ST-HL-AE-1643, Forwards Response to Gw Knighton Transmitting Comments on Emergency Plan.Encl Rev 2 to Emergency Plan Includes Draft Tables Which Will Be Revised by 860501.NRC Response Expected by 860523
| ML20202G296 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/08/1986 |
| From: | Dewease J HOUSTON LIGHTING & POWER CO. |
| To: | Noonan V Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20202G301 | List: |
| References | |
| CON-#286-731 OL, ST-HL-AE-1643, NUDOCS 8604140321 | |
| Download: ML20202G296 (34) | |
Text
.
The Light Company n.,ou<m u aiiog&iwer x
i:o. in,x i7on iiousiou.;iem 77"oi <7:3> 22+9.>ii April 8, 1986 ST-HL-AE-1643 File No.: G9.8 Mr. Vincent S. Noonan, Project Director PWR Project Directorate #5 U. S. Nuclear Regulatory Commission Washington, DC 20555 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Emergency Plan
Dear Mr. Noonan:
In response to G. W. Knighton's letter dated November 15, 1985, which transmitted NRC comments on the South Texas Project Electric Generating Station (STPEGS) Emergency Plan, Houston Lighting & Power (HL&P) prepared draft revisions to the Plan. These draft revisions were discussed in a meeting with the Emergency Plan reviewer on March 7, 1986. HL&P has revised the Emergency Plan based on the feedback received in the March meeting.
Attached for NRC's review is Revision 2 of the STPEGS Emergency Plan and responses to each of the questions transmitted by the November 15, 1985 letter. These responses refer to the revised sections of the Errergency Plan where the question is addressed. Please note that the Emergency Plan format has been expanded to accommodate adequate responses to the NRC's comments.
Also, many of the attachments to the initial plan have been incorporated into the text for better readability.
To avoid delays in submitting this revision, some of the figures and tables provided are draft. These drafts provide information which describes their contents. We expect to be able to provide these figures and tables no later than May 1, 1986. We do not believe the draft tables and figures should impede your review.
Based on our March meeting, we understand that NRC will provide comments on this revision by May 23, 1986.
Ohck P L3/NRC/r h
c-flouston Lighting & Power Company ST-HL-AE-1643 File No.: G9.8 Page 2 If you should have any questions on this matter, please contact Mr. M. A. McBurnett at (512) 972-8530.
Very truly yours, J. . _wease M 6.A C V e President Nuclear Plant Operations MAM/ljm Attachments: 1) Responses to bRC Questions Dated November 15, 1985, STPEGS Emergency Plan
- 2) STPEGS Emergency Plan Revision 2
, L3/NRC/r k
f Houston Lighting & hmer Company ST-HL-AE-1643 File No.: G9.8 Page 3 cc:
, Hugh L. Thompson, Jr., Director Brian E. Berwick, Esquire Division of PWR Licensing - A Assistant Attorney General for Office of Nuclear Reactor Regulation the State of Texas U.S.. Nuclear Regulatory Commission P.O. Box 12548, Capitol Station Washington, DC 20555 Austin, TX 78711 ,
Robert D. Martin ~ Lanny A. Sinkin Regional Administrator, Region IV Christic Institute Nuclear Regulatory Commission 1324 North Capitol Street 611 Ryan Plaza Drive, Suite 1000 Washington, D.C. 20002 Arlington, TX 76011 Oreste R. Pirfo, Esquire N. Prasad Kadambi, Project Manager Hearing Attorney U.S. Nuclear Regulatory Commission Office of the Executive Legal Director 7920 Norfolk Avenue U.S. Nuclear Regulatory Commission Bethesda, W 20814 Washington, DC 20555 Claude E. Johnson Charles Bechhoefer, Esquire Senior Resident Inspector /STP Chairman, Atomic Safety &
c/o U.S. Nuclear Regulatory Licensing Board Commission U.S. Nuclear Regulatory Commission P.O. Box 910 Washington, DC 20555 Bay City, TX 77414 Dr. James C. Lamb, III M.D. Schwarz, Jr., Esquire 313 Woodhaven Road Baker & Batts Chapel Hill, NC 27514 ;
One Shell Plaza Houston, TX 77002 Judge Frederick J. Shon Atomic Safety and Licensing Board J.R. Newman, Esquire U.S. Nuclear Regulatory Commission Newman & Holtzinger, P.C. Washington, DC 20555 1615 L Street, N.W.
Washington, DC 20036 Mr. Ray Goldstein, Esquire 1001 Vaughn Building
- Director, Office of Inspection 807 Brazos i and Enforcement Austin, TX 78701 U.S. Nuclear Regulatory Commission l Washington, DC 20555 Citizens for Equitable Utilities, Inc.
