View source for PY-CEI-NRR-0149, Forwards Clarifications of Rev 3 to Emergency Plan OM-15A Re SER Review Comments.Changes Will Be Incorporated in Rev 4 of Plan.Info Closes SER Outstanding Issue 19 Re Onsite Emergency Planning

{{Adams
| number = ML20107B602
| issue date = 10/29/1984
| title = Forwards Clarifications of Rev 3 to Emergency Plan OM-15A Re SER Review Comments.Changes Will Be Incorporated in Rev 4 of Plan.Info Closes SER Outstanding Issue 19 Re Onsite Emergency Planning
| author name = Edelman M
| author affiliation = CLEVELAND ELECTRIC ILLUMINATING CO.
| addressee name = Denton H
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 05000440, 05000441
| license number = 
| contact person = 
| document report number = PY-CEI-NRR-0149, PY-CEI-NRR-149, NUDOCS 8411020258
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 11
}}

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{{#Wiki_filter:...,._,                      .        --
f TH E CLEV Ei. A U D ELECTRIC ILLU Mili ATlH G CO M P AN Y P.O. box $000 - CLEVELAND. oHlo 44101 - TELEPHONE (216) 622-9800 - lLLUMINATING BLOG. - $$ PUBLICSQUARE Serving The Best Location in the Nation MURRAY R. EDELMAN VICE PRESIDENT                                          October 29, 1984
          " " *"                                                  PY-CEI/NRR-0149 L Mr. Harold R. Denton Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Clarifications to Revision 3 Submittal of the Emergency Plan OM-15A

==Dear Mr. Denton:==

The third revision of the Emergency Plan for Perry Nuclear Power Plant (PNPP) which was submitted on April 28, 1984 included changes which resulted from the NRC review comments as outlined in Safety Evaluation Report (SER) Supplement 4, Section 13. Additional clarification is provided on several of the items related to the SER review comments. The necessary clarifications are individually addressed in the attachments to this letter. Those clarifications which include changes to the Emergency Plan will be incorporated into Revision 4 of the Plan, which is scheduled for issuance in January 1985. The attachments follow the format of the SER to facilitate review and resolution in a future SER supplement.
It is expected that this information should close Outstanding Issue 19 dealing with onsite emergency planning for PNPP. Please contact us if there are any questions.
Very trul       ours, y             p M.
Murray R. Edelman Vice President Nuclear Group MRE:nje Attachments cc:    J. Silberg, Esq.                                                                $.
J. Stefano J. Grobe I f/h[
8411020258 841029                                                                               '
PDR ADOCK 05000440 E                         PDR

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pg. 1 of 10 t
13.3.2.1
       -Revisions will be made as follows to indicate the interface and provisions for coordination with the Commonwealth of Pennsylvania on ingestion pathway control I    -measures.
i Add new section:
2           "2.5.2.6   Pennsylvania Emergency Management Agency (PEHA), Commonwealth of Pennsylvania Disaster Operations Plan, Annex E, " Fixed Nuclear Facility incidents."
Add to Section 3.2.1'
;           " Coordination with the Pennsylvania Emergency Management Agency for ingestion 4
        - pathway control measures is-also provided by the State of Ohio."
        ' Add to Section 6.4.5
          -" Interface with the Pennsylvania Emergency Management Agency for ingestion
   ,    ' pathway exposure control measures is provided by the State of Ohio."

