ML19343B649
| ML19343B649 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 12/04/1980 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | Dunn C DUQUESNE LIGHT CO. |
| References | |
| TAC-12162, NUDOCS 8012290312 | |
| Download: ML19343B649 (11) | |
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o, UNITED STATES NUCLEAR REGULATORY COMMISSION l3
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- 77 Decertber 4,1980 Qj y*
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Docket No. 50-334 d
Mr. C. N. Dunn, Vice President Operations Division Duquesne Lignt Company 435 Sixth Avenue Pittsburgh, Pennsylvania 15219
Dear Mr. D'unn:
We have completed our review of the Beaver Valley Emergency Plan that was submitted on March 10, 1980. Our review was based on the criteria stated in NUREG-0654, " Criteria for Preparation and Evaluation of Radiological
- mergency Plans and Preparedness in Support of Nuclear Power Plants."
These criteria address the standards in revised 10 CFR Part 50 that became effective on November 3,1980. We find that additional information and commitments are required before we can cor:1ude that your onsite emergency preparedness program meets these criteria.
At a recent meeting with members of your staff, we discussed the comments /
questions that are enclosed with this letter. We request that you revise your Emergency Plan to respond to these concerns in accordance with the provisions of revised 10 CFR 50.
- ncerely,
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V S,'teven A.\\ arga, Chikf V
4 Operating Reactors B'rbnch #1 Division of Licensing Enclosure :
Comments on Beaver Valley Emergency Plan cc: w/ enclosure See next page 8012290 3g
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t Mr. C. N. Dunn 2-December 4, 1980 Duquesne Light Cogany cc: Gerald Charnoff, Esquire Mr. James A. Werling Jay E. Silberg, Esquire Plant Superintendent Shtw, Pittman, Potts and Trowbridge Beaver Valley Power Station 1800 M Street, N.W.
P. O. Box 4 Wash?ngton, D. C.
20036 Shippingport, Pennsylvania 15077 Karin Carter, Esquire Mr. John A. Levin Special Assistant Attorney General Public Utility Comission Bureau of Admin'strative Enforcement P. O. Box 3265 Sth Floor, Executive House Harrisburg, Pennsylvania 17120 Harrisburg, Pennsylvania 17120 Mr. J. D. Sieber, Superintendent Mr. Roger Tapan of Licensing and Cogliance Stone and Webster Engineering Duquesne Light Cog any Corporation Post Office Box 4 P. O. Box 2325 Shippingport, Pennsylvania 15077 Boston, Massachusetts 02107 Irvin A. Popowsky, Esquire Mr. F. Noon Office of Consumer Advocate R & 3 Center 1425 Strawber y Square Westinghouse Electric Corpora-ion Harrisburg, Pennsylvania 17120 Building 7-303 Pittsburgh, Pennsylvania 15230 Mr. Charles E. Thomas, Esquire
- Thomas and Thomas B. F. Jones Memorial Library 212 Locust Street 663 Franklin Avenue b x 999 Aliquippa, Pennsylvania 15001 harrisburg, Pennsylvania 17108 l
Mr. John Carey, Director Resident Inspector Nuclear Operations U. S. Nuclear Regulatory Comission Duquesne Light Cogany Post Office Box 298 435 Sixth Avenue Shippingport, Pennsylvania 15077 Pittsburgh, Pennsylvania 15219 Mr. R. E. Martin l
Duquesne Light Cogany l
435 Sixth Avenue Pittsburgh, Pennsylvania 15219 Marvin Fein Utility Counsel l
City of Pittsburgh 313 City-County Building l
Pittsburgh, Pennsylvania 15219 e
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l BEAVER VALLEY EMERGENCY PLAN REVfEW NUREG-0654 CRITIETI COMMENT /0UESTION Section A Assioraent of Resoonsibility 1.b The Plan should provide a specific " concept of operations".
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~The Beaver Valley Emergency Plan (or the Plan) does not in-dicate if communications lines will be continously manned over a protracted period of time.
3.
The Plan also does not provide all of the letters of Agree-ment needed.
Section B Onsite Emergency Organization 1; 5,8 The Plans fails to cover onsite and offsite staff assig-ment as shown in Table B-1.
The major functional areas and major tasks assigned the people in Table 5.1 is not discussed for energency situations. A table similiar to -
Table B-1 should be included in the Plan including the time frames augment personnel will arrive on site.
6.
Section 5.3.4 lists the local support service organizations but does not discuss the services or how/when they will be used. Also Figure 5-4 does not show direct interface be-tween Dusquesne Light and State (PA) or County EOC's.
9.
Letters of Agreement need to be provided for contractor and private organizations that may be requested to provide tech-nical assistance / augmentation.
10.
Need copies of the Letters of Agreement for services pro-l vided by local agencies.
The Plan does not include Appendix E.
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NUREG-0554 CRITERIA COMMENT /0UtSTION Section C Emercency Resconse Succort and Resources 1.
