ML19256B666

Responds to Re Inadequate Emergency Evacuation Plans.Ltr Treated as Request for Formal Hearing.Forwards Order Issued to Util Requiring Design Mods & Changes in Operating Procedure.W/O Encl

ML19256B666
Person / Time
Site:	Davis Besse
Issue date:	05/17/1979
From:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Lodge T TOLEDO COALITION FOR SAFE ENERGY
Shared Package
ML17338B295	List: ML17338B294 ML19256B637 ML19256B639 ML19256B641 ML19256B645 ML19256B647 ML19256B651 ML19256B657 ML19256B661 ML19256B663 ML19256B666
References
NUDOCS 7908160306
Download: ML19256B666 (1)

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May 17, 1979 Mr. Te r ry J. Lo d ge, Chai r. san Toledo Coalition for Safe Energy P.O. Box 4545 Toledo, Ohio 43620

Dear Mr. Lodge:

TDis is in reply to your letter of AC-11 24, 1979, identifying steps schich you believe chould be taken relative to rest._.ption of op erations of the Davis-Besse nuclear plant.

As you probably know, based on infor:4-tion obtained to date from the Three Mile Island accident, the NRC issued an Order to all operating reactor licensees cuning 3abcock and Wilcox Co=pany cucient steam supp1v systens, including Davis-Besse, requiring certain design =odifications and changes in opcrating procedures. A copy of the Order to Toledo Edison-Co=pany is provided ar an enclosure.

The reactor will not be permitted to return to operation until the actions specified in the Order have been completed to the natisfaction of the NRC.

With respect to the actions specified in your letter, we are creating your letter as a request for a for=al Hea ring in accordance with part 2.206 of the NM: Rules and Regulations (Title 10 - Chapter 1 Code of Federal Regulations).

As such, I have forwarded your let tdr to our Headquarters staff for consideration of your request.

You can expect to hear directly from them regarding this matter.

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If you have additions 1 questions regarding the NRC's actions :.n this natter, please let =e know.

Sin ce rely,

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James G.

Ye 1er Director

Enclosure:

s pA Order to Toledo Edison Cc=pany bec v/o enclosure:

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q9 Mr. James G. Keppler, Director

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Nuclear Regulatory Commission, Region III r

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Dear Mr. Keppler:

We have foilowed with considerable interest the actions of the NRC and Toledo Edison, operator of the Davis-Besse nuclear plant, since the Three Mile Island disaster.

After reading your comments in the April 20, 1979 Toledo Blade concerning personnel performance at Davis-

- Besse, we are greatly concerned about the irresponsibility of the NRC decision to allcw Davis-Besse to go back on line before numerous safety questions have been answered.

Our concerns have been redoubled by the' April 19 findings of the Ohio Public Interest Research Group (OPIRG) that documents the gross inadequacies of emergency and evacuation plans in the event of a serious accident at Davis-Besse. The NRC appears to be an accomplice in a no-win situation, allowing a less-than-public spirited utility to return to power generation while that utility continues to maintain incompetent staff and substandard emergency preparations.

Therefore, the Toledo Coalition for Safe Energy de.mands that the folicwing steps be taken by your office immediately:

That Toledo Edison officials be restrained from reope.ning Davis-1/

Besse until such time as all possible operational problems, human and mech-anical have been corrected; That revised and updated evactsation plans be posted in visible 2/

public places within a 50 mile radius of Davis-Besse within 30 days of your receipt of this notice, and prior to D-B's reopening; That a full-scale disaster drill be conducted within a 10 mile 3/

radius of the plant prior to its return to power generation; That all consumers in the Toledo Edison and Cleveland Electric 4/

Illuminating jurisdictions receive a complete written description of emergency procedures with their las+ electric bills prior to the startup of Cavis-Besse; That these and other matters become the subject of full and 5/

Open public hearings initiated by the NRC prior to D-S's startup.

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Your earlest written response to these urgent requests will be

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C Mr. Ja5es G. Tep?ler 4/24/79 Pg.,2 greatly appreciated.

Thank you.

