ML20132E128

Forwards Results of Review & Evaluation of Adequacy of Emergency Plan Through Rev 7 & Commitments in . Upon Completion of Identified Items,Emergency Plan Will Meet Requirements of 10CFR50 & App E

ML20132E128
Person / Time
Site:	Hope Creek
Issue date:	07/17/1985
From:	Butler W Office of Nuclear Reactor Regulation
To:	Mittl R Public Service Enterprise Group
References
NUDOCS 8508010690
Download: ML20132E128 (24)

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4 UNITED STATES l Ej3 (g NUCLEAR REGULATORY COMMISSION i 3 J' \ /1 8 WASHING TON, D. C. 20555 e, Y'

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i Docket No. 50-354 i Mr. R. L. tiitti, General Manager

Nuclear Assurance and Regulation i Public Service Electric & Gas Company

! P. O. Box 570, T22A tiewerk, New Jersey 07101

SUBJECT:

HOPE CREEK EMERGEliCY PLAN The Hope Creek Safety Evaluation Report (SER) issued in October 1984 provided the statf's review and evaluation of the Hope Creek energency plan through Revision 4. In the SER, the staff identified a number of open and confirmator'y i teras . In response to the emergency plan deficiencies identified in the SER, PSE&G submitted Revisions 5 through 7 to the plan. Certain changes incorporatt.d by these revisions were discussed with PSE&G ouring an onsite visit on May 17. 19PE.

During this visit, PSE&G ccnciitted to provide inforTaation/ clarification requested by the staff. Those conunittents were confirmed in your letter of h6) OC,1905.

The staff has completed its review and evaluation of the adequacy of the I!cpe j Creek en;ergency plan (through Revision 7) and the cor.saltments in your hay 30, 1985 letter. The results of this evaluation are provided in the Enclosure.

The staff's findings are discussed under the same headirSs arid nurcbering system l used in the SER. Section 13.3.3 provides a status update on the Federal Ener-i gency Management Agency's (fella) report on the state of offsite trcrpncy j planning and preparedness. Section 13.3.4 provides the staff's conc.LLitt.s.

c 3 On the basis of our review of the onsite plan, we conclude that upon satisfer-

tory completion of the items conmitted to by PSE&G as idelitified in fection l 13.3.2 of the Enclosure, the llope Creek emergency plan will provide an adequate j planning basis for an acceptable state of unsite crtrcercy preparedness and will meet the requirements of 10 CFR 50 and Appendix E thereto. The stLff will l

confirm that PSE&G has complied with its corinittrents in a future supplerent to i the SER following a review of the revisions to the llope Creek emergency plon.

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F h Ab $ 354 PH 2 . ,

UUL 171985 FEMA has advised the staff that a complete offsite plan finding based on revised New Jersey State plans and an evaluation of the April 1985 offsite ru.iedial exercise will be furnished to the NRC by September 15,19ES. After reviewing the findings and determinations made by FEltA on the adequacy of state and local energency response plans, a supplement to the SER will provide the staff's overall conclusions on the adequacy of emergency preparedness for Hope Creek prior to authorization for operation above five percent of rated power.

Sincerely, Mainel signed by:

L! alter R. Butler, Chief Licensing Branch ha. 2 Division of Licensing

Enclosure:

As stated cc: See next page DISTRIBUTION Docket-File NRC PDR Local PDR PRC System NSIC LBf2 Peading EHylton D\lagner Dewey, OELD ACRS (16)

JPartlow BGrimes EJordan DPerrotti 1

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-1.Ciz. /Uht LB#2/bl/BC Dt!agner:lb WButler 07/g85 07/yE5

c FEF.A has advised the staff that a complete offsite plan finding based on revised New Jersey State plans and an evaluation of the April 1985 offsite remedial exercise will be furnished to the NRC by September 15, 1985. After reviewing the findings and determinations made by FEMA on the adecuacy of state and local emergency response plans, a supplement to the SER will provide the staff's overall conclusions on the adequacy of emergercy preparedness for liepe Creek prior to authorizaticn for operation above five percent of rated pcwer.

