ML093290312

ISFSI (Lbdcrs 09-MP1-001, 09-MP2-020, and 09-MP3-008) - Application for Proposed Change to Emergency Plan

ML093290312
Person / Time
Site:	Millstone
Issue date:	11/24/2009
From:	Hartz L Dominion, Dominion Nuclear Connecticut
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
09-614, LBDCRS 09-MP1-001, LBDCRS 09-MP2-020, LBDCRS 09-MP3-008, FOIA/PA-2011-0115
Download: ML093290312 (31)

Text

Dominion Nuclear Connecticut, Inc.

>()OO Dominion Boulevard, Glen Allen, Virgini.i ) ,(160

\.*h \ddrcss: www.dom.com November 24,2009 Attention: Document Control Desk Serial No.: 09-614 U. S. Nuclear Regulatory Commission NLOSIWEB RO Washington, D. C. 20555-0001 Docket Nos.: 50-245 50-336 50-423 72-47 License Nos.: DPR-21 DPR-65 NPF-49 DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNITS 1, 2, 3 AND ISFSI (LBDCRS 09-MP1-001, 09-MP2-020, AND 09-MP3-008) APPLICATION FOR PROPOSED CHANGE TO THE MILLSTONE POWER STATION EMERGENCY PLAN In accordance with the provision of 10 CFR 50.90, Dominion Nuclear Connecticut, Inc. (DNC) is submitting a license amendment request to change the Millstone Power Station Emergency Plan for Millstone Units 1, 2, and 3 and the Independent Spent Fuel Storage Installation (ISFSI) at the Millstone Power Station.

The proposed change replaces the emergency plan position of Emergency Medical Technician (EMT) with a licensee first aid team. This change is consistent with the planning standards and evaluation criterion of NUREG-0654/FEMA-REP-1, Revision 1, Section 11.0.3. The plan, as changed, would continue to meet the standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR 50. Pursuant to 10 CFR 50.54(q), DNC requests NRC approval of this proposed change to the Millstone Power Station Emergency Plan prior to implementation. The proposed change will change the reference to an EMT to a reference to a licensee first aid team in the Table of Contents, Sections 5,5.1.10,5.1.11, Table 5.1, Sections 6.5,6.5.4,7.11, 8.1.3.b, 8.1.3.c, and Appendix A.

Justification for the proposed change is provided in Attachment 1 to this letter and tine proposed changes are defined in Attachment 2.

The proposed amendment does not involve a Significant Hazards Consideration pursuant to the provisions of 10 CFR 50.92. DNC's Facility Safety Review Committee has reviewed and concurred with the determination.

Serial No. 09-1614 Proposed Change to Millstone Power Station Emergency Plan Page 2 of 3 DNC requests approval of the proposed change by May 28, 2010, or earlier consistent with approval of the proposed change to the Millstone Power Station Emergency Plan requested on May 28,2009. (ADAMS Accession No. ML091520618)

Upon NRC approval, DNC will implement the amendment within 60 days.

In accordance with 10 CFR 50.91(b), a copy of this amendment request is beinq provided to the State of Connecticut, Department of Environmental Protection.

Should you have any questions in regard to this submittal, please contact Mr. William Brown at 860-444-5264.

Sincerely,

(~~ccr-Leslie N. Hartz Vice President - Nuclear Support Services Commitments made in this letter: None Attachments:

1. Discussion and Justification for Proposed Change to the Millstone Power Station Emergency Plan

2. Proposed Change to the Millstone Power Station Emergency Plan

3. Marked Up Pages for the Proposed Change to the Millstone Power Station Emergency Plan

Serial No.09-614 Proposed Change to Millstone Power Station Emergency Plan Page 3 of 3 cc: U.S. Nuclear Regulatory Commission Region I Regional Administrator 475 Allendale Road King of Prussia, PA 19406-1415 Ms. C. J. Sanders Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 08B3 11555 Rockville Pike Rockville, MD 20852-2738 Mr. J. B. Hickman Project Manager Two White Flint North Mail Stop T-8 F5 11545 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power Station Director Bureau of Air Management Monitoring and Radiation Division Department of Environmental Protection 79 Elm Street Hartford, CT 06106-5127

Serial No.09-614 ATTACHMENT 1 DISCUSSION AND JUSTIFICATION FOR PROPOSED CHANGE TO THE MILLSTONE POWER STATION EMERGENCY PLAN MILLSTONE POWER STATION UNITS 1, 2, 3 AND ISFSI DOMINION NUCLEAR CONNECTICUT, INC.

Serial No.09-614 Attachment 1 Page 1 of 6

1.0 INTRODUCTION

In accordance with the provision of 10 CFR 50.90, Dominion Nuclear Connecticut, Inc.

(DNC) is submitting a license amendment request to change the Millstone Power Station Emergency Plan for Millstone Units 1,2, and 3 and the Independent Spent Fuel Storage Installation (ISFSI) at the Millstone Power Station.

