ML14272A415

SONGS EP RAI Response Review Slides - Public Meeting September 25, 2014

ML14272A415
Person / Time
Site:	San Onofre
Issue date:	09/25/2014
From:	Southern California Edison Co
To:	Division of Operating Reactor Licensing
Wengert T
References
Download: ML14272A415 (51)

Text

SONGS EP RAI

Response

Review September 25, 2014

Meeting Agenda Topic Time Speaker Introductions 12:30 NRC/SCE Summary Overview 12:35 SCE SONGS EAL RAI responses 12:45 SCE SONGS PDEP RAI Responses 12:55 SCE Discussion 1:35 SCE/NRC Path Forward 2:00 SCE Summary/Actions 2:05 SCE Opportunity for Public Questions 2:15 Public Closing Remarks/Adjourn 2:30 2

Emergency Planning During Decommissioning

• SCE submitted a proposed Permanently Defueled Emergency Plan (PDEP) to the NRC on March 31, 2014 for the San Onofre Nuclear Generating Station (SONGS) that reflects the plant's permanent shutdown.

• The requirements for emergency planning at SONGS have evolved because most potential accidents related to an operating plant are no longer possible at decommissioned nuclear plants (such as SONGS) that do not have fuel in the reactor.

3

Operating Plant and Decommissioning Plant E-Plans Operating Plant Decommissioning Plant Multi-faceted approach to address a wide variety of Focused on addressing low-consequence, limited impact emergencies that could affect the Health and Safety emergencies.

of the Public and includes:

• No formal Off-site REP

• No EPZ, ANS, ETE.

• Formal Off-site Radiological Emergency Plan

• Event Classification levels limited to NOUE and (REP) including: Alert

- Emergency Planning Zones (EPZs)

- Alert and Notification Systems (ANS)

• Prompt (30 minute) Notification

- Evacuation Time Estimates (ETE)

• Streamlined ERO to include:

- Event Classifications: NOUE, Alert, SAE, GE - Assessment/Classification

- ERO Activation

• Pre-planned off-site protective actions - Off-site Notification/Communication

- Training

• Immediate (15 Minute) Notifications - Facility/Equipment

• Extensive On and Off-site Emergency - Event Recovery Response Organizations (EROs)

• No dedicated Off-site facilities

• Dedicated on and Off-site Facilities

• Single On-site Command Center

• Joint On and Off-site biennial (1 every 2 years)

• Off-site organizations invited to participate in exercise biennial exercise 4

Summary

• The enclosed draft responses to SONGS Permanently Defueled Emergency Plan (PDEP) and Emergency Action Level (EAL) Requests for Additional Information (RAIs) are summarized to meet the agenda time durations.

• Slides are organized with technical RAIs first, followed by editorial and/or clarification RAIs.

5

Request for Additional Information (RAIs) and Responses SONGS EMERGENCY ACTION LEVELS (EALS) 6

EAL RAI #1

• Please annotate in Section 1, "Purpose,"

RAI #1 that this document will be maintained in accordance with 10 CFR 50.54(q).

• The Permanently Defueled Emergency Plan (PDEP) Emergency Action Level Draft (EAL) Technical Bases Manual will be Response revised to state that the manual will be maintained in accordance with 10 CFR 50.54(q).

7

EAL RAI #2

• Please explain why the definitions for the following terms are not included, as stated in the endorsed guidance, or revise RAI #2 accordingly:

• Explosion,

• Fire, and

• Visible Damage.

Draft

• The PDEP EAL Technical Bases Manual will be revised to include the definitions of the Response terms Explosion, Fire, and Visible Damage.

8

EAL RAI #3

• Under Initiating Condition PD-AU1, please explain how EAL #2 is declared in a timely RAI #3 fashion and whether the capability to perform this evaluation is maintained on-site 24-hours per day, seven days per week (24/7).

• SONGS maintains staff qualified to sample and analyze liquid and gaseous effluents.