The Plan does not contain provisions for incorporating the Federal response capability into its operations (i.e., De-partment of Energy). The Plan should specify the Federal resources expected for accident categories in Appendix 1 of the criteria, including expected times of arrival at the site.
Specific licensee resources as needed to sup-port the Federal Response should be listed in the Plan, e.g., air fields, command posts, telephone lines, radio frequencies and telecommunications centers.
25.
The Plan does not provide for the dispatch of a represent-ative to the principal offsite governmental EOC's.
3.
The plan does not identify radiological laboratories, their general capabi11 ties and expected availability to trovide radiological services which can be used in an emergs.cy.
4 Provide letters of agreement for nuclear facilities or organizations relied upcn to provide emergency assistance.
Section D Emeroency Classification System 1.
The Plan does not include the specific instruments, para-meters or equipment status. The licensee lists each ini-tiating condition but fails to provide the parameter or system identification to be used in classification of the accident. A table should be provided tying the stated ini-tiating condition to a plant parameter or system.
2.
The licensee has not related the initiating conditions to emergency plan operating and implementing procedures.
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NUREG-0654 "CRITERtA COMMENT /00ESTI0N Section. E Notification Methods and Procedures 1,3 The Plan does not describe " mutually agreeable bases for notifjcatio.n", actien. J evel. schemes nor does. it document.
mesiage: cont'eht.that will.c6nform to NUREG-0654. 1he. 7 Plan.doesino_t establisht. message verification procedures. ~
A standardized' form for sbch reports should' be devised..
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and a copy appended to the Plan.'
',f The Plan.does' hot provide a standardized.foimat.and mes.
4 sage. content. f6r prov,$d;ihgl th'e,information.specified in
6's' 7 The Plan fa'ilE to state that the p.iume EPZ:po'pulation ca'n
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be notified within 0654 time limits. There is no docu-mentation that prior arrangements have been made to use..
pubile'. commuhi~ cations. for issuin; publ.ic ins't' ructions...'. l
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Nor is there. evidence that pre written messages have been' prepared that are con'sistent with each class and are avail-able for public. release..
The Plan must describe the administrative. and physical means which has the capability to essentially complete i
the initial notification and provide emergency instrue.
tions to"ttm public within the plume EPZ within 15 min-l This.must include all populated areas.and areas
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normally~ fre'gbented by t'rahsients.
An implemehtati.on
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sch'edule m,ust' be p~rovided to include:
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4, test date, The Plan must provide the basis for concludi.ng that the l
public warning system has. the capability to notify the public (.to include those indoorst both day a~nd night. In addition, it must be demonstrated that emergency instruc-tions can be supplied to the public within 15 minutes.
This must include a description of the radio /TV stations to be used, how 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coverage of the plume EPZ was assured, and the procedures / system used to broadcast I
accurate protective information within 15 minutes of the decision to activate the system, e
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fiUREG-0554 CRITERIA COMMET;T/00ESTION If a siren alert system is to be utilized the information specified in the fortacoming revision of NUPEG-0654, Ap-pendix 3 must be provided.
Section G public Education and Information
- 3. a b Provide more details on your news media facility, corporate on site contacts for information, ac.d the types of inform-ation which will be made available to the media.
Section H E.ercency Facilities and Ecuiomens Provide more description on your emergency facilities, in-1,2 cluding the instrumentation and communications available at your interim facilities, as well as information and in-j strutmentation which are planned for your permanent facil-ities.
Provide the times required to activate and fully staff 3.
your emergency facilities.
The Plan does not indicate if an onsite backup meteor-6 ology system is available nr if arrangemente have been made o secure meteorological data from offsite sources.
l The Plan does not indicate if an onsite hydrologic sy-stem exists capable of measuring deviations in river flow rates.
The Plan does not adequately discuss meteorological 8
criteria as expressed in 0654 Appendix 2.
1 The Plan does not describe equipment / instrument in-10 specting inventories and operational checks.
The Plan fails to specify an estimated completion date 12 for the permanent ECC or the distance from the plant.
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'NURE3-0654 CR*TERIA COMMENT /00ESTION
'Section K Radioloeical Excesure Control 2.
The Plan does not specify who is authorized to allow emergeacy workers higher de e exp:sures.
3.a The Plan does not :ndicate if. the station energen y organization has the capability for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> dosimeter distribution to emer-gency workers.
5.a The Plan does not specify action levels for determining decon-tamination needs..
..g 5.b The Plan does -not-mention the ability.to decontaminate supplies, instruments and equipment.
The Plan does not address the.onsite contamination control o'f area access, po able water and food supplies and the criteria for returning. areas to normal use.
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7.
The Plan does not address the decontamination.of relocated per-sonnel, provisions for extra clothing and suitable,decontaminants.
Section L Medical and Pu61ic Health'Suppo.-
Provide with the Plan the letters of agreement,with each-medical support organization.
