3.2.5 (1) 6.4.2

-(2) -

7.2.5 s

13.3.2.6 (1) 7.2.2; Figure 7-6 (2) 7.2.2.8 13.3.2.7 (1) 8.4.1.1 (2) .

..- 7.1.4 ,

13.3.2.8 (1) 5.2.3 (2) Appendix C; 8.3; *

(3) 7.3.7

. (4)

• 13.3.2.9 (1) 5.2.2.4; Table 5-1 13.2.2.10 (1) 6.4.1 ; Figure 6-7 (2) 6.5.3; AK:endix C; 6.4.1

. (3) ,

13.3.2.11 (1 ) 6.5.1 (2) 6.5.3 ; 4.4.4.1 ; Appendix C 13.3.2.12 (1) 5.3.3.2; 5.3.3.3;

• o (2) 6.5.3; 8.1.3 13.3.2.14 (1) -

8.5.4.2' (2) <

8.5.4.1 (3) 8.5.4.3;

• 13.3.2.15 (1 ) 8.1.3 13.3.2.16 (1) 8.2-(2) 8.2;

(3) Appendix F

• Clarification is provided~in attached pages.

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13.3.2.2 Onsits Emergsney organization ,

(1) The applicant's concept of augmented shift staffing, with respect to health physics capibilities, is not consistent with the guidance found in Table 2 of Supplement 1 of NUREG-0737. The applicant should either change their concept to be consistent with the guidance or provide alternative means for achieving the goals set forth in the guidance.

RESPONSE

, Table 5-1 of the PNPP Emergency Plan has been revised to be consis-tent with the guidance found in Table 2 of Supplement 1 of NUREG-0737. One area where this may still not appear clear is Radio 18egi- .

cal . Accident Assessment. The 60 minute column of Table 5-1 indi-cates that the Chemistry Unit Supervisor will be fulfilling this function. This is because at PNPP, the Chemistry Unit is respon-sible for routine offsite dose assessment instead of Health Physics as is the case at most other plants. Therefore, in keeping with the policy of assigning responsibilities during an emergency to

. reflect normal functions, the Chemistry Unit Supervisor will ter- -

form emergency dose assessment.

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13.3.2.4 Emergency Classification System (1) The plan should incorporate into the PNPP.emer6ency classification scheme the comments forwarded to the applicant (Youngblood:

January 11, 1984). .

P.ESPONSE The comments forwarded in Youngblood: January 11, 1984 have been addressed on Table 4-1 of the PNPP Emergency Plan with the exception of the comment on Site Area Emergency initiating condition

• 15b. This was not incorporated because the location of PNPP and

. the design of the intake structure preclude the sensitivity'to low lake level that may be true at other coastal sites.

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l 13.3.2.4 Emergency Classification System ,

(3) Protective action recommendations based on the potential for release of radioactive materials should be more thoroughly discussed in the plan. Specifically, the plan should discuss: (1) other non-radiological means of core status determination; (2) the relation-ship between gap activity and percent failed fuel as it relates to protective action recommendations; and (3) how the core status

- graph found in Figure 4-1 of the plan will be used in the emergency-action level scheme.

RESPONSE

Protective action recommendations based on the potential for a' release are more thoroughly discussed in Sections 4.1.4 and 6.4.3 of the Emergency Plan. Specifically these discuss!.ons relate the curves of Figure 4-1, which provide indication of bap activity and percent f ailed fuel, to specific protective action recommendations.

NOTE TO REVIEWERS: .

Part (1) of this finding has been withdrawn by the NRC (See Young-blood: February 29, 1984).

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13.3.2.8 Emergency Facilities and Equipment ,

(2) The plan should indicate that emergency equipment and supplies will be available in the Control Room. Further, calibration frequency for emergency equipment should be specified, and the plan ~

should indicate that instruments removed from service will be replaced with a comparable instrument.

RESPONSE

Emergency equipment and supplies available in the Control htoom are discussed in App:.ndix C of the PNPP Emergency Plan and Section 8.3 of the PNPP Emergency Plan discusses calibration of emergency instrpment s.

• NOTE TO REVIEWER:

The request for specification of calibration frequency has been withdrawn by the NRC (See Youngblood: February 29, 1984).

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13.3.2.8 Emergency Facilities and Equipment (4) The applicant should provide a commitment that the permanent emer-gency response facilities and equipment will be' operational prior to fuel loading, or that adequate interim facilities and capabilities .

will be in place.

. RESPONSE .

Commitments regarding the completion of emergency response f acilities were provided in CEI Letter PY-CEI/NRR-0032L of' April, 15 1983 from M. R. Edelman to B. J. Youngblood in response to Generic Letter 82-33.

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13.3.2.10 Protective Response ,

(3) The evacuation ti=e estimate study should address the effects of adverse weather (i.e., a thunderstorm) on a Summer Sunday evacua-tion. Also, the plan should indicate that the evacuation time estimates have been reviewed by the appropriate State and local officials.

RESPONSE

The evacuation time estimate study for PNPP has been reevaluated.

The most recent draft of this new study is included as Appendix D to the PNPP Emergency Plan. This draft is currently being reviewed

with State and local officials and a letter of concurrence is expected from each. This draf t study is being submitted at this time to allow adequate time for staff reviews. We expect only minor changes to occur between this draft and the final.

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l 13.3.2.12 Medical and Public Health Support ,

i (1) A letter of agreement with the Northwestern Memorial Hospital should be included'in the plan. .

RESPONSE

Section 5.3.3.2 has been revised to clarify the point that the -

agreement with Northwestern Memorial Hospital is made by Radiation Management Corporation and not by PNPP. Section 5.3.3.3 indicates that PNPP mintains. an agreement with Radiation Managen.ent Corpora-tion for emergency medical assistance.

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1 13.3.2.14 Exercises and Drills (3) The plan should indicate that part of each communication drill will involve evaluating'the aspect of understanding the contents of the message. -

RESPONSE

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Section 8.5.4.3 has been revised to indicate that the ability of emergency response personnel to understand and transfer me.ssages over the various communication systems will be evaluated during the Annual Emergency Plan Exercise rather than during each com-munication drill. The PNPP interpretation of the more frequent commu,nications tests is that these tests are to ensure opera *uility of the systems not to evaluate eersonnel performance.

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1 13.3.2.16 Responsibility for the Planning Effort: Development,

• Periodic Review, and Distribution of Emergency Plans (2) The administrative procedures used to revise and update the Emergency Plan and implementing procedures should be described in more detail. Particularly, the plan should ' indicate that revised pages are dated and marked to show where changes have been made.

RESPONSE

Section 8.2 has been revised to provide more detail on ' revisions and updates to the Emergency. Plan and implementing instructions.

The PNFP Administrative Procedures provide for pages to carry a revision number and indication of where changes were made s in'that revision by side bar. The date of revision is indicated o'n the title page.

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