ML20134E617
| ML20134E617 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/29/1996 |
| From: | Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20134E620 | List: |
| References | |
| TXX-96492, NUDOCS 9611010252 | |
| Download: ML20134E617 (64) | |
Text
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Log # TXX 96492 F7 File # 10013 clo
=
=
920 clo r
2 Ref. # 10CFR50.54(q) 1UELECTRIC*
- c. unce Terry October 29, 1996 Gnmp Mce Prendent U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50 445 AND 50 446 TRANSMITTAL OF CPSES EMERGENCY PLAN. REVISION 25 i
Gentlemen:
)
In accordance with 10CFR50.54(q), TU Electric herewith submit
. vision 25 of the CPSES Emergency Plan (EP). The changes comprising Re,.
an 25 were evaluated and determined to not decrease the effectiveness of the existing plan.
The changes were made effective at CPSES on October 1, 1996.
Changes are indicated by a Revision 25 change bar. A detailed j
description / justification is provided in the Attachment, except for Appendices K. P and Q. for changes indicated by the Revision 25 change bar.
The following is a general summary, by section, of the changes included in this revision to the CPSES Emergency Plan:
Section 1.0 "Oraanization"(ma.ior revision) 1 1.
Preface revised and relocated to new Section 1.0 " Purpose";
)
information previouly discussed in multiple subsections was revised and/or consolidated (e.g., federal agency support described in 1.1.1.3 and 1.3.3 now in new section 1.2.5).
1 2.
Table 1.1 " Staffing Requirements for Emergencies" and Table 1.2
" Graded Emergency Organization Response" were revised and combined into new Table 1.1 " Staffing Requirements for Ett"gencies."
Previous Table 1.140 minute responders were delewd: responding personnel are now either assigned onshift and respond at NOVE, or are 70 minute responders and respond at ALERT (or higher) classification. Also, split the graded emergency response previously described in Table 1.2 from Alert / Site Area Emergency and General Emergency to Alert und Site Area Emergency / General
,f Emergency.
gyj /f 9611010252 961029 PDR ADOCK 05000445 F
ppy P. O. Box 1002 Glen Rose Texas 76N3
TXX 96492 Page 2 of 6 3.
Revised the CPSES Emergency Response Organization (ERO).
Defined key emergency response organization positions as those responsible for functions designated in new Table 1.1.
Other position descriptions (not in new Table 1.1) were deleted from the Emergency Plan (but not necessarily from the ER0).
Combined the detailed list of position duties and responsibilities into more general responsibility statements for each described key position.
4.
Provided for accident classification to remain with the TSC Manager when other emergency response duties of the Emergency Coordinator are transferreo to the EOF Manager.
5.
Relocated Table 2.1 " Predetermined Response Actions" to new Table 1.2.
6.
Deleted organizational Figure 1.4 " Emergency Organization Overview".
1.10 " Logistical Support Center" and 1.11 "TU Electric Corporate Support"; revised and renumbered the remaining figures to reflect the new ERO.
Section 2.0 "Emeroency Classification System" 1.
Revised and relocated Table 2.1 " Predetermined Response Actions" to new Table 1.2.
2.
Renumbered Table 2.2 " Initiating Conditions for Emergency Classifications" to new Table 2.1.
Section 4.0 "Emeraency Commuciations" 1.
Replaced facility communications interface information in Figures 4.1 thru 4.6 with new Table 4.1 " Communications Interfaces".
2.
Renumbered Table 4.1 " Emergency Communications Responsibilities and Interfaces" to new Table 4.2.
3.
Revised description for section 4.1.6 " Direct Telephone Line to the System Dispatcher". 4.4 " Autodial Calling System" and 4.5 "CPSES Microwave Communications System".
TXX 96492 Page 3 of 6 Section 6.0 "Emeraency Facilities and Eauinment" (maior revision).
1.
Combined existing descriptions of the CPSES Emergency Response Facilities in the Emergency Plan and FSAR.Section III.A; describe in Emergency Plan new Section 6.
2.
Deleted the Logistical Support Center (LSC).
3.
Revised facility activation time goal from approximately 60 minutes to 70 minutes.
4.
Revised the inventory frequency for emergency equipment and supplies from monthly to quarterly.
5.
Deleted detailed descriptions of laboratory faciliites in the Nuclear Operations Support Facility (N0SF) (Section 6.7) and various plant assessment systems and instrumentation (Section 6.13).
These detailed descriptions were replaced with functional descriptions and/or a reference to the FSAR or other Licensing Basis Document (LBD) where a detailed description already exists.
Section 7.0 " Accident Assessment" 1.
Revised a Section 7.0 " Accident Assessment " reference to procedures regarding information on " PASS" from " Emergency Plan Procedues" to
" Chemistry Procedures".
2.
Revised Section 7.3.2 "Offsite Radiological Assessment" to delete reference to Emergency Plan Procedures and Table 6.3 " Environmental Sampling Locations".
Section 8.0 " Protective Resoonse" (ma.ior revision) 1.
Reformatted to separately group onsite and offsite protective response.
2.
Revised the practice of monitoring potentially contaminated site evacuees and discussions of respiratory protection, protective clothing and radioprotective drugs.
3.
Deleted description of CPSES owner controlled area and reference to EPZ evacuation, population distribution and special facilities maps.
TXX 96492 Page 4 of 6 Section 9.0 "Radioloaical Exoosure Control" 1.
Deleted description of "in plant" decontamination facilities from Emergency Plan Section 9.3 " Decontamination" and Figure 9.1
" Decontamination and First Aid Facilities in the Plant";
these facilities are described in FSAR Section 12.5.
2.
Revised Figure 9.2 " Emergency Operations Decontamination and First Aid Facilities in the Nuclear Operations Support Facility."
Section 11.0 " Reentry and Recovery" 1.
Revised selected ERO position titles, added a general consideration for plant recovery actions, revised statements concerning " corporate support", deleted references to " construction activities" and revised Secton 11.2 " Estimating Total Population Exposures".
Section 12.0 " Exercises and Drills" 1.
Revised Section 12.1 " Exercises" to reflect NRC rulemaking which now requires a " biennial" rather than " annual" full participation exercise with local authorities.
2.
Revised Section 12.0 and 12.3 to change "Vice President of Nuclear Operations" to " Plant Manager".
Section 13.0 "Radioloaical Emeraency Resoonse Trainina"(ma.ior revision) 1.
Revised section to delete superfluous description, consolidate the emergency preparedness training program with respect to specified groups of individuals (i.e., plant staff (non ER0): onshift staff (ERO): augmentation staff (ER0): and offsite agencies). Training I
not related to these specific groups or functions was relocated to
)
other sections of the Emergency Plan or deleted as redundant to the l
FSAR (e.g., Section 13.3B Fire Brigade Training).
l l
Section 14.0 "Resoonsibility for Plannina Effort" 1.
Revised statements with respect to maintaining staff proficiency (Emergency Planning staff), program responsibilities, approval authority, program audit and document / procedure review / control. The signature authority for approving Emergency Plan Procedures (EPPs) was changed from the Vice President of Nuclear Operations (Plant Manager) to the Emergency Planning Manager.
I
TXX-96492 Page 5 of 6 2.
Revised periodic review of Emergency Plan Procedures from annual to biennial.
Section 15.0 "Anoendices" 4
1.
Revised titles of selected Appendices.
i Anoendix H " Letters of Aareement and Sunoortina Emeraency Plans" 1.
Revised title and Appendix to reflect the relocation of the actual
" letters of agreement"; the change provides an updated list of the letters of agreements which are now maintained in the administrative files of the Emergency Planning department.
Anoendix J "Emeraency Eauioment and Sucolies" l
1.
Revised to delete reference to the Logistical Support Facility (LSC) and relocate a commitment from Section 6 concerning the number of company vehicles designated for use by the offsite monitoring teams.
Anoendix K " List of Emeraency Plan Procedures"
+
1.
Revised to reflect deletion of Emergency Plan Procedure EPP-117 i
" Administrative Controls for Sampling Under Post Accident Conditions": EPP 214 " Activation of the Logistical Support Center (LSC): EPP 215 " Corporate Support During Emergencies":
change descriptions / justifications provided in the Attachment address these deletions.
4 2.
Revised to reflect deletion of EPP 313. " Handling Contaminated Injured Personnel". This procedure was incorporated into the station administrative procedure for the Industrial Safety Program:
therefore, to prevent redundancy. EPP 313 was deleted.
3.
Revised the procedure cross reference to Emergency Plan Sections.
ADDendix M "CPSES Evacuation Tme Estimates and Staffina Estimates" i
1.
Revised to reflect an updated estimate for the time to staff the CPSES ERFs with responding ERO personnel after notification at home.
Anoendix P "CPSES Emeraency Plan /NUREG 0654 Cross Reference" 1.
Revised to reflect an updated cross reference between NUREG-0654 criteria and changes to the CPSES Emergency Plan (thru Revision 25).
- =_.
i 4
A TXX 96492 Page 6 of 6 i
Anoendix 0 " Acronyms and Definitions" 1.
Revised to delete acronyms and revise and/or delete selected defintions.
i Enclosed is the following as prescribed in 10CFR50.4(b)(5):
CPSES ENERGENCY PLAN - 1 Original (REVISION 25)
Sincerely, C. L. Terry By:
D. R. Woodlan Docket Licensing Manager CLW/grp Attachment Enclosure c-Mr. L. J. Callan, Region IV Mr. J. I. Tapia, Region IV (clo)
Hs. G. Good, Region IV Hr. T. J. Polich, NRR (clo)
Resident Inspectors (clo)
Attachment to TXX - 96492 Emerg:ncy Pirn Chang:s and Justifications (Revision 25)
SECTION 1 DESCRIPTION OF CIIANGE:
JUSTIFICATION:
1.
Table of Contents, List of Tables, Changes reflect the actual numbering sequences as the j
List of Figures section is rewritten.
2.
Incorporated the Preface into the new The Preface included an overview of the Plan that makes Section 1.0, " Purpose." Made minor for a good introduction with out duplicating the information editorial changes to the preface in Section 1.0. Therefore incorporated this information into
- material, the Plan.
i i
Editorial changes include:
a) Deleted statement about alternatejob functions being discussed in the PLAN. These alternate job functions are discussed in various Emergency Plan Procedures (EPPs).
The Emergency Plan as required by 10 CFR 50.47 and App. E discusses only the primary responsibilities of key personnel.
b) Changed title of Emergency Organization to Emergency Response Organization (ERO). This is to be consistent i
with the industry.
c) Changed the word " activation" to " staffing", to refer to l
the call out of the ERO. Activation is a term used for declaring an emergency response facility ready to perform
()
its designated functions.
i 3.
Section 1.0, " Organization" The Preface section replaced this information. The information contained in the deleted information is j
Deleted this section.
contained in the new Plan sections. This change does not remos any requirements or information,just removed duplicated information.
4.
Deleted Section 1.1.1," ERO and Relocated this information to new section,1.2. This Responsibilities" reduces the duplication ofinformation in the Plan and consolidates the informadon into one location.
5.
Section 1.1.1.1, "TU Electric" As stated in the new 1.0 Purpose, The Plan provides the direction and coordination of the ERO. The entire Plan i
Deleted this section.
provides this information. The list of TU Electric responsibilities have been deleted in this section but are j
Page 1 of 58
Attachment to TXX - 96492 Emerg:ncy Pl n Cheng:s and Justifications (Revision 25)
SECTION 1 DESCRIPTION OF CIIANGE:
JUSTIFICATION:
still maintained in the Plan as discussed under response personnel responsibilities. No responsibilities have been deleted. The Plan content and intent is the same.
l 6.
Section 1.1.1.2, " Local and State a) The Texas Department of Health has primary Agencies" responsibility for protective actions for radiological events, in accordance with the Texas Emergency Management a) Deleted reference to Texas Plan.
Department of Agriculture.
b) This information was duplicated in existing section 1.3.
b) Cornbined with existing Combined the information and placed in one section in the infonnation in section 1.3 and Plan. (new section 1.2.2 and 1.2.4) The information in the removed reference to Appendix F.
rewrite, with the exception of the Dept of Agriculture, does not change the intent or content of the existing material.
7.
Section 1.1.1.3," Federal Agencies" This information was duplicated in section 1.3.3.
Combined the information and placed in one section in the Combined with existing information Plan (new section 1.2.5). The Plan content and intent is in section 1.3.3.
the same in the rewrite as it was before.
8.
Section 1.1.2, " Concept of a) The information was reformatted into new section 1.1.2 Operation" Response. The content of the information remains unchanged.
a) Information rewritten.
b) Deleted the references to sections 2.0,3.0, and the b) Deleted references to sections 2.0 information in 1.1.2.1, and 1.1.2.2. This information has and 3.0. Deleted sections 1.1.2.1 and been combined with information from Table 2.1 in new 1.1.2.2.
