ML20053A044
| ML20053A044 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/28/1982 |
| From: | Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Carey J DUQUESNE LIGHT CO. |
| Shared Package | |
| ML20053A045 | List: |
| References | |
| NUDOCS 8205240484 | |
| Download: ML20053A044 (28) | |
See also: IR 05000334/1981027
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APR 2 81982
Docket No. 50-334
Duquesne Light Company
ATTN: Mr. J. J. Carey
Vice President
435 Sixth Avenue
Pittsburgh, Pennsylvania 15219
Gentlemen:
Subject:
Emergency Preparedness Appraisal
To verify that licensees have attained an adequate state of onsite emergency
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preparedness, the Office of Inspection and Enforcement is conducting a special
appraisal at each operating power reactor site.
The appraisals are performed
in lieu of certain routine inspections normally conducted in the area of
The objectives of the appraisal at each facility are
to evaluate the overall adequacy and effectiveness of emergency preparedness
and to identify areas of weakness that need to be strengthened. We use the
findings from these appraisals as a basis not only for requesting individual
jicensee action tc correct deficiencies and effect improvements, but also for-
effecting improvements in NRC requirements and guidance.
During the period of October 4-16, 1981, the NRC conducted an appraisal of the
emergency preparedness program for Unit I of the Beaver Valley Power Station.
Areas examined during this appraisal are described in the enclosed report
(50-334/81-27). Within these areas, the appraisal team reviewed selected
procedures and representative records, inspected emergency facilities and
equipment, observed work practices, and interviewed personnel.
The findings of this emergency preparedness appraisal-indicate that certain
corrective actions are required in your emergency preparedness program. These
are discussed in Appendix A, "Significant Emergency Preparedness Findings."
Significant findings for which you have made acceptable commitments to resolve
were discussed in the confirmatory action letter dated November 2, 1981, a
copy of which is enclosed for your convenience.
These findings are described-
in further detail as items '1,
2, 3, 4, 5, 6, 7, 9,10 and 11 of Appendix A.
It is our understanding based upon your letter of January 5,1982, that corrective
actions on these items have been completed.
Other areas needing improvement are discussed in Appendix B, " Preparedness
s.
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Improvement Items".
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Duquesne Light Company
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APR 2 81992
In. conjunction with the aforementioned appraisal, emergency plans for your
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facility were reviewed by the Emergency Preparedness Licensing Branch. The
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results of this review indicate that certain deficiencies exist in your emergency-
plan. These are discussed in Appendix C, " Emergency Preparedness Evaluation
Report".
Appendices A, B and C of this letter and Section 8 of the report contain an
inclusive listing of all outstanding emergency preparedness items at your
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facility at this time.
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We recognize that an explicit regulatory requirement pertaining to each item
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identified in Appendices A, B, and C may not currently exist. Not withstanding
this, you are requested to submit a written statement within thirty (30) days
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of the date of this letter, describing the corrective actions taken or planned
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for each of the items identified in Appendix A and the results of your consider-
ation of each of the items in Appendix B.
This description is to include, (1)
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actions which have been taken, (2) actions which will be taken, and (3) a
schedule for completion of actions for each item. With regard to Appendix C,
you are requested to provide to this office within 120 days of the date of
this letter, page changes to the emergency plan correcting each deficiency or
provide written justification as to why you believe a revision should not be
made.
Copies of these changes are to be submitted in accordance with the
procedures delineated in 10 CFR 50.54(q).
This is to inform you that if the remaining Appendix A item (No. 8) is not
corrected within 120 days from the date of this letter, the Nuclear
Regulatory Commission will determine whether enforcement action is appropriate.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of
this letter and the enclosures will be placed in the NRC's Public Document
Room.
If this report contains any information that you (or your contractors)
believe to be exempc from disclosure under 10 CFR 9.5(a)(4), it is necessary
that you (a) notify this of fice by telephone within ten (10) days from the
date of this letter of your intention to file a request for withholding; and
(b) submit within 30 days from the date of this letter a written application
to this office to withhold such information.
