ML20135C808
| ML20135C808 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle  |
| Issue date: | 02/27/1997 |
| From: | Brons J COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TAC-M91309, TAC-M91310, TAC-M91311, TAC-M91312, TAC-M91313, TAC-M91314, TAC-M91315, TAC-M91316, TAC-M91317, TAC-M91318, TAC-M91319, TAC-M91320, NUDOCS 9703040306 | |
| Download: ML20135C808 (17) | |
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Ormmonwraith hiiwn Company 1600 Opus Place ih m ner$ Gn n e. II. GM I S Feb.27,1997 U.S. Nuclear Regulatory Commission Washington, DC 20555
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Attentiori:
Document Control Desk
Subject:
Braidwood Station Units 1 and 2 Byron Station Units 1 and 2 Dresden Station Units 1,2, and 3 i
LaSalle County Station Units 1 and 2 i
Quad Cities Station Units 1 and 2 Zion Station Units 1 and 2 Commonwealth Edison Response to: USNRC Request for Additional Information dated 12/17/96 regarding the Central Emergency Operations Facility (TAC Nos. M91309, M91310, M91311, M91312, M91313 M91314, M91315, M91316, M91317, M91318, M91319, M91320) i NRC Dockets 50-454 and 50-455 l
NRC Dockets 50-456 and 50-457 N_RC Dockets 50-10. 50-237 and 50-249 NRC Dockets 50-373 and 50-374 NRC Dockets 50-254 and 50-265 NRC Dockets 50-295 and 50-304
Reference:
1)
Comed letter, John C. Brons' to USNRC dated January 5,1995, l
" Commonwealth Edison Submittal: Proposal to Consolidate Near-Site Emergency Operations Facilities (EOFs) into a Central EOF" 2)
USNRC letter, George F. Dick, to D. L Farrar dated May 23, 1996,
- Request for Additional Information regarding the Central Emergency Operations Facility" 3)
Comed letter to USNRC, John B. Hickman, dated August 5, 040077
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" Response to Request for Additional Information Related to the Proposed Generating Station Emergency Plans (GSEP) Revision incorporating the Corporate EOF as an Interim EOF" t
4)
USNRC letter (G.F. Dick) to Comed (l.M. Johnson) dated I @l December 17,1996, " Request for Additional Information 9703040306 970227 PDR ADOCK 05000010 15g555N111 F
PDR A linicom Lumpan)
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Document Control Desk (2)
Fcbruiry 27,1997 This letter provides the Commonwealth Edison (Comed) response (Attachment 1)
I to the most recent Request for Additional information (Reference 4) pertaining to the consolidabon of Comed's near site Emergency Operations Facilities (EOFs) into a Central EOF (cEOF) (Reference 1). Comed remains firmly convinced that the i
consolidsbon desenbod in Reference 1 provides the most effective response to a classifiable emergency condition in accordance with our Emergency Plan and the i
overall coordinated plan originally contemplated in NUREG-0654/ FEMA Rep.1.
While this proposal was originally submitted as a Cost Beneficial Licensing Action, and remains so today, this emergency plan change enhances our ability to effectively respond to potential emergencies. A list of the other additional benefits is provided as follows:
Prompt " minimum staffing" dunng normal working hours.
e Improved access for greater numbers of Comed responders off hours.
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immediate access to various corporate support organizations.
e Enhanced ability of Senior personnel to quickly respond.
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Increased floor space for Comed, State and Federal Responders.
e Reduced susceptibility to potential near-site problems.
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Proximity to USNRC Regional Headquarters. (10 minute drive time) e 1
Comed proposes to demonstrate the use of the Downers Grove facility as a single EOF (cEOF) for the 1997 Dresden Full State participation exercise in the summer of 1997. It was last successfully demonstrated in this capacity when performing its licensed function as the back-up EOF for Zion Station in a utility only drill.
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l Comed appreciates the opportunity to clarify our submittal. Comed will also make j
arrangements with NRR to schedule a meeting to discuss this further with the Staff.
Please contact Mrs. l.M. Johnson at (830) 663-2096 if you have any questions pertaining to this response or the proposed meeting.