Table 1.2.
9.
Section 1.1.3 "ERO This information is contained in the rewrite in section Interrelationships" and 1.1.4 1.1.2.2,"CPSES ERO"
" Emergency Response Functions" 10.
Section 1.1.5, " Authorities and a) This is a list oflegal documents that provide for the Agreements" support of federal, state and local agencies. This information provides no guidance or information towards a) deleted the list of documents the planning of emergencies. The written response plans which establish authority for local are all in place and the interrelationships of the groups are and state agency support.
shown in Figure 1.1. The Texas Emergency Management Plan, as discussed in new section 1.2.4, continues to Page 2 of 58
Attachment to TXX - 96492 i
Emergcncy Plan Changes and Justifications (Revision 25)
SECTION 1 DESCRIPTION OF CliANGE:
JUSTIFICATION:
b) rewrote paragraphs discussing include the information on establishing the authority for the.
written agreements.
state and local plans.
b) Section 1.2 in the rewrite describes the different agencies involved with emergency response at CPSES.
The rewrite describes the type of agreement between CPSES and the agency involved. See Appendix H for changes / justifications regarding Letters of Agreement.
11.
Section 1.2 "CPSES Organization",
a) Section 13 of the Plan discusses training. The i
1.2.1 "TU Electric Nuclear information concerning TRA-105 already is in section 13 Production Group",1.2.2 "CPSES of the Plan. Relocated this information from section 1.2 and Operating Organization" combined with section 13 to reduce redundancy.
a) Relocated information concerning b) The remaining information in these sections is training to section 13 of the Plan.
redundant ofinformation that already exists in the FSAR i
section 13. Deleted the information from the Plan and i
b) Summarized the remaining replaced with a statement that directs the individual to the information and added a reference to FSAR section 13 for information concerning normal the FSAR section 13.
operations organizations, and minimum shift compliment j
for Control Room staff.
i 12.
Section 1.2.3, " CPSES Emergency a) The rewrite (Section 1.1.2.2) discusses the augmentation Organization" of the on shift crew. The section describes the personnel who augment the on shift crew to include: station a) Deleted the first sentence, employees, local, state, federal, and private agencies. This sentence is redundant ofinformation already contained in b) Deleted the information the Plan.
concerning training, drills, and exercises.
b) This is redundant ofinformation contained in section 12 and 13 of the Plan.
I c) Kept the reference to Table 1.1, deleted the information concerning c) Table 1.1 continues to show the minimum functions l
facility activation.
required to be performed and the timeliness for augmenting these functions. The information for facility activation is i
d) Reworded the paragraph leading discussed in section 6 of the Plan and was deleted from to the list of duty and responsibilities section 1.0 because of redundancy.
of key emergency response organization personnel.
d) The intent and information of the rewritten section remains unchanged from the original.
1 Page 3 of 58
Attachment to TXX - 96492 Emerg:ncy Plan Changes and Justifications (Revision 25)
SECTION 1 DESCRIPTION OF CIIANGE:
JUSTIFICATION:
i l
13.
Section 1.2.3.1, " Emergency a) The existing duties and responsibilities stated in the Plan Coordinator" also contain task statements that are part of the primary responsibilities. The revised responsibilities state the a)
Revised responsibilities of primary responsibilities only and are inclusive of the EC.
previous task statements. The revised responsibility list is a summary ofinformation that previously existed. The Plan b)
Deleted the declaring and continues to discuss certain additional tasks that the EC classifying of an emergency perfomis. The responsibility to approve news releases has from the list of non-delegable been transferred to the Company Spokesperson. Based responsibilities of the EC.
upon experience, the majority ofinformation used in news releases has previously been approved by the Emergency c)
Revised the information Coordinator during the event response. Approving the about the transfer of EC information again for the news release is redundant and duties from the Shift distracts the Emergency Coordinator from more important Manager, TSC Manager, and matters. This change makes news releases more timely and EOF Manager.
enhances the operation of both the EOF and News Center.
i d)
Revised discussion of when b) The responsibility to assess, classify, and declare an EC duties are formally emergency event was relocated from the list of non-transferred.
delegable responsibilities to the list of responsibilities of EC. This allows the TSC Manager to retain accident classification responsibilities when EC duties are transferred to the EOF Manager. This change minimizes the communications links to actually make an event classification; therefore, events are classified in a more timely manner and the offsite agencies are able to consider / implement protective actions in a more timely manner which is a program enhancement. This change was field tested during a drill on May 2,1996 with no problems encountered.
c) The information was revised to incorporate the change discussed in (b) above about accident classification.
d) The information about completion of formally transferring EC duties was deleted. The criteria for allowing the transfer (i.e. briefing takes place) is still in Plan as 1.1.2.2.c. This is detail that is contained in the EPPs.
Page 4 of 58
Attachment to TXX - 96492 Emsrgency Plan Changes and Justifications (Revision 25)
SECTION 1 DESCRIPTION OF CHANGE:
JUSTIFICATION:
14.
Section 1.2.3.2, " EOF Manager" This information is now discussed in section new 1.1.2.2.c.
Deleted the statement discussing transferring Emergency Coordinator duties to the EOF Manager.
15.
Section 1.2.3.3," EOF The primary responsibility is maintained. The functions are Communications Coordinator" deleted because this section is to address primary responsibilities, not detailed functions. The details are Deleted the stated functions of the discussed in the EPPs.
EOF Communications Coordinator.
16.
Section 1.2.3.4," Company The primary responsibility is maintained. The detailed list Spokesperson" of responsibilities is more tasks associated with carrying out the responsibility than actual responsibility statements.
Deleted the detail list of The details are still discussed in the EPPs.
responsibilities.
17.
Section 1.2.3.5, " EOF Security The summary statement is the primary responsibility. The Coordinator" details are discussed in the EPPs.
Deleted the detailed list ofindividual responsibilities and replaced with a summary statement of responsibilities.
I 8.
Section 1.2.3.6, " EOF Logistical The summary statement is the primary responsibility. The Support Coordinator" details are maintamed in the EPPs.
(See description for item 17 above.)
19.
Section 1.2.3.7, " EOF Radiation The sum. mary statement is the primary responsibility. The Protection Coordinator" details are maintained in the EPPs.
(See description for item 17 above.)
20.
Section 1.2.3.8, " EOF OFFRAC" The EOF Offsite Rad Assessment Coordinator is not specified in the group of key personnel describea,. the Deleted this section.
Plan. The duties and responsibilities of this position remain in the EPPs and the ERO. Table 1.1 shows the Page 5 of 58 i
Attachment to TXX - 96492 Emergency Plan Changes and Justifications (Revision 25)
SECTION 1 DESCRIPTION OF CIIANGE:
JUSTIFICATION:
responsibilities, functional areas, and position titles of the key ERO members.
i 21.
Section 1.2.3.9, " EOF Engineering This position has been a back-up resource to the TSC Support Coordinator" Engineering Team and has duplicated the functions of the TSC Engineering Team Coordinator. The EOF and TSC Deleted the position of EOF Engineering Teams are being combined and are relocated in Engineering Support Coordinator the TSC where they are better able to work on correcting from the Emergency Response plant problems. The responsibilities of the EOF Organization.
Engineering Support Coordinator are transferred to the TSC Engineering Team Coordinator. This minimizes the needed communications links and improves the working relationship between the engineering team members. This change was field tested on May 2,1996 and was determined to be a program enhancement.
i 22.
Section 1.2.3.10, "TSC Manager" The summary statement is the p.imary responsibility. The details are maintained in the EPPs.
1 (See description for item 17 above.)
23.
Section 1.2.3.11,"TSC Maintenance The duties and responsibilities of the TSC Maintenance Coordinator" Coordinator have been transferred to the TSC Operations Coordinator and the TSC Communications Coordinator. A j
This position was deleted from the drill was conducted May 2,1996 to field test deletion of the 1
Emergency Response Organization.
Maintenance Coordinator position. The OSC was kept Deleted the information in this informed of priorities and the TSC was kept informed of section.
ERDC team activities. A table top discussion was conducted after the drill, and the outcome of the table top was that this function could be performed without the Maintenance Coordinator. The duties are not part of the key ERO positions as determined by Table 1.1 so they are no longer described in the Plan.
24.
Section 1.2.3.12,"TSC Operations The duties of this position are not part of the key ERO Coordinator" positions as determined by Table 1.1 so they are deleted Deleted position description from the from the Plan, but are maintained in EPPs.
Plan.
25.
Section 1.2.3.13,"TSC Eng Team As previously discussed, ( #21), the EOF Engineering Coordinator" Support Coordinator position has been deleted and the EOF Page 6 of 58
1 Attachment to TXX - 96492 Emsrgency Plnn Changes and Justifications (Revision 25)
SECTION 1 l
DESCRIPTION OF CHANGE:
JUSTIFICATION:
Incorporated EOF Engineering Engineering Team has been combined with the TSC Support Coordinators responsibilities Engineering Team. This places the engineering function in and summarized the responsibilities, one location (the TSC), close to the plant problems, and minimize communication problems caused by the i
Engineering Team being in separate facilities. The summary statement is the primary responsibility. Details are maintained in the EPPs.
26.
Section 1.2.3.14,"TSC ONRAC" The list of responsibilities were actually tasks associated with carrying out the radiological responsibilities onsite.
Deleted the detailed list of Summarized the list into a primary responsibility statement.
responsibilities.
The details of the list are maintained in the EPPs.
27.
Section 1.2.3.15,"TSC Advisor" The position title change is more descriptive of what the Changed the title of TSC Advisor to position is actually responsible for and provides TSC Communications Coordinator.
consistency between the TSC and EOF position titles for
)
Deleted the detailed list of similarjobs. Summarized the responsibility list into a responsibilities and replaced with a primary responsibility statement. The details of the list are summary statement of maintained in the EPPs.
responsibilities.
28.
Section 1.2.3.16," Operations Defined key members as those positions necessary to carry Advisor" out the functions outlined in Table 1.1, " Staffing Deleted position description from the Requirements for Emergencies." Table 1.1 is based on Plan.
Table B-1 from NUREG-0654. The Operations Advisor remains a position in the Emergency Response Organization, but is not a key position for carrying out Control Room or TSC responsibilities.
29.
Section 1.2.3.17,"LSC Manager" The LSC Manager position is deleted from the ERO. The Logistical Support Center (LSC) as a separate Emergency Deleted this position description Response Facility is deleted. The functions of the LSC from the Plan have been transferred to the EOF and are a responsibility of the EOF Logistical Support Coordinator. The functions of the LSC continue to be performed.
30.
Section 1.2.3.18,"OSC Manager" The summary statement is the primary responsibility. The Summarized the list of details are maintained in the EPPs.
responsibilities.
Page 7 of 58
_~
Attachment to TXX - 96492 i
Emergency Pinn Changes and Justifications (Revision 25) i l
SECTION 1 4
DESCRIPTION OF CIIANGE:
JUSTIFICATION:
31.
Sections 1.2.3.19,"OSC RP These positions are not key response personnel. This Supervisor" 1.2.3.20, "OSC section deals with key personnel only required to satisfy the Maintenance /ERDC Supervisor, requirements of Table 1.1. Table 1.1 is based on Table B-1 1.2.3.21,"OSC Chemistry from NUREG- 0654. These positions and functions remain i
Supervisor" in the ERO.
q Deleted these position descriptions from the Plan.
32.
Section 1.2.3.22,"STA" The STA is an On-shift position at CPSES. The information for this position was relocated to the on-shift l
Relocated this information to the description (Section 1.1.2.1) for consistency. The words discussion of the on-shift personnel, were changed to fit with the new layout of the section l
Reworded the infonnation.
rewrite. The intent of the information remains unchanged.
Additional information is also contained in the FSAR section 13.1.2.1 and FSAR Table 13.1-2.
33.
Section 1.2.3.23," Local EOC This information was relocated to reduce redundancy in Advisor" section 1.2.3.23,1.3.1, and 6.2. The intent of the Relocated this information to new information remains the same, but consolidated the section 1.2.1.
information into one location within the Plan.
34.
Section 1.2.3.24," Corporate Support By September 1,1996, essentially all of the nuclear Coordinator" production support that was located in Dallas at corporate headquarters has been moved onsite at CPSES. In the Deleted this position description current TU Electric organization, all principal nuclear j
from the Plan and ERO.
management, engineering and support personnel are permanently officed at CPSES. CPSES is the only nuclear power plant in the TU Electric system. Provisions for 24-hour staffing and augmentation of the CPSES ERO are covered by the onsite CPSES personnel. Accordingly, there is no longer a need to separately designate a
" Corporate Support Coordinator" position in the ERO for marshaling offsite corpomte support to a CPSES emergency response. TU Electric does have other corporate resources available to CPSES; new section 1.2.1 provides a general policy statement with respect to TU Electric's commitment to the other capabilities and their availability to the CPSES ERO.