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TCSE Legal Acticr Cocini ttee cc:

Members, U.S. Nuclear Regulatory Corr. mission Washington, D.C. 20555 Senator Hcward Metzenbaum 234 Summit St.

Toledo, OH 43604 O

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j frscuency,0f Err' ors By Personne A7. Javis-Besse s lrickr NRC Sfudy.

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specine valve at the faciUty. Ir. stead of worrisc=e that an NRC inspecter re-

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he tur=* c'=ur ured Mr..Keppw e shut ce &-

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9 off two other valyes - a rnistake that plut down and keep it closed untd the.--

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situation could be ccrrected.

,ii J By MICIIAEL WOODS. !... partial y inactivated the reactor's Davis-Besse currendy remains shut G

crucial ernergency ccre coolleg system.

M at so.,o e,r WASHINGTON - ne US Nuefear, The Toledo Edhon Co., which h'as down, fotowkg a scheduled outage for cabtenance. Mr'. Keppier said he does M

r-Regulatory Commission is trying to de. charge of operat!ocs at Davis.Besse,rnay be fined for r?E term.ne why Be Davis-Besse Nuclear

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Power Station near Toledo coctbues to pier said. Toledo Edison is co-owner of plut shot

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surance from Toledo Edison Preside:t be plagued by as unusuaUy high number Davis.Besse, z!oeg with the Cleveland John Winianson that operauc

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5 of person =el errors."

Davis-Besse has come under sharp resume untd the'pe soccel problem is James Keppler, director of NRC's sched ~ j, my *,'.

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Chicago regional office, said the fr,. NRC scrutby in recent weeks in the No Action To Prevent Restart

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queccy and pote=tial seriousness of mis. aftermath of the accident at the Three 55 takes made by p!act persoccel have giv Mile IsInd nuclear power plant near NRC has taken :o actica t'.;at w 7==

prevent' Edison 'fio:n restarti=g Ge

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en Davis.Besse one of the poorest repu. Hum. turg, Pa. -

Davis desse's reactor !s a sister to the plant irnmediately. Tech::ically, all 6 ~

-J tatiocs for operator precision la the re. reactor at Threa Mile Island, eth hav-Edison would have to do is nctify NRC U ~

ne Chicago regional effice oversees ing been built by Ge nuclear engineer og its p3,.3 to. 80 gion..

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ici firm of Babcock & Wilcor. In addi' plut.

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": i 21 nuc! ear pcwer pMts spread through tion, NRC has identifled malfunctions Anocer factor, Mr. Kepp'er saic, is t May of the persoccel. errors at simdar to those at nree M13e Island that Edison perso=el at th 5

a broad section of th Udwest.

Davis Besse have been mi:or, Mr. Kep. that occurred in less serious for=s early seem capable of cperating 1-J 2.2

. 1.2 pler said. But others have involved in the operatinglife cf Davis-Besse.

a " passable f ashica.-

If"he were to rate operater per-5.-

crucial safety systems, where mistakes Shatdown Urged The plant's contbulcg problem with formance there on a " pass f a

carry the potential for the : nest serious personnel errors, which Mr. Keppler dis-Mr. Keppler said he would c

.g kinds of cuclear reactor ace: dents.

Turned Off Wrong Valves cussed during an bterview nursday, passing grade.

Mr. Keppler cited, as an iUustration, are an additional factor.

Mr. Kepler said that mistakes by per-Turn to Page 7 Col. 3

._.~I one incident la:t month in which a plant

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2 j iHE' BLADE:. TOLEDO,. OHIO,. FRIDAY,. APRIL 20, 1979 E

r.1 Javis-3 esse Personne Errors L,ncer Stucy L

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Continoed fromT!nt Par

' Besse in the mont5s foUowing startup in 'Besse shut down until be is cer.ain bat Performance of plant perso operation can resume safely.

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'T?rn cut he also. dicatedht on a scale

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personnel errors have remained g

gg to q] of A, B, C, D, or F, he probably wocid

'. y high at the plant and show noti:g Sat operators - sorne cf whom E.5

_. _i de pla t personnel performaace mth dicat2ca of drcppirg off after two M2 +cd'm'

_ =g years of cperating experience.

