ML20069J949

Supplemental Answers to Sunflower Alliance,Inc Second Set of Interrogatories.Certificate of Svc Encl

ML20069J949
Person / Time
Site:	Perry
Issue date:	10/20/1982
From:	Silberg J CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	SUNFLOWER ALLIANCE
References
NUDOCS 8210250322
Download: ML20069J949 (17)

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00CHETED US!RC October 20,g 9 g y g'0 N 9

r eiCRETAPY UNITED STATES OF AMERICA 'I L E NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY, ET AL. ) 50-441

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(Perry Nuclear Power Plant, )

Units 1 and 2) )

APPLICANTS' SUPPLEMENTAL ANSWERS TO SUNFLOWER ALLIANCE, INC. ET AL.

SECOND SET OF INTERROGATORIES TO APPLICANTS As stated in Applicants' September 30, 1982, Answer to Sunflower Alliance, Inc. Motion To Compel Applicants To Answer Second Set of Interrogatories (" Applicants' Answer"),

Applicants have agreed to provide answers to certain interroga-tories to which they originally objected. Applicants hereby answer those interrogatories.

RESPONSES

44. Demonstrate and discuss how emergency response facilities meet each and every critet.. '

listed in NUREG-0814; answer all questions therein. (Emergency response facilities include the control room, Technical Support Center, Operational Support Center and Emergency Operations Facility.)

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Response

Sunflower Alliance, Inc. (" Sunflower"), by its Motion To Compel Applicant To Answer Second Set of Interrogatories, has limited Interrogatories #44, #45, #46 and #47 to Applicants' Emergency Operations Facility (" EOF"), and has further restric-ted Interrogatory #44 to Sections 5.1 and 5.2 of NUREG-0814.

See Applicants' Answer at 3.

The following is a comparison of Applicants' commitments cn the EOF with each of the criteria of Sectier.2 5.1 and 5.2 of NUREG-0814.

NUREG-0814 Criteria Responses to NUREG-0814 Criteria 5.1 Integration with Overall Emergency Planning

1. The design of the Emergency Section 7.1.3 of the Operations Facility (EOF) Emergency Plan for addresses the following Perry Nuclear Power goals: Plant, CEI Report No.

OM-15A, Rev. O (September

a. Management of over- 22, 1982) (" Emergency all licensee emergency Plan") states that the responses; EOF will be staffed to address each of these

b. Coordination of goals or functions. Further, radiological and the EOF has been designed l environmental to provide sufficient l assessment; space to perform each of the functions assigned to

c. Determination of EOF personnel. See recommended public Figure 7-3. E.g., the protective actions; and radiation dose assessment l function will be carried i d. Coordination of out in the display room; l emergency response coordination with off-site l

activities with agencies will take place Federal, State, and in the communication room.

local agencies.

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2. The EOF shall be staffed by Applicants' primary licensee, Federal, State, staffing commitments local and other emergency for the EOF are described personnel designated by in Section 5.2.4 of the the emergency plan. Emergency Plan. As shown

( in Figure 7-3, space will be provided for State and local agency repre-sentatives (room labeled "L/S") as well as Nuclear Regulatory Commission representatives (room labeled "NRC") in the event of a radiological emergency. Thus, should these agencies' own plans and/or procedures call for them to send repre-sentat.ives to the EOF, their representatives will be accommodated.

3. Facilities shall be pro- The technical instru-vided in the EOF for the mentation and data acquisition, display, available in the EOF and evaluation of all ra- will include computer diological meteorological terminals from the and plant system data per- Emergency Response tinent to determining off- Information System site protective measures. ("ERIS") and the Radiation Protection Data Information System

("RPDIS"). See Section 7.1.3 of the Emergency Plan. The ERIS and RPDIS systems are described in Sections 7.3.1 and 7.3.2, respectively. The on-site meteorological measurements program will provide data as inputs for these systems. The meteorological program is described in Section 7.3.7.