Draft Response

• The Shift Radiation Protection (RP)

Technician is an on-shift position and can provide timely field survey results for EAL #2.

9

EAL RAI #4

• Under Initiating Condition PD-AU2, please clarify whether there are any remote reading alarms RAI #4 associated with the decrease in spent fuel pool water level, and if not, what means will be in place to ensure timely classification if warranted.

• Spent Fuel Pool (SFP) High/Low level annunciation will be provided in the Control Room/Command Center. The low level set-point ensures annunciation Draft is provided at a SFP level at or above the SFP low level assumed for the EAL classification. This low Response level annunciation will be the method used to ensure timely classification under Initiating Condition PD-AU2.

10

EAL RAI #5

• Under Initiating Condition PD-SU1, please clarify whether there are any remote reading alarms associated RAI #5 with the increase in spent fuel pool water temperature, and if not, what means will be in place to ensure timely classification if warranted.

• The Control Room/Command Center will have remote reading instrumentation with an associated alarm indication for a high SFP temperature. The high Draft temperature set-point will be chosen to ensure annunciation is provided at a SFP temperature at or Response below the SFP temperature assumed for the EAL classification. This high temperature annunciation will be the method used to ensure timely classification under Initiating Condition PD-SU1.

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Request for Additional Information (RAIs) and Responses SONGS PERMANENTLY DEFUELED EMERGENCY PLAN (PDEP) 12

PDEP RAI #8

• Under Table B-1, "ERO Minimum Staffing Requirements," please provide [sic] responses to the following:

• a. Has SONGS performed an on-shift analysis for ERO functions to ensure sufficient personnel will be able to respond to the limiting event, which is a catastrophic loss of spent fuel pool (SFP) water inventory using the minimum shift staffing as indicated in the Table B-1? The response should include:

• SFP mitigation strategies as described in SCEs letter dated August 26, 2013 (ADAMS Accession No. ML13240A130), and

• All functional areas of the Table B-1 to address any potential collateral duties.

• b. What personnel are assigned on-shift to monitor personnel exposure and determine if radiological conditions exist that may preclude access to the SFP to perform mitigative actions, if RAI #8 required?

• c. Footnotes (b) and (c) state, "May be contract personnel." Will these personnel be initially trained to perform required function(s), and will they maintain the training qualifications as provided in Section O?

• d. Footnote (d) states, "Survey can be performed with assistance from outside sources if deemed necessary." Who specifically would be performing these surveys in the unlikely event that there is a radiological release, and in what timeframe would these outside sources be available to perform surveys?

• e. Footnote (e) states, "Fire Fighting and rescue operations are provided by agreement with offsite resources." What on-shift capability is there to perform firefighting, first aid, and rescue activities?

Are these measures considered under the SONGS Mitigation Strategy License Condition?

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PDEP RAI #8 Response

• (a) Songs has performed a shift staffing study. Adequate staff is available.

• (b) An RP technician has been added to on shift staffing

• (c)If utilized, contract personnel will have training consistent with their roles and responsibilities and will be maintained as described in Section O.

• (d) Support from contracted services can be expected to arrive within 24 Draft to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> Response * (d) State agencies maintain independent capability to perform surveys and dose assessments. While no formal agreement exists with these state agencies regarding response times, historically their response time has been consistent with the Stations Emergency Response Organization.

• (e) The DOE Aerial Monitoring System (AMS) is available to perform rapid radiation and contamination surveys following a radiological emergency.

14

PDEP RAI #28

• Part II, Section J.2, Mitigation Strategies and Equipment, refers to documented spent fuel pool mitigation strategies for mitigation of emergencies involving the spent fuel pool. In SCEs letter to the NRC dated August 26, 2013 (ADAMS Accession No. ML13240A130), SCE indicated its intent to maintain SFP strategies.