35.
Section 1.2.4, " Minimum Staffing" See justification for Table 1.1.
Page 8 of 58
Attachment to TXX - 96492 Emergency Pirn Changes and Justifications (Revision 25)
SECTION 1 DESCRIPTION OF CIIANGE:
JUSTIFICATION:
36.
Section 1.2.5, "Other Onsite The information which is referenced by the material has j
Emergency Organization been moved to the section which describes the on-shift Assignments" capabilities (1.1.2.1) for emergency response; therefore, the i
Deleted a portion of the second statement that is deleted no longer applies to this section.
sentence.
The intent of the section remains unchanged.
1 37.
Section 1.2.5.1," Station Operations This information is a brief summary of the content of the and Fire Fighting" Technical Specifications 6.1 and the FSAR section 13.1.2.
j Since this material is covered in detail in other licensing Deleted this section from the Plan.
documents it does not need to be summarized in the Plan.
i 38.
Section 1.2.5.2," Security" Revised this information; however, the content and intent 2
of the section remains unchanged. Material is relocated to Revised and relocated information.
new section 1.1.2.1.
39.
Section 1.2.5.3," Administrative This information is generic in nature and is duplicated by l
Support" the responsibilities listed for the EOF Logistical Support i
Deleted this section from the Plan.
Coordinator.
4 40.
Section 1.2.5.4, "RP and Chemistry" Table 1.1 outlines the functions and tasks to be performed by the RP Technicians. Section 13.0 addresses the i
Deleted this section from the Plan.
qualifications of Emergency Ruponse Organization members. This is duplicate information that already exists in the Plan; The information is also in FSAR Table 13.1-2.
i l
4 41.
Section 1.2.5.5," Engineering Teams" The EOF Engineering Team is being combined with the TSC Engineering Team. This provides one location near
)
4 i
Deleted this section from the Plan.
the plant for engineering analysis. This increases efficiency due to locating the teams together and removing the communication barriers that have existed. This was field
{
tested May 2,1996 during a drill. The engineering team performed their function well, and agreed that the change
{
was an improvement for the team. The rest of the verbiage in this section is duplicate information that exists in Table 1.1, Figure 1.6, and responsibilities of the TSC Engineering j
Team Coordinator, j
42.
Section 1.2.6," Interfaces" The intent and content of this section remains unchanged i
with the exception of the Logistical Support Center. The This information reworded and LSC has been deleted as an emergency response facility.
Page 9 of 58
Attachment to TXX - 96492 Emerg:ncy Plan Changes and Justifications (Revision 25)
SECTION 1 DESCRIPTION OF CIIANGE:
JUSTIFICATION:
relocated to section 1.1.2.2.
The functions of the LSC have been reassigned to personnelin the EOF. Figure 1.1 shows the interrelationships between organizations.
43.
Section 1.2.7, "Long Term The information concerning the Emergency Coordinator is Operations" duplicate information already contained in section 1.0 of the Plan. The information concerning the recovery efforts Deleted this section from the Plan.
is duplicated in section 11.0, " Recovery and Reentry."
44.
Section 1.2.8, " Corporate Support" See discussion in item 34.
Reworded the information in this 1
section.
45.
Section 1.2.9, " Squaw Creek Park",
This section duplicated information that is contained in section 8.1 and 8.2. More instructions are given in section Deleted this section from the Plan.
8.0; therefore, deleted this information in section 1.0.
46.
Section 1.3," Emergency Response This information is introductory in nature and provides no Support Organizations" actions or requirements, it is merely a discussion of what Deleted this information from the follows.
Plan.
47.
Section 1.3.1," Local Agencies" Editorial changes do not alter the content of the section.
Made editorial changes to the The material is now in section 1.2.2.
I section.
48.
Section 1.3.1.1, " Law Enforcement" The location of the Local EOC's is deleted. The Hood and Somervell County Emergency Plans establish the locations Made editorial changes.
of the Local EOC's. Section 6.0 of the Plan also describes the location of the local EOC's. The new material is in section 1.2.2.
49.
Section 1.3.1.2," Fire Fighting Content remains unchanged. New material is in section Support" 1.2.2.
Made editorial changes.
50.
Section 1.3.1.3," Medical Support" This was nothing more than a reference to another section of the Plan. Deletion of the reference changes no content.
Deleted this information from the The information in the referenced section remains Plan.
unchanged.
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SECTION 1 i
DESCRIPTION OF CHANGE:
JUSTIFICATION:
j 51.
Section 1.3.2," State Agency Content remains unchanged. New material is in section i
Support" 1.2.4.
Made editorial changes.
52.
Section 1.3.3, " Federal Agency Content of the information remains unchanged with the Support" exception of the information in section 1.3.3.3 which discussed the DOE. CPSES has a letter of agreement with Made editorial changes, the DOE which outlines the information and provides the details from section 1.3.3.3. The redundancy has been deleted. New material is in section 1.2.5.
53.
Section 1.3.4, " Private Organization Content of the information remains unchanged. Added Support" infocmation concerning Houston Lighting and Power, and i
Made editorial changes.
American Nuclear Insurers. New material is in section 1.2.3.
54.
Table 1.1,"Staffm' g Requirements" See description of changes /justi6 cations for Table 1.1.
55.
Table 1.2 " Graded Emergency a) Split the Site Area Emergency and Alert functions.
Organization Response" Added the Site Area Emergency Functions to the General Emergency. This is how the Plan actually reads as far as Table 1.2 was combined with Table 1.1 into actions taken by emergency response organization new Table 1.1. The following changes personnel. This is supported throughout the Plan.
describe Table 1.2 informationas incorporated in new Table 1.1.
b) The LSC has been deleted as an emergency response facility. See section 6.0 for more details on this deletion.
a)
Moved Site Area Emergency The EOF has taken over the functions previously functions to column with General performed by the LSC.
1 Emergency, c) Title changed to TSC Communications Coordinator to b)
Deleted the Logistical Support be more reflective of the duties the position performs.
Center d) Deleted this position from the ERO. Security Plan and c)
Changed title of TSC Advisor procedures perform without the TSC Security Advisor position. The Security Shift Supervisor maintains d)
Deleted TSC Security Advisor responsibility for implementing the Security Plan. Drill on May 2,1996 Held tested this change with no problems e)
Deleted Shift Manager from encountered.
Radiation Protection.
e) Shift Manager has no RP duties at an Unusual Event.
Page 11 of 58
Attachment to TXX - 96492 Emergency Plan Changes and Justifications (Revision 25)
SECTION 1 DESCRIPTION OF CHANGE:
JUSTIFICATION:
f)
Updated Engineering Team f) The STA in the Control Room initially has information responsibility for engineering functions, to include core thermal hydraulics. The nuclear member of the g)
Added mechanics, electricians, and Engineering Team relieves the STA of this function. The I&C Technicians to emergency nuclear member also can perform shutdown margin and repair area. Changed Control Room core damage assessment. These are all normal day to day to auxiliary operators and deleted RP activities of these personnel. The remainder of the Techs.
Engineering Team is staffed at the ALERT and provides corrective actions for plant problems under the direction of h)
Replaced operations and safety the Engineering Team Coordinator.
services with Fire Brigade.
g) RP Techs are already covered on this Table in the i)
Changed Control Room Personnel to Radiological Assessment section. The Auxiliary Operators Control Room Communicator, are more descriptive as who would be doing corrective actions from the Control Room, and added the mechanics, electricians and, I&C Techs. This is an improvement over the existing program.
h) Fire Brigade is the specific group which provides fire j
lighting function.
i) The change allows other on-shift personnel to perform the communications function. This is supported by Table 1.1, which identifies Control Room Communicators for this function.
56.
Figure changes.
a) Changes to these figures reflect changes that have been made to the ERO.
a)
Figures 1.1,1.5,1.6,1.7,1.8,1.9 revised and renumbered.
b) Fig 1.4 is being deleted because the text (Section 1.1.2.2.c) provides the overview of the ERO during b)
Figures 1.4,1.10,1.11 are deleted.
different levels of activation and new Fig 1.1 shows the totaliesponse organization depending on the level of facility activation.
Fig 1.10 has been deleted because the LSC has been deleted as an emergency response facility. The EOF has taken the duties previously performed by the LSC. Fig 1.5 shows the LSC functions in the EOF.
Page 12 of 58
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Attachment to TXX - 96492 Emergency Plan Changes and Justifications 4
4.
(Revision 25)
SECTION 1 DESCRIPTION OF CHANGE:
JUSTIFICATION:
1-Fig 1.11 has been deleted because the corporate support l
function has been deleted. See discussion in item 34 this section.
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Attachment to TXX - 96492 Emerg:ncy Plan Chnng:s and Justifications (Revision 25)
TABLE
1.1 DESCRIPTION
OF CIIANGE:
JUSTIFICATION:
1.
Station Operations The information in the Plan is a summary of the information in the FSAR. The FSAR prescribes the current Referenced FSAR Section required minimum on shift complement. Also the Plan 13.1.2.3 and FSAR Table 13.1-2 only shows the minimum stafrmg for one unit operation, while CPSES is now a two unit site. The FSAR discusses minimum staffing for two units during all modes of operation. Referencing the FSAR prevents inconsistencies between the Plan and the FSAR.
2.
Emergency Direction and Control This addition is for clarification purposes for the function Added task statement to the table.
of Emergency Direction and Control.
3.
Communications a) The addition of this information more clearly defines the function of communications.
a) Added local, state, and federal personnel to the task statement.
b) The titles rather than expertise makes the Plan more clear.
b) Specified by title rather than expertise the positions which c) The Plan currently allows one communicator to make conduct these functions, the station, local, state, and federal notifications. This remains unchanged. During the federal notifications, if the c) Moved the 40 minute responder NRC wants the communicator to remain on the line, the to on-shift (NOUE) and reduced the communicator requests assistance from the Shift Manager 70 minute responders (Alert) by one.
who assigns a member of the crew from the unaffected unit to talk with the NRC. This is the 40 minute responder that is being moved to on shift. This is reflected in the written EPPs and this practice has worked well in the past during drills and exercises. This arrangement has also been demonstrated during NRC walk throughs on the simulator to test the on shift minimum response capabilities.
The 70 minute responder is the TSC Communications Coordinator. The reduction of 70 minute responders is possible by having the Control Room Communicator walk upstairs with the TSC Manager (Emergency Coordinator) when the command function is transferred to the TSC.
There are still two (2) communicators available, both now in the TSC to conduct the communication / notification functions.
Page 14 of 58
Attachment to TXX - 96492 Emergency Plan Changes and Justifications (Revision 25)
TABLE
1.1 DESCRIPTION
OF CIIANGE:
JUSTIFICATION:
The intent of the communication function is to have two people making notifications, whether they are in the TSC or the Control Room. The Plan provides for two communicators in each facility. Initially, by having both communicators on shift; later, by calling in one additional communicator and having one of the control room communicators relocate to the TSC when the command function transfers to the TSC. The intent of having two communicators is assured by this change, and so the Plan as rewritten is as good as before.
4.
Station System Engineering The Plan currently requires health physicist expertise to arrive within 40 minutes. There is also a 40 minute Made the STA responsible for the responder in the radiological assessment function. Both of duties and responsibilities of the 40 these 40 minute responders are to perform offsite dose minute responders for engineering projections using the CPSES computer model. The and health physicist.
f2nction of performing dose projections is transferred to the STA in this revision with no additional responders.
j The Plan and EPPs now reflect the guiding principle of the NRC when making protective action recommendations (PARS), which is to base the initial PARS upon plant conditions. By basing the PARS on plant conditions rather than dose projections, the PARS reach the general public faster, which better ensure public protection and safety.
The STA is trained and has the capability to perform dose projections using the computer model and performs dose projections on a priority / time availability basis to verify that plant condition PARS were sufficient.
As the emergency response facilities become activated, the function of performing dose assessment / projections is transferred to the EOF per the Plan and EPPs.
The engineering function, specifically core / thermal hydraulics is also transferred to the STA. This is part of the qualification requirements called for by the FSAR section 13.1.2.3.
Page 15 of 58
Attachment to TXX - 96492 Emergency Plan Changes and Justifications (Revision 25) 4 4
TABLE
1.1 DESCRIPTION
OF CIIANGE:
JUSTIFICATION:
With the STA satisfying the capability requirements for dose projections and engineering, there is no need to have 40 minute responders to report to perform these functions.
Since the functions are capable of being performed by a member of the on shift crew rather than waiting for a 40 j
minute responder, this change is an enhancement to the Plan.
5.
Radiological Assessment a) This change reflects the position title in the normal 4
operating organization.
a) Changed the name of Chem &
Envir Technician to Chemistry b) Offsite survey teams are made up of one driver and one Technician.