Section 2.790(b)(1) requires
that any such application must be accompanied by an affidavit executed by the
owner of the information which identifies the document or part sought to be
withheld, and which contains a full statement of the reasons on the basis
which it is claimed that the information should be withheld from public disclosure.
This section further requires the statement to address with specificity the
considerations listed in 10 CFR 2.790(b)(4). The information sought to be
witheld shall be incorporated as far as possible into a separate part of the
If we do not hear from you in this regard within the specified
periods noted above, the report will be placed in the Public Document Room.
The telephone notification of your intent to request withholding should be
made to the Supervistor, Files, Mail and Records, USNRC Region I, at (215)
337-5223.
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Duquesne Light Company
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AER 4 3122
The reporting requirements contained in this letter affect fewer than ten (10)
persons and are, therefore, not subject to the Of fice of Management and Budget
clearances as required by PL 96-511.
Should you have any questions concerning this inspection, we will be pleased
to discuss them with you.
Should you have any questions concerning the items
of Appendix C, please contact Richard Van Niel, Emergency Preparedness Licensing
Branch at (301) 492-4535.
Sincerely,
M eimi ?!r wd By
[ LAG l
Geor6e H. Smf th
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Director, Division of
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and Operational Support
Enclosures:
1.
Appendix A, Significant Findings
2.
Appendix B, Preparedness Improvement Items
3.
Appendix C, Emergency Preparedness Evaluation Report
4.
Letter to Duquesne Light Company, dated November 2,1981.
5.
NRC Region I Inspection Report No. 50-334/81-27
cc w/encls:
F. Bissert, Manager, Nuclear Support Services
R. Washabaugh, QA Manager
H. P. Williams, Station Superintendent
W. S. Lacey, Chief Engineer
R. Martin, Nuclear Engineer
J. Sieber, Manager, Nuclear Safety and Licensing
T. Jones, Manager, Nuclear Operations
R. M. Mafrice, Nuclear Engineer
N. R. Tonet, Manager, Nuclear Engineering
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
Conmonwealth of Pennsylvania
NRC Resident Inspector
J. W. Brucker, Regional Director, FEMA Region III
bec w/ enc 1:
Region I Docket Room (with concurrences)
Chief, Operational Support Section (4 o encls)
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APPENDIX A
SIGNIFICANT APPRAISAL FINDINGS
Based on the results of the NRC's appraisal of the Beaver Valley Power Station
Emergency Preparedness Program, conducted October 4-16, 1981, the following
improvements are required:
(References are to the sections in NRC Inspection
Report No. 50-334/81-27.)
1.
Implementation of current proposals in the emergency plans and procedures
which call for transferring emergency functions from the control room /ECC
to the other emergency response facilities, so as to allow control room
personnel to concentrate on plant operations and corrective actions.
(Section 2.1)
2.
Completion of plans to ensure that the required minimum number of personnel
are available on shift by July 1, 1982. (Section 2.1)
3.
Implementation of revisions to plans and procedures which call for prompt
staffing of the interim Emergency Operations Facility (EOF) to perform
the emergency functions of NUREG-0696.
(Section 2.2)
4.
Improvements in the ability to promptly augment the emergency organization
in the functional areas called for by NUREG-0654, Table B-1 (Section
2.2).
5.
Development of approved lesson plans covering specialized areas of emergency
preparedness training.
(Section 3.1)
6.
Completion of specific training intended for licensee personnel having
assigned emergency duties and responsibilities and for offsite supporting
organizations.
(Section 3.2)
7.
Completion of necessary preparations to make the interim Emergency Operations
Facility operational and capable of performing the emergency functions of
NUREG-0654 and NUREG-0696.
(Section 4.1.1.4)
8.
Provision of appropriate facilities and supplies to enable decontamination
of onsite personnel during emergencies.
(Section 4.1.2.3)
9.
