ML20154M622

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Requests Review & Approval of Certain Proposed Changes to CPSES Emergency Plan,Per 10CFR50.54(q).Description of Proposed Plan Changes & justifications,marked-up Copy of Current Plan Affected Pages & New Plan Pages,Encl
ML20154M622
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 10/15/1998
From: Terry C, Walker R
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TXX-98207, NUDOCS 9810200349
Download: ML20154M622 (63)


Text

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' Log #TXX-98207 Z-File # 10013 Ref. # 10CFR50.54q 1UELECTRIC i October 15, 1998

c. ime.ncry -

" Senior Vice President

& PrincipalNuclear Officer U. S. Nuclear Regulatory Commission Attn: Document Control Room Washington, DC 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 REQUEST FOR NRC P,EVIEW AND APPROVAL OF CHANGES TO CPSES EMERGENCY PLAN Gentlemen:

The purpose of this letter is to request review and approval of certain proposed

. changes to the CPSES Emergency Plan.

TV Electric is submitting herein certain proposed changes to the CPSES Emergency .

Plan for the NRC staff to review and approve prior _ to implementation at CPSES. I These changes, except as noted below for Section 1, were categorized to be either in a " grey area"_with respect to current guidance and understanding of what may be  ;

deleted or otherwise changed under 10 CFR 50.54(q) without prior NRC approval, or a potential decrease in the effectiveness of the current CPSES Emergency Plan and therefore require prior NRC approval. Some of the Section 1. proposed changes are of lesser significance and may not fit the above categorization; however, these changes have been included in this submittal because they are small, were identified at the same time, and are not deemed to warrant processing as a separate amendment. All of the proposed changes herein have been reviewed and approved by CPSES management and the CPSES Station Operations Review Comittee (SORC).

Attachment _1 provides a description of the proposed plan changes and associated t justifications. Attachment 2 provides a marked-up copy of the current plan pages

-affected. Attachment 3 provides the proposed new plan pages reflecting these \ 1 changes.

TU Electric requests that the NRC staff review and approve these changes prior to February, 1999.

q Olivn 3

9810200349 981015 "

PDR ADOCK 05000445 F PDR COMANCilE PEAK STEAM ELECTRIC STATION P.O. Box 1002 Glen Rose, Texas 76043-1002 p

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TXX-98207
Page 2 of 2 If there are any questions concerning this submittal, please contact Mr. Norman Hood, Emergency Planning Manager, at (254) 897-5889.

Sincerely.

0. 0, C. L Terry By: @ '

Roger D. Walker Regulatory Affairs Manager CLW/grj Attachments c- Mr. E. W. Merschoff, Region IV Mr. J. I. Tapia, Region IV (clo)

Ms. G. M. Good, Region IV Mr. B. Murray, Region IV (clo)

Resident Inspectors, CPSES (clo)

Mr. T. J. Polich, NRR 1

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Attachment 1-to TXX-98207- 1 Page 1.of 11-

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i DESCRIPTION AND JUSTIFICATION OF PROPOSED CHANGES TO THE CPSES EMERGENCY PLAN P.1-10, Section 1.2.2. " Local Services Support" Change.

Description:

Delete. the sentence "The following organizations are the local support groups which have agreed to provide services, if requested:" and the six (6) organizations immediately following in bullets. Revise the preceding.

sentence which refers to letters of agreements in Section 15.0, Appendix H, to add the words "which identifies the local services support organizations".

Justification:

I This information is identified for deletion because it is redundant to information provided in Appendix H. Section 1.2.2 continues to state that letters of agreements are maintained with each local services support agency. Section 1,2,2 is also clarified to identify these local agencies by reference to Appendix H which provides a list of the letters of agreement maintained and includes those local support agencies being deleted from Section 1.2.2 ' .

P. 1 11, Section 1.2.3 " Private Sector Support" Change

Description:

Delete the underlined words in the sentence: "The following organizations have aareed to provide services, if requested:"

Justification:

c This change is for clarification. A self-assessment concluded that the underlined words implied that a letter of agreement exists with the organizations (following) described in bullets. CPSES does net maintain a letter of agreement with all of the organizations described (i.e., American Nuclear Insurers: Westinghouse, Corp).

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t Attachment 1 to TXX-98207 Page 2 of 11 P. 1 12 Section 1.2.4 " State Agencies"

Change Descriptions
1. Delete the word " lead" from the description of the State Division of Emergency Management (DEM).
2. Revise the description of the Texas Department of Health (TDH).

Justifications:

1. This change is for clarification. A self-assessment concluded that the use of the words " lead agency" in the description for the DEM implied that there is more than one (1) coordinating agency for the State's emergency response.

The Texas DEM is the one and only designated coordinating agency for the State of Texas.

2. This change is for clarification. The revised wording more accurately reflects the iole of the TDH as described in the State of Texas Emergency Management Plan.

P.1 13 Section 1.2.5 " Federal Agencies" Change

Description:

Delete statements concerning the NRC's mobile laboratory.

Justification:

The NRC Region IV Office no longer has this response capability.

Table 1.1 " Staffing Requirements For Emergencies"

' Change Descriptions:

-1. Revise the task of providing technical support to the onshift STA by changing the " additions within minutes of Alert" column requirements to

, delete the Engineer responding at 40-minutes and add one additional member to the TSC Engineering Team responding at 70-minutes. This change effectively moves this technical support from a 40-minute response to a 70-minute response.

2. Revise footnote annotations of (*) and (**) to (a) arf (b). respectively.

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Attachment 1 to TXX-98207 l Page 3 of 11 l 3. Add footnote (c) as applicable to the onshift minimum staffing column. This footnote allows, upon exercising certain compensating actions, a temporary l exception to the onshift minimum staffing requirements due to unforseen j~ circumstances (e.g., personal illness).

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Justifications:

! l '. This change is related to one aspect of guidance found in NUREG-0654/ FEMA-REP-1 (Rev.1) Table B-1 " Minimum Staffing Requirements for NRC Licensees for Nuclear Power Plant Emergencies", which recommends that the onshift STA position be supported within about 30-minutes with one additional individual who can provide technical support in the area of core / thermal hydraulics.

l The CPSES Emergency Plan is currently approved for a 40-minute support response.

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The justification for allowing the change to a 70-minute responder (support l would come via the TSC Engineering Team) is based on the following:

l l a) The current understanding of the development and timing of reactor core

! degradation / melting during a postulated severe accident is documented in NUREG 1465 " Accident Source Terms for Light-Water Nuclear Power Plants" published in 1994. NUREG-1465 information postulates that significant core degradation / melting first occurs at longer times post-accident than previously believed (i.e. as postulated in the reactor safety study of WASH-1400, published in 1975, which is one basis for NUREG-0654. Table B-1 response timing). NUREG-1465 contends that, for PWRs, during the first 30-l minutes only a small fraction of the core inventory of radionuclides could l be released into containment, and the onset of significant fuel damage occurs at over an hour post-accident. This more current understanding of the

! timing sequence for PWR post-accident core damage (i.e., damage occurs after

'a longer time period post-accident that previously believed) acts to l increase the creditable planning basis for the time from the initiating

event to start of atmospheric release and therefore reduces the immediacy for providing augmented technical support. Additionally, it is recognized that information for quantifying fuel damage would not be required, or l

available, until some time after the TSC is expected to be activated. For i

example NUREG-0737, Supp.1, recognizes that determining the level of fuel l

damage requires chemistry data / analysis and provides the expectation that this sampling / analysis be completed within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> from the decision to do so.

' b) The CPSES TSC Engineering Team (which would be increased from 3 to 4 members and assume this responsibility) would have sufficient personnel resources to take on this technical support and is staffed / activated in a

, time frame (within 70 minutes of Alert) adequate to meet the required support needs (see item above).

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, ._ _ _ _ _ _ _ _ _ to TXX-98207 Page 4 of 11 c) The recent development and availability of the CPSES Emergency Response Guidelines and Severe Accident Management Guidelines enhance the resources immediately available to the onshift operating crew and serve to make the initial response to a severe accident situation more manageable. The availability of these guidelines reduces the level and/or immediacy of augmentation support that may be required from the STA.

d) Since NUREG-0654 was issued in November, 1980. the accident assessment capabilities of nuclear power plants (including that for CPSES in the area of core / thermal hydraulic evaluation) have been greatly enhanced by the installation and application of new systems / equipment such as the Safety Parameter Display System (SPDS) and the Radiation Monitoring System (PC-11 at CPSES). Parameters such as core exit thermocouple temperature, reactor vessel water level, containment radiation level, etc., are easily monitored and trended using these systems. These systems are readily available to assist Control Room staff in the early stages of an accident and were not accounted for in minimum staffing considerations of NUREG-0654. Table B-1.

2. This change enhances table readability and reduces the potential for misinterpretation.
3. This footnote addition allows a temporary exception to minimum staffing that is consistent with similar provisions allowed for the onshift crew in the CPSES Technical Specifications and FSAR. Proposed footnote (c) is intended to be used by the onshift staff, especially during backshift or weekends, in response to certain situations such as sudden illness, family emergency, or in the case of the CPSES pre-identified onshift medical responders (i.e.. Chemistry Technicians), to allow care for, or transport of, injured plant personnel to the hospital. Similar temporary staffing exceptions are already allowed by either the CPSES Technical Specification Administrative Controls (6.2.2), FSAR (Table 13.1-2) or the regulations of 10 CFR 50.54(m)(2)(1) note 1 for the minimum staffing of onshift Radiation Protection Technicians, Chemistry Technicians, Fire Brigade members or licensed operators.

These temporary exception criteria are recognized'precedences with the NRC for allowing short time absence from required minimum onshift staffing to accommodate unforseen situations (e.g., unexpected individual sickness, accident, etc.). The short exception period proposed (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) and the related compensatory measures (replacement call-in), coupled with the very small chance of an exception being exercised coincident with a declared emergency event, make this change reasonable for ANY onshift position when weighed against the benefit to an affected individual and the rather onerous logistics that would otherwise be required to meet 24-hours-a-day minimum staffing. It is inconsistent with the established precedences to not be able to apply some form of temporary exception criteria. It is also not practical

Attachment 1 to TXX-98207 Page 5 of 11 or reasonable to add several additional personnel to the prescribed minimum staffing complement just to cover the remote chance that an individual will have to leave the site via a. subject absence.

As an example in support of this discussion, a recent CPSES off-hours event occurred in which one of the two required onshift Radiation Protection

. Technicians had a family emergency and left the site after getting supervision concurrence and promptly calling for a replacement Radiation Protection Technician. In this event the position was vacant for about 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (consistent with Operations procedures and the TS allowance).but was a literal noncompliance with the CPSES Emergency Plan's Table 1.1 minimum staffing requirements.

l Table 1.2 " Predetermined Response Actions" Change

Description:

' Add a predetermined response action statement to " recommend protective actions to offsite officials" at classification of a Ger.eral Emergency.

Justification:

This response action is already stated under the purpose of a General Emergency in plan Section 1.1.2. but was not originally included in Table 1.2. This change provides consistency between Table 1.2 and Section 1.1.2 and makes Table 1.2 "more complete" as a summary of the important predetermined response actions.

P. 31 thru 3 4, Section 3 " Notification Methods and Procedures" Change

Description:

Revise and reformat all Section 3 information.

-Justification:

Section 3 has been extensively revised and reformatted. Information in current Sections 3.0 through 3.6 is revised and relocated to new proposed Sections 3.0 and 3.1. These changes reformat / clarify content, define

" Initial Notification" and " Followup Notification" and identify to whom these notifications are sent, specify the content of the Initial and Followup notifications, identify time requirements for these notifications, and allow State and local authorities to specify the frequency for receiving Followup Notifications if their need is different from 1-hour. The

i l Attachment 1 to TXX-98207 Page 6 of 11 l responsibility of the Shift Manager currently in Section 3.1 for ensuring (initial) notifications after an emergency is declared at CPSES is deleted based on similar statements already in plan Sections 1.1.2.1 and 1.1.2.2.

l Information in current Section 3.7 "Public Warning" is rearranged, revised and relocated to new proposed Section 3.2. These changes are editorial.