RP Tech by the EPPs. This change reflects the makeup of 4
the offsite survey team.
b) Added vehicle drivers to the offsite survey task.
c) The function of onsite surveys is to locate unmonitored releases as soon as possible. With the PC-11 "looking" for c) Moved the 40 minute responder releases from within the plant and the onsite surveys for onsite surveys to on shift.
determining if there are any unmonitored releases, any (NOUE) release that does occur should be detected rapidly. The l
information can be used to form PARS sooner and the a
d) Moved the 40 minute responder health and safety of the public is better assured.
i for offsite surveys to Site Area Emergency column and reduced the d) The Plan currently states that an offsite survey team total number of offsite survey must be deployed within 120 minutes of an emergency.
personnel to two.
The Plan also describes sending field teams out at the Site Area Emergency in both section 7.0 and new Table 1.2.
With the 120 minute criteria established, there is no reason to bring one individual in to respond within 40 minutes.
4 Therefore the 40 minute responder is deleted. An offsite survey team is composed of at least one RP Tech and one driver. Previously, Table 1.1 called for one 40 minute responder and three 70 minute responders. This allowed j
for the dispatch of two offsite survey teams, each team with two RP Techs. Ilowever, the Plan and EPPs are written to require only one team within 120 minutes of the emergency. The previous Table 1.1 numbers were actually an overstatement of the minimum resources required to perform the task of offsite surveys. One team is sufficient i
to initially detennine if a release is having an impact to the Page 16 of 58 s
1 Attachment to TXX - 96492 Emerg:ncy Plan Changes and Justifications (Revision 25)
TABLE
1.1 DESCRIPTION
OF CIIANGE:
JUSTIFICATION:
general public. One team is made up of one driver and one RP Tech, as reflected in the rewrite. Additionally, this change allows for the redistribution of three RP Techs back towards the station where they could be better put to use in the early phase of an accident.
Though the staffing number actually decreased from four to two offsite survey individuals, the required task of performing offsite surveys can be accomplished with two individuals forming one team.
6.
System Corrective Action Electricians,. mechanics, and I&C Technicians have been on shift since Jan.1,1996. This change reflects changes that Added to the Task statement the have taken place in the normal operating organization.
words " Emergency Repair." Moved Adding additional 70 minute responders in each discipline the 40 minute responders to on shift allows 2 person teams to be dispatched from the same (NOUE). Added an additional discipline for second checking and self verification which Electrician and I&C Technician to decreases the occurrence of errors that might be made in the the 70 minute responders (Alert).
field. This enhances the program.
7.
Protective Actions The tasks that responders performed (i.e. access control, personnel monitoring, dosimetry issue) have all been Deleted this entire function, task, and automated. Personnel requiring access to the RCA receive staffing requirements, training on how to use the system to allow self-service at access control. Individuals are responsible for getting dosimetry required for entry, reading the access permit, processing in on the access control computer, all without the aid of an RP Tech. This is the practice during norrnal operations; therefore, there is now no need to have personnel on shift or required to respond to perform these functions.
8.
Firefighting, Rescue Operations, and a) These tasks are performed by the same personnel so First Aid they have been combined.
a) Combined these functional areas b) Letters of Agreement are in place with local support and added task statements to the agencies for medical, firefighting, and rescue support.
functions.
These agreements provide assistance as requested.
Response is as soon as possible from the time of b) Changed the Local support from notification. As such, they do not fit in any of the three Page 17 of 58 i
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. Attachment to TXX - 96492 1
l Emergency Plan Changes and Justifications (Revision 25)
TABLE
1.1 DESCRIPTION
OF CHANGE:
JUSTIFICATION:
40 minutes to 70 minutes (ALERT).
categories (on shifl,40 min, and 70 min), but are listed to i
show that there is additional resources available if needed.
)
i 1
9.
The 70 minute column was When existing Table 1.1 and 1.2 were combined, the 70 i
incorporated into the Alert column.
minute responders are shown by title in the Alert column.
Section 6.0 describes activation times for the TSC and OSC 3
to be 70 minutes from an Alert declaration. Therefore, the Alert column corresponds to 70 minute responders. The information previously contained in the 70 minute column remains unchanged with the exception of changes made in items 1-8.
i N.
J I'
)
Page 18 of 58
Attachment to TXX - 96492 Emergency Plan Changes and Justifications (Revision 25) i
+
NEW TABLE 1.2 1
DESCRIPTION OF CHANGE:
JUSTIFICATION:
i 1.
Table 2.1 is relocated to Section 1.0 Section 1.0 of the Plan describes the concept of operations l
as new Table 1.2.
for the Emergency Response Organization. Section 2.0 of the Plan describes the emergency classification system.
2 The information in Table 2.1 was determined to fit better in section 1.0 than it did in section 2.0; therefore, the table i
was relocated.
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Attachment to TXX - 96492 i
i i
)
Emergency Plan Changes and Justifications (Revision 25) 4 5
SECTION 2
)
i DESCRIPTION OF CHANGE:
JUSTIFICATION:
4 1.
Section 2.1, " Emergency Classifications" This change is only relocation of material. See Removed the reference to Table 2.1. Table discussion for new Table 1.2, item 1.
2.1 is relocated to Section 1.0 as new Table 1
1.2.
1 2.
Table 2.1, " Predetermined Response The dermitions and purpose statements for each Actions" (new Table 1.2) emergency classification are already in the Plan in Section 2.1. The purpose statements are word for Removed the regulatory definitions and word from NUREG-0654 and are explanations used purpose statements from Table 2.1.
to describe what the classifications were to be used for as defined in the early 1980's. Today, emergency classifications are more widely understood and purpose statements are not particularly useful. The purposes are discussed in the text of section 2.1. The predetermined response actions (new Table 1.2) also reflect the purposes of the classification.
3, Table 2.1, NOUE (new Table 1.2)
Items a, b, and d are all additions to the existing a) Added the time limit for notifying state Plan. These additions are all enhancements to the and local authorities. (This change is for all program.
four classifications.)
b) Added notifications to NRC. (This Item c is not a predetermined action. As stated, the change is for all four classifications.)
statement reads "ifrequired." As stated in Section c) Deleted augmentation of on-shift 1.0 of the Plan, the Emergency Coordinator can take resources as precautionary measures, actions as required to protect the health and safety d) Added periodic updates to offsite of the public. Therefore, since this is not a pre-authorities, determined action and the Emergency Coordinator already has the authority to take the action, the information is deleted.
4.
Table 2.1, Alert (new Table 1.2)
This is in accordance with 10CFR50.72 (a)(4). The Added activate the ERDS at an Alert or addition is an enhancement to the Plan.
higher classification level.
S.
Table 2.1, Site Area Emergency and General The LSC is being deleted as an emergency response Emergency (new Table 1.2) facility. See discussion for Section 1, item 29, and Deleted the Logistical Support Center from Section 6, item 14.
the list of facilities to be activated.
Page 20 of 58
)
i Emergency Plan Changes and Justifications (Revision 25) i SECTION 4 DESCRIPTION OF CHANGE:
JUSTIFICATION:
1.
Section 4.0, First paragraph, Table 4.1, " Communications Interfaces" contains Deleted reference to Figures 4.1 equivalent information as the previous figures,just in a through 4.6. Replaced with new new format. The single page table rather than six pages Table 4.1.
of figures makes it easier to see the actual communication interfaces. The table is therefore an improvement over the figures, and constitutes an improvement to the Plan. (See individual changes to each figure to determine differences between Table 4.1 and associated figures.
I 2
Section 4.4, Changed words from In June of 1996 Emergency Planning upgraded the "up to 16" to " multiple",
autodialing machine. The new machine software runs i
faster than the old machine software. Also with the upgrade, four (4) additional phone lines were added for a total of twenty (20). The function of the system is to call out the ERO in the event of an emergency. The Plan j
sets the timing goal for activating the facilities. The number oflines needed for the call out machine is a function of the number of people to be called and the facility activation time specified. The number oflines does not need to be specified in the Plan since the time requirement for activation is in the Plan.
3.
Section 4.5, Changed The important point here is that the capability exists for
" Southwestern Bell trunks" to commercial trunk lines. The corporate company name is
" commercial trunk lines.
unimportant 4.
Table 4.1,(new Table 4.2) a) The Logistical Support Center as a separate emergency response facility is being deleted. See
- a) Deleted the Logistical Support discussion for Section 1, item 29, and Section 6, item 14.
Center b) See discussion for Section 1, item 34 and new section b) Deleted Dallas Corporate 1.2.1.
Office 5.
Changed figures 4.1-4.6 to delete In situations where point-to-point phones are used there point-to-point designation for all is also a standard telephone unit. In some positions there phones with the exception of the are two point-to-point phones and a standard phone. It is Control Room to TU Electric not possible to have effective communications on two or Page 21 of 58
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Attachment to TXX - 96492 Emergency Plan Changes and Justifications (Revision 25)
SECTION 4 DESCRIPTION OF CHANGE:
JUSTIFICATION:
dispatcher.
three lines at the same time. It also is not possible to have effective communications on one line while the other phone is ringing endlessly. To solve these barriers to effective communications, the work stations with multiple phones have been reconfigured by combining the multiple phones on to one instrument. The single instrument phone have speed dial buttons in place of the point-to-point feature. The same locations are still able to be called. The clutter of multiple phones is gone, the noise level in the facilities has been decreased, and the individuals are able to communicate more effectively.
This new setup was field tested during an exercise on May 2,1996 with nothing but positive responses.
6.
Changed the Emergency The ENS and HPN lines are provided by the NRC. The Notification System to read as NRC has made changes to these lines. They are now Federal Telecommunication part of the Federal Telecommunication System as System. Deleted the Health described in section 4.2. This change reflects changes Physics Network designation.
that have already been made by the NRC and now makes (Various figures) the Plan accurate.
7.
Deleted the Logistical Support This supports the discussion of the change described in Center on the figures.
4.a above.
8.
Deleted the corporate offices from The justification for this is in the discussion of 4.b the figures and Figure 4.7.
above.
Per the Plan section 4.1.4 the in-plant radio system is 9.
Deleted the two way radio different from the security radio system. This change communicetion link between makes the communications interfaces consistent with the security and il:e CPSES text of the Plan.
emergency response facilities on the figures.
10.
Deleted the state / county dedicated The BRC has never received information via the system line from the BRC on the state / county line. This line only connects CPSES with
- figures, the local counties and DPS Waco. (See section 4.1.9 of the Plan.) The BRC does receive notifications per the EPPs by telecopier, which is accurately reflected in the communication interfaces. There is a dedicated line in Page 22 of 58
Attachment to TXX - 96492 Emergency Plan Changes and Justifications
]
(Revision 25) j SECTION 4 DESCRIPTION OF CHANGE:
JUSTIFICATION:
both the TSC and EOF which can be used for telephone communications between the plant and the 13RC.
11.
Deleted the telephone link to the The survey teams are dispatched from the OSC with onsite and in-plant survey teams radios. The teams use radios to keep the OSC informed
' 'm the figures.
of status. If the radios were unavailable the plant page j
party system could be used. Telephones could be used by these teams under extraordinary circumstances but they would not be readily available. The current arrangement implies that the telephones would be l
readily available. This change reflects the actual communication links normally used.
i 12.
Added communication links not This revision describes communication links that are previously shown.
readily available for use between the various agencies (new Table 4.1) and facilities. Additions to new table 4.1 clearly define these communication links and are an enhancement to the program.
13.
Section 4.1.6, " Direct Telephone This section describes an existing line to the system Line to System Dispatcher" dispatcher. This line does not include a speaker circuit.
This change reflects as built design of the line.
l Deleted words "and speaker l
circuit."
1 Page 23 of 58
.-=
. -. ~ -
Attachment to TXX - 96492 Emergency Plan Changes and Justifications (Revision 25) 1 SECTION 6 DESCRIPTION OF CliANGE:
JUSTIFICATION:
i 9
1.
Section 6.0, first paragraph, first This provides consistency throughout the Plan, when sentence, Added the word discussing the ERO.
" Response" i
)
2.
Section 6.0, first paragraph, The addition of the word " staffed" adds to the discussion second sentence, relocated the of the section. Deleting the rest of the sentence is a
l information to section 6.1.3, appropriate since section 6.1 now describes the Control added the words " staffed", deleted Room.
the words "and thus is not considered in this discussion."
3.
Section 6.0, second paragraph, The facility layouts were required when all the j
second sentence, deleted the emergency equipment and telephones were stored in I
words " Facility layouts and."
lockers. The equipment is now setup in the facility along with the phones. A facility layout is no longer required to arrange the facility; therefore, the layout i
diagrams have been deleted.
4.
Section 6.0, second paragraph, Duties and responsibilities of key ERO positions are last sentence, deleted the sentence.
described in section 1.1.2. Other support personnel responsibilities are described in the EPPs, as appropriate, as stated in section 1.0.
5.
