ML20245H858
| ML20245H858 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/27/1989 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-89103, NUDOCS 8903060048 | |
| Download: ML20245H858 (10) | |
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File # 10013 g
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r 1UELECTRIC February 27, 1989
' W.J.Cahm.
Executive Vke President I
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.U. S. Nuclear' Regulatory Commission Attn: Document Control Desk Washington, D..C.
20555
SUBJECT:
COMANCHE' PEAK STEAM ELECTRICJSTATION (CPSES)
RESPONSE TO NRC' QUESTIONS ABOUT.THE CPSES EMERGENCY PLAN.
. Gentlemen:
r
- On January 23, 1989, TV Electr.ic personnel met with members of the NRC staff
- to discuss the CPSES Emergency Plan, Revision 9 and 10.
At-the end of.the meeting, there were seventeen (17) action items to be resolved.
Subsequently, three (3).'of the issues were resolved with your reviewer.
The TV Electric response.to the reviewers concerns are enumerated in-the attachment.
This-response also provides the basis for the next revision-to the CPSES Emergency.
Plan,.which is tentatively scheduled.for August 31, 1989. On February 23, 1989, an ' extension to February 27, 1989, was granted by Mr. J. H. Wilson of your office'.
Sincerely, l
L William J. Cahill, Jr.
GLGid( m Attatnment c - Mr. J. H. Wilson, OSP Ms. Melinda Malloy, OSP Resident Inspectors, CPSES (3 copies)
Mr. Don Perrott4, NRR O
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89030600A8 890227 PDR ADOCK 05000445 i
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____-___--_____-___-_-_____--_-_-_E
Attachment to TXX-89103 February 27, 1989 Page 1 of 9 Response to NRC Concerns about the CPSES Emergency Plan.
CONCERN #1:
Table 1.1 - Designation of E0F Director RESPONSE #1:
Indicated on Table 1.1, the Shift Supervisor is responsible for emergency direction and control until relieved as discussed in 1.2.3.1.
(This succession chain is also illustrated on Table 1.2.)
During the discussion of this concern, the aspect of the TSC assuming the responsibilities of the EOF was determined to need clarification; therefore, the following change is proposed:
Revision 10, Section 6.1:
"The TSC has been designed and is equipped to support continuous operations over an extended period."
PROPOSED Revision 11:
The TSC has been designed and is equipped to support continuous operations over an extended period
[(includingcoordinationofresponseactivitieswith offsite authorities as needed until the E0F has been activated).]
L.._____________
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U Attachment toLTXX-891'03 Fdbruary 27,'1989 lp Page.2' of; 9 CONCERN #2i Emergency Action Level (EAL) Scheme L.
RESPONSE #2 The.~ discussion of this concern ranged from clarifying the terms l
" Emergency. Action. Levels" and " Initiating' Conditions" to the adequacy of some of the EALs.. 'The adequacy issue will be evaluated further after EPP-201,. Revision 4 (EAL and Emergency Plan Activation procedure) has been reviewed by the.NRC.- (This procedure was transmitted to the staff under TXX-89085 on February 20,.1989.)- The'following proposed' changes should clarify the terminology.
Revision 10, Sectiori.2.0:
." Emergency Action Levels (EAls)--(also known-as-Initiating Conditions) established for each emergency classification have received concurrence from offsite authorities ' responsible for. implementing protective measures for the popul ation-at-ri s k. "
PROPOSED Revision 11:
Emergency Action Levels (EALs) [] established for each emergency classification have received concurrence.from offsite authorities responsible for implementing protective measures for the population-at-risk.
Revision 10, Section 2.1:
" Emergency Action Levels which determine the appropriate classification are' generally described in the following paragraphs and are specifically defined in Table 2.2.
Specific instruments, parameters and equipment status used to determine a classification are specified in appropriate Emergency Plan procedures."
PROPOSED Revision 11:
-[ Initiating Conditions] which determine the appropriate classification are described generally in the following paragraphs and are specifically defined in Table 2.2.
[ Specific instrument readings, parameters or equipment status, are used to determine whether an Emergency Action Level has been reached as specified] in the appropriate Emergency Plan procedures.
Revision 10, Appendix Q: Emergency Action Levels - Initiating conditions which
~
provide basis for deti ming the appropriate Emergency Classification."
PROPOSED Revision 11:
Emergency Action Levels - [ Plant or radiological parameters which are the basis for quantifying the initiating condition and classifying the severity of the emergency.]
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At.tachmentLto TXX-89103
.L February 27, 1989--
i:
Page'3 of 9 CONCERN #3:
I'nitiating condition related to steam generator tube (s)-failure.