Information in current Section 3.8 " Methods of Providing Public Information l

Regarding Protective Action Measures" is revised and relocated to new proposed Section 3.3. Specific references to "a booklet or other l publications" and " posters and stickers" are changed to " printed media" l which is a more generic term with the same intent. Statements in Section 3.8 concerning the Emergency Alert System (EAS) and preformatted messages are l relocated to new Section 3.2. The Section 3.8 sentence that refers to what

! may be addressed in messages transmitted to the public is deleted on the basis that it is unneeded detail and/or conjecture, and is covered by the statement that preformatted messages (for the public) are included in the county and State plans.

l P. 7 3, Section 7.3.1 "0nsite Radiological Assessment" Change

Description:

1. Change " Chemistry / Environmental Technicians" to Chemistry Technicians" l 2. Change the responsibility statement of the Technical Support Center (TSC)

! Onsite Radiological Assessment Coordinator (0NRAC) and Emergency Operations Center (EOF) Radiation Protection Coordinator (RPC) for functions of onsite l and offsite radiological assessment and survey activities to be effective upon activation of the TSC and EOF, instead of the declared emergency classifications of Alert and Site Area Emergency, respectively. This change l also deletes "onsite" from the scope of the overall radiological assessment l

responsibilities assumed by the RPC when the EOF is activated.

Justification:

l 1. Change reflects the current position title and CPSES organizational responsibility assignments.

l 2. A CPSES self-assessment concluded that this responsibility statement needed to be clarified. Changes allow assumption of responsibilities independent of declared emergency classification and clarify the intended shift of

responsibilities between the ONRAC in the TSC and the RPC in the EOF.

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Attachment ~1 to TXX-98207-

' Page:7 of.11-4 P. 7 3, Section 7.3.2 "Offsite Radiological Assessment" Change

Description:

Change the RPC's responsibility for assuming the coordination of offsite radiological monitoring and assessment from "In the event a Site Area Emergency or General Emergency is declared" to "Once the EOF is~ activated".

Justification: ,

A CPSES'self-assessment concluded that this responsibility statement needed ,

to be clarified. Change allows the RPC to assume this responsibility earlier and independent of event emergency classification. At CPSES'the EOF is. staffed and may be activated at an Alert. This change also clarifies the intended shift of this_ responsibility between the ONRAC in the TSC and the RPC in the EOF.

P. 8 2. Section 8.1.6 "Radioprotective Drugs" Change

Description:

i Revise to add a sentence on the maintenance of Potassium Iodide (KI) supplied by TV Electric and clarify a statement of KI use with respect to the contents of State or local government emergency plans and procedures.

Justification:

Change adds a clarifying sentence which states that KI supplied by TV Electric to onsite and offsite locations is maintained in accordance with provisions given in Appendix J of the CPSES Emergency Plan. Section 8.1.6 is also clarified to more correctly reflect what is described in the State and local plans or procedures with respect to KI use. The sentence stating what is described in the State or local government emergency plans and procedures is being changed to replace the words " describe KI use respective to emergency response personnel and institutionalized persons" with " describe KI use respective to offsite personnel" The current wording in the CPSES Emergency Plan is inconsistent with the current wording in the State and i local county plans. The State and local county plans are also currently in a state of flux on the subject of KI and this proposed change to the CPSES Emergency Plan allows for greater flexibility and/or consistency with possible future revisions to the State and county plans.

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Attachment 1 to TXX-98207- l Page 8 of 11 P.12 2, Section 12.2.4 " Radiological Monitoring Drills" Change

Description:

Revise to provide consistency with other statements in the-CPSES Emergency-Plan and change the scope of monitoring activities to be performed in drills by CPSES personnel assigned to radiological monitoring teams.

Just'ification: i This change provides consistency with statements in CPSES Emergency Plan Sections 1.0 and 1.2.4 and clarifies that CPSES personnel assigned to radiological monitoring teams shall participate in annual drills for performance of air sampling / beta-gamma exposure rate determinations and should participate in drills to collect other environmental samples. The proposed change. takes partial exception to annual drills for 1 sampling / analyzing some environmental sample media (NUREG-0654 criteria N.2.d) by implying that CPSES personnel are not required to collect / monitor media cther than air (i;e., water, vegetation and soil) These environmental media are primarily a responsibility of State monitoring' personnel. The l State of Texas (Bureau of Radiation Control) and CPSES have had discussions i on this responsibility and have agreed that the State has the lead for

. collecting / analyzing the sample media of water, vegetation and soil. CPSES personnel should only maintain an assistance capability in this area in order to assist, if necessary, State agencies during an Ingestion Pathway phase. This position is consistent with guidance provided in NUREG-0654, Appendix 5 " Glossary" which clarifies responsibilities that must be assigned j among various organizations and states, in part: "Where the guidance in this 4

document indicates a function that must be performed, emergency planners at i all levels, must decide and agree among themselves, which organization is to o perform such function."

Appendix B " Time / Distance / Dose (Thyroid) Curve For A LOCA Condition At CPSES" Appendix C " Time / Distance / Dose (Whole Body Gamma) Curve For A LOCA Condition at CPSES" Appendix D " Time / Distance / Dose (Whole Body Total) Curve For A LOCA Condition at CPSES" ,

Change

Description:

Delete Appendix B,C and D from the CPSES Emergency Plan.

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. _ - - . . - - - - - .- - - . - _ . . to TXX-98207 Page 9 of 11 Justification:

This change deletes pre-1980 required graphs that compare reference thyroid or whole body dose values (including old 10 CFR Part 20 organ dose limits) to the doses that were estimated to be received by individuals at certain times and distances downwind of CPSES following a design basis accident (LOCA) and a radioactive release.- These graphs were to provide a means for quickly assessing potential offsite dose consequences and aiding offsite protective action decision making. The graphs were originally developed per the guidance of Revision 0 (11/75) and Revision 1 (3/77) of Regulatory Guide (RG) 1.101 " Emergency Planning and Preparedness for Nuclear Reactors" which specified that graphs of post-LOCA time / distance / dose be prepared and provided in the emergency plan contents (Apper, dix) as described by RG 1.70,

" Standard Format and Content of Safety Analysis Report; for Nuclear Power Plants" In August, 1980, the NRC upgraded its requirements for emergency preparedness in amendments to 10 CFR 50 (45 FR 55402). The NRC withdrew the guidance of RG 1.101 (Revision 1) in September, 1980, because it did not reflect the new requirements. In Revision 2 of RG 1.101, the NRC published new guidance (October, 1981) which endorsed the provisions of NUREG-0654 (FEMA-REP-1) as the preferred method to demonstrate compliance with the planning standards of 10 CFR 50.47. NUREG-0654 does not suggest development or inclusion of these graphs as part of an acceptable emergency plan.

Subsequent developmental revisions of the CPSES Emergency Plan have failed to remove these obsolete graphs from the Appendices.

In the current CPSES Emergency Plan, which has been developed to the guidance of RG 1.101 Revisions 2 & 3 and has substantially incorporated the provisions of NUREG-0654, the graphical information in Appendices B, C and D is not used or referenced. These appendices are not currently used as a planning basis for offsite evacuations as was originally intended by RG 1.70, nor are they used as a tool during emergency response at CPSES. The current CPSES Emergency Plan, via NUREG-0654 guidance and provisions incorporated within Sections 7.0 " Accident Assessment" and 8.0 " Protective Response". encompasses the intent of these graphs. Finally, there is no mention of these appendices in the CPSES Safety Evaluation Report (SER) or supplements, related NRC inspection reports or correspondence.

Based on the above, it was determined that the subject graphs were not used as a licensing basis for the CPSES Emergency Plan and that deletion of the graphs should be acceptable,

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Attachment l'to TXX-98207 )

Page 10 of 11 1

i P. J 2 thru J 4. Appendix J " Emergency Equipment And Supplies" L

! Change'

Description:

l L Revise all Appendix J information.

Justification:

l 1 This change revises all information to eliminate redundancy, unnecessary and )

meaningless detail, ambiguities and erroneous information, and-delete 4 certain listed items of equipment / supplies.'This Appendix continues to

. reflect the intent of NUREG-0654. Section H

  • Emergency Facilities and i Equipment', paragraph 11 which states: "Each plan shall, in an appendix, include identification of emergency kits by general category (protective equipment, communications equipment.. radiological monitoring equipment and emergency supplies." u l .

l Certain items of equipment / supplies are being deleted from the Appendix L

listing. TU Electric no longer maintains respirators or plastics in the CPSES Emergency Response Facilities (ERFs). TU Electric does not believe this to be a compliance issue because of the following:

1 a) The current Appendix J listing of equipment / supplies is stated as being l

" representative of that which is maintained" and "the specific inventory of equipment and supplies for each facility or location is prescribed by and

maintained in accordance with Emergency Plan Procedures (EPPs)". This I wording is intended to mean that the Appendix J listing of l supplies / equipment maintained is " typical" with the " actual" supplies / equipment maintained being specified by the EPPs and related quarterly inventory logs

l b) A previous CPSES Emergency Plan description of respiratory protection L equipment (RPE) (e.g., full-face respirators, particulate and sorbent canisters, etc.) maintained in the ERFs was revised and clarified in Revision-22. effective June 25, 1995. Revision 22 deleted the description of RPE.in the ERFs (except for Self Contained Breathing Apparatus (SCBAs) and provided clarifying discussions of what protective measures may be implemented instead. The Appendix J listing of RPE was inadvertently not revi. sed with the Revision 22 changes. This proposed change updates Appendix J and provides consistency with the sections of the CPSES Emergency Plan that were previously changed in Revision 22 (Section 6.2 " Operations Support Center": 6.11 " Emergency Equipment and Supplies"; 8.4 " Provisions for Protecting Onsite Emergency Response Personnel": and 8.4.1 " Respiratory Protection"). The Revision 22 justification was that RPE is readily L .available if needed from other plant locations and supplies maintained by Radiation Protection. Also, coincident with implementing the new 10 CFR Part i

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Attachment 1 to TXX-98207 Page 11 of 11 l 20 regulations and related new polices concerning RPE. the unevaluated use.

l' of RPE against airborne radionuclide hazards was generally reprioritized by l

nuclear power licensees to a last resort in lieu of other protective measures JSome reasons for not using RPE include: An unevaluated use of RPE may actually increase an individuals' radiation exposure: increased personal safety considerations and slower response times must also be considered due

- to physical and mental stress, fogging / limited vision, limited communications, etc. by employing a combination of ERF habitability monitoring..other protective measures and administrative controls (e.g. exterr.a1 exposure thresholds, DAC-hr tracking, ingestion of KI. and/or relocation), RPE'use by ERF and offsite team personnel will not normally be required, l P..Q 4,' Appendix Q " Definitions" Change

Description:

Add a definition titled " Periodic Definitions" that defines the terms

" monthly", " quarterly"," semi-annual or semi-annually", "12-months", and l

" annual or annually" as used in the CPSES Emergency Plan. l Justification: I Change adds a definition of each frequency term used in describing  !

events / tasks that are required to be performed on a regular periodic basis.