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-=m eld here Apr:1 5, a week after the Poor Mottratfoc, DiscipHme Assuring. Complete Safety giy ne rea: ens, Mr. Keppler said, are Scme of the plant oparators wiU be trai ed shcr*.ly in new procadcras ste Davis-Besse's ceetbuirgbroblems. John's'o!CQ.rplexing. A=20cg" the possibilities

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insp *ctien Aid enforce =ent, noted dur. ping cocsidered by NRC are I:

mi:g froc2 'he tree Mile Isbed ec2-

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'..:. 5 irg the =eeting "If we did have a rat.g'trabmg of the operators, poor :nctiva. dent. Tra==, g will be en a ec=puter j

' !:g system of A, B, C, we would putt tfon, and poor disciplice. Ironically plant simu!ator at ce Babcock & WI'ecx cu-TZ W' Dap.3-Besse C on this scale. It should be persoccel secred wen on the federal c! ear facility in Lynchburg.,Va.

V Ucensing esminatics for re~ actor opera.

a bettqlast."

n'e primary concern at this point is [

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15~5 Mr. KeNder ack=owj.t'.g 1 per tors, Mr. Keppler noted-assuring cc:nplete safety of the pMt

= 7 so=e1 errors do tend tn be more fre-Mr. Keppler said that Edson rean es and not the eccoomic imp.act of de

-- - -__ pe:t duricg the early :noncs of opera-that there have been problems with per. shutdow 2, he ::oted. Mr. Wa"-: said

.ti:n at any cew atomic power plast, sonnel at the plamt and has ag eed to it probably mil be a catter of weeks, p

" when the staff is oew and relatively submit a p'.an for cor-ecting them.

rather thu dap or :no:ths, tefore ce j --

7' Mr. Wdila= son said Thursday be has V lisexperienced. A=d, indeed, personnel......

.a A.%,,,4 W Cans-pla t is set to res;=e operstmcs.

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J OHIO PUBLIC INTEREST RESEARCH GROUP hll ) u (7, hSTATE OFFICE 65 S. 4th ST. COLUMBUS, OHIO 43215 -[6141 461-0136 OTHER CFFICES: CBERLIN COLLEGE, WITTENBERG UNIVEBSITY,

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UNIVERSTTY OF CAYTON, WILMINGTON COLLEGE, CAPITAL UNIVERSITY FOR IMPEDIATE RELEASE O II O' Wednesday, April 18, 1979

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Janis White 614-461-0136 p3 p @,, g 614-299-8827 2

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Kathy Vestby

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216-775-8137 CC

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216-775-5283 3

ra EMERGENCY EVACUATION PLANS AT DAVIS-BESSE PLANT INADEQUATE Plans to safely evacuate the residents of the area near the Davis-Besse nuclear pcwer plant in case of a nuclear accident appear to be inadequate, acecrding to the Ohio Public Interest Research Group (CPIRG).

The group has called for a full scale evacuatien drill before the plant reopens.

"Ve have discovered that neither the utility nor the state emergency plans meet all the recc. mended federal guidelines and that the two pl ans d,i f fer in r:nny aspects which could affect the srnooth functioning of an actual evacuation,"

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said Kathy Vestby, research ccordinator.

" Government and utility persennel charged with responsibilities in the plans do rot always knew what these respensib i f itles are," Ves thy said.

Developing and implementing emergency evacuation procedures are the joint respcasibility of the Tcledo Edisen Co., the operater of the Davis-Besse plant, and the Chio Disaster Services Agency.

The util i ty pl an, filed with the Nuclear Regulatory Cc.mi ssion, covers emergency precedures within the plant and pl ans for off-site support by government agencies.

The state's draf t plan, incomplete at :heugh the plant has been in operatien, establishes the roles and respcnsibil-

.8 ities of government personnel in the event of' an emergency.

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According to Vestby, the only employee of the Ottawa County Disas ter Services

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Agency was not aware tha t he is s'e,cosed to play a moJor role in evacuating residents and arranging for their relocation.