Sincerely, t
%lohn C, Brons i
Nuclear Support Vice-President MV/JCB/hg I
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r EPMisC/ChrerWonk/11 i
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0, Document Control Desk (3)
Fcbru_ry 27, 1997 s
Specific Response to NRC Request for Additional information, (Reference 4) i Comed Detailed Response with respect to Metropolitan i
Edison Company (Three mile Island Nuclear Station, Unit No.
i 1), CLI-83-22, NRC 299,308 (1983).
cc:
A.B. Beach, Regional Administrator, USNRC Region lli R. Capra, Director of Directorate lil-2, NRR G. Dick, Comed Generic issues Administrator, NRR Senior Resident inspector (Braidwood)
Senior Resident inspector (Byron)
Senior Resident inspector (Dresden) i Senior Resident inspector (LaSalle)
Senior Resident inspector (Quad Cities)
Senior Resident inspector (Zion)
R. Wight, Office of Facility Safety, IDNS EPMISC/ChronNonW12
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i CommonweaMh Edison Detailed Response J
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USNRC Request for Additional Information (RAl)
Related to the Review of The Central Emergency Operations Facility EPMISC/ChronNonk/13
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During its review of the Interim Emergency Operadons FaclHty (EOF)
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requent kom the 2:^ ^:::, one of he issues that was addressed was Comed's i
ablHty to ateWand acdvete he sincHity within 60 minutes. In response to the i
ateW's concerns, Comed successfuHy conducted unannounced driHs to i
support its position that the interim EOF can be acdveted in a Gmely manner (80 minutes). However, during an actual event at Quad Cides in Afay 1996, the
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Ncensee took 00 minutes to accompHah the activation of the Interim EOF.
Whet assurances can ComEdprovide to the stew that the Central EOF wlH be i
ateWed and acdvated within 60 minutes, including oW-hours, in accordance l
with the goal as stated in NUREG-0737, Supplement I(Clarificadon of Tnti Acdon Plan Requirements)?
f Comed immediately initiated a review of the Quad Cities event to determine lessons l
leamed, and identify needed improvement areas That evaluation has been j
provided on several occasions to NRC Staff performing on-site inspections and was summarized in the SALP meeting.
i The review concludes the delay in activation of the Interim EOF experienced at j
Quad Cities was due to a delay in initiating the notification system and would have 4
existed regardless of the location or makeup of the EOFs. The Bulk Power Operator (BPO), assigned responsibility to activate the Computer Response Unit, j
did not respond to the initial NARS call. The BPO is a position staffed by a Comed 1
f employee 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, seven days a week, located in our Bulk Power Office.
l The BPO is connected to the GSEP system through the Nuclear Accident Reporting j
System (NARS). This is the system Comed uses to perform state notifications of an emergency classification.
i in past notification schemes, the BPO when notified of the emergency classification would notify the Nuclear Duty Officer (NDO), who in tum would activate the offsite emergency response organization. [The NDO is the person responsible for l
monitoring operations of the six Comed Nuclear Stations and acting as a liaison l
with senior corporate management during events.) in order to minimize the offsite j
emergency response activation time the responsibility of offsite activation was given directly to the BPO. The BPO was selected for this role because the position is notified simultaneously to the State using the same notification system. This i
ensures activation of the offsite response organization as the next immediate action after State notification. This activation scheme also does not burden the Control Room at a time when they are focused on reactor safety concems.
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_ During the Quad Cities event in May 1996, the Station, recognizing that the BPO had not responded to the NARS notification, notified the BPO via land lines. Prior to activating the Interim EOF, the BPO confirmed with the Nuclear Duty Officer that, in fact, the interim EOF should be activated. Once activated, the Interim EOF l
responders were notified and responded in a timely manner.
l Comed's intemal investigation of the event indicated that had the initiation occurred in normal sequential order all minimum staff would have arrived at the Interim EOF j-in approximately 65 minutes.
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EPMISc/ClworWonW14 4
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Efforts to prsvent recurrence cf this pirticular problIm were directed tow:rd the i
BPO funcbon. BPO Procedure 13-4.05 was enhanced in July to further emphasize i
the order and importance of notifications. The emphasis is placed upon the fact j
that Interim EOF activation is the first priority followmg NARS notification, followed then by notsficaten of the NDO. The NDO's procedure has also been modified to check activation of the interim EOF, immediately following his notifcation by the BPO. In parallel to the procedure changes, supervision in the Bulk Power Offee reinforced to the onshift BPOs the importance of the notifcation requirements.
l Three drills using simulated NARS notifications have been conducted with BPO since the implementation of the corrective schons to ensure effectiveness. On-shift j
BPOs correctly initiated the appropriate facility activation, j
For events initiated at an ALERT classifcation, it remains Comed's intention to activate the cEOF staff, equivalent to the Interim EOF staff (13 people) as approved by the Nuclear Regulatory Commission, for either daytime or off-hours events. The remainder of the EOF staff would then be activated should the classifcation increase to Site Area or General Emergency.
