IR 05000430/2005001
| ML20133C923 | |
| Person / Time | |
|---|---|
| Site: | Vogtle, 05000430  |
| Issue date: | 07/29/1985 |
| From: | Novak T Office of Nuclear Reactor Regulation |
| To: | Foster D GEORGIA POWER CO. |
| References | |
| NUDOCS 8508070180 | |
| Download: ML20133C923 (72) | |
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July 29, 1985
, DISTRIBUTION: _ . _ .
- Uocket Nosr 502424/475 5 % .
l NRC PDR
! Docket Nos: 50-424 local PDR and 50-425 PRC System
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EAdensam L MDuncan Mr. Donald MMiller
- Vice President and Project General Manager Attorney, OELD l
Georgia Power Company JPartlow Rt. 2, Box 299A 8 Grimes Waynesboro, Georgia 30830 Edordan ACRS (16)
Dear Mr. Foster:
i Subject: Transmittal of Draft Safety Evaluation on Vogtle l Emergency Preparedness Enclosure 1 contains the staff's safety evaluation of the Vogtle Emergency Plan l
through May 15, 1985. Most of the items discussed in the evaluation were i discussed with your staff in an April 30-May 1,1985, site visit. However, some l items in the evaluation were identified by the staff following this meeting.
Those specific items are outlined in Enclosure 2. Your staff should incorporate those items in Enclosure 2 into the Emergency Plan. We are presently reviewing
! your latest submittal revising the Vogtle Emergency Plan dated May 17, 1985.
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If there are any questions or if you wish to discuss the staff's comments, con-tact the Project Manager, Melanie Miller, at (301) 492-4259.
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Sincerely,
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- hia:1 Sigra:1 Cy l Items M. Navak Thomas M. Novak, Assistant Director for licensing Division of licensing i Enclosures:
! As stated cc: See next page i
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T vak L
MM r/hmc MDddcan 7 85 7/f(/85 7/3/85 7/$85 9 I 8508070180 hDR ADOCK 05008507h424 PDR
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Mr. Donald Foster Georgia Power Company Vogtle Electric Generating Plant cc:
Mr. L. T. Gucwa Resident Inspector Chief Nuclear Engineer Nuclear Regulatory Commission Georgia Power Company P. O. Box 572 P.O. Box 4545 Waynesboro, Georgia 30830 Atlanta, Georgia 30302 Mr. Ruble A. Thomas Deppish Kirkland, III, Counsel Vice President - Licensing Office of the Consumers' Utility Vogtle Project Council Georgia Power Company / Suite 225 Southern Company Services, Inc. 32 Peachtree Street, N.W.
P.O. Box 2625 Atlanta, Georgia 30303 Birmingham, Alabama 35202 James E. Joiner Mr. R. E. Conway Troutman, Sanders, Lockerman, Senior Vice President - Nuclear & Ashmore Power Candler Building Georgia Power Company 127 Peachtree Street, N.E.
P.O. Box 4545 Atlanta, Georgia 30303 Atlanta, Georgia 30302 Douglas C. Teper Mr. J. A. Bailey Georgians Against Nuclear Energy Project Licensing Manager 1253 Lenox Circle Southern Company Services, Inc. Atlanta, Georgia 30306 P.O. Box 2625.
Birmingham, Alabama 35202 Laurie Fowler, Esq.
218 Flora Avenue, N.W.
Ernest L. Blake, Jr. Atlanta, Georgia 30307 Bruce W. Churchill, Esq.
Shaw, Pittman, Potts and Trowbridge 1800 M Street, N.W.
Washington, D. C. 20036 Tim Johnson Mr. G. Bockhold, Jr. Executive Director Vogtle Plant Manager Educational Campaign for Georgia Power Company 'a Prosperous Georgia Route 2, Box 299-A 175 Trinity Avenue, S.W.
Waynesboro, Georgia 30830 Atlanta, Georgia 30303 Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta Street, N.W., Suite 2900 Atlanta, Georgia 30323
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Enclosure 1
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18.3 Emergency Preparedness Evaluation 13.3.1 Introduction
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The Georgia Power Company filed with the NRC Revision 0 to the Emergency Plan for the Vogtle Electric Generating Plant (VEGP) dated November 30, 1984.
Previously, the staff had reviewed and commented on an earlier version of this emergency plan. Also Georgia Power Company provided a description of the VEGP
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Display System. The acceptance criteria used as a basis for the staff's review
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of the VEGP Emergency Plan are specified in Section 13.3, " Emergency Planning,"
of the Standard Review Plan, NUREG-0800, dated July 1981 and include the planning standards bf 10 CFR 50.47(b), the requirements of Appendix E to 10 CFR 50 and the specific criteria of NUREG-0654/ FEMA-REP-1, Revision 1, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," dated November 1980. The criteria of NUREG-0654 have been endorsed in Regulatory Guide 1.101, Revision 2. " Emergency Planning and Preparedness for Nuclear Power Reactors," dated October 1981 and thus have the same status as a regulatory guide.
Evaluation of the state of emergency preparedness for VEGP also involves the review of State and local radiological emergency response plans by the Federal Emergency Management Agency (FEMA). The Standard Review Plan states that the FEMA findings on offsite plans are reviewed by the NRC and a full-scale exer-cise is to be conducted at the facility. In accordance with the revised rule
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-2-on emergency planning (47 I]t 30232), no NRC or FEMA findings and determinations concerning the state or adequacy of offsite emergency preparedness are required before issuance of an operating license authorizing only fuel loading and low-power operations up to 5% of rated power. The findings and determinations
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of FEMA on the adequacy of the State and local emergency response plans and the
! overall conclusion of the NRC on the state of- emergency preparedness for VEGP
4 will be presented in-a future supplement to the SER.
i Section 13.3.2 of this report lists each planning standard of 10 CFR 50.47(b)
., followed by an evaluation of the applicable portions of the VEGP Emergency Plan
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that principally relate to that particular standard. Section 13.3.3 of this report provides the staff's conclusions.
13.3.2 Evaluation of the Emergency Plan 13.3.2.1 Assignnent of Responsibility (Organization Control)
Standard Primary responsibilities for emergency response by the nuclear facility licensee and by the State and local organizations within the Emergency Planning Zones (EPZs) have been assigned, the emergency responsibilities of the various
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supporting organizations have been specifically established, and each principal i
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-3-response organization has staff to respond and to augment its initial response on a continuous basis.
Emergency Plan Evaluation
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In the event of an accident at VEGP, the app 1icant's staff is responsible for _
recognizing and declaring an emergency condition, classifying the event, notifying and activating the onsite organization, notifying offsite authori-ties, taking corrective actions to mitigate accident consequences, requesting
-- additional support 'if needed, establishing and maintaining effective comuni-cations with onsite and offsite organizations, taking protective actions onsite, recomending protective actions offsite, monitoring and controlling radiation exposures of applicant personnel and providing public information on the event in conjunction with State and local authorities. The applicant's emergency response is carried out under the control of the Emergency Director.
Initially the onshift operations supervisor assumes the position of Emergency Director until properly relieved by a more senior VEGP manager or the VEGP General Manager or the Vice President, Nuclear Operations from the applicant's headquarters.
The VEGP is located in Burke County, Georgia near the Savannah River across from the Savannah River Plant (SRP) on the South Carolina side of the river.
The SRP is operated by the U.S. Department of Energy (D0E) and covers almost
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the entire area within a ten mile radius of VEGP that extends into South Carolina.
Therefore the DOE is responsible for the offsite emergency response within the plume exposure pathway EPZ and the State of South Carollr.: is only responsible for emergency response for actions needed in the ingestion pathway EPZ. This
^- agreement is based on the fact that the areas outside the SRP site are eight to
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ten miles in distance from VEGP and the fact ,that there are essentially no residents within these areas. Appendix 11 of the VEGP Emergency Plan contains a letter of agreement between the Emergency Preparedness Division, Military Department of the State of South Carolina and the applicant regarding this
. arrangement and sta'tes that the State of Georgia will notify them of an emergency at VEGP. However, the VEGP Emergency Plan does not indicate the manner in which the notification will be made, what actions South Carolina proposes to take under these conditions and there is no documentation from the State of Georgia that they intend to provide this notification.
Since the SRP consists of land owned or leased by the Federal government, the DOE is responsible for the direction and control of all emergency response actions within the SRP site. By memorandum of agreement between DOE and the applicant it is agreed that they will provide a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> point of contact with each other, maintain lines of communication and will promptly notify each other of emergencies as well as exchange meteorological and radiological information.
In the event of an emergency at VEGP, the DOE will promptly notify all
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-5-personnel at the SRP within the plume exposure pathway EPZ, assess the radio-logical hazards within the SRP and implement any protective actions decided upon to protect the health and safety of individuals within the site. SRP will also provide radiological monitoring and assessment to South Carolina on
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request. A copy of this agreement memorandum is provided in Appendix 5 of the VEGP Emergency Plan. ,
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The plume exposure pathway EPZ within the State of Georgia is located inside the boundaries of Burke County. A small area (two square miles) of Richmond County
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is located between hine and ten miles from VEGP, but is excluded from the EPZ i
because it is an uninhabited wetlands area. A letter from the Georgia Emergency Managenent Agency (GEMA) included in Appendix 11 of the VEGP Emergency Plan states that this area is to be excluded.
The Georgia Department of Natural Resources (DNR) is the lead agency in re-sponding to peacetine radiological emergencies within the state. DNR is responsible for assessing radiological conditions, providing radiation control, personnel, equipment, technical expertise and advising the Governor on whether an emergency exists. Upon being advised of a radiological emergency, the Governor activates GEMA which is an agency within the Georgia Department of Defense. GEMA is responsible for overall control and coordination of disasters and automatically activates eight other Georgia State agencies that support the emergency effort through its GEMA Emergency Operations Center. The principal
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support agencies include: the Georgia Department of Human Resources which provides radiation monitoring teams and radiological health expertise; the Georgia Department of Defense, with broad legal, authority to protect the health and safety of the public, which provides emergency comunications, radiological
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monitoring assistance, public warning and evacuation procedures, area security and control assistance an'd transportation; and the Georgia Department of Public Safety which provides comunications, transportation and law enforcement
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functions.
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- The Georgia Department of Defense will establish a State Emergency Operations
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Center or establish a mobile Emergency Operations Center to maintain a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> radio net, commercial telephone, National Warning System, National Comunications, teletype and other comunications systems. However, the VEGP Emergency Plan does not describe how the mobile center is used, when it is established or where it is to be located in the event of an accident at VEGP. DNR provides a state
- radiation emergency coordinator to interact with the appropriate State, local and Federal agencies as well as private organizations to direct necessary radiation control actions, but it is unclear as to whether this capability exists 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> i per day, where this individual is located during emergencies and how he assesses the radiological conditions at VEGP and directs the DNR functions. It is also unclear how the DNR and GEMA coordinate and direct their key emergency functions as described in the VEGP Emergency Plan.
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i-7-Within Burke County, the Chairman of the Board of Comissioners has the overall responsibility to provide radiological emergency response planning, initiating actions and providing direction control to county agencies. The Burke County
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Emergency Management Agency and the Sheriff's Department have the major role in
. .. responding to accidents at VEGP. The Burke County Emergency Management Agency is responsible for receiving emergency notifications from VEGP and GEMA as well i
as maintaining comunications with them, activating the public notification
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l system, coordinating the Burke County radiological emergency response, activat-ing and directing offsite reception centers and providing information to the
, public and the media. The Burke County Sheriff's Office is responsible for d
j providing traffic control and access control within the plume exposure pathway EPZ, backup and ancillary public notification capability and is the alternate for notification from VEGP and GEMA. The VEGP Emergency Plan states that the emergency notification comunications with Burke County Emergency Management Agency are manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. However, it is unclear whether the Emer-gency Management Agency or the Sheriff's Office has the authority to alert the public without conferring with the Chairman of the Burke County Board of Comissioners and the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> availability of this authority in emergencies is not provided.
Agreements for medical support to VEGP with the Burke County Ambulance Service, the Burke County Hospital in Waynesboro, Georgia, the Humana Hospital in Augusta, Georgia, the Radiation Management Corporation and with six physicians
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in the Waynesboro - Augusta area are provided in Appendix 2 of the VEGP Emer-gency Plan. In addition, an agreement to provide fire fighting assistance with the Waynesboro Fire Department is provided. Arrangements have been made for engineering, technical and administrative support with the Westinghouse Elec-
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tric Corporation and.the Bechtel Power Corporation. The DOE has agreed to r
provide radiological assessment support and VEGP is a member of the Nuclear
, Power Plant Voluntary Assistance Group sponsored by the Institute of Nuclear
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l Power Operations.
The following items' require resolution:
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(1) Additional information should be provided on what the State of South l Carolina intends to do when notified of an emergency at VEGP, the manner l in which the State of Georgia intends to notify South Carolina, the time required to make th'e notification and documentation from the State of Georgia confirming that this notification will be made.
l (2) Additional information should be provided on the purpose of the Georgia l State mobile Emergency Operations Center, how it functions and where and when it will be established during an emergency at VEGP.
(3) Additional information should be provided on the DNR State Emergency Coordinator with regard to his functions, location and 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> availabili-
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ty, the methods DNR will use to assess accident conditions at VEGP to
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'e-9-determine if an emergency should be declared, how DNR advises the Governor I
of Georgia to make such a declaration and clarification of the manner in which DNR and GEMA coordinate their activities and responsibilities during an emergency.
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l (4) Addition information should be provided on the authority within Burke County
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to notify the public with regard to an emergency at VEGP and to implement I protective action reconinendations, as well as the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> availability of l
this authority, f
-_} ~i 13.3.2.2 Onsite Emergency Organization Standard I
l l_ On-shift facility licensee responsibilities for emergency responses are unam-biguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmenta-tion of response capabilities is available, and the interfaces among various l onsite activities and offsite support and response activities are specified.
Emergency' Plan Evaluation
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When an emergency or incident occurs, the initial onsite staffing of the VEGP emergency organization will be provided from personnel normally employed at the site. If needed personnel from other Georgia Power Company organizations
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-10-(company headquarters, Hatch Nuclear Plant) as well personnel from other contract or agreement organizations will augment this staff. Initially the on-shift operations supervisor or the shift supervisor, if the on-shift opera-tions supervisor is not immediately available, will fill the position of
- 1 Emergency Director and has the authority and is responsible for overall direc-H tion of the VEGP emergency organization. This individual remains the Emergency
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Director until a more senior member of the VEGP or Georgia Power Company
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management arrives at the site and assumes this responsibility. An on-shift
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emergency organization is established and emergency assignments for the normal operating crew have' been made. The relationship between the emergency organ-
- ization and the shift complement is illustrated in Tables B-1 and B-2 as well as Figures B-1, B-2, B-3 and B-4 of the VEGP Emergency Plan. The positions and/or titles and major tasks and responsibilities for all key personnel in the emergency organization are specified, including the responsibilities that may not be delegated by the Emergency Director. The position of Support Coordina-tor, who initially reports to the Technical Support Center (TSC) and then moves to the Emergency Operations Facility (E0F) when it is activated, is defined under the staff of both facilities. The position descriptions are not identi-cal and it is unclear whether this is the same position or two different positions.
The applicant's concept of shift augmentation generally adheres to the guidance provided in Table 2 of Supplement 1 to NUREG-0737. There is no 30 minute
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i-11-augmentation goal since all of the staffing for the normal shift complement and the 30 minute augmentation are filled by the on-shift operating crew.
Table B-2 of the VEGP Emergency Plan indicates that the position of Emergency s - Director will be filled by the VEGP General Manager or the Vice President,
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Nuclear Operations with a list of five alternates and provides a footnote
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stating that the most senior member of VEGP or Georgia Power Company, who is
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qualified, may assume this position upon arrival at the site. In the descrip-tion of the Emergency Director position in Section B of the plan it states that the on-shift operations supervisor will fill the position until a more senior M_ member of VEGP or Georgia Power Company management arrives onsite and assumes the position. It appears that a large number of individuals may assume this essential, key position and the method to determine their qualifications is not provided. In addition, there is nothing in the VEGP Emergency Plan that describes the method to be used in transferring this position from one individual to another, including whether the individual will be briefed, the details of the briefing and the procedures to be followed.
The interfaces among the functional areas of the onsite emergency organization and between the onsite and offsite support organizations are provided. The
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Georgia Power Company Corporate Emergency Plan is provided in Appendix 7 and the written agreements by support organizations to provide for ambulance,
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-12-medical, law-enforcement, technical, engineering and fire-fighting assistance are identified and copies of these agreements are appended to the plan.
The following items require resolution:
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(1) The qualifications required by all individuals to assume the position of Emergency Director should be provided and a complete list of those indi-
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viduals with their normal job description and title who will be permitted to assume this key position.
(2) The method and procedures to be used to transfer the position of Emergency Director from one individual to another should be described.
(3) The position of Support Coordinator in the TSC and E0F should be clarified.
13.3.2.3 Emergency Response Support and Resources Standard Arrangements for requesting and effectively using assistance resources have been made, arrangements to accomodate State and local staff at the licensee's near-site E0F have been made, and other organizations capable of augmenting the planned response have been identified.
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Emergency Plan Evaluation The VEGP Emergency Plan identifies the Federal, State and local government organizations, private organizations and local support groups and individuals
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that can be relied on for assistance in an emergency. Letters of agreement
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documenting the availability of assistance are provided in Appendix 2 to the
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plan from the following:
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(1) Board of Commissioners of Burke County (ambulance services)
(2) Burke County Sheriff's Department (3) City of Waynesboro (fire-fighting assistance)
(4) Radiation Management Corporation (medical consulting and training)
(5) Humana Hosptial (6) Ralph W. Buchanan, M.D.
(7) A. F. Garrison, M.D.
(8) Plastic Reconstructive and Cosmetic Associates (medical services)
(9) Burke County Hospital (10) Medical Specialists, Inc.
(11) Department of Energy, Savannah River Operations Office (12) Westinghouse Electric Corporation (13) Bechtel Power Corporation
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-14-The Georgia Power Company has entered into the Nuclear Power Plant Emergency Response Voluntary Assistance Agreement sponsored by the Institute of Nuclear Power Operations a copy of which is provided as Appendix B of the Corporate Emergency Plan appended to the VEGP Emergency Plan as Appendix 7. In addition,
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Georgia Power Company has contracts for radiochemical laboratory assistance with Teledyne Isotopes and the University of_ Georgia. Engineering, health physics and general emergency support are available from the Southern Company
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Services, Inc. and the Alabama Power Company.
-. Federal assistance 'is available from DOE, NRC, the Federal Emergency Management Agency (FEMA) and the Environmental Protection Agency. The plan lists all the airports within a 35 mile straight line distance from VEGP along with the road mileage to VEGP from each airport and the direction of the airport from the plant. However, the plan does not specify the communications and other local resources available to support the Federal response. Anticipated arrival times for DOE, NRC and FEMA assistance are provided.
Provisions are made to accommodate representatives from FEMA, NRC as well as the State of Georgia in the VEGP E0F. In addition, space for NRC representa-tives is available in the TSC. Georgia Power Company will send technical representatives to offsite governmental centers as required or requested.
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I-15-tbsite laboratory facilities are provided for radioactive sample analysis and a post-accident sampling system (PASS) is available to take reactor coolant and containment sump liquid samples as well as containment atmospheric samples for chemical and radiochemical analyses. The PASS system also can be used to
. obtain grab samples for laboratory analysis. A laboratory located in the training center which also houses the E0F is also available for analysis of
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environmental media. The two laboratories and the PASS are equipped with
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solid-state gamma spectrometers. Backup facilities for VEGP will be provided by the Hatch Nuclear Plant. .Further information is needed on the capabilities of these laboratories and the PASS as well as the capabilities of the laborato-ry assistance to be provided by Teledyne Isotopes, Inc. and the University of Georgia.
The following items require resolution:
(1) The plan should specify the local communications and other local resources available to support the Federal response.
(2) Clarification and additional information should be provided in the plan for the capabilities and equipment of the onsite laboratories, support laboratories and the PASS.
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-16-13.3.2.4 Emergency Classification System Standard
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A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear
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facility licensee, and State and local response plans call for reliance on
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information provided by facility licensees for determination of minimum re-sponse measures.
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Emergency Plan Evaluatior
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The emergency classification and action level scheme uses a symptomatic analysis of plant conditions and the integrity of fission product barriers combined with the presence of certain initiating conditions. A preliminary evaluation of this scheme indicates that the classification of certain events as described in the guidance in NUREG-0654, Appendix 1 would not be properly classified. The applicant is reevaluating this emergency classification and action level scheme and a final evaluation will be provided in a supplement to the SER.
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i-17-13.3.2.5 Notification Methods and Procedures Standard s.. .
Procedures have been established for notification, by the licensee, of State and local response organizations and for notification of emergency personnel by
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all response organizations; the content of initial and followup messages to
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response organizations and the public has been established; and means to provide early notification and clear instructions to the populece within the
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Emergency Plan Evaluation Procedures are established for notifying onsite and offsite emergency person-nel, Federal, State and local government response organizations. The Emergency Director is responsible for classifying an event and notifying onsite personnel through the plant public address system and the use of tone signals. There is a separate signal for an Alert, Site Area Emergency and General Emergency as well as a fire followed by announcements on the public address system. Notifi-cation of an Unusual Event will be announced on the public address system without a tone signal. The plant operations duty officer, on duty 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, is responsible for notifying plant management, thN corporate duty offices and the Hatch Nuclear Plant duty officer. Selected plant management also can
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-18-be notified by a beeper system. The Emergency Director is responsible for notifying the shift supervisor of the VEGP Security Department who will acti-vate the tone signal. The Security Department is also responsible for notify-ing all visitors, the visitor's center and the VEGP Recreational Park, Plant
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Wilson and any other individuals located within the VEGP site boundary. Backup onsite communications are provided by plant radio services. During normal working hours, VEGP management will assemble the emergency staff in the VEGP ERFs. During the backshift, the plant operations duty officer is responsible for notifying plant emergency personnel using a call fanout system; although s this fanout system 1s not described in the VEGP Emergency Plan. The Security Department is responsible for evacuating all visitors and nonessential personnel from the site, the visitor's center, the recreational park and Plant Wilson.
Visitors will receive training in the required emergency actions or will be escorted by trained VEGP personnel.
Notification of the State and local response personnel is the responsibility of the Emergency Director using a dedicated telephone system called the Emergency Notification Network (ENN). Notification of GEMA, Burke County Emergency Center and SRP Emergency Center is made via the ENN which is manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. Declaration of an emergency to these locations can be made within 15 minutes. GEMA is responsible for notifying the State of South Carolina at an Alert or higher emergency classification, however, this is not documented in the VEGP Emergency Plan. Backup is provided by commercial telephone and radio, i
The Emergency Director is also responsible for contacting the NRC Operations Center on the ENS telephone.
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-19-Examples of notification forms for the ENN and the NRC ENS system as well as followup message forms are provided in the plan. All notifications by dedicat-ed telephone will be verified by roll call and notifications by radio or commercial telephone by call back.
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The public notification for the plume exposure pathway EPZ which is entirely
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within Burke County, since DOE has assumad the responsibility for notifying all
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personnel within the SRP boundaries, uses the National Oceanic and Atmospheric Administration (NOAA) Alert System. NOAA has agreed to activate this system at
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'y is not described or documented in the VEGP Emergency Plan. While the NOAA Alert System can broadcast 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, none of the local commercial radio stations and or.ly WRDW-TV in Augusta broadcasts 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. In the event of an emergency all of the local stations have agreed to go on the air within 30 minutes after a key person is notified to broadcast emergency information.
The initial public notification with any appropriate protective action instrutions would be initially broadcast over the NOAA system. Further in-structions would be provided through commercial radio and TV stations who are members of Emergency Broadcast System (EBS). The authority for State or local officials to activate the EBS is given, but the method and the officials with the authority to perform this notification is not given in the plan. Documented agreements with the local commercial radio and TV stations are provided in Appendix 2 of the plan. Georgia Power Company provides NOAA radio receivers for all residences,
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-20-businesses, schools and other establishments within the plume exposure pathway EPZ and will replace any defective receivers. The instructions to the public for their use and the procedures for test and maintenance of this system are not given in the plan.
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In addition to the NOAA and EBS broadcast systems, vehicles from the Burke County Sheriff's Department, the Georgia State Patrol and the County Emergency Management Agency equipped with sirens and/or loudspeakers would notify people in the recreational areas and anyone who had not heard the alert broadcasts.
Boats supplied by the Georgia Department of Natural Resources and by the Burke
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County Emergency Management Agency and equipped with a loudspeaker or a sound device will travel the Savannah River to notify sportsmen, boaters or other individuals along the river within the EPZ. The location where these boats and vehicles are located, the procedures for deploying them and how they would be notified to deploy are not given in the plan.
The applicant states that this system of notification should assure 100%
coverage of the population within the EPZ 45 minutes after being notified by VEGP. The NOAA alerting broadcast can be made within 15 minutes after notifi-cation of State and local officials. The applicant states that while the administrative and physical means have been established for providing an initial warning to the public within 15 minutes, State and local agencies are accountable for activating the notification system. However, in Appendix
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-21-E, Part IV.D3 of 10 CFR 50, this administrative and physical capability includes mutually agreed upon procedures and methods between the applicant and local authorities that will allow for prompt notification of the public in a rapidly escalating emergency. Evidence that such procedures and methods have been
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developed is not provided in the VEGP Emergency Plan.
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The following items require resolution:
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(1). The individuals, methods and procedures to be used by GEMA to notify the
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State of South. Carolina should be described.
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(2) The individuals, methods and procedures to be used to activate the NOAA Alert System and the EBS stations should be described.
(3) The instructions to be provided to the public for use of the NOAA Alert System should be appended to the plan.
(4) The system for testing and maintaining NOAA receivers should be described in the plan.
(5) The methods, procedures and individuals who will activate the vehicles and boats, including their deployment and location should be described.
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i-22-(6) The call fanout system to notify VEGP personnel offsite during the back-shift should be described.
13.3.2.6 Emergency Communications s . :.
Standard
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Provisions exist fo prompt communications among principal response organizations to emergency personnel and to the public.
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% Emergency Plan Evaluation The VEGP Emergency Plan describes the communications systems available for use in emergencies. Communications available in the control room and ERFs include dedicated telephone circuits, normal plant telephone circuits, a facsimile line, base station radio console, sound-powered telephones and the plant page system. This redundancy of communications systems assures onsite communications during emergencies. Backup power using a battery system is
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also provided. The communications systems for the backup E0F are not described in the plan.
The primary means of communications with GEMA, Burke County Emergency Center and SRP duty officer is the ENN which provides a dedicated telephone line to (
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-23-each of these locations from the control room, TSC and E0F at VEGP. The ENN is manned and available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. Comercial telephones and a Georgia Power Company microwave system in Atlanta provide a backup system with GEMA.
In addition, backup radio communications can be provided to GEMA through the
, Georgia State Patrol. Backup comunications with Burke County officials is provided by commercial telephones and the local Civil Defense Network. Radio communications can be provided between VEGP and the Burke County Sheriff'
Department using the law enforcement network. Comercial telephone lines provide a backup means of comunication to SRP.
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Primary comunications to the NRC Operators Center in Bethesda and NRC Region II in Atlanta are through the ENS dedicated NRC telephone system. The HPN priority NRC telephone system is not described in the plan. ENS extensions are available at VEGP in the control room, TSC and EOF. The Georgia Power Company microwave system and comercial telephone lines serve as backups to the ENS.
Commercial telephone is the primary means of comunication between the two hospitals and VEGP with radio backup through the Burke County Sheriff's Department. The VEGP ambulance and the Burke County Ambulance Service are equipped with radio comunications and VEGP can comunicate with these vehicles while in transit.
Comunications channels with GEMA, Burke County, SRP and NRC will be tested monthly and. all emergency comunications systems will be checked for i
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-24-operability quarterly. All communications procedures and systems also will be tested during the VEGP annual emergency exercise.
The following items require resolution:
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(1) The consnunications capabilities of the backup E0F should be described.
(2) A descripticn of the NRC priority HPN telephone system should be provided.
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13.3.2.7 Public Information Standard Information is made available to the public on a periodic basis on how they will be notified and what their initial actions should be in an emergency (e.g., listening to a local broadcast station and remaining indoors), the principal points of contact with news media for dissemination of information during an emergency (including the physical location or locations) are estab-lished in advance, and procedures for coordinated dissemination of information to the public are established.
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-25-Emergency Plan Evaluation The Georgia Power Conpany will provide information to the public on the emer-gency notification and initial actions in the event of accident at VEGP. This
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will be disseminated at least annually by placing it in local telephone books,
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posting in public areas and/or publications distributed by mail within the plume exposure pathway EPZ. The information provided will include:
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instructions on the use of the NOAA Alert System; discussion of evacuation and sheltering actions; radio stations that will broadcast emergency information; descriptions of evacua-
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tion routes and loc'ation of eception centers; educational information on radiation;
' contacts to obtain additional information; and special needs for the handicapped.
None of these public information materials have been provided by the applicant.
In addition, Georgia Power Company will use the VEGP Visitors Center to provide the public education programs on plant operations, plant safety and radiation.
News centers to coordinate and disseminate information to the media will be established to accommodate representatives from Georgia Power Company, Burke County, the State of Georgia and Federal response agencies. For emergencies where a small media response is anticipated the VEGP Visitors Center will be established as the news center. If media response exceeds approximately 100 representatives or if radiological conditions indicate the center should be relocated, the news center will be established at the Burke County Office Park in Waynesboro.
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-26-A description of the Georgia Power Company public information organization is provided in Appendix 8 to the VEGP Emergency Plan as well as in Section G.
Discrepancies exist between Section G and Appendix 8 including: the identity
- - of the corporate spokesman, the locations of the news centers, how the rumor control program operates and where the public information organization person-
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nel will be located during various phases of the emergency. The Corporate Emergency Plan in Appendix 7 does not cover the assignment of the corporate spokesman and does not identify the various points of interfacing between the s, public information staff and the corporate organizations. In addition, Appen-
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/ dix 8 does not clearly identify who will fill all the key public information emergency positions, where these individuals will be located during emergen-cies, the organizational structure of the emergency public information function and how these individuals will interface with the corporate and VEGP emergency organizations.
Georgia Power Company will conduct annual training sessions for the public information department and will offer training to the media located within the State of Georgia. The goals and procedures to be used in this training are unclear and there is no indication that the system will be exercised in conjuntion with the VEGP annual exercise.
The following items require resolution:
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i-27-(1) The corporate spokesman and the alternates for this position should be clearly identified by normal position title in Section G, Appendixes 7 and 8 of the VEGP Emergency Plan.
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(2) The public information materials to be provided in telephone books and/or distributed by mail as well as posters for display in public areas should be submitted for. review.
(3) The discrepancies between Section G and Appendix 8 of the VEGP Emergency
. Plan with regard to the corporate spokesman, news center locations, the rumor control program and personnel locations should be corrected.
(4) The identification of the key emergency public information managers by normal job position; where these individuals will be located during the various phases of the emergency, the organizational structure including an organizational chart of the public information organization and how this organization interfaces with the corporate headquarters and VEGP should be clearly delineated.
(5) The annual training for the public information organization and the media and how this will be coordinated with the VEGP annual exercise should be described.
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-28-13.3.2.8 Emergency Facilities and Equipment Standard s..
Adequate emergency facilities and equipment to support the emergency response are provided and maintained.
Emergency Plan Evaluation The emergency facilities and equipment are described in Section H of the VEGP Emergency Plan and a description of the ERFs also is provided in FSAR Section 9.5.10. The information on the ERFs in the plan and FSAR Section 9.5.10 is not clear, consistent and covers these facilities and their equipment in varying degrees of detail.
The TSC is located adjacent to the Unit I control room and is shared by both units. The TSC provides plant management and technical support personnel with a dedicated facility to assist the control room during emergencies. A layout of the TSC is provided in figure H-1 of the VEGP Emergency Plan and FSAR Figure 9.5.10-1. Figure H-1 gives a simple line drawing of the various rooms within
! the TSC while FSAR Figure 9.5.10-1 is a construction drawing showing the placement of much of the equipment in the TSC. Neither drawing identifies the
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i-29-main operations area and the anticipated work location of the key TSC personnel.
The TSC is designed to accommodate 25 people including five NRC personnel. The TSC is an integral part of the Seismic Category I power block and the structure and ventilation system provide the same level of protection for radiological
.u ;. hazards as the control room. According to FSAR Section 9.5.10 the design meets
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the requirements of General Design Criterion 19 and Standard Review Plan 6.4
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for the duration of the accident. It is unclear from these differing.descrip-tions whether the TSC and the control room are supplied by the same or differ-ent ventilation systems and what the exact capabilities of the TSC ventilation
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., system are.
The TSC is equipped with an ERF Computer System which has access to the Process and Effluent Radiation Monitoring System (PERMS) which provides data on normal and accident conditions within VEGP to the control room. The PERMS consists of a minicomputer with data provided by each radiation detector equipped with a data processing module as described in FSAR Section 11.5. The system includes process radiation monitors, effluent radiation monitors, radiation area moni-tors, airborne radiation monitors and post accident radiation monitors. The ERF Computer System consists of display CRTs, line printers, video copiers, a CPU located in the power block between the TSC and the control room and associ-ated hardware and software. This system has -he capability to store two hours of pre-event data, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of post-event data and two weeks of additional post-event data with reduced time resolution.
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-30-There are five ERF Computer CRTs, two printer / plotters, a line printer and a video copier in the TSC. The system has a 0.01 unavailability which provides a high degree of reliability. In addition, plant monitoring and data handling systems provide meteorological, seismic and fire detection data to the TSC
- 1 although it is unclear how this data is inputed. Meteorological data includes wind speed, wind direction, vertical temperature difference, ambient temperature,
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dewpoint temperature and precipitation from a 60 meter tower onsite. . The ERF Computer System also receives a large number of parameters on the status and conditions of various plant systems and engineered safety features. All signals
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from safety systems'are individually isolated. The ERF Computer System is rt -
i~ equipped with remote processing units which can input data from field monitoring teams and nonnuclear safety data. SPDS data is also provided to the TSC.
The TSC is equipped with two radiation area monitors and portable monitoring instruments for personnel leaving the TSC complex. Portable respirator apparatus and protective clothing are also provided for TSC personnel.
Normal TSC power is provided from offsite normal power through a motor control center backed by the security diesel generator or the battery-backed uninter-ruptible power system. Battery operated emergency lighting can provide a minimum of eight hours of continuous operation. It is unclear if the ERF Computer is included on this emergency power system.
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-31-The TSC and the control rooms share the same records center for documents, procedures, specifications, drawings and plans. While the list of information present is adequate, separate copies of the Technical Specifications, plant operating procedures, emergency operating procedures, FSAR, the VEGP Emergency
.>.. Plan and EPIPs do not appear to be provided for the TSC and the control room.
The Operations Support Center (OSC) is located at an unspecified location in the maintenance building and is used as an assembly area for support personnel and oncoming shift personnel to aid in the emergency. It is also the initial
, assembly point for radiological emergency monitoring teams. The layout of the
- ') OSC is provided in Figure H-2 of the VEGP Emergency plan. This layout does not indicate the location of the OSC Manager or any status or briefing displays.
l Also there is no indication of where damage control and assessment teams will get their equipment, manuals and other needed supplies.
Emergency kits with radiation monitoring equipment and instruments, respiratory protective equipment, protective clothing, decontamination supplies and port-able lighting and radio equipment are available. In the event the OSC becomes uninhabitable, the OSC functions will be moved to the TSC, but the plan does not describe how this will be performed or where space for personnel in the TSC will be provided.
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-32-The EOF is located in the south wing of the VEGP Training Center, approximately 1.5 miles from the plant. The E0F is the comand center for overall management of the emergency and coordination of the radiological assessment of the accident.
The layout of the E0F is provided in Figure H-3 of the VEGP Emergency Plan and
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FSAR Figure 9.5.10-3. The EOF can accommodate 35 people including nine NRC and one FEMA personnel. This also will include representatives from Burke County and the State of Georgia.
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Figure H-3 is a line drawing showing 11 rooms labeled as to their function while FSAR Figure 9.5.10-3 is a construction drawing showing a limited equipment location. Neither of these drawings show the location of
, the Emergency Direc' tor, the EOF Manager, the NRC Director of Site Operations,
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the location of data displays or the work stations in the E0F.
The E0F ventilation system is equipped with HEPA filters and the facility can be isolated with recirculating ventilation. The structure has a shielding factor of five for some unspecified energy and type of radiation.
The normal power supply to the E0F is from Plant Wilson and backup lighting is provided by battery wall packs that can be operated for three hours. The records and information available in the E0F should be adequate to perform its functions. Data acquisition is provided by the ERF Computer System which is directly wired to the E0F. Four CRTs and video copier are provided in the EOF as readouts for this system. Emergency kits for offsite monitoring are provided in the EOF and a list of radiological equipment is given in Appendix 4
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of the VEGP Emergency Plan for the EOF.
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t-33-The Georgia Power Company district office in Waynesboro outside the plume exposure pathway EPZ is designated as the backup E0F in the VEGP Emergency Plan in the event that the primary EOF becomes radiologically uninhabitable.
The dose assessment and decisionmaking functions will be temporarily trans-
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ferred to the TSC until the backup E0F is functional. No description of the procedures or the time required for making this transfer are provided including the method by which_the TSC will assume this additional workload. The distance of the backup E0F from VEGP, its address, a layout of the facility, the communi-cations capabilities, the methods for providing dose assessment and data acquisition and the emergency supplies are not discussed in the plan.
The TSC and the OSC will be activated at an Alert or higher classification of emergency and the EOF will be placed in standby status. The EOF will be activated at the Site Area Emergency or higher emergency classification. All
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the ERFs have an activation time of about one hour.
The contents of the various types of emergency kits for the VEGP facilities are ,
described in Appendix 4 of the plan. These descriptions do not provide the types and the measuring ranges of the radiation measuring instrumentation except for direct reading dosimeters. The proposed ranges of the direct reading dosimeters are not adequate, particularly for the OSC and the health physics control point.
The use of charcoal air sampling filters is questioned in these kits. Dosimetry and respiratory protection are not included in offsite decontamination kits.
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, -34-The offsite ambulance kits do not include radiation measuring instruments,
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dosimetry, respiratory protection, protective clothing, radiation warning tags and tape.
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The following items require resolution:
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(1) The description of the ERFs should be consistent between the Emergency Plan and FSAR Section 9.5.10. The plan should provide all of the detail in FSAR Section 9.5.10 in order to provide adequate clarity.
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(2) The layout of the TSC should provide adequate detail to illustrate the general work station and major equipment locations as well as the location of the key managers.
(3) The description of the TSC ventilation system should be clarified.
(4) The data system or methods to provide meteorological, seismic and fire detection information to the ERF Computer System or the ERFs should be described.
(5) The backup power for the ERF Computer System or the methods for providing data acquisition and assessment to the TSC and EOF if power to the system fails should be provided.
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/ (6) Separate copies of the Technical Specifications, plant operating procedures, FSAR, Emergency Plan and EPIPs should be provided to the TSC and control roo'm.
.+- (7) The exact location of the OSC in the maintenance building should be provided.
(8) The layout of the OSC should provide a better illustration of the physical
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area, the location of information displays and the work station of the OSC Manager.
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7h (9) The descr'1ption of how the damage assessment and control teams obtain their equipment, drawings, manuals and other materials should be provided.
(10) A description of the methods to be used to relocate and operate the OSC in l
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the TSC should be provided.
(11) The layout of the E0F should provide adequate detail to illustrate general work station locations, major equipment locations and the work station location of the Emergency Director, E0F Manager and the NRC Director of Site Operations. -
(12) The exact protection factor for EOF habitability should be defined.
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-36-(13) The address and the distance of the backup E0F from VEGP should be provided.
i (14) A description of the methods to transfer and carry out the EOF functions s. in the TSC and then in the backup E0F should be provided.
(15) A general layout of the functional areas and equipment for the backup EOF should be provided. '
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(16) A description of the type and ranges of radiation monitoring instruments in the emergency kits should be provided. Higher ranged direct reading dosimeters should be available in the OSC and health physics control point emergency kits.
c (17) A description of the use of the charcoal filters for air sampling in the emergency kits should be provided.
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(18) The emergency kit descriptions for offsite decontamination and offsite ambulance service should include instrumentation and other equipment as k described in the evaluation above.
(19) The applicant should provide a coninitment that either the final ERFs will be completed and operational prior to fuel loading or that adequate interim facilities will be in place.
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Subsequent to resolution of the above items, the staff will make a determina-tion of the acceptability of the applicants' emergency response facilitities
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and equipment on an interim basis for licensing. The staff will confirm the adequacy of the applicant's final ERFs during a post implementation inspection
. , against the requirements of Supplement 1 of NUREG-0737 on a scheduled to be
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l 13.3.2.9 Accident Assessment
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Adequate methods, systems, and equipment for assessing and monitoring actual or j potential offsite consequences of a radiological emergency condition are in
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Emergency Plan Evaluation i
Plant systems and effluent parameter valuee characteristic of a spectrum of off-normal conditions and accidents are described in Section D of VEGP Emergen-cy Plan which is still under revision and review. This classification scheme and its application to accident assessment will be evaluated in a supplement to the SER.
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-38-i Inplant radiological measurements using the PASS and PERMS monitoring systems will be used to assess emergency conditions. The description of methodology to perform this assessment is not adequate to provide an evaluation. The de-scription of the PASS in Section H of the plan does not provide an adequate
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description of its capabilities. Although the plan states the use of high
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range radiation monitors and the containment hydrogen monitor will be used to correlate these readings with the extent of core damage based on the Westinghouse Owner's Group Post-Accident Core Damage Assessment Methodology, the plan does not provide an adequate description of the plant specific methods s to be used. Determination of the release rate of radioactivity from the plant
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i will be made using the PASS and PERMS with conversion charts. Neither the inclu-sion of these charts nor an adequate description of their characteristics is provided in the plan.
The dose projection system uses a microcomputer which will take meteorological i
data and release rates from the ERF Computer System to obtain whole-body and thyroid doses. The meteorological model used to determine the transport and diffusion of an airborne radioactive release is a variable trajectory Gaussian puff technique. The description of these models is not adequate to perform an evaluation. The meteorological data can be asses;2d by the control room, TSC, EOF, NRC and will be made available to State and local representatives in the E0F. A simplified manual dose calculation method will be used for dose project in the control room and as a backup procedure in the TSC and E0F. No
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-39-description of this simplified methodology is provided in the plan. Although the plan states that default values will be used for dose projections when meteorological data or information on plant conditions are not available, the default values or the methods to be used to arrive at the default values is not
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provided. Also the method for obtaining weather forecasts is not described.
Four field monitoring teams, three offsite and one onsite, can be deployed from the OSC or the E0F and will consist of two individuals in a Georgia Power vehicle equipped with a two-way radio, although the plan does not indicate the
- availability of these vehicles and how they will be obtained and deployed. The
VEGP Emergency Plan states that these teams will be equipped with gamma and beta / gamma dose rate measuring instruments, respirators and protective cloth-ing; however, the equipment list in Appendix 4 of the plan does not include them and the ranges of the instruments are not specified. Also the use of charcoal air sampling filters is questioned. The plan states that preselected sampling and monitoring locations will be used to determine sampling positions; however, no map is provided showing where these positions are located. The plan states that a communicator maintains continuous radio contact with each team, but this system of communications is poorly described. The plan states that the field measurement lower limit for airborne radioiodine is 10 7 microcuries per cubic centimeter and is inadequate. While the plan states that field analysis of air sampling cartridges can be made without interference from noble gases, this methodology is not described. No mention of fixed field i
monitoring using TLDs or other radiation detectors is provided in the plan.
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I-40-Also there is no description of how the VEGP field monitoring will be coor-dinated with Federal, State and/or local monitoring capabilities. Although the plan states that laboratory analysis of field samples with relatively high radioactivity levels will be made, a description of the laboratory capabilities
.q or the radioactivity levels at which the analysis will be made are not provided.
The plan states that field monitoring data will be used to refine dose projections
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and modify protective action recomendations, but the description of the methodology is not provided.
3 A methodology to provide ingestion pathway dose projections offsite is not described in the plan.
The following items require resolution:
(1) A description of the PASS and measurement capabilities of this system should be provided.
(2) The methodology using PASS and PERMS to determine plant conditions and release rates as well as the charts and graphs to correlate these readings should be provided or described in adequate detail for evaluation.
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-41-(3) The meteorological and dose projection models; the default values or methods to be used when data is unavailable on meteorological or plant conditions; and the method for obtaining weather forecasts should be described in adequate detail for evaluation.
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(4) A description of the simplified manual dose projection methodology should be provided for evaluation. )
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(5) A description of methodology for deploying field monitoring teams and providing vehicles with two-way radios should be provided.
(6) A more detailed description of the field monitoring capabilities including radiation instrumentation sensitivities and ranges, sampling techniques, measuring techniques (to 10-7uCi/cc for radioiodine under field conditions)
and a clarification of the equipment list should be provided. l l
(7) A map showing the location of the preselected monitoring and sampling l locations should be provided.
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(8) the description of the radio communications with the field monitoring teams should be more fully described and clarified.
(9) A descripiton of the fixed field monitoring system, instrumentation, a map
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illustrating the monitoring locations and methodology should be provided.
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-42-(10) A description of the system for coordination of field monitoring between VEGP, Federal, State and/or local monitoring teams should be provided.
. . (11) A description of the laboratory analysis and the radioactivity levels that will determine 1, hen analyses are made should be provided.
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(12) A description of the methodology for using field monitoring data to refine dose projections and modify protective action recommendations should be provided.
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(13) The means of making ingestion pathway dose assessments and projections including a description of the methodology should be provided for evaluation.
13.3.2.10 Protective Response Standard The range of protective actions has been developed for the plume exposure path-way EPZ for emergency workers and the public. Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure path-way EPZ appropriate to the locale have been developed.
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-43-Emergency Plan Evaluation All personnel onsite at VEGP will be notified of emergency conditions. Upon notification personnel with emergency responsibilities will report to their
- onsite designated stations in the control room and other ERFs. Accountability reports will be provided to the Security Department. Personnel emergency assignment tracking procedures will be used to account for personnel onsite during the emergency, however, no description of these procedures is provided.
Non-essential plant personnel, visitors and contractors will evacuate from the
..,. protected area leaving their ID badges at the Security Department. The Securi-l' -
ty Department will use the computerized accountability system or visual inspec-tion of the badge exchange as well as-the accountability reports to determine the accountability of personnel within the protected area within about 30 minutes. Evacuation of nonessential personnel will be ordered by the Emergency Director when a Site Area or General Emergency is declared or when a threat to the safety to onsite personnel exists, however, the criteria for making this determination are not given.
Personnel evacuated from the site will travel to an assembly area at Plant Wilson or the VEGP recreation area in their own vehicles and buses using the evacuation routes shown in Figure 11 of the VEGP Emergency Plan. However, this map has poor legibility and does not illustrate the protected area, the visitor's
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-44-center and the protected area access gates. A security patrol will check all offices and work locations to ensure that personnel have reported to the assembly areas. If the protected area accountability reveals missing person-nel, search and rescue will be initiated to locate these personnel. Although
.. the assembly areas are designated, no description is provided in the plan of the facilities available in the area or how the area will be managed and controlled.
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Monitoring of personnel evacuating the site will be performed at the protected area gate using portal nonitors or with portable instruments brought to the
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assembly area by a monitoring team dispatched for this purpose when a release of radioactivity has occurred. The monitoring team will establish a control point at the assembly area to monitor evacuees and vehicles before releasing them from the assembly area. The methods used to establish the control point and the procedures to monitor personnel are not described in the plan. Decon-tamination will be performed in the control building for those personnel detected by portal monitoring and decontamination areas will be established at the assembly areas using the equipment listed in Appendix 4 of the plan.
, Decontamination and waste disposal will be performed using plant emergency procedures, but these procedures are not described or referenced in the plan.
Although a supply of potassium iodide (KI) is available for use the criteria
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and distribution methods are not described in the plan.
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The VEGP Emergency Director is responsible for ensuring that timely recommenda-tions are provided to offsite officials through initial notifications and
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-45-followup communications. These recommendations are based on the EPA Protective Action Guides and the criteria for airborne releases are provided in Table J-2 of the VEGP Emergency Plan. However, the criteria did not indicate that effective dose equivalence for the most critical segment of the population
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, is provided and the recommendation to evacuate children and pregnant women if constraints exists is not as appropriate as evacuating all residents and personnel located wtthin 2 or 3 miles of the site. In addition, plant procedures will be used to recommend sheltering within a two mile radius and five miles ~
downwind as a minimum if a General Emergency is declared and precautionary
,]j evacuations will be recommended based on the estimated time until the radioactive release occurs. These plant procedures are neither described or referenced in the plan. Also no information is provided on where or how evacuees and residents will be relocated and sheltered during an evacuation.
No information or criteria are provided in the plan for making recommendations for protective actions in the ingestion pathway.
Evacuation time estimates for the plume exposure pathway EPZ and sheltering shield factors are provided in Tables J-4 and J-3 respectively in the VEGP Emergency Plan. Also evacuation time estimates for SRP and a detailed methodology and analysis for the estimates in Table J-4 are provided in Appendix 6 of the plan. However, state and local officials have established different evacuation areas than are used in the analysis and the time studies are being
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-46-revised by the applicant. In addition, the basic methodology for the SRP time estimates are not provided and are needed to provide a general staff evaluation.
A staff evaluation of the evacuation time estimates will be made in a supple-ment to the SER after estimates for Burke County have been revised and the SRP
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basic methodology is obtained by the applicant,
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A map illustrating the plume exposure pathway EPZ is provided in Figure iii and
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a map illustrating the ingestion pathway EPZ is provided in Figure iv of the plan. However, both of these maps are illegible and do not illustrate the
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location of the visitor's center, the E0F, the backup E0F, the VEGP site
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boundary, Plant Wilson, the VEGP recreation area, the boundaries of SRP, the Burke County Emergency Center, the Burke County Sheriff's Department, the Georgia State Mobile Emergency Center, the backup news center, the Burke County Hospital, the Humana Hospital, the offsite relocation centers, and the local airports.
The following items require resolution:
(1) The criteria for determining that nonessential onsite personnel should be evacuated from the site should be provided.
(2) The legibility of Figure 11 should be improved and the site protected area, the protected area access gates and the visitor's center should be
illustrated on this map.
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i-47-(3) A description of the facilities at the assembly areas and how they will be managed and controlled should be provided.
(4) A description of the methods used to establish a control point and the
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procedures used to monitcr personnel and vehicles at the assembly areas should be provided. -
(5) A description and referenced plant procedures for performing decontamination and waste disposal at the assembly areas should be provided.
(6) A description of the distribution methods and criteria for issuing KI to onsite and plant personnel should be provided.
(7) The criteria for protective actions for airborne releases should be modified to indicate that effective dose equivalence is provided for the most critical segment of the population and the protective action evacuation reconnendation under constraints should be changed.
(8) The plant procedures for reconinending a precautionary evacuation offsite should be described and referenced.
(9) Information on where and how evacuees and residents from the plume exposure pathway EPZ will be relocated and sheltered during an evacuation should be provided.
_ _ _ _ _ _
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.
(
-48-(10) A description of the methodology and the criteria for making protective action recorrrnendations in the ingestion pathway should be provided.
'
(11) Revised evacuation time studies and the basic methodology for the SRP
.
evacuation time estimates should be provided for evaluation.
_
(12) The maps in Figures iii and iv should be modified to make them legible and at least one of these maps should 111ustrate the location of the ,
visitor's center, the EOF, the backup E0F, the VEGP site boundary, Plant Wilson, the VEGP recreation center, the boundaries of SRP, the Burke County Emergency Center, the Burke County Sheriff's Department, the Georgia State Mobile Emergency Center, the backup news center, the Burke County Hospital, the Humana Hospital, the offsite relocation centers and the local airports.
13.3.2.11 Radiological Exposure Control Standard Means for controlling radiological exposure, in an emergency, are established for emergency workers. The means for controlling radiological exposures shall l
include exposure guidelines consistent with EPA Emergency Worker and Lifesaving l l
- Activity Protective Action Guides. '
t
.
.
\
-49-Emergency Plan Evaluation Emergency exposure criteria for emergency workers have been established for VEGP
'
in the event of an accident which are generally consistent with the EPA Emergency Worker and Lifesaving Activity Protective Action Guides and are provided in Table K-1 of the VEGP Emergency Plan. The VEGP Emergency Director is authorized to permit radiation exposures in excess of 10 CFR 20 limits, but within the limits of Table K-1. While decisions on appropriate exposures and relative risks for mitigating, damage control and assessment actions will be made by the Emergency
'
Director in consultation with the health physics staff, the design criteria for equipment and facilities to limit personnel exposure while preforming
, planned functions, such as PASS sampling, under emergency conditions are not provided and the footnote in Table K-1 is unclear. Where time and urgency permit, normal radiation work permit procedures will be used. In all cases, a briefing describing the hazards which are involved in the planned action as well as protective actions to be implemented will be given by the health physics staff.
Logs of the emergency exposures to personnel will be maintained by the emergency health physics supervisor, but the methods or procedures for maintaining these exposure records and controlling radiation exposure are not described.
All emergency personnel will be equipped with both TLDs and direct reading
, dosimeters including offsite personnel responding to the emergency. Emergency
I
-
.
.
(
-50-personnel will be instructed to check their direct reading dosimeters every 15 to 30 minutes during the emergency. TLDs will be read monthly or more fre-quently if the situation warrants, but the criteria for more frequent readings are not provided and the ability to read the TLDs on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis is not
-
indicated.
.
Personnel decontamination facilities are located in the control building, but their exact location and decontamination capabilities are not fully described.
Radiological waste control is available in these facilities. Personnel decon-
'
, tamination will be' accomplished using water washes and station health physics
procedures which are applicable for decontamination of radiciodine on skin surfaces, however, these procedures are not described or referenced in the plan. Equipment and area decontamination will be performed using station health physics procedures which are not described or referenced. Also the methods for measuring or evaluating highly contaminated personnel and areas to determine the relative hazard are not described. The action levels for determining the need for decontamination are provided in Table K-2 of the VEGP Emergency Plan, but the limits for area contamination do not indicate whether they are for fixed or removable contamination.
Onsite radiological contamination control will be provided by access control by the Security Department to the protected area and by barriers, signs,
. . _ ___
.
.
i-51-locked doors or personnel stationed at the location. The emergency health physics supervisor will determine if onsite food and water supplies may be consumed, but the criteria for making this determination are not provided.
i
The following items require resolution:
.
(1) The personnel exposure design criteria for equipment and facilities to perform planned emergency functions, such as PASS sampling, should be provided and the footnote in Table K-1 should be clarified.
(2) The methods or procedures for maintaining personnel emergency exposure records and exposure control should be described, i
(3) The criteria for more frequent reading of TLDs and the methods to determine radiation dose 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day should be provided.
d (4) The exact location of onsite personnel decontamination facilities and their
- capabilities should be described.
(5) The station personnel, arta and equipment decontamination procedures should i
be described or appropriately referenced.
.
. _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ . . . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _
i
.
.
(
-52-(6) The methods for measuring highly contaminated personnel and areas to determine the relative hazard should be described.
(7) The contamination levels for plant areas in Table K-2 should indicate
whether these are fixed or removable contamination levels.
.
(8) The criteria for acceptable contamination levels for food and water onsite should be provided.
'
'13.3.2.12 Medical and Public Health Support
,_ )
-
Standard Arrangements are made for medical services for contaminated injured individuals.
Emergency Plan Evaluation VEGP has made provisions to assist personnel who are injured and are externally contaminated or who may have received high radiation doses. Decontamination materials and first aid kits are available at strategic locations throughout the station. Onshift personnel and onsite and offsite emergency organizations have been trained in the Red Cross Multimedia Course. However, it is unclear whether personnel trained in first aid and decontamination are available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. A first aid and decontamination area is at the health physics
. _ _ ._ __ ___ _ -
.
I-53-station in the control building at the 220 foot elevation. The plan implies that if injured personnel are contaminated, they will be decontaminated prior to removal to the hospital, regardless of their need for immediate medical attention. Transportation of injured personnel will be performed by either
. the VEGP ambulance crew or the ambulance from the Burke County Medical Service as documented in Appendix 2.
VEGP has established arrangements with the Burke County Hospital to treat contaminated patients which has facilities to provide such treatment as de-
.,
scribed in the plan. Humana Hospital in Augusta is tt.a backup hospital if
. A i
Burke County Hospital is not available to provide treatmer.t and the plan states it also is equipped to handle contaminated patients although the facilities are not described. Agreements with these hospitals and with six local physicians to provide medical treatment are documented in Appendix 2. VEGP also has an agreement with the Radiation Management Corporation to provide management of radiation accident victims and consultation services on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis as required as well as provide training to the local hospitals and physicians.
Although a radiation protection technician will accompany patients to the hospital, the plan does not describe the health physics support and procedures to be used at the hospital. Also the ambulance crews receive training to handle contaminated patients, but a description of the procedures to be used are not provided.
F
.
l-54-The following items require resolution:
(1) The availability of personnel trained in first aid and decontamination pro-cedures onsite 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day should be clarified.
.
,
(2) The plan should be modified to state that injured, contaminated personnel requiring immediate medical treatment will be transported to the hospital as quickly as possible without performing decontamination procedures.
A description of the capabilities of the Humana Hospital to handle contami-C,,(3)
nated patients should be provided.
(4) The health physics support and procedures to be used at the Burke County and Humana Hospitals should be described.
.
(5) A description of the contamination control procedures to be used by ambulance crews in transporting contaminated patients should be provided.
13.3.2.13 Recovery and Reentry Planning and Post-Accident Operations Standard General plans for recovery and reentry are developed.
o a
-55-Emergency Plan Evaluation The VEGP Emergency Plan describes general plans for recovery and reentry operations following any declared emergency condition. The criteria for down-
'
grading from an emergency classification to a recovery condition are: the reactor is in a stable condition and can be maintained in that condition indefinitely; the radiation levels are stable or decreasing; releases of radio-activity have terminated or are being controlled within permissible limits; fires or other conditions no longer constitute a hazard to safety-related
..? systems, equipment or personnel; and the consultation and coordination with the
State of Georgia, the NRC, Burke County and SRP officials do not identify any valid reason to remain in an emergency condition.
The transittffrom an emergency classification to a recovery condition will bedefsredbytheVEGPEmergencyDirector. Notification of Federal, state and local officials that this declaration has been made will be performed using the emergency communications systems. At that time the Emergency Director will designate a Recovery Manager to constitute the recovery organization. The plan describes by title, the authorities and responsibilities of the key positions in the recovery organization and provides an organizational structure in Figure M-1 of the VEGP Emergency Plan. However no provision is made for a manager to to assume the health physics and environment assessment responsibilities.
l
I(
,
-56-Reentry activities will be controlled in accordance with the criteria in the normal plant procedures and radiation work practices will follow ALARA program principles. TLDs and other dosimetry as appropriate will be issued to all personnel who require access to VEGP. These TLDs will be read monthly or more
[ often if work in high radiation areas is undertaken. However, the criteria for
'
reading the TLDs more often is not provided. The plan states that the State of Georgia is responsible for determining population exposure in the plume exposure and ingestion pathways and that VEGP will provide information on release rat'es, quantity of radioactivity released, radionuclide composition of the releases and meteorological data to assist the state in its determinations. However,
)
l NUREG-0654 recommends that the licensee establish a method for periodically esti-mating total population radiation dose.
i The following items require resolution:
l (1) The plan should be modified to provide for the assignment of responsi-bilities for health physics and environmental assessment in the recovery-l reentry organization.
,
i (2) The criteria for reading TLDs and assessing radiation dose more often than on a monthly basis should be provided.
(3) The plan should be modified to establish methods and procedures to periodically estimate total population radiation dose and these methods and procedures should be described.
(
r-57-13.3.2.14 Exercises and Drills Standard
\
Periodic exercises are (will be) conducted to evaluate major portions of emergency response capabilities, periodic drills are (will be) conducted to develop and maintain. key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected.
's Emergency Plan Evaluation-l The VEGP Emergency Plan provides for emergency exercises and drills to be conducted to evaluate the adequacy of ERFs, equipment, procedures, communica-tions links, emergency personnel response actions and VEGP coordination with offsite emergency response organizations. Some of these drills and exercises will be unannounced. Emergency exercises will test the integrated response and will be conducted in accordance with NRC and FEMA guidance. Exercises will be conducted every 12 months plus or minus three months and will be coordinated with Federal, State and local agencies as appropriate. Exercise scenarios will be varied from year to year to test all major elements of the VEGP emergency preparedness program within a five year period. An exercise will be initiated
I
"
,
,
.
(
-58-between 6:00 p.m. and midnight and between midnight and 6:00 a.m. Once every six years. Although no effort will be made to conduct exercises under a variety of weather conditions, it is expected that they will be conducted under a variety of weather conditions since the date of the exercise is established several
- months in advance and may vary by date by as much as six months.
>
Emergency drills will be conducted to test, develop and maintain skills in a particular emergency operation. The following types of drills will be conduct-ed on the frequency indicated: .
(1) Comunications Drills will be conducted by VEGP using the actual message formats to test the understanding of the message content as well as the systems hardware. Contact will be established from the control room, TSC and EOF, but the comunications from the backup E0F are not included.
Drills with all offsite organizations will be conducted annually, normally during the annual emergency exercise except for communications with Federal organizations and States within the ingestion pathway EPZ which will be conducted quarterly.
(2) Fire drills will be conducted in accordance with the VEGP Technical Specifications for the VEGP fire brigade on a quarterly basis. Drills will be scheduled to ensure that each member of the fire brigade partici-pates in at least two drills per year.
,- ._ . . _ -- - __ ___ .- -- -
r
.
. .
-59-(3) Medical Emergency Drills involving a simulated contaminated victim being I
i transported by ambulance to the hospital with subsequent treatment by the hospital staff will be conducted at least annually and may be performed
.
as part of the annual emergency exercise.
.
(4) Radiological Monitoring Drills will be conducted annually for onsite and offsite field monitoring. A team was dispatched to demonstrate proper use of monitoring equipment and sampling techniques, but the plan does not
~'
) describe how this will be accomplished or what specific procedures will be
'
tested. The communications used to direct the team and report the results also will be tested. This drill will be normally conducted during the annual exercise.
(5) Health Physics Drills are conducted semiannually and involve the response and analysis of simulated airborne and liquid samples as well as direct radiation measurements in the environment. Also simulated high radiation level liquid sampling using the PASS is demonstrated. The methods for performing these simulations and specific procedures that will be tested are not described. One of these drills may be conducted as part of the annual exercise.
)
The plan provides for the development of drill and exercise scenarios that
,
include the basic objectives and evaluation criteria, dates, time period, l
- . _ ~ . . . , . . , _ _ - - _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . - _ . . . . _ . , _ . _ _ , . _ _ ~ _ . . _ _ - . . _ _ _ _ _ _ _ _ _ _ _ _ - _ . , _ . _ _ , , _ , . _ . _ _ _ _ . . . . _ . . - _ . _ _ _ . _ _ . . _ _
.
.- _ _ . _ . - - _- __ ._. ..
.
.
Ii-60-places and participating organization, simulated events, a time schedule for real and simulated events, a narrative summary and the assignment of
'
controller / evaluators and Federal observers for exercises. Scenarios for drills will be directed by the corporate Nuclear Chemistry and Health Physics
. Department or its designee. The scenarios for annual exercises will be pre-pared under the direction of the Exercise Coordinator and will be coordinated with NRC, FEMA and other offsite authorities. The results of all drills and exercises will be evacuated and specific arrangements will be made to allow free play in the decisionmaking process. The Exercise Coordinator or the Nuclear Chemistry and Health Physics Department or its designee is responsible
^
C to critique exercises and drills respectively and report results to the VEGP General Manager to implement corrective actions.
The following items require resolution:
(1) The plan should be modified to include the backup E0F in the communica-tions drills and tests.
<
(2) A description of the methods to be used to demonstrate the proper use of monitoring equipment and sampling techniques as well as what specific
-
procedures will be used for the radiological monitoring drills should be provided and referenced.
- _ . - . . _ . . _ _ . . ._ _ . _ _ _ _ . _ , . _ _ _ _ . - _ _ _ . _ . _ _ _ _ _ _ . _ _ _ _ _ . _ _ . , . - _ - _ , _ _
.
_ . .
. - __ __. - . _ _ _. ._. _ _ _ _ _ _ . .
.
.
l -61-I
, (3) The methods for simulating airborne and liquid sampling of radioactive I
effluents and direct radiation measurements as well as the specific proce-
- dures that will be tested during health physics drills should be described
,
and referenced, i
(4) The methods for simulating high radiation level liquid u nples and the r
specific procedures that will be tested during health physics drills should be described and referenced.
i -
i s 13.3.2.15 Radiological Emergency Response Training
!
Standard
Radiological emergency response training is provided to those who may be called
.
on to assist in an emergency.
Emergency Plan Evaluation
The VEGP Emergency Plan establishes a radiological emergency response training r
program which is briefly sumarized. The extent of the training program will be documented in the VEGP procedures and follows the guidelines of INP0 82-004,
" General Employee Training Guideline" dated February 1982. Specialized train-
ing is to provide for all personnel to be,ecalled on to respond to an emergency
,
_ _ - _ _ _ _ _ _ _ _ _ _ _ _
(
\
.
.
(
-62-situation. The description of the trainir.g program provides for ten types of training subject areas for VEGP emergency personnel, local law enforcement personnel, local fire departments and state and local emergency management personnel. However, the descriptions of training subject areas do not have ,
, adequate specificity to determine if the training purposed is adequate for the
>
emergency response positions indicated. Also the emergency positions in Table !
0-2 of the plan are not adequately categorized to determine if the training
_
subject areas assigned to the positions will provide the needed training. In addition, there is no indication that a'mbulance crews and local fire fighters will be provided with basic radiation protection training as recommended in i
,
Radiological emergency response training is offered throughout the year with each subject area covered at least once a year. However, since there may be a number of different courses required within a subject area for different personnel, the adequacy of the training frequency cannot be determined, s
Improvements in the training program are to be provided from the experience obtained in the previous year's drills. Upon the completion of each training
'
session or drill participants will be asked to critique the training in order to ensure continued improvement.
,
!
.
m - _ - _ _ - - - . _ . - - _ - . - _ _ _ - - . . - - - - - . - _ - - _
f
,
,
.
-63-I In order for individuals to be qualified to fill a position in the VEGP Emergency Organization they must have received training for the specific subject areas and participated in the appropriate practical drill within
'
the past 15 months. In addition, some individuals will have additional pre-
-
?
requisites for qualification. However, it is unclear from the description
- in the plan that this additional training is mandatory.
i
-
!
The following items require resolution: l
.
l .
! '
(1) A more specific description of the radiological emergency response training
' i 3" subject areas should be provided.
(2) A more specific categorization of the emergency positions in Table 0-1 of the plan should be provided, p (3) The plan should be modified to indicate that basic radiation protection training will be provided to ambulance crews and local fire departments who have agreed to assist in fire fighting onsite.
(4) The description of the frequency with which radiological emergency response training courses will be presented should be clarified to ensure that an adequate number of courses within each subject training area are presented.
_ _ _ _ _ - _ _ - _ _
. _ _ _ _ _ _ _ _ _ _ _ _ - _ _ . __
.
.
I-64-(5) The requirements for additional prerequisites for certain emergency personnel should be clarified to indicate that they are mandatory.
, 13.3.2.16 Responsibility for the Planning Effort: Development, Periodic
'
Review and Distribution of Emergency Plans
..
Standard Responsibilities for plan development and review for distribution of emergency
^
plans are established, and planners are properly trained.
Emergency Plan Evaluation The Vice President-Nuclear Operations has overall responsibility and authority j for all nuclear activities including emergency preparedness programs. The corporate manager of nuclear chemistry and health physics has the responsibili-ty for emergency planning and preparedness and this departnent is responsible for developing and maintaining emergency plans and coordinating them with other ( response organizations. The emergency preparedness coordinator at VEGP, who reports to the plant superintendent - health physics coordinates emergency planning and preparedness at VEGP and in the vicinity of the plant. An organ-izational chart of the emergency preparedness functions is provided in Figure
'
P-1 of the VEGP Emergency Plan.
,
i
.
_. _ _ - - - - - - - - -
. _ _ _ _ - _ _ _ _ . _
.
a l -65-Approved changes to the VEGP Plan are forwarded to key organizations and appropriate individuals responsible for implementing the plan. Revised pages are dated and marked to indicate where changes have been made, but there is no j description of how these changes are distributed to ensure that all copies of l- the plan are updated. Telephone numbers referenced in the EPIPs are updated l
quarterly. .
-.
An independent review of the emergency program is conducted annually and the interval between reviews will not exceed 15 months. However, the plan does not
,
.._
1.s indicate who will perform this independent review and the methods by which the
l
.-- managenent will implement and evaluate the review findings. Also the plan does not indicate how management will ensure that defects or problems uncovered as j
the result of exercises and drills are corrected. Records of reviews will be maintained for at least five years.
l l A list of supporting emergency plans for the VEGP Emergency Plan are provided l
( in Section P of the plan. Appendix 9 of the plan provides an index of EPIPs, hcuever, the list appears to be somewhat incompleted. For example, all the
normal station operating and health physics procedures which are to be used or referenced in the VEGP Emergency Plan are not included in this list.
.. .
_ _ - _ _ _ _ _
______ _____________________ _ _ _ _____ ___________ ________ ________ _ __________ ___
-
- .
-66-The following items require resolution:
(1) A description of distribution of the VEGP Emergency Plan and the methods used to ensure that all copies are furnished with updates should be
. . provided.
>
,, (2) The individuals or organizations who will perform the independent annual review of the VEGP Emergency Plan should be indicated.
.
(3) The administrative procedures by which changes and corrections to the plan resulting from exercises and drills are incorporated, as well as how the findings of the independent review are evaluated and implemented should be
'
described (4) All the normal station operating and health physics procedures which are to be used or referenced in the plan should be listed in Appendix 9.
.
13.3.3 Conclusion l
On the basis of our review the Vogtle Electric Generating Plant, Units 1 and 2 Emergency Plan for conformance with the requirements of Appendix E of 10 CFR 50, and the specific criteria in NUREG-0654/ FEMA-REP-1 which addresses each of the planning standards of 10 CFR 50.47(b), the staff concludes that a final evalua-tion of adequacy cannot be made until the applicant provides additional
.
_ - _ _ _ . _ . - _ _ _ _ - _ - _
__ _
l
,
-67-information including revisions to the emergency classification system, the emergency data acquisition system, the dose projection system and the meteoro-logical models for transport and diffusion, and the evacuation time studies.
Further evaluation of the Emergency Plan and a determination of the adequacy of the planning basis for an acceptable state of onsite emergency preparedness will be provided in a supplement to the SER. _
.
After a review of the findings and determinations made by FEMA on the adequacy of state and local emergency response plans, and of the revisions to the
., applicant's emergency plan requiring resolution and commitment as identified
~
in Section 13.3.2 of this report, a supplement to the SER will provide the staff's overall conclusions as to whether the state of onsite and offsite emergency preparedness provides reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.
_ _ _ _ _ .
.
Enclosure 2
. l List Of Unresolved Items From The Vogtle SER Not Previously Identified To The Applicant
>
Subsection 13.3.2.1 Assignment of Responsibility (Organization Control)
(3) Additional information should be provided on the DNR State Emergency Coordinator with regard to his functions, location and 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> avail-ability, the methods DNR will use to assess accident conditions at VEGP to determine if an emergency should be declared, how DNR advises the Governor of Georgia to make such a declaration and clarification of the manner in which DNR and GEMA coordinate their activities and respon-sibilies during an emergency.
f' Subsection 13.3.2.2 Onsite Emergency Organization (2) The method and procedures to be used to transfer the position of Emergency F Director from one individual to another should be described.
Subsection 13.3.2.3 Emergency Response Support and Resources (1) The plan should specify the local comunications and other local resources available to support the Federal response.
Section 13.3.2.5 Notification Methods and Procedures (2) The individuals, methods and procedures to be used to activate the NOAA Alert System and the EBS stations should be described.
(5) The methods, procedures and individuals who will activate the vehicles and boats, including their deployment and location should be described.
Subsection 13.3.2.6 Emergency Comunications (1) The comunications capabilities of the backup EOF should be described.
Subsection 13.3.2.8 Emergency Facilities and Equipment (3) The description of the TSC ventilation system should be clarified.
(4) The data system or methods to provide meteorological, seismic ~and fire detection information to the ERF Computer System or the ERFs should be described.
(5) The backup power for the ERF Computer System or the methods for providing data acquisition and assessment to the TSC and E0F if power to the system fails should be provided.
(9) The description of how the damage assessment and control teams obtain their equipment, drawings, manuals and other materials sMuld be provided.
_. . _ . -
. _ _ - . -
..- . - _ _ - _ - - . , . - . - . _ - -, .. . .
. _ . _. _ - - . _ . .__ _
I-2-(10) A description of the methods to be used to relocate and operate the OSC in the TSC should be provided, i
(13) The address and the distance of the backup E0F from VEGP should be l provided.
l (14) A description of the methods to transfer and carry out the EOF functions in the TSC and then in the backup EOF should be provided.
(15) A general layout of the functional areas and equipment for the backup EOF f should be provided.
(19) The applicant should provide a comitment that either the final ERFs will be completed and operational prior to fuel loading or that adequate interim facilities will.be in place.
Subsection 13.3.2.9 Accident Assessment (2) The methodology using PASS and PERMS to determine plant conditions and release rates as well as the charts and graphs to correlate these readings should be provided or described in adequate detail for evaluation.
(5) A description of methodology for deploying field monitoring teams and '
providing vehicles with two-way radios should be provided.
(9) A description of the fixed field monitoring system, instrumentation, a map illustrating the monitoring locations and methodology should be provided.
(10) A description of the system for coordination of field monitoring between VEGP, Federal, State and/or local monitoring teams should be provided.
(12) A description of the methodology for using field monitoring data to refine dose projections and modify protective action recomendations should be
.
provided.
Subsection 13.3.2.10 Protective Response
!
(1) The criteria for determining that nonessential onsite personnel should be evacuated from the site should be provided.
(8) The plant procedures for recomending a precautionary evacuation offsite should be described and referenced.
(9) Information on where and how evacuees and residents from the plume exposure pathway EPZ will be relocated and sheltered during an evacuation should be provided.
~
- . - ...
-
. - ,-,,-------,n --v.,- - - , ,--,,.,,,n ,,,,, . -.-..--- - - ..,., . - - --- - . - .- . - , , , -- - ---,. . . -,-
,
.
-3-Subsection 13.3.2.11 Radiological Exposure Control (2) The methods or procedures for maintaining personnel emergency exposure records and exposure should be described.
(3) The criteria for more frequent reading of TLDs and the methods to detennine radiation dose 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day should be provided.
, - (4) The exact location of onsite personnel decontamination facilities and their
, capabilities should be described.
Subsection 13.3.2.12 Medical and Public Health Support
-
(1) The availability -of personnel trained in first aid and decontamination pro-cedures onsite 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day should be clarified.
(3) A description of the capabilities of the Humana Hospital to handle contami-nated patients should be provided.
,
(4) The health physics support and procedures to be used a the Burke County and Humana Hospitals should be described.
Subsection 13.3.2.13 Recovery and Reentry Planning and Post-Accident Operations (2) The criteria for reading TLDs and assessing radiation dose more often than on a monthly basis should be provided.
Subsection 13.3.2.14 Exercises and Drills (1) The plan should be modified to include the backup EOF in the comunications I drills and tests.
13.3.2.15 Radiological Emergency Response Training (1) A more specific ~ description of the radiological emergency response training subject areas should be provided.
(2) A more specific categorization of the emergency positions in Table 0-1 of the plan should be provided.
(4) The description of the frequency with which radiological emergency response training courses will be presented should be clarified to ensure that an adequate number of courses within each subject training area are presented.
(5) The requirements for additional prerequisites for certain emergency personnel should be clarified to indicate that they are mandatory.
_
.
-4-13.3.2.16 Responsibility for the Planning Effort: Development, Periodic Review and Distribution of Emergency Plans (1) A description of distribution of the VEGP Emergency Plan and the methods used to ensure that all copies are furnished with updates should be provided.
(2) The individuals or organizations who will perfonn the independent annual
,
review of the VEGP Emergency Plan should be indicated.
'
(3) The administrative procedures by which changes and corrections to the plan resulting from exercises and drills are incorporated, as well as how the findings of the independent review are evaluated and implemented should be described. . ,,
I
!
I