The proposed change replaces the emergency plan position of Emergency Medical Technician (EMT) with a licensee first aid team. This change is consistent with the planning standards and evaluation criterion of NUREG-0654/FEMA-REP-1, Revision 1, Section 11.0.3. The plan, as changed, would continue to meet the standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR 50. DNC has reviewed the proposed change in accordance with 10 CFR 50.54(q), and, although the proposed change meets regulatory standards and requirements, has determined this change will decrease the effectiveness of the existing approved emergency plan.

2.0 BACKGROUND

Millstone Power Station Emergency Plan Table 5-1, Station Emergency Response Organization, combines the major functional areas of firefighting and the first-aid portion of Rescue Operations and First-Aid. The plan currently specifies emergency medical training for the Fire Brigade at the EMT level. Requiring training at EMT level represents an overcommitment with respect to regulatory standards and requirements.

The Fire Brigade was reorganized in 2007 from being a separate entity to being an Operations Department function. Training for the reorganized Fire Brigade does not require maintenance of EMT qualifications; however, the requirements of the Emergency Plan continue to be met using personnel with EMT qualifications.

3.0 PROPOSED CHANGE

S The proposed change replaces the emergency plan position of EMT with a licensee first aid team, which is consistent with the planning standards and evaluation criterion of NUREG-0654/FEMA-REP-1, Revision 1, Section 11.0.3. The plan, as changed, would continue to meet the standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR 50. See Attachment 2 - Proposed Change To Millstone Power Station Emergency Plan.

Discussion of Change The proposed change will replace reference to an EMT with reference to a licensee first aid team in the Table of Contents, Sections 5, 5.1.10, 5.1.11, Table 5.1, Sections 6.5" 6.5.4,7.11, 8.1.3.b, 8.1.3.c, and Appendix A.

Serial No.09-614 Attachment 1 Page 2 of 6 ONC has reviewed this change in accordance with 10 CFR 50.54(q), and has determined that although the proposed change meets regulatory standards and requirements, the change will decrease the effectiveness of the existing plan and requires prior approval before implementation. The determination in decrease of effectiveness is based solely on the relative qualification requirements between an EMT trained individual and one trained to be part of a first aid team, which is the regulatory standard. There is no reduction in functional capability with respect to the regulatory standard.

The Plant Equipment Operators (PEOs) on all unit operating shifts have completed the Medic First Aid training program - "BasicPlus - CPR, AEO and First Aid for Adults." New PEOs will be trained as part of Non-Licensed Operator Initial Training. This is equivalent to Red Cross Multi-Media First Aid training. Retraining is performed every 2 years as part of Non-Licensed Operator Continuing Training. Therefore, approximately 3 to 4 first aid trained, respirator qualified, PEOs per unit are available each shift to provide first aid capability on a 24-hour basis. Electrical Maintenance personnel, although not necessarily respirator qualified, are also provided this training, since they serve in a supplemental support capacity.

4.0 TECHNICAL ANALYSIS

These changes affect the Millstone Power Station Emergency Plan and do not alter requirements of the Operating License or the Technical Specifications. These changes do not alter any of the assumptions used in the safety analyses, nor do they cause any safety system parameters to exceed their acceptance limit. Therefore, the proposed changes have no adverse effect on plant safety. Additionally, these changes can be made without adverse impact to plant operations or to the health and safety of the public.

Based on the technical analysis performed by ONC, the proposed changes are acceptable. Reference to EMT represents an overcommitment with respect to regulatory standards and requirements. The proposed changes are consistent with the planning standards and evaluation criteria of NUREG 0654/FEMA-REP-1 Revision 1, Section 11.0.3, which specify "training for individuals assigned to licensee first aid teams shall include courses equivalent to Red Cross Multi-Media." The plan, as changed, would continue to meet the standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR 50.

5.0 REGULATORY ANALYSIS

Regulatory Guide 1.101 "Emergency Planning and Preparedness for Nuclear Power Reactors", Revision 5, July 2005, provides the methods the NRC staff considers

Serial No. 09-1614 Attachment 1 Page 3 of 6 acceptable for complying with the requirements in Appendix E to 10 CFR 50 and the planning standards in 10 CFR 50.47(b) that must be met in onsite and offsite emergency response plans. These criteria provide a basis for NRC licensees and State and local governments to develop acceptable radiological emergency plans and improve emergency preparedness. Regulatory Guide 1.101 endorses the use of NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants."

Regulatory Issue Summary (RIS) 2005-02, Clarifying the Process for Making Emergency Plan Changes, provides a framework for determining whether a change to an emergency preparedness requirement constitutes a decrease in effectiveness. A change that would degrade the capability to perform a function or relax the time requirements of affected emergency preparedness requirements is considered a decrease in effectiveness, even if the regulatory requirements are met by the change.

10 CFR 50.47(b) states "The onsite and, except as provided in paragraph (d) of this section, offsite emergency response plans for nuclear power reactors must meet the following standards:" Item 15 of these standards states: "Radiological emergency response training is provided to those who may be called on to assist in an emergency."