Added new section 6.1 to discuss The Plan discusses Control Room duties and the Control Room.
responsibilities in section 1.0 and the Control Room is mentioned throughout the Plan. This information provides consistency for the Plan.
6.
Revised section 6.1 as new section llaving descriptive information for an emergency 6.2. Combined information from response facility (ERF) in two separate Licensing Basis the FSAR since the FSAR, Documents (LBD's)is cumbersome and redundant. The Section Ill.A.I.2, also describes information in the two documents were not exactly the the TSC. Arranged the same but led to interpretations that could be different.
information into appropriate By combining the information and describing in the Plan subsections to match FSAR only, there is a single source ofinformation describing format.
this ERF. The intent of the infonnation remains unchanged.
7.
In rewriting section 6.1 into new
- a. seejustification #6, above.
section 6.2, editorial changes were Page 24 of 58
Attachment to TXX - 96492 Emergcncy Plan Changes and Justifications (Revision 25) 4 SECTION 6 DESCRIPTION OF CHANGE:
JUSTIFICATION.
made as follows to the
- b. seejustification #6, above.
information to allow the combination of the sections and
- c. The time to activate the CPSES emergency response splitting the information into facilities (ERFs) (i.e. TSC, EOF, and OSC) is "as soon subsections.
as possible" after notification following a classification of alert or site area emergency as applicable. This a.
1st para., Ist and 2nd sentences; activation time has nat changed. The goal of achieving l
2nd para., last sentence; and facility activation "within 60 minutes"is an estimate i
3rd para.,2nd,3rd, and 4th based on several factors including emergency response l
sentences.
organization demographics, assumed weather conditions, l
changes in surrounding general population density, Combined with information from traffic control and/or road system development, and
(
FSAR III.A.l.2 and relocated to consideration of all significant steps in an individuals section new 6.2.1.
physical preparation and travel from home to the ERFs.
This change from "60" to "70" minutes simply provides b.
Ist para.,3rd sentence; and an updated estimate to the expected achievable time for 3rd para., Ist sentence.
facility activation,(see change for Appendix M). The expected timing for facility activation still remains "as Combined with information from soon as possible." On this basis, this change does not l
FSAR III.A.I.2 and relocated to decrease the effectiveness of the emergency new section 6.2.3.
preparedness program. It only represents a change in the estimate based on more current information of the l
c.
The goal or estimate for activating contributing factors.
emergency response facilities is changed from "60 minutes"to "70
- d. seejustification #6, above.
minutes."
- e. This information is personnel duties and d.
2nd para.,1st sentence, combined responsibilities, which is discussed in new section with information from FSAR 1.1.2.2 and shown in new Figure 1.3.
III.A.I.2 and relocated to new i
section 6.2.2.
2nd para.,2nd sentence, combined with information from FSAR III.A.I.2 and relocated to new section 6.2.6.
2nd para.,3rd sentence, combined with -
information from FSAR Ill.A.I.2 and relocated to new section 6.2.4.
Page 25 of 58
Attachment to TXX - 96492 Emcrg::ncy Plan Changes and Justifications (Revision 25)
SECTION 6 DESCRIPTION OF CHANGE:
JUSTIFICATION:
2nd para.,4th sentence, combined with information from FSAR llI.A.l.2 and relocated to new sections 6.2.8 and 6.2.9.
6.1.5/Figl.2/ Fig 1.3; 3rd para.,last three sentences, Combined with information from FSAR IILA.l.2 and relocated to new section 6.1.5. The information about the Ops Coord and Ops Advisoris shown on new Fig.1.2 and 1.3.
c.
Fourth paragraph, deleted.
8.
Revised section 6.2 into new See justification for Section 6, item 6.
section 6.3. Combined information from the FSAR since the FSAR, Section Ill.A.l.2, also discusses the OSC. Arranged the information into the appropriate subsections to match FSAR l
format.
i 9.
In rewriting section 6.2 into new a.
seejustification for Section 6, item 6.
section 6.3, editorial changes were made as follows to the b.
see justification for Section 6, item 6.
information to allow the combination of the sections and c.
see justification for Section 6, item 6.
splitting the information into subsections.
d.
The rooms and offices that the OSC are contained within have been renamed. The a.
Ist para,1st sentence, combined changes to the Plan reflect the current room with information from FSAR naming.
Ill.A.I.2 and relocated to new section 6.3.1.
e.
Relocated the information to the appropriate b.
Ist para,2nd sentence. combined subsection. Deleted the reference to the LSC with information from FSAR because the LSC as a dedicated ERF is being Ill.A.l.2 and relocated to section deleted (see section 1, item 24, and section 6, 4.0 and Table 4.2.
item 14). Reworded the sentence after deleting c.
Ist para,3rd and 4th sentences, the LSC so that the sentence reads clearly, combined with information from Page 26 of 58
i Attachment to TXX - 96492 l
Emergency Plan Changes and Justifications (Revision 25)
SECTION 6 DESCRIPTION OF CIIANGE:
JUSTIFICATION:
FSAR III.A.I.2 and relocated to f.
see justification for Section 6, item 6.
new section 6.3.2.
d.
Revised the rooms and offices that g.
This information is redundant to information in the OSC is located within.
section 6.11.
c.
Ist para, last sentence, relocated the information to new section h.
This information is personnel duties and 6.3.4. Also deleted the reference responsibilities which is covered in section to the Logistical Support Center 1.1.2.2. The responsibility is covered also in and reworded the sentence.
Table 1.1.
f.
2nd para,1st sentence, combined with information from FSAR lil.A.l.2 and relocated to new section 6.3.3.
g.
2nd para,2nd and 3rd sentences, revised the information and relocated to section 6.11.
h.
2nd para, last sentence, deleted the information.
10.
Revised section 6.3 into new See justification for Section 6, item 6.
section 6.4. Combined information from the FSAR since the FSAR, Section Ill.A.I.2, also discusses the EOF. Arranged the information into the appropriate subsections to match FSAR format.
j 11.
In rewriting section 6.3 into new a.
seejustification for Section 6, item 6.
section 6.4, editorial changes were made as follows to the b.
see justification for Section 6, item 6.
infonnation to allow the combination of the sections and c.
see justification for Section 6, item 6.
i splitting the information into subsections.
d.
see justification for Section 6, item 6.
a.
1st para,1st three sentences, e.
seejustification for Section 6, item 7.c.
combined with information from FSAR III.A.l.2 and relocated to f.
see justification for Section 6, item 6.
new section 6.4.1.
Page 27 of 58
Attachment to TXX - 96492 Emergency Plan Changes and Justifications (Revision 25)
SECTION 6 DESCRIPTION OF CliANGE:
JUSTIFICATION:
b.
Ist para, last sentence, combined g.
seejustification for Section 6, item 6.
with information from FSAR lll.A.I.2 and relocated to section h.
This information is a description of the NOSF new 6.4.2.
and not the EOF. The News Center is described c.
2nd para, combined with in new section 6.5. The decon facilities are i
information from FSAR III.A.I.2 describes in section 9.3. The lab facilities are and relocated to new section 6.4.4.
described in the FSAR section II.B.3.4.
d.
3rd para,1st sentence and 4th para, last sentence, combined with i.
seejustification for Section 6, item 6.
information from FSAR III.A.l.2 and relocated to new section 6.4.3.
j.
Section 1.0 is for discussion of duties and e.
Changed the facility activation responsibilities. The EOF positions are time from goal of 60 minutes to discussed in section 1.1.2.2. The EOF i
70 minutes.
organization is shown in Fig 1.5. Table 1.1 f.
3rd para,2nd sentence, combined shows the functional responsibilities and with information from FSAR minimum stalling. Section 1.0 already states that III.A.I.2 and relocated to new ERO responsibilities are in EPPs, as appropriate.
section 6.4.8.
This information is redundant as described above l
g.
3rd para,3rd sentence, combined and is deleted.
with information from FSAR Ill.A.I.2 and relocated to new section 6.4.9. The communications comments are addressed by section 4.0 and Table 4.2.
h.
3rd para,4th sentence, deleted.
i.
3rd para,5th sentence, combined with infonnation from FSAR Ill.A.l.2 and relocated to new section 6.4.4.
j.
4th para; 1st,2nd, and 3rd sentences. This information relocated to section 1.1.2.2, Fig 1.5, and Table 1.1.
12.
Revised section 6.4 into new Only reformatted this section.
section 6.5 to be consistent with the format of the previous facility discussions. Intent of the infbrmation remains unchanged.
Page 28 of 58
Attachment to TXX - 96492 Emergancy Pl:n Changcs and Justifications (Revision 25)
SECTION 6 DESCRIPTION OF CIIANGE:
JUSTIFICATION:
13.
In rewriting section 6.4, editorial
- a. Revised section to be consistent with the format of changes were made as follows to the previous facility discussions.
the information to allow the combination of the sections and
- b. Revised section to be consistent with the format of splitting the information into the previous facility discussions.
subsections.
- c. Revised section to be consistent with the format of a.
Ist para,1st sentence, relocated to the previous facility discussions.
new section 6.5.1.
b.
Ist para,2nd sentence, relocated
- d. Relocated the infonnation to section 6.5.3. Revised to new section 6.5.4.
to be consistent with the other facility activation c.
1st para,3rd sentence, relocated to statements.
j section 6.5.2.
- e. Section 1.0 discusses duty and responsibilities of the d.
2nd para,1st sentence, revised ERO. News Center Manager position is being deleted, and relocated to section 6.5.3.
but the tasks of the position are being transferred to other i
e.
2nd para,2nd sentence, deleted News Center staff positions. The Company the information.
Spokesperson is the lead person in the News Center, f.
3rd para, relocated information to The Company Spokesperson is discussed in section new section 6.5.5.
1.1.2.2. The News Center organization is shown in Fig.
1.6. Table 1.1 assigns public information responsibilities to the Company Spokesperson.
- f. Revised section to be consistent with the format of the previous facility discussions.
14.
Section 6.5; deleted the entire The functions that have been carried out by the LSC are section.
being transferred to the EOF. Personnel previously assigned to the LSC are being reassigned to the EOF.
Fig 1.5 shows the new EOF organization.
15.
Section 6.6 is being combined See justification for Section 6, item 6.
with information from FSAR Ill.A.I.2. The material that is specific to a facility is being relocated to the respective facility habitability section. The generic information will rcmain in section 6.6.
16.
In rewriting section 6.6, editorial
- a. The entire section 6.0 is revised to describe the Page 29 of 58
Attachment to TXX - 96492 Emergency Plan Changes and Justifications (Revision 25) i SECTION 6 DESCRIPTION OF CIIANGE:
JUSTIFICATION:
changes were made as follows to specifications in NUREG-0696. The statement does not the information to allow the need to be in the Plan and is redundant to discussion in combination of the sections and FS AR Ill.A.1.2.
splitting the information into i
subsections.
- b. Combined with information from FSAR section Ill.A.I.2 and relocated to the TSC habitability section 4
a.
Ist para, Ist sentence, deleted 6.2.6.
b.
1st para,2nd sentence, relocated the information to section 6.2.6.
- c. The LSC as a separate facility is being deleted (see c.
Ist para,3rd sentence, deleted the section 1, item 24, and section 6, item 14). Combined i
LSC, relocated the OSC with FSAR section III.A.I.2 and relocated to the OSC information to section 6.3.4 and habitability section 6.3.4. and News Center habitability the News Center information to section 6.5.5.
section 6.5.5.
d.
1st para, last two sentences,
- d. Combined with information from FSAR section e
relocated the information to Ill.A.l.2 and relocated to the EOF habitability section j
section 6.4.6.
6.4.6.
i e.
2nd para,1st and 2nd sentences, relocated this information to each
- e. The CR and TSC are designed to be habitable during facility discussion on habitability.
design basis accidents, per new section 6.1.4. The OSC, l
f.
2nd para, last sentences, revised EOF, and News Center have discussion of habitability the wording of the last sentence.
and action for facility evacuation, per new sections 6.3.4, l
g.
3rd para, relocated information to 6.4.6, and 6.5.5 respectively.
j new section 6.4.6.
- f. New words allowed transition to what follows based i
on preceding information being relocated. The intent of j
the sentences remains unchanged.
4 4
- g. This information more appropriate in the discussion of the EOF. Information remains unchanged.
17.
Section 6.7; Ist para, revised the The lab is locatedjust outside the EOF. The text description to site location relative description makes it clear where the lab is without to the EOF rather than refer to a referring to a figure, figure.
I 8.
Section 6.7; 2nd para, replaced The subject lab is actually for training purposes by the with a reference to the FSAR chemistry section. Chemistry and Chemistry Training section II.B.3.4.
maintain the lab and lab equipment. If required, the lab could be made ready for sampling as discussed in the Page 30 of 58
~ - _ - -
Attachment to TXX - 96492 Emergency PI:n Chnngts and Justifications (Revision 25)
SECTION 6 DESCRIPTION OF CHANGE:
JUSTIFICATION:
FSAR. The information in the Plan is verbatim to information contained in the FSAR in a complete section on the PASS. The information is more appropriate to i
remain in the FSAR with a reference to this information in the Plan.