Impro- ,ent of notification procedures / facilities to enable completion of
initi.i notifications within 15 minutes of an emergency declaration.
(Section 5.4.1)
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Appendix A
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10.
Identification of techniques to be incorporated into the dose calculational
procedures to compensate for the potential uncertainty associated with
plume trajectories in order to provide reasonable assurance that adequate
protective measures (scope and area) can be recommended in the event of a
radiological emergency condition.
(Section 5.4.2).
11. Revision of decontamination / monitoring procedures used during an accident
to include action levels for decontamination and assessment, procedural
guidance for determining individual dose equivalent and data sheets
necessary to maintain proper records.
(Section 5.4.3.4 and 4.1.2)
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APPENDIX B
PREPAREDNESS IMPROVEMENT ITEMS
Based on the results of the NRC's appraisal of the Beaver Valley Power Station
Emergency Preparedness Program conducted October 4-16, 1981, the following
matters should be considered for improvement:
(References are to the sections ;
in NRC Inspection Report No. 50-334/81-27).
1.
Specification of qualifications and training required for individuals who
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would be assigned to the functional areas of the emergency organization.
(Section 2.1)
2.
Specification of working level cmergency pers'onnel who would respond to
augment the onsite emergency organization in station callout procedures.
(Section 2.1)
3.
Clarification of EPP/IPs to specify reporting locations, responsibilities
and limitations of non-licensee personnel who wou'd augment the licensee's
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emergency organization.
(Section 2.2)
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4.
Provisions for training emergency response personnel in changes to procedures
and equipment occurring in the periods between annual training cycles.
(Section 3.1)
5.
Provisions for management controls to assure that individuals complete
assigned emergency preparedness training. assignments.
(Section 3.2)
6.
Relocation of the post-accident gas, particulate, and noble gas effluent
air sampling systems to an adequately shielded location.
(Section 4.1.1.7)
7.
Improvement in wind measurement from the 35 ft. level of the primary
meterological tower.
(Section 4.2.1.4)
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Identification of appropriate adjustments to available data from the
primary meterological system for use in dose projections.
(Section
4.2.1.4)
9.
Identification of four-wheel drive vehicles which would be available for
use by emergency teams during winter months and other periods of severe
weather.
(Section 4.2.6)
10. Revisions to EPP/IPs so that " procedure" sections list sequential action
steps, reference interrelated tasks, and include appropriate supplies of
data and signoff sheets.
(Section 5.1)
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Appendix B
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11.
Inclusion of onsite radiation protection concerns as part of the EPP/IPs.
($ection 5.3)
12.
Inclusion of the authority of the Emergency Director within Implementing
Instructions.
(Section 5.3)
13. Modification of initial notification procedures EPP/IP 1.1 to call for
additional direct notifications of Ohio and West Virgina following declaration
of a General Emergency.
(Section 5.4.1)
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Designation of specific onshift individuals in the EPP/IPs (other than
the Emergency Director) who will be tasked and trained to make emergency
notifications.
(Section 5.4.1)
15. Modification of Post-Accident Stack Effluent Sampling Procedure to provide
warning on anticipated dose rates during accident conditions.
(Section
5.4.2.8)
16. Development and implementation of precautions and prerequisites for
taking high activity liquid effluent samples. (Section 5.4.2.10)
17.
Relocation of equipment used to refill SCBA air bottles to an area of the
plant which would be readily accessable during accident conditions.
(Section 5.4.3.1)
18.
Provision for reporting the status of personnel accountability performed
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at Beaver Valley Unit II to the Unit I emergency organizations. (Section
5.4.3.3)
19. Development of specific access Control Standards for identifying personnel
authorized to enter the interim TSC or EOF areas. (Section 5.4.4)
20.
Location of security personnel at the TSC/ EOF to ensure meaningful information
flow and workload tasking to the security organization during emergencies.
