ML20101K408

Clarifies Items Pending,Per Sser 4,Section 13.3 & F Kantor Conversations.Facility Emergency Response Plan Revised Per NUREG-0654,delineating Goals of 30 & 60 Minute Staffing of Emergency Response Facility & Planning W/Local Authorities

ML20101K408
Person / Time
Site:	Fermi
Issue date:	12/17/1984
From:	Jens W DETROIT EDISON CO.
To:	Youngblood B Office of Nuclear Reactor Regulation
References
RTR-NUREG-0654, RTR-NUREG-0798, RTR-NUREG-654, RTR-NUREG-798 EF2-72034, NUDOCS 8412310347
Download: ML20101K408 (8)

Text

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W yne H. Jens Vice Present ,

Nucear Qwrato,s Formet 6400 North Dme Highway ISOn - (Newport, Mrhigan 48166 313l 386-4150 EF2-72034 December 17, 1984 Director of Nuclear Reactor Regulation Attention: Mr. B. J. Youngblood, Chief Licensing. Branch No. 1 Division of Licensing U. S. Nuclear Regulatory Commission

Reference:

(1) Fermi-2 NRC Docket No. 50-341

Subject:

Response to Section 13.3 of Supplement 4 to Safety Evaluation Report (NUREG-0798)

Subsequent to Detroit Edison's review of SSER 4 and conversations with Mr. F. Kantor (NRR-EPB), the following clarifications concerning the Fermi-2 emergency response program are provided for your review.

1) SSER 4, Section 13.3.2.2 .

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"In response, the applicant indicated in Section B.1.2.of Revision 2 to the Fermi-2 emergency' plan that it intends to comply with the 30-minute and 60-minute augmentation criteria of Table B-1 of NUREG-0654 as a goal in staffing the emergency response facilities."

Edison Response:

Section B.1.2 (Page B-2) of the Fermi-2 RERP Plan will be revised in Revision 4 to more clearly delineate Edison's commitment to the goal of 30 and 60 minute augmentation criteria of NUREG-0654 Attachment 1 reflects the planned revision which will read:

"During off hours under normal conditions, key positions (as listed in Table B-1) can be staffed within 30 minutes the majority of the time. There may be some cases, however, where up to 60 minutes may be required."

O B412310347 841217 PDR ADOCK 05000341 E PDR

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Mr. B. J._Youngblood December 17, 1984 '

'EF2-72034 Page 2

2) SSER 4, Section 13.3.2.5

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"We find that_the applicant has coordinated-planning efforts with offsite authorities and while.:Lt appears that the. capability exists for these authorities to make prompt. protective action decision to protect the public, we conclude that,this item is confirmatory pending further clarification from the applicant regarding the County's response procedures."

Edison Response:

Attachment 2 provides-an-excerpt from the Monroe County Nuclear Faci 11ty Procedures, Appendix 1, tb - reflects the requested clarification.

3) SSER 4 Section 13.3.2.10

" Based on our review of EP-545, and on the applicant's commitment-to revise the emergency plan to indicate that-PAR's are based on plant conditions as well as dose estimates, the staff finds that this item has been resolved.- We will confirm the applicants-implementation of this item in a future supplement to the SER."

Edison Response:

The Fermi-2 RERP Plan will be' revised to. reflect that' protective action recommendations will be based on "... meteorological conditions, projected potential or actual offsite doses, and/or plant conditions...". Attachment 3 reflects the planned revision of Appendix J of the RERP Plan to incorporate this clarification.

4) Issue: Lake Breeze Edison Response:

RERP Implementing Procedures EP-544, " Meteorological Data Assessment" .and EP-545, " Protective Action Recommendation Guide-lines", will be revised to include criteria for the. occurrence of a lake-breeze (e.g. April through October; daylight hours; A B, or C stability class; and wind direction from 57 through 168 degrees) and-the associated protective action recommendations should one occur during an emergency at Fermi-2.

Mr..B..J. Youngblood December 17, 1984 EF2-72034 Page 3 The above clarifications should. support the resolution of items pending from SSER 4 and recent conversations with the reviewer,

.Mr. Kantor.

Please direct any questions to Mr. O. K. Earle at (313) 586-4211.

Sincerely, f

ec: Mr. P. M. Byron

• Mr. F. Kantor*

)(f -

[44g Mr. M. D. Lynch * .