• Please provide a description of the actions SONGS could take to mitigate the consequences of an event involving the SFP, or include appropriate reference to describing these actions. The description should include:

• Permanently installed equipment available to fill or spray the SFP; RAI #28

• On-site portable equipment available to fill or spray the SFP;

• Off-site equipment available to fill or spray the SFP; and See next slide for

• Available water sources.

response

• Written procedures to perform the mitigation strategies and how they are maintained;

• The personnel who would perform these mitigation strategies and how they are trained;

• How the equipment used in the mitigating strategies are stored, maintained and tested;

• Approximate times it would take to deliver, setup, and start delivering makeup/spray to the SFP using portable equipment; and

• How makeup/spray could be delivered to the SFP in the event that radiation levels at the SFP prohibited entry to the area.

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PDEP RAI #28 Response

• The response will address permanently installed equipment, on site portable contingency equipment, off-site contingencies and water sources.

• Mitigation strategies are implemented with site procedures.

• Site procedures specify storage, maintenance and testing of contingency equipment utilized for mitigating strategies.

Draft Response

• Procedure references will be provided in the response.

• On-shift staffing studies indicate mitigating strategies for a beyond design basis single SFP event could be implemented within approximately 85 minutes and approximately 140 minutes for a beyond design basis dual SFP event .

• External mitigation strategies exist that can be implemented without entering the SFP room itself.

16

PDEP RAI #6

• Since events classified at SONGS as an Alert are based on a radioactive release, explain why the Radiation RAI #6 Protection Coordinator is part of the "supplemental" ERO, rather than required to report to the Command Center within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of declaration of an Alert.

• An RP technician has been added to on shift staffing

• The Shift RP Technician can perform all required Draft radiation protection tasks until the supplemental ERO is activated, therefore there is no need for the RP Response Coordinator to be part of the augmented ERO.

• The on shift RP Technician is also available to support transport of a contaminated injured person.

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PDEP RAI #29

• Part II, Section L.4, "Medical Transportation," states that prompt ambulance transport is available on a 24-hour per day basis. It further states that during transportation Radiation Protection personnel will accompany the victim.

RAI #29 Please clarify how transport is supported promptly since the on-shift staff does not include a Radiation Protection Technician. Also, the plan states that such service is confirmed by letter of agreement. Please specify organization(s) that will be providing transport to allow staff to verify with letters of agreement listed in Appendix 3.

• As discussed in the SCE response to SONGS-RAI-06, an RP Technician will be added to the required shift staffing organization described in Section B.1 and Table B-1.

Draft

• The Marine Corps Base, Camp Pendleton and Air Methods Corporation are Response the organizations that will be providing transport in accordance with the letters of agreement listed in Appendix 3 of the PDEP. Ambulance service personnel receive training in transportation of contaminated injured individuals.

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PDEP RAI #5

• Part II, Section B references Appendix 3 for a listing of active and in-force letters of agreement. Please RAI #5 submit copies of applicable letters of agreement applicable to this proposed plan for NRC staff review.

Draft

• Letters referenced in Part III, Appendix 3 of PDEP will be provided Response with RAI response.

19

PDEP RAI #7

• Part II, Section B.9 (Supplemental Emergency Assistance to ERO) states that agreements are in place for outside agencies to support Law Enforcement; however, Appendix 3 does not provide a reference for law enforcement support. Please confirm that any letters of agreement for law enforcement RAI #7 support are covered under the SONGS Permanently Defueled Security Plan and verify under what program or plant procedures, law enforcement and other offsite support (firefighting, medical assistance, etc.) would be coordinated in response to a security event at the SONGS site.

• The SONGS Physical Security Plan references the SONGS Draft Law Enforcement Response Plan (LERP) which outlines roles/responsibilities and coordination aspects. The LERP is Response designated Safeguards information. The necessary letters of agreement with law enforcement agencies are in place.