(Section 5.4.4)
21. Development of Specific Access Control Standards to enable identification
of essential licensee and non-licensee augmentation personnel who must
respond onsite.
(Section 5.4.4)
22. Modification of Radcon Emergency Operation Procedure 2.1, to place the
conditions for requiring self-contained breathing apparatus in BOLD FACE
TYPE or some other technique to highlight their importance.
(Section
5.4.5)
23. Modification of the emergency plan and procedures to call for testing
iommunications links at the frequency specified in Section N.2.a of
(Section 5.5.2)
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Develcoment 01 a procedure outlining the administrative controls for
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tracking dr,iM s and exercises and for ensuring that the actions necessary
to respond:.to observations ace implemented. (Section 5.5.2)
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Modificat. ion of emergenry planning audit / review procedures to ensure that
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comprehens(ve independent reviews are performed at least every twelve
months.
(section 5.574)
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Equipping end^rgenc/4 survey kits with casters or dolleys to aid in safe
movement frotlt,orage locations.
(Sections 7.2.8)
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APPENDIX C
EMERGENCY PREPAREDNESS EVALUATION REPORT
BY THE
DIVISION OF EMERGENCY PREPAREDNESS
OFFICE OF INSPECTION AND ENFORCEMENT
U. S. NUCLEAR REGULATORY COMMISSION
IN THE MATTER OF
BEAVER VALLEY POWER STATION
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UNIT 1
DOCKET NO.'50-334
NOVEMBER 1981
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INTRODUCTION
The Duquesne Light Company herinafter refer;ed to as the licensee) filed with
the Nuclear Regulatory Commission Revision 3 the Veaver Valley Power Station
Emergency Plan dated December 29, 1980.
The plan was reviewed against the 16 planning standards in Section 50.47 of
10 CFR Part 50, the requirements of Appendix E to 10 CFR Part 50, and the
criteria of NUREG-0654/ FEMA-REP-1, Revision 1 entitled " Criteria for Prepara-
tion and Evaluation of Radiological Emergency Response Plans and Preparedness
in Support of Nuclear Power Plants'" November 1980.
This evaluation report follows the format of Part II of NUREG-0654 in that
each of the Planning Standards is listed and followed by a summary of the
applicable portions of the plan and the deficiencies that relate to the
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specific standard.
The final section of this report provides our
conclusions.
A separate report will be issued describing the' findings and determinations of
the Federal Emergency Management Agency of the State and locatl response
plan.
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EVALUATION
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A.
ASSIGNMENT OF RESPONSIBILITY (0RGANIZATION CONTROL)
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Planning Standard
Primary reponsibilities for emergency response by the nuclear facility licensee,
and by State and local organizations with the Emergency Planning Zones have been
assigned, the emergency responsibilities of the various supporting organizations
have been specifically established, and each principal response organization has
staff to respond and to augment its initial response on a continuous basis.
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The Beaver Valley Power Station Emergency Plan. identifies those State,
local, and Federal response organizations which have response roles in the
event of an accident.
Since the plume exposure and ingestion Emergency
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Planning Zones incorporate portions of Pennsylvania, Ohio, and West-Virginia,
three State county emergency response agencies have primary response roles;
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Pennsylvania Emergency Management Agency (PEMA), Ohio Disaster Services ~
Agency (0DSA), and West Virginia Office of Emergency Services (WV0ES).
Similarily, the Beaver County Emergency Management Agency, Columbiana
County Disaster Services Agency, and'the'Hancock County Emergency Services
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Agency serve as the lead county response agencies.
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A concept of operations and i.ts relationship to the total effort is speci-
fied.
The interrelationships are illustrated in Figure 5.4 of the onsite
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The Emergency Direct r is identified as the person who will assure overall
direction and control of the Duquesne Light emergency response.
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Twenty-four hour per day emergency response, including manning of communi-
cations links is provided.
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Written agreements from Federal, State, and local agencies and other support
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organizations having an~ emergency response role within the'EPZs are included "
in'this plan.