c/o Ms. Peggy Buchorn
- T.V. Shockley/R.L. Range Route 1, Box 1684 l
Central Power & Light Company Brazoria, TX 77422 P.O. Box 2121 Corpus Christi, TX 78403 Docketing & Service Section Office of the Secretary H.L. Peterson/G. Pokorny U.S. Nuclear Regulatory Commission City of Austin Washington, DC 20555 P.O. Box 1088 (3 Copies)
Austin, TX 78767 Advisory Committee on Reactor Safeguards J.B. Poston/A. vonRosenberg U.S. Nuclear Regulatory Commission City Public Service Board 1717 H Street P.O. Box 1771 Washington, DC 20555 San Antonio, TX 78296 i
l Revised 12/2/85
ST-HL-AE-1643 File No.: G9.8 Page 4 cc:
C. L. Born Bureau of Radiation Cohntrol 1212 E. Anderson Lane Austin, TX 78752
ATTACHMENT I ST HL AE n*%
RAGE I OF30 RESPONSES TO NRC QUESTIONS DATED NOVEMBER 15, 1985 l South Texas Project Electric Generating Station EERGENCY PLAN A.1. The plan does not identify the state and local organizations within the State of Texas other than the Texas State Division of Emergency Management and the Matagorda County Sheriff's Office that are intended to be part of the overall response. (A.l.a and App. 5)
Response
Section 2 of the Plan has been created to provide the requested detail on State and County emergency response.
Refer to Sections:
B-1.2 State of Texas l B-1.3 Matagorda County l B-1.4 Local, State and Federal (summarizes Letters of Agreement)
B-1.5 Private Sector l
B-1.6 Summary of State and County Responses l
Notification methods are covered in Section E.
A.2. The plan does not specify each Federal, state or local organization having an operational role in the emergency response, except the Department of Energy and does not specify the concept of operations or their relation-ship to the total effort. (A.l.b and A.3) l
Response
i The response to A.1 covers the information requested. The Federal response is covered in Sections B-1.4.m, B-1.4.n, and B-1.4.0.
ATTACHMENT I ST HL AE Ib43 PAGE .1 OF 30 2
A.3.-;The plan does not provide a block diagram illustrating the interrelation-ships between the applicant and the various Federal, state and local organizations and suborganizations during emergency conditions. (0.1.c)
Response
The requested block diagram is provided as Figure B-1.
A.4. The plan does not Identify a specific individual by title who shall be in charge of each Federal, state and local organization or stho ganization having an operational role in the emergency response. (A.1.c)
Response
This information is included in response to A.1, particularly in Table B-1.
A.5. Although the plan states the communications between the plant site, the Matagorda County Sheriff's Office and the Texas Department of Public Safety are manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day and that the Bay City and Palacios Fire Departments as well as the Matagorda General Hospital are available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, it does not discuss the availability of the Houston Lighting and Power Company (HL&P) Nuclear Engineering and Construction Department or other Federal, state and local organizatiens having an operating role in the emergency response. (A.l.e)
Response
The response to this item is covered by the information provided in A.1 and H.5.
Information relative to availability of the County Sheriff and Department of Public Safety is covered under Communications in Section C-1.16.
Section B-1.6.b covers activation of the County Emergency Operation Center and local communication methods.
The Houston EOC is no longer a part of the STPEGS Emergency Plan.
ATTACHMENT I ST HL-AE 8 MS -
3 PAGE 3 OF30 A.6. Attachment 2 of the plan lists the agreement letters and references the Federal Radiological Emergency Response plan referring to the concept of operations between the applicant and Federal, state and local agencies and 4
support organizations; however the agreement letters are not provided, the agreements are not adequate described in a signature page format is not used to verify these agreements. In addition the list of agreement letters does not appear to be complete. (A.3)
Response
Attachment 2 contains all of the Letters of Agreement. These Letters are listed in Section A-1.2 and summarized in Section B-1.4. Private sector organizations are covered in Section B-1.5.
A.7. The plan does not discuss the capability for continuous (24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) operations for a protracted period of time or specify the individual responsible for assuring continuity of resources for HL&P in Houston as well as the state and local organizations having an operating role in the emergency response. (A.4)
Response
This information is covered in response to A.1, in particular Sections 8-1.3, B-1.2 and C-1.5.1.
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n-ATTACHMENT l ST HL AE 1643 4 PAGE 4 OF 30 l
B.1. The plan specifies the onsite emergency organization; however in Figure 9.2 this organization appears to be rather unwieldy in that 12 managers report directly to the Emergency Director. In addition duties are i assigned to a Radiological Services Manager and it is unclear as to l
I whether this is the Radiological Manager or some other individual not covered in the functional descriptions in the plan. There is no j functional description in the plan for the Technical Support Center Coordinator and the Emergency and Safety Services Supervisor does not appear to be involved in the emergency organization. Also there is no line of succession for the Records Manager in the plan. (B.1 and 8.2)
Response
The organization has been revised as described in Section C.
B.2. Although the plan identifies a line of succession for the Emergency Director, it does not identify or describe the specific conditions and procedures for higher level utility officials assuming this position.
(8.3)
Response
- Lines of succession are covered in Table C-3. The turnover procedure is l described in Section F-1.5.2. Turnover is provided for as described in Sections C-1.1 and C-1.3.
8.3. The functions of the Emergency Director which may not be delegated are given in the plan, however they do not clearly include the responsibility to notify offsite emergency authorities. (8.4)
Response
The non-delegateable duties are listed in Section C-1.3.