pg. 2 of 10 p
              - 13.3.2.2 (1).
13.3.2.9 (1)-
F The'following changes will be made in Revision 4 to address staff augmentation in the area of radiation monitoring:
Section 5.2.2.2~ Item 3-
                "3. Radiation Monitoring Teams"
         ~
Section 5.2.2.4, Page 5-9, Paragrar* 1
                " Radiation' Monitoring Teams (RMTs) are cesposed of two members. The RMT Leader
            - ;is~a' trained member of the Radiation Protection Section. The RMT Helper may be cany RMI trained individual of the permanently assigned PNPP staff. The number
(-           'of_ teams' responding is dependent on the emergency classification. For an
{              Alert, two (2) Radiation Monitoring Teams will respond to perform monitoring; for.a Site Area or General Emergency, three (3) teams will respond. Additional teams'may be organized as the situation warrants.. RMTs will obtain radio equipped, four-wheel-drive vehicles from Security. RMTs are equipped to perform direct radiation measurements, airborne radioactivity sampling and measurement, and environmental sample collection."
Section 5.2.3 Page.5-11l Paragraph 5
  '               " Radiation Monitoring Teams (RMTs), during the initial phase, will consist of
                             ~
     -            qualified RMT personnel available and. equipped in the Operations Support Center (OSC),'and under the direction of the Shift Supervisor. During the interim phase,'two (2) RdTs will. assemble and will be under the direction of the l_         #
                 ' Radiation Protection Coordinator.in the Technical Support Center (TSC). During l-
                .the. final phase, three-(3) RMTs will assemble and be under the direction of the
                                     ~
Offsite Radiation Advisor."
                = Table-5-1 page;5-22 i
                  'PNPP. Emergency Response Organization functions and Shift Staff Augmentation i-                ' Plan'(see next page).
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                        -      -                                           ,                           .          .     .               _~.        .    ', j; .. ., a . , . . .g Q
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t                                                                                 - TABLE 5-1 (Cont.) -
                                                                                                    .                                       ~ COALS FOR ADDITION MAJOR FUNCTIONAL          HAJOR TASKS                         POSITION TITLE .               ' ON SitIFT .'        - 30 MIN                           60 HIN AREA                                                     OR EXPERTISE              MIN. NO./ TITLE     .
TITLc; L                        TITLE (FROM NUREC 0654.                  (LOCATION)           (LOCATIGd)                      (LOCATION)
TABI.E B-1)
                                  'Onsite (out of plant)                                                                      2 Rad. Proc. Tech ~             1 Rad. Prot.
and Of fsite Surveys -                                                                         (OSC)                     . Tech.
j                                                                      .                                                      2 I&C Tech.                     1 I&C Tech.-
(OSC)                           (OSC/ EOF) 4
;                                  In Plant Surveys                   HP Technicians             _HP Tech       I)            1 HP Tech. (HPSR)               1 HP Tech.
(H PSR)                .
Chemistry / Radio--                Rad / Chem Tech. ."           1 them. Tech.                                             1 Chem. Tech.-
;    y                             chemistry                                                   ,
(Chem Lah) .
Plant System         Technical Support                  Shif t Tech.~ Adv.            1 Shif t Tech'.           1 Tech.'Sec.           'I  . I' ND&A CSE Engineering, Repair                                                                   Advisor                    CS(TSC)                         (TSC)               l
             & Corrective Actions                                     Core /Ihermal'                                         NL&FM                                                i
                                                                 , ' Hydraulics            .
                                                                                                              .               1 Nuclear Eng (TSC)
}                                                                     Electrical                                ,                                             1 ND&A Elect.
Eng. (TSC).
l                                                                     Hechanical                                                                              1 Tech. Sec.
1                                                                                                '.                                                           Mech' Eng (TSC)          s j                                  Renair and Cor-                    Mech. Maint.                  1 Perry P                                                 1 Hsint. Supv.
rective Actions                      .                          Operator { ggt     '
(Elec) (OSC)
RW Operator                   1 Radwaste Tech.
i                                                                   *Elec. Maint.                    1 Perry P                1 Maint. Supv.               '1 Maint. Gen.
3    g                                                                                             Operator {gpt              (Mech) (OSC)                  ' Supv. (OSC)
Instrument & .                1 I&C Tech. (2)                                           1 I&C Unit
]-   "
Con trol                                                                                Supv. (TSC) -$
(I&C) Tech.                                                                                               *+
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'I                                                                                                                                                                              O i bl u+                              T       t-~-                                                                                                             w--          T-

