ML19340B127

Forwards 800501 Evaluation of Revised Facility Emergency Plan.Plan Is Well Written & Addresses Objectives in Logical & Comprehensive Manner.Suggestions Not Considered Deficiencies.Included as Proposals for Addl Clarification

ML19340B127
Person / Time
Site:	Surry
Issue date:	10/17/1980
From:	Myers J Battelle Memorial Institute, PACIFIC NORTHWEST NATION
To:	Rohrer R NRC - EMERGENCY PREPAREDNESS TASK FORCE
References
NUDOCS 8010210470
Download: ML19340B127 (21)

Text

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0Battelle Pacific Northwest Laboratories I

P.O. Box 999

' Richland, Washington U.S.A 99352

' Telephone (509) 375-3759 Telex 15-2874 October 17, 1980 fir. R. Rohrer, Team Leader Emergency Preparedness Task Force; i ' Muclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Rohrer:

Review and Evaluation of the Surry Power Station Emergency Plan Dated May 1, 1980.

.The subject Emergency Plan has been evaluated against the sixteen Planning-Objectives and the emergency preparedness criteria in Part II of NUREG-0654.

The plan.is.well written and addresses the planning objectives in a logical and comprehensive manner. This is evidenced by the fact that the intent of the objectives has been either completely or partially satisfied.

i The deficiencies noted under the seven planning objects that were partially

< satisfied are not of an extrene. nature and can, therefore, be easily included in the plan without najor disruption.

! You will also note that in several instances suggestions for improvement or 1 enhancement of the plan have been = included in the body of the narrative portions of the evaluation.

These suggestions are not considered deficiencies and have been included only as proposals for additional plan clarification.

Very truly yours, f!;g .y //!f y

.i r , , . , .

John G.'Myers i

Consultant' Health Physcis Technology Section JGM/Inl

-cc: M. L'. Smith 0 A. E. Desrosiers - g.

1 Site File 9t l File /LB l l

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I EMERGEf!CY EVALUATION REPORT SURP,Y POWER STATION VIRGINIA ELECTRIC AND POWER COMPANY The revised Emergency Plan issued-by Virginia Electric and Power Company for l their Surry Power Station dated June 16,1980 was evaluated to assess if the l

Company has met the intent of the sixteen Emergency Planning Objectives in l . Part II of the Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in support of Nuclear Power Plants (NUREG-0654) i The following report lists each objective in order, followed by a summary of j the planning commitnents, and overall evaluation, and comments on deficiencies

'in the plan.

A. Assignment of Responsibility (Organization Control) l.

Planning Objective To assure that primary responsibilities for emergency response in nuclear facility operator, State and local organizations within the Emergency Planning Zones have been assigned, that the emergency responsibilities of

j. -the various supporting organizations have been specifically established, 1

and that each principal. response organizatioc is staffed to respond and to augment.its initial response on a continuous basis.

Emergency Plan

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.The shift- supervisor for each nuclear power generating facility is

~-initially.. designated. as the Emergency Director. When an abnormal l

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J condition arises, it is his responsibility to determine if the abnormality ,

constitutes lin emergency according to ' implementing procedures. If in his i judgement, the abnormality falls within one of the Emergency Action Le'vels

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classes specified'in Appendix I of-fiUREG-0654, it .is his responsibility to implement the emergency plan.

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' Federal, State, local and private agencies and organizations have been identified and their responsibilities defined. There is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 1t day communication linkage between the station and Federal, State, local and

, I private agencies and/or organizations to insure rapid transmittal of

accurate notification information and emergency assessments data is made l available to them.-

The' plan ' vests responsibility for overall performance of the emergency

! ' response organization-in the Station Manager who. is empowered to implement

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company policy with regard to operation of the Surry Power Station.

l Qualified members of the station staff who report directly to him have been a'ssigned specific responsibilities for. major elements of emergency 4 ' response.

Copies aof current Agreement Letters with Federal, State. . local' and private organizations are included in Appendix 10.1. The letter from the State

-l Office of Emergency;and Energy Services. dated April 30,.1980 refers only.

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.to'the tbrth Anna Power Station Emergency Plan. The letter should be '

revised-to include the Surry. Plant.-

f F The 'pla. satisfies'the-intent of the objective.