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II RESPONSE.#3:
Resolution' contingent'upon the. review of EPP-201, Revision 4; see Response'#2.
1 CONCERN #4:
Communication for offsite monitoring teams.
RESPONSE #4:
Revision 10, Section 4.1.4:
"A two-way radio transmitter-receiver system, operating on a unique wavelength, is provided for emergency response communications between emergency response support personnel-(e.g.
radiological monitoring teams-and emergency repair and damage control teams) and,various emergency response facilities."
PROPOSED Revision 11:
A two-way radio transmitter-receiver system,-
operating on a unique wavelength,:is provided_for emergency. response communications between emergency response support personnel-(e.g.[, onsite and-offsite) radiological monitorino teams and emergency repairanddamagecontrolteams}andvarious emergency response facilities.
Revision 10, Section 7.3.2:
"CPSES Offsite Monitoring Teams shall be equipped with survey equipment, including dose rate meters, air samplers protective clothing and other equipment."
PROPOSED Revision 11:
CPSES Offsite Monitoring Teams shall be equipped with
[two-way radios;] ' survey equipment, including dose rate meters and air samplers; protective clothing and other equipment.
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(*
At.tachment to TXX-89103
~
February 27, 1989 Page 4 of 9 l
CONCERN #5:
Time for activation of TSC and EOF RESPONSE #5:
Revision 10, Section 6.1:
" Personnel assigned to the TSC are notified at an Alert or higher classification and should l
activate the facility in accordance with Emergency Plan Procedures."
PROPOSED Revision 11:
" Personnel assigned to the TSC are notified at an l
Alert or higher classification and should activate the facility [as soon as possible with a goal of~
sixty (60) minutes] in accordance with Emergency Plan Procedures."
Revision 10, Section 6.3:
The EOF is staffed at an Alert Classification and shall be activated if a Site Area or General Emergency is declared as prescribed in appropriate Emergency Plan Procedures."
PROPOSED Revision 11:
The EOF is staffed at an Alert Classification and [,
if a Site Area or General Emergency is declared,]
shall be activated [as soon as possible with a goal of sixty (60) minutes] in accordance with Emergency Plan Procedures.
CONCERN #6:
Provision for detecting and measuring particulate and noble gases in the OSC and TSC.
RESPONSE #6:
During a subsequent conversation with the reviewer, this concern was resolved.
No further action is required.
CONCERN #7:
Provide infonnation on RMS, particularly those detectors / devices that are associated with accident detection, EAls, etc.
RESPONSE #7:
In addition to the proposed text change, a table (scheduled to be Table 6.4 in the E-Plan.) is included see page 7 of 7 which lists those process monitors used for accident detection.
Revision 10, Section 6.13.3:
"The Radiation Monitoring System (RMS) includes the Area Radiation Monitoring System (ARMS) and the Process Radiation Monitoring System (PRMS)."
PROPOSED Revision 11:
The Radiation Monitoring System (RMS) includes the Area Radiation Monitoring System (ARMS) and the Process Radiation Monitoring System (PRMS).
[ Table 6-4 provides a list of monitors from these systems which are associated with accident detection.]
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February. 27, 1989 1Page.5 of 9 7
CONCERN #8:-
Capability for. detecting and measuring. radioiodine under field conditions (i.e., interference from noble' gases).
RESPONSE #8: During a subs.equent conversation with the reviewer, this. concern was resolved. -No further action is required.
CONCERN #9:
Configuration of the plume EPZ.
-RESPONSE #9: During a subsequent conversation with the reviewer, this. concern was resolved.
(The requested figure is available in the Emergency Plan Procedures.)
No further action is required.
CONCERN #10:
Revise plan to conform to criteria 1.4 and 1.5 regarding evacuation of non-essential persons and accountability.
RESPONSE #10: During subsequent discussions regarding this concern, the scope was. reduced to establishing the point at which the accountability effort begins.
Revision 10, Section 8.2:
'"The' Comanche Peak ~ Engineering Building and the Site Support Center Building Personnel will assemble.as directed at the time of the emergency.
Approved Emergency Plan Procedures detail actions that.shall be taken if site evacuation is required."
PROPOSED Revision 11:
The Comanche Peak Engineering Building and the
[ Support Services] building personnel will assemble as directed at the time of the emergency.
[ Site evacuation may be ordered-any time by the Emergency Coordinator; however, site evacuation shall be implemented at a Site Area or higher Emergency.]
Approved Emergency Plan Procedures detail actions,
[ including accountability]' that shall be taken if a site evacuation is required.