Ins tead, he believed his role was

. a minor one, simply to act as a liaison between the plant and state officials d

to provide needed support af ter the accident.

One fire of ficial said, "We don't have any of that wicked stuff [ dangerous radiation] here (at the plant]." He told OPIRG researchers he had formed this p

cpinion based en information he had received frem Davis-Besse officials.

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The utility c mpany is required to centract with two hospitals for the provision of emergency medical services.

The principle hospital identified in the utility plan is the Hagruder Memorial Hospital, in Port Clinten, approximately eleven miles frem the plant.

They are only equipped to handle up to 80 sericus radiological victims.

Tne second hospital named in the plan is the University of Pennsylvania Hospital in Philadelphia. An administrator at Magruder however, though t the

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second hospital was probably St. Charles Hospital in Teledo and was totally cna <are of the role of the University of Pennsylvania Hospital.

"Given the fact that the primary hospital is within the possible radiation -

ene, and that the other one is almost 400 miles away with no apparent plans for transporting victims, makes us question the adequacy of medical previsions in the plan," said Vestby.

Current plans would evacuate residents within a 2 mile radius of the plant, althcugh there ha s been some recent discussion of er. tending that to a 20 mile

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"A full scale nuclear accident could affect an area the si:e of Pennsylvania.

Vhat scod would these plans do us then?" said Janis White, Di rectcr of OPIRG.

"Even if a less serious accident occurred, it could become necessary to

evacuate the Toledo area which is only 35 miles from the plant," she added.

The ? state draft plan equates nuclear evacuation procedures wi th those used of a natural disaster such as floods or high water.

In the even

" Nuclear accidents and natural disasters are not equivalent and cannot be Differences in warning tibes and signals, as weil as handled in the same way.

the health hazards connected with radiation exposure require special considera-tion for a nuclear emergency.

By comparing the two, the s tate is demons trating its lack of awareness of the real dangers of a nuclear disaster," White said.

"Neithey plan meets all the reccamended federal guidelines," Vestby added.

"For instance, estimates of expected accident assessenent times, evacuation times, or traffic capacities of evacuation routes are not mentioned at all in the plans."

Our r'esearch "0PIRG quastions the eff'ectiveness of these plans.

Indicates that they are ambiguous, contradictory, inccmplete, and un-tes ted," said Ves tby.

"A few of the agencies listed in the plans have held their own practice drills, but no coordina1:ed, full scale drills have been conducted based on the "The public ha~s never been told how they will be con-plans," centinued White.

tacted or what they should do in case of a nuclear emergency."

"In the states where nuclear evacuation drills have been conducted, evacua-tion plans have had to be rewritten to reflect reality," she added.

"Ve call on Toledo Edison and the state of Chio to schedule a full scale evacuation drill before the Davis-Besse plant is put back in operation," said "They have ace $pted the public responsibility to protect Chicans - we

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have the right to see if the plans on paper will work in practice."

OPIRG is a statewide, university based research and advocacy organization concarned with censumer protection, envi ronmental qual i ty, human rights,

governt ent responsiveness, and corporate responsibility.-

gj$6 e / State and Utility Evacuation Plans: Are Tney inadequate? Utilh

mpanies and the state, hare the responsibility for deveicping and impiecenting emergency evacuation plans in the event of a nuclear accident.

The Nuclear Regulatory Commission requires the utility company to file a plan The s tate plan delineates dealing with both in plant and off-site procedures. the roles and responsibilities of off-site agencies involved in evacuation pro-cedures. Evacuation plans for the Davis-Besse nuclear pcwer piant have been developed by the Toledo Edison Co. and the Ohio Disaster Services Agercy (draf t plan). OPIRG has analyzed whether the Toledo Edison pian and the State of Chio Officials named in the two plans were also con-pian meet federal standards. d tacted by letter and/or phone to find out what they believe they are suppose to du in case of a nuclear emergency. 7 h Failure To Meet Federa! Guidelines Both plans f ail to meet some of the recommended federal guidelines. T?.e utility plan does not centain: the expected accident assessment time the expe.ted time required to notify the popul a tion estimates of evacuation times for the ' areas which would be affected estimates of the traf Cc capacities of egress routes arrangements wi th contiguvis states The state draf t plan does not contain: planning coordination with nearby states a population chart by sectors around tne plant an acccunt of institutions and transient populacions which may impair mobility egress n::utes and their traf fic capaci ties plans for yearly driif s and exercises Ambiguities and Contradictions The folicwing char; compares what the plans s tate should happen with what the officials interviewed believe they would do: THE OFFICIALS SAY: THE PLANS SAY: 1. SHIFT FOREMAN would contact Taiedo Edison - company U til i ty Pfan: evaluates accident, no-would then c:ntact sheriff. tifies off-site support groups in case of emergency, contacts other piant of-ficials, county sheriff, medical assis-rg 3,') jj/ tance and fire depar* ment if needed. 5: ate Plan _: dces not specify who f rem

