ML20009B100
| ML20009B100 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 06/16/1981 |
| From: | Tedesco R Office of Nuclear Reactor Regulation |
| To: | Aswell D LOUISIANA POWER & LIGHT CO. |
| References | |
| NUDOCS 8107140784 | |
| Download: ML20009B100 (6) | |
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g.7 JUN 1619M Docket No. 50-382 5
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/-O @f.j_y Mr. D. L. Aswell Vice Prissident, Power Production iy A.N 2 3 M > g Louisiana Power & Light Company 142 Delaronde Street G wa-r__"
Q New Orleans, Louisiana 70174 O
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Dear Mr. Aswell:
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SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION We ave completed our review of the Waterford-3 Station Radiation Emergency Plan, FSAR Section 13.3 including Amendment 17 thereto, dated April 1981, which included LP&L's response to the Staff's raview comments (Q-l's) sent to you on March 30, 1981.
Your plan was reviewed against the criteria set forth in NUREG-0654/ FEMA-REP-1,
" Criteria for Preparation and Evaluation of Radiological Emergency Plans and Preparedness in Support of Nuclear Power Plants," Rev.1. November 1980. This document addresses the standards set forth in the revie.ed emergency planning regulations of 10 CFR 50 and Appendix E thereto which became effective November 3, 1980.
Our review has indicated that additional information and commitment: are re-quired before we can conclude that your onsite emergency prepardness program meets these criteria. Enclosed ara our coments for which resolution is nec-cessary. Your plan should be revised to address these comment in accordance with the provisions of the revised 10 CFR 50. You are requested to provide your responsa within 30 days of receipt of this letter, noting changes made in response to our comments.
Sincerely.
Original signed by Robert I.. Tedeseo Robert L. Tedesco Assistant Director l
for Licensing l
Division of Licensing cc: See next page l
8107140784 810616 PDR ADOCK 05000382 F
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OFFICIAL RECORD COPY
a JUN 1 g iggy REVIEW COMMENTS ON WATERFORD 3 EMERGENCY PLAN (AMENDMENT 17 TO FSAR, APRIL 1981)
DOCKET NO. 50-382 The following comments apply to the Waterford 3 Nuclear Station Emergency Plan (hereinafter called the Plan) and identify, in parenthesis, the applicable eval-uation criteria of NUREG-0654, Revision 1.
The number following the parenthesis identifies the LP&L designator from FSAR Section 13.3, Amendment 17.
810.22 Planning Standard Assignment of Responsibility (Organizational Control)
- Existing agreerrant letters must be upgraded with respect to access control of the 10-mile EPZ (A.3) 810.1-3 1.
U.S. Coast Guard (USCG) - The agreement letter with the USCG found on page C-1 of the Plan covers only access control of the waterway within the Waterford-3 Exclusion Area and not the 10-mile EPZ. This letter predates the upgraded planning requirements set forth in NUREG-0654. The agreement letter between the USCG and the Louisiana Office of Emergency Preparedness dated October 17, 1980, found in the Louisiana State Emergency Plan, may be used as the basis for upgrading the letter between LP&L and USCG with regard to access control of the 10-mile EPZ.
2.
Missouri Pacific Railroad Company (MPR Co.) - The agreement letter between LP&L and MPR Co., dated November 1,1978, covers only that
portion of the railroad right-of-way that traverse. the exclusion area. The letter must be upgraded with regard to the access control of the 10-mile EPZ.
3.
Lafourche Basin Levee District (LBLD) - Amendment 15 to Waterford-3 FSAR Section 13.3, dated February 1981 (hereinafter called the Emer-4 gency Plan), contained an agreement letter between LP&L and the LBLD Board of Commissioners which referred to Exclusion Area Control at Waterford-3 site. Amendment 17 to the Emergency Plan (item 810.1-3) which deleted the reference of the LBLD from Appendix C to the Plan, states that LBLD does not provide access control on any levees in which it has jurisdiction. Since the LBLD has jurisdiction over the levee (s) which transverses the Waterford-310-mile EPZ, access con-trol of the levee (s) must be clarified, the agency or agencies having the authority and capability to establish access control must be iden-1 tified in the Emergency Plan, and appropriate letters of agreement must be established, maintained and included in the Emergency Plan.
810.23 Planning Standard B.
Onsite Emergency Organization
- The Plan does not describe the specific conditions under which utility or.1cials above the position of Plant Manager-Nuclear would succeed to the position of Emergency Coordinator.
(B.3 ) 810.2-1 4
Response to question 810. 2-1 states, that the criteria for higher level officials assuming the function of emergency coordinator are identified in revised Subsection 13.3.4.2.1.2.
The revised Subsection 13.3.4.2.1.2 does not address higher level utility officials (i.e. higher than the Plant Manager-Nuclear).
810.24,Plannf ag Standard D.
Emergenct Classification System
- The initiating conditions for Unusual Event Alert and Site Area Emergency do not include security emergencies.
(0.1.2) 81 0.4-1,4-2,4-3 Your response indicated that security threats, attempted entry, attempted sabotage, etc. are adequately addressed in the Waterford-3 Physical Security Plan, Safeguard Contingency Plan and Procedures and should not have to be repeated in the Emergency Plari.
It is our position that security emergencies be included in the Emer-gency Plan EAL's in order to assure prompt notification and immediate response, including offsite support. References may be made to the Security Plan or Contingency Plan (ex. Alert - a security emergency has been called by the security force as defined in the Safeguards Contingency Plan). However, it must be addressed in the Emergency Plan in such detail that the reviewer can ascertain whether the re-quirements of NUREG-0654 have been met.
The initiating conditions for the Site Area Emergency Cla.ss do not include " entry of uncontrolled flammable gases into vital areas" and
" entry of uncontrolled toxic gases into vital areas where lack of access to the area constitutes a safety problem".
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your response to question 810.4-3 does not address vital areas outside the envelope of the control room, access to which may be prohibited due to toxic gases. In addition, the potential for thf s type of emergency is magnified due to the large number of industrial chemical companies in the vicinity of the site.
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JUN 16 EMll Mr. D. L. Aswell Vice President, P0ower Poduction Louisiana Power & Light Company 142 Delaronde Street New Orleans, Louisiana 70174 W. Malcolm Stevenson, Esq.
Monroe & Lemann 1424 Whitney Building New Orleans, Louisiana 70130 Mr. E. - Blake Shaw, Pittman,' Potts and Trowbridge 1800 M Street, N. W.
Washington, D. C.
20036 Mr. 0.-B. Lest'er Production Enoineer Louisiana Power & Light Company 142 Delaronde Street l New Orleans, Louisiana 70174 -
Lyman L. Jones, Jr., Esa.
Gillespie & Jones P. O. Box 9216-Metairie, Louisiana 70005 Luke Fontana, Esq.
Gillespie &.lones 824 Esplanade Ave New Oricans, Louisiana 70116 Stephen M. Irving, Esq.
535 North 6th Street Baton Rouge, Louisiana 70802 Resident Inspector /Waterford NPS P. O. Box 822 Killona, Louisiana 70066 l
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