NUREG-0654/FEMA-REP-1,Section II, "Planning Standards and Evaluation Criteria,"

items 11.0.3 and 11.0.4 address the 10 CFR 50.47(b)(15) planning standard. 11.0.3 specifies the type of training to be provided to licensee first aid team members who may be called on to assist in an emergency as: "11.0.3: Training for individuals assigned to licensee first aid teams shall include courses equivalent to Red Cross Multi-Media." Item 11.0.4 specifies categories of training to be provided in a training program for instructing and qualifying personnel who will implement radiological emergency response plans.

Item 11.0.4.fspecifies: "First aid and rescue personnel" as one of these categories.

Additionally, the following three 10 CFR 50.47(b) standards and their associated NUREG-0654/FEMA-REP-1 evaluation criteria were evaluated with respect to this proposed change:

• Emergency planning standard 10 CFR 50.47(b)(2) states, in part: "On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, ... " Items 11.8.1 and 11.8.5 specify on-shift emergency organization responsibilities and duties.

• Emergency planning standard 10 CFR 50.47(b)(12) states: "Arrangements are made for medical services for contaminated injured individuals." Item 11.L.2 specifies provisions for on-site first aid capability.

• Emergency planning standard 10 CFR 50.47(b)(14) states, in part: "Periodic drills are (will be) conducted to develop and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected."

Item II.N.2.c specifies conduct of annual medical emergency drills and items

Serial No. 09-1614 Attachment 1 Page 4 of 6 II.N.3, II.N.4 and II.N.5 specify scenario composition, critique and corrective action.

The proposed changes to the Millstone Power Station Emergency Plan follow the guidance provided in Regulatory Guide 1.101, Revision 5, for complying with the requirements in Appendix E to 10 CFR 50 and the planning standards in 10 CFR 50.47(b), RIS 2005-02, and NUREG-0654/FEMA-REP-1,Section II. Therefore, ONC concludes that the Millstone Power Station Emergency Plan for Millstone Units 1, 2, and 3 and the Independent Spent Fuel Storage Installation at the Millstone Power Station as modified by the proposed changes will continue to meet the criteria specified in 10 CFR 50.47(b).

10 CFR 50.54(q) requires, "Proposed changes that decrease the effectiveness of the approved emergency plans may not be implemented without application to and approval by the Commission. The licensee shall submit, as specified in 10 CFR 50.4, a report of each proposed change for approval."

No Significant Hazards Consideration ONC has evaluated whether or not a significant hazards consideration (SHC) is warranted with the proposed changes by addressing the three criterion set forth in 1(I CFR 50.92(c) as discussed below.

Criterion 1:

Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

These changes affect the Millstone Power Station Emergency Plan and do not alter any of the requirements of the Operating License or the Technical Specifications. The proposed changes do not modify any plant equipment and do not impact any failure modes that could lead to an accident. Additionally, the proposed changes have no effect on the consequence of any analyzed accident since the changes do not affect any equipment related to accident mitigation. Based on this discussion, the proposed amendment does not increase the probability or consequences of an accident previously evaluated.

Criterion 2:

Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Serial No. 09-1314 Attachment 1 Page 5 of 6 Response: No.

These changes affect the Millstone Power Station Emergency Plan and do not alter any of the requirements of the Operating License or the Technical Specifications. They do not modify any plant equipment and there is no impact on the capability of the existing equipment to perform their intended functions. No system setpoints are being modlfied and no changes are being made to the method in which plant operations are conducted.

No new failure modes are introduced by the proposed changes. The proposed amendment does not introduce accident initiator or malfunctions that would cause a new or different kind of accident. Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Criterion 3:

Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

These changes affect the Millstone Power Station Emergency Plan and do not alter any of the requirements of the Operating License or the Technical Specifications. The proposed changes do not affect any of the assumptions used in the accident analysis, nor do they affect any operability requirements for equipment important to plant safety.

Therefore, the proposed changes will not result in a significant reduction in the margin of safety as defined in the bases for technical specifications covered in this license amendment request.

In summary, ONC concludes that the proposed amendment does not represent a significant hazards consideration under the standards set forth in 10 CFR 50.92(c).

6.0 Environmental Consideration ONC has determined that the proposed amendment would not change requirements with respect to use of a facility component located within the restricted area, as defined by 10 CFR 20, nor would it change inspection or surveillance requirements. ONC has evaluated the proposed change and has determined that the change does not involve:

I. A Significant Hazards Consideration.

II. A significant change in the types or significant increase in the amounts of any effluent that may be released off site, or III. A significant increase in individual or cumulative occupational radiation exposure.

Serial No. 09-1314 Attachment 1 Page 6 of 6 Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (10)(ii). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 REFERENCES

1. RIS-2005 Clarifying the Process for Making Emergency Plan Changes.

2. NUREG-0654 / FEMA-REP-1, Revision 1, Section 11.0.3.

3. Reg Guide 1.101 - "Emergency Planning and Preparedness for Nuclear Power Reactors".

Serial No.09-614 ATTACHMENT 2 PROPOSED CHANGE TO THE MILLSTONE POWER STATION EMERGENCY PLAN MILLSTONE POWER STATION UNITS 1, 2, 3 AND ISFSI DOMINION NUCLEAR CONNECTICUT, INC.