USNRC, Document Control Desk Uashington, D. C. 20555

• With attachments l

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FERMI-2 RERP PLAN ATTACHMENT 1 emergency classification. Nuclear Operations provides the majority of the personnel required to staff the organization.

Additional Detroit Edison personnel are called upon to provide  ;;

specific expertise as necessary (e.g., meteorologists).

During an emergency, the Emergency Response Organization is located in the Control Room and the three Emergency Response Facilities (ERFs) described in Section H: Operational Support Center (OSC), Technical Support Center (TSC), and Emergency Operations Facility (EOF). Responsibilities in the Control Room and TSC are assigned by the Emergency Director and in the EOF by the EOF Coordinator. The Emergency Officer has overall manage-ment responsibility for the Emergency Response Organization and for all assignments in the organization.

f The Emergency Response Organization is predefined by the Super-j visor, Radiological Emergency Response Preparedness (RERP).

{ Alternate assignments to various positions are specified to provide-timely, unambiguous staffing. Table B-1 shows the min-( imum staffing for the Fermi 2 Emergency Response Organization according to functional area, ERF, and emergency classification.

Table B-1 reflects Detroit Edison's intent to achieve the 30-minute and 60-minute augmentation times indicated in 3 NUREG-OoS4/ FEMA-REP-1 Table B-1 and in NUREG 0737 as a desirable goal for staffing the ERFs.

The key functional areas in Table B-1 of this section can be

! staffed within 30 minutes of the emergency classification during l3 during normal working hours. This is possible because the major-l

! ity of the key positions are staffed by personnel on-site, that l-j is, either in the plant or at the Nuclear Operations Center (NOC). usi... .f f Le.s., a the eemse. , 00 min ;m e 1. s.3. ired if l

f;r :::ffing f h:3 :::rg;;:y :::;:::: p::iti:::. .RERP leple-menting Procedure EP-291 puts all key TSC and OSC personnel on l

l standby at the Unusual Event classification and key EOF personnel on standby at the Alert classification. Should the emergency 00 Change

( Revision 3 - February 1984 During off hours under normal conditions, key h>dF positions (as listed in Table B-1) can be staffed Revision 3A - August 1984 within 30 minutes the majority of the time. There may be some cases, however, where up to 60 minutes may be required.

, . ATTACHMENT 2

64. Scenario - The hypothetical situation, frm start to finich, in an exercise which is the thene or basis upon which the cction or play of the exercise unfolds. .

( 65. Sheltering - Action taken by the public to take advantage of the protection against radiation exposure afforded by remaining indoors,;

away from doors and windows, during and following the passage of the radioactive plune. All doors and windows should be closed and ventilation systems turned off.

66. Site Area anergency - The third emergency classification level declared by the utility when as incident at a nuclear power plant threatens the uncontrolled release of radiation into the i M iate area of the plant.

67. Stand-by - Organizations or personnel are placed at a state of readiness. Personnel should be able to respond but can remain at work, home or wherever as long as they can easily be reached by telephone or radio. Personnel placed on stand-by should review their plans, responsibilities and procedures.

68. Thermoluminescent Dosimeters - A smil device used to naasure nuclear radiation, utilizing physical properties of the particular crystal of which it is made.

70. Transportation Staging Area - A designated location frczn which transportation resources are coordinated and/or dispatched.

71. Unmet Needs - rapabilities and/cr resources required to support

( energency operations but neither available to or provided for by Monroe County. Pre-& ' ermined unmet needs will be reported to the State in advance ard emergency-specific unnet needs will be reported to the State upon recognition.

72. Unusal Event, Notification of - Tim first level of emergency classificaticn, indicatireg potential degradation of plant safety levels.

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V. CCNCEPT OF OPERATIONS A. Inpl ing Proced

1. The Chairperson of the 2nroe County Board of Otanissioners (Chief Executive) is responsible for inplementing the necessary protective actions and for directing the disaster relief forces in the County. In the event of a nuclear incident where off-site releases have occurred resulting in a local emergency or there is the inninent threat thereof, he will declare a State of i Brergency, thereby fully activating the 2nroe County Energency Operations Plan. This is likely to occur only under the Site Area Brergency or General BTergency classes of incidents (refer r

BP-1-ll Rev. 10/84 t ( n l

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FERMI-2 RERP PLAN ATTACHMENT 3 Either method pro-inspection using the badge exchange system.

vides for accountability of all individuals within 30 minutes of #;

the start of an evacuation and continuously thereafter for all individuals remaining onsite. Accountability is performed by Nuclear Security in accordance with RERP leplementing Procedure EP-205-30.