20

PDEP RAI #14

• Part II, Section D.1, "Emergency Classification System," refers to the capability to assess, classify, and declare an emergency condition within 60 minutes of the availability of indications.

• a. Please provide technical basis for designating 60 minutes as a threshold for event declaration once indications are available. Specifically, explain what activities or actions would be underway that would justify a delay classification of emergency out to 60 minutes.

• b. 5th bullet states, "The 60-minute criterion will not prevent implementation of response actions necessary to protect public health or deny the State and local authorities the opportunity to implement RAI #14 measures necessary to protect the public health and safety." Please provide the basis for this statement, since State and local authorities must still have the capability to implement offsite protective measures, if needed, which would be based on the time notification of the emergency classification, and while unlikely, assessment of the release of radioactive materials.

• c. The PDEP also states, in part, that "SONGS utilizes the classification methodology endorsed by the NRC in Regulatory Guide 1.101 [Emergency Planning and Preparedness for Nuclear Power Reactors] for development of initiating conditions and emergency action levels." Regulatory Guide 1.101 identifies NUMARC/NESP-007 and NEI 99-01 as acceptable alternatives to guidance provided in Appendix 1 to NUREG-0654/FEMA/REP-1, but only NEI 99-01 provides criteria for the development of initiating conditions and emergency action levels for a defueled plant. Please clarify the specific methodology used to develop defueled initiating conditions and emergency action levels.

Draft

• The requested change of event declaration threshold from 15 to 60 minutes was reconsidered and reduced to 30 minutes. The consequences resulting from the remaining creditable events develop over a lengthy period of time, Response therefore necessary emergency actions are not adversely impacted by the change from 15 to 30 minutes.

21

PDEP RAI #15

• Part II, Sections D.1.a and b state that notifications will be made by SONGS to required off-site agencies within 60 minutes of the declaration of an Unusual Event or Alert classification. Please provide technical justification for the 60 minute threshold, especially RAI #15 based on requested threshold of 60 minutes to classify an event, which may result in a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> time lapse from the availability of indication to classify an event until required off-site agencies are notified. Has this 60 minute notification threshold been discussed and agreed upon with State and local agencies receiving notification?

• As stated in the response to SONGS-RAI-14, the classification time has been changed from 60 minutes to 30 minutes. Therefore, the total time lapse from availability of indication to classify an event until Draft required off-site agencies are notified is 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.

• The change of notification time from 15 to 60 minutes is appropriate Response because events described in the design basis accident analysis and postulated beyond design basis accident analysis demonstrate that the time provided is sufficient to initiate State and local government emergency responses if warranted.

22

PDEP RAI #17

• Part II, Section E.1 states, "SONGS, in cooperation with state and local authorities, has established mutually agreeable methods and procedures for notification of offsite response organizations" Please provide documentation that reflects the RAI #17 engagement with State and local agencies on the establishment of mutually agreeable methods and procedures for notification, including agreement on notification message content and format, means of verification, along with methods of transmission as stated in Section E.3.

Draft

• Documentation concerning engagement with State and local agencies will be provided

Response

23

PDEP RAI #26

• Part II, Section J states that protective actions for the public are no longer necessary since it is no longer possible for the radiological consequences of design basis accidents or other credible events at SONGS to exceed EPA PAGs beyond the site boundary requiring offsite protective actions. The statement should be RAI #26 revised to reflect that the pre-defined protective action recommendations by the licensee (SONGS) are no longer required. Offsite agencies will maintain the ability under their comprehensive emergency management (all-hazard) plans to implement an offsite protective measure, if needed, in the unlikely event of a release due to a beyond design-basis event.

• The PDEP will be revised to reflect that while there is no pre-Draft defined Protective Action Recommendation by SONGS, the offsite Response agencies will maintain the ability to implement protective actions under their all-hazard plans.

24

PDEP RAI #10

• Note (4) under Figure B-1 states, "Southern California Edison will provide or arrange for additional technical, maintenance and other support as needed to restore station to pre-event condition."