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ATTACHMENT I l ST HL-AE- I W3 p 5 PAGE 5 OF 3h l
I B.A. Although minimum staffing requirements appear to be met in Table 2-1 and i Figure 8.8 of the plan, they do not agree with each other and it is unclear as to whether Table 2-1 applies to shift staffing for one or two i
reactor units. (B.5)
Response
All organization Tables and Figures have been revised, in particular Tables C-1 and C-2 and Figures C-2, C-3, and C-4.
B.5. In subsection 2.5.2 of the plan, the statement that emergency response personnel assigned to the Emergency Operations Center or Emergency Operations Facility, (EOF) will not normally be in the EOF, "but in their responsible areas of the Station" is unclear and should be fully explained. (B.5 and B.6)
Response
The revised organization figures denote locations of key individuals, see Figures C-2, C-3 and C-4. This concept of operation has been revised.
B.6. The plan does not specify adequately the interfaces between and among the onsite functional areas of emergency activity, HL&P in Houston and the state and local emergency organizations t determine if they will be ef fective. The diagram in Figure 9.2 is incomplete in that it does not illustrate all the Federal, state and local emergency organizations involved in the response. (8.6)
Response
l l This information is covered by the revised Sections 8 and C. In l particular, Figure B-1 provides the interrelationship of Emergency Response Organizations.
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ATTACHMENT I ST.HL AE tW3 6 PAGE k, OF 3D B.7. The plan does not provide copies of the arrangements and agreements with contractor, private and local support agencies and the authorities, responsibilities and limits on actions of these organizations are not clearly delineated. (8.9)
Response
The Letters of Agreement are covered in response to A.6.
C.1. The expected response time to receive assistance from the U.S. Coast Guard is not given in the plan and although the plan indicates that assistance in weather forecasts will be obtained, the source of this assistance is not identified. (C.l.b)
Response
The requested information is provided in Section B-1.4.1 for the Coast Guard and H-1.1.6 for the National Weather Service.
C.2. The plan does not specify specific applicant, state and local resources available to support the Federal response (e.g. near-site airfields, telephones and other communications systems). (C.l.c)
Respons_e Information regarding airfields is provided in Section G-1.19 and Figure G-7. Communications is covered in Section G-1.16.
C.3. The plan does not indicate that the applicant will dispatch representatives to principal offsite government emergency operations centers. (C.2.b)
_Respons_e This information is provided in Section G-1.7.
ATTACHMENT l ST.HL AE IW5 7 PAGE 7 OF Ja C.A. The plan identifies radiological laboratories both onsite and offsite to provide radiological analysis assistance, however it does not describe their capabilities and copies of agreements with private organizations for the use of these facilities are not provided. (C.3)
Re_sponse Laboratory capabilities are identified in Sections G-1.9 and J-1.16.
C.5. The plan identifies a number of nuclear and other organizations that will provide assistance to the applicant in an emergency but the services are not adequately described and letters of agreement are not provided. (C.4)
Response
This information is provided in response to A.6.
0.1. The plan provides for an emergency classification system but the parameters and specific instrument readings are not always provided. In addition, the actions to be taken by the applicant under each emergency class do not always follow the criteria provided with respect to notification frequency, providing dedicated comunicators or ADP terminals to offsite authorities, activation of the Technical Support Center (TSC) and Operational Support Center (OSC), radiological monitoring, periodic press briefings and availability of senior technical and management personnel to offsite authorities. (0.1 and Appendix 1)
Response _
The Emergency Action Levels have been completely revised as described in Section D.
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ATTACHMENT f ST HL AE 1643 8 PAGE F OF 3D D.2. The Initiating conditions for the emergency classification' system given in the plan do not always provide an adequate emergency classification as provided in the criteria particularly for external events (e.g.
e earthquakes, hurricanes, missiles). In addition a number of initiating conditions in the criteria are not covered in this emergency classification system (e.g. offsite dose projections and explosions).
(D.2 and Appendix 1)
Response
This information is included in response to D.1.
E.1. The plan provides for an emergency notification procedure between the South Texas Project and offsite authorities; but it does not describe mutually agreeable bases for notification of the response organizations or the procedures for verification. (E.1)
Response
The emergency notification process is described in detail in Section E.
E.2. The plan does not adequately describe the procedures for alcrting, notifying and mobilizing emergency response personnel both onsite and at H.&P offices in Houston. (E.2)
Respons_e_
The emergency notification process is described in detall in Section E.
Also, the communications and prompt notification system are described in Sections G-1.16 and G-1.17, respectively. The state and local organizations are described in Sections B-1.2 and B-1.3.
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ATTACHMENT f 9 ST PAGEHL9AE l'[4a O 50 l E.3. The plan describes the contents of the initial emergency messages to be i
sent from the plant; however, an example of the format for these messages should be appended to the plan. (E.3)
- Response f
Figure E-1 contains a typical initial message.
E.4. The contents of followup emergency messages from the plant are described; however, an example of the format for these messages should be appended to the plan. (E.4)
Response
l i
Figure E-1 contains a typical followup message.
l E.5. The administrative and physical means for providing prompt instruction to the public are not adequately described in the plan including: (1) where the warning sirens are located; (2) who is responsible for testing and maintaining the siren system; (3) how are individual tone alert receivers distributed, maintained and tested; (4) the instruations provided for the l use of tone alerts and who provides them; (5) whether KMKS-FM is available l
to activate the tone alert system 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, seven days per week; l and (6) how is this station directed to activate the tone alert system and by whom.