This change is added for clarification. The definitions added are specific )

- to use in the CPSES Emergency Preparedness Program and are to be used in meeting timely implementation / maintenance-of those periodic CPSES Emergency Plan requirements that are tracked and/or scheduled by the CPSES Emergency Planning or Nuclear Overview Department action item tracking systems. These definitions have been reviewed for consistency with guidance documents. The proposed definition of "12-months" is consistent with NRC staff Memorandum dated August 28, 1990 from Phillip F. McKee, Chief, Reactor Safeguards Branch. Office of Nuclear Reactor Regulation, on the subject " Guidance--

Definition of "Every 12 Months" and information in NRC Inspection Module

  1. 81034. The proposed definition of " annual" is consistent with information

. documented in NRC Inspection Report 50-445/446 95-21, Section 4.1.

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ATTACHMENT 2 TO TXX-98207 MARKED-UP COPY OF CURRENT PAGES AFFECTED l

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CPSES/EP 1.1.3 RECOVERY 25

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Actions taken to return the plant to an operational status or maintain long term safe shutdown condition after the emergency response actions have been completed.

, If a recovery effort is deemed necessary, the CPSES Recovery Organization is

! established in accordance with Section 11.0 " Recovery and Reentry " {

1.2 EMERGENCY RESPONSE SUPPORT AND RESOURCES 1.2.1 Corocrate Succort i

TV Electric maintains sufficient management and personnel resources at the CPSES site to effectively staff (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) the CPSES Emergency Response Organization and its intended emergency mitigation functions. This arrangement preempts the l need for a separate organization of offsite corporate personnel to be identified for, and incorporated in, the CPSES Emergency Response Organization; however, in l the event of an emergency requiring assistance from offsite organizations. TU Electric management is fully committed to providing other resources to assist the CPSES Emergency Response Organization. Examples of other corporate capabilities existing within TV Electric include public information services, materials procurement services, contract manpower and ccnstruction services, legal and insurance services, and additional technical support.

1.2.2 Local Services Succort The local response organizations involver with emergencies at CPSES are the Hood County and Somervell County Emergency Organization. Each county has an emergency operations plan which describes the counties emerger3gy response. The County 26 Judge is in charge of the emergency organizations and has the legal authority for protective action decision making within their respective county. a assist the 25 county emergency organizations. TV Electric sends a representative who is familiar with station operations and the CPSES Emergency Plan to each county l Emergency Operations Center. The representative functions as an advisor and may act as liaison between the county officials and the CPSES Emergency Response Organization; however, these representatives are not company spokespersons. w/dcli h, d, eg rht twat Support from local organizations may be obtained through direct notification to g g the individual organization. Letters of Agreement from each organization to

@f8g provide their respective emergency assistance to CPSES are maintained onsite list of Letters fclicwing of Agreement crgaaizat4 is provided

  • 1eal eupper+in Section groupe 15.0.have which Appendix agree Hf_ Jr.s tc provide--

_ ser"4ccc. if idquested.

Sumervell Cvuuif V0lunL66i Ilie. RC; cue, and [MS Servic5 - 10c51 26 n rc fighting ;upport

- Scmcrve!' Ccurty Sher 4f'- 13: enforccm:nt, c::itt e"acu tion 25 cfforts, traffic C0ntrr': Occurity e Hood County Sheriff law cnfcrccment. ;asist avacuet10n effort 3. ---

- traffic control:. ::curity

=- Leke Giantury "cdic 1 Center treatme..t Of contaanneted inJuied 27

_e Big 0 ^~bu'ence Ser" ice (Gr:nbury) trcn;portatico of cuuLaonnetcb 26 4njured

- Wall 3 R69iGnal MO3pitGl tie 5tsent Of cQuioniinaLed ulJUFed 26

-perserne!

l 1-10 Revision 27 July 24, 1998

1 CPSES/EP f

1.2.3 Private Sector Succort 25

Support from private sector organizations may be obtained through direct

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notification to the individual organization. The following organizations-hsm ym w provide services, if requested: l e Westinahouse Corocration l

Westinghouse Corporation, the designer for the Nuclear Steam Supply System (NSSS) has an emergency response group which provides for ,

emergency engineering assistance to facilities having a NSSS designed by Westinghouse. This assistance is available on a 24-hour / day. 7-day / week basis. Details of the response is contained in the Westinghouse Emergency Response Plan.

e Institute of Nuclear Power Ooerations (INPO)

INP0 is an industry technical association whose Emergency Preparedness Division acts as a clearinghouse for maintaining a roster of individuals and skills available to each utility for augmenting the onsite ERO. INP0 also serves as a clearinghouse for maintaining an inventory listing of material, equipment, and services which may be used to supplement onsite resources. Details of the response is contained in a letter of agreement.

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e Houston Lichtinc and Power The South Texas Project provides a backup service for analyzing

~ Post Accident Samples. A Letter of Agr,eement outlines the analyzing capabilities of the Septh Texas Project Laboratory, e American Nuclear Insurers (ANI)

TU Electric maintains a policy with ANI. ANI has agreed to assume responsibility for promptly assisting members of the public who may be adversely affected by an event at CPSES. This insurance policy alleviates the imediate financial burden that may be incurred by members of the public due to evacuation and relocation associated with an incident. ANI will have their representatives on the scene, prepared to comence the distribution of emergency funding at the earliest possible time, on a 24-hour a day basis.

1.2.4 State Aaencies The State of Texas has developed a Radiological Emergency Management Plan as a part of the State of Texas Emergency Management Plan. The fundamental legislation providing the basis for emergency response by civil authorities is the Texas Disaster Act of 1975, as amended. This act creates a Division of Emergency Management. The Division of Emergency Management is part of the

! Governor's office and is placed under the Director of the Texas Department of l

Public Safety by an Executive Order of the Governor. The duties and responsibilities of the principle and support agencies of the State of Texas are summarized below. The Comissioners of the Texas Department of Agriculture and 26 the Texas Department of Health are responsible for implementing protective actions within the Ingestion Exposure EPZ in accordance with the Texas Emergency Management Plan. A detailed discussion of the state's response is contained in the Texas Emergency Management Plan and supporting Letters of Agreement. See Section 15.0 Appendix H for a list of Letters of Agreement.

l 1-11 Revision 26 l

October 15, 1997 I

CPSES/EP o Division of Emeraency Manaaement 25 The Division of Emergency Management (DEM) is the4ead. agency l

^

responsible for coordinating overall response to emergency situations in the State of Texas. The Director. DEM, assumes overall direction and control of the state's response to an  ;

emergency condition at CPSES. I e Texas Deoartment of Public Safetv The Texas Department of Public Safety (DPS) serves as the primary communication contact and coordinates emergency comunications between CPSES and the State of Texas. Hood and Somervell Counties.

The DPS coordinates with the local law enforcement officials and assists in maintaining traffic control, protecting life and property, establishing road-blocks, and alerting and warning L persons in the affected area. The Highway Patrol Captain in l District 6A Waco, Texas serves as Chairman of the Disaster District Committee. Requests for assistance from the local county EOC's are forwarded to District 6A. Requests that exceed the District's capability are forwarded to the state EOC in Austin. Response time

for DPS personnel from the Disaster District Office in Waco to t!1e station is approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. ,

ggg

  • Texas Decartment of Health /ct to i overwents b'*, & - ' ,

The Texas Department of Health (TDH), ' of Radiation Control S j (BRC) is the responsible agency for madt to a radiological emergency at CPSES. Once notified of a Site Area or General

^

Emergency by DEM, the BRC will establish a communication link from their Austin office to the station. The BRC dispatches response 26 teams to the station in accordance with provisions of the Texas Radiological Emergency Management Plan, The BRC response is 25 directed by the Bureau Chief. The response team is capable of providing environmental sampling and radiological monitoring.

including a mobile radiological laboratory. This laboratory serves to analyze low-level radiological environmental samples. CPSES provides telephone and electrical hook-ups for use by the laboratory. It is expected that BRC personnel and the laboratory should arrive at pre-determined locations within approximately four hours of notification. Space and telephone lines have been provided in the EOF for the response team. The BRC also provides assessment of offsite hazards and protective action recomendations.

. 1.2.5 Federal Acencies

The CPSES Emergency Coordinator is authorized to request federal assistance on

, behalf of the station under provisions of the Federal Radiological Emergency l

Response Plan. The CPSES Emergency Coordinator requests federal assistance by contacting the NRC. The Federal Emergency Management Agency (FEMA) is also a federal agency responding to CPSES.

r 1-12 Revision 26 October 15, 1997

- . . . . _ ~ _ _ - - . - _. .. - -.._-.

CPSES/EP @

To support the federal emergency response efforts, the following facilities are 25 available:

Airports: Granbury. Cleburne. Stephenville. Meacnam in Fort Worth. Love Field in Dallas, and Dallas-Fort Worth International Motels: Granbury. Cleburne. Stephenville. Dallas, and Fort Worth CPSES: Working space within the CPSES Emergency Response Facilities (ERFs) has been allocated for co-location of NRC personnel. Phones are available for NRC personnel within the ERFs.

e Nuclear Reculatory Commission Specific responsibilities assigned to the NRC include:

Notification of FEMA whenever a radiological event occurs or when there is a high potential for such an event.

Monitoring operational data and assuring that adequate information and recomendations are being provided to offsite agencies.

As a back-up to CPSES, providing a technical assessment of diisite radiological and plant conditions to FEMA and other federal agencies, and keeping state and local offsite agencies apprised of any operational discussions that may affect offsite protective actions. ,

' In coordination with CP3ES and state and local offsite agencies, disseminate onsite data to FEMA and federal agencies, the news media, and the general public.

l Methods of notifying the NRC are discussed in Section 3.0.

' " Notification Methods and Procedures." The NRC may be expected onsite within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of receiving notification of the event.

R: "C ch; h:: : :Obile h boratory ith the c5p5bilitie3 to I T andy 0 Post Mcidcr.t R :p10 and en"4ronm0nt:1 :::pks. UUd-ups wa-ev:ibbh :t th0 MOSF to Opcrate this laboratory. l e Federal Emeraency Manaaement Acency i

FEMA is responsible for coordinating all offsite federal agency responses. Specific responsibilities assigned to FEMA include:

Coordination of federal support to state and local officials.

Dissemination of data on offsite support actions to the federal agencies.

i FEMA may send personnel to the EOF to coordinate activities with CPSES. NRC. and the state.

1 l

1-13 _.

October 15, 1997

Y TABLE 1.1 STAFFING REQUIREMENTS FOR EMERGENCIES .

PAGE 10F 2 ,

i FUNCTIONAL AREA TASK- ONSHIFT ADDITIONS WITHIN MINUTES OF ALERT ADDITIONS AT' 26 SAE OR GE. .

40 70 Station Operations Assessment of Operational Shift Manager (SRO) Plant Equipnent 27 ; .q

l. Aspects Unit Supervisor (SRO) Operator .;

Reactor Operators (RO) (2)-

Plant Equipment Operators (4)  !

Emergency Directi Direction and control of onsite Shift Manager (SRO) " TSC Manager EOF Manager . 26 -  !

and Control e emergency act'vities as Emergency Coordinator.  !

Comunications Notify station.. local. state. I&C Technician TSC Connunications EOF Communications and federal personnel and Coordinator. Coordinator'  !

f maintain comunications.  ;

Comunicato. TSC ENS Corr 1unicator

.t Security Site access control and Security Shift Supervisor Local Support EOF Security l

personnel accountability Coordinator .;

Security Officers (Per Security y Plan)

Public Information Approve release of public Shift Manager *- TSC Manage M h Company information Spckesprson [

s Logistics Obtain/ Expedite needed resources Shift Manage d ) TSC Comunications EOF Logistical [

for the ERO. Coordinator *- N Support '[

Coordinator ,

Station System Coordination / Control TSC. Engineering Team [

< Engineering Coordinator [

Y f Technical Support Shift Technical Advisor S;i - TSCEngTeam(/)

l l

r Revision 27 t July 24. 1998

i TABLC 1.1 . j STAFFING REQUIREMENTS F0P. EMERGENCIES PAGE 2 0F 2 FUNCTIONAL AREA TASK ONSHIFT ADDITIONS WITHIN MINUTES OF ALERT' ADDITIONS AT ,

SAE OR GE 40 70

[

Radiological In-plant Survey R.P. Technician R.P. Technician (2)  !

