ML18040A929
| ML18040A929 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 04/10/1989 |
| From: | Hansell J PENNSYLVANIA POWER & LIGHT CO. |
| To: | Obrien K LUZERNE COUNTY, PA |
| Shared Package | |
| ML17156B118 | List: |
| References | |
| PLE-11374, NUDOCS 8904240055 | |
| Download: ML18040A929 (7) | |
Text
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ACCESSION, NBR:8904240055 DOC.DATE: 89/04/10 NOTARIZED: NO DOCKET FACIL:50-387 Susquehanna Steam Electric Station, Unit 1, Pennsylva 05000387 50-388 Susquehanna Steam Electric Station, Unit 2, Pennsylva 05000388 AUTH.NAME AUTHOR AFFILIATION HANSELL,J.B.
Pennsylvania Power 6 Light Co.
RECIP.NAME RECIPIENT AFFILIATION O'RIEN,K.
Wilkes-Bar re, PA
SUBJECT:
Forwards first draft of Hazardous matl emergency offsite R
response lan a questions s
comments.
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- Plans, Implement'g Procedures, C
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Pennsylvania Power 8 Light Company Two North Ninth Street
~ Allentown, PA 18101
~ 215/ 770.5151 April 10, 1989 Mr. Kevin O'rien Operations and Training Officer Luzerne County Emergency Management Agency Luzerne County Courthouse Wilkes-Barre, PA 18711 SUSQUEHANNA STEAM ELECTRIC STATION HAZARDOUS MATERIAL EMERGENCY OFF-SITE
RESPONSE
PLAN CCN 741326 FILE R9-6 PLE-11374
Dear Mr. O'rien:
The Pennsylvania Power and Light Company (PPItL) is submitting the first draft of the Sus uehanna Steam Electric Station Hazardous Material Emer enc Off-Site Res onse an or your review.
P ease 1 entify any portions of the P an whic require c arification, elaboration, etc.
We are also enclosing questions and comments regarding the guidance document provided by PEMA, as discussed in our phone conversation.
These questions and comments need to be resolved for us to finalize the Plan.
If you have any questions, please call Gregg Shields at (215) 770-5142, or me at (215) 770-7887.
Respectfully, ohn B. Hansell, Jr.
Environmental Scientist-Nuclear gasltc8393c(25) cc:
N.R.Butler NRCD Enclosures 4~4o0SS 8904g0 PDR ADOCK 05000387 F
PNU
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Pennsylvania Power & Light Company Two North Ninth Street
~ Allentown, PA 18101
~ 215 I 7705151 April 10, 1989 Mr. Kevin O'rien Operations and Training Officer Luzerne County Emergency Management Agency Luzerne County Courthouse Wilkes-Barre, PA 18711 SUS(UEHANNA STEAM ELECTRIC STATION HAZARDOUS MATERIAL EMERGENCY OFF-SITE
RESPONSE
PLAN CCN 741326 FILE R9-6 PLE-11374
Dear Mr. O'rien:
The Pennsylvania Power and Light Company (PP&L) is submitting the first draft of the Sus uehanna Steam Electric Station Hazardous Material Emer enc Off-Site es onse an or your review.
ease 1 ent1 y any portions of the an w 1c require c arification, elaboration, etc.
We are also enclosing questions and comments regarding the guidance document provided by PEMA, as discussed in our phone conversation.
These questions and comments need to be resolved for us to finalize the Plan.
If you have any questions, please call Gregg Shields at (215) 770-5142, or me at (215) 770-7887.
Respectfully, hn B. Hansell, Jr.
Environmental Scientist-Nuclear gasltc8393c(25)
CC:
Enclosures
+lr.r p~R~24OOSS 8904iO PDR ADO'SOOO38 PNU
Attachment COMMENTS AND QUESTIONS ON ANNEX F-GUIDANCE DOCUMENT FOR DEVELOPMENT QF HAZARDOUS MATERIAL EMERGENCY OFF-SITE
RESPONSE
PLAN 1)
No requirement for establishing a Table of Contents for the plan was given.
The established subdivisions make it difficult to determine where a given item can be found.
Me are proposing to add a Table of Contents with revised subdivisions.
2)
Page F-30 Section 2.A - Situation No guidelines were given on the establishment of an evacuation distance.