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3 B. Onsite Emergency Organization Planning Objective To assure that on-shift facility operator responsibilities for emergency response are unambiguously defined, that adequate staffing to provide

' initial facility accident response in key functional areas is maintained at all times, and timely augmentation of response capabilities is

! available, and that the interfaces among various onsite response activities and offs;te support and response activities are specified.

Emergency Plan The shift supervisor on duty at the tine of an adnormal occurrence is designated as the Emergency Director until relieved by a senior nember of the piant staff. A seven-stop line of succession has been established commencing with the Station Manager and decending in order by station-st:ff members reporting directly to him. The authorities and '

responsibilities of the Emergency Director have been clearly specified j including tnose.that cannot be delegated. The EmergMcy Director can l

l immdiately and unilaterally declare an emergency status and make offsite i l'

notifications.

Station. staff emergency assignments have been made and the relationship between the energency organization and normal staff complenent are shown

! in the plan.. Positions and/or titles and' qualifications of shift and plant staff personnel, both onsite and offsite who are assigned specific j V

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i l . emergency duties, are listed and conform to assignments shown in Table 8- .

-1, NUREG-0654. The staffing level with the exception of the deficiencies I

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.'noted below.is adequate to perform anticipated' corrective actions during an energency. The augnentation tine is one hour with two exceptions.

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- Augmentation time for the Manager, fluclear Operations and Maintenance and the Director, Health Physics and Chemistry is 90 minutes.

Corporate management personnel who will augment the plant staff and their

! duties and responsibilities have been established. A long term energency i

frame work is in place headed by' the Executive Vice President-Power.

Interfaces between and among the Coapany Corporate staff.. station staff, governmental and private sector organizations and technical and/or

engineering contractor groups have been specified along with services to be provided.

j- The plan partially satisfies the intent of the objective.

Deficiencies-

1. The plant minimum shift shown in Table 5.1 does not provide for a Chemistry / Radiochemistry Technician on shift as required by Table B-1, NUREG-0654. In case of. emergency, radiochemical analyses may be required before a technician can arrive from off site.

2. Table 5.1 indicates mechanical and electrical maintenance personnel are onsite for only 17 out of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (i.e., there is no coverage between 3:30 p.m. to 7:00 p.n. and 3:30 a.m. ' to 7:00 a.m.) In case of  !

emergency during uncovered periods immediate mechanical or electrical maintenance could be vital for accomplishing safe plant shutdown or j mitigation of the emergency.

- C. Emergency Response:and Resources Planning Objective

To assure that arraagements for requesting and effectively using assistance resources have been made, that arrangements'for-State and local L i

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staffing of. the operators near-site Emergency Operations Facility have l.

been made, and that other organizations capable of augmenting the planned resporise have been identified.

Energency Plan-l-

The plan identifies in a general way the resources available through the L RAP program, although "the company' does not place major reliance in this support". The persons with whon the RAP team maintains contact is not l

specifically . identified although it is inferred to be either the Emergency Director or Recovery ttanager.

Backup radiological laboratories are identified along with tiheir response times, but ne letters of agreement docunenting capabilities and response l

l-times are provided. Thorcugh docunentation of backup assistance from other offsite organizations is provided.

The plan partially satisfies the intent of the objective.

Deficiencies

-1. There is no provision in the plan to' dispatch a licensee representative to the principal governmental Energency Operation Centars. This is necessary:in order to provide technical expertise and assistance to offsite response organizations.

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D. Emergency Classification Systen Planning Objective

-To assure that a standard energency classification and action. level scheme

-is in fuse by the nuclear- facility. operator, including facility systen and I'

effluent parameters; Land to assure that State and local response l

organi:ations,'will rely on information provided by facility operators for Edeterminations-of initial offsite..respo.nse measures.

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6' Emergency Plan Example initiating ~ conditions for each Emergency Action Level Class form the basis for establishment' of specific instrument readings which,' if exceeded initiate'the appropriate emergency class. The current Virginia 4 Radiological Response Plan and the local conunties energency classification system recognize only two Emergency Action. Levels, " Yellow" (Site Emergency) and " Red" (General Emergency). When the state office of Energency and Energy Services is notified by the Energency Director of-either a " Yellow" (Site Emergency) or " Red" (General Emergency) they will notify the Virginia Department of Health who will inplement the- State response procedures.