Assessment [

Chem / Radiochemistry Chemistry Technician Chemistry Technician [

l Onsite Surveys R.P. Technician R.P. Technician -

l Offsite Surveys R.P. Technicians (2) Vehicle Drivers (2) i Dose Assessment Shift Technical Advisor TSC OnRAC EOF Dose Assessor Protective Actions R.P. Technicians (2) d M R.P. Technicians (2) R.P. Technicians (2)

Coordination / Control' Shift Manage F TSC OnRAC A EOF R.P.

Coordinator  !

System Corrective Emergency Repair and Damage Plant Equipment Operator N N OSC Nanager ' 27 I Action Control (ERDC) Mechanic Mechanic- [

Electric 1an A. Electrician ~ [

I&C Technician IEC Technician ,

Fire Fire Fighting Fire Brigade (SP 0o local Support 26-i f

Medical Rescue Operations and First Aid Safety Services ~ Technician Local Support I

Chemistry Technician *-N TOTAL 18 &6 -& *2,2. 6 y be provided by onshift or augmentation personnel assigned other functions. 26 .

Shift Mamger serves in this capacity until relieved by a designated individual (Section 1.1.2.2).

g h _

(c) The minimum crew conposition may be one (1) less that the minimum specified for any position for a period of time not to exceed two (2) hours in order to acconunodate unexpected absence, provided inanediate action is taken to fill the required position. This exception does not pemit any ciew composition to be unmanned upon shift turnover due to an oncoming crew menter being late or '

absent. l l

^ '_ f Revision 27 o 1 f\eid,-

Q l

_ _ _ _ . . -_ - . . _ _ - . . _ - - _ _ - _ _ _ _ _ _ _ _ _ _ . - - _ _-_____ __ - - - - - _ _ _ _ _ _ _ _ - _ - - _ - _ ._ - _______ _ . __-_ _D

TABLE 1.2 l PREDETERMINED RESPONSE ACTIONS

PAGE 1 0F 1 l

l PREDETERMINED RESPONSE ACTIONS NOUE ALERT SAE GE Notify state and local authorities within 15 X X X X l- minutes of declaring the event. .

Notify the Nuclear Regulatory Commission X X X X

[ (NRC) immediately after notification of the -

i state and local authorities but not later than one (1) hour after. declaring the event.

Staff and activate the Emergency Response X i X X Facilities:

Technical Support Center (TSC)

Operations Support Center (OSC)

Emergency Operations Facility (EOF)

< Activate the Emergency Response Data System X X X l (EROS) as soon as possible but not later than i l one (1) hour after declaring the event. !I Assess the event and respond accordingly.. X X X X Dispatch Onsite Survey Teams. X X X l Dispatch Offsite Monitoring Teams. X X l Provide periodic plant status-updates to X ., X X X offsite authorities. .-

Provide periodic assessments.of X X X meteorological conditions to offsite authorities.

l Provide periodic media briefings. X X 1

! Provide senior onsite technical and X X management staff available for consultation with NRC and state on periodic basis.

Provide release rate and dose projection X X X jnformation.

Escalate to more severe <: lass. if X X X appropriate.

Closecut the event with verbal summary to X2 X, X, Xz offsite authorities followed by written l

summary.

1 EOF activated at the SAE.

! q 2' Notification Message Form used to closeout the emergency may be used to l satisfy the requirements of verbal notification and written summary to offsite agencies.

NOUE Notification of Unusual Event SAE Site Area Emergency GE General Emeraency f2ecommead robOve adYoM N i ,

t ofOite 8 DIS Revision 25 '

.. October 1, 1996 0 -

CPSES/EP 3.0 NOTIFICATION METHODS AND PROCEDURES '

c Thish:: ionhapdescribes

[sy methods,for cnd - sto+dyIM9"ich dure: by CPSES per: nnel tr:ncmit

- ;:n ;afo,m:t4:ntelocq,1andf:: ate authoriti ue du W:tleclSE.S Ksspo".re Ory4 Wizod Emuyeut- cIAssINcahW af CMES,

  1. gs, and 4ub:q)w ntly, from such74. si (Geo) d., 6 red eineryen autherdtic t; the public. Details required in land $ low-ud messages are. described. = Or typa cf n= rele:::: 44 ch may ha "ce +0 arevide publi ,

A# '"?Cr=tiCn ^ gc(criniy These NoYcedtodS

Emergency Plan Procedures (EPP's) describe processes for,,netif.r ng the CFSES l E crgcacy Or gonitoi ivo und ' ci" tai"",g the CPSES Natific;tica "- te , ntai -

i

- emerg:n 3 talcphvoe numven, ivi off:it genci;;

transmitting information to local/ and The/ pr:::::

tate of00natifjin; s)and th; centain[m M

^

oHNh- E<nere/ pendIo"r O 6vr/cVyfd Emeqe /""1 ON}'y'thoeilieS a fs */^'j;' *W on'e.

, , e-}ewies a kSESEmerg c c$aNizabn ugg/ ae Cgj Qjg7,,g ,7y;,,c j g7 jgjj4/

g, eithertheplantpagepartysystem,theintrah elephone stem' or commerci,al clfig te1ephone. The fayer Cyg/en, iS cW afh'.ra.,fe m eco U S -fo Alst-i .s e/cch elas eri ecf saemsy fedica' ber,g of %6,1590 7)uu. ,

! Offsite agencies are notified via dedicated telephone, commercial telephone or telecopier. r Moreinfopati d j3 f h , gn rAlsp carding b Scrlbss b w! b communication systems 4l4ce. WITANtl may be found

/c Ale Smergeac /%wi ~2one. ( LS g/e 26/ k A clVISc ) D f K. 65 em 6y /cc4/ SNA-io ls .

M INITIAL NOTIFICATION fef g k

@ Following declaration of an emergency at CPSES, th: .o-uuLy ChiTL .onosc.

the following are notified:

coaui ca \ [\ reloedhy v e. u)

a. Hood and Somervell County Emergency Operations Centers 3 /./)

l b. Texas Department of Public Safety in Waco, Texas l

l e On-aty 9c"-it3 hift Supervi:cr hejacdjfo 3 ch

d. NRC Operations Center Li gacy C. ;;"4 "H nn ar= ret (vea /

(fcICC4 3 l.2 ) to 3o j _ .

j

--4-e-- VERIFICATION OF INITIAL NOTIFICATION 7p,l,,gy/

Authenticity of initial notification provided to Hood and Somervell County f^l Emergency Operations Centers and Texas Department of Public Safety shall be -

rtou/

verified as specified in operating procedures of Texas Department of Public

/-/

L . Safety Communications Center, Region 6 Headquarters. Waco, Texas.

1 l

l 3-1 Revision 27 July 24, 1998

py 'hYhvJ h,l.} h INITIAL notifications from CPSES to local and State authorities are performed when the

- following conditions occur:

e ' Initial declaration of an emergency classification

{

(Notification of Unusual Event, Alert, Site Area Emergency, General Emergency) e Escalation of an emergency classification e Initial Protective Action Recommendation (PAR) e - Change in a PAR e Emergency termination INITIAL notifications shall begin no later that fifteen (15) minutes after one of the above conditions are met.

w 1

i

CPSES/EP 44- ' INITIAL MESSArfS TO'0FFSITE AUTHORITIES The initial notification message transmitted to offsite authorities contains: ,

a. Caller identification g]
b. Class and brief description of emergency ) pep)
c. Whether a radiological release is in progress and areas / zones / sectors affected.

3./.l}s 1

d. Recommended protective actions, if any.

.. L4- FOLLOW-UP NOTIFICATION ,]g gblgg l(reloedeA As the situation progresses, follow-up 1iformation is sent to offsite re7 esied by 7bJe

,g

' support / response authorities at intervals of approximately one hour or p ,

v8W 3*I- ' conditions change (i.e., change in protective action recommendations, Guergency C roj ec M /d class escalation or de-escalation, termination of the aergency). This fu S.//)

'information is usually transmitted by telecopier but m y be " announced" or -

transmitted by voice communications. Telecopier transmission of information uses G re.locM commercial telephone systems, where voice communications may be by dedicated ;g a y, A telephone or commercial telephone. /

l C . '; FOLLOW-UP MESSAGES TO 0FFSITE AUTHORITIES

' The following information, as it becomes available, is provided to offsite authorities in follow-up messages:

a. Caller identification "C"
b. Emergency Classification }d
c. Meteorological conditions (wind velocity, direction, temperature, deM atmospheric stability data, and form of precipitation, if any) x 3.l.3J
d. ~ Status of emergency response actions initiated l
e. Recomended offsite emergency response actions, including protective action measures
f. Requests for onsite support from offsite organizations 3.0 INFORMATION PROVIDED TO TEXAS BUREAU OF RADIATION CONTROL l Upon request, the following information shall be provided to the Texas Bureau of l Radiation Control:

I L a. Type (airborne, waterborne or surface spill) and estimated duration of radiological release (actual or projected)

b. Estimated quantity of radioactive material released and point of release-3-2 Revision 27 l- July 24, 1998 L

CPSES/EP

c. Chemical and physical form of released material, including estimates c of relative quantities and concentrations of noble gases, iodines and %hp '

particulates

d. Estimctes of radioactive surface contamination, onsite or offsite.
e. Actual'or projected dose rates and integrated doses at the site boundary,'and at two, five and 10 miles, and affected zones and sectors. f2.'/.3
f. Prognosis for escalation or termination of emergency based on current plant information.

3.h PUBLIC WARNING l The resident and transient population within the 10-mile EPZ is alerted to an emergency at CPSES by an Alert and Notification System. The Alert and Notification System is comprised of a series of sirens which alert the populace to tune their televisions or radios to designated Emergency Alert System (EAS) stations to obtain current information and recommended protective actions.

'The EAS provides emergency related information to the general public in the CPSES '

area over radio station WBAP (820 AM) and television station KXAS-TV (Channel 5).

N'lCd/

l Information and instructions provided to the general public via the EAS originates from county officials.

l Q

Local officials, primarily County Judges and County Sheriffs, are responsible for

-operating the Alert and Notification System and providing messages to the EAS g

. stations. CPSES and state emergency response personnel provide recommendations to local officials concerning use of the system: however, only local officials i can authorize use of the system in warning the public.

-0 The Alert and Notification System consists of 66 sirens and was designed, installed and tested to meet the requirements of FEMA.

Operation of the Alert and Notification System is accomplished from either county's Emergency Operations Center (E0C). Normally, each county EOC will operate those sirens within its jurisdiction: however, if needed, either E0C can

, operate the entire system. The 10-mile EPZ is divided into quadrants. Sirens located in each quadrant are programmed to a unique control code. Each quadrant can be activated independently; however, each siren can be operated individually for purposes of testing.

, Tu f)MM l-

~

GREG retains ownership of, maintains and tests sirens as described in appropriate mergency Plan Procedures.

i asa l

l t

4 L 3-3 Revision 27 l

July 24, 1998

1 CPSES/EP j S l 3.[ METHODS OF PROVIDING PUBLIC INFORMATION REGARDING PROTECTIVE ACTION MEASURES '

(frinig !!w}Io Public warning, discussed previously, is part of the mechanism for providing information to the publ ic. Preceding and continuing into the operation of CPSES, emergency response infc rmation is provided to the public within the 10-mile EPZ. l p g/ gesidents are provided)Ia backlet ci ethcr publication which provides instructions for emergency actions. Information regarding emergency actions is also provided m)gM l

-en-imnci 5 aod h at various location or establils iments within the 10-mile yo l P and in local telephone _ directories. Emergen related Information_is _ y j transmitte via the Emergency Aler ys em (EAS). 1c5;agc; m y addrccc- i

_ p, c  :; grarr e w c m .