p L                                                                              pg. 4 of 10 p-      ,
13.3.2.3 (2)
The last paragraph of Section 7.3.9 will be revised as follows to clarify the laboratory. facilities available in the EOF:
)                   .. ,
          "Should it become necessary,~ there is space available in the decontamination room and whole body counting room of the Emergency Operations Facility to relocate the equipment provided in the back up counting room of the Technical r.
Support Center to analyze samples obtained by the Radiation Monitoring Teams."
4 N' :  y A
* Pg 5 of 10 13.3.2.6 (1)
To clarify backup communications capabilities at PNPP, Section 7.2.2 of the
       .          PNPP Emergency Plan will be revised as follows:
I            "7.2.2      EMERGENCY COMMUNICATIONS The .various communications systems described in Section 7.2.1 provide reliable
                                 ~
and redundant means for communicating between areas throughout the PNPP. To
                                     ~
enhance the reliability of communications with offsite areas, agencies and authorities, various dedicated leased telephone lines with a direct ring capability are employed. In the event that one or more of the dedicated line
                - networks are inoperative the Private Branch Exchange (PBX) and Off-Premise i            Exchange -(OPX) systems will provide back-up means of communications both within PNPP and between PNPP and all state / local governmental authorities with primary
                - responsibilities during an emergency. A block diagram of the emergency
                 -communications network is provided'in Figure 7-6."
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7 pg 6 cf 10 3                 ,
g.
3 13.3.2.10 (1)
                   - The first parcgraph of Section 6.4.1 will be revised as follows:
                     "In the event of'a Site Area or General Emergency, site personnel will be
   +
instructed'to begin personnel accountability. This notification will be performed cssentially immediately using the Public Address and Exclusion Area Paging Systems described in Section 7.2.1. To accomplish personnel accountability with 30 minutes, all personnel without an emergency response
                   - function will be directed to exit the site' areas via normal exit routes and exit procedures."
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pg 7.of 10
        , ','   . , ,-     .-~            -
h                     -13.3.2.4-(3)                                                                           ,
                        ~13.3.2.10 L
     ~
                       -The following changes will be made in Revision 4 of the PNPP Emergency Plan to clarify the use'of' protective actions based on the potential for releases of I                      r$dioactive material.
                         "Section 4.1.4, page 4-4 While the EALs identified for a Ceneral Emergency indicate that time should be available to provide confirmative assessments prior to implementation of
                       -. extensive protective actions, the Emergency Plan Implementing Instructions (EPI's) ' provide that upon declaration of a General Emergency, the Emergency Coordinator will recommend, as a precautionary measure, shelter for the general ipublic within 2 miles of_the plant:and in at least 3 downwind sectors to 5
                       . miles. .Also, protective actions based on the potential for releases of radioactive material'will be recommended as folicws (see Figure 4-1 for g                      directions on using' curves):
Indication                       Protective - Actions
: 1. Above Curve 4        -360 degree shelter.to 2 miles
                                                         -Precautionary shelter in at least 3 downwind sectors to 5 miles 2 .- Above Curve 3        -360 degree-evacuation to 2 miles g
                                                         -360 degree shelter between 2 and 3 miles
                                                         -Shelter in at least 3 downwind sectors between 3 and 5 miles l
l
: 3. ~ Above Curve 2        -360 degree evacuation to 2 miles-n,                                                       -Evacuation in at least 3 downwind sectors between   l 2 and 5 miles L ;gc-                                                   -Shelter between 2 and 3 miles in unaffected areas f
                             ''4. 'Above Curve 1         -360 degree evacuation to 3 miles
[                                                        -Evacuation in at least-3 downwind sectors between f
i 3 and 5 miles
                                                         -Shelter between 3 and 4 miles in unaffected areas The above. protective action recommendations assume that conditions listed in
                        ' Table 4-1 for a General Emergency have been met or exceeded. As noted above,
  +
assessment activities as described in the EPI's will continue to determine if additional protective actions should be recommended."
e

E-pg. 8 of 10 Section 6.4.3 on~page 6-11:
                 -Indication         Protective Actions
                  ~
1.- Above. Curve =4'   -360 degree shelter to 2 miles
                                     -Precautionary shelter in at least 3 downwind sectors to 5 miles
             -2.   -
Above Curve 3   -360 degree evacuation to 2 miles
                                     -360 degree shelter between 2 and 3 miles
                                     -Shelter in at least~3 downwind sectors between      l 3 and 5 miles
             -3.       Above Curve 2 -360 degree evacution to 2 miles
                                     -Evacuation in at least 3 downwind sectors between l
2 and'5 miles
                                     -Shelter between 2 and 3 miles in unaffected areas
: 4. .Above Curve 1      -360 degree evacuation to 3 miles-
                                     -Evacuation in at least 3 downwind sectors between   l 3 and 5 miles
                                     -Shelter between 3 and 4 miles in unaffected areas k
w
: j.                . . . ..                                                                      Pg. 9 cf 10 13.3.2.14 (1)
Section 8.5.4.1 of the Emergency Plan'will be revised as follows:
                            "1.      A major exercise appropriate to a Site Area or General Emergency will
                                    .be-conducted within one year prior to issusnee of a full power operating license and annually thereaf ter in accordance with federal regulations to include conducting exercises under varying weather conditions.
2.. The degree of participation by state and local agencies will be in accordance with rederal Regulations. Each exercise will include testing of the Prompt Alerting System.
3.. Delete
                             '4. _( Renumber as f3, otherwise no change)"
                        ' Note that this change includes changes committed to in the August 20, 1984
                        ' letter from M. R. Edelman to H. R. Denton letter PY-CEI/NRR-0135L.
A

       ,.;.1                                                                  pg 10 of 10-v 13.3.2.16 (1)
The'following will'be added to the end of Section 8.2:
          "The PNFP Operational Quality Assurance Program describes the management controls that exist to provide documentation and correction of deficient areas and incorporation of these corrections into the Emergency Preparedness Program."'
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