The plan describes the role of each of the agencies.'with which
-there are agreement. and is relationship to the role of the plant.
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The plan describes a corporate level support organization which would be
responsible for assuring _ continuity of resources for protracted 24-hour
operations.
B.
ONSITE EMERGENCY ORGANIZATION
Planning Standard
On-shift facility licensee reponsibilities for emergency response are unambiguously
defined, adequate staffing to provide initial facility accident response in key
functional areas is maintained at all times, timely augmentation of response capabil-
ities is available, and the interfaces among various response activities and offsite
support and response activities are specified.
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The onsite emergency organization of plant personnel for all shifts and its
relation to the responsibilities and duti'es of the normal staff complement
are specified.
Plant staff emergency assignments for managers and key coordin-
ators are described.
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The on-shift s'upervisor is designated as the Emergency Director and has the
authority to initiate emergency actions and recommend protective measures
to offsite officials until relieved of Emergency Director duties by a desig-
nated senior management official (Statica Superintendent, Chief Engineer,
or Maintenance Supervisor).
The responsibilities, lines of succession and
functions which cannot be delegated are also described.
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Table 5.1 specifies the positions or title and major tasks to be performed
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bythepersonstobeassignedtothefunctionalareasofemergencyactivii,y. ~
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The plan indicates the staffing levels which can be augmented within 60-120
minutes.
The interfaces between and among the onsite functional areas of emergency
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activity and the offsite emergency organization made up of corporate support,
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local services support, and State and local government response organizations
are specified.
A block diagram is provided in Figure 5.4 of the plan.
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The corporate management, administrative, and technical support personnel
who will augment the plant staff are generally specified for those functional
areas of emergency response except those performed in the Emergency Operations
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Facility (EOF).
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The contractor and private organizatior5 who may be requested to provide
technical assistance to and augmentation of the emergency response organi-
zation are specified.
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The services to be provided by local agencies for handling emergencies, including
police, ambulance, medical hospital, and fire-fighting organizations are
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specified.
Copies of letters of agreement with these organizations as well.
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as letters of agreement with Westingh'ouse Electric Corporation (the NMSS
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supplier) Teledyne Isotopes.and INP0 are' appended to the plan.
Deficiencies
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The plan should describe how working level personnel will augment the BVPS
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emergency organization in the areas of Table B-1 to NUREG-0654.
Furthermore,
the plan should provide a commitment that the minimum staffing requirements
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including the times for augmentation from offsite personnel will be as specified
in Table B-1 of NUREG-0654, Rev.1 by July 1,1982.
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2.
The plan should describe augmentation plans to allow the Emergency Opera-
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tions Facility to be staffed so as to perform the emergency functions of
NUREG-0654, Table B-1 and NUREG-0696.
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EMERGENCY RESPONSE SUPPORT AND RESPONSES
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Planning Standard
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Arrangements for requesting and effectively using assistance resources have been
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made, arrangements to accommodate State and local staff at the licensee's near-
site Emergency Operations Facility have been made, and other organizations capable
of augmenting the planned response have been identified.
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The roles and types of support expected to be provided by Federal
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Assistance Organizations is described in the plan, including activation of
the Federal Radiological Monitoring and Assessment Plan.
Arrangements have been made for the license to dispatch representatives to
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key governmental emergency operations centers and facilities will be available
for governmental representatives at the E0F.
Nuclear and other facilities, organizations or individuals which can be re. lied
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upon in an emergency to provide assistance, including medical and radiation
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management capabilities, are identified.
Letters of agreement are appended.
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The plan should specify persons by title who are authorized to request Federal
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assistance.
D.
PLANNING STANDARD
- A standard emergency classification and action level scheme, the bases of which
include facility system and effluent parameters, is in use by the nuclear facility
licensee, and State and local response plans call for reliance on information
provided by facility licensees for determinations of minimum initial offsite
response measures.