_ Sincerely, Walter R. Butler, Chief Licensing Branch No. 2 Division of Licensing

Enclosure:

As stated cc: See next page i

fir. R. L. liitti Public Service Electric & Gas Co. Mcpe Creek Generating Station cc:

Crcgcry Finor Susan C. Remis Richard Hubbard Division of Public Interest Advocacy Dale Bridenbaugh New Jersey State Department of IHB Technical Associates the Public Advocote 1723 Hamilton Avenue, Suite K Richard J. Hughes Justice Comples San Jose, California 95125 CN-850 Trenton, llew Jersey 08625 Troy B. Conner, Jr. Esquire Office of Legal Counsel Conner & Wetterhahn Department of Natural 1:esvLrces 1747 Pennsylvania Avenue N.W. ar.d Environmental Control

Washir.gton, D.C. 20006 89 Kings Highway j P.O. Box 1401 Dover, Delaware 19903 Richard Fryling, Jr., Esquire Mr. K. W. Currowes, Project Engineer i Asscciate General Solicitor Cechtel Peter Corporation i Ptblic Service Electric & Gas Ccrpany 50 Beale Street P. O. Box 570 T5E P. O. Box 3965 Newark, New Jersey 07101 San Francisco, Calitcrr iu E4119 Mr. J. M. Ashley

, Residert Inspector Senior Licensins Er,91neer U.S.N.R.C. c/o Public Service Electric & Oas Co.

P. O. Box 241 Bethesda Office Ccnter, Suit 550 Hancocks bridge, New Jersey 08038 4520 East-West Highway Bethesco , l'aryland 20814 Richard F. Engel Deputy Attorr.ey General Mr. A. E. Giardinc Divisicn of Law I:anaSer - Quality Assur6r ce EcC Environmental Protection Section Public Service Electric & Get Cr.

Richard J. bughes Justice Complex P. O. Box A Cli-112P Honcocks Eridcr.. Few Jersey 08038

- Trentcn,liew Jersey 08625 fir. Robert J. Touhey,  !!r. Anthcny J. Pietrofittu Acting Director bener al llanager DrikEC - Livisicn cf Pcwer Production Engineerti.9 Envircr.rtrital Control Atlantic Electric 89 Kings Highway 1199 Cluck horse Fike P. O. Box 1401 Plcesantville, liew Jersey Ob23%

Dover, Delewcre 1 % 03 kegional Administretot, I. trier I I Nr. k. S. Salvesen L. S. huclear Peculatory Commissict General Itcnacer-Hope Creek Operation 631 Pork 8ser.ue l Public Service Electric & Gas Co. Kinc cf Prussia, Per.nsylvania 19400 i P.O. Bux A l Hancccks Bridcr., i:rw Jersey 08038 l

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Public Service Electric & Gas Co. Hope Creek Generating Station cc:

Mr. 6. A. Preston Project Licensing Manager Public Service Electric & Gas Co.

P. O. Box 570 T22A Newark, New Jersey 07101 Ms. Rebecca Green

, New Jersey Bureau of Raciation Protection 360 Scotch Road Trenton, New Jersey 08628

Enclosure e

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13.3 Emergency Plan 13.3.1 Background The SER issued October 1984 provided the staff's review and evaluation of the Hope Creek Generating Station radiological emergency response plan (plan) through Revision 4 submitted by letter dated September 12, 1984. In the SER, the staff identified an open item and confirmatory items for which the appli-cant had made connitments, but had not yet revised the plan. In response to the SER, the applicant submitted R9 vision 5 to the plan on November 9,1984, Revision 6 on January 16, 1985 and Revision 7 on April 4, 1985 which resolved some of the confirmatory items. Certain changes, to the plan incorporated by

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Revisions 5, 6 and 7 were discussed with the appkicant during an onsite visit on May,17, 1985. The applicant committed to provide information/ clarification requested by the staff during that meeting . The applicant confirmed these commitments in a letter dated May 30, 1985, and the staff has included two new

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confirmatory items related to these commitments in this SSER.