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'At,tachment to TXX-89103:
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i February 27, 1989 1
o i:
n iPage 6:of 9:
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1 1
s CONCERN #11: : Identification of 31 notification / evacuation zones, including separate zones for Granbury, Tolar, Glen Rose, 'and TV Electric property.
RESPONSE #11:
Revision 10, Section 8.6.1:
"The. Plume Exposure EPZ, with a 10-mile radius,-
and the Ingestion Exposure EP7, with a 50-mile l
l' radius are divided into sixteen 22.5 degree
. sectors and concentric circles of one of 10-mile increments. Maps of these EPZ's are provided in Section 15.0, Appendices F and'G."
PROPOSED Revisi'n 11:
The Plume Exposure EPZ, with.a 10-mile r'adius, and o
the Ingestion Exposure EPZ, with a 50-mile radius are divided into sixteen 22.5. degree sectors and concentric circles of one of 10-mile increments.
.[The 10-mile Plume EPZ is also subdivided into thirty-one (31) Emergency Response Zones.
These zones are bounded / described by physical landmarks / boundaries and are used when protective.
actions are recommended to identify the areas of potential risk.] Maps of these EPZ's are provided in Section 15.0, Appendices F and G.-[An illustration of
-the 31 EPZ is contained in the EPP.]
CONCERN #12:
Prerequisites for going into recovery / termination from emergency.
RESPONSE #12: The process for transitioning into the recovery phase is outlined in the Emergency Plan Procedures (See EPP-121,
" Recovery and Reentry").
CONCERN #13:
Notification of state, local, and F.ederal organizations before initiating a recovery effort.
RESPONSE #13:
Revision 10, Section 11.0:
" State and county emergency response organizations and the NRC shall be notified regarding status change."
PROPOSED Revision.11:
State and county emergency [ prior to initiating response organizations and the NRC shall be notified recovery phase.]
L.-
1 i 3At.tachment'to TXX-89103 r
' February 27, 1989.
- Page 7 of 9 O
n CONCERN #14: C1'arification of " annual / field," biennial, full participation, partial participation,'and "other" exercises'.
RESPONSE #14:
Revision 10, Section 12.1:
" Biennially, the " annual" exercise, involves full participation 'of. local response organizations.
and at least partial participation of. state organizations.
Thel state.shall fully-participate with CPSES' at least once every four years."
PROPOSED Revisi.on 11:-
Biennially, the,[] _ exercise involves full participation of local response ~ organizations and at least partial. participation of' state organizations.
The state []. fully participates [s] with CPSES' at.
least once every four years.
CONCERN ~#15: Communication test between CPSES with NRC headquarters from the control room, TSC.and EOF on a monthly. frequency.
RESPONSE #15:
Revision 10, Section'12.2.1:
" Communications drills shall also address the aspect-of understanding messages."-
PROPOSED Revision 11:
Communications drills shall also address the aspect' of. understanding messages..[A communications
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equipment' test.between the NRC Response' Center and CPSES shall be conducted monthly and shall involve the ENS telephone in the Control Room and the ENS and HPN telephones in the TSC and EOF.]
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7: At.tachment to TXX-89103-February 27, 1989 Page 8 of 9 t-L CONCERN'#16':
Basic CPSES Emergency Plan training for CPSES personnel not assigned to the CPSES' Emergency Organization.
. RESPONSE #16:
. Revision 10, Section 13.0:
"All CPSES personnel and visitors, including l
those working on site temporarily. or in training, who will be unescorted within the Protected Area, shall receive an orientation on the CPSES Emergency Plan to apprise them of their expected actions and ensure their safety.
in the event of an emergency."
PROPOSED Revision 11:
All-[TU Electric] personnel,and [ contractors (who are assigned to or routinely visit the site] shall receive an orientation on the CPSES Emergency Plan to-a) prise them.of their expected actions and ensure t1eir safety 'in the. event of an emergency. - [This orientation includes points of contact.to report emergencies;~ locations of assembly areas; expected actions'in the event of an emergency; methods of notification; etc. and may be presented in General Employee Training (GET) safety meetings, orientation sessions, etc.
This information is also posted throughout the plant.]-
CONCERN #17: Update letters of agreement as needed, and certify as current.
RESPONSE'#17: Copies of the current letters of agreement will be supplied in revision 11 of the Emergency Plan.
Revision 10, Section 1.1.5:
" Letters of Agreement are. updated as necessary and reviewed annually as a part of.this document."
PROPOSED Revision 11:
Letters 'of Agreement are updated as necessary[and.
reviewed annually as a part of this document (in accordance with the Emergency Plan Procedures)].
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