4. The licensee shall use the Applicants will use EOF to coordinate its emer- the EOF to coordinate ,

gency response activities its emergency response j with those of the local, activities with those 1

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State, and Federal agencies, of the local, State including the MRC. Licensee and Federal agencies, personnel in the EOF will including the NRC.

assess potential offsite See Sections 5.2.4 and effects and make appropriate 7.1.3 of the Emergency protective action recom- Plan. Licensee personnel mendations for the public in the EOF will assess to State and local emergency potential offsite effects response agencies. The EOF and make appropriate may be used as a location protective action recom-for information dissemina- mendations for the tion to the public via the public to State and local news media by designated emergency response agencies.

spokespersons in accordance See Section 5.2.4. The with the licensee's emer- EOF will not be used as gency plan. The licensee the location for infor-also may use the EOF as mation dissemination to the post-accident recovery the public via the news management center. Since media. Applicants the specific allocation of will use the EOF as the functions assigned to emer- post-accident recovery gency facilities will differ management center. -

from design to design, the Functions assigned to proposal should clearly the EOF and EOF staff state which functions by Applicants appear ,

(Radiological Assessment, in Sections 7.1.3 and Security, Coordination 5.2.4., resp ;ctively.

with Offsite Agencies) are assigned to the EOF.

. 5.2 Location, Structure and Habitability

1. The siting of the EOF should include the following criteria:

a. Whether the location The following are among facilitates carrying the ways in which the EOF out the functions location facilitates specified for the EOF carrying out the functions (i.e., determination specified in Sections of public protective 5.2.4 and 7.1.3 of the actions to be recom- Emergency Plan: the mended by the licensee facility is located to offsite officials, sufficiently close to and coordination of the PNPP to permit secure, licensee with Federal, direct data link State, and local connections for ERIS organizations). and RPDIS displays between Describe the transpor- the plant computers and tation network in the the computer terminals at i

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vicinity of the EOF the EOF; the location of adequate to assure the EOF adjacent to the rapid coverage of the PNPP training facility EPZ by monitoring teams. facilitates emergency preparedness training; the location of the EOF close to PNPP allows use of the plant site emergency communica-tions systems at the EOF. The transporta-tion network around PNPP is described in the evacuation time estimate study prepared for Applicants by PRC Voorhees and presented as Appendix D of the Emergency Plan.

Is the EOF placed in a The EOF is located about location that is readily one-half mile from Route accessible by road to 20, a major east-west Federal, State, local route crossing the plume government officials as exposure pathway EPZ.

well as the licensee's Thus, it is easily corporate and sit.e accessible by road.

operations personnel?

Has the selection of the No, the selection of EOF location been co- the EOF location has ordinated with State / not been coordinated local officials? with State or local officials. State and local officials are aware, however, of the EOF location.

b. What radiation doses A Loss of Coolant Accident would be expected when ("LOCA") which results the EOF is accessed from a spectrum of during DBA or other postulated piping breaks specified accident within the reactor coolant (less than or equal pressure boundary is one to 5 rem)? example of a DBA. The calculated radiological I exposures for this event are presented in Table 15.6-18 -# the i PNPP FSAR. A 5 shown there, the ext tres at the exclusion .ea l

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boundary constitute only a small fraction of the limits set by 10 C.F.R., Part 100. The EOF is located near enough to the exclusion area boundary (about 600 meters from the center of the Control Complex compared to 863 meters for the exclu-sion area boundary) that exposures at these distances can be considered roughly equivalent. Further, the exposures presented in Table 15.6-18 are calculated for the duration of the postulated accident.

Thus, exposures during accessing of the EOF would constitute only a fraction of those doses.

Is the EOF accessible Since the releases resulting during periods of from a LOCA at PNPP will radiation releases? not exceed the 10 C.F.R.,

Part 100 limits for the exclusion area bound-ary, and since the EOF is located near the exclusion area bound-ary, the EOF will be accessible during predicted radiological releases for this DBA.

If for any reason the EOF were not accessi-ble, there is an alternate EOF.

Is there an alternate The alternate EOF is EOF? located at CEI's Concord Service Center.

2. The EOF must be able to The EOF is located in withstand reasonable an area which would not expected adverse conditions be inundated with water (e.g., 100 year floods and in a 100 year flood.

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high winds). Further, the EOF is designed to withstand How would the 100-year water 35 PSF (positive) and levels and winds affect the -31 PSF (negative) operation of the EOF? on the walls, and -62 PSF (negative) at the corners. These specifications are roughly equivalent to a wind speed of 100 mph. Thus, the EOF will be able to with-stand reasonable, expected, adverse conditions.

3. The EOF chall have a pro- Since the EOF is located tection factor greater than within 10 miles of the or equal to five if located TSC, the EOF portion of within 10 miles of TSC; no the Training Facility is protection level is neces- designed to provide a sary if located beyond 10 protection factor of miles cf the TSC. Protec- greater than or equal tion factor is defined in to 5 for .7 MeV gamma terms of the attenuation radiation. See Section of 0.7 MeV gamma radiation. 7.1.3 of the Emergency Plan.