Serial No.09-614 Proposed Change To The Millstone Power Station Emergency Plan Attachment 2 Page 1 of 4 The following table provides a list of the proposed changes to the Millstone Power Station Emergency Plan. The table shows the affected section, current statement and the proposed change. This attachment also contains the marked-up pages of the Millstone Station Emergency Plan.

Current Proposed TOC, page i: 5.1.10 Fire Brigade/EMT 5.1.10 Fire Brigade 5.1.11 First Aid Team (Added to Plan)

Section 5, The on-shiftlon-site positions are The on-shift/on-site positions are Emergency part of the normal station part of the normal station Response organization, which includes: organization, which includes:

Organization, Page 5-2:

• Fire Brigade I EMT

• Fire Brigade

• First Aid Team (Added to Plan)

I Section 5.1.10, Fire Brigade I EMT Fire Brigade Page 5-5: The Fire Brigade provides The Fire Brigade provides immediate response to a fire on- immediate response to a fire on- I site. EMT qualified personnel site.

assigned to the Fire Brigade provide emergency medical services for on-site personnel injuries.

Section 5.1.11, First Aid Team Page 5-5: The First Aid Team provides emergency medical services for injuries to on-site personnel.

(Added to Plan)

Serial No.09-614 Proposed Change To The Millstone Power Station Emergency Plan Attachment 2 Page 2 of 4 Table 5-1,

• Major Functional Area:

• Major Functional Area:

Station Firefighting Firefighting Emergency

• Major Tasks: Firefighting /

• Major Tasks: Firefighting Response Emergency Medical Services

• Normal PositionlTitle: Fire Organization,

• Normal PositionlTitle: Fire Brigade Page 5-17 Brigade / EMT

• Emergency PositionlTitle: Fire

• Emergency PositionlTitle: Fire Brigade Brigade / EMT

• Emergency Location: As

• Emergency Location: As Required Required

• On-Shift: Per TRM (a)

• On-Shift: Per TS (a)

• Minimum Staffing: 30-60

• Minimum Staffing: 30-60 Minutes: -blank-Minutes: -blank-

• Minimum Staffing: 60 minutes:

• Minimum Staffing: 60 minutes: Local Comm Support Local Comm Support

• Full Staffing: -blank-

• Full Staffing: -blank-

• Training Summary: 1 [Overview]

• Training Summary: 1 [Overview]

• Rad Worker: YES

• Rad Worker: YES

• Resp Qual: YES

• Resp Qual: YES Major Functional Area: First Aid

• Major Tasks: Emergency Medical Services

• Normal PositionlTitle: First Aid Team

• Emergency PositionlTitle: First Aid Team

• Emergency Location: As Required

• On-Shift: 2 (a)

• Minimum Staffing: 30-60 Minutes: -blank-

• Minimum Staffing: 60 minutes:

Local Comm Support

• Full Staffing: -blank-

• Training Summary: 1 [Overview]

• Rad Worker: YES

• Resp Qual: YES (Added to Plan)

Serial No.09-614 Proposed Change To The Millstone Power Station Emergency Plan Attachment 2 Page 3 of 4 Section 6.5, Aid Provisions are made to assist Provisions are made to assist to Affected personnel who are injured and/or personnel who are injured and/or Personnel, have received high radiation have received high radiation Page 6-15 exposures. EMT qualified exposures. First aid qualified personnel, assigned to the Fire personnel provide on-site Brigade, provide on-site emergency medical services. First emergency medical services. First aid and decontamination facilities aid and decontamination facilities are available on-site and off-site.

are available on-site and off-site. The following subsections describe The following subsections describe measures to be used to provide measures to be used to provide necessary assistance.

necessary assistance.

Section 6.5.4. EMT qualified personnel are First aid qualified personnel are First Aid, Page available to assist ill or injured available to assist ill or injured 6-17: personnel on-site 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per personnel on-site 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. If necessary a physician may day. If necessary a physician may be requested to provide medical be requested to provide medical assistance on-site. assistance on-site.

Section 7.11. 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day first aid services 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day first aid services First Aid and are provided by EMT qualified are provided by first aid qualified Medical personnel. First aid supplies and personnel with, as a minimum, Facilities, Page equipment are stored in various multi-media first aid training. First 7-10: locations throughout the station. aid supplies and equipment are The site Medical Facility is also stored in various locations available during selected hours, throughout the station. The site which may provide equipment and Medical Facility is also available personnel to assist in medical during selected hours, which may emergencies. provide equipment and personnel to assist in medical emergencies.