I 19.
Revised section 6.8 to provide In section 1.0 of the Plan, outside support resources are only a list of the labs available.
identified. Also in section 1.0, more detail is provided Deleted the information about the labs; therefore, only listed the labs in section associated with the labs.
6.8 and referred to the more detailed descriptions in section 1.0.
20.
Deleted the infonnation in section The FSAR section 12.5.2.2 describes the in-plant decon 6.9. Replaced with a reference facility. The Plan section 9.3 describes the NOSF decon 3
where the information can be facility. The Plan (section 6.9) now references these j
- found, descriptions to prevent redundancy. The information about liquid and solid waste is relocated to section 9.3.
21.
Deleted the information in section Section 10.0 revised to adequately describe the 1
6.10. Replaced with a reference emergency aid facilities. A reference to the information i
i to section 10.0.
in section 10.0 removes redundancy.
l 22.
Section 6.11; 1st para, deleted the The listing of ERF's is redundant since the sentence listing of ERF's, revised already states "each". The frequency ofinventories has frequency ofinventories, added been changed from monthly to quarterly. This change is information on correcting consistent with guidance provided in NUREG-0654, problems, and recorded criteria H.10, and is supported by an evaluation of the infonnation.
occurrence and significance of past observed discrepancies. In order to assess the effect of this change, the results of past monthly inventories was evaluated. The evaluation concluded that the number and significance of the inventory discrepancies observed would not make any difference with respect to inventory 2
frequency and the effective availability of the subject equipment and supplies. The evaluation found only minor (insignificant) discrepancies during the period and i
no significant discrepancies. Regardless of whether the observed minor discrepancies are considered monthly, or totaled and considered cumulatively every three months, the result is the same, i.e., no significant unavailability Page 31 of 58
.~
Attachment to TXX - 96492 l
Emergency Plan Changes and Justifications (Revision 25)
SECTION 6 DESCRIPTION OF CIIANGE:
JUSTIFICATION:
of the dedicated emergency response equipment or supplies. On the basis of the above discussion and historical evaluation, and in consideration that storage locations and storage inventory practices have not otherwise changed, it is concluded that the inventory frequency for emergency response equipment and supplies may be changed from monthly to quarterly without decreasing the expected availability of the subject equipment or supplies. Accordingly, there is no decrease in the effectiveness of the emergency preparedness program.
23.
Section 6.11; deleted the 2nd para.
The infonnation deleted is described in Appendix J of the Plan. Deletion of the material prevents redundancy.
24.
Section 6.11; 3rd para, relocated Section 8.0 of the Plan discusses protective measures.
information to section 8.1.6.
KI is a protective measure, so the information is more Deleted " federal" as a group for appropriate in section 8.1.6. There are no requirements whom CPSES stockpiles KI.
for making K1 available for federal workers. A check with NRC Region IV Offices confirmed that CPSES i
does not need to supply federal workers with KI, so
" federal" was deleted.
25.
Section 6.11; last two paras, Appendix J is the Plan section where equipment and kits j
relocated information to are described. This information is more appropriate in Appendix J.
Appendix J.
26.
Section 6.12; 1st two paras, The new section provides for the establishment, location, i
revised the information.
and provides a reference where more detailed information can be found. The intent of the information remains unchanged.
l 27.
Section 6.12; 3rd para, relocated Section 1.0 discusses duties and responsibilities of ERO the information.
personnel. Section 1.2.2 provides a discussion of the advisor's for the local EOC's. The information is more appropriate in section 1.2.2 than in section 6.12 so the information has been relocated.
28.
Section 6.13; changed the word NUREG-065411.5 provides guidance for information in
" describe" to " identify",
this section. NUREG-0654 states that the licensee l
l Page 32 of 58
Attachment to TXX - 96492 Emergency Pl:n Changes and Justifications (Revision 25) i SECTION 6 DESCRIPTION OF CHANGE:
JUSTIFICATION:
should identify and establish assessment systems and equipment. The guidance does not specify or require detailed descriptions of the identified systems or equipment. Therefore, the systems and equipment that have been identified are listed in section 13.0. The detailed system descriptions have been deleted since j
they are not required. The details have been replaced with a functional statement of the system or equipment and a reference to where the details can be found (e.g.
FSAR). Also added where the systems can be accessed where appropriate. The deleted information was "for information only" and no actions required by the ERO have been deleted. The corresponding Figures and Tables have also been deleted.
29.
Tables 6.1,6.2, and 6.3.
Seejustification for Section 6, item 28 Deleted these Tables.
30.
- a. Figures 6.1, 6.2, 6.3, 6.4, 6.5,
- a. Seejustification for Section 6, item 28.
and 6.6.
Deleted these figures.
- b. Seejustification for Section 1, item 24 and Section 6, item 14.
- b. Figure 6.7.
Deleted this figure.
Page 33 of 58
Attachment to TXX - 96492 Emergency PI:n Changes and Justifications (Revision 25)
SECTION 7.0 l
DESCRIPTION OF CIIANGE:
JUSTIFICATION:
1.
Section 7.0, third paragraph, EPP-117 is an administrative procedure. The changed Emergency Plan information contained in EPP-117 is duplicated in the Procedures to Chemistry Position Assistance Documents, Chemistry Procedures Procedures.
and Chemistry Instructions. Deletion of EPP-117 will increase the efficiency of PASS Teams by deleting redundant information.
2.a)
Section 7.3.2, second paragraph, a) Updated locations for these environmental monitoring changed Emergency Plan locations are contained in Plant procedures. This Procedures to Plant Procedures.
removes a reference to a redundant source of information.
b)
Section 7.3.2, second paragraph, deleted reference to Table 6.3.
b) See justification for Section 6, item 28.
i
)
i Page 34 of 58
1 Attachment to TXX - 96492 Emergency Plan Changes and Justifications (Revision 25)
SECTION 8 4
DESCRIPTION OF CIIANGE:
JUSTIFICATION:
Reformatted entire Section 8 of the Plan.
Reformatted in order to group onsite protective response separately from offsite protective response. The current mix of these two concepts is confusing and causes much repetition ofinformation within this section.
1 All required concepts of protective response that were addressed in the old Section 8 are addressed by the new 4
Section 8.
1.
Reworded section 8.0.
Definition and descriptive information only.
2.
Section 8.1.1, deleted site Site description redundant to FSAR Section 2.1..
description.
)
3.
Changed the term " plant New term is cleaner and more encompassing.
Employees, contractors, and visitors" to "onsite plant personnel and visitors".
4.
Section 8.1.1, deleted description System description redundant to FSAR section 9.5.2.
of the Plant Page-Party System.
1 5.
First two paragraphs of 8.1.2, Site description and listing of activities permitted within deleted site description and list of owner controlled areas redundant to FSAR Section 2.1.2.
l activities permitted within owner controlled areas.
6.
3rd paragraph of 8.1.2, warning of Now grouped with other offsite protective actions for offsite personnel within owner consistency.
controlled areas was relocated to new Section 8.2.
7.
Last sentence of 3rd paragraph of This is a statement of an expectation or planning 8.1.2, deleted statement of standard. No specific actions possible.
expectation to warn all personnel of the emergency before it effects them.
8.
First 2 paragraphs of section 8.2 Creation of a separate section (8.1.1.) dealing just with rewritten into new section 8.1.1, evacuations effecting onsite personnel consolidates Page 35 of 58
Attachment to TXX - 96492 Ernergency Phn Changes and Justifications (Revision 25)
SECTION 8 d
DESCRIPTION OF CIIANGE:
JUSTIFICATION:
" Evacuation".
information previously found among several d
subsections.
9.
The statement allowing an early This capability (evacuation at any classification) is dismissal of non-TU Electric clearly discussed in the first paragraph of the new engineering and construction section 8.1.1. The group encompassed by the term "non-personnel (3rd para. of 8.2) was TU Electric engineering and construction personnel" is deleted.
no longer applicable at CPSES.
4 10.
Changed "The Emergency The first paragraph of the new section 8.1.1 allows the Coordinator shall declare a site EC to usejudgement in deciding whether an evacuation evacuation if the emergency presents a higher risk to evacuating personnel than classification is a SAE..." to a remaining in place.
should statement (1st sentence of 4th para. 8.2) 11.
Area affected by a site evacuation Creation of a separate section (8.1.1.) dealing just with j
and responsibilities (5th para of evacuations affecting onsite personnel consolidates 8.2) rewritten into new section information previously discussed in several subsections.
8.1.1.
4 12.
Details concerning actions taken Squaw Creek Park (SCP) maintains an emergency plan by Squaw Creek Park personnelin that details actions to be taken in response to an response to an evacuation emergency declaration or ordered evacuation. SCP is declaration are removed from this notified in accordance with EPPs.
section.
13.
Accountability (6th and 7th para New section 8.1.2 of 8.2) rewritten into it's own a.
Accountability is defined in App. Q. Removes section, with the following redundant information from the section.
changes:
b.
Plant procedures better implement the methods to a.
what constitutes accountability accomplish this task, has been removed.
c.
No action is necessary by the facility managers.
b.
removed discussion of Security performs initial accountability whether accountability methods (security the facilities are activated or not.
computer).
d.
This change allows the normal Security and c.
removed action by facility emergency response organization chain of 1
managers to accomplish initial command to be used to handle this report. Plant j
accountability.
procedures better implement the methods to d.
Results of accountability are report accountability results and to locate missing Page 36 of 58
Attachment to TXX - 96492 Emergency Plzn Changes and Justifications (Revision 25)
SECTION 8 DESCRIPTION OF CIIANGE:
JUSTIFICATION:
reported as specified by plant personnel.
procedures versus always straight to the EC.
14.
Section 8.2, deleted site NUREG 0654, section J.8 specifically requires plume evacuation time estimate.
exposure EPZ evacuation time estimates only. An EAB evacuation estimate was performed to verify attributes of the Plan evacuation scheme, but it is not required to be included in the Plan.
15.
Section 8.3(1st para.). changed to New section 8.1.3 discusses the availability of offsite offsite radiological monitoring of reception centers for radiological monitoring of site site evacuees (if necesrary) by evacuees if deemed necessary by the EC.
offsite reception centerr versus radiological monitoring :eams dispatched from the plant.
16.
Section 8.3(2nd para.), deleted.
Covered in sections 6 and 9. These supplies and facilities are not intended for support of a site evacuation effort.
17.
Section 8.3(3rd and 4th para.),
Since evacuees are to be directed to an offsite reception deleted.
center for monitoring and decontamination, this detail is not necessary in the Plan.
18.
Section 8.4, deleted.
Covered in new section 8.1 19.
Section 8.4.1, Respiratory a.
CR breathing air (SCBAs and spare air) is Protection, rewritten into new discussed in FSAR section 6.4.1.3.
section 8.1.4, with the following b.
Supply and maintenance of EOF respiratory changes:
protective equipment is controlled by the Plan, a.
does not discuss CR breathing air Section 6 and Appendix J.
b, does not discuss supply and c.
These are not onsite facilities. Protective maintenance of EOF respirators measures (habitability assessment / relocation) c.
deleted mention of NC and LSC for these facilities are handled by plant procedures.
20.
Protective Clothing (section 8.4.2) a.
editorial changes with no change ofintent rewritten into new section 8.1.5, b.
CPSES has no intention of dressing out everyone with the following changes:
in all facilities. Normal RP supplies of protective a.
minor wording changes clothing will ensure an adequate quantity are Page 37 of 58
Attachment to TXX - 96492 Emergency Pl n Changes and Justifications (Revision 25)
SECTION 8 DESCRIPTION OF CIIANGE:
JUSTIFICATION:
b.
delete mention of quantity available for the limited population during an
~
of PCS available, emergency.
21.
Section 8.4.3, Radioprotective This change identifies that KI quantities and stockpile Drugs, is revised to new Section locations will be cited in an implementing procedure or i
8.1.6.
other instructions. This change identifies that State and Local Governments also play a roll in the use of KI based on their respective plans. This change meets the intent of NUREG 0654 and allows CPSES the flexibility to change the specific amounts without making a Plan change in the future 22.
Section 8.5, Offsite Protective a.
EBS message information is only one aspect Actions, rewritten into new implemented by the local officials; this section 8.2, with the following information is included in the local Plans and is changes:
not appropriate here.
a.
2nd half of 1st para. concerning b.
This information is contained within section 3.0 implementation of protective of the Plan.
3 action decisions is deleted c.
Minor editorial changes without change ofintent.
b.
2nd para. is deleted c.
3rd para is reworded into the 2nd para of the new section 8.2 23.