The changes implemented since the Quad Cities event and the continuing commitment to staff the Interim EOF or, following approval, the staff described above for the cEOF are designed to provide asserance of Comed's commitment to the staffing of an EOF in accordance with the 60 minute goal described in NUREG-0654. These commitments will be carried overinto the activation of the cEOF staff.
2)
Itis the expectadon of the staff and the generalpractice of the industry
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that from the dme a Site Area Emergency or General Emergency is declared acdvadon of an EOFshould occur within 60 minutes. Please Indicate the dme at which the "acdvedon clock"is started and the criteria used to determine
. when the EOF is acdveted for the Comed Central EOF.
Comed considers the activation clock, as it applies to the NUREG-0654 staffing i
goals to start at the classifcation time of the event. This classification time is recorded on the NARS form. The clock is stopped when the minimum staff (defined in the GSEP) is in the appropriate facility. For example, if the Site Emergency were classified at 10:00 AM the clock for determination of attaining the 4
staffing goal in accordance with NUREG-0654 would expire at 11:00 AM. To further enhance Comed's ability to staff the offsite facilities within the one hour goal Comed intends to staff cEOF positions equivalent to the current Interim EOF staff at the ALERT or above for either daytime or offhours events as described in the answer to Question 1. The remainder of the full cEOF staff will be activated at a Site Area Emergency Classification or higher.
3)
The conduct of a Mi participadon exposure and Ingestion pathway exercise as specitled in 10 CFR 50, Appendix E (F)(2)(c) and (d) would fully demonstrate the funcdonality of the Central EOF. Please Indicate to the staff how this willbe accomplished.
As specified in 10 CFR 50, Appendix E (F)(2)(c), Comed will conduct a full scale exercise with the State of Illinois at Dresden on August 20,1997. We intend to use
. the cEOF, as a fully staffed, stand alone EOF for this exercise to fully demonstrate the functionality of the concept. We offered and continue to offer the NRC the opportunity to participate in this exercise.
EPMISC/chrorWonk/15
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With regard to the ingestion pathw y requirzments speciftd in 10 CFR Pcrt 50, Appendix E (F)(2)(d), these requirements apply to the states. Ingestion activities
' are a function of the states and, to the degree requested, the Federal agencies.
Licensees have minimal, if any, activities to be performed in ingestion exercises or real event ingestion activities. Ingestion activities have been demonstrated at the Zion Federal Field Exercise in 1987 (Wisconsin & lilinois), the Byron Ingestion Exercise in 1989 (Wisconsin & Illinois), the Quad Cities ingestion Exercise in 1990 i
(lowa),~ and the Dresden ingestion Exercise in 1995 (Indiana & lilinois). Comed, as j.
the licensee, had no role in ingestion activities. The states successfully l
demonstrated the exercise objectives related to ingestion pathway requirements operating out of their respective Emergency Operations Centers and not the i
Licensee's EOF. No ingestion pathway exercise involving Comed is scheduled to i
be conducted until 2001.
4)
In response to queadon 8 of he staff's May 23,1996 RAI, Comed i
indicated that any ofits six stodons' Technical Support Centers (TSC) can act as a back up to be Central EOF. Please provide Information on the use of l
these TSCs as a backup, including the present and hature plans, arrangements, training, procedures and experience using this approach.
in the highly unlikely event that Comed would be unable to use the cEOF, the TSC at an unaffected station could provide adequate capabilities to function as an EOF.
All TSCs are connected with the same redundant communications channels as the 4
j EOF. Access to computer programs necessary for emergency response are available through the Comed Wide Area Network With regard to staffing, unaffected station staff would be already available to initially staff with existing qualified TSC personnel and take on EOF duties. The existing station TSC staff's parallel EOF staff in training and positions and in many instances personnel are qualified EOF responders. The stations have repeatedly demonstrated the
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capability to staff their respective TSC's within 60 minutes (both daytime and off-hours). The station staff responding would be supplemented as needed by l
qualified EOF responders.