Section 8.1.3.b, The Fire Brigade is composed of The Fire Brigade is composed of Additional designated station firefighting designated station firefighting Emergency personnel. Initial and annual personnel. Initial and annual Preparedness refresher training is provided to refresher training is provided to Training I Fire Fire Brigade Members and Fire Fire Brigade Members and Fire Brigade Brigade Leaders in accordance Brigade Leaders in accordance Training, Page with training department with training department 8-2: procedures. Station EMTs receive procedures. I

~

certification and training through the State of Connecticut, Office of Emergency Medical Services.

Serial No. 09-614-Proposed Change To The Millstone Power Station Emergency Plan Attachment 2 Page 4 of 4 Section 8.1.3.c, Station first aid teams are provided Additional a Medic first aid training program:

Emergency "BasicPlus - CPR, AED and First Preparedness Aid for Adults" or equivalent, at a Training I First minimum. (Added to Plan)

Aid Team Training, Page 8-2:

Appendix A, Emergency Medical Technician - Delete definition of EMT.

Definitions, Personnel assigned to the Fire Abbreviations Brigade which maintain EMT and Acronyms, certification with the State of Page A-5: Connecticut.

Serial No. 09**614 ATTACHMENT 3 MARKED UP PAGES FOR THE PROPOSED CHANGE TO THE MILLSTONE POWER STATION EMERGENCY PLAN MILLSTONE POWER STATION UNITS 1, 2, 3 AND ISFSI DOMINION NUCLEAR CONNECTICUT, INC.

TABLE OF CONTENTS Section Page List of Appendices viii List of Tables ix List of Figures x

1. Concept of Emergency Operations .......................................*............................................".. 1-1 1.I. Description of the Millstone Emergency Planning Zones 1-1 1.2. Interrelationships of State/LocallLicensee Emergency Plans 1-2 1.3. Actions 1-2 1.4. Assistance 1-3 1.5. Public Notification 1-3 1.6. Public Information Program 1-3

2. Applicability and Supporting Plans 2-1

3. Section Intentionally Blank (Reserved) 3-1

4. Classification System.....................................................*..**.*.*................................................ 4-1

5. Emergency Response Organization 5-1 5.1. On-Shift Positions 5-3 5.1.1 Shift Manager 5-3 5.1.2 Shift Technical Advisor 5-4 5.1.3 Manager Of Control Room Operations 5-4 5.1.4 Emergency Communicator 5-4 5.1.5 On-Shift Operators 5-4 5.1.6 Health Physics Technicians 5-4 5.1.7 Chemistry Technicians 5-4 5.1.8 Security Shift Supervisor and Security Personnel.. 5-4 5.1.9 Station Duty Officer 5-5 5.1.10 Fire Brigade I EMT 5-5 6* \. \\ y:;p.sr ~\cl'""L~P-M" . - _. - - - ~ ~ - - ~ - - .. - - ~. --- S-s Millstone Station Emergency Plan Revision 36 October 2008

• Unit Supervisor (Unit 2 and Unit 3)

• Control Operators (Unit 2 and Unit 3)

• Plant Equipment Operators (Unit 2 and Unit 3)

• Health Physics Technicians (same as Radiation Protection Technicians)

• Chemistry Technician

• Security Shift Supervisor and Security Personnel

• Station Duty Officer

• Fife Brigade / EMT.-J Q \-I{l. 5'1 AI d \~(.\(YV"\

The minimum staffing management positions include the following:

• Director of Station Emergency Operations

• Assistant Director, Emergency Operations Facility

• Assistant Director, Technical Support (Unit 2,3)

• Manager of Technical Support Center

• Manager of Radiological Consequence Assessment

• Manager of Radiological Dose Assessment

• Manager of Communications (Unit 2,3)

• Manager of Operational Support Center (2 Positions)

• Chief Technical Spokesperson

• Nuclear News Manager

• Manager of Resources

• Public Information Technical Advisor 5-2 Millstone Station Emergency Plan Revision 36 October 2008

5.1.9. Station Duty Officer (SDO)

The Station Duty Officer or available SRO notifies the NRC, assists with communications, precautionary dismissal, and evacuation or assembly of station personnel.

5.1.10. Fire Brigade.f..EM:F j /

__c * -c-;,,--,. The Fire Brigade provides immediate response to a fire on-site. ~.~

./ ) J:Halifi@Q p@rsoiln@l assigB8Q to tJa8 Fire ErigaQ@ prOViQ8 8IB8rg8BQ:Y

/-",g~Z \\

.J-" 1,../ IB8Qical S8fVic:s for OB sit: p:rsoBlu:l iRjllrie~.

,(\ J ----~)o ..