RAI #10 Please describe what arrangements are or will be in place to expedite support for these functions. In addition, in what timeframe would outside sources be expected to be available to perform these function(s)?

• As a large utility, SCE has many resources that can be utilized to support emergency response to Draft SONGS. The company has procedures in place and routinely responds to casualty events.

Response

• SONGs requires an Emergency Response clause in major Supplemental Provider Purchase Orders.

25

PDEP RAI #11

• Note (5) under Figure B-1 states, "They may be provided by an Emergency Services Contract." Will these personnel be initially trained and maintain RAI #11 training qualifications as provided in Section O? In addition, in what timeframe would outside sources be expected to be available to perform radiation protection function(s)?

• If non SCE RP Technicians are utilized they would receive training on plant access and procedures. If warranted for emergency response, they would be Draft provided Just in Time Training (Ref RAI 08).

Response

• Outside resources can be obtained from other utilities or contracted services within a reasonably short period of time.

26

PDEP RAI #12

• Part II, Section C.2.a states, "If a near site Incident Command Post (ICP) has been established for a large scale or hostile action event, SONGS will send liaisons to the ICP to provide specific information relative to the event and assist as needed."

• a. Please describe whether SONGS has discussed this response with respective offsite response organizations, based on the decommissioning status of the site, and whether the dispatching of liaisons and coordination RAI #12 with offsite organizations at the near-site ICP is contained in established plant procedures. In addition, was the dispatching of these liaisons considered in the on-shift staffing analysis discussed in SONGS-RAI-08(a)?

• b. Please provide further details identifying assistance expected from appropriate State, local, and Federal agencies with responsibilities for coping with emergencies, including an act that includes the use of violent force to destroy equipment, take hostages, and/or intimidate to achieve an end. This may include an attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices to deliver destructive force.

Draft

• SONGS utilizes a Law Enforcement Response Plan (LERP) in accordance with 10CFR73.55 (k) (9)

• Liaisons sent to an Incident Command Post are supplied from the Response Supplemental ERO.

27

PDEP RAI #19

• Part II, Section F.1.b, "Communications with State/local Governments," states, "Offsite notifications are provided to local [underline added] agencies warning points (which are continually staffed) from the Command Center using commercial telephone lines or other mobile communications devices" Please provide responses to the following:

• a. Part II, Section E.3 states that, at a minimum, an initial notification will be made to the State of California and the Marine Corps Base (Camp Pendleton), in addition to Orange County and San Diego County. Please address the notification of the State of California and the Marine Corps Base (Camp Pendleton), and verify that phrase "local agencies" is RAI #19 specifically referring to Orange County and San Diego County.

• b. Plan simply states, "local [underline added] agencies warning points." Please identify organizational titles and alternates at both ends of communication for the State of California, Marine Corps Base (Camp Pendleton), Orange County, and San Diego County, based on agreement with respective offsite agencies.

• c. Plan states, "commercial telephone lines or [underline added] other mobile communications." Please clearly designate the designated primary and backup means of communication for required initial notification points from the Command Center, based on agreement with respective offsite agencies.

• The PDEP will be revised to explicitly include the State of California and the Marine Corps base (Camp Pendleton) as part of the offsite notification.

Draft

• The PDEP will be revised to include a table of warning point organizational titles and alternates (if applicable)

Response

• The PDEP will be revised to specifically state the primary and backup means for the required notification points from the Command Center will be commercial phone line (primary) and satellite phone (backup) 28

PDEP RAI #20

• Part II, Section F.1.e, "ERO Notification System,"

refers to using multiple methods of notifying the RAI #20 ERO. What specifically are the primary and backup communication methods? How are these systems maintained, tested and validated?

• The specific communication methods to notify the SONGS Emergency Response Organization Draft (ERO) will be commercial telephone (primary) and satellite phone (backup).

Response

• The PDEP will address communication system testing, maintenance and validation.