4. The EOF ventilation system The EOF will have an shall be functionally isolable, high-efficiency comparable to the control particulate air filtered room system and TSC (i.e., ("HEPA") ventilation system high efficiency particulate which will function in a air filter; no charcoal) if manner comparable to the located within 10 miles of Control Room ventilation TSC. If located beyond 10 system.

miles from the TSC, the EOF needs no ventilation protection.

To what level will the The HEPA filters will be HEPA filters reduce 99.97 per cent efficient particulate levels? on particles of .03 microns in size. (ANSI standards N509/510 were used as guidance.)

Is the HVAC system con- The HVAC system will be trolled to permit isolation controlled to permit of the intake? isolation of the intake.

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At what level of airborne Isolation of the system activity is isolation per- will occur at about the formed? 1 mpc level of Cesium 137, Strontium 90, Iodine 131 or Xenon 133.

How is the level determined? This threshold will be set based on the air flow and the sensitivity of the equipment in counts per microcurie. A particulate, iodine and noble gas radiation monitor with sensors in the supply duct will distinguish radio-iodines at quantities as low as 10-7 microcuries/cc.

Where are the sensors Sensors for the airborne located? monitor will tap off the common air supply discharge.

Where is this level Local indication will be monitored? available in the vicinity of the mechanical equipment room. The area monitor indication will be in the display room.

5. Protective clothing, res- Protective clothing, piratory equipment and po- respiratory equipment tassium iodide shall be and potassium iodide readily available to all will be available for EOF personnel. EOF personnel and Radiation Monitoring Team members operating out of the EOF. It is not yet determined whether all personnel will be supplied with such clothing and equipment. All personnel will be supplied with potassium iodide.

If not, how many people The exact number of people would be supplied? to be supplied with protective clothing and respira-tory equipment has not ,

yet been determined. 1 l

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Are reserves of supplies Reserves of supplies will available? be available.

Where are they located? Reserves will be located in various storage areas inside the plant.

How is the need for these Health Physics Instructions, supplies determined? (i.e., still in the draft stages, when will respiratory will describe when and equipment be used?) how to use these supplies.

Is the protection factor The protection factor for for respiratory equipment respiratory equipment will equivalent to full face be equivalent to a full mask? face mask.

Are instructions for KI use Instructions for KI use provided in the EOF? will be provided in the EOF.

45. Where will the Emergency Operations Facility be located (on-site or off-site)? If on-site, explain why, since NUREG-0696 at p. 16 clearly states that the EOF is to be an off-site support center.

Response

The EOF is located about one-half mile from the Control Complex along the PNPP site access road. The EOF is located outside of the site-protected area. Applicants understand NUREG-0696 at p. 16 to state that the EOF is to be a support center for off-site activities, not that the EOF itself must be located off-site.

46. Describe and give the exact location of the alternate (backup) EOF, the Concord Service Center (FSAR, Appendix 13A, Sec. 7.1.3).

Response

The CEI Concord Service Center is located at 7755 Auburn Road in Concord Township. This facility is about 10.8 miles SSW of PNPP.

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47. For both the main and backup EOFs, describe any normal, non-emergency activities occurring there. Do these activities enhance or detract from emergency preparedness? Are unauthorized persons excluded from the EOF during normal conditions? Define the term " unauthorized person."

Response

The EOF is part of a larger CEI facility called the Training Facility. During working hours, the Training Facility will be in constant use by Applicants' personnel. The EOF itself will normally be used by Applicants' personnel for emergency preparedness training as well as for drills and exercises.

The EOF will have doors separating it from the rest of the Training Facility. Those doors will not normally be locked during working hours. However, since the Training Facility will be owned and controlled by Applicants, persons not wearing CEI or approved visitor badges would be subject to question if they entered the facility. After working hours, the Training Facility will be locked. Further security precautions cannot be revealed without jeopardizing their effectiveness.

The backup EOF, the CEI Concord Service Center, will normally Le used for office and conference space. When either the EOF or backup EOF is activated during an emergency, routine activities will be immediately discontinued; non-emergency personnel will be asked to leave; and a security guard will be posted. Hence, normal activities will not intarfere with l emergency preparedness at PNPP.