5.2. Minimum Staffing Positions 5.2.1. Director of Station Emergency Operations (DSEO)

After relieving the CRDSEO, the EOF DSEO assumes overall command and control of the SERO and the licensee emergency response. The DSEO is responsible for classification, notification, release of information to off-site authorities and the public, recommending protective actions to the State of Connecticut, and approval of personnel appointed to fill SERO vacancies during an emergency. The DSEO will ensure that additional SERO staff positions, as determined necessary to effectively respond to the specific emergency, will be staffed within 90 minutes of facility activation. The following DSEO responsibilities cannot be delegated:

• Command and control of station emergency response, including coordination of response by off-site agencies

• Event classification

• Approval of off-site Protective Action Recommendations

• Authorization of emergency exposures greater than 25 rem TEDE for lifesaving activities

• Authorization of off-site notifications

• Requests for federal assistance to support station response

• Final approval of news releases 5.2.2. Assistant Director, Technical Support (ADTS)

The ADTS reports to the DSEO. The ADTS is responsible for providing command and control of the SERO technical, operational, assessment and repair staff. The MCRO, MRCA, MOSC, MTSC, and MOS report to the ADTS.'

The ADTS primary responsibilities include:

• Ensuring actions are taken to mitigate degradation of plant systems

• Recommending changes in classification to the DSEO 5-5 Millstone Station Emergency Plan Revision 36 October 2008

INSERTW 5.1.11 First Aid Team The First Aid Team provides emergency medical services for injuries to on-site personnel.

lable 5-1 Station Emergency Response Orgaulzation

---

~-- r ~~-~-- ------~- --~ ~,_-------~-- ~--- ~T

-1 TMi~i;;;~;"Staffi~-g~T ~ -Full

tafflng I Training Summary I vVurkel Rad I Resp Qual I

{Refer to Aop Kl ~----~--

~ 1---

Major Functional Area Major Tasks Normal PositionfTitle" Emergency PositionfTitle Emergency Location On- 30-60 60 Shift Minutes Minutes Plant System Engineer Assist Manager of Technical Safety Analysis, Nuclear Accident Management TSC/OSC 1 1,2,4,8 YES Repair and Corrective Support. Provide accident Fuel Engineering T earn- Leader Action analysis Safety Analysis, Nuclear AMT-Thermal-Hydraulic TSC/OSC 1 1,2,4 YES Fuel Enoineerino Enqineer IT-HI Repair and Corrective Evaluation, repair, and Manager-Maintenance Manager of Operational TSC/OSC, OSC AA 1 1 1,4,9 YES Actions corrective actions Supervisor Support Center Mechanic Mechanic OSCAA 1 1 1 YES YES Electrician Electrician OSCAA 1 1 1 YES YES I&C Technician I&C Technician OSCAA 1 1 1 YES YES Operational Support Coordinate on-site activities and Supervisor-Maintenance OSC Assistant TSC/OSC, OSC AA 2 1,4,9 YES personnel Supervisor-Maintenance OSC Assistant TSC/OSC, OSC AA 2 1,4,9 YES Resource Acquisition & Coordinates requests for Various Manager of Resources EOF 1 1,4,9 Personnel Dispatching assistance, organizes station personnel for relief shift work, account SERO personnel.

Coordinate acquisition of personnel and equipment from coroorate or outside sources.

Information Resources Maintain computer availabililv IT Personnel None Millstone Station m Firefighting Firefighting IIOAlBf!lBA8V---'

Mellieal SBf\'iGBS Fire Brigade f-EM'f y Fire Brigade+EM'F ~ As Required Per (a)

'ffl; Local Comm 1 YES YES TRrm Support 71 Search and Rescue Search and rescue operations Security Personnel I Security Personnel I Station As Required Per 1 YES YES Operations Station Personnel, as Personnel Sec.

required Plan External Response Provide logistics support for licensing, Engineering Regulatory Liaison EOF 1 1,4 Logistics external response personnel.

liaison with NRC Site t BackupSERO Notifications Communications Resoonse team.

Communications with ADTS/DSEO. Packup SERO Notification Svstem HP Communications Security Personnel HP Staff Security Person RAD Communicator CASISAS EOF, TSCIOSC 1

2 1

1,4 YES YES YES

\ Exposure Control Exoosure Monitorino HPStaff CBElS Operator OSCAA 1 1,4 YES

'0 \ e.";, Aic\--no I'>(W\ Il\=i !lST ~i-",'i\7 L,oLQL 1-\ \1..";, A-\ c\ '2.rm.E'..'~'r--\c\ \'VIe.(,'-"\ ~(\l,US Pis {2.E~

-, .c , 4' p,{'IY\ L*U (--c ))

I :;l L,,) CV(V'Y'ofT'V'\

7>.... oo N!:-r- 1 "(t::) '-iE:..S 5-17 Millstone Station Emergency Plan Revision 36 October 2008

f. Off-site surface contamination and other radiological control criteria are detailed in the state and local RERP.

6.4.4. Personnel Radiation Dose Determination Health Physics (HP) coverage is provided 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day to support normal Station operations. During accident conditions, HP technicians may accompany emergency workers, as needed, during RCA entries.

Emergency dosimetry (i.e. self-reading Pocket Ion Chamber dosimeters (PICs) or alarming dosimeters) and permanent recording dosimeters (TLDs) are used by the initial SERa responders, as necessary. Additional dosimetry is distributed by HP personnel and is issued to individuals, including off-site individuals arriving at the EOP.