The ti:itiating conditions for the Emergency Action _ Level Classes shown in 1 j

' Apper. dix 1, NUREG-0654 have.been addressed in the plan with one exception. l The plan partially satisfies the intent ~of the objective.

i Omissions

-1. Example' initiating condition 10, " Loss of Function Needed for Plant Cold Shutdown," in the Alert Classification has not been addressed.

The purpose'of this example initiating condition is to provide attention to failed equipment needed-to obtain cold shut down status and make necessary repairs while-the reactor is operating. If the reactor trips or if the reactor must be' shut down' when equipnent needed for cold- shutdown is out. of service a- Site Emergency declaration is_ required.

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7-i E. flotificnion Methods and Frocedures j Planning Objective To assure that procedures have been established for notification, by the facility, of State and local response organization and for notification of energency personnel by all response organizations; to assure that the content of initial and followup messages to response organizations and the p9blic have been established; nd to assure that means to provide early warning and clear instruction' to the populace within the plune exposure pathway Energency ' Planning Zone have been established.

Emergency Plan

{ The plan satisfactorily provides for the notification of offsite 4

authorities and for verification of notification. It is assumed that the f:RC can be notified within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, but more explicit documentation would be useful. The plan provides a standard form for nessage content that is

$ straightforward and complete. The plan identifies the specific organization responsible for notifying the affected population, and discusses the ability of the local authorities to notify the public within 15 minutes. A 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> / day capability to warn the public is assuned but not spectifically addressed. Prewritten messages to be conmunicated in the event of tne different types of emergencies are provided, it would be useful to identify the specific radio' station over which these messages would be broadcast. The plan acknowledges the requirement for the annual statistical' sample'of plune EPZ population exposure..

The olan satisfies the intent'of the objective.  ;

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F. Emergency Communications Planning Cbjective:

To _ assure that provisions exist for prompt communications among principal response organizations, to emergency personnel and to the public.

Emergency Plan i

l 'The_ plan has paid careful attention to specifying communication links.

Based on the letters of_ agreement it is clear who will notify the FAA, the railroad and the Coast Guard, although such notifications could be more explicitly identified in the text. It is not clear who notifies the fbtional Weather Service. The plan identifies organizational titles and alternates, the major communication systems, reliable primary and alternate meanslof communication, and the testing of the communication l

i links.

The plan satisfies the intent of the objective.

l G. Public Information l' Planning Objective l

! To assure that accurate and timely infornation is provided to the public on how they will be notified and what their initial actions should be; to

' assure that the principal points of ccntact with the new media for l Edissemination of information (including physical location or locations) i l

are. established in advance; and to establish procedures for coordinated

. dissemination of information to the public. -

Emergency Plan The plan describes provisions for the periodic dissemination of .

information to the public. . The plan identifies the-location of a public

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- news center, and discusses the annual program to brief news media. The spokesperson is designated in the plan and arrangements are identified for the timely exchange of information among the various parties.

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-The plan satisfies the intent of the objective.

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l H. Emergency Facilities and Equipment Planning Objective-To assure that adequate emergency facilities and equipment to support the-

j. emergency response are provided.

Emergency Plan

. Emergency facilities needed to support an emergency response have been provided including a Technical Support -Center, near site Emerency

Operations Facility and onsite Operations Support Center. Each will be-activated for an alert or higher classification. The onsite Technical Support Center is established in the Control Room Annex. The Center contains a complete controlled set of drawings, technical manuals and other records. . Communication systems link the Center with other plant emergency facilities,-and governmental and support agencies.

The nearsite' Emergency Operations Facility is located on Company property. The precise location in not given in the plan. Corporate, and governmental officials will assemble at this facility to evaluate and coordinat'e reentry / recovery operations on a continuing basis. The

. facility will also be the Center for the receipt and analysis of field l monitoring information.. A communication system links the facility with other plant emergency facilities and.as well as governmental and . support agencies. An alternate Emergency Operations Facility has been established i.

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,-----3 in the Lebanon. Elementary School in town of Surry. The distance from the plant ~ site is 'not 91 ven .in the plan.