Response
l Figure G-7 and sections E-1.3, G-1.17, and G-1.18 cover the above aspects
! of the Prompt Notification System. Section B-1.4.f covers KWS-FM.
E.6. The plan does not adequately describe the contents of written messages with instructions for specific protective actions to be taken by the public and examples of these types of messages are not appended to the plan. (E.7)
R_esponse Figure E-2 will contain a typical message with instructions to the public.
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ATTACHMENT I ST HL AE 445 10 PAGE 10 OF 36 F.1. Although the plan provides for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, redundant emergency communications system between the South Texas Project, HL&P in Houston, Matagorda County Sheriff's Office and Texas Department of Public Safety in Pierce, it does not provide adequate information on the communications with other state and local agencies and emergency operations center. (F.1) i
Response
This information is covered in response to A.I.
The Houston EOC is no longer a part of the Emergency Plan.
F.2. The plan does not provide the titles and alternates of these individuals responsible for the State and local communications links. (F.1 and 10 CFR 51, Appendix E, IV.E.9)
Response
This information is covered in response to A.1 and A.5.
F.3. The plan does not cover the testing of the entire emergency communications system on a periodic basis. (F.3 and 10 CFR 50, Appendix E, IV.E.9)
Response
Communications system testing is covered in Section G-1.20
'G.I. The plan does not provide sufficient details on the types and topics of ;
public information to be disseminated to determine if it meets the criteria. (G.1 and G.2) e
Response
The types and topics of public information have been expanded and are described in Sections K-1.1.3 and K-1.2.
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ATTACHMENT I ST HL AE lis43 yy PAGE ll OF 30 G.2. .Although the plan provides for the Media information Director or other designee,'as the primary spokesman, these individuals are not identified in Table 2-2 and his relationship to the Communications Coordinator as well as the description of the public information organization is unclear.
(G.3.a and G.4.a)
Response
This information is now included in Table C-3 and Figure C-4 and Section i K-1.5.
.f G.3. The location and facilities of the Media Information Center is not adequately described in the plan. (G.3.a)
Response
This information is now provided in Section G-1.5. Section K-1.10.1
, addresses the location of the rumor control organization, and Section K-1.11 provides details on telecommunication equipment in the Media Infctmation Center.
i G.A. The plan does not provide sufficient information on the arrangements for the timely exchange of information among the designated spokespersons from 4
HL&P and the various Federal, state and local response organizations to i evaluate these arrangements against the criteria. (G.4.b) 4
Response
i Information exchange is now covered in Sections K-1.8 and K-1.11.
G.5. Although the plan provides for a Rumor Control Coordinator, this individual is not identified in Table 2-2 and his capabilities and staffing are not described. In addition the means and methods for dealing with rumors are not adequately described. (G.4.c)
Response
This individual is now in Table C-3. The means for dealing with runars is detailed in Section K-1.10.
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ATTACHMENT I ST HL AE 1445 12 PAGE la, OF 30 G.6. The program to annually acquaint news media with emergency plans, information concerning radiation and with points of contact for the release of emergency information are not adequately described. (G.5)
Response
This program is more fully described in Section K-1.4.1.
H.l. The description of the Technical Support Center (TSC) is unclear and implies that there is one TSC for the station while the FSAR indicates l there is a TSC for each reactor unit. The information on the TSC given in FSAR Appendix 7A should be included in this description of the facilities and any discrepancies corrected between the plan and the FSAR. The plan l
indicates there are drawings for the layout and location of the TSC in Attachment 19, however no such drawings are provided in the plan. FSAR j' Figures 7.A.5.8-4 and 7.A.5.8-2 should be provided in Attachment 19 of the l
plan. In addition the description of the emergency data acquisition I systems, availability of data, information, drawings and radiation l
l monitoring instrumentation should be provided. (H.1)
Response
l The TSC is now described in the requested detail in Section G-1.3.
H.2. The description of the Operational Support Center (OSC) is inadequate and i
the layout and exact location are not provided in the plan; although the j plan states these are shown in Attachment 19. FSAR Figure 7.A.5.8-1 and a layout drawing of the OSC should be provided in the plan. (H.1)
Response
The OSC is now described in the requested detail in Section G-1.2.
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ATTACHMENT I ST HL AE 8 643 13 PAGE 13 OF 30
- H.3. 'The plan description of Emergency Operations Center, which is the
. equivalent'of the Emergency Operations Facility (EOF), is incomplete and should include the information given in FSAR Appendix 7A. The figures provided in Attachment 19 of the. plan are inadequate and should be replaced by FSAR Figures 7.A.S.8-5, 7.A.5.8-6 and 7.A.5.8-7. Also the backup or alternate EOF address is not provided, no layout of this facility is provided and the time necessary to activate this facility is not given. (H.2)
Response
The EOC is now described more fully in Section G-1.4.
H.4. The Houston Emergency Operations Center, the Radiation Protection Office and the Site Access Facility appear to'be part of the emergency response facilities but their functions are not clearly described in the plan. The functions and staffing of these facilities and their locations should be provided. (H.1 and H.2)
Response
The Houston EOC is no longer a part of the Plan. The Site Access Facility is covered in Sections F-1.3 and G-1.6. The Radiation Protection Office is no longer referenced in the. Plan.
