ML20151J169

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Forwards Three Changes to Maine Yankee Emergency Plan,Per 10CFR50.54(q).Changes Do Not Decrease Effectiveness of Plan Resulting in Loss of Reasonable Assurance That Adequate Protection Can Be Taken in Event of Radiological Emergency
ML20151J169
Person / Time
Site: Maine Yankee
Issue date: 07/29/1997
From: Hebert J
Maine Yankee
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20151J175 List:
References
JRH-97-181, MN-97-87, NUDOCS 9708050097
Download: ML20151J169 (6)


Text

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"a MaineYankee RELIABLE ELECTRICITY SINCE 1972 l

l-329 BATH ROAD + BRUNSWICK, MAINE 04011 + {207) 798-4100 l

July 29,1997 i

MN 97-87 JRH 97-181 UNITED STATES NUCLEAR REGULATORY COMMISSION Attention: Document Control Desk Washington D.C. 20555

References:

(a) License No. DPR-36 (Docket No. 50-309)

(b) Maine Yankee Emergency Plan, dated December 1,1992

Subject:

Changes to the Maine Yankee Emergency Plan Gentlemen:

Pursuant to 10 CFR 50.4, please find enclosed three changes to the Maine Yankee Emergency Plan.

The changes have been made in accordance with the provisions of 10 CFR 50.54(q).

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Change 97-01 documents the relocation of the primary radiation emergency medical facility to Midcoast Hospital's Brunswick campus from Midcoast Hospital's Bath campus. This relocation

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l continues to provide quality medical services for contaminated injured individuals in a hospital l

facility outside the EPZ. Change 97-02 eliminates utility Offsite Dosimetry Assistants provided to local EPZ communities in a declared emergency as a sufficient number of qualified community and county (backup) emergency responders are available. Change 97-03 contains programmatic updates j

and editorial clarifications.

A description of the Plan changes, along with informational copies of revised pages of the Emergency Plan, are summarized in Attachment A. A complete set of revised pages will be distributed under separate cover to all those on the controlled distribution list for the Maine Yankee Emergency Plan, j

These changes have been reviewed by the Plant Operations Review Committee. It has been determined that these changes to the Maine Yankee Emergency Plan:

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l (1) do not decrease the effectiveness of the Plan resulting in the loss of reasonable l

assurance that adequate protection can and will be taken in the event of a radiological l

emergency as required by 10 CFR 50.47 (a);

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(2) do not result in the loss of ability to meet any of the standards described in 10 CFR 50.47 (b) or any NRC approved alternatives to these requirements:

(3 do not delete or contradict any regulatory requirement.

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MaineYankee UNITED STATES NUCLEAR REGUL ATORY COMMISSION MN-97-87 Attention: Document Control Desk Page Two We trust this information is satisfactory. Should you have any questions regarding this information, please contact me.

Very truly yours, M

ames R. Hebert i

Manager, Regulatory Affairs JMT/jmt Enclosures c:

Mr. Hubert Miller (2 copies) l Mr. J.T. Yerokun Mr. D. H. Dorman Mr. John H. Lusher l

i Mr. P.J. Dostie, SNSI Mr. John W. Libby, Director, Maine Emergency Management Agency i

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ATTACHMENT A Summary of Changes to the Maine Yankee Emergency Plan i

CHANGE 97-01 -CHANGE IN MEDICAL FACILITY LOCATION i

Midcoast Hospital relocated its primary 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day Emergency Department from its Bath campus to its Brunswick campus. The Bath campus, which has housed our Radiation Emergency Area (REA) for over 10 years, is now considered an " urgent care" facility, staffed approximately 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> a day only. Maine Yankee decided to relocate its REA facility from the Bath campus to the Brunswick campus to ensure that 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day coverage by trained and qualified medical staff would continue to be available. All REA equipment and supplies have been moved from Bath to Brunswick, and training for physicians and key hospital Emergency Dept. Staff has been accomplished. Hospital plans, ambulance procedures and cnsite emergency plan implementing procedures (see for example 2-50-19, Medical Emergency Plan) have been revised to reflect this move, which became effective on June 9,1997.

Page 6.25 has been changed to reflect the fact that the Midcoast Hospital Radiation Emergency Area facility is not located at the Bath hospital anymore.

The Emergency Plan as changed continues to be consistent with the requirements of 10 CFR 50.47 (b) and the change:

(1) does not decrease the effectiveness of the Plan resulting in a loss of reasonable assurance That adequate protection can and will be taken in the event of a radiological emergency As required by 10 CFR 50.47 (a); and (2) does not result in the loss of ability to meet any of the standards described in 10 CFR 50.47 (B) or any NRC approved alternatives to these requirements; (3) does not delete or contradict any regulatory requirement.