Comed has no immediate plans to make additional changes to the TSC with respect to training, organization, or physical arrangement to formalize the use of a J
TSC as a cEOF back-up.
5)
In Comed's response to question 12 of the statt a May 23,1996 RAI, Comed stated that the NRC site team could use the current EOF's in order to be located near he site. Please provide additionalInformation regarding the number and tyrs of personnel, physical arrangements, communications, and o@er support requirements that would be available.
Comed anticipates that NRC would send site team members to the station's Technical Support Center, the Operational Support Center and the Joint Public Information Center, and that the remainder of the site team would report to the central EOF.
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For those NRC personnel who desire near site space, Comed intends to maintain i
the facilities currently at Mazon (Dresden, Braidwood, & LaSalle), Morrison (Quad i
Cities), Dixon (Byron), as Joint Press information Centers (JPICs). The dedicated space currently assigned the NRC for EOF purposes would be available.
EPMtSC/ChrerWonk/16
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i For Zion, no Comed personnel dedicated to Emergency Risponse at what is now e*
1 the Zion nearsite EOF would be present under the new system. Like the other existing EOFs the NRC room currently maintained for dedicated NRC use in an emergency would continue to be maintained. Comed could provide an individual to assist with access and setup of the workspace maintained for NRC. The Public l
j information staff would continue to be maintained at the Highland Park JPIC.
j If the NRC desires, the FTS communications already installed in the dedicated i
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rooms can be maintained. The currently available NRC counterpart seating that exists at any the EOFs will be eliminated. The space currently provided in the NRC j
rooms has been demonstrated to be adequate during exercises in which the NRC l
has played.
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Beyond the floor space and communications listed below and the staffing described i
j above, Comed does not propose to provide any additional staffing, plant documents, or supplies to these facelsties beyond what is needed to support public j
information activities.
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j NRC Room j!
Dixon Facility Dimensions:
24' by 30' FTS Phone Lines:
6 Mazon Facility Dimensions:
17' by 28' FTS Phone Lines:
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j Morrison Facility Dimensions:
17' by 28' J
FTS Phone Lines:
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Zion Facility Dimensions:
32' by 30' FTS Phone Lines:
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l 6)
Comed's response to quesdon 13 of the staff's nGay 23,1996 Rill, did not adequately answer the queadon regarding accommodating Federal, State and local response agencies, ifin the future, those agencies wanted to send personnel to the site. Please provide information on how Federal, State, and local response agencies would be accommodated near the plant?
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j Responding agencies have already designated those locations near the plant to which they intend to respond A detailed summary of these facilities is provided i
below. Designated available locations pruvide sufficient opportunity for nearsite j
(beyond EPZ) operations and coordination.
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In addition to the Radiological Emergency Assessment Center (Springfield, IL), the i
Illinois Department of Nuclear Safety (IDNS) currently dispatches their resident
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inspectors to the plant Technical Support Center. In addition, IDNS establishes a 1
Radiological Assessment Field Team (RAFT) location near the plant site. This team
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is dispatched by IDNS in Springfield and reports to an existing forward operating j
location. For the long term, the RAFT will most likely co-locate with Federal Radiological Monitoring and Assessment Center (FRMAC) or vice versa. The RAFT j
locations are described below.
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EPMisC/ClworWonivi7
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Station RAFT Lv=5 Distance to Site (miles)*
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I Dresden Mazon Middle School 10 i
Mazon, IL LaSalle Mazon Middle School 12 l
Mazon, IL Braidwood Mazon Middle School 12 Mazon, IL Byron Rochelle IDNS Office 13 Rochelle, Illinois Quad Cities Garden Plain Township Bldg.
11 Garden Plain, IL Zion Warren Tovmship Center 13 Warren Township, IL
- Straight line distance in !ddition to the State Emergency Operations Center (Springfield, IL), Illinois Emergency Management Agency (IEMA) establishes a State Forward Command
.i Post (SFCP) nearsite but beyond the EPZ. IEMA, as does other states, uses such l
forward operations for disasters of all types. lilinois, for example, activated the i
SFCP at the Mazon facility for the flooding in Northem Illinois in 1996. The SFCP locations are described below.
l Station SFCP Location Distance to Site (miles)
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Dresden Mazon Facility 10 Mazon, IL LaSalle Mazon Facility 13 Mazon, IL Braidwood Mazon Facility 10 Mazon, IL Byron Lee County EOC 19 Dixon, Illinois Quad Cities Garden Plain Township Bldg.