29

PDEP RAI #21

• Part II, Section G, "Emergency Public Information," refers to dissemination of information during an event at SONGS.

Please explain how the following NUREG-0654/FEMA-REP-1 evaluation criteria are addressed:

RAI #21

• Designated spokesperson, which should have access to all necessary information. (G.4.a)

• Arrangements for the timely exchange of information among designated company/agency spokespersons.

(G.4.b)

• Coordinated arrangements for dealing with rumors. (G.4.c)

Draft

• SCE has a dedicated Corporate Communication Response spokesperson who serves as a liaison with local media.

30

PDEP RAI #22

• Part II, Section H.1, "Command Center," states that plant systems and equipment parameters may be monitored in the Command Center. Please explain how the following NUREG-0654/FEMA-REP-1 evaluation criteria are addressed or provide justification for why criteria are no longer considered applicable:

RAI #22

• Onsite monitoring systems that are to be used to initiate emergency measures, as well as those to be used for conducting assessment.

The equipment shall include: geophysical phenomena (hydrologic/seismic) monitors, and fire and combustion products detectors. (H.5.a/b/d)

• Provisions to acquire data from or for emergency access to offsite geophysical phenomena (hydrologic/seismic) monitors. (H.6.a)

• The Command Center will incorporate instruments capable of Draft monitoring parameters necessary to classify events. There are no Emergency Action Level Initiating Conditions directly related to seismic Response monitors.

31

PDEP RAI #23

• Based on the elimination of the Emergency Operations Facility (Part II, Section H.2/H.3),

RAI #23 describe the means in place to coordinate potential response actions with off-site Emergency Operations Centers.

• While it is not anticipated that the offsite agencies would activate their Emergency Draft Operation Centers for an incident at SONGS, Response the Control Room or Command Center would be the facility from which the Emergence Director would coordinate with offsite agencies.

32

PDEP RAI #25

• Part II, Section J, "Protective Response," refers to protective actions during an event at SONGS. Please explain how the following NUREG-0654/FEMA-REP-1 evaluation criteria are addressed:

• 1. Each licensee shall establish the means and time required to warn or advise onsite individuals who may be in areas controlled by the operator, RAI #25 including:

• a. Employees not having emergency assignments;

• b. Visitors;

• c. Contractor and construction personnel; and

• d. Other persons who may be in the public access areas on or passing through the site or within the owner controlled area.

Draft

• Site personnel are notified of an emergency using the Public Address system and recognizable site alarms. These means will be maintained Response consistent with the site population.

33

PDEP RAI #27

• Under Part II.J.5, "Protective Actions for Site Personnel," clarify that the capability will exist to account for all individuals RAI #27 onsite at the time of the emergency within 30 minutes of initiation of accountability/site evacuation.

• The PDEP will be revised to clearly state Draft that accountability will be completed Response within 30 minutes of initiation of accountability/site evacuation.

34

PDEP RAI #30

• Under Part II, Section M.2, "Recovery Organization,"

please provide further detail on how normal SONGS organization will be structured to address the following NUREG-0654/FEMA-REP-1 evaluation criteria:

RAI #30

• Each licensee plan shall contain the position/title, authority and responsibilities of individuals who will fill key positions in the facility recovery organization.

This organization shall include technical personnel with responsibilities to develop, evaluate and direct recovery and reentry operations.

Draft

• SCE will revise the PDEP to clearly reference that the Plant TS contains the requirement to maintain the Response normal organizational requirements in the UFSAR.

35

PDEP RAI #32

• Under Part II, Section N.2, "Other Drills," please address the following NUREG-0654/FEMA-REP-1 evaluation criteria:

• (Under Communications Drill) Testing of communications with Federal RAI #32 emergency response organizations (N.2.a), specifically with NRC Headquarters and NRC Regional Office Operations Center; and

• (Under Radiation Protection Drills) Plant environs and radiological monitoring drills shall be conducted annually (N.2.d).