The. onsite Energency. Support Center (Assembly Area) is located in the-station's switch gear room and will be the assembly point for unassigned

' personnel. The. plan does not indicate the adequacy of capacity, shielding or ventilation. Protective equipment is normally stored in the Health Physics Office and. warehouse and will be transferred to the operations Support Center as needed. f'o reference is made about .the location of the Health Physics Office and warehouse relative to the 0perations Support

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Center.-

Onsite monitoring systems and instrumentation used to initiate energency measures and/or provide continuing assessment are identified. They are a meteorology system with wind speed and direction and tenperature capability; seismic instrumentation to monitor acceleration levels of ground movement;' installed process radiation nonitors to measure deviations in radiation levels in process lines that contain or potentially contain radioactive effluents; installed area radiation monitors that measure deviations in radiation levels at specific locations in the station; fire and smoke detection instruments placed at strategic locations in' the plant; portable dose rate and radiation detection instruments and , laboratory counting and analysis facilities.

. Provisions for offsite monitoring equipment have been nade.

Meteorological ~and/or seismic data, respiratory equipnent, portable

radiation -detection-instrumentation and-laboratory facilities can be obtained from the VEPCO .f' orth -Anna . Power Station. The Virginia State

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. Cepartment.of Health is also equipping a mobile laboratory with

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[ 11 radiological. ' assay equipment to respond to radiation emergencies. There are no offsite meteorological facilities close to the Surry Power Station. However, data can,be obtained from nine locations ranging from 6 to 55 miles from the plant. Stored equipment is inspected and invento.r_ied each quarter and replaced'if in need of calibration or repair and~

sufficient' equipment exists to ensure a minimum inventory in case of '

replacement' delay. Portaole survey.instrunents and counting room j - equipment.is calibrated at least bi-annually. Appendix 10.5 lists the contents.of emergency kits. The appendix does not state the number of kits.available or where they are located.

The plan partially satisfies the intent of the objective Deficiencies

1. There is no provision for an onsite back up meteorological system.

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2. lnstalled process monitors' and radiation nonitoring instruments are not listed-by. type of instrument, detection range, (i.e., cpm, mR/hr, l

pressure, temperature, etc.) or function.

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3. The adequacy.of. inplant iodine, reactor core cooling and in-containment radiation levels were not clearly or. specifically discussed.

4. The'locat! ion;~of the primary near site Emergency Operations Facility (i.e., distance from plant and name of. building wher.: housed) was not -

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. identified. 'The distance from the plant' to the alternate E0F was not stated.

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12 I.. Accident Assessment

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Planning Objective

-To assure the adequacy of' methods,. systems and' equipment for assessing and-nonitoring actua1 Lor potential offsite consequences of a radiological

~ emergency co_nditions.

Emergency Plan' The plan divides assessnent actions.into eight discrete areas of interest as opposed to' being grouped under specific energency classsifications, since certain' assessment actions will be required prior to the-classification of an emergency. The areas of interest are: t'atural Phenomena, Personnel' Hazards, Stations Conditions, .0ffsite Conditions,

!- Onsite Radiological, Offsite Radiological, Post /ccident ' Sanpling and t

Offsite ffonitoring Teams. .This listing does not' imply that each action would be taken for every situation but_ only that actions have been considered on a broad enough basis to cover the entire classification system.

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The Emergency Plan Implementing Procedures contain radiological effluent parameter values characteric of a spectrum of off-normal conditions. The j<

_ parameter values' and other information. are tabulated for each Emergency Class. Specific ~ set points and_ alarms both audio and visual in the l control room ' alert the operator. The EPIP's provide three methods for determining the nagnitude of a- release:

1..Use of measurements and' samples continuously obtained by the onsite

radiation nonitoring systems, l

2. Using'known inventory data from systens affected,

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3. A obtaining offsite data from air samplers, dosimeters and survey results and using these data to calculate release.

The plan ~ partially satisfies the intent of the objective.

Deficiencies-

1. The' plan does not address the mechanism used to determine the offsite dose based on actual or potential release of large guantities of f

radioactive-gases or halogens from the containment structure.

2. The plan does not_ give or refer to detailed procedures to be used by station personnel in responding to abnormal conditions or in assessing l

the actual or potential magnitude of a release.

J. Protective Response.

Planning Objective To assure'that a range of protective actions is available for the plume exposure pathway for emergency workers and the public, guidelines for the choice of protective actions during an energency, consistent with Federal guidance, are developed and in use, and that protective actions for the ingestion-exposure pathway appropriate to the locale have been developed.