11 Garden Plain, IL Zion Lake County Fair Grounds
- 13 Lake County, IL
- lilinois is currently planning to move to this facility. This was also the site of the DFO and FRMAC during the Zion Federal Field Exercise.
EPMisC/ChrorWonk/18
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- in addition to the State Emergency Oper tions Center (Des Moines, IA), the Stata l
of Iowa also establishes a SFCP location in Stockton, Iowa. The Iowa Field Team l
Coordmation Group was previously located with the Illinois RAFT at Garden Plain.
Exercise performance showed that, given the improvements in available communicaten resources, the improved timelmess of response to the lows Forward Command Post, and the ability to remain away from the potentially contaminated i
area, the lows teams coordmation has been relocated from a joint lows /lilinois conter to the Iowa Forward Command Post in Stockton Iowa. Stockton Iowa is j
approximately 30 miles southwest of the Quad Cities Station.
In addition to the State Emergency Operations Center (Madison, WI), The State of Wisconsin establishes a Forward Operating Center / Mobile Laboratory at the National Guard Armory in Kenosha, Wisconsin. The Armory is located approximately 18 miles from Zion Station.
4 County Emergency Operations Centers (EOC) are located nearsite but are beyond the 10 mile EPZ. Current county plans do not provide for any presence in the EOF.
County decisionmakers have expressed a desire to remain with their support staff at their respective EOCs to be certain all necessary decisions are being handled property.
Comed understands and appreciates the NRC's concem that the use of the cEOF would remove the current EOF's as potential sources of discretionary space should it be desired by other Federal agencies. Although the provision of such discretionary space is not required by NRC regulations, Comed believes that such discretionary space would be available, nearsite, for Federal agencies, at the Disaster Field Office and the FRMAC as contemplated by Federal Plans.
The designated locations described above provide sufficient location and f
opportunity for nearsite, and beyond EPZ, operations and coordination.
7)
In response to quesdon 15 of the staW's Afay 23,1996 RAI, Comed discussed its layered communicadons system. Are any of these systems dedicated for emergency properedness? How ohen is the computerized call out system tested and what is its reliability record since being installed?
Comed does have a layered communication system which provides a defense in depth philosophy to communications. The phone systems that are dedicated for emergency preparedness are described in the approved Generating Stations Emergency Plan. Those dedicated phones are described below.
Nuclear Accident Reporting System - Activated from the Control Room, TSC, Interim EOF, EOFs, or State EOC's. Used to contact states and locals.
Decisionmakers Conference Lines - Available for Zion and Quad Cities only. Activated by TSC, interim EOF, EOFs, or State locations. Used to connect licensee decisionmakers with state technical decisionmakers.
EPMISC/CtwenNonk/19
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l Generating Station Emergency Plan (GSEP) Phone - Available from TSC, Interim EOF, & EOF. Used to connect licensee decisionmakers.
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Alternate (GSEP) Phone - Available from Control Room, TSC, Interim EOF,
& EOF. Used to transmit technical information between licensee facilities.
Environmental Party Line - Available from TSC, interim EOF, & EOF.
Allows personnel of the same discipline to conference up to six different locations at the same time.
With regard to the computenzed callout system reliability record, Comed conducted six drills and one actual callout dunng 1996. While the computer system adequately s
handled callout of the interim EOF staff, it could not be successfully programmed in a cost effective manner, to callout the full EOF staff. Consequently, Comed has contracted with Community Alert Network (CAN) which has been used successfully
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by other utilities to perform callouts. CAN has the capability to handle 6,000 l
calls / hour (100 7, alls / min). CAN functions from two locations (Reno Nevada and Schenectady New York) that backup each other. Each CAN location has backup power and backup computer systems.
i The CAN system will be placed in operation in the first quarter of 1997. Comed intends to test the callout capability at least quarter 1y.
Eleven Augmentation Drills involving the Interim EOF have been conducted since the implementation of the VRU system and are summaized below.