CIIANGE 97-02 -ELIMINATION OF OFFSITE DOSIMETRY ASSISTANTS Plan Chapter 5, Section 5.4, Coordination with Participating Governmental Agencies, contains a paragraph which describes the Maine Yankee Offsite Dosimetry Assistant (ODA) program.

Maine Yankee, approximately 15 years ago, created a cadre of technical type employees who were l

trained and qualified to assist area EPZ communities with the use of dosimetry and the maintenance of contamination and exposure control operations. While there is no requirement in 10 CFR 50.47, Appendix E, or in NUREG 0654 for such assistance, it was deemed prudent in the early 1980's to provide this utility based expertise to local community volunteer emergency responders, as they did not work with dosimetry and survey meters with any regularity.

i At an Alert or higher emergency classification, ODAs would be called in and briefed at the onsite EOF, and then dispatched to area towns within 5 miles of the plant, and other towns downwind of the plant, depending on meteorological conditions at the time of the accident. Each ODA would 1

o arrive at the assigned local EOC, and offer his services to the EOC manager. If the local EOC staff performed well with dosimetry control and contamination control, and the EOC manager indicated the services of the ODA were not needed, the ODA would then proceed to his secondary assignment at another nearby EOC and offer his services there.

l Through years ofincreased training by the State of Maine Maine Emergency Management Agency (MEMA) and the Maine Division of Health Engineering (DHE), sufficient local staff are now trained and qualified to adequately perform these duties without assistance from Maine Yankee. MEMA and DHE conducted an 8-10 hour workshop in 1996 for approximately 25 members oflocal and county ERO staffs within the EPZ on dosimetry and the use of survey meters, exposure control, contamination control and other topics ofinterest. Additional specialized training is anticipated for local ERO key staffin 1997.

An analysis of recent biennial full participation exercises also lends credence to the fact that utility assistance is no longer needed. FEMA issued 20 Areas Regtaring Corrective Action (ARCAs) directly related to local dosimetry, monitoring and decontamination issues at the local level, following the September 21,1994 biennial exercise. After the June 12 and 131996 biennial /IPZ exercise, only 2 new ARCAs relating to local dosimetry, monitoring, or decontamination issues were issued, with past ARCAs closed out.

Refinements have been made to town plans and checklists, additional supplies have been located at the local level, and annual training has been more focused on radiological concerns. Each local plan directs municipal officials to call upon their County Emergency Management Agency (EMA) if they need assistance, additional equipment, or for reporting of field information. The Lincoln County EMA staff now has a cadre of 11 FEMA certified radiation monitors (with more to be trained in l

1997), about half of whom could be dispatched to a local EOC in either county to acsist with l

dosimetry, monitoring, and other issues as needed. Mr. Gerald Silva, Director of the Lincoln County and the Sagadahoc County Emergency Management Agency was contacted on or about June 30, 1997, and concurs with the decision that sending utility ODAs to local communities is unnecessary, since the county EMA staff would provide those services as needed.

Finally, to enhance local emergency planning, the State has created a State Transportation Staging Area / Emergency Worker Monitoring and Decontamination Facility (STSA/EWMD) in Brunswick, staffed by 30 plus trained members of the Brunswick Fire Dept. The STSA/EWMD facility was satisfactorily exercised in a FEMA evaluated drill on June 2,1997. All objectives were met for the exercise. The STSA/EWMD facility is designed to monitor emergency workers and their emergency vehicles, providing another level of assurance that local dosimetry and contamination control methods can be effectively implemented in the event of a radiological emergency.

The Maine Emergency Management Agency and the State of Maine Division of Health Engineering were consulted on or about June 30,1997 on this matter, and both agencies concur that adequate capability exists within the community response organizations, and coupled with backup from the County, dosimetry assistance from Maine Yankee is unnecessary.

Page 5.12, which described the ODA program, has been eliminated. Section 8.1.2 describing the Eplan training program has been updated to climinate the ODA training module, and Table 1-3 has been revised to climinate reference to the ODA function. Figure 5-5, Maine Yankee Emergency Response Organization, has also been updated to reflect the elimination of the ODA function in the EOF. Table 1-2, List of Emergency Plan Implementing Procedures, has been revised to eliminate reference to the ODA procedure,2-50-21.