1 The staff has completed its review and evaluation of the adequacy of the applicant's plan (through Revision 7) and the applicant's commitments in correspondence dated May 30, 1985. The results of this evaluation are given in Section 13.3.2 below. The staff's findings are discussed under the same headings and numbering system used in the SER. Section 13.3.3 provides a 4 status update on the Federal Emergency Management Agency's (FEMA) report on the state of offsite emergency planning and preparedness. Section 13.3.4 provides the staff's conclusions. - *

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] 2-i 13.3.2. Evaluation of the Emergency (Onsite) Plan 13.3.2.1 Assignment of Responsibility (Organizational Control)

Confirmatory Item 1 i

The staff will rely on FEMA's evaluation of offsite plans to ensure that Hope

Creek is incorporated into the states' plans for the plume and ingestion i

Emergency Planning Zones (EPZs).

1 Evaluation 5 FEMA's evaluation of the status of offsite plans is discussed in Section 13.3.3 i of this supplement. This confirmatory item is closed. Updates on FEMA's evalu-l ation of offsite plans will be discussed in Section 13.3 of future supplements to this report.

i 1 Confirmatory Item 2 1 .

i The matter of finalizing the draft and interim letters of agreement with the i

agencies / individuals identified in Attachment 2-1 to the plan is confirmatory. l

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1 1 The agreement letters have not been finalized. This matter remains confirmatory.

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t 13.3.2.3 Emergency Response Support and Resources Confirmatory Item Section 4.4.2 of the plan specifies that the emergency response capabilities of the General Electric Company will be provided later.

Evaluation .

f The applicant has not provided this information. This matter remains confirmatory.

13.3.2.4 Emergency Classification System I

Confirmatory Item The matter of the Event Classification Guide (ECG) is confirmatory, and the staff will ensure that the ECG is completed before fuel loading, currently l

projected for December 1985.  !

Evaluation The applicant's ECG (Section 5.0 of the plan, Rev. 2 January 11,1985)was submitted by Revision 6 to the plan. Minor changes were made to the ECG by Revision 7 to the plan. The staff has completed its review and evaluation of the ECG, Rev. 2 dated January 11, 1985 and finds that additional information

i and clarification are required before the staff can make a finding that the, ',

l emergency action levels contained in the ECG meet the guidance criteria,0ff ,

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l Appendix 1 to NUREG-0654 The staff has requested the applicant to furnish the additional information and clarification. Following its review of the revised ECG, the staff will provide its evaluation of the ECG in a future supplement to 1 this report. This matter remains confirmatory.

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13.3.2.5 Notification Methods and Procedure,s ',  ;

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Confirmatory item 1 The applicant is required to submit the emergency plen implementing procedures F ,

for staff review at least 180 days before the scheduled issuance of an operat-ing license.

Evaluation The applicant submitted the emergency plan implementing procedures on' Jane 3, 1985. The procedures will be reviewed during the onsite appraisal in August 1985. The staff finds this portion of the applicant's plan adeounte. / ^

Confirmatory item 2 i

The applicant briefly described an emergency broadcast system (EBS) manuti and committed to reference the manual in the plan. This matter is confirmatory, g l .

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l Section 6.0 (Rev. 5, dated April 1, 1985) to the plan contains a reference to the EB5 manual developed by the States of Delaware and New Jersey for broad-casting information on predetermined emergency responses to the public. The s

staff finds this portion of the applicant's plan adequate.

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/'P j d Confirmatory item '

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Comunication links with the NRC will consist of dedicated lines. The location of these lines will be determined at a later date. A description of the Hope Creek internal comunication system will be provided by December 1984. This matter'is confirmatory. ,

Evaluation

. Section 7.0 (Rev. 3, dated October 31,1984) of the plan describes the Hope Creek internal communicatica and alarm systems. The description includes an ala.,n system consisting of fire, radiation alert, and evacuation (reactor

'.  ! building, refueling floor and emergency diesel room) alarms, station public l

address (PA) system,stationtelephonesystem,andstationradiosystem. The site radiation alert alarm will be broadcast throughout the site by the PA

, ' system. The alarm has a manual suppress feature used to lower the alarm volume

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after about 15 seconds, so that further information or instructions may be broadcast on the PA system regarding special measures that may be necessary for site personnel. If evacuation from the site or certain buildings onsite becomes necessary, appropriate instructions will be broadcast. Evacuation alarms sounding in the reactor building, refueling floor or emergency diesel room call for an immediate evacuation of that area.