H.S. The plan does not clearly describe the activation and staffing of the TSC, OSC, EOF and other facilities; however FSAR Appendix 7A states that the TSC and EOF can be staffed in approximately one hour. The plan should provide a clear description of the activation and staffing including staffing times and where the key numbers of emergency organization will be located during each emergency classification. (H.4)
Response
The staffing of the OSC, TSC and EOC are discussed in detail in Sections C and F-1.5. The organization charts in Section C depict the locations of key personnel. Staffing times are reflected in Table C-2.
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ATTACHMENT I ST HL AE 1643 g PAGE I4 OF 3 o H.6. The plan provides a description of the seismic and meteorological monitoring systems, but the range and sensitivity of this instrumentation and how the data from these systems is transmitted to the emergency response facilities is not provided. (H.5.a)
Response
These systems are now more fully described in Sections G-1.14.4, G-1.13.2 H-1.1.6, and H-1.1.2.
H.7. The plan does not provide an adequate description of the plant radiological monitoring systems or how the data from these systems are transmitted to the emergency response facilities. The plan should include a sue.ary of the information on these systems provided in FSAR Sections 7.5.1, 9.3.2, 9.3.6, 11.5.2 and other appropriate FSAR sections as well as a description of how these data are transmitted, displayed and what data is available in the TSC and EOF. (H.si.b)
Response
These systems are now more fully described in Section G-1.15 and Table G-4. The Radiological monitoring system is more fully described in Sections J-1.14, G-1.14 and H-1.1.
H.8. The plan does not provide an adequate description of the plant process monitoring and ESF instrumentation and does not describe how the data from this instrumentation is transmitted and displayed and what data is available in the TSC and EOF. (H.5.6)
Response
This information is now provided in Sections H-1.1.3 and G-1.15.
H.9. The plan does not describe how meteorological data will be acquired from offsite or from other sources (H.6.a and H.8)
Respons_e The use of offsite sources for meteorological information is now more fully described in Section H-1.1.6.
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ATTACHMENT I ST HL AE- 164%
15 PAGE15 OF$0 H.10. The description of the offsite radiological monitoring capability and equipment is not provided. (H.6.b)
Response
Offsite radiological monitoring capability is now described in Section J-1.15.
H.11. The description of the offsite laboratory facilities and equipment to
- support onsite and offsite monitoring is not adequate in the plan. (H.6.c)
Response
More detailed description of laboratories are provided in Sections G-1.9 and J-1.16.
H.12. The plan does not provide for offsite radiological monitoring or equipment. (H.7)
Response
Offsite radiological monitoring equipment is now covered in Section J-1.15.
H.13. The plan does not adequately describe the provisions for inspection, inventory and checking operability of emergency instrumentation and equipment or the frequency of these inspections and checks. (H.10)
Response
j These provisions are now described in Table G-1. The table is a draft at this time. It does indicate the content of the final table.
H.14. Appendix 18 of the plan provides for lists of portable instrunentation and other equipment for emergencies, however the ranges and sensitivities of
- the instrumentation is not provided and most the lists do not appear to be complete. The most common omission observed was dosimetry. (H.ll)
Response
. This information is now provided in Table G-1. The table is a draft at
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this time. It does indicate the content of the final table, w .. -. -- _ _
ATTACHMENT l
. ST HL AE 1643 16 PAGE 16 OF Jb H.15. The ' plan does not describe how field monitoring data and samples will be collected and analyzed or how the data from Federal, state and local organizations will be coordinated. (H.12)
Response
- The field monitoring process is described in Sections H-1.2 and H-1.4.
I.1. The plan does not completely identify the plant systems or provide the effluent parameter values for a spectrum of off-normal conditions and accidents to the example initiating conditions (e.g. dose projections).
.The plan does not always specify the kinds of instruments being used and their capabilities. (I.1)
Response
This information is covered in response to D.l.
I.2. The plan does not provide adequate information on the capabilities, types of instrtsnentation and equipment and resources for accident assessment including post-accident sampling, effluent monitors, in-plant iodine and particulate measuring instrumentation and radiation monitoring in containment to determine if the criteria are met. (I.2)
Response
This information is now provided in Sections J-1.14 and H-1.1.5.
I.3. The plan does not adequately describe the methods and techniques to be used to determine the source term of releases of radioactive material from the plant or radiation instrument readings expected. (I.3.a)
Response
This information is now provided in Section H-1.4.
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ATTACHMENT /
ST HL AE /*#3 17 PAGE Ff OF 3 d I.A. The plan does not adequately describe the methods and techniques to determine the magnitude of the radioactive releases based on plant systems conditions and effluent monitors or measurements. (e.g. failed fuel monitors, PASS) (I.3.b)
Response
This information is now provided in Section H-1.4.
I.S. The plan does not establish the relationship between effluent monitoring readings and onsite and offsite exposures and contamination for various meteorological conditions. (I.4)
Response
Section H-1.4 and Table H-4 have been added to address this concern.