Augmentation Drill Results using the VRU System Qatt Success Reason 09/18/95 Yes (Note 1) 11/21/95 Fail Computer Failure (Note 2) 12/18/95 Yes 01/31/96 Staff Late 1 designated Minimum Staff position, theTechnical Support Manager was not contacted.
03/04/96 Undetermined (Note 3) 03/25/96 Staff Late 1 designated Minimum Staff position, a Radiation Protection responder (1 of 2 equivalordy qualified responders) was not available for 85 minutes.
04/16/96 Staff Late 1 Minimum Staff position, the Technical Support Manager was not available for 93 minutes. (Note 4)
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05/10/96 Staff Late Quad Cities ActuCl Evont. BPO l
delayed activation for approximately 30 minutes. (See Question 1) 09/11/96 Undetermoed Computer Record Failure (Note 5) (Note 2) 12/05/96 Undetermined Computer Record Failure (Note 5) (Note 2) 01/29/97 Yes i~
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j Note 1:
Yes = Minimum Staff attained in 60 minutes based on drive times l
Note 2:
The Backup Notification System was activated following the results of the surveillance for facility staffing.
Note 3:
Duel Activation Codes were entered which eliminated time record data. Individuals were contacted but time of response could not be determined.
Note 4:
Additional Technical Support Managers with Downers Grove assignments were identified and qualifieKl.
j Note 5:
Computer Time Stamp was lost. Individuals were contacted but without time stamp time estimate was not possible.
The backup system to the computer actuated call-out consists of Corporate Emergency Preparedness Staff assigned pager responsibility for four pre-designated call lists. Two lists divide the Interim EOF responders and the remaining two support normal nearsite EOF call-out. Each caller is provided an approved procedure including an updated copy of the current Emergency Responder phone directory. The back-up system is tested weekly for pager functionality and semi-annually for call-out capability as a portion of the full EOF augmentation drill. In addition, senior Emergency Preparedness Staff are maintained on the same pager system with access to all four of the call-out lists and can be activated by the Nuclear Duty Officer to support any of the pre-designated call-outs.
Pursuant to these surveillance results, Comed has continued to evaluate timely staffing of offsite Emergency Response Facilities. The existing VRU system has demonstrated the ability to rapidly notify offsite responders to initiate staffing of the facilities. To further facilitate timely response, Comed has continued to evaluate personnel qualifications and identify additional responders to further improve the capability. Approximately 50 additional responders where identified in the Corporate organization for training and qualification. Comed has not been satisfied with the record management capability of the VRU system. The surveillance results led us to further evaluate the technology currently available and begin conversion to the CAN system previously described.
8)
Please explain how the use of a centralized EOFprovides the "opdmum" liuncdonal characterlsdcs specified in NUREG-0698, " Functional Criteria for Emergency Response Facilities,"(pp.17-18) as compared to a near-site EOF. Please include in your response consideration of the Commission's determinadon that face-to-face - rather than telephone -
communications between a IIcensee and offsite officials provide the best means to exchange information and formulate protective action recommendadons. Afetropolitan Edison Company (Three mile Island Nuclear Stadon, Unit No.1), CLI-83-22, NRC 299, 308 (1983).
EPMISC/ChronNonW21
l NUREG-0696 is guidance to license:s on how to implement the NRC's cmergency preparedness requirements. Neither it, nor the underlying requirements explicitly recommend face-to-face communication. Reliance on face-to-face communications arose in the context of a specific case in which the State and local officials argued i
strongly for such communications in the face of opposition by the licensee. The j
Commission, consistant with its poley of supporting State and local offmials in emergency preparedness matters, responded to State and local concems by supportmg face-to-face communications in that case. Where the facts are completely different, as they are here, because State and local officials have no desire to rely on face-to-face communcation but, instead, have relied consistently on communication technology that was not available earlier, the imposition of face-to-face communication would be inconsistent dih Commission policy.
This origin of the preference for face-to-face communications is important for several reasons. First, it shows that the Commission is especially sensitive to the communication needs of Stato and local officials. Where, as here, those offmials have expressed no interest in face-tc face communications but, rather, prefer to rely on modem communication techniques that were not available when the Commission made its decision in the TMI-1 case, this precedent indicates that the Commission will honor that position and not impose such communications. Second, face-to-face communications was not considered by the NRC to be a generic
" optimum functional characteristic of emergency response. Face-to-face communications was not among the characteristics enumerated in NUREG-0696.