The station telephone system is a conventional system for use by station personnel in making calls within and outside the station. Two independent telephone cables will have backup power by batteries located onsite. The control room will have a direct telephone line to the load dispatching center at the company headquarters in Newark. A separate, microwave telephone system will back up the conventional telephone system. This system will be located at key points throughout the station and at the emergency operations facility (E0F)..

The station radio system is a multi-frequency security radio system. When an emergency event is declared, one specific frequency is assigned for emergency comunications between the control room, technical support center (TSC), EOF, and onsite and offsite radiation monitoring teams.

The plan specifies that direct comunication to the NRC will be located in the control room, TSC and E0F. l The staff finds this portion of the applicant's plan adequate.

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13.3.2.7 public Information Confirmatory Item The applicant furnished the staff with a sample public information brochure and informed the staff that the final brochure would be provided in mid-1985. In a letter dated September 12, 1984, the applicant committed to provide the final brochure to the local population as outlined in the plan. This matter is confi rmatory.

Evaluation The final brochure has not been submitted for review. This matter remains confi rmatory.

13.3.2.8 Emergency Facilities and Equipment Confirmatory Item 1 In its January 31, 1984 submittal, the applicant stated that the Operations Support Center (OSC) and TSC are under construction, and as information on these facilities becomes available, it will be incorporated into the plan.

This matter is confirmatory.

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Evaluation A detailed discussion of the OSC and TSC has not been incorporated into the plan. This matter remains confirmatory.

Confirmatory Item 2 In the January 31, 1984 response to the staff's request for additional informa-tion on onsite monitoring systems used to initiate emergency measures and for conducting assessment, the applicant stated that the plan will be updated as information becomes available on these systems. This matter is confirmatory.

Evaluation Section 9.1 of the plan generally describes the radiological and process monitoring systems. Potential gaseous release pathways are identified. Table 9-8 provides a detailed listing of the radiological and process monitors including identification of the monitor, number of channels, detector type, location and range, and minimum detectable concentration. Table 9-8 also provides a listing of area radiation monitor locations and ranges. According l to the plan, FSAR Sections 11.5 and 12.3.4 provide a complete description of the radiation monitoring program. The staff finds this portion of the appli-cant's plan adequate. Assessment systems are discussed in Section 13.3.2.9 of this supplement.

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Confirmatory Item 3 In a letter dated September 12, 1984, the applicant committed to include information on seismic and hydrological monitors in the next plan revision, scheduled for October 1984 This matter is confirmatory.

Evaluation Section 9.1 of the plan generally describes the seismic and river level moni-toring systems. According to the plan, a complete description of the seismic monitoring system may be found in Section 3.7.4 of the FSAR. The ECG contains emergency action levels based on readings from these geophysical monitoring systems. The geophysical instrumentation at the Salem Generating Station will provide backup capability. The staff finds this portion of the applicant's plan adequate.

Confirmatory Item 4 The matter of the meteorological monitoring program, as presented in the plan, is confirmatory pending the outcome of the onsite appraisal.

l Evaluation The onsite appraisal at Hope Creek is currently scheduled for August 1985, however, no specific date has_ been set as yet. Following the conduct of the e

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onsite appraisal and issuance of an inspection report , the staff's conclusions on the meteorological monitoring program will be presented in a future supple-ment to this report. This matter remains confirmatory.

13.3.2.9 Accident Assessment Open Item Before the staff can complete its evaluation in this regard, the applicant must provide a description of the emergency dose assessment computer model or the alternate computer support to be us'ed. This is an open item.

Evaluation Three methods for assessing the potential and actual consequences of a release of airborne radioactivity are stated in the plan. The primary method uses a dedicated telephone line connection to Pickard, Lowe and Garrick (PLG) to use PLG's Meteorological Information and Dose Assessment System (MIDAS) on time-shared facilities. This MIDAS software will be installed later on the VAX 11/750 computers which are part of-Hope Creek's Central Radiation Processor 1

(CRP).

The CRP contains the second method for assessing accident consequences. The CRP provides release rate calculations, dose rate calculations and dose inte-gration. Most calculations are provided using a modified puff advection model which includes a straight line Gaussian modification for the initial release

calculation. Dose conversion factors are taken from Regulatory Guide 1.109.