Section 8.5.1, revised discussion Intent of the paragraph is unchanged but revised to be of EPZs that started section 8.5.1; more concise and consistent with the way the rest of the new section 8.2.1.
Plan has been revised.
1 24.
Section 8.5.l(2nd para), deleted This makes the descriptions in the Plan consistent with CPSES owner-controlled area information provided to the public and consistent with from description of zones and the definition of an EPZ Zone descriptions and details 3
j removed reference to the number are included in Appendix F and G of this Plan.
ofzones.
25.
Section 8.5.l(3rd para.), split New format improves information presentation and between new sections 8.2 and clarity.
8.2.2.
26.
Section 8.5.2, rewiitten into new Evacuation plans are included in the local county plans section 8.2.2. Removed the and are administered therein.
developmental reference to Page 38 of 58
Attachment to TXX - 96492 Emergency Plan Ching:s and Justifications (Revision 25) i SECTION 8 DESCRIPTION OF CHANGE:
JUSTIFICATION:
a.
NUREG-0654, 27.
Section 8.5.3, deleted reference to Not needed by CPSES ERO personnel. Part of county EPZ evacuation maps.
plans.
i 28.
Section 8.5.4, deleted reference to Not needed by CPSES ERO personnel. Part of county population distribution maps.
plans.
I 29.
Section 8.5.5, deleted reference to Not needed by CPSES ERO personnel. Part of county maps showing special facilities plans.
within the EPZ.
30.
Section 8.5.6, rewritten into new New format improves information presentation and section 8.2 without reference to clarity. SANDIA studies have been superseded by EPA-SANDIA studies.
400-R-92-001.
1 i
4 Page 39 of 58
~. - -... _ -...
Attachment to TXX - 96492 Emergency Plan Changes and Justifications (Revision 25)
{
SECTION 9 i
DESCRIPTION OF CIIANGE:
.IUSTIFICATION:
1 1.
Deleted description ofin-plant Redundant to FSAR, Section 12.5 decontamination facilities; now i
references FSAR Section 12.5.
2.
Relocates information from Relocation ofinformation within the Plan.
I Section 6.9 of the Plan to i
Section 9.3 3.
Delete Figure 9.1 Redundant to FSAR, Section 12.5 4.
Revise Figure 9.2 Shows redistribution and redesignation of work space in the Decontamination Area.
l Page 40 of 58
l l
Attachment to TXX - 96492 i
Emergency Plan Changes and Justifications j
(Revision 25) i l
SECTION 11 l
\\
DESCRIPTION OF CIIANGE:
JUSTIFICATION-l 1
1.
Section 11.0,3rd para.; changes Changed to reflect new title in Plan section 1.
)
i title from TSC Advisor to TSC Communications Coordinator.
2.
Section 11.0,4th para., line 2; This is a vital consideration for initial plant recovery added phrase " verification of actions.
system / equipment status and alignment" 3.
Section 11.0,6th para., line 2; Reworded to clarify that the concern to be addressed replace "a previously evacuated here is " radiological hazards."
area" with " an area previously evacuated for radiological reasons".
l 4.
Section 11.1,line 1; revised See discussion for Section 1, item 34 and new Section reference to corporate support.
1.2.1.
5.
Section 11.1.1.1,1st para., line 2; This goal could be an unrealistic expectation of the removed the goal of restoring recovery organization. The goals of the Recovery j
CPSES to fully operational status.
Organization are stated in 11.0,1st sentence.
6.
Section 11.1.1.1, Ist para., line 3:
The current requirement to designate an individual who changes who is selected for the is trained as an Emergency Coordinator is not regulatory position of Recovery Manager.
driven and is not appropriate since the site is exiting the 1
emergency phase and entering the recovery phase, i
7.
Section 11.1.1.1,2nd para.; delete Sentence is redundant to statement / intent of the first part the last sentence.
of the same paragraph and new section 11.1.1.4.
8.
Section 11.1.1.3, b and d; delete Both CPSES units are operational and no longer have "and construction".
construction activities.
9.
Section i1.1.1.4; revised See discussion for Section 1, item 34 and new Section discussion of corporate support.
1.2.1.
i' 10.
Section 11.2; revised the section.
The current statement describes station activities that l
support ongoing license compliance, not emergency l
response efforts. The State of Texas Emergency Management Plan covers this information during Page 41 of 58
_ _ _ - ~
- Attachment to TXX - 96492 Emergancy Plan Changes and Justifications (Revision 25)
SECTION 11 l
DESCRIPTION OF CHANGE:
JUSTIFICATION:
emergency response.
3 11.
Figure 11.1; delete the word The intent of this figure is to show support available
" office" from corporate support.
from the corporate level, not a particular office.
i 1
I I
1 4
?
l 4
)
i i
Page 42 of 58
~.-
Attachment to TXX - 96492 Emsrgency Plan Chrnges and Justifications (Revision 25) 1 SECTION 12 DESCRIPTION OF CIIANGE:
JUSTIFICATION:
l.
Section 12.1, changed " annual" to Federal Register (6/14/96) changed 10CFR50 App. E
" biennial."
from a requirement to hold an annual full participation exercise to a biennial requirement. This change matches 9
the Plan to the current requirements.
2.
Section 12.0 and 12.3, changed Changed to reflect current CPSES Organization titles "Vice President ofNuclear and responsibilities per FSAR Chapter 13.1.
Operations" to " Plant Manager."
f h
Page 43 of 58
Attachment to TXX - 96492 Emsrgency Plen Changes and Justifications (Revision 25)
SECTION 13 DESCRIPTION OF CilANGE:
JUSTIFICATION:
i 1.
Section 13.0,1st para., Rewrote The Emergency Preparedness Training Program is the first two sentences to be more administered at group levels. The extent of training that concise.
each group receives is dependent upon the individual's responsibility to emergency planning. The groups are divided as Plant Staff (personnel employed or contracted by TU Electric who are involved in the operation, i
construction, maintenance or support of operation, construction, maintenance at CPSES-and are non ERO members), On-shift Staff (ERO members),
Augmentation Staff (ERO members), and Offsite Response Agencies.
The Plant Staff (non-ERO) personnel have no emergency preparedness duties and responsibilities other than reporting emergencies. Section 13.0 as rewritten describes what information the non-ERO members are i
required to receive (reporting emergencies and expected actions in case of an emergency). The details of how the information is delivered to the individuals is described in TRA-105, " Emergency Preparedness Training" as stated in section 13.0 of the Plan.
i i
This training meets and exceeds the requirements of 10CFR19.12, Instruction to Workers.
2.
Section 13.0,1st para., Deleted This part of the second sentence was a "maybe" clause the end of the second sentence.
that pmvided no realinformation. Section 13.0 now Deleted the 3rd sentence.
states what information non-ERO personnel are to 4
receive. TRA-105 outlines the details of how this information is actually disseminated.
The third sentence was deleted because the information is not training related. As stated in the rewrite, non-ERO members are given information on reporting emergencies and expected actions in case of an emergency. These expected actions are detailed in
,l section 8.1.1,8.1.2, and 8.2 of the Plan. ERO members are directed to report to their respective facility. As stated in the Plan, personnel should follow instructions provided over the announcing system or by Security.
Page 44 of 58
Attachment to TXX - 96492 Em:rgency P12n Chrnges and Justifications SECTION 13 DESCRIPTION OF CIIANGE:
JUSTIFICATION:
Therefore there is no utility in making the statement that the information is posted around the site.
3.
Section 13.0,2nd para.,
in the rewrite of the sentence added the information that Reworded the Grst sentence.
TRA-105 outlines the training requirements for personnel who routinely visit or are assigned to the site.
This would include non-ERO personnel. The sentence previously only pertained to ERO members. This change combines the information in the above changes with the ERO training requirements. The intent to provide information to non-ERO personnel and train ERO members in their specine duties and responsibilities remains unchanged.
4.
Section 13.0,2nd para., Deleted The second sentence is nothing more than a description the second and third sentences.
of procedure TRA-105," Emergency Preparedness Training." Based on the rewrite of section 13.0, this descriptive information is already contained in the Grst sentence of section 13.0. Therefore, there is no need to repeat the information.
The third sentence is an administrative function put into place to prevent unqualined personnel from being assigned to the 130 Roster. This section deals with the training that ERO personnel receive not the administrative workings of maintaining the ERO Roster.
As rewritten, the section states that ERO personnel receive training to qualify them for their respective position. The administrative maintenance requirements for the ERO Roster are contained in TRA-105, EPP-100, and Staff Guideline 008. These documents specify that CPSES does not place personnel on the ERO Roster until their qualineation requirements are complete.
5.
Section 13.0,2nd para.,
The intent of this information is already contained in Relocated the fourth sentence to section 14.0. This sentence was relocated to section 14.0 section 14.0 of the Plan.
and rewritten to mesh with what is already in section 14.0. This change only relocates information to another section of the Plan.
6.
Section 13.0,3rd para., Rewrote 10 CFR 50 App E (F)(5) states that all training, Page 45 of 58
l Attachment to TXX - 96492 Em:rgency Plan Changes and Justifications SECTION 13 DESCRIPTION OF CllANGE:
JUSTIFICATION:
4 the paragraph to include including exercises, shall provide for formal critiques...
additional means to provide for formal critique of training.
This change better states what CPSES def'mes as formal critiques. Student feedback is still included as one of four methods that may be used to satisfy the requirement for a formal critique. This change is an enhancement to j
the program.
7.
Section 13.0,4th para., Changed The EP Manager is now responsible for all EP Training.
the responsibility for the This change reflects an organizational change that has Emergency Response Training taken place. This responsibility relocated to section 14.0 Program to Emergency Planning of the Plan.
Manager. Relocated to section 14.0 of the Plan.
8.
Section 13.0,5th para., Deleted The information in this paragraph is redundant of the information from section 13.0.
information that is already in section 14.0 of the Plan.
An annual independent review of the Emergency Plan and Emergency Plan Procedures is conducted by Nuclear Overview Department which was formerly the Quality Assurance Department. The independent review includes emergency preparedness training.
i 9.
Section 13.1, Deleted the 10 CFR 50.47 (b)(15) requires training to personnel who information in this section.
may be called upon to assist in an emergency, but does not specify what that training has to be.10 CFR 50 App E (IV) (F) requires that the Plan provide a description of
{
the training program, not individual training modules.
i Section 13 as rewritten provides the description of the i
training program based upon the level ofinvolvement with emergency related activities. The section specifies who will be trained and what level of training they will receive; with the specifics of how the program is implemented being outlined in procedure TRA-105, j
" Emergency Preparedness Training."
The level of detail provided by section 13.1 far exceeds 3
the level of detail required by the regulations. This level i
of detail is appropriate for the procedure TRA-105.
10.
Section 13.2, Deleted the This section (13.2) states that ERO members are Page 46 of 58
Attachment to TXX - 96492 Emergency Plan Changes and Justifications SECTION 13 DESCRIPTION OF CIIANGE:
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information in this section.
provided training under a list of broad categories. The rewrite states that personnel assigned to the ERO receive training to qualify them for their respective position.
However, the broad list of categories has been deleted based upon the following discussion.
Section 1.0 of the Plan assigns duties and responsibilities for functions that must be conducted in an emergency as well as the expected responses for the different classification levels. This is where the broad list of functions, duties and responsibilities exists.
Emergency Planning has conducted ajob and task analysis for each position of the ERO. Based upon the results of the task analysis, training has been designed to qualify each member of the ERO to perform the duties and responsibilities for their specific function.
In summary, Section 13.0 as rewritten states that i
personnel assigned to the ERO receive training to qualify them for their respective position. The section also states that the training program is outlined in TRA-105, " Emergency Preparedness Training."
Therefore, the intent of 10 CFR 50 App E (IV)(F) is maintained without relisting the categories in section 13.0 of the Plan.
11.
Section 13.3, Deleted the New Table 1.1 of the Plan prescribes that personnel are information in this section.
required to be on shift at all times to provide first aide response. This is a functional responsibility of members of the ERO. Therefore, they must receive training to qualify them for their position. This training is outlined in TRA-105.
NUREG-0654 0.3 provides guidance that this training should be equivalent to Red Cross Multi-Media. The Red Cross Multi-Media course was discontinued in the late 1980's. Ilowever, CPSES has continued to use the most current revision of Red Cross first aid training materials available.
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Attachment to TXX - 96492 Emsrg:ncy P12n Chrnges and Justifications SECTION 13 DESCRIPTION OF CHANGE:
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7 The level of detail, specifying the actual course that must be taken, far exceeds the requirements for information in the Plan. TRA-105 is the proper level for this type of information, and TRA-105 provides for the training requirements for each ERO position. Section 10.2, j
"Onsite First Aid", discusses onsite capability and training for the first aid response.
l 12.
Section 13.4, Deleted the 10 CFR 50.48 and 10 CFR 50 App R outline the
]
information in this section.
requirements for fire protection at nuclear power plants.