Energency Plan The Emergency Director will recommend or initiate evacuation and will take l.

appropriate measures in cooporation with. local and state agencies for evacuation of persons in the Exclusion Area (i.e. outside the fenced area bu?. inside VEPC0 owned property) and members of the public who may be in L .

or passing-through the. exclusion' area; -Evacuation of employees within the exclusion.and protected areas 'who are considered non-radiation workers -

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"may occur" if projected doses to the majority of the affected workers will . exceed a dose'of 1.0 rem whole-body or 5.0 rem thyroid due to inhalation. In any event members of the public considered as " transients" on- VEPC0 owned-property will be evacuated by security personnel in case of an alert or higher classification emergency.

Emergency Plan Implementing Phocedure-9 addresses personnel accountability with or without an evacuation. Form EPIP 9.1 " Personnel kcountability" is used by station management and supervisica to determine the location and/or status of onsite personnel. Onsite personnel who are being evacuated will monitor themselves for contamination prior to entering the Restricted Clean Area. They will then leave the site on route 650 and go to to route 617, the assembly area.

The recommended actions (i.e., sheltering or evacuation) inade to the State for a " Yellow" .(Site Emergency) or-" Red" (General Emergency) will be based on current meteorological -data and projected whole body and/or thyroid dose, factored against the protection afforded by dwellings in the plume exposure pathway and evacuation times. Shielding factors for representative housing within the 10 mile EPZ for both a gamma cloud source and surface deposited radionuclide and evacuation time estimates are included in the plan. Warning. methods to inform the public are stated in the plan._ It is estimated-that the primary sector and two buffer sectors can be alerted and given instructions'within two hours of the

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( ' declaration of_an energency. This will be reduced to 15 minutes when the -

early warni- ; ystem is completed by about July 1, ?9@I.

The plan partially satisfies ~the objective

15 Deficiencies

1. The plan fails to state if the licensee will have the capability to-

-_ decontaminate personnel at relocation centers.

2. The accountability procedure outlined in Section 6.4.1 fails to indicate if the procedure can be completed.within the 30 minutes after declaration of' an emergency as required in NUREG-0654.

-K. Radiological Exposure Control Planning Objective To assure that means for controlling radiological exposures,-in an emergency, are established for emergency workers and the affected

population.

Emergency Plan The plan has established onsite exposure guidelines consistent with EP)

Emergency tlorker and Life Saving Activity Protective Action guides for removal of injured persons, corrective and protective actions, first aid, personnel decontamination and ambulance and medical service. Emergency response personnel may receive radiation exposure in excess of 10 CFR 20 i

limits when authorized by the Emergency Director. 1 l

l l The licensee has made provisions for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day capability to l

distribute both self reading and~accumnulative type dosimeters to l emergency workers regardless-of company affiliation, deter lne radiation

. doses received and maintain dose records through out the emergency. l An-a'ction level for determining the need f_or radiological decontamination of personnel and equipment has been established at 1000 dpm/100 cm2 of removable contamination.

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Onsite contamination control including area access, potable water and food supplies have been established. The criteria for return of areas and items to normal.use and contamination levels in designated eating and.

drinking locations'within the' station beyond which decontamination or i

access control is required are not given.

The station will supply clothing and decontanination materials to onsite personnel required to relocate and who routinely leave the plant site.

The plan partially satisfies the intent of the objective.

Deficiencies L

1. Contamination levels beyond which decontamination or radiation storage is required and the radiation / contamination level (s) beyond which area l access is required is not clearly stated. Release levels for l personnel, equipment, materials, access control and in plant food and l water supplies (e.g , lunch room, canteens etc.) should be clearly specified preferrably .in tahular form.

i L. Medical and Public Health Support Planning Objective To assure that arrangements are made for medical services for contaminted

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-Emergency Plan Medical.' services will be provided by the Medical College of Virginia (MCV) for personnel injured or. exposed to radiation and/or radioactive 'l material. A . letter of agreement with the college defines the services to be provided. The plan refers to the MCV-VEPC0 Radiation Energency Plan,

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4 k ' Appendix 10.7. The plan is not in the appendix. The location of the MCV ~

} me' dical facilities in relation to the plant. site is not given.

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The station has a first aid facility containing the normal compliment of

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first aid supplies. and equipment necessary to treat-injuries not involving

. hospitalization or. medical services.- Arrangements have been made through

, letters of agreenent with. volunteer rescue squads in Surry and Smithfield,

VA. to provide ambulance service when needed.