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75. Will emergencies of various classifications be declared whenever the Emergency Action Levels indicate that such declarations are in order? Or does the Shift Supervisor / Emergency Duty Officer have the discretion not to declare an emergency even though it is indicated by the applicable EAL? What other criteria will be used by the Shift Supervisor /EDO to classify or declare an emergency?

Response

The Emergency Planning Instruction on Emergency Classification is the guidance which the Shift Supervisor will use to classify plant emergencies. The instruction will direct the Shift Supervisor to declare an emergency of the appropriate level when he has valid indication that an EAL has been exceeded. The Shift Supervisor's discretion also will be outlined in the instruction. If the Shift Supervisor deter-mines that plant conditions are degrading rapidly, he may declare an emergency level earlier than would be indicated by the instruction. However, unless he can verify that the instrumentation is faulty, the SSift Supervisor may not declare an emergency level later than would be indicated. The Emergency Planning Instruction still is in the draft stages.

85. Would local police officers / departments ever be called on-site to aid PNPP security during any security threat at the plant? If so, have any letters of agreement been signed with local police departments? Describe any security threat scenarios that would result in radiation exposure to off-site police personnel called on-site. Have local police departments received env training or equipment for situations involving radiation tposure?

Response

As stated in Applicants' Answer at 17, Applicants will not answer any portion of the Interrogatory directed at Applicants' security plans.

Arrangements with local police are set forth in Sheriff Edwin Cunningham's letter to PNPP Plant Manager John Waldron, which appears in Appendix B of the Emergency Plan. All other information on police response appears in the PNPP security plan.

The State of Ohio Disaster Service Agency ("ODSA") is required under the State of Ohio Nuclear Power Plant Emergency Response Plan to provide radiological emergency response training to offsite emergency workers. See Section II, Part N of the State Plan. The ODSA training for the PNPP offsite emergency workers began on October 4, 1982 with the City of-Eastlake. The ODSA will provide radiological monitoring equipment to emergency response agencies through the respective County DSAs.

86. Has the Applicant (or anyone on behalf of or to the knowledge of the Applicant) conducted any studies on protective 4

actions other than evacuation for the general public?

Specifically, are there any estimates or analyses of the time required to effectuate sheltering or thyroid prophylaxis?

(Also for Counties?)

Response

The following are studies on the subject of protective actions for the general public other than evacuation of which Applicants have knowledge:

1. D. Aldrich and R. Blond, " Examination of the Use of Potassium Iodide (KI) as an Emergency Protective Measure for Nuclear Reactor Accidents," Nuclear Regulatory Commission, Office of Nuclear Regulatory Research, Rept.

No. SAND-80-0981 (October, 1980).

2. D. Aldrich and R. Blond, " Radiation Protection:

An Analysis of Thyroid Blocking," Nuclear Regulatory Commission, Div. of Systems and Reliability Research, Rept. No. CONF-801056-3; 1AEA-CN-39/102 (October, 1980).

3. G. Anno and M. Dora, " Protective' Action Evaluation, Part I: The Effectiveness of Sheltering as a Protective Action Against Nuclear Accidents Involving Gaseous Releases," Rept. No. EPA-520/1-78-001A (April, 1978).

4. G. Anno and M. Dora, " Protective Action Evaluation, Part II: Evacuation and Sheltering as Protective Actions Against Nuclear Accidents Involving Gaseous Releases," Rept. No. EPA-520/1-78-00.1B (April, 1978).

5. R. Finck, et al., " Implications and Procedures at Large Release of Radioactive Matter From the Swedish Nuclear Power Stations During State of Emergency and War,"

in Swedish (February, 1980).

6. International Atomic Energy Agency, " Planning for Off-Site Response to Radiation Accidents in Nuclear Facilities," (Vienna, Austria) (1979).

7. D. Moeller, Second semi-annual report on the project, " Planning for Nuclear Emergencies," being conducted under contract to Office of Nuclear Regulatory Research, Nuclear Regulatory Commission, directed to Dr.

J. Foulke, ONRR (June 1, 1982).

88. Describe in detail any independent monitoring for radiation around the PNPP site. (Independent monitoring here means monitoring by a governmental or private entity that is not an agent of the Applicant.) Include the type of monitors to be used, both mobile and stationary and detection /manufac-turer type, manner and frequency of reading / analysis, avail-ability of instantaneous data, type of data link with the responsible agency, name and affiliation of responsible agency, type of meteorological monitors / data input, of [ sic) any, means of calculating projected doses, and the source of funding of the responsible agency.