Acceptable guidance documents should have been suggested.
The U.S.
Department of Transportation - 1987 Emergency
Response
Guidebook was used to establish the evacuation distance for the SSES.
This reference specified a distance and a width for evacuation downwind and another distance for evacuation in all other directions.
Annex F requires that an evaluation radius be given; however, it does not specify how this is to be arrived at.
The plan developed for SSES reflects a worst case scenario involving fuming sulfuric acid (i.e.: evacuation of a 3 mile radius) and accordingly evaluates potential impacts and planning concerns only within this radius.
Questi'ons arise as to whether this is the proper methodology.
3)
Page F-30 Section 2.B - Summary of Hazardous Material Vulnerability Analysis The guidance plan does not specify what this analysis is to include.
Me have included Reportable Quantities (RQs) in this analysis although this is not required.
4)
Page F-33 Section 3.D. 1 - Types of Releases Requiring Notification This section requires some clarification and should be more consistent throughout.
The following changes are suggested for Sections 3.D. l.a, 3.D.1. b and 3.D.l. c:
D.
Emergency Notification Reporting responsibilities under SARA and CERCLA are separate.
Reports may be required under either or both statutes if the release is not Federally permitted and if it meets the Reportable Quantity (RQ) criteria below.
1.
Types of Releases Requiring Notification a.
SARA/CERCLA Substance 1
Requires SARA notification because it is yn Extremely Hazardous Substance, and CERCLA noti'fication because it is a
Hazardous Substance if:
( 1) equal to or exceeding SARA Extremely Hazardous Substance Rg given in 40 CFR 355, and (2) or exceeding CERCLA Hazardous Substance Rg given in 40 CFR 302.
b.
SARA/Non-CERCLA Substance Requires SARA notification because it is an Extremely Hazardous Substance, but does not require CERCLA notification because it is not a Hazardous Substance, if:
( 1) equal to or exceeding SARA Extremely Hazardous Substance Rg given in 40 CFR 355, and (2) it is not a CERCLA Hazardous Substance listed in 40 CFR 302.
c.
CERCLA/Non-SARA Requires CERCLA notification because it is a Hazardous Substance, but does not require SARA notification because it is not an Extremely Hazardous Substance if:
( 1) equal to or exceeding CERCLA Hazardous Substance Rg given in 40 CFR 302, or (2) it does not have a final CERCLA Rg established in 40 CFR 302, but exceeds one pound or more as specified in Chapter 102(b). of CERCLA, and (3) it is not a
SARA Extremely Hazardous Substance listed in 40 CFR 355.
5)
Page F-34 Section 3.D.2.c - Transportation Accident Notification Notification procedures require clarification.
Responsibilities of the carrier, the LEPC, and the accident responders should be more clearly defined.
Also, note that the National
Response
Center must be notified if, in addition to being a
SARA Extremely Hazardous Substance, the released material exceeds the CERCLA Hazardous Substance Rg.
6)
Page F-34 Section 3.D.3.a - Initial Report This section does not state that this is a verbal (telephone) report and does not state who is to give the report; note that it is the Facility Owner/Operator.
The Facility Owner/Operator may, however, not be the party giving the initial report if a transportation accident is involved with the release.
2
7)
Page F-36 Section 3.F - Protective Actions It is suggested that more guidance be given on this section.
What is the status on expanding this?
8)
Page F,-37 Section 4.C - Assignment of Responsibilities The actual names of responsible individuals should probably be given and updated annually.
Oo all of these people/positions actually exist?
Also, it is not clear at which governmental level the various responsibilities will take place (i.e.:
- state, county, or local), and how these different levels interface with the facility.
Another issue that should be addressed is that some of the responsibilities'ary from established procedures.
For example, the police chief would be charged with providing route alerting for the County EHC if evacuation is required.
County and municipal "All-Hazard" Emergency
Response
Plans use local municipal emergency management agencies to provide this function.
Instead of reinventing the wheel, it would be best if we perform all offsite functions in the framework which is currently established and tested.
It would be much clearer to just reference the county and municipal all-hazard plans when dealing with providing protective actions to the pubic'.
9)
Page F-58 Enclosure 1 - Release Reporting Decision Chart This flowchart has been reproduced to make the decision making process easier to read and understand since the original was of poor quality.
gas/rpc1647i (13) 3