I.6. The plan provides for the capability of acquiring and evaluating meteorological information; however, the description is not adequate for evaluation against the criteria. The NRC, state and local will have access to this data, but it is unclear how this information is provided to the TSC and EOF. (I.5)
Response
The description has been enhanced and is now provided in Sections G-1.14.4 and H-l.l.6.
I.7. The plan does not establish a methodology for determining the release rate / projected doses if the instrumentation used for assessment reads offscale or is inoperable. (I.6)
Response
This methodology is covered by the Offsite Dose Calculation Manual.
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ATTACHMENT /
OT-HL AE /643 18 PAGE /r OF 38 I.8. The plan does not describe the capabilities, techniques, instrumentation and other resources for field monitoring within the emergency planning zones and this capability does not appear to be an intrinsic part of the applicant's emergency operation. (I.7)
Response
This capability is now described in Sections H-1.2, H-1.4, and J-1.15.
I.9 The plan does not adequately describe methods, equipment and expertise to make rapid assessments of the actual or potential magnitude and locations of radiological hazards through the liquid or gaseous release pathways.
The means for activation and notification of field teams as well as their i
composition, transportation, canmunication, monitoring equipment and i estimated deployment times are not provided in the plan. (I.8)
Response
Field monitoring teams are now discussed in more detail in Sections H-1.2, H-1.4,' and J-1.15.
I.10. The plan states that the applicant has portable instrumentation and equipment to measure 1 x 10-7 microcuries per cc of radiciodine under field conditions, but the techniques and instrumentation are not described and the effects of the presence of noble gases and high background radiation are not provided. (I.9)
Response
The techniques and instrumentation are now covered in Sections J-1.15 and H-1.4.
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ATTACHMENT /
ST HL AE /#3 19 PAGE/4 OF So I.11. The means for relating various measured parameters to dose rates for the key radionuclides given in Table 3 of the criteria and gross radioactivity measurements are not described in the plan. The provisions for estimating integrated dose from projected and actual dose rates and comparing these estimates with the protective action guides is not adequately described.
(I.10)
Response
This issue is now covered by Section H-1.4.
J.l. The plan provides for transportation of onsite personnel using either HL&P or privately owned vehicles and states that the evacuation routes are provided in Attachment 17. However, no evacuation routes are provided in Attachment 17 and there is no information on the relocation or assembly areas for' evacuated onsite personnel provided in the plan. (J.2)
Response
Evacuation is now discussed in Sections I-1.2, I-1.3, E-1.5.4, and E-1.5.3. Figures I-3, G-4, and G-2 cover the evacuation routes and assembly areas.
J.2. The pl4n does not adequately describe the methods, procedures, e
instrusentation and equipment to be used for radiological monitoring of i
personiel evacuated from the site. (J.3)
Responge Radiological monitoring of evacuated personnel is now described more fully in Section J-1.10.
L
ATTACHMENT /
ST HL AE /6 20 PAGE .2OOF J.3. The plan provides for the evacuation of onsite non-essential personnel.
during a Site Area or General Emergency; however, the arrangements for the possible radiological monitoring and decontamination of these personnel are not adequately described. (J.4)
Response
These arrangements are provided for in Sections J-1.10 and I-1.2.1.
J.A. The procedures and techniques to account for all individuals onsite to ascertain the names of missing individuals within 30 minutes is not adequately described. (J.5)
Response
These procedures and techniques are described in detail in Section I-1.3.
J.5. The plan does not provide an adequate description of how personnel remaining or arriving onsite will be issued protective clothing and respiratory protection or whether KI or other protective drugs will be provided. (J.6)
Response
This is now in the plan as described in the response to H.4 and in Section J-1.13.6.
J.6. The mechanism for recommending protective actions and the dose limits for the principal radionuclides in the ingestion pathway are not adequately described. In addition, some of the proposed protective action recommendations need clarification. (J.7)
Response
This mechanism is now covered in detail in Sections I-1.4 and I-1.5 and in Table I-1. ,
ATTACHMENT /
ST HL AE- /6 VJ PAGE.21 OF 30 J.7. The maps provided in the plan are inadequate and illegible. Maps should be provided illustrating preselected radiological monitoring points, both onsite sod offsite evacuation rcutes, relocation centers, assembly areas for onsite personnel, hospital locations, siren locations, school locations, evacuation zones, EOF and backup EOF locations, state and local EOC locations, local airports, population centers, and other important topographical features within the emergency planning zones. (J.10.a, J.10.b, and J.10.c)
Response
Map (s) depicting this information'are now included as Figure G-7.
K.I. The plan does not establish exposure guidelines for performing first aid, personnel decontamination and medical treatment as well as for personnel performing ambulance service. (K.l.d, K.l.e, K.l.f and K.l.g)
Response
Section J-1.1 now references specific exposure guidelines to these activities. Also refer to Sections J-1.9 and J-1.7.
K.2. The plan does not adequately describe the plant emergency radiation protection program on implementation of exposure guidelines, how decisions to exceed normal exposure limits will be made, exactly which individuals by emergency position title have authority to permit exceeding the exposure guidelines, and the methods for recording and controlling radiation exposure of emergency personnel. (K.2)
Response
Section J-1.1 provides details on approval and processes for exceeding exposure guidelines.
t
ATTACHMENT l ST HL AE 1643
" PAGE 4AOF 3D 22 K.3. The plan does not adequately describe the guidelines for issuing personnel dosimetry of different types and what ranges of dosimetry are available.