pia.nt notifies off-site support groups. COUNTY SHERIFF Utility Plan: contacts Ohio and Ot-would contact relevant agencies and help tawa County Disaster Services A-evacuate people. gencies' initiates emergency no-tification system, sets up road blocks and other evacuation pro-cedures. State Pian: notifies all county and state agencies involved, notifies [), residents in af fected area, desig-y[i nates road blocks. iII. OTTAWA COUNTY ENGINEER Utility Plan: assist in traffic would help evacuate, noti fy public, set control &nd back-up cwmun7 ca-up road blocks, a:.'sess equipment and get more help if needed. tions. State Plan: provide barriers, make equipment and manpcwer available, support evacuation, assist in door to door notification. ~ IV. CHIO Of SASTER SERVICES AGENCY Ut il i ty Plan: work with sherif f to have prepared draft state plan - doesn't cetermine evacuacien routes and deal with evacuation routes, does relocation centers, arrange for have list of potential care centers food, Todging, and medical care. for Ottawa county. State Plan: not mentioned in text. V. OTTAWA COUNTY DISASTER SERVICES AGENCY Utility Plan: not mentioned in consists of one employee who believes his role.is after the disaster, weuld t e.t t. !' ate _ Pian: evacuate residents, contact Ohio Disaster Services Agency identify and prepare evacuation for help, said he would play minor centers, arrange for 10 days sup-rol e. port, coordinate emergency planning with other county agencies. VI. FIRE DE?ARTMENT Utliity Plan: contacted if needed. would help put out plant fires (however State Plan: assist sheriff with do not have any special equipment public notification, assist in at Department for fighting radiological evacuation procedures and fight fires), would help with public notifi-ca tion. any fires. 855 $58 VII. MEDICAL. SUPPORT A. AMBULANCE SERVICE Utility Plan: provided by Robinson no Tonger provided by Robin cn Funeral Hone - sold to Carroll Tcwnship Emer-Funeral Home, Oak Harbor. State Plan: not mentioned in text. gency Medical Service - unable to find supervisor there. S. MAGRUDER MEMORI AL HOSPITAL., Port Clinton Utility _ Plan: radiation emergency could handie up to 80 serious cases of area ready if needed, have special radiation expcsure, informal agree-

ments with other area hospitals equipment. S t a te. Pl an:. not mentioned in text. to handle overflow. C. UNIVERSITY OF.PENNSYt.VN!! A HOSPITAL, Philadelphianot contacted (Magruder Hospital ad Utility Plan _: second facility named ministrator not aware that University to handle radiation exposure cases. of Pennsylvania Hospital isthe State _ Plan: not mentioned in text. back-up hospital). D. RADI ATION PARAGEMENT CORPORATION did not respond to OPIRG 1etter. U ti l i ty_ Plan: provide training and and evaluation of erergency medical plans. State Plan: not mentioned. in text. V!II. TOLEDO EDI:;0N CO. U ti l i ty Plan: release public infor-Public Relations staff parson knew y little about plan or procedures. mation. State _ Plan: not mentioned in text. Scme other agencies are listed in the plans as playing secondarf roles, but were not contacted by CPIRG. Gt C]J CHO FUEUC WTEFEST PESEARCH GECCP 4/17/79 461-0136 y ~b e e o e 836 339 .}}