The plan satisfies the intent'of the objective.  !

M. Recovery and Reentry Planning and Post Accident Operations l Planning Objective j To assure tht general ~ plans for recovery arid reentry are developed.

4 Emergency Plan ,

.The plan satisfactorily identifies and defines.the general plans and i

j - procedures to be used -by VEPC0 management in implementing the recovery, reentry and post accident phase of an emergency.

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{ . Personnel comprising the Company recovery team have been identified along 2

with their alternates (Figure 9.1). The-team headed by the Executive Vice l President-Power is comprised of supervisory personnel who have the 3,

authority .to assure-the best available use. of company resources to assist i

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in :a- rapid recovery. -

l The decision on the Company's part to relax-protective measures in based on a . comprehensive review of identified station system parameters by both 1l

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'the Emergency Director and Recovery Manager. Conditions considered ~ ,

- appropriate--for crnsideration of relaxation of protective measures have

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18 been identified in the plan. A procedure for notification of Federal, State, local and private support organizations of the decision to initiate recovery operations and any resulting changes in Station organization has been stated. The plan reviews and discusses the procedures and methods that will be used to periodically estimate the population dose in the affected sectors and zones.

The plan satisfies the intent of the objective.

M. D ercises and Drills Planning Objecti3 To assure that periodic exercises are conducted to evaluate major portions of energency response capabilities, that the results -of exercises form the basis for corrective action for identified deficiencies and that periodic drills are conducted to develop and maintain key skills.

Emergency Plan The plan satisfactorily addresses the frequency of exercises and drills.

A combined States, local and station exercise will be held annually and drills will be scheduled on an annual basis so that all major elements of the Emergency Plan are tested over a 5 year period. The plan also p:ovides for scheduling an annual drill once each 6 years for the periods between 6:00 p.m. and midnight and midnight and 6:00 a.m. Communication, fire, medical, radiological monitoring and Health Physics drills have been )

addressed and scheduled in accordance with Section F2 of MVPEG-0654. l l

The content of exercise scenarios and arrangements for a critique of )

1 exercises and drills have been appropriately addressed. A statement in I l

the plan regarding capability (s) of " qualified" observers would be helpful.

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L The plan satisfies the intent of the objective.

O. Radiological Emergency Response Trairing i lanning Objective l

To. assure that radiological emergency response. training is provided to i t.! hose who may be called upon to assist in an emergency.

I Energency Plan

- The plan satisfactorily addresses preparedness training for Company personnel involved in emergency response, Figure _8.1. Training will be

(- ' appropriate to their functions, authority and role during an emergency and -

l will be_ conducted in a formal fashion with individual tests at the end of the training period to determine each persons competence. After initial training, each person will be retested annually. Although not specifically required a statement concerning the minimun level-of competence that must be' achieved by each person in an emergency role would be helpful.

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The plan satisfies the intent of the objective.

P. Responsibility for the Planning Effort:

Development, Periodic Review and Distribution of Emergency Plans Planning Objective

.To assure that responsibilities for plan development, review and distribution' of emergency plans are established and that planners are properly trained.

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i . Emergency Plan The plan provides for training of personnel responsible for emergency plan-deyelopment' including Lthe Emergency Plan Coordinators at both the station and c'orporate levels and the Executive Manager - Licensing 'and- Quality Assurance who has overall-authority and responsibility for emergency

- respose planning.

An annual review of the plan and its associated emergency plan implementing procedures by the Station fbclear Safety and Operating 4

Comittee (SNSOC) for adequacy and applicability has been established.

Changes and/or revisions to the plan and/or EPIP's must be approved tur i SNSCO prior to distribution. Selected personnel from offsite agencies '

likely. to respond. to emergency situation are invited to attend meetings to discuss emergency planning and' response activities. -Provision for bi-annual re-negotiation of letters of agreement has been established in the

- plan.

If results of exercises, drills, critiques require it, or changes in Federal, State or local requirements occur, revisions will be issued to i

' the plan. Revisions will be numbered, pages dated and forwarded to those on 'the-Controlled Distribution list with an acknowledgement receipt request. -Quality Assurance personnel will audit those on the distribution list to ensure the plans are kept updated, and will also conduct'bi-annual l

l auditsLto assess the completeness of procedures and the adequacy of {

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. training.

The plan satisfies the intent of the objective.

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