The accountability of persons at the Visitors' and Training Centers is the responsibility of the guides who are escorting each group. Persons leaving the NOC and Fermi 1 are accounted for by their work supervisors. Asse= bled groups report to the senior person at each location.

J.3 RADIATION PROTECTION EOUIPMENT Adequate supplies of radiation protection equipment are maintained for

( persons remaining in or entering the Protected Area or the Emergency Response Facilities. This emergency equipment is listed in Health

( Ph>Jics Procedure 69.000.25 maintained and inspected per RERP Adcini-3 strative Procedure EPA-5 and Health Phy rics Procedure 69.000.25.

The Medical Department maintains adequate amounts of potassium iodide (KI), with the appropriate shelf life, to support the On-Site Emer-gency Response Orfanization for emergency situations at Fermi-2. The Emergency Director is responsible for reco= mending, authorizing the 3

use of KI by Detroit Edison personnel upon the authorization of the Detroit Edison Medical D.'. rector or delegate. Use and distribution of KI is outlined 'n Health Physics Procedure 69.000.11. Protective clothing and respiratory protection equipment are used as indicated by l

the Emergency Director (or delegate).

J.4 PROTECTIVE ACTIONS

' W In e nacleer e;ergency, en-estimate-is made er u,m rodistian deem dmt 7p. >ere est4aate aff.re.d pnpy1. tine groups -ey pne-ee< 117 - e - 4..e _ .

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Ls celled the projected peteetfel er prefect:d :::uci 4 ::. .^ pre:: -

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tive ection-is taken-to evefd ^* educe the efferer ef thfe projected J-5 Revision 3 - February 1984 Revision 3A - August 1984

TERM 1-2 RERP PLAN

, ATTACHMENT 3 dese. The Pretective-Aetien Osideline @AC) is a pr: determine 4-leve-1 cf p cj :t:d d::: t: individual: ir th: populatier thet-wassants .

taking pr;tectiv :: tion.

nrnp 91.n T re n t .~ n

• 4 n e, p e n ~ ,ane. F.P-545=is = a = gu id e-4er-the -Eme r gency Easponsa OKBanisatica for rece- ending pret::tiv: :: tic:: te c*:te end lece' eff-site energency re: pence egencie:. Freept ::tif-ication-of erargency eituatienr st: Fermi ~2~is made to7ederal, stete7 and--lece-1

...,4. 4. .,,.m ,i.--. me,w c.. 4-- n or ,w nrn* Pl= w nd-RERP I pir- eting Prc: dcre EP-299.

All such recommended actions taken off-site to protect the health and safety of the general public are the responsibility of the State of Michigan in conjunction with Federal and local emergency response 3

agencies.

( The Michigan Emergency Preparedness Plan (MEPP), the Monroe and Wayne Cout. ties Emergency Operations Plans and the Brownstown Township Plan 3

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desetite the provisions to implemert protective measures for the plume expost.re pathway EPZ for State and local e=ergency response personnel and th*- public. Provisions include the following:

o Maps showing evacuation routes, evacuation areas, relocation centers, and shelter areas.

o Maps showing the population distribution around the nuclear facility.

o Methods for notifying all segments of the transient and resident population.

o Means for protecting institutionalized or confined individuals whose mobility may be impaired.

J-6 Revision 3 - February 1984 Revision 3A - August 1984

' CHANGES T0 ATTACHMENT 3

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During'an emergency at Fermi-2, it may be'necessary to make protective action recommendations to Local and State offsite Emergency Response Organizations for the protection of the health and safety of the public.

RERP Implementing Procadure EP-545-is a guide for the Detroit Edison Emergency Response Organization to formulate protective action recommen .

.t dations. These recommendations are based on meteorological conditions, A' projected potential or actual offsite doses, and/or plant conditions 1

such as fuel clad failure or core melt that indicate release of radioactivity may occur.. These recommendations are based on pre-determined levels of projected offsite dose or. plant status-that warrant taking protective actions.

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