!v' otic" rcutc; eiid relac5ticri

-w- ~m,m ,,,c+

n rm ,4 an antnrmstinn 3hn,,t +hn ~c4+.u4- t enrre ed In co~nty and s ate emN e k rb M lans. T8 '"!

dditiona in orma 1on a ou pub ic in o lo 1s pro 1 e in hapter 5 o "To this plan. M 3b 1

3-4 Revision 27 July 24. 1998

CPSES/EP h

7.3.1 ONSITE RADIOLOGICAL ASSESSMENT Initially, during an emergency condition, the on-shift Radiation Protection and 24 Chemistry /Cc..i -end Technicians perform onsite and in-plant radiological l assessment, and sampling activities, respectively, as directed by the Shift Manager' ,

O n c e r A e. TSC l5 Acrwaded

_In the cant th; sccsicj c: cites to er ^1ert, responsibilities for onsite and 12l offsite radiological assessment and sur,ey activities shall be assumed by the TSC i Onsite Radiological Assessment Coordinator. As CPSES Emergency Organization 8 i personnel become available, onsite radiological survey teams shall be formed as required and dispatched from the OSC. Onsite Survey Teams initially shall be l I

composed of at least two members, at least one of which shall be a Radiation Protection technician. The Onsite Survey Team (s) perform required onsite and 10 in-plant surveys in accordance with approved Emergency Plan Procedures.

0Nce The GOP [S AdEnded 4n the e'!ent the ergency waleter to : Sit: Ara Occ;ac., cc Cec.arai 12 Emer;:ncy, overall responsibility for encit; cad offsite radiological assessment shall be assumed by the EOF Radiation Protection Coordinator.  ;

1 l

Communications between the Control Room, TSC, OSC. EOF and the Onsite Survey 8 Team (s) shall be conducted in accordance with Section 4.0 of this plan.

Transportation for Onsite Survey Team (s) is provided in accordance with Emergency 10 Plan Procedures. Based on arrival time (s) of CPSES Emergency Organization .

8 personnel. Onsite Survey Teams should be deployed within 15 to 30 minutes after arrival on site. Deployment time may vary due to duration of onsite briefing session, time required to obtain protective clothing and equipment and time required to prepare for entry into plant environs.

7.3.2 0FFSITE RADIOLOGICAL ASSESSMENT

()Mce The 80 P i6 Ach%9 fed ency or General Emergency 10 dc & red, the EOF

=Ir the c'/ent 3 Wo Aron E 12 l Radiation Protection Coordinator assumes responsib111 ties for coordinating offsite radiological assessment and monitoring activities. Each Offsite Radiological Monitoring Team should be composed of at least two members, one of which shall be a Radiation Protection technician. 26 In the event that dose projection or onsite monitoring results indicate the potential for radioactivity release with offsite dose consequences, a Radiological Offsite Monitoring Team can be dispatched. Deployment time for the first offsite team dispatched is estimated to be within E5 to 70 minutes of an Alert or higher classification. This time includes team c rival, equipment check out and receiving a brief on expected radiological conditicsis.

The E0F Radiation Protection Coordinator and his staff dispatch Offsite 12 Radiological Monitoring Teams to preselected points in affected downwind sectors.

Offsite environmental monitoring locations are identified in Plant Procedures. 25 At preselected points, the team should perform external dose measurements, obtain 10 air samples, determine contamination levels and obtain vegetation and liquid samples as required. From this point the team can be moved to determine the plume boundary, centerline of the plume and other factors necessary to determine impact of t;he release, on the public and environment. This monitoring shall continue, as required, during the emergency so the need for protection measures can be quickly assessed.

~

7-3 Revision 26 October 15, 1997

l 8.1.3 MONfTORING OF EVACUEES 25 During a site evacuation, if the evacuees are potentially contaminated, the Emergency Coordinator should direct evacuees to proceed for radiological monitoring at an offsite Reception Center. At this center, evacuees are logged l

in/out, monitored for contamination, and decontaminated if required.

8.1.4 RESPIRATORY PROTECTION Ouring an emergency, air sampling is performed throughout the site area to ensure protective measures are implemented in a timely manner. These protective measures may include external exposure thresholds, DAC-hr tracking, ingestion of radioprotective drugs, relocation, respiratory protective equipment, or a combination of the above. Respiratory protective equipment is available onsite for issue in accordance with Radiation Protection procedures.

8.1.5 PROTECTIVE CLOTHING Protective clothing is available from storage areas and Radiation Protection supplies located throughout the site. This clothing is standard anti-contamination clothing and includes coveralls, hoods, gloves, and boots g,, j

  1. "/P d N #Gk 8.1.6 RADI0 PROTECTIVE ORUGS supplicA A055k locallws ,

I A thyroid blocking agent such as Potassium Iodide (XI),kstadpilciat varip_us g strategic onsite and offsite locations shall be offered to CPSES emJr.gency g g response personnel in accordance with an Emergency Plan Procedure.AState or loca g ggg government emergency plans and procedures describe KI use respective tocergeng &7 h,od 16, C5W personnel * ^" """~ ~' ~^ ~~

V ^--^^- '

,w);g 3 8.2 0FFSITE PROTECTIVE ACTIONS N

Personnel and visitors offsite, but within the owner-controlled area, are warned 26 of an emergency by the Security,Drganization or by Squaw Creek Park personnel in accordance witn the Squaw Creek Plan for Response to Declared Emergencies at CPSES. Security personnel are notified of the emergency by Control Room personnel as described in Section 3.1. Squaw Creek Park personnel are notified of.the emergency by the CPSES Security organization in accordance with Security procedures.

i Protective action recomendations (PARS) are formulated during an emergency by 25 CPSES personnel and are included in notifications to offsite authorities as specified in Section 3.0. These PARS are based on either existing plant conditions or projected offsite doses, and are updated 'as conditions warrant.

Offsite protective actions are then directed and implemented by State and local authorities based on the ocomendations and information supplied by CPSES.

Specific protective actions to be recommended are based on the guidance of the EPA's " Manual of Protective Action Guides and Protective Actions for Nuclear Incidents."

8.2.1 EMERGENCY PLANNING ZONES Emergency Planning Zones (EPZ) have been established surrounding CPSES for

! s planning purposes in the event of an accidental release of radioactive material from the site. . .

8-2 Revision 26 October 15, 1997

CPSES/EP .f, /g ,, m 2 , h 12.2.4 RADIOLOGICAL MONITORING DRILLS $

5,neryeaa

,fisa] 27v;)

20 "

hDN,f T/a //im Station person assignedtoradiologicalmonitoringteads/%ahhall pafticipate inEeidy eg ofA annual drillsg,1ch inv0hc rcaponse5 to cate and cff;ite cnviron=ntal phase,9m monitorwj.

7 These drills shall include colkctic" and an:lysi; cf :!' agic medie 'c.9.c 6 Mater "eget: tion, 30i1 and cir!, and provisions for communications and record keeping.

d 12.2.5 HEALTH PHYSICS DRILLS Health physics drills shall be conducted semi-annually and involve response to 6 and analysis of simulated elevated airborne and liquid samples and direct radiation measurements in the environment.

In accordance with approved ALARA guidelines, an analysis of in-plant lig:'M 11 samples with actual elevated radiation levels, including use of the Post-AL;ident Sampling System, shall be included in health physics drills annually.

12.3 DRILL AND EXERCISE SCENARIQS, Drill and exercise scenarios are developed to provide a method to test and 12 evaluate the CPSES Emergency Preparedness Program. These scenarlos are designed 9 to allow free play in decision-making and shall include, as appropriate:

a. Basic objective (s) of each drill and exercise, and appropriate 6 evaluation criterla;
b. Date(s). Ume period (s), location (s) and participating t organizations;
c. Simulated events:
d. Time schedule of real and s'mulated initiating events;
e. Narrative summary describing c6nduct of the exercise or drill which addresses simulated casualties, offsite fire department assistance, rescue of personnel, use of protective clothing, deployment of radiological monitoring teams, public information activities; and
f. Description of arrangements for and advance materials to be provided 6 to official observers.

The Emergency Planning Group is responsible for developing drill objectives, 13 exercise objectives, and developing exercise scenarios. Scenarios and objectives 27 developed for those exercises or drills requiring NRC and/or FEMA evaluation shall be approved by the Plant Manager

  • and submitted to the NRC and/or FEMA for review and approval.
  • See FSAR Section 13.1 Mcdi p g,} 7b t%d 'ca/ nwriYMN '

"IVMS 9" 0N 5"N w .gcysyef Sh"'I?cA/ jdf ak )Nd mskln// S

- ewi m'@'

dS SD/lfwrer, gd Vef aGcw. Td ese./o colkc ///s maihla'4' 4Ya4 g" l d 'f j f4 ,, l } y q ' y % k

  • 9 " " " U "'" $

12-2 Revision 27 July 24, 1998

- . . CPSESfEP

/

v i

\

APPENDI B

.g=

TIME /DISTANC / DOSE (THYROID)

CURVE FOR A LOCA CONDITION AT CPSES l

.a l

B-1 h

4 m

. . . - . _ _ m.m ._ - _._. _ __ . - , _ . . _ . __ - . . ._. _- .. . _. . -. . - ._.

I

!. CPSES/EP l-i APPENDIX B The graphs, Figures B1,'C1 and'D1 (appendices B, C, D,Lrespectiv y), 10 represent reference dose limits at x miles downwind and t hour following a postulated loss of coolant accident. The assumptions made t achieve these accident conditions are fully described in the FSAR, Secti 15.6.5.4. The following is a synopsis of those assumptions; Integrated doses to the thyroid and whole body a , calculated using methods and assumptions in conformance with Re latory Guide 1.4 and are:

a. 25. percent of radiciodines are avail le for leakage in the i

following form:

t i i l 91 percent - element iodin 5 percent - particulate odine-4 percent - organic i ides l

l

-b. 100 percent of the radio tive noble gas inventory is available l for leakage from conta ment.

I

c. Effects of radiolog al decay during holdup in containment are taken into account l d. Containment art ' system functions, reducing elemental I radioiodines a allable for leakage by several orders of magnitude.

i e. Containmen leak rate is 0.10 percent of containment volume per

! day duri first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and 0.05 percent per day for duration

.of acci nt.

f. Accid nt duration is 30 days.
g. Al releases are made at ground level, t

l h. o credit is taken for depletion of effluent plume by decay or deposition.

l i 1 -Breathing rate and iodine dose conversion factors are in the FSAR, Section 15.6.5.4.