FSAR section 13.3B outlines the CPSES Fire Protection Program. Section 13.3B.2.1 outlines the training requirements for the Fire Brigade which includes radiological aspects of fire fighting. With this information in the FSAR, it is not necessary to duplicate any of the information in the Plan.
j i
13.
Section 13.5, Deleted the 10 CFR 73 App B (11) outline the requirements for the information in this section.
training and qualification of security personnel. The CPSES Security Plan and the Security Training and Qualification Plan specify the training requirements for the security force at CPSES. With this information in the Security Plans, it is not necessary to duplicate any of the information in the Plan.
a 14.
Section 13.6 and 13.7. Combined 10 CFR 50.47 (d)(7) requires that radiological these two paragraphs. Revised the emergency response training has been made available to paragraphs to be concise and those offsite who may be called upon to assist in an delete redundant information.
emergency onsite.
The rewrite of sections 13.6 and 13.7 provides for training to be offered to all offsite emergency response organizations who may be called upon to help in an onsite emergency. The current sections 13.6 and 13.7 call for training to only a small group of the ofTsite agencies. Therefore, the rewrite is more encompassing than what was originally written and better implements i
the requirements of 10 CFR 50.47 (d)(7).
l 15.
Section 13.8, Relocated NUREG-0654 discusses this information in section P information to section 14.0.
which is equivalent to section 14.0 of the CPSES Plan.
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For consistency with NUREG-0654, this information is being relocated in the Plan.
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SECTION 14 DESCRIPTION OF CllANGE:
JUSTIFICATION:
1.
Added 1st para to section 14.0.
For consistency this incorporates information relocated from section 13.8 of the Plan. NUREG-0654 contains this information in section P which is equivalent to section 14.0 of the Plan.
2.
Sentence 1; changed title from Reflects organizational change and FSAR 13.1.
"Vice President of Nuclear Operations" to " Plant Manager" 3.
Sentence 2 deleted Written procedures are necessary for the implementation of the Plan and are required by the regulations.
4.
Sentence 3; deleted reference to a Record retention is an aspect of document control and is specific retention period, and addressed by station administrative procedures and changed to read " Copies of the regulatory guidance (ANSI.45.2.4 -1974 " Requirement Emergency Plan and Emergency for Collection, Storage, and Maintenance of Quality Plan Procedures are distributed to Assurance Records for Nuclear Power Plants").
the appropriate individuals and organizations with emergency response / planning responsibilities.
These documents are controlled and changed / revised in accordance with station administrative procedures."
5.
Sentence 4; replace "The Vice
- a. Responsibility for approving changes to the President of Nuclear Operations Emergency Plan remains with the Plant Manager.
shall approve the Emergency Plan and recommended changes to the
- b. The responsibility for approving Emergency Plan Emergency Plan and Emergency Procedures (EPPs), and changes thereto, is reassigned Plan Implementing Procedures."
from the Plant Manager to the Emergency Planning with new sentences 3 and 5.
Manager. This approval is consistent with the regulations and is the management approval practice at a.
sentence 3 - The Plant Manager other industry plants in NRC Region IV.
j has overall responsibility for the emergency preparedness program At the time oflicensing and initial operation of CPSES, and shall approve changes to the the Vice President of Nuclear Operations (Plant Emergency Plan.
Manager) was assigned the responsibility for approving b.
sentence 5 - The Emergency all CPSES Station Administration, Security and Page 50 of 58
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Emergency Plan Changes and Justifications i
(Revision 25) l SECTION 14 DESCRIPTION OF CIIANGE:
JUSTIFICATION:
i Planning Manager shall approve Emergency Preparedness procedures. This level of I
the Emergency Plan Procedures management approval was assigned at the time to most I
and is responsible for maintenance effectively ensure specific program compliance aspects, and coordination of emergency and in addition, to ensure other general plant aspects j
preparedness program and such as broad safew related, operational or i
j training of the Emergency organizational / personnel impacts and overall station l
Response Organization (ERO).
acceptance. It has now been determined that Plant Manager approval for changes to the EPPs adds little or i
no value; therefore, approval should be reassigned to the Emergency Planning Manager to support more effective use of available resources. The 50.54(q) evaluation of l
this change is as follows:
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In order to assess the effect of this change, an evaluation must be made as to the value added by the Plant Manager's review and approval. In the current CPSES procedure approval process, the Emergency Planning Manager reviews and approves EPP changes prior to submittal to the Plant Manager for approval. Because of his day-to-day involvement in emergency preparedness program development and compliance, involvement in current industry issues, interface with onsite CPSES Emergency Organization personnel and offsite officials, l
etc., the Emergency Planning Manager is much more cognizant of emergency preparedness program requirements and impacts than the Plant Manager; therefore it can be assumed that the Plant Manager j
would not add any substance, relative to that already l
added by the Emergency Planning Manager, to the procedure approval process with respect to maintaining emergency preparedness. The Plant Manager might add value regarding broad safety, operational or personnel impacts that go beyond just maintaining emergency preparedness. The Plant Manager might be expected to i
provide management expectations in these areas.
If broad safety or operational concerns were expected, the process should specify operations involvement or
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even SORC review. These are not required by the regulations or the current CPSES Licensing Basis Page 51 of 58 i
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l Emergency Plan Changes and Justifications (Revision 25)
SECTION 14 l
DESCRIPTION OF CIIANGE:
JUSTIFICATION:
l Documents. The only area remaining where value might l
be added is in the area of personnel impacts and management expectations. Personnel concerns are not l
normally resolved or even obvious from the content of procedures. Personnel problems are more likely to surface when emergency organization position l
assignments are made and during drills or training.
l There is ample opportunity at that time for the Plant l
Manager to ensure that any personnel matters are j
addressed to his satisfaction. That leaves management l
expectations as an area for adding value. Although a l
very broad term, management expectations, as they may exist regarding emergency preparedness, are best i
l captured by the Emergency Plan. Changes to the CPSES l
Emergency Plan are already approved by the Plant Manager.
i On the basis of the above discussion, it is concluded that the Plant Manager provides no substantial value to the i
review / approval of EPPs ovcr that value already l
provided by the Emergency Planning Manager; therefore, the change does not decrease the effectiveness of the CPSES emergency preparedness program.
l 6.
Sentence 5 "NRC approval shall This was a redundant statement. NRC approval of be obtained as appropriate" is appropriate changes are inherently obtained because of deleted.
the licensing process and the maintenance of that license as delineated by 10CFR50.54Q.
7.
Sentence 6: review of the Plan The emergency plan procedure review was changed remains on an annual basis, but based on a letter from Thomas P. Gwynn (NRC) to W. J.
l review of the emergency plan Cahill (TU Electric) dated July 31,1994. The enclosure procedures is changed from to this letter entitled " Plant Procedure Review annually to biennially.
Guidance" specified that non-routine procedures
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(procedures such as emergency operating procedures, off normal procedures, procedures which imnlement the smergency nlan, and other procedures which may be dictated by an event) should be reviewed at least every two years and revised as appropriate. Based on this information, and the fact that discrepancies are usually l
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SECTION 14 DESCRIPTION OF CHANGE:
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found from procedure implementation /use during drills or exercises and not from the annual review, leads to the conclusion that this change don not decrease the effectiveness of the emergency preparedness program.
8.
Sentence 7; rewritten and Paragraphs 2 and 3 were combined and rewritten to relocated to sentence 5 of new reflect a logical sequence of the areas of responsibility section.
and the position or organization that is identified with those responsibilities.
9.
Sentence 8; deleted.
Specific responsibilities of the Emergency Planning Group are delineated in the EPPs. The listed examples of responsibilities were encompassed in a categorical j
responsibility statement which is the responsibility of the Emergency Planning Manager. The Manager then assigns tasks as needed to the emergency planners.
10.
Sentence 9; revised wording.
Revision is editorial only to make it fit with the other changes in this section.
'l 11.
Sentence 10; revised sentence to The independent review encompasses the entire expand the scope and relocated to emergency preparedness program, including the Plan j
sentence 13.
and procedures. This review is required by 10CFR50.54(t).
- 12.
Sentence 11; deleted sentence, This sentence is encompassed under the umbrella of addressed by new sentence 13.
emergency preparedness " program". This review is j
required by 10CFR50.54(t) which provides the criteria for program reviews.
13.
Sentence 12; deleted retention This record retention is an aspect of document control period. Revised sentence and and is covered by administrative procedures and required relocated to sentence 14.
by the regulations (10CFR50.54(t)).
14.
Sentence 13; revised sentence and Copies are necessary for effective implementation of the relocated to sentence 9.
Emergency Preparedness Program and station administrative procedures ensures distribution to the appropriate personnel.
15.
Sentence 14; revised sentence and Editorial rewrite for consistency to other parts of the Page 53 of 58
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.i Emergency Plan Changes and Justifications l
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SECTION 14 l
DESCRIPTION OF CHANGE:
JUSTIFICATION:
1 relocated to sentence 10.
Plan.
16.
Sentence 15; deleted sentence.
This is a facet of emergency preparedness maintenance and is encompassed in the maintenance procedure of the emergency preparedness program.
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Attachment to TXX - 96492 Emergency Plan Changes and Justifications (Revision 25)
APPENDIX H I
l DESCRIPTION OF CHANGE:
JUSTIFICATION:
t 1.
Table of Contents, page vii; add 10CFR50.47(b)1 requires that emergency
" List of" to title of Appendix II.
responsibilities of the various supporting organizations have been specifically established. The Plan states in Section 1.1.5 that, " written agreements have been executed with support agencies, as well as private support organizations, having an emergency response role." The Plan describes the support agencies and private sector organizations. The Plan also describes these agencies responsibilities. This DOES NOT change any of the agencies or responsibilities of these agencies.
l This changes merely removes the written agreements from Appendix II, replaces the agreements with a list of I
agreements, and adds a note that Emergency Planning maintains the agreements on file. The letters of agreement will continue to be updated as necessary and i
reviewed annually per the Plan, Section 1.1.5.
r 2.
Last para. of Section 1.1.5; See justification for item 1.
describes Appendix II of the Plan as containing a list of the Letters l
of Agreement versus containing l
the Letters of Agreement i
l themselves.
1 3.
Section 1.3.1; describes Appendix Seejustification for item 1.
l H of the Plan as containing a list i
of the Letters of Agreement i
versus containing the Letters of j
Agreement themselves.
4.
Section 1.3.4.2; references the Seejustification for item 1.
Letter of Agreement, but deletes saying that it is in App. H.
5.
Section 15.0; add " List of" to title See justification for item 1.
of Appendix H.
6.
Appendix II, Title Page; add " List See justification for item 1.
of" to title of Appendix H.
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'n Attachment to TXX - 96492 Emergency Plzn Changes and Justifications (Revision 25)
APPENDIX H DESCRIPTION OF CHANGE:
JUSTIFICATION:
7.
Appendix H; revise listing of See justification for item 1.
Letters of Agreement and Organization titles to reflect current letters maintained.
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Attachment to TXX - 96492 i
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(Revision 25)
APPENDIX J DESCRIPTION OF CHANGE:
JUSTIFICATION:
1.
First paragraph; deletes reference to the See discussion for Section 1, item 24 and Section Logistical Support Center.
6, item 14, 2.
Added information relocated from Relocated information (i.e. number of company Section 6.11 of the Plan.
vehicles available for offsite monitoring) to a more relevant section.
3.
Third paragraph; added information Clarify that inventories are prescribed by and l
concerning equipment inventory and maintained in accordance with an EPP.
l location.
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I Attachment to TXX - 96492 Emergsney Plsn Chrnges and Justifications i
(Revision 25)
APPENDIX M i
DESCRIPTION OF CHANGE:
JUSTIFICATION:
r 1.
Staffing augmentation time T is not addressed in the current' App. M estimates. It estimate formula; added factor T,.
is the time to travel from a responders vehicle to the
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emergency response facility which can take from 5 to 15 minutes depending on the number of security personnel on duty and the number ofother personnel l
trying to access the facility.
l 2.
Changed population distribution Changes in the assumptions made to the staffing l
for ERO domiciles.
evaluation are applicable. Over the past several years since licensing of both units, there has been a shift in the residence locations of CPSES personnel. Since the i
original App. M estimate, more people have moved closer to the site, but for those people that still live outside the Glen Rose / Granbury / Tolar local areas, it takes longer to arrive on site. This is attributed to the installation of traffic lights on the roads traveled to CPSES, even taking into consideration the speed limit increase to 70 mph. There are still a significant number of key ERO personnel that would be challenged to arrive safely in the ERF within the 60 minute goal. These changes reflect the most recent ERO survey.
i 3.
Updated listed travel time These changes reflect the most recent ERO survey.
estimate ranges for the various cities.
4.
Updates goal for TSC and EOF This reflects the changes listed above.
i activation time estimates.
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