The system provides for data storage and reporting according to the guidelines in Regulatory Guide 1.21.

4 The third method available for assessing potential and actual accident doses is a manual method using transparent Gaussian plume overlays on site maps. The procedures and materials for utilizing this method will be incorporated in 1985 in the plan implementing procedures, and will be kept in the emergency kits in the emergency response facilities.

The MIDAS software system includes two plume dispersion models; one model uses the straightline Gaussian technique and a second model estimates plume trajec-tory using a segmented approach. The straightline Gaussian model conforms to the description of a Class A model in Appendix 2 to NUREG-0654, Rev.1. It will produce isopleth plots on a base map of the site vicinity.

The other model to be installed at Hope Creek in 1985 is an enhanced Class A model which meets the guidance criteria in Appendix 2 of NUREG-0654, Rev. 1, for a Class B model. This plume segment model, based on the CRACIT program, calculates meteorological dispersion and deposition of the released radioactive material as the material travels downwind, and estimates resulting doses. The meteorological dispersion is modeled assuming Gaussian diffusion and variable trajectory transport.

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i Several choices of source term input will be incorporated by the end of 1985 into the procedures for use of the various models. These include information on radionuclide concentrations and flow rates from plant effluent monitors, measurements.of dose rates inside containment, and preset release scenarios for accident scenarios based on design basis accidents. Meteorological information necessary to use the dose assessment methodologies can be obtained from the plant Meteorological Monitoring System and alternative sources. The methods described by the applicant can estimate doses to the relevant target organs of individuals in the vicinity of the site.

The applicant has comitted to develop procedures by the end of 1985 to monitor potential release pathways and to use the monitoring results to make dose projections for different meteorological conditions. Procedures will be developed in the same time frame for making dose projections based on field sampling results. Plan implementing procedures will also be developed describing in detail how dose projections will be made if radiation monitors are off-scale or out of service.

In the event of a radioactive release to the liquid pathway, i.e., the Delaware ,

River, water samples will be taken and counted with NaI gamma scintillation detector or equivalent, and dose projections made from instrument readings.

Procedure EP-IV-107. also provides a method for rapidly estimating doses from liquid releases.

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On May 8,1985, the staff requested additional infonnation/ clarification as a result of its review of Section 10 of the plan submitted on January 16, 1985.

The staff's request lists the dose assessment capabilities that need to be confirmed by the applicant. Accordingly, this matter is confirmatory pending review of the applicant's response by the staff. The staff's conclusions will be provided in a future supplement to this report.

Confirmatory Item 1 The matter regarding the onsite radiation monitoring and assessment systems is confi rmatory.

Evaluation The evaluation of the onsite radiation monitoring system is contained in Section 13.3.2.8 of this supplement. The evaluation of the assessment system is contained in the evaluation of the Open Item above. This confirmatory item is closed.

Confirmatory Item 2 The applicant has committed to provide curves of containment radiation monitor reading versus time for various scenarios (i.e., reactor coolant release, coolant and gap activity,1% fuel inventory, and 10% fuel inventory) at a later time. This matter is confirmatory.

Evaluation '

Section 10.3 of the plan has been revised to reference procedures that will include methods to evaluate potential doses based on accident scenarios includ-ing those stated above. However, the applicant has not identified the specific procedure (s) nor have the curves been furnished for staff review. This matter remains confirmatory.

13.3.2.10 Protective Response Confirmatory Item The plan commits to develop a predetermined protective action recommendation scheme as described in Appendix 1 to NUREG-0654, Revision 1 as clarified by Office.of Inspection and Enforcement Information Notice 83-28, and to incorpo-rate it into Procedures EP 1-4, " General Emergency," and EPI-20. " Protective Action Recommendations."

Evaluation Procedures EP I-4 and I-20, incorporating the guidance of Appendix 1 to NUREG-0654, have been submitted by the applicant. These procedures will be reviewed during the onsite appraisal in August 1985. The staff finds the portion of the applicant's plan adequate.