G/

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_ CPSESEP PENDIX C TIME /DISTA E/ DOS 5 (WHOLE BODY GAMM J CURVE FOR A LOCA NDITION AT CPSES C-1

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WHOLE BODY GAMMA DOSE i REVISION 5 OCTOBER 12, 1982 FOLLOWING LOCA 1

j FIGURE C.1

,. CPSES/EP ,

I W

APPE IX D TIME /DISTANC DOSE (WHOLE BODY TOTAL) RVE FOR A LOCA CO ITION AT CPSES l

i

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k i D-1 4

l

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O-l (1/ 0.01 0.05 0.1 0.5 1 5

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0/ DISTANCE FROM RELEASE (mi)

COMANCHE PEAK STEAM ELECTRIC STATION EMERGENCY PLAN WHOLE BODY TOTAL DOSE REVISION 5 (GAMMA & BETA)

OCTOBER 12, 1982 FOLLOWING LOCA FIGURE D.1

,. 4 - . . . . _ . . , ,,_ - . - ~ . . . ~ - , _ . . ..

u v" m' ""r" r, i g ", Af i

CPSES/EP' -l

(

m n l

/k Gyy TV Tb3 fA}L ,

1 I

l l

L APPENDIX J )

Emergency Equipment and Supplies l

l r

I.

t 1

i F

i J-l Revision 12 l September 28, 1990 M N $

l

j. CPSES/EP

~

~

s n('L W D-] 16 EMERGENCY EOUIPMENT aND SUPPLIES . ,

" gg pe) o f/cd.e FACr lil/e5 re y s e }cabine+s,;pmud nd M i.s /*'shMslPm'A W ruch

,s;3 e p y j pkces as TUElectricmaintainsemergencyfeguipmentandsuppliesingtheControlRoom. 25 i

Technical gggnt gr,atg upgr;tpngymergency j Operations ,

Facil_ ity. kcal hospit 13. nd Other Orit0 locations d(de 7/7'S *1"' T

g., ,,e2  ;+. 5aesa)h p- oc,rr,w p aca.S nSgcaq. w Emye y Opwa//$.s &n/us(/d"#' Gdsf p h 1^
:t,tfiree company vehicle h:11 be availeble Tw Offsite Mogtoring hms, t pers;nn:1 A strh e a,' W i' f

'_' offsde-

&radlol:&IcN[Nn/W" o- *- F J" '* bl* ' "'C '3 I- Q JMi nkig saiy>l,'n Three field monitoring kits are locatedh the NpSF. These kit -

maint ine , 95 IWrk I?s/'y bdos u, ~.s . ow m .a . /WA eVotinent ref/ues w, _ m ..m.u .~m.~

I 4c IV L/W 6 lig 8856 h (hbl pillCli Qilu buph sCb :b [ehie5Gbwe 4de h 66 be rv i (i n [ -

j

-mCint;in d 4" *o Ima "C^"C'/ EO pOn 0 F Ciliti;^ 07 th: field m;ni;Uiin3 ki;5.

j - Cc ause Loe arcvific t:2 pc. Tu meu vy io il; . cs and monitoring tc;;; ;r; d1ffccent thc cquip::nt and $bppiics atogpagegiiLy or m may concein --

-eil g t g ty g.g t. Thy 1ficp=:rt:v of equipment and supplies 4eNA/ 25 eachfacilityylocationps L id a neer-ibed dn'fic ^b;fAkLII and I; int:in;d in erJ U

r-9--e with n T

u----,,-,-,,.,+, iu'fenhv

-~.w--> ~ ~ . . -

jm

,na;p+ar slod ,4cco gods /w is w

.Scriliad/ arks and with ad E eyeq A,A./ 7;tdie, l

![

g P: r r EMmrt rd %=Mn '- "x ' M i Geiyr-mdl\er(Gm)ad hull *J 'hb*r T)w Allowin l'h% > by /c4 /

t

- C=: 9:te Instruments Lt. tage

- Oc5e Cat: In:truccnt lligh Rense g M yg

,,u,,. -- , ~ ~

e m er9,yc pu d .s rcpp/Je- p smoonk,n*Agee#

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l (XirSampiertoi1l7 AAd!o #

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) cordaminch,A SnlI g,j,,n g n y (cM Pirdic  ! YY/eE'SEY'e'h l

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GM j- - r"11 Fx C;;pirat0rF(without filici as A4 dy (eM l - Particulac Cenn.5tec5 (fcc pc;tectt;n frcm aWLeOui wiculeJD-l _Scrb0nt Onni;tcr; (for pr^tecticn m from u;cLu oc Rudiciedines)-

in nT - -.

u, " ' '

CC s cr a e,n k $t ide. AlE6 M

l J-2 Revision 25 W October 1. 1996

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. . . .. . . - _. . - . - ~ .. .. . - - - . . - .

CPSES/EP

]

NONESSENTIAL PERSONNEL 25 l

- Personnel in one or more of the following categories: I J

Employees not having emergency response organization assignments, excluding-on-shift Nuclear. Operations personnel.

Visitors i 1

Contractors (excluding Security organization). .unless authorized by the 27 Emergency Coordinator.

Individuals involved in non-operational activities permitted by the FSAR 25 within the Exclusion Area.

Squaw Creek Park patrons. l Other persons who may be in a public access area or passing through the Owner Controlled Area.

27 0FFSITE 12 All areas not covered under the definition of "onsite."

- ONSITE

~

The land area forming the peninsula on which (PSES is sited. The western boundary of this area is the western most evaporation pond.

OPERATIONS SUPPORT CENTER (OSC) 25 The onsite emergency response staging area where the Emergency Repair and Damage 27 Control Group personnel assemble and are dispatched during an emergency.

27 PLANT EVACUATION ROUTES 12 Predetermined evacuation routes designated by signs located throughout the plant.

PLANT PERSONNEL 17 Personnel employed or contracted by TU Electric who are involved in the 27 operation, construction or maintenance at CPSES.

$w NScLex 4

ren P+

Q-4 Revision 27 July 24. 1998

i DrA CD cyc o r s -s 3pg aa_7 - .

l gn A nElk G,3 PERIODIC DEFINITIONS l

The following definitions are applicable to those plan events / tasks which occur on a regular basis:

" Monthly" means once during a calendar month; j

" Quarterly" means once during a calendar quarter;

" Semi-annual"or " Semi-annually" means twice during a calendar year; l "12 Months" means once per 12 months but not to exceed 13 months; I I

" Annual" or " Annually" means once during a calendar year.

I 1

6

ATTACHMENT 3 TO TXX-98207 PROPOSED NEW PLAN PAGES r

l l

I i

l

@ CPSES/EP 1.1.3 RECOVERY Actions taken to return the plant to an operational status or maintain long-term safe shutdown condition after the emergency response actions have been completed.

If a recovery effort is deemed necessary, the CPSES Recovery Organization is established in accordance with Section 11.0 " Recovery and Reentry."

1.2 EMERGENCY RESPONSE SUPPORT AND RESOURCES 1.2.1 Corocrate Sucoort TU Electric maintains sufficient management and personnel resources at the CPSES site to effectively staff (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) the CPSES Emergency Response Organization and its intended emergency mitigation functions. This arrangement preempts the need for a separate organization of offsite corporate personnel to be identified for, and incorporated in, the CPSES Emergency Response Organization; however, in the event of an emergency requiring assistance from offsite organizations. TV Electric management is fully committed to providing other resources to assist the CPSES Emergency Response Organization. Examples of other corporate capai>ilities existing within TU Electric include public information services, materials procurement services, contract manpower and construction services, legal and insurance services, and additional technical support.

1.2.2 Local Services Sucoort The local response organizations involved with emergencies at CPSES are the Hood County and Somervell County Emergency Organization. Each county has an emergency operations plan which describes the counties emergency response. The County Judge is in charge of the emergency organizations and has the legal authority for protective action decision making within their respective county. To assist the county emergency organizations, TU Electric sends a representative who is familiar with station operations and the CPSES Emergency Plan to each county Emergency Operations Center. The representative functions as an advisor and may act as liaison between the county officials and the CPSES Emergency Response Organization; however, these representatives are not company spokespersons.

Support from local organizations may be obtained through direct notification to the individual organization. Letters of Agreement from each organization to provide their respective emergency assistance to CPSES are maintained onsite. A list of Letters of Agreement is provided in Section 15.0, Appendix H, which identifies the local services support organizations.

1-10 Proposed Revision

CPSES/EP 1.2.3 Private Sector Suocort Support from private sector organizations may be obtained through direct notification to the individual organization. The following organizations provide services, if requested:

  • Westinahouse Corocration Westinghouse Corporation, the designer for the Nuclear Steam Supply System (NSSS), has an emergency response group which provides for emergency engineering assistance to facilities having a NSSS designed by Westinghouse. This assistance is available on a 24-hour / day. 7-day / week basis. Details of the response is contained l in the Westinghouse Emergency Response Plan.
  • Institute of Nuclear Power Ooerations (INPO)

INPO is an industry technical association whose Emergency Preparedness Division acts as a clearinghouse for maintaining a roster of individuals and skills available to each utility for augmenting the onsite ERO. INP0 also serves as a clearinghouse for ;

maintaining an inventory listing of material. equipment. and I services which may be used to supplement onsite resources. Details i of the response is contained in a letter of agrecment. l l

e Houston Liahtina and Power l

The South Texas Project provides a backup service for analyzing Post Accident Samples. A Letter of Agreement outlines the l analyzing capabilities of the South Texas Project Laboratory. 1 I

e American Nuclear Insurers (ANI)

TU Electric maintains a policy with ANI. ANI has agreed to assume responsibility for promptly assisting members of the public who may be adversely affected by an event at CPSES. This insurance policy alleviates the immediate financial burden that may be incurred by members of the public due to evacuation and relocation associated with an incident. ANI will have their representatives on the scene, prepared to commence the distribution of emergency funding at the earliest possible time, on a 24-hour a day basis.

1.2.4 State Aaencies The State of Texas has developed a Radiological Emergency Management Plan as a part of the State of Texas Emergency Management Plan. The fundamental legislation providing the basis for emergency response by civil authorities is the Texas Disaster Act of 1975, as amended. This act creates a Division of Emergency Management. The Division of Emergency Management is part of the Governor's office and is placed under the Director of the Texas Department of Public Safety by an Executive Order of the Governor. The duties and responsibilities of the principle and support agencies of the State of Texas are summarized below. The Commissioners of the Texas Department of Agriculture and the Texas Department of Health are responsible for implementing protective actions within the Ingestion Exposure EPZ in accordance with the Texas Emergency Management Plan. A detailed discussion of the state's response is contained in the Texas Emergency Management Plan and supporting Letters of Agreement. See Section 15.0, Appendix H for a list of Letters of Agreement.

1-11 Proposed Revision

CPSES/EP i l

.o- Division of Emeraency Manaaement l The Division of Emergency Management (DEM) is the agency l responsible for coordinating overall response to emergency j i situations in the State of Texas. The Director. DEM assumes

! overall direction and control of the state's response to an emergency condition at CPSES.

e Texas Deoartment of Public Safety The Texas Department of Public Safety (DPS) serves as the primary  !

communication contact and coordinates emergency comunications between CPSES and the State of Texas. Hood and Somervell Counties. ,

I The DPS coordinates with the local law enforcement officials and assists in maintaining traffic control, protecting life and l property, establishing road-blocks, and alerting and warning ,

persons in the affected area. The Highway Patrol Captain in District 6A Waco, Texas serves as Chairman of the Disaster District Committee. Requests for assistance from the local county E0C's are forwarded to District 6A. Requests that exceed the District's capability are forwarded to the state EOC in Austin. Response time for DPS personnel from the Disaster District Office in Waco to the station is approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, e Texas Deoartment of Health The Texas Department of Health (TDH) Bureau of Radiation Control (BRC) is the responsible agency for providing technical assistance and advice to local governments during a radiological emergency at CPSES. Once notified of a Site Area or General Emergency by DEM.

the BRC will establish a communication link from their Austin office to the station. The BRC dispatches response teams to the station in accordance with provisions of the Texas Radiological Emergency Management Plan. The BRC response is directed by the Bureau Chief. The response team is capable of providing environmental sampling and radiological monitoring including a mobile radiological laboratory. This laboratory serves to analyze low-level radiological environmental samples. CPSES provides telephone and electrical hook-ups for use by the laboratory. It is expected that BRC personnel and the laboratory should arrive at pre-determined locations within approximately four hours of notification. Space and telephone lines have been provided in the EOF for the response team. The BRC also provides assessment of offsite hazards and protective action recomendations.