Third, even if face-to-face communication has become an " optimum" characteristic of emergency preparedness, its history shows that its consideration as an
" optimum" characteristic is relative, based on the specific situation. Face-to-face communication may be an " optimum" characteristic where it is desired by State and local officials, it cannot be so considered where those officials have expressed a clear desire to rely on other, more modem means of communication. Finally, even if face-to-face communication is viewed by the NRC as a generically applicable
" optimum" characteristic of emergency preparedness, it is not required to be adopted by a licensee, especially where it would serve no purpose. There is no regulatory requirement to adopt the " optimum" functional characteristics in NUREG-0696. Reasonable assurance of adequate protection is the well established regulatory standard. It is met in this case where State and local officials have determined that they can best engage in the necessary communication with the licensee by using modem communication technology. Consistent with it, prior deference to such State and local decisions, the Commission should honor those desires in this case too and not impose an unnecessary and unwanted requirement for face-to-face communication.
See Attachment 2 for additional clarification to this response.
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EPMISC/CN'22
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1 ATTACHMENT 2 j
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Comed Detailed Response with respect to Metropolitan Edison Company (Three mile Island Nuclear Station, Unit No.1),
CLI-83-22, NRC 299, 308 (1983).
1 EPMISC/CironNonW23
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l 8)
Please explain how he use of a centralized EOFprovides the "opdmum" funcdonal characterisdcs specilled in NUREG-0696, "Funcdonal l
CrNoria kr Emergency Response Facilldes,"(pp.17-18) as compared to a i
f near-eNo EOF. Please include in your roeponse consideradon of the Commission's determinadon that ince to-face - rather than telephone -
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communicadons between a licensee and offsite oMicials provide the best i
means to exchange informadan and krmulate protecdve acdon l
recommendadons. Metropolitan Edison Company (Three mile Island Nuclear j
Stedon, Unit No.1), CLI-83-22, NRC 299, 300 (1983).
l To more fully answer this question, it is useful first to establish the framework in i
which the answer must be evaluated. NUREG-0696 is a draft report. It " describes l
a set of NRC functional cntena for nuclear power plant emergency facilities." The functional criterion that is relevant to this response is that the " EOF is designed to i
provide assistance in the decision making process to protect the public health and j
safety". To implement this critorion the NUREG contemplates that the " EOF shall j
be the location where the licensee will provide current information on conditions potentially affecting the public to the NRC and to State and local emergency response agencies." In particular, to fulfill the function of providing information, 1
"[s)dequate communications systems are necessary for the EOF to... disseminate j
information to responsible govemment agencies....As a minimum, priority access l
voice communication links shall be provided between the EOF and... State and local emergency response networks."
NUREG-0696 is guidance on how the emergency preparedness requirements should be implemented. The staff stresses that NUREG-0696,... provides i
guidance to licensees on how they can adequately implement the Commission's j
emergency planning regulations". Under well-established NRC practice, it does not establish requirements. That conclusion is particularly important in this case because licensees must be responsive to the methods of communication that are preferred by the State and local officials. Where State and local officials prefer to rely on adequate voice communications systems exclusively and choose not to j
engage in face-to-face communication, a licensee could not be found to be in non-l compliance with NRC emergency preparedness requirements when it cannot alter the decision of those govemment agencies.
k' j
As guidance, NUREG-0696 describes the " optimum" functional characteristics for i
an EOF. Since reasonable assurance is a regulatory standard, there is an i
implication that there is a range of attematives, which may be considered less than optimum in some sense, that are also acceptable to as demonstrate compliance i
with the NRC emergency preparedness requirements.10 CFR 50.47 and Appendix i
E to 10 CFR Part 50 require licensees to adopt the optimum attemative for i
implementing the rule. Flexibility in implementation is especially important where, as j
here, the State and local officials clearly have determined that face-to-face l
communication would be optimum for them. Since this is the choice of the State and local officials, the licensee has no choice but to defer to them. This is -
l consistent with the NRC's cooperation with State and local officials in this particular f
area, as is clearly shown by the TMI-Decision.
f in the TMI-Decision, the issue decided by the Commission was narrowly limited to when responsibilities for making radiological assessments and protective action recommendations needed to be transferred from the Emergency Director in the control room to the Emergency Support Director in the EOF.