TLDs are available from and analyzed by the Dosimetry Laboratory. The individual integrated dose records are maintained by the HP Department.

Exposure information is recorded from self-reading dosimeters and provides personnel exposure tracking until TLD results become available. The TLD results will be used as a permanent exposure record.

Permanent dosimetry will usually be read when it is determined that the emergency workers have received an exposure near their administrative limit or if an overexposure is suspected. All other dosimetry is read on a schedule established by the MRCA.

6.5. Aid to Affected Personnel

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radiation exposures. EMT qualified personnel, assigned to the E Brigade, provide 0 -

site emergency medical services. First aid and decontami Ion facilities are available on-4

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6.5.1. Exposure Control Guidelines In the event of an ALERT, SITE AREA EMERGENCY or GENERAL EMERGENCY, emergency worker exposure limits are automatically increased in accordance with EPA 400. This limit remains in effect until mission-specific limit upgrades are required and authorized by the appropriate emergency manager (refer to Table 6-1). The use of radioprotective Potassium Iodide will be evaluated for administration to on-site and off-site SERa personnel in accordance with emergency procedures. Exposures are commensurate with the significance of the objective and are held to the lowest levels that the emergency permits, In all situations, every reasonable effort is made to minimize exposure to emergency personnel.

6-15 Millstone Station Emergency Plan Revision 36 October 2008

INSERT 'e' Provisions are made to assist personnel who are injured and/or have received high radiation exposures. First aid qualified personnel provide on-site emergency medical services. First aid and decontamination facilities are available on-site and off-site. The following subsections describe measures to be used to provide necessary assistance.

6.5.4. First Aid ~ <,

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EMT qualified personnel are available to assist il . ~ured personnel on-sit:)e 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. If necessary, a physician may be requested to provide medical assistance on-site. ~/"

6.5.5. Medical Transportation Injured or radioactively contaminated injured personnel requiring hospitalization are transported using local community ambulance services. The ambulance may be requested via dedicated or commercial telephone. The ambulance crews are trained to respond to radiological incidents. Personnel qualified in radiation protection are directed to report to the receiving hospital or accompany the injured, contaminated patients to the hospital. If necessary, the receiving hospital will be provided details of patients being transported. Station procedures provide detailed instructions for personnel responding to personnel injuries or contamination.

6.5.6. Medical Treatment Arrangements for the primary care of injured, or radioactively contaminated injured personnel are made with the Lawrence and Memorial Hospital in New London and Middlesex Hospital in Middletown. Communications will be by commercial telephone lines. The hospital staff is trained annually and the facility is equipped to treat contaminated injured patients. Contaminated wounds are treated and decontaminated as necessary by the hospital staff.

6.6. Public Information The public information emergency response personnel consist of the Public Information Technical Advisor (PITA), the Nuclear News Manager (NNM), the Chief Technical Spokesperson (CTS) and supporting staff. The PITA reports to the ADEOF at the Station EOF. The PITA gathers and transmits event information to the ICSC external affairs staff. The PITA may initiate a news release as determined necessary by the DSEO when the NNM is not available to issue news releases. Additionally, when corporate support is available, public information will be coordinated with the assistance of the Corporate External Affairs Manager. This assistance may include the use of personnel assigned to the news release process and representation between the licensee, state and media officials.

At an Unusual Event the NNM will determine the actions to take regarding notification of media in coordination with the DSEO and station management.

In an ALERT or higher, the NNM reports to the Chief Technical Spokesperson and manages public information activities at the EOF and Joint Media Center. The NNM issues DSEO approved news releases from the Hartford State Armory. The Chief Technical Spokesperson represents the licensee in communications with state and media officials until a Corporate Executive Spokesperson assumes this responsibility.

6-17 Millstone Station Emergency Plan Revision 36 October 2008

INSERT'D' First aid qualified personnel are available to assist ill or injured personnel on-site 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. If necessary a physician may be requested to provide medical assistance on-site.

7.10. Assessment Facilities Appropriate on-site and off-site monitoring instruments and laboratory facilities needed to analyze an accident are available 24-hours per day and are listed in Appendix H, Tables H-1 and H-2. The MRDA and MRCA will coordinate the collection of sample media by the Radiological Monitoring Teams (RMTs). The RMTs will return samples to the EOF for analysis when directed. Appendix B provides letters of agreement with private laboratory facilities specified in Table H-2. Post-accident environmental samples are collected by responsible state agencies and analyzed by the State Health Department laboratory. The licensee will assist the State of Connecticut in the collection of environmental samples under direction and control of the Department of Environmental Protection, as requested.

7.11. First Aid and Medical Facilities . 't"c<.-

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The Site Medical Facility is also available during selected hours, which may

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7.12. Damage Control Equipment Damage control equipment consisting of fire hydrants, fire hose stations, fire extinguishers, and portable lanterns are provided throughout the station for fire fighting. Self-contained breathing apparatus is located strategically throughout the station for fire fighting and entry into airborne radioactivity or toxic gas areas.