1.2.5 Federal Acencies The CPSES Emergency Coordinator is authorized to request federal assistance on behalf of the station under provisions of the Federal Radiological Emergency Response Plan. The CPSES Emergency Coordinator requests federal assistance by contacting the NRC. The Federal Emergency Management Agency (FEMA) is also a federal agency responding to CPSES.

l 1-12 Proposed Revision

CPSES/EP To support the federal emergency response efforts, the following facilities are available:

1

' Airports: Granbury, Cleburne, Stephenville, Meacham in Fort Worth. Love Field in Dallas and Dallas-Fort Worth International l

Motels: Granbury. Cleburne. Stephenville Dallas, and Fort Worth' 1

CPSES: Working space within the CPSES Emergency Response l Facilities (ERFs) has been allocated for co-location of 4 NRC personnel. Phones are available for NRC personnel l within the ERFs.

e Nuclear Reaulatory Commission Specific responsibilities assigned to the NRC include:

Notification of FEMA whenever a radiological event occurs or when i i there is a high potential for such an event. l Monitoring operational data and assuring that adequate information and recommendations are being provided to offsite agencies.

As a back-up to CPSES. providing a technical assessment of onsite j radiological and plant conditions to FEMA and other federal agencies, and keeping state and local offsite agencies apprised of any operational discussions that may affect offsite protective actions.

In coordination with CPSES and state and local offsite agencies. l disseminate onsite data to FEMA and federal agencies, the news  !

media, and the general public.

Methods of notifying the NRC are discussed in Section 3.0,

" Notification Methods and Procedures." The NRC may be expected i onsite within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of receiving notification of the event.

I e Federal Emercency Manaaement Aaency FEMA is responsible for coordinating all offsite federal agency responses. Specific responsibilities assigned to FEMA include:

Coordination of federal support to state and local officials.

Dissemination of data on offsite support actions to the federal agencies.

FEMA may send personnel to the EOF to coordinate activities with CPSES. NRC, and the state.

I ll 1-13 Proposed Revision

( , . . , . .

_-___ _ ~ .. ,_ .

t TABLE 1.1 '

STAFFIG RE@lREKNTS FOR EERGENCIES PAGE 1 0F 2 ADDITIONS WITHIN HINUTES OF ALERT- ADDITi(NS AT TASK ONSHIFT "'

FUNCTIONAL AREA SAE OR GE '

40 70 shift Manager (SRO) Plant Equipment Station Operations Assessment of Operational Unit Superstsor (SRO) Operator Aspects Reactor Operators (RO) (2)

Plant Equipment Operators (4) ,

TSC Hanager EOF Hanager ,

Emergency Direction Direction and control of onsite Shift Manager (SRO) "*

i and Control ** emergency activities as Emergency Coo Ninator.

TSC Comunications EOF rn===tications Comunications Notify station. local, state. I&C Technictan _!

Coordinator Coordinator and federal personnel and .

maintain comunications.

Comunicator *** TSC ENS Comunicator Local Support EOF Security [

Security Site access control and Security Shift Supervisor Coordinator personnel accountability  !

Security Officers (Per Security t Plan) .

TSC Hanager "8 Company l Approve release of public Shift Manager "*

Public Information Spokesperson information TSC Comun1 cations EOF Logistical  ;

Logistics Obtain/ Expedite needed resources Shift Manager "8 Coordinator "* Support .

for the ERO.

Coordinator {

TSC Engineering Team

> Station System Coordination / Control Coordinator Engineering t

TSC Eng Team (4)

Technical Support Shift Technical Advisor I t

i  !

k Proposed Revision  ;

a 4

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_ _ . . _ . . _ _ _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _____________ ___________________[

- -_~. . _ . . - - - _ _ -___ -. _ _ __ -_ --. -_

TABLE 1.1 STAFFING REQUIREMENTS FOR EMERGENCIES PAGE 2 0F 2- .

FUNCTIONAL AREA TASK ~ ONSHIFTj ADDITIONS WITHIN MINUTES OF ALERT. ~ ADDITIONS AT  ;

SAE OR GE j 40 70 Radiological In-plant Survey R.P. Technician R.P. Technician (2).

Assessment Chem / Radiochemistry Chemistry Technician Chemistry Technician Onsite Surveys R.P. Technician R.P. Technician r

Offsite Surveys R.P. Technicians (2) Vehicle Drivers (2)

Dose Assessment Shift Technical Advisor ' TSC OnRAC EOF Dose Assessor I

Protective Actions R.P. Technicians (2) R.P. Technicians (2) R.P. Technicians (2) ,

Coordination / Control Shift Manager '*' TSC OnRAC (a) EOF R.P.

Coordinator i System Corrective Emergency Repair and Damage Plant Equipment Operator '*' OSC Manager ,

I Action Control (ERDC) Mechanic Mechanic Electrician Electrician I&C Technician I&C Technician

-l Fire Fire Fighting Fire Brigade (5) '*' Local Support ~ i Medical Rescue Operations and First Aid . Safety Services Technician Local Support Chemistry Technician

i TOTAL 18 5 22 6 i i .

(a) May be provided by onshift or augmentation personnel assigned other functions.

4 (b) Shift Manager serves in this capacity until relieved by a designated individual (Section 1.1.2.2). i (c) The minimum crew composition may be one (1) less that the minimum specified for any position for a period of time not to exceed i two (2) hours in order to accommodate unexpected absence, provided imediate action is taken to fill the required position. This ,

exception does not permit any crew composition to be unmanned upon shift turnover due to an oncoming crew menter being late or absent. -

[

t Proposed Revision I

3 6

_ _ . . _ . . _ _ ..__m. _____._t._m . _ _ _ _ _ _ _ _ _ _ _ _ .__.m _________.___m__.___________m_

_ _ _ _ _ _ _ _ _ _ ___e _ c--<-. _ . , _ -

TABLE 1.2 PREDETERMINED RESPONSE ACTIONS ,

PAGE 1 0F 1 )

PREDETERMINED RESPONSE ACTIONS NOUE ALERT SAE GE Notify state and local authorities within 15 minutes X X X X of declaring the event.

Notify the Nuclear Regulatory Commission (NRC) X X X X immediately after notification of the state and local authorities but not later than one (1) hour after declaring-the event.

i Staff and activate the Emergency Response Facilities: X 1 X X Technical Support Center (TSC)

Operations Support Center (OSC)

Emergency Operations Facility (EOF)

I Activate the Emergency Response Data System (ERDS) as X X X soon as possible but not later than one (1) hour after declaring the event.  !

Assess the event and respond accordingly. X X X X Dispatch Onsite Survey Teams. .X X X.

X X Dispatch Offsite Monitoring Teams.

Provide periodic plant status updates to offsite X X X X authorities.

X X Provide-periodic assessments of meteorological X conditions to offsite authorities.

X X Provide periodic media briefings.

X Provide senior onsite technical and management staff X available for consultation with NRC and state on periodic basis.

X Provide release rate and dose projection information. X X X

Recommend protective actions to offsite officials.

X Escalate to more. severe class. .if appropriate. X X Closecut the event with verbal summary to offsite X2 X, X2 X, authorities followed by written summary.

1 E0F activated at the SAE.

2 Notification Message Form used to closecut the emergency may be used to satisfy the requirements of verbal notification and written sumary to offsite  ;

agencies.

NOUE Notification of. Unusual Event SAE Site Area Emergency GE General Emergency Proposed Revision

CPSES/EP j l

3.0- 'NOTfFICATION METHODS AND PROCEDURES

.This chapter describes methods for notifying local and State authorities and the CPSES Emergency Response Organization (ERO) in the event of a declared emergency i

classification et CPSES. Details required in INITIAL and FOLLOWUP messages are  ;

also described. l Emergency Plan Procedures (EPP's) describe processes for performing these l notifications and contain the message format for transmitting information to local and State Emergency Operation Centers (E0Cs). EPPs also describe maintenance of the CPSES ERO Roster and the Emergency Facility Telephone l' Directory that lists emergency telephone numbers for offsite agencies and authorities.

Upon declaration of an emergency at CPSES, the CPJ,ES Emergency Response '

Organization and the CPSES Security Shift Supervisor are notified using either the plant page party system, the intraplant telephone system or commercial telephone. The pager system. described in Section 4.6. is an alternate means to notify selected members of the ERO.

Offsite authorities are notified via dedicated telephone, commercial telephone or

.telecopier.

More information regarding comunication systems may be found in Chapter 4.

' This plan chapter also describes how the populace within the 10-Mile Emergency Planning Zone (EPZ) is alerted to and advised of a CPSES emergency by local officials.

3.1 NOTIFICATIONS i

3.1.1 INITIAL Notifications INITIAL notifications from CPSES to local and State authorities are performed when the following conditions occur; e Initial declaration of an emergency classification (Notification of Unusual Event, Alert, Site Area Emergency. '

General Emergency) e Escalation of an emergency classification

  • e Initial Protective Action Recomendation (PAR)
  • Change in a PAR e Emergency termination i- INITIAL notifications shall begin no later than fifteen (15) minutes after one of the above conditions are met.

INITIAL notifications are made to the following offsite authorities / locations:

e Somervell County EOC e Hood County E0C l

e Texas Department of Public Safety in Waco. Texas i

l 3-1 Proposed Revision

CPSES/EP ,

INITTAL notifications, either verbal or via Notification Message Form, to Somervell County E0C. Hood County EOC. and DPS Waco provide the following information:

o CPSES Comunicator's name o Emergency Classification and brief description of emergency e Warning of whether an emergency-related radiological material release is occuring and IF so, what sectors and Emergency Response Zones (ERZs) are affected by the release, e PARS , i f any. l The first Notification Message Form sent from CPSES to offsite authorities is verified authentic as specified in operating procedures of the Texas Department of Public Safety Communications Center. Region 6 Headquarters. Waco. Texas.

3.1.2 Notification of NRC The NRC Operations Center should be immediately notified after notification is made to those offsite authorites identifed above. The NRC should always be notified within one hour of these notifications.

3.1.3 FOLLOWUP Notifications FOLLOWUP notifications are made to status ongoing emergency response efforts.

FOLLOWUP notifications are made to offsite authorities approximately every hour unless otherwise requested by these authorities.

In addition to information required for an INITIAL notification, the following information is provided in the FOLLOWUP notification:

e Meteorological conditions (wind velocity, direction, temperature, atmospheric stability data, and form of precipitation, if any) e IF needed, requests for onsite support.

e IF requested, by the Texas Bureau of Radiation Control:

(a) Type of radiological material release (whether actual orprojected): airborne, waterborne or surface spill and estimated or known release duration (b) Estimated or known quantities of radioactive material released.

(c) Point of release (d) Chemical and physical form of released materY, including estimates of relative quantities cnd concentrations of noble gases, radiciodines and particulates.

(e) Estimates or known quantities of radioactive surface contamination, onsite or offsite.

3-2 Propesed Revision

CPSES/EP (f) Actual or projected dose rates and integrated doses at ,

the site boundary, and at two, five and 10 miles, and affected sectors and Emergency Response Zones (ERZs).

(g) Prognosis for escalation or termination of emergency based on current plant information.

3,2 PUBLIC WARNING An Alert and Notification System consisting of 66 sirens within the 10-Mile Emergency Planning Zone (EPZ) is owned, maintained and tested by TV Electric in accordance with CPSES Emergency Plan Procedures. The system was designed,  !

installed and tested to meet the requirements of the Federal Emergency Management Agency (FEMA). The resident and transient population within the 10-mile EPZ is dlerted to an emergency at CPSES by the Alert and Notification System. Upon being alerted by this system, the populace has been informed to tune their televisions or radios to designated Emergency Alert System (EAS) stations to obtain current information and recommended protective actions. 1 The Emergency Alert System (EAS) provides emergency related information to the general public in the CPSES area over radio station WBAP (820 AM) and television station KXAS-TV (Channel 5). CPSES and state emergency response personnel provide ,

protet.tive action recommendations to local officials; however, information and  !

' instructions provided to the general public via the EAS originates from the i county officials.

Local officials, primarily County Judges and County Sheriffs, authorize use of and are responsible for operating the Alert and Notification System and providing messages to the EAS stations. Preformatted EAS messages are included in county and State emergency plans.

Operation of the Alert and Notification System is accomplished from either county's Emergency Operations Center.(EOC). Normally, each county E0C will operate those sirens within its jurisdiction; however, if needed, either E0C can operate the entire system. The 10-mile EPZ is divided into quadrants. Sirens located in each quadrant are programmed to a unique control code. Each quadrant can be activated independently; however, each siren can be operated individually for purposes of testing.

3.3 METHODS OF PROVIDING PUBLIC INFORMATION REGARDING PROTECTIVE ACTION MEASURES Public warning, discussed above, is part of the mechanism for providing information to the public. Preceding and continuing into the CPSES operations phase, emergency response information is provided to the public within the 10-mile EPZ. Local residents are provided printed media which provides instructions for emergency actions. Information regarding emergency actions is also provided by printed media at various locations or establishments within the 10-mile EPZ, and in local telephone directories. Additional information about public information is provided in Chapter 5 of this plan.

3-3 Proposed Revision

$ CPSES/EP 7.3.1 ONSITE RADIOLOGICAL ASSESSMENT Initially, during an emergency condition, the on-shift Radiation Protection and Chemistry Technicians perform onsite and in-plant radiological assessment, and sampling activities, respectively, as directed by the Shift Manager.

Once the TSC is activated. responsibilities for onsite and offsite radiological assessment and survey activities shall be assumed by the TSC Onsite Radiological Assessment Coordinator. As CPSES Emergency Organization personnel become available, onsite radiological survey teams shall be formed as required and dispatched from the OSC. Onsite Survey Teams initially shall be composed of at least two members. at least one of which shall be a Radiation Protection technician. The Onsite Survey Team (s) perform required onsite and in-plant i surveys in accordance with approved Emergency Plan Procedures. l Once the EOF is activated, overall responsibility for offsite radiological assessment shall be assumed by the EOF Radiation Protection Coordinator.

Communications between the Control Room. TSC. OSC. EOF and the Onsite Survey Team (s) shall be conducted in accordance with Section 4.0 of this plan. i l

Transportation for Onsite Survey Team (s) is provided in accordance with Emergency Plan Procedures. Based on arrival time (s) of CPSES Emergency Organization personnel. Onsite Survey Teams should be deployed within 15 to 30 minutes after arrival on site. Deployment time may vary due to duration of onsite briefing session, time required to obtain protective clothing and equipment and time required to prepare for entry into plant environs.

7.3.2 0FFSITE RADIOLOGICAL ASSESSMENT Once the EOF is activated, the . " Radiation Protection Coordinator assumes responsibilities for coordinating offsite radiological assessment and monitoring activities. Cach Offsite Radiological Monitoring Team should be composed of at ,

least two members, one of which shall be a Radiation Protection technician.

In the event that dose projection or onsite monitoring results indicate the potential for radioactivity release with offsite dose consequences, a Radiological Offsite Monitoring Team can be dispatched. Deployment time for the first offsite team dispatched is estimated to be within 55 to 70 minutes of an Alert or higher classification. This time includes team arrival, equipment check out and receiving a brief on expected radiological conditions The EOF Radiation Protection Coordinator and his staff dispatch Offsite Radiological Monitoring Teams to preselected points in affected downwind sectors.

Offsite environmental monitoring locations are identified in Plant Procedures.

At preselected points, the team should perform external dose measurements, obtain

. air samples, determine contamination levels and obtain vegetation and liquid samples as required. From this point the team can be moved to determine the plume boundary centerline of the plume and other factors necessary to determine impact of the release on the public and environment. This monitoring shall continue, as required, during the emergency so the need for protection measures can be quickly assessed.

7-3 Proposed Revision

1 CPSES/EP 8.1.3 MONITORING OF EVACUEES During a site evacuation, if the evacuees are potentially contaminated the Emergency Coordinator should direct evacuees to proceed for radiological monitoring at an offsite Reception Center. At this center, evacuees are logged in/out, monitored for contamination, and decontaminated if required.

8.1.4 RESPIRATORY PROTECTION During an emergency, air sampling is performed throughout the site area to ensure protective measures are implemented in a timely manner. These protective measures may include external exposure thresholds, DAC-hr tracking, ingestion of radioprotective drugs, relocation, respiratory protective equipment, or a combination of the above. Respiratory protective equipment is available onsite for issue in accordance with Radiation Protection procedures.

8.1.5 PROTECTIVE CLOTHING Protective clothing is available from storage areas and Radiation Protection supplies located throughout the site. This clothing is standard anti-contamination clothing and includes coveralls, hoods gloves, and boots.

8.1.6 RADI0 PROTECTIVE DRUGS I

A thyroid blocking agent such as Potassium Iodide (KI). supplied at various I strategic onsite and offsite locations, shall be offered to CPSES emergency response personnel in accordance with an Emergency Plan Procedure. Quantities of KI supplied at the onsite and offsite locations shall be maintained in accordance with provisions of Section 15. Appendix J. State or local government emergency plans and procedures describe KI use respective to offsite personnel.

8.2 0FFSITE PROTECTIVE ACTIONS Personnel and visitors offsite, but within the owner-controlled area, are warned of an emergency by the Security Organization or by Squaw Creek Park personnel in accordance with the Squaw Creek Plan for Response to Declared Emergencies at CPSES. Security personnel are notified of the emergency by Control Room personnel as described in Section 3.1. Squaw Creek Park personnel are notified of the emergency by the CPSES Security organization in accordance with Security procedures.

Protective action recommendations (PARS) are formulated during an emergency by CPSES personnel and are included in notifications to offsite authorities as specified in Section 3.0. These PARS are based on either existing plant conditions or projected offsite doses, and are updated as conditions warrant.

Offsite protective actions are then directed and implemented by State and local authorities based on the recommendations and information supplied by CPSES.

Specific protective actions to be recommended are based on the guidance of the EPA's " Manual of Protective Action Guides and Protective Actions for Nuclear Incidents."

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CPSES/EP 12.2.4 RADIOLOGICAL MONfTORING DRILLS Station personnel assigned to radiological monitoring teams shall participate in annual drills to prepare them to perform air sampling and beta-gamma exposure rate determinations within the 10-Mile Emergency Planning Zone during the Plume Exposure Pathway phase. These drills shall include provisions for comunications and record keeping.

Station personnel assigned to radiological monitoring teams should participate in drills to collect environmental samples such as soil, water, and vegetation.

These drills maintain station personnel capable to assist, if necessary, state agencies during the Ingestion Pathway phase.

12.2.5 HEALTH PHYSICS ORILLS Health physics drills shall be conducted semi-annually and involve response to and analysis of sinulated elevated airborne and liquid samples and direct radiation measurements in the environment.

In accordance with approved ALARA guidelines, an analysis of in-plant liquid samples with actual elevated radiation levels, including use of the Post-Accident Sampling System, shall be included in health physics drills annually.

12.3 DRILL AND EXERCISE SCENARIOS Drill and exercise scenarios are developed to provide a method to test and evaluate the CPSES Emergency Preparedness Program. These scenarios are designed to allow free play in decision-making and shall include, as appropriate:

a. Basic objective (s) of each drill and exercise, and appropriate evaluation criteria;
b. Date(s), time period (s), location (s) and participating organizations;
c. Simulated events:
d. Time schedule of real and simulated initia!4ng events;
e. Narrative summary describing c% duct of the exert ise or drill which addresses simulated casualF.es offsite fire depa-tment assistance, rescue of personnel, use of protective clothing deployment of radiological monitore.g teams, public informatior, activities; and
f. Description of arrangements for and advance ma'.erials to be provided to official observers.

The Emergency Planning Group is responsible for develcr,ing drill objectives, exercise objectives, and developing exercise scenarior, Scenarios and objectives developed for those exercises or drills requiring NRC and/or FEMA evaluation shall be approved by the Plant Manager

  • and submittej to the NRC and/or FEMA for review and approval.
  • See FSAR Section 13.1.

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CPSES/EP  ;

APPENDIX B Time / Distance / Dose (Thyroid) Curve for a LOCA Condition at CPSES THIS APPENDIX HAS BEEN DELETED l

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APPENDIX C 1

Time / Distance / Dose (Whole body, Gamma) l 1

Curve for a LOCA condition at CPSES

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CPSES/EP APPENDIX D l

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Curve for a LOCA condition at CPSES  :

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CPSES/EP 1

EMERGENCV EOUTPMENT AND SUPPLIES TV Electric maintains emergency response equipment and supplies in onsite and offsite facilities, cabinets, and footlockers. Onsite this equipment is staged in such places as the Control Room. Technical Support Center. Operations Support Center. Emergency Operations Facility and Nuclear Operations Support Facility (NOSF). Offsite this equipment is staged in such places as county Emergency Operations Centers (EOCs), hospitals, and Relocation Centers.

Self-Contained Breathing Apparatus (SCBAs) and spare SCBA bottles are maintained for the Control Room: SCBAs are also maintained at the NOSF.

Three company vehicles equipped to support radiological monitoring activites are available for use by Offsite Field Monitoring Teams. Three offsite field monitoring kits are located in the NOSF. The kits contain supplies and equipment represented in the listing below.

The specific type and amount of equipment and supplies in each onsite or offsite facility, location, or kit is identified on a facility inventory worksheet. The inventory worksheet is prescribed by and maintained in accordance with an Emergency Plan Procedure.

The following listing, by category, represents typical emergency response equipment and supplies maintained:

Personal Protection and Dosimetery Coveralls, shoe covers, gloves, hoods Thyroid Blocking drugs (PGassium Iodide [KI])

Thermoluminescent Dosimeters (TLDs). dosimeters i Radioloaical Monitorina Geiger-Mueller (GM) and Ionization Chamber instruments Air Sampler, equipped with sampler head for particulates and silver zeolite collectors Particulate and Silver Zeolite collectors Calculators ,

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CPSES/EP Contamination Control Modesty clothing, plastic bags, signs / barricades, Step-Off Pads, tape, decontamination supplies Communications Vehicle-installed radios, base stations, handheld radios l Miscellaneous Portable lights. Instrument check source, clerical supplies, maps, clipboards, tweezers, etc.

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NONESSENTfAL PERSONNEL L

L Personnel in one or more of the following categories:

Employees not having emergency response organization assignments, excluding on-shift Nuclear Operations personnel.

Visitors l

Contractors (excluding Security organization), unless authorized by the  ;

Emergency Coordinator.

Individuals involved in non-operational activities permitted by the FSAR within the Exclusion Area.

Squaw Creek. Park patrons.

l l Other persons who may be in a public access area or passing through the i Owner Controlled Area.

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! 0FFSITE All areas not covered under the definition of "onsite."

i. ONSITE l The land area forming the peninsula on which CPSES is sited. The western boundary of this area is the western-most evaporation pond.

OPERATIONS SUPPORT CENTER (OSC)

The onsite emergency response staging area where the Emergency Repair and Damage  !

- Control Group personnel assemble and are dispatched during an emergency.

PERIODIC DEFINITIONS l The following definitions are applicable to those plan events / tasks which occur on a regular basis:

" Monthly" means once during a calendar month: l

" Quarterly" means once during a calendar quarter:

" Semi-annual" or " Semi-annually" means twice during a calendar year:

"12 Months" means once per 12 months but not to exceed 13 months:

" Annual" or " Annually" means once during a calendar year.

I PLANT EVACUATION ROUTES Predetermined evacuation routes designated by signs located throughout the plant.

PLANT PERSONNEL I Personne1' employed or contracted by TU Electric who are involved in the L operation, construction or maintenance at CPSES.

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