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i The Emergency Plan as changed continues to be consistent with the requirements of 10 CFR 50.47 j

(b) and the change.

(1) does not decrease the effectiveness of the Plan resulting in a loss of reasonable assurance i

that adequate protection can and will be taken in the event of a radiological emergency as required by 10 CFR 50.47(a), and (2) does not result in the loss of ability to meet any of the standards described in 10 CFR 50.47 (b) or any NRC approved alternatives to these requirements; (3) does not delete or contradict any regulatory requirement.

CIIANGE 97-03 -MISC. PROGRAMMATIC UPDATES AND CORRECTIONS

1. Revised Letters of Agreement Appendix 1, has been updated to reflect the receipt of revised letters of agreement from INPO and the US Dept. Of Energy, and to eliminate three letters of agreement maintained with area bus transportation providers, as these letters are being transferred to the state of Maine RERP, Volume
1. The Maine Emergency Management Agency anticipates completion of an updating of their entire RERP for Maine Yankee, which will include addition of these letters of agreement, by December 31,1997.

l This change does not decrease the efTectiveness of the plan. The transportation provider LOAs were obtained by Maine Yankee at the request of the State in October 1990 to expedite the procuring of needed additional (standby) transportation resources. MEMA has agreed to now include their LOAs l

in Volume 1 of the State of Maine RERP for Maine Yankee.

2. Change from EBS to EAS Effective in early 1997, the State of Maine received FCC approval of their plan to convert their antiquated Emergency Broadcasting System (EBS) to a modern, electronically controlled and activated Emergency Alert System (EAS).

Pages 3.3,6.6,7.6, Figure 6.2 and Table 7-1 have been revised accordingly.

This change is a name change only, and has no impact on the effectiveness of the Emergency Plan whatsoever

3. Updated graphics The following figures have been redone in a new, more readable format. No information contained l

in the figures has changed, except as noted elsewhere.

l Figure 5.1, Basic Shift Organization Figure 5.4, Maine Yankee Emergency Response Organization Interfaces Figure 6.2. Maine Yankee Initial Notification and Activation Process

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Figure 7.6, Maine Yankee Environmental TLD Locations Figure 9.1, Sampic Recovery Organization These changes have been made to enhance the readability of the Emergency Plan, and do not decrease the effectiveness of the plan.

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4. General updates a.

Page 6.1 has been revised to reflect the elimination of the Duty Call Officer (who no longer performs any emergency plan related duties) from the list ofinitial notifications made by the control room. DCO notification has also been eliminated from Figure 6.2 above.

The DCO has not been required to perform any Eplan related functions for several years, as all notification functions previously assigned to the DCO have been reassigned to the on-shift security force or STA. The DCO was notified of an emergency classification as a courtesy, and would have been informed of an emergency classification anyway if he was a member of the ERO. This change does not decrease the effectiveness of the Eplan, as the DCO performs no Eplan related functions as a DCO.

b.

Table 6-2, List of Supporting Plans and Procedures, has been updated to reference the NRC Response Coordination Manual (RCM-96), and to reficct changes in Radiological Controls procedure numbers.

Page 7.8 has changed to reflect the increase in the number of key ERO and supervisory c.

personnel with pagers from approximately 55 to over 100.

d.

Figure 7-7, TLD and Air Sampler Locations, has been updated to reflect current locations of air samplers around the Maine Yankee plant. TLD locations are included in Figure 7-6.

Page 8.1 has been revised to reflect title changes: Manager, Regulatory Affairs, from e.

Manager, Licensing and Engineering Support, and the EHS and Emergency Preparedness Section Head from Emergency Planning and Environmental Engineering Section Head.

f.

Page 8.2 has been reworded to clarify the difference between initial qualification / certification for an ERO position and annual recertification training, g.

Page 8.6 has been revised to clarify, in Section 8.1.3. that monthly " communication tests" are conducted with the Plant and the NRC.

All these changes are programmatic updates, title changes, or minor clarifying changes that do not have any negative impact on the effectiveness of the Plan or upon the ability of the ERO to effectively implement the Eplan as required.

The Emergency Plan as changed continues to be consistent with the requirements of 10 CFR 50.47 (b) and the change:

(1) does not decrease the effectiveness of the Plan resulting in the loss of reasonable assurance that adequate protection can and will be taken in the event of a radiological emergency os required by 10 CFR 50.47 (a);

l (2) does not result in the loss of ability to meet any of the standards described in 10 CFR 50.47 (b) or any NRC approved alternatives to these requirements; (3) does not delete or contradict any regulatory requirement.

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