(k.3.a)
Response
The guidelines for issuing dosimetry are covered in Sections J-1.1 and J-1.2. Ranges of available dosimeters are covered in Table G-1.
1 K.A. The methods and guide 11nos for reading, recording and maintaining dose records during emergencies is not adequately described in the plan.
1 (K.3.b)
Response
This is now described in more detail in Section J.
K.5. The limits and guidelines for determining the need for decontamination of emergency personnel and injured personnel are not provided in the plan.
(K.5.b)
Response
This is now described in detail in Section J, particularly J-1.1.
i K.6. The description of the instrumentation and methods for the radiological monitoring of wounds as well as radioactive waste disposal and contamination control for contaminated, injured personnel during ambulance transport and at the Matagorda County Hospital is inadequate. (K.5.b)
Response
This is now described in more detail in Section J, particularly J-1.9, J-1.12.5 and J-1.8.
L
ATTACHMENT I ST HL AE 1643 23 PAGE.23 OF Jo K.7. The plan does not adequately define the contamination and control procedures and guidelines for drinking water and food supplies. (K.6.b)
Response
This issue is now covered in detail in Section J-1.5.
K.8. The plan does not provide for decontamination and monitoring of onsite personnel at relocation sites or provision for extra clothing. (K.7)
Response
Section J-1.10 now provides for decontamination and monitoring following evacuation.
L.l. The plan provides for medical services for handling injured as well as injured and contaminated plant perscnnel at the Matagorda General Hospital, but it does not indicate that this hospital can evaluate radiation exposure and uptake. The plan also states that the University of Texas System Cancer Center is available for consultation and treatment, but does not indicate whether this is the backup hospital for the plan.
In addition, the exact location of both hospitals is not provided nor is there documentation of the agreements with these institutions. (L.1)
Response
The issue of radiation exposure and uptake is covered in Section J-1.2.5.
The backup hospital is Wagner General Hospital as described in Section B-1.4. The University of Texas System Cancer Center's function is described in Section B-1.5.
L.2. Although the plan provides for an onsite medical assistance team on each shift and a plant First Aid Room, it does not describe the teams capabilities or the equipment in the First Aid Room and its exact location. (L.2)
Response
Additional detail is provided in Sections C-1.4.4.c and G-1.ll.
m
ATTACHMENT ST.HL AE f(o43l 24 PAGE M OF 30 L.3. The plan provides for transport of injured and contaminated personnel from the plant to medical facilitics, but documentation of this capability by agreement is not provided. (L.4)
Response
Section J-19.2 describes the plans for transport by site ambulance.
M.l. The plan does not describe adequately the general plans.and procedures for reentry and recovery of the plant after an accident in that the conditions do not include that plant systems are in a long-term stable condition; personnel radiation exposure control and dosimetry are not described adequately; relief and turnover procedures are nct described; the notification and communications with offsite authorities are not well defined and the use ' offsite assistance and resources are not described.
(M.1)
Response
Section L has been expanded to provide more detail on recovery.
M.2. The plan does not describe the recovery organization management structure and does not provide the key positions by title or their authorities and responsibilities during recovery operations.
Response
Section L has been expanded to provide more detail on recovery.
M.3. The specific means and procedures for ~ informing both onsite and offsite authorities that recovery operations are being initiated is not described in the plan. (M.3)
Response
This information is now provided in Sections L-1.5 and L-1.7.
L - _ _ _ . , _
,w ATTACHMENT /
ST HL AE 16G 25 PAGE J.5 OF Ji)
M.A. Tne plan provides for the evaluation of population radiation dose using prepositioned thermoluminsent dosimeters located throughout the 10 mile EPZ; however, the locations, number of dosimeters, the dosimeter type, range and sensitivity, the dosimeter exchange procedures and how these dosimeters will be used to estimate population dose is not provided.- In addition, the use of field measurements and dose projections to supplement the dosimetry data and the distance from the site that the population dose will be estimated is not covered in the plan. (M.4)
Response
The locations of the dosimeters will be on Figure F-2. Ranges and types of dosimeters are described in Table G-1. The program for use of the TLD's is described in Sections F-1.5.3 and F-1.5.4.
N.l. The plan does not indicate that exercises will be conducted in accordance with NRC and FEMA criteria or that exercises will be designed to test a major portion of the basic elements existing within the emergency plans and organization of the applicant as well as state and local authorities.
(N.1.a)
Response
These commitments are made in Section M-1.9.1, N.2. It is unclear whether the variations in the exercise scenarios over a five year period will test the major elements of the emergency organizations of the applicant as well as state and local authorities and there are no provisions for unannounced exercises. (N.l.b)
Response
Sections M-1.9 and M-1.9.4 now commit to this item.
ATTACHMENT f ST HL AE l(a4 26 PAGE4 OF 30 N.3. The plan does not state that all drills will be supervised and evaluated by a qualified drill instructor. (N.2)
Response
Table M-2 makes this statement.
N.4. The plan does not indicate that one of the purposes of communications drills is to test the comprehension and understanding of emergency messages of various types. Also the plan does not describe adequately the procedures used for conducting emergency drills. (N.2.a)
Response
Table M-2 now contains this commitment.