Selected equipment spare parts are stored in the warehouse for emergency repairs.

Tools and equipment required for equipment maintenance are available in the maintenance shops.

7.13. Meteorological Data Acquisition The Millstone site has a primary meteorological installation consisting of a 450-foot instrumented tower, a climate-controlled shelter, and a computerized data acquisition system. Wind speed and direction are measured at four different levels: 33, 142,374, and 447 feet. Vertical temperature difference is measured at 142,374, and 447 foot levels: the vertical intervalin all three cases is measured from a baseline height of 33 feet. The critical parameters of wind speed, wind direction, and a measure of atmospheric stability are continuously available in the Unit 2 and Unit 3 Control Rooms and at the base of the meteorological tower.

Other non-critical meteorological parameters are also measured.

The site has a backup meteorological monitoring system located near the training facility. The system consists of a lO-meter instrumented mast, a climate-controlled shelter, and a backup computerized data acquisition system. Additional information may be obtained from a weather service organization, listed in Appendix B.

7-10 Millstone Station Emergency Plan Revision 36 October 2008

INSERT 'E' 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day first aid services are provided by first aid qualified personnel with, as a minimum, multi-media first aid training. First aid supplies and equipment are stored in various locations throughout the station. The site Medical Facility is also available during selected hours, which may provide equipment and personnel to assist in medical emergencies.

Appendix K provides a summary listing of training topics for SERO personnel.

Section 5, Table 5-1 lists the topics for personnel by SERO position. Detailed training lesson plans and administrative requirements for SERa personnel are contained in NTP 7.212 and MP-26-EPA-FAPOl.

8.1.2. Off-Site Emergency Response Training Training for local off-site emergency response personnel, such as local fire, police, mutual aid responders and emergency management officials is offered annually. Training for off-site agencies consists of radiation protection, emergency classification, notification, emergency plan overview and general plant access information. Local ambulance and hospital emergency room staff are trained annually in plant access and the medical treatment of contaminated, injured patients.

State personnel, representing agencies at the State EOC, are trained in specific procedures through participation in periodic drills. In addition, responsible state agencies are trained in emergency classification. Field monitoring and sampling team personnel are trained annually in radiation protection, monitoring and ingestion sampling procedures.

Host community emergency organizations are trained in radiation monitoring and protection, activation and operation of evacuee reception centers.

8.1.3. Additional Emergency Preparedness Training

a. Plant Access Training (PAT)

Employees obtaining unescorted access to the station for the first time receive general instruction on the Emergency Plan as part of their plant access training. This includes a review of the purpose of emergency planning, the emergency classification system, and the precautionary dismissal, and evacuation. This information is reviewed annually as part of the employee's Plant Access Training Program. Company and contractor personnel obtaining unescorted access to the station receive general instruction on the Emergency Plan as part of their plant access training.

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b. Fire Brigade Training e ~ e is comp sea of dedicated stati firefighting personnel.

Initial and annual refresher training is provo a to Firefighter Technicians and Brigade Captains in accordance training department procedures.

Station EMTs eceive certi and training through the State of Connecticut, Office of Emergency Medical Services.

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8-2 Millstone Station Emergency Plan Revision 36 October 2008

INSERT 'F' The Fire Brigade is composed of designated station firefighting personnel. Initial and annual refresher training is provided to Fire Brigade Members and Fire Brigade Leaders in accordance with training department procedures.

INSERT 'G' Station first aid teams are provided a Medic first aid training program: "BasicPlus - CPR, AED and First Aid for Adults" or equivalent, at a minimum.

Appendix A Emergency Operations Facility (EOF)

A facility located on the site access road from which station activities related to an emergency will be carried out and from which information will be provided to the corporate, federal, state officials and local community chief executive officers.

Emergency Planning Zone (EPZ)

An area surrounding the Millstone Power Station for which planning is conducted to ensure that prompt and effective actions can be taken to protect the public in the event of an accident. For the plume exposure pathway, the EPZ has a corresponding radius of about 10 miles; and for the ingestion exposure pathway, the EPZ has a corresponding radius of about 50 miles.

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V Event Based EAL A listing of symptoms and conditions under generic event categories.

Event Category A generic group of plant conditions; e.g., loss of power, equipment failure, radiation hazard, security threat, etc.

Exposure Path.way Plume Exposure Pathway The pathway by which exposure to a radioactive plume and subsequent deposition of radioactive material could result in external exposure and by which inhalation of the radioactive plume could result in internal exposure.

Ingestion Exposure Pathway The pathway by which deposited radioactive materials could be ingested from contaminated water or food, such as milk or fresh vegetables which would cause internal exposure.

Full Staffing SERO positions which are beyond the required minimum staffing. Full staffing positions, as a goal, will be staffed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of SERO activation. Personnel assigned to fill these positions are drawn from a pool of qualified individuals.

A-S Millstone Station Emergency Plan Revision 36 October 2008