EPMISc/ChrorWonk/24
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There is no dispute between the parties regarding the functions that are to be performed from the EOF during an emergency, the controversy centers on how quickly that facility must be fully funcbonal following the declaration of a site emergency.
[18 NRC 306]
l The Commission determmed that such transfer should occur no later than one hour following the declarabon of an emergency. In reaching that decision, the 4
Commission rehed pii.>cipdf on the need to mmimize confusion in control room, and in part on the desires of the Commonwealth of Pennsylvania to engage in j
face-to-face communication in the control room promptly after the declaration of an emergency.
I The Commonwealth's position was summarized by the Commission as follows:
t The Commonwealth also disagrees with the Appeal board. Its primary concem is with the adequacy of informatum exchange and the interaction between Commonwealth and Licensee officials during the early state of an accident. It emphasizes that the ultimate decision regarding protective schons is made by the Govemor, based on recommendations received from his designated representative at the site. The Commonwealth stresses that j
the process of protective schon decisionmaking is bi-directional and that in l
making its recommendation to the state, the Licensee will need information such as weather and road conditions as well as information regarding the specific technical status of the plant. The Commonwealth asserts that the EOF is the facility specifically designed for the exchange of information between the officials of the utility and the representative of the Commonwealth and where the implications of that information can be discussed. Accordingly it believes Licensee's proposal would impede necessary exchanges of information.
In response, the Commission adopted the Commonwealth's concem:
Furthermore, as the Commonwealth stresses, the EOF is the ideal place for face-to-face communications regarding protective actions recommendations between federal, state, and local officials, and the Licensee official charged with making the recommendations to the Commonwealth. The Commission does not believe, as Licensee suggests, that telephonic communications between the govemmental officials in the EOF and the Ucensee's decisionmaker in the control room provide an equivalent opportunity for an exchange of information. The Commission views the opportunity for face-to-face communications as the best means to exchange pertinent information between govemment officials and the Licensee and to formulate protective action recommendations, particularly when it is essential that there not be misunderstandings between those involved.
[18 NRC 30]
Since 1983, when this dictum was written, the situation regarding emergency preparedness has changed substantially in general and in particular for Commonwealth Edison. Electronic communications have improved in ways that could not have been anticipated. Many exercises have been held to provide clearer insights into the limits on the value of face-to-face communication. New avenues have been opened for transmitting plant status to State and local officials.
EPMISC/ChrorWonk/25
l h.'
P.
For Commonwealth Edison, the changes since 1983 hava been cspecially dramabc. State and local officials have affirmatively declared that face-to-face.
communication is not their preferred mode for communicating with licensees. Years of successful exercises have demonstrated that the altemative provided by technologically improved communication equipment provides more than adequate opportunsbos to communicate effectively. Plant status information is transmitted regulady to the Illinois Department of Nuclear Safety in a manner not contemplated in 1983. Illinois' Reactor Data Link (RDL) is a real time computer link from the six stations on-line computer monitoring system, directly to Springfield, in excess of 1000 data points, identified as cribcal by Comed and IDNS personnel are transmitted to the Radiological Emergency Assessment Center (REAC) in Springfield on a continuous basis. IDNS personnel have developed extensive analytical techniques to assess plant conditions based on this data. Similariy, with the adophon of the NRC's Emergency Response Data System (ERDS), plant
- status, selected as cribcal by the Nuclear Regulatory Commission, is transmitted to the Rockville Operations Center and the Regions incident Response Center. ERDS is subsequently available to those affected states. These factors clearty demonstrate that the reasons for the Commission's TMI-Decision do not apply to this request for a cEOF.
For the Commission to follow its underlying logic in the TMI-Decision as applied to this request, the Commission would need to take into account the communication desires of the State and local officials, as it took into account the desires of the Commonwealth of Pennsylvania. Since the states and local officials do not desire face-to-face communication they Commission would conclude that face-to-face communication is not an optimum functional characteristic for this situation.
Finally, it should be noted that the guidance in NUREG-0696 does not explicitly recommend fact-to-face communications between licensee and offsite officials. A licensee, by using adequate voice communication systems, would use the EOF as the location to provide current information to State and local emergency response 1
agencies. Accordingly, face-to-face communications were not considered at the time to be an optimum functional characteristic of an EOF.
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