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Thelicenseehasestablishedanemerhencyclassificationandemergehcy
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action level scheme' compatible with the scheme set forth in Appendix 1,
NUREG-0654, Rev. 1.
Specific instruments, parameters or equipment status for each emergency
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class is established in the emergency procedures or in the plan.
Postulated accidents (Section 14 of the FSAR) and the example initiating
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conditions in Appendix 1, NUREG-0654, Rev. l_ are covered in Section 4 of
the plan.
E.
NOTIFICATION METHODS AND PROCEDURES
Planning Standard
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Procedures have been established for notification, by the licensee of State and
local response organizations and for notification of emergency personnel by all
response organizations; the content of initial and followup messages to response
organizations and the public has been established; and means to provide early
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notification and clear instruction to the populace within the plume exposure
pathway Emergency Planning Zone have been'estiblished.
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Procedures which describe mutally agreeable bases for notification of
response organizations consistent with the eraergency classification and
action level scheme, including means for confirmation, are established.
Procedures for alerting, notifying, and mobilizing emergency response
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personnel are established, including means of notifying onsite staff and
off-shift personnel as needed for minimum emergency staffing levels.
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The contents'of the initial and followup' emergency message to be sent from
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the plan are established,
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Methods and procedures for notifying the public of an emergency at BVPS
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have been established using a combination of fixed sirens and transmission
line signaling devices.'
These devices would activated by county officials.
The Federal Emergency Management Agency (FEMA) will determine the adequacy
of the offsite emergency notification system.
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-The Public Information Department emergency procedures contain guidance -
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for messages intended for the public.
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Deficiencies
1.
The plan describes notification procedures for key emergency coordinators.
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The plan should also provide a description of the system and procedures to
be used to notify and mobilize working level personnel who perform the
emergency functions described in NUREG-0654, Table B-1.
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F.
EMERGENCY COMMUNICATION
Planning Standard
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Provisions exist for prompt communications among principal response organiza-
tions to emergency personnel and to the public.
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Primary and backup means of communication for operators, local, and State
response organizations are provided by hotlines, commercial telephone, and
radio systems.
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The Emergency Director and the Communicator are established as providing
communications from the plant.
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Twenty-four hour notification to the activation of the State / local emergency
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response network are pr'ovided.
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Communications with contiguous State / local governments within the EPZ are
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provided.
Communications with Federal emergency response organizations are provided.
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Communications between the nuclear facility Control Room, the Emergency
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Control Center, State and local E0Cs and monitoring teams are addressed.
Means to alert or activate emergency personnel are provided.
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Communications by the licensee with NRC headquarters, the NRC Regional
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Office, and the Emergency Control Center are addressed.
A telephone link between the plant and the hospital, and a radio link
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between the hospital and the ambulance are provided.
Routine tests of the communication links between the Control Room Emergency
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Control Center and the States and three county warning points and E0Cs are
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specified.
Tests of the communication links with the NRC are specified.
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Deficiencies
1.
The frequency of communications tests with the States and three counties
within the EPZ should be at least monthly instead of quarterly.
G.
PUBLIC EDUCATION AND INFORMATION
Planning Standard
Information is made available to.the public on a periodic basis on how they will
be notified and what their initial actions should be in an emergency (e.g., listen-
ing to a local broadcast station and remaining indoors), the principal points
of contact with the news media for dissemination of information during an emergency
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(including the physical location or locations) are established in advance, and
procedures for coordinated dissemination of information to the public are
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Annual dissemination of information to the public regarding how they will
be notified and what their actions should be in an emergency is to be
prepared and disseminated on an annual basis, beginning in the fall of
1981.
The initial brochure is to contain the appropriat.e information.
Advertisements containing useful emergency information which can be placed
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in the phone book will be prepared.
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The Manager, Public Information Department, will provide a point of contact
for the news media emergency conditions.
The position of Emergency News-
Center Director is provided to manage the Emergency News Center and act as
official company spokesperson for events classed higher than an Alert.
