ML20209D250

Informs That Util Has Revised All Sections of Rancho Seco Emergency Plan (Rsep),Change 4,effective 990624

ML20209D250
Person / Time
Site:	Rancho Seco
Issue date:	06/24/1999
From:	Delezenski J SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Masnik NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NQA-99-072, NQA-99-72, TAC-M98432, NUDOCS 9907130085
Download: ML20209D250 (7)

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(,,'l S M U D SACRAMENTO MUNICIPAL' UTluTY DISTRICT C P. O. Box 1583o, Sacramento CA 95852-1830, (916) 452-3211 AN EL'ECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA NQA 99-072 June 24, 1999 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 {

Docket No. 50-312 4 Rancho Seco Nuclear Station License No. DPR-54 10 CFR 50.54(q) 30 DAY REPORT OF EMERGENCY PLAN CHANGES Attention: Dr. Masnik In accordance with 10 CFR 50.54(q) and 10 CFR 50.4(b)(5)(ii), the District repons that it has revised all sections of Rancho Seco Emergency Plan (RSEP) Change 4, effective June 24,1999.

Based on a District evaluation, the District concluded this RSEP revision did not decrease the effectiveness of the RSEP and did not require NRC approval prior to 1[

implementation. The main purpose of the revision was to incorporate:

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l. Applicable 10 CFR 50 and 10 CFR 72 emergency planning requireme..ts into the RSEP to accommodate (1) removing spent fuel assemblies from the Spent Fuel Pool (SFP) in a cask and canister system and (2) transferring the fuel to the Rancho Seco Independent Spent Fuel Storage Installation (ISFSI) for dry storage; and

2. NRC review comments documented in R. Dudley (NRC) to S. Redeker O (SMUD) letter dated May 18,1999, Review of Revised Rancho Seco Emergency Plan (TAC No. M98432).

The following is a summary of the substantive changes made as part of the RSEP Change 4 revision:

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RANCHO SECO NUCLEAR GENERAMNG STATION O 14440 Twin Cities Road, Herald, CA 95638-9799; (209) 333-2935

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Dr. Masnik . NQA 99-072 i

, . General RSEP Change.3

1. Incorporated State of California and Sacramento County comments into the revised RSEP,'

' 2.' Included RSEP Section 9, Section 10, and Appendix B information into RSEP Sections 5,1, and 4, respectively, so RSEP Section 9, Section 10, ano Appendix B may be voided and the RSEP may be streamlined, 3, . Deleted Evacuation and changed Dismissal to include the actions previously associated witr Evacuation, 4.' Changed the Emergency Planning Zone (EPZ), which was limited to the Rancho Seco Industrial Area, to include the ISFSI location, and

5. Deleted reference to Federal Eroergency Management Agency (FEMA) since (1) the EPZ is limited to the Industrial Area and (2) the RSEP does not require or include protective actions for protection of the general public.

RSEP Section 1

1. No additional substantive changes beyond those described above.

. RSEP Section 2

1. ' Added the requirement to submit a 30-day wtitten report to the NRC following declaration of an emergency in accordance with 10 CFR 72.75, and

2. Included a section on community right to know in accordance with 10 CFR 72.32 regarding information on hazardous chemicals used at Rancho Seco.

RSEP Section 3 ..

S Clarified and expanded the definition of Emergency Action I.evel (EAL) to include spent fuel,  !

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Dr. Masnik L NQA 99-072 i

RSEP Section 3 (Continued)

- 2. - Revised the definitions'for Unusual Event and Alert to (1) clarify the 1;urpose for declaring an emergency event and (2) provide an overview of the actions taken when an event is declared,.

3. Deleted the Protective Action Recommendation for Sacramento County to evacuate the Rancho Seco Park since the park and its access road are outside the EPZ,-

4. Revised the Emergency Action level (EAL) summary tables for the two 4

' emergency classifications (Unusual Event and Alert) to incorporate 10 CFR 50 and 72 aspects of spent fuel handling during cask loading activities, ,

'. including transpon to, and storage at, the ISFSI,- 1 5.- Added a section on~ detecting accidents to provide gt..clance on when an emergency declaration should be made,

' 6. Added a summary of licensing basis accidents to show the relationship between accident analyses and EALs, and

7. Rc vised the Unusual Event and Alert response summary tables to describe the Rancho Seco and Sacramento County emergency responses when an Unusual Event or an Alert is declared.

- RSEP Section 4 --

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1. Added a summary of 12tters of Agreement and Contracts with off-site agencies to summarize local agency commitments and support for Rancho e Seco during emergency conditions, -

2. Addressed providing radiological information, dosimetry, and escorts to off-

~s ite medical personnel accessing Rancho Seco to ensure medical personnel protection upon entering the site,

3. Updated law enforcement section to indicate that Sacramento County Sheriff or FBI assistance may be requested for suppon in more areas than just access control in accordance with the Rancho Seco security program, and i

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). I Dr. Masnik -~ NQA 99-072 I

I RSEP Section 4 (Continued) l

=4. Deleted the Western Regional Radiological Emergency Mutual Assistance Agreement (WRREMAA) and the Sacramento County Radio

. Communications Contract from, and added the State Department of Health Services to, the list of letters of Agreement and Contracts.

. WRREMAA existed to restore a nuclear plant to a safe shutdown condition  ;

following an accident. This condition is not applicable to defueled plants. j The Sacramento County Radio Communications service provided between the District off-site emergency facilities and State and County radiological monitoring organizations is not applicable during the defueled condition.

I RSEP'Section 5 - l

1. Reduced the number of Chem / Rad Decommissioning Technicians (C/RDT),

required to respond to the site within two hours for an emergency event, from l three to one because (1) on-shift operators are qualified as RP Responders, (2) 1 a C/RDT is required on-shift during fuel handling operations, and (3) a Radiological Assessment Coordinatoris assigned to the TSC and is required to provide emergency response support Within two hours. This available support and response capabi!ity provides sufficient RP coverage du'ing ,

potential emergency events,  !

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2. . Clarified the division between the Control Room and Technical Support

? Center (TSC) organizations consistent with the Emergency Plan _q

Implementing Procedures (EPIPs),

3. Changed description of Fire Brigade to address fighting only incipient stage

- fires due to reduced fire hazard in radiological areas and a significant )

- reduction in flammable liquids and hazardous materials at Rancho'Seco,

4. Added the methods for notifying TSC personnel to activate the TSC as addressed in the EPIPs,-

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5. Modified the list of duti:s that the Emergency Coordinator (EC) is not allowed to delegate, clarified ' Authorize Emergency Exposure Limits for l

Emergen'c y Workers,' and deleted ' Approval of Public Information Releases.'

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Dr. Masnik ; NQA 99-072 RSEP Section 6 -

x1. Updated the Unusual Event and. Alert response measures consistent with the

changes made as addressed above for RSEP Secthn 3,

2. Deleted the Rancho Seco Park closure / evacuation recommendation since protective action guidelines are not exceeded beyond the EPZ (i.e., the Rancho Seco Industrial Area, including the ISFSI),

3. ' Expanded the Industrial Area' Boundary radiation dose projection information to include unmonitored gaseous releases that could potentially occur when the Fuel Storage Building roll-up doors are open during fuel off-load activities.

The default value for an unmonitored release while handling one fuel assembly is 10 mrem. Each additional damaged fuel assembly is assumed to contribute an additional'10 mrem to the two-hour integmted accident dose.

The maximum release is for a fully loaded dropped cask event (24 fuel assemblies or 240 mrem),

4, Updated Protective Action descriptions to address notifying plant' personnel h~ ' of hazards and the actions they must take to protect themselves, y 5. Revised the Radiation Exposure Control section to invoke the current dosimetry program and establish the standard for exposure control duriug emergency response, L 6. ' Changed the emergency exposure limits in ac.;ordance with EPA 400-R 001 to correct the previously listed limits, c 7. . Added a dAscription of respiratory equipment issue and use requirements for emergency response activities, 8.' Clarified that Security response to events during emergencies is conducted in coordination with the emergency organization to protect on-site personnel, 9.! Specified Operations Casualty procedure OP-C.53 as the guide for requesting medical suppon from off-site agencies, t --

k Dr. Masnik . NQA 99-072

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' RSEP Section 7 l

1. Described the Control Room as the initial Emergency Response Facility to better describe the Control Room function, and added the NRC Headquarters to the list of agencies that are provided emergency notification from the .

Control Room, -

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. Clarified (1) the time limit for activating the Technical Support Center (TSC),

- (2) the emergency response ~ supplies contained in the TSC, and (3) that the

. TSC is activated for an Alert classification emergency event to better describe TSC use during emergency events,

3. - Added information from the Defueled Safety Analy;is Report (DSAR) on

.. Control Room and TSC availability to address that it is not necessary to designate relocation facilities for the Control Room and TSC, and

. 4. Removed reference to flashing amber lights and intennittent sounding horns previously used in high operating plant noise areas to alert personnel that the emergency siren had been activated. Since high plant operational noise areas

. no longer exist, the flashing lights and intermittent horns are not needed.

Decommissioning noise levels are localized, intermittent, and much lower

. than previous cont'.nuously high operational plant noise areas.

RSEP Section 8-

1. Referenced A 1erican Red Cross standards as re-cenification requirements to clarify Emergency Team training requirements,  ; .

( 2.'- ' Specified the Radiation Protection / Chemistry (RP/ Chem) department as the

. group responsible for developing, planning, scheduling, and conducting emergency drills and exercises,

3. - Included a requirement to (1) invite the NRC to observe and invite local agencies. to" participate in the annual emergency exercise and (2) provide a

/ copy of annual exercise objectives and scenario to the NRC for comment at least 60 days prior to the annual exercise,-

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Dr. Masnik NQA 99-072 RSEP Section 8 (Continued)'

4. Added the requirement to renew the Letters of Agreement and contracts specified in RSEP Section 4 at least every four years or as necessary, and J

. 5. Changed the RP/ Chem internal RSEP review requirement from annual to biennial, consistent with the biennial EPIP review requirement. The Quality Assurance group continues to conduct an annual audit of the emergency preparedness program.

i The District submitted an information copy of the revised RSEP and the associated 10 CFR 50.59 determination and 10 CFR 50.54(q) evaluation under separate cover (i.e., S. Redeker (SMUD) to R. Dudley (NRC) letter MPC&D 99-087, dated May 27, 1999, " Rancho Seco Emergency Plan, Change 4").

Members of your staff requiring additional information or clarification may contact  ?

Mr. Steve Nicolls at (916) 732-4850. l Sincerely, t

[ /

erry Delezenski Supervisor Quality Assurance / Licensing / Administration cc: _ E. W. Merschoff, NRC, Arlington, Texas (2 copies)

g. R. Dudley, NRC, Rockville 4

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