• The PDEP will be revised to include quarterly testing of communications with NRC Headquarters and NRC Regional Office Operations Center.

Draft

• The PDEP will also be revised to include annual drills to measure all sample Response media at or near the site boundary and they will also demonstrate communications and record keeping. Wording to invite offsite agencies to participate at least once per drill cycle will also be added.

36

PDEP RAI #33

• Under Part II, Section O, "Emergency Response Training," please address the following:

• a. Please define the frequency for "annual" training.

• b. (Section O.1, "Assurance of Training of the Offsite Response RAI #33 Organization") Please clarify that training on "special problems potentially encountered during a nuclear plant emergency" includes radiological orientation.

• c. Please include or reference what training is provided for fire control teams (fire brigades), security personnel, and headquarters support personnel on emergency plan-related response activities, as applicable.

Draft

• The PDEP will be revised to address each point

Response

37

RAI Responses 1-4, 9, 13, 16, 18, 24, and 31 EDITORIAL AND CLARIFICATIONS 38

PDEP RAI #1

• The NRC staffs evaluation of the associated March 31, 2014, exemption request for SONGS will consider the ability of applicable design-basis accidents to exceed U. S.

Environmental Protection Agency (EPA) Protective Action Guides (PAGs) at the site boundary. The statement in the RAI #1 3rd paragraph of Part I, Section B states, "The analysis of potential radiological impact of an accident in a permanently defueled condition indicates." It is not clear from the statement if this analysis applies to design-basis accidents only. Please clarify this sentence.

Draft

• The statement in the 3rd paragraph of Part I, Section B will be revised to clarify applicability to design basis accidents Response only.

39

PDEP RAI #2

• Part I, Section C: "Scope"

• (1) Clarify whether the second sentence concerning "postulated accidents" is meant to address design-basis accidents only.

RAI #2 * (2) The scope of the plan should also address/include provisions in the plan regarding notification of offsite government agencies concerning the classification of emergency events and the impact of the potential release of radioactive materials to inform decision making by offsite authorities on protective measures, if needed. Please revise the proposed plan, as necessary.

• (1) The statement will be revised to clarify applicability to design basis accidents only.

Draft * (2)Section C: Scope will be revised to state that the PDEP provides for Response notification of offsite government agencies concerning the classification of emergency events, the impact of a potential release of radioactive materials and information on any protective measure, if needed.

40

PDEP RAI #3

• The NRC staffs evaluation of the associated March 31, 2014, exemption request for SONGS will consider that, in the unlikely event of a beyond design-basis accident resulting in a radiological release due to a postulated zirconium fire, early offsite protective measures could be implemented.Section IV.B.1 to Appendix E of Part 50 still requires that the licensee have the means to determine the magnitude of, and for RAI #3 continually assessing the impact of, the release of radioactive materials.

Part II, Section A.1.b, "SONGS Concept of Operations," lists the functions provided by the Emergency Response Organization (ERO).

There is no reference to any type of radiological monitoring or dose assessment. Revise the plan to reflect ERO performance of these specific types of functions, or provide justification for not addressing these functions.

Draft

• The PDEP will be revised to include radiological monitoring and dose assessment in the list of functions provided by the ERO.

Response

41

PDEP RAI #4

• Planning Standards cited in Part II reflect statements as exempted. For clarification RAI #4 purposes, please consider adding the phrase "as exempted" following planning standard number.

• The words "as exempted" will be added after the stated Planning Standard number (which Draft is in a box at the beginning of each Part II Response section of the PDEP) for which a change was requested in the SONGS exemption requests.

This applies to sections A, C, D, E, F, G and J 42

PDEP RAI #9

• Note (1) under Figure B-1, "Emergency Response Organization," states, "Shaded boxes indicate shift positions."

RAI #9 There are no shaded boxes on this figure. Please revise as required to clarify or provide basis for note.