Section M Recovery and Reentry Plannina and Postaccident Operations ThePlandbeskbot: establish-a:
Imethod for peri ~ dica'lly estimating o
4 total' population exposure. Procedures to determine total man-rem exposure based on calculated releases or actual environmental meas 0rements should. be.deyeloped.: The. Plan-should: describe
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the methodology used.-
Section N Exercises and. Drills.
3..
Section 8.1.2(1) paragraphs 1 & 3 infer that State, federal &
1.a & b county participation. is limited to once every-5. years. This is contrary to NUREG-0654.-
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NU?.EG-0554 CRITERjgA COMMENT /00ESTION Section I Accident Assessment 2.
The Plan fails to pre ide the methods and mechanisms for making dose assessments from the measured or pro-jected dose rates for the plume pathway environment.
3.a Address the methods and techniques for determining the,
source term of releases of ' radioactive material within plant systems.
4.
There is no reference to the relationship between effluent monitoring system readings and onsite/offsite contamina-j tion levels under various meteorological conditions.
6.
Describe the methodology to be used for determining re-lease rates and projected doses if the instrumentation used for such assessment are offscale or inoperable.
8.
Describe your capability and resources for field moni-toring within the plume exposure Emergency Planning Zone including the methods, equipment, and expertise to make rapid assessments of the actual or potential magnitude and locations of any radiological hazards through the licaid or gaseous pathway:-
Your descrip-tion should address activation criteria, means of noti-fication, field team composition, trantportation, com-munication, monitoring equipnent, and tstimated deplov-ment times.
9.
Confirm your capability to detect and measure radio-iodine concentrations as low as 5 x 10E-08 pCi/cc under all weather field conditions. Interference from the pre-sence of noble gas and background radiation shall not decrease the stated minimum detectable activity.
10.
Describe your means for relating the various, measured parameters (e.g., contamination levels, water and air activity levels) to dose rates for key isotopes and gross radioactivity measurements. Also describe your provisions for estimating integrated dose from the pro-jected and actual dose rates and for comparing these estimates with protective action guides.
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NUREG-065k CRITtRIA COMMENT / QUESTION Section J
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1.
The Plan fails to address precisely how individuals in-volved in a unit or site emergency will be notified.or warned, particularly those individuals'outside the pro-tected area and.inside the exclusion area. The. Plan..
also fails lo discuss.the timeh)l required to notify, ~
account for and/or evacuate persons from company con-trolled areas.
2 2.
The Plan infers $ evacuation by onsi+e pers$nnei will be
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by personal vehicles'but fails to address evacuating people in the exclusion area without a personal vehicle.
The Plan does not identify evacuation routes ~and al-ternatives routes for inclement weather, high density traffic or radiological conditions.
3.
The Plan fails to identify who will conduct surveys and if decontamination of personnel and vehicles.can be provided at or near the remote essembly area.
6.c The Plan does not addrc3 the use of radioprotective drugs for thyroid protection for emergency workers.
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The Pian discusses the generai p'roced'ure's' tb' b'e' used 5.
for personnel accountability but fails to indicate if accountability can be achieved within 30 minutes after declaration of an emergency as specified.
10.a There is:no' map that specifically identifies. evacuation rbutes',' shelter ~ areas.,; medical or hospital' /acilities.
TIE Plan should s't' ate how the resid'entlaP'popuiation,
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- 10. c within. the 10. miles EP2,,w.ill, be. notified and inform,ed in'chse:of. emergency......
The ba' is for recommend'ed pro'tecEive acitons -iit the 10.or s
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piume EPZ, including analysis of protection afforded by residential. units, from direct or inhalation ex,.
posure needs to be addressed..
g The Plan fails to address the times required for noti-
- 10. k fication, preparation and response under various con-ditions.
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NUREG-0654 C0!O'ENT/00ESTION CRITERIA Section N Exercises anc Orilis (cont.)
l.b No arrangements are in the Plan for conducting an exercise during the hours of 6-12pm, 12am -6am at least once every 6 years.
2.a Communicatiens drills shall be scheduled to test communications with county and States within the piume EPZ at least monthly; with Federal agencies, States in the ingestion EPZ annually, between the nuclear facility, State and local EOCs, and field assessment teams annually.
2. e' Health Physics Drills do not provide for inplant sample analysis with actual elevated radiation levels.
3.a-e The scenario requirements stated in NUREG-0654 N 3a-e are no't discussed in the Plan.
Section 0 Radiological Emercency Response Training 1.b, 2 The Plan does not indicate if on-the-spot corrections of mistakes in performance aremade by instructors during training.
The Plan does not identify " hands on" training.
3.
The Plan does not state if the training given to the fire brigades and First Aid & Rescue personnel includes the Ped Cross Multi-Media Course.
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I Section P Responsibility for Planning Effort, Development Re"iew, and Distribution of Emergency Plans 1.
The Plan does not provide for training of individuals responsible for the planning effort, emergency planning methods and procedures.
The Plan does not specify the method (si used to insure that l
3.
copy holders receive revisions and copies are kept up-to-date.
No provisions are made for auditing controlled copies.
8.
The Plan does not have an index cross reference to NUREG-0654.
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