N.5. The plan does not describe adequately the procedures for conducting medical emergency drills and does not indicate that radiation monitoring,
- contamination control and decontamination of the injured person as well as other personnel and facilities involved will be tested during this drill.
(N.2.c)
Response
Table M-2 now contains this commitment.
N.6. The radiological monitoring drill procedures are not described adequately in the plan and monitoring of the ingestion pathway is not included.
These drills should be conducted semi-annually rather than annually as stipulated in the plan. The statement that "On-station monitoring situations will also be a portion of this drill periodically" needs to be clarified. [N.2.e.(1)]
Response _
This drill is clarified in Table M-2.
L.
4 . . . . .
1 ATTACHMENT /
ST HL AE 1643 27 PAGE 2 OF 30 N.7. The plan does not describe adequately the post-accident sampling drills and does not include the radiation protection, contamination controls and the methods by which actual radiation levels will be provided for such drills. [N.2.d.(2)]
Response
Table M-2 now describes more details on the post-accident sampling drills.
N.8. The descriptions of exercises and drills given in the plan do not indicate how they will be carried out to allow free play for decision making, the appropriate evaluation criteria, the simulation of events and the arrangements to provide advanced materials to official observers. (N.3)
Response
4 Free play is provided for in ~Section M-1.10.2.
N.9. The management control system to ensure that corrective actions are taken to rectify deficiencies observed during exercises and drills is not i
described adequately in the plan. (N.5)
Response
{
Deficiencies are brought to management attention for disposition as i described in Sections M-1.9.3 and M-1.13.
] 0.1. The plan does not describe adequately the training program for offsite support personnel who may be called upon to assist plant personnel under emergency conditions and it is unclear whether these personnel will receive training in basic radiation protection. (0.1.a)
Response
This has been included in Section M-1.8.
F
[ l ATTACHMENT l i ST-HL AE 16V3 '
PAGE_.8 OF.30 28 0.2. The training procedures and techniques described in the plan are not provided in adequate detail. The statement, " Demonstration of practical factors and drill participation (with on-the-spot correction where appropriate)," is unclear and should be rewritten to clarify its meaning.
(0.2)
Response
This item has been clarified. See Section M-1.7.
0.3. The plan does not describe adequately the specialized and initial training for instructing and qualifying emergency personnel. The scope, nature and frequency of most of this training is not provided in the plan. A
. training matrix identifying specific training cwrses and emergency positions or groups or teams to be provided this instruction as well as a description of the instructional topics to be covered in each course should be appended to the plan. (0.4 and 0.5)
Response
Section M more clearly indicates who gets what training. Table M-1 provides a training matrix.
P.1 The plan does not provide specifically for training of the individuals responsible for the emergency planning effort. (P.1)
Response
This is covered in Section M-1.ll.7.
P.2 The plan states that agreement letters with support organizations "...
will be reviewed and updated as needed, at least once every two years."
rather than on an annual basis as recommended in the er teria. (P.4)
Response
This item is covered in Section M-1.12.
ATTACHMENT l ST HL AE 1643
-29 F..GE Q OF20 P.3. The plan does not describe adequately the methods for distributing the controlled copies of the plan or the identity of the holders of these controlled copies. The plan provides for a signed receipt for revised pages to the plan from the holders of controlled copies, but does not indicate who gets these receipts and reviews them to ensure that all controlled copies of the plan have received updates. (P.5)
Response
Section M-1.12 now has the required detail on receipt verification.
P.4. . The plan lists the state and county emergency plans, but does not provide a detailed listing of all the supporting plans and their sources. (P.6)
Response
These are the only supporting plans.
P.S. The plan contains an appendix listing by title, the emergency plan implementing procedures including the sections of the plan to be implemented. This appendix also should list all the standard plant procedures to be used or implemented during emergencies. In addition, the listing should be organized by subject area or some other method of organization rather than the random listing provided. (P.7)
Response
This list will be provided as Attachment 1.
P.6. The cross-referencing of the plan to the criteria is deficient in that the references are not always complete or are sometimes in error (e.g., 0.1, J.2) and are often too general in that a whole chapter, appendix or a major section of the plan is referenced. (P.8)
Response
A revised detailed NUREG 0654 cross reference is provided as Attachment 1.
ATTACHMENTI ST HL-AE ib43 PAGEso OF 3 0 30 P.7. The plan does not clearly define how the corporate management will be involved or aware of detected deficiencies and corrections to the emergency plan and procedures. The plan should describe the members and functions of the " Plant Operations Review Committee." Also the plan should describe the " Station Operations Quality Assurance Department" and how it interfaces with the corporate Quality Assurance Manager. (P.9)
Response
As now discussed in Section M-1.12 and M-1.13, HL&P management is informed of program deficiencies by the Quality Assurance audit process.
l P.8. The plan statement that a quarterly update of telephone listings for the
-" Duty Emergency Response Organization" will be performed and that "other 4 listings of notification telephone numbers" will be updated in accordance with procedures is imprecise and should be clarified. (P.10)
Response
This statement has been clarified in Section M-1.12.
. _ _ _ _ _ _ _ _ _ _ _ _ - _ .