• The SONGS PDEP Figure B-1 will be Draft revised to delete the shading and Response shadowing effects and Notes 1 and 2 will be revised.

43

PDEP RAI #13

• Part II, Section C.3 states, "Laboratory facilities are available and equipped to support normal plant and expected emergency operations." Please identify the location(s) and briefly describe the RAI #13 capabilities of these facilities to support expected emergency operations. In addition, the plan states, "Agreements may also be used to obtain laboratory services from other stations." Please include referenced agreements in Appendix 3 and submit copies for NRC staff review.

• The PDEP, Part II, Section C.3 is revised by adding a paragraph as follows:

• Laboratory facilities are available and equipped to support normal plant and expected emergency operations. Services will be Draft contracted as needed for declared events. Agreements may also be used to obtain laboratory services from other stations.

Response

• Support of the radiation monitoring and analysis effort is provided by Sierra Analytical Labs, located in Laguna Hills, California and GEL Laboratories in Charleston, South Carolina. The laboratories have the capability for radiological and chemical analyses of terrestrial, marine, and air samples.

44

PDEP RAI #16

• Part II, Section D.4, "Offsite Emergency Planning,"

states, "Although they may not be specific to an event at SONGS, the Emergency Preparedness Manager should [underline added] coordinate with offsite agencies for response planning to an emergency at the station." This statement implies that coordination RAI #16 with offsite agencies is optional for events that may require a response by offsite organizations (firefighting, medical assistance, etc.) to the station.

Please discuss interactions with State and local agencies that SONGS plans to maintain to ensure the effective maintenance and implementation of the SONGS Defueled Emergency Plan.

Draft

• The PDEP will be revised to require Manager, EP to coordinate with off-site agencies.

Response

45

PDEP RAI #18

• Part II, Section E.3, "Initial Notification Messages," states that the initial notification form will provide the following information:

• d. Type of actual or projected abnormal release (airborne or liquid).

• g. Actual or projected dose rates and/or integrated dose at the Site Boundary.

• h. Estimate of any abnormal surface radioactive contamination in plant or onsite.

RAI #18

• a. Items e & f have either been omitted or the list mis-numbered.

Please correct the listing to provide missing information or renumber as appropriate.

• b. How is the radiological information, stated in Items d, g, and h above, determined in a timely manner to support the initial notifications, since the on-shift staff does not include a Radiation Protection Technician?

Draft

• The list will be renumbered.

• As discussed in the SCE response to SONGS-RAI-06, an RP Technician Response will be added to the required shift staffing organization.

46

PDEP RAI #24

• Under Part II,Section I.10, "Dose Estimates,"

states, "Events at the permanently defueled station no longer can exceed the Alert level (i.e.,

offsite doses will not reach EPA Protective RAI #24 Action Guides)." Revise statement to clearly reflect that Alert level threshold is based on a release for an applicable design-basis accident only reaching a fraction of the EPA PAGs.

Draft

• PDEP will be revised as requested.

Response

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PDEP RAI #31

• Under Part II, Section N.1, "Biennial Exercise," provide further details on how an integrated drill, performed on alternating years, will include a combination of some of the principal functional areas of the onsite emergency response capabilities, including:

• activities such as management and coordination of emergency response,

• accident assessment,

• event classification, RAI #31

• notification of offsite authorities,

• assessment of onsite impact of radiological releases, and

• system repair and mitigative action implementation.

• Also, clarify that during these drills, the following areas would be addressed:

• opportunity to consider accident management strategies;

• supervised instruction would be permitted, and

• operating staff would have opportunity to resolve problems (success paths).

Draft

• PDEP will be clarified to address each point.

Response

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NRC QUESTIONS/FEEDBACK 49

ACTIONS/

SUMMARY

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Decommissioning Principles Safety Stewardship Engagement For more information on SONGS Emergency Planning; please visit www.songscommunity.com 51