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13.3.2.11 Radiological Exposure Control Confirmatory Item The plan specifies that site evacuation criteria, protective action recommenda-tion guidance, emergency worker exposure limits, and decontamination guidance to be used by emergency response personnel will be provided in the plan procedures.

Evaluation Plan implementing procedures which cover the above emergency planning aspects have been submitted by the applicant. These procedures will be reviewed during the onsite appraisal in August 1985. The staff finds this portion of the applicant's plan adequate.

13.3.2.12 Medical and Public Health Support Confirmatory Item The applicant agreed to coordinate with Salem Memorial Hospital (SMH) and Radiation Management Corporation in finalizing the revisions to the SMH plan.

This matter is confirmatory.

Evaluation On February 7,1985, the applicant submitted a revised SMH plan, Revision 4, dated October 1984. The staff has reviewed the revised SMH plan and finds that additional information/ clarification is needed to properly interface the SMH plan with the Hope Creek emergency plan. This matter was discussed with the applicant on May 17, 1985. During this discussion the applicant commited to provide the information/ clarification requested by the staff. The applicant confirmed this commitment in a letter dated May 30, 1985.

The staff finds the applicant's response acceptable. This matter remains confirmatory pending further changes to the SMH plan as agreed to by the applicant.

13.3.2;14 Exercises and Drills Confirmatory Item (new)

A recent revision to Section 15.0 (Rev. 3, dated April 1,1985) of the plan deleted previous commitments related to: 1) exercises at night, 2) biennial exercises classified as General Emergencies, 3) personnel accountability drills, and 4) emergency response callout drills. In addition, the pages of revised Section 15.0 were not marked to indicate that the deletions were made.

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1 The above matter was discussed with the applicant on May 17, 1985. Based on l

the discussion, the applicant committed to provide the information requested by the staff and include it in the next revision to the plan. The applicant confirmed this commitment in a letter dated May 30, 1985. This matter is confir-matory pending the revision to the plan as agreed upon by the applicant.

13.3.2.15 Radiological Emergency Response Training Confirmatory Item

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A visitor's guide, similar to one currently used at Salem, will be used at Hope Creek. This matter is confirmatory.

Evaluation A sample visitor's guide has been provided to the staff. Review of the final visitor's guide and its implementation will be conducted during the onsite emergency preparedness implementation appraisal at Hope Creek currently scheduled for August 1985. The results of this review will be included in an inspection report. This item is closed.

Confirmatory Item (new)

A recent revision to Section 16.0 (Rev. 6, dated April 1,1985) of the plan deleted Table 16-1, " Summary of Training Program Applicability," which was a

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matrix of specialized training by group function code keyed to plan organiza-tion charts. The staff had previously found the applicant's emergency pre-paredness training program adequate based, in part, on the description of the specialized training indicated by Table 16-1.

The above matter was discussed with the applicant on May 17, 1985. Based on the discussion, the applicant committed to include Table 16-1 in the next revision to the plan. This commitment was confirmed by the applicant in a letter dated May 30, 1985. This matter is confirmatory pending a revision to the plan as agreed upon by the applicar.t.

13.3.3 Federal Emergency Management Agency (FEMA) Review of State and Local Emergency Response Plans In correspondence dated March 5,1985, FEMA confirmed that a complete offsite plan finding based on offsite plans and preparedness will be furnished the NRC by September 15, 1985. FEMA's finding on offsite plans and exercise evalua-tions will be provided in a future supplement to this report, prior to author-ization of Hope Creek operations above five percent of rated power.

13.3.4 Conclusions On the basis of the staff's review of the applicant's plan, the staff concludes that, upon satisfactory completion of those items committed to the applicant as c

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identified in Section 13.3.2 of this supplement, the Hope Creek Generating Station radiological emergency plan will provide an adequate planning basis for an acceptable state of onsite emergency preparedness and will meet the require-ments of 10 CFR 50, and Appendix E thereto. The staff will confirm that the applicant has complied with its emnnitments in a future supplement to this report following a review of the revisioni to the applicant's plan.

After reviewing the findings and determinations made by FEMA on the adequacy of State and local emergency response plans and prior to authorization to er.ceed 5% of rated power, a supplement to this report will provide the staff's overall

conclusion as to whether the state of onsite and offsite emergency preparedness

, provides reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.

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