Response

ODSA will organize and direct independent radiation monitoring teams as described in the State of Ohio Nuclear Power Plant Emergency Response Plan, Parts II-G, II-H and II-I.

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The equipment which the State of Ohio Emergency Response Teams will bring to the plant site is described in Part II-G of the State Plan. Part II-I outlines the State's communications links, including the radio frequency used by survey teams.

Meteorological data for the State of Ohio accident assessment function will be transmitted by PNPP to the State of Ohio DSA/EOC in Worthington, Ohio at 15 minute intervals. ODSA, the Ohio Department of Health and the Ohio EPA are all funded by the State of Ohio. The dose assessment method of the State of Ohio is set forth on p. II-H-4 of the State Plan.

Respectfully submitted, SHAW, PITTMAN, POTTSJ& TROWBRIDGE

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By: W // j df4 Jay Silberg, P.C. ff Robe,E.

rt L. Willmore '/

./ I Counsel for Applicants 1800 M' Street, N.W.

Washington, D.C. 20036 (202) 822-1000 Dated: October 20, 1982.

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THE CLEVELAND ELECTRIC ILLUMINATING COMPANY CLEVELAND, OHIO AFFIDAVIT Rebecca 3. Coff ey, being duly sworn according to law, deposes and says that she is Associate Environmentalist, Licensing and Permite Section, The Cleveland Electric Illuminating Company, and that the f acts set forth in the foregoing Applicants' Answer to Sunflower Alliance Inc., el al. Second Set of Interrogatories

1. 44 through 47, 75, 85, 86, & 88, dated April 30, 1982, are true and correct to the best of her knowledge, information and belief.

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Subscribed and sworn before me this 15th day of October,1982.

hotady Public [O JOSEPH C. $ZWEJK0W5KI Netary Pci:, S*.ste et Ohio - Ceya Cty My Cw.nttssion Exprs: Jaly 14, 1985 i

October 20, 1982 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION o

Before the Atomic Safety and Licensing Board In the Matter of )

)

THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY ) 50-441

)

(Perry Nuclear Power Plant, )

Units 1 and 2) )

CERTIFICATE OF SERVICE This is to certify that copies of the foregoing " Applicants'

, Supplemental Answers to Sunflower Alliance, Inc. et al. Second Set of Interrogatories to Applicants" were served by deposit in the United States Mail, First Class, postage prepaid, this 20th day of October, 1982, to all those on the attached Service List.

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JAY ,E. SILBERG DATED: October 20, 1982 [/ / /'

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UNITED STATES OF' AMERICA NUCLEAR. REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of *

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THE CLEVELAND ELECTRIC. ) .Do'cket Nos. 50-440 ILLUMINATING COMPANY . ) -

50-441

)

(Perry Nuclear Power Plant, ) ,

Units 1 and 2) )

SERVICE LIST l

Peter B. Bloch, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Appeal Board Panel

U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Jerry R. Kline Docketing and. Service Section Atomic Safety and Licensing Board Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Mr. Frederick J. Shon James M. Cutchin, IV, Esquire Atomic Safety and Licensing Board Office of the Executive U.S. Nuclear Regulatory Commission Legal Director Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Christine N. Kohl, Chairman

Atomic Safety and Licensing Ms. Sue Hiatt

! Appeal Board OCRE Interim Representative i U.S. Nuclear Regulatory Commission 8275 Munson Avenue Washington, D.C. 20555 Mentor, Ohio 44060 Dr. John H. Buck Daniel D. Wilt, Esquire Atomic Safety and Licensing Post Office Box 08159 Appeal Board Cleveland, Ohio 44108 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Donald T. Ezzone, Esquire

. Assistant Prosecuting Attorney

}' Gary J. Edles, Esquire Lake County Administration Center Atomic Safety and Licensing 105 Center Street Appeal Board Painesville, Ohio 44077 U.S. Nuclear Regulatory Commission ,

Washington, D.C. 20'$3 John G. Cardinal, Esquire  !

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Prosecuting Attorney Atomic Safety and Licensing Ashtabula County Courthouse ,

Board Panel e Jefferson, Ohio 44047 U.S. Nuclear Regulatory Commission

Washington, D.C. 20555 Terry Lodge, Esquire l 915 Spitzer Building i Toledo, Ohio 43604 I. _

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