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near-site Emergency News Center will be set up at the Willows Motel about
'3 miles from the site.
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The Public Information Department will maintain a representative at the
TSC and E0F to ensure that proper information is provided for public release.
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The Consumer Services Department will be staffed and prepared to deal with
rumors which may develop during an emergency.
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Programs will be conducted on an annual basis by Duquesne Light Company to
acquaint news media personnel with the emergency plans, information concern-
ing radiation and points of contact for release of public information in
an emergency.
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H.
EMERGENCY FACILITIES AND EQUPMENT
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Planning Standard
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Adequate emergency facilities and equipment to support the emergency. response
are provided and maintained.
Emergency Plan:
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The licensee has established an interim Technical Support Center,
Emergency Control Center, Recovery Center, and an Operations Support
(Assembly) Center.
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Onsite and offsite monitoring and analysis systems and equipment have been
established and are identified in the plan.
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Routine inspection, inventory, calibration, and maintenance of emergency
equipment and identification of emergency kits are addressed as well as
the location for receipt and analysis of field monitoring data and coordin-
ation of sample media.
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Deficiencies:
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The plan should provide a commitment and' schedule for the permanent
Emergency Response Facilities in accordance with NUREG-0696.
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The plan should be. modified to provide for the interim Emergency Operations
Facility (EOF) to perform the functions of (a) overall licensee accident
management, (b) radiological / environmental assessment, and (c) protective
action recommendations.
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I ACCIDENT ASSESSMENT
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Planning Standard
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Adequate methods, systems and equipment for assessing and monitoring actual or
potential offsite consequences of a radiological emergency condition are in
use.
The plan identifies plant system and effluent parameters characteristic of
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a spectrum Jof off-normal conditions 'and accidents, however, specific values
and setpoints are not included in the plan.
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Onsite capability and resources are provided for initial and continuing assess-
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ment during an accident including instrumentation for detection of inadequate
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core cooling, in plant iodine instrumentation, and postaccident sampling
capability.
The plan describes the methodology for ' determining the s'ource term, magnitude
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of releases, and the relationship between effluent monitor readings and projected
offsite doses.
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Provisions have been made for determining release rates and projected doses
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in the event that the plant vent monitor is offscale and inoperable, based
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on FSAR accident analysis source terms and field measurements.
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Resources are provided for prompt field monitoring within the environs
including field detection and monitoring of radioiodine concentrations as
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low as 10 7 uCi/cc.
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Deficiencies
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Specific parameter and instrument setpoints which correspond to accident
class initiating conditions should be specified in the plan.
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The plan should explicitly identify the means for relating various measured
parameters in the field to dose rates for the key isotopes listed in Table
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J.
PROTECTIVE RESPONSE
Planning Standard
A range of protective actions have been developed for the plume exposure pathway
EPZ for emergency workers and the public.
Guidelines for the choice of protec-
tive actions during an emergency, consistent with Federal guidance, are developed
and in place, and protective actions for the ingestion exposure pathway EPZ appro-
priate to the locale have been developed.
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The licensee has established the means to warn, advise, account for,
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radiologically monitor and evacuate onsite personnel,
Individuals remaining onsite will be furnished with protective c'10 thing,
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respiratory equipment and issued radioprotective drugs if necessary.
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The plan identifies the mechanism for' promptly recommending protective actions
to appropriate State and local authoriti'es, and provides time estimates for
evacuation within plume exposure EPZ.
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The plan describes sampling procedures for liquid and gaseous radiological
release.
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The basis for choice of recommendation of protective actions from the plume
exposure pathway are incl'ided in the plan.
Deficiencies
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The clan should contain maps with preselected monitoring and sampling points
arour.d the facility.
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RADIOLOGICAL EXPOSURE CONTROL
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Planning Standard
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Means for controlling radiological exposures, in an emergency, are established
for emergency workers.
The means for controlling radiological exposures shall
include exposure guidelines consistent with EPