ML17193A013

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Forwards Review of Util Generating Station Emergency Plan & Draft Ltr Requesting Addl Info & Commitments from Util
ML17193A013
Person / Time
Site: Dresden, Quad Cities, Zion, LaSalle  Constellation icon.png
Issue date: 08/28/1980
From: Pagano F
Office of Nuclear Reactor Regulation
To: Varga S
Office of Nuclear Reactor Regulation
References
NUDOCS 8009100378
Download: ML17193A013 (5)


Text

August 28, 1980 Dockets Nos. 50-10/~254; 50-249/265; 50-295/304; and 50-373/374 MEMORANDUM FOR ;<*'"steve Varga, Chief

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Operating Reactors Branch #1 Division of Licensing Frank G. Pagano, Acting Chief Emergency Preparedness Licensing Branch GENERATING SliATIONS EMERGENCY PLAN (GSEP) REVIEW We t1'ave completed the review of Commonwealth Edison Company's Generating Stations.Emergency.*P:lan (applicable to Dresden, Quad-Cities, Zion, and LaSalle).* Additional information and commitments are req~ired before we can conclude that the emergency preparedness program meets the criteria of NUREG-0654.

It is requested that a letter, similar to the sample enclosed, and our review comments be sent to the licensee.

The revised plan should be submitted within the time specified to permit an orderly review..

Enclosure:

Sample Letter and Review Comments cc w/enclosure:

T. Ippolito B. J. Youngblood

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LEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 Dockets Nos. 50-10/237/254; 50-249/265; 50-295/304; and 50-373/374 Commonwealth Edison Company ATTN:

Mr. D. L. Peoples Director of Nuclear Licensing P. 0. Box 767 Chicago, IL 60609

SUBJECT:

GENERATING STATIONS EMERGENCY PLAN (GSEp) "REVIEW Gentlemen:

The staff has completed its review of your submittals dated January 3, April 4, June 18, and July 30, 1980, relating to prompt improvement of emergency preparedness associated with the Dresden, Quad-Cities, Zion and LaSalle Stations.

Based on our review, we conclude that your revised emergency plan (July 30, 1980, Revision 1) and its associated site specific:annexes me~t the requirements df 10 CFR 50, A~~endix E, and the regulato~y positions of Regulatory Guide 1.101 and NUREG-0610.

In addition, the staff has reviewed this emergency plan against the criteria stated in NUREG-0654.

Our review has indicated that additional information and commitments are required before the staff can conclude that your onsite emergency preparedness program meet the criteria. A detailed discussion of our comments was held with members of your staff.

Enclosed are the staff comments.

We request your emergency plan be revised to address these comments and a revision to the plan provided to'us within two months of receipt of this letter.

Regarding licensing of the LaSalle Nuclear Station, your upgraded emergency response plan must be in substantial compliance with NUREG-0654, except that only a description of and completion schedule for the means for providing prompt notification to the population (Appendix 3 of NUREG-0654), the staffing for emergencies in addition to that already required (Table B.1 of NUREG-0654) and an upgraded meteorological program (Appendix 2 of NUREG-0654) need be provided.

In addition, NRC will give substantial weight to the FEMA finding on offsite plans in judging the adequacy against NUREG-0654, and an emergency response exercise designed to test the integrated capability of the emergency preparedness plans must be conducted before issuance of the Operating License.

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-- In our view, your emergency plan dated July 30, 1980, reflects improvement over your existing plan and gives a greater margin for public health and safety. Since the revised plan does not downgrade the effectiveness of your emergency preparedness, you should begin to implement this revision.

We understand that-this plan was implemented as of July 1, 1980.

Enclosure:

Comments on Commonwealth.

Sincerely, Steve Varga, Chief Operating Reactors Branch #1 Division of Licensing Edison Generating Stations Emergency Plan cc w/enclosure: See next page

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COMMENTS ON COMMONWEALTH EDISON GENERATING STATIONS EMERGENCY PLAN (GSEP) AND SITE SPECIFIC ANNEXES FOR DRESDEN, QUAD-CITIES, ZION AND LASALLE NUCLEAR STATIONS DOCKETS NOS. "50-10/237/254; 50-249/265; 50-295/302; 50-373/374 The following comments are listed in NUREG-0654 format:

B.

Onsite Emergency Organization

-T~bles DA4~2* (Dresden Annex), QCA4-l (Quad-Cities Annex), and LA4-2

  • (LaSalle Annex) do not m~et the minimum shift* staffing requirements for emergencies as per Table S-1 of the criteria. Provide a description of*and completion *schedule for meeting this requirement.

Table ZA:4-l (Zion Annex) is adequate for a dual unit site. For the Dresden site, sixteen personnel per shift are required - *ten personnel per shift as indicated in Table B~l, plus two additional shift foremen, two control

  • room operators, and two auxiliary operators.

Figure 4.2-2 {Generic GSEP) provides guidance for augmentation of the onsite emergency organization.

At this time, your plan states shift augmentation can be achieved within 60 minutes.

In addition, provide a description of the current capabilities, by functional area, which can be achieved within 30 minutes and 45 minutes.

E.

Notification Methods and Procedures The generic GSEP and site annex do not address the administrative and physical means, and the time required for notifying and providing prompt instructions to the public within the plume exposure Emergency Planning Zone.

(See Appendix 3 of the criteria). Provide a description of and a completion schedule for meeting this requirement.

G.

Public Information

- The GSEP commits to provide annual dissemination of information to the public regarding how they will be notified and what their action should

  • be in an emergency.

Further, the GSEP commits to implement this by January 1, 1981.

Provide a sample of this public information program to us for our review prior to implementation.

H.

Emergency Facilities and Equipment This section i~ adequate to meet the short term Lessons Learned for operating reactors. However, when long-term Lessons Learned criteria for the Technical Support Center and Near-Site Emergency Operations Facility are completed, the GSEP should be revised to include as-built diagrams of these facilities.

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2 The GSEP and the Dresden, Quad-Cities, and LaSalle Annexes do not pro-vide meteorological instrumentation and procedures which satisfy the criteria in Appendix 2. Specifically, the plan indicates that the meteorological program does not provide measurement of standard deviation of wind direction (sigma theta) at all measured levels or precipitation

  • measurements near ground lev~l. Further, the plan does not indicate a Quality A~surance Program consistent with applicable provisions of 10 CFR 50, Appendix B will be maintained nor does the plan indicate what provisions are available for redundant power sources to the equipmen~.

The ~te specific annexes for Dresden, Quad-Cities, Zion, and LaSalle do not indicate what emergency equipment _is available to the onsite Operations Support Center.

Provide a general list of emergency equipment (e.g., respiratory protection, protective clothing, and portable lighting) which will be available to this center.

  • J. Protective Response The plan does not provide the basis for the choice of recommended pro-tective actions from the plume exposure pathway (e.g., dose reduction factors (ORF) from sheltering in residential units).

Further, the site specific annexes do not provide evacuation time estimates for areas near the nucl~ar plant. A summary of these times for the various sectors should be included in the plan. These times and the ORF for the affected sectors should help to for~ the bases for recommending sheltering or evacuation.

M.

Recovery and Reentry Planning and Postaccident Operations The plan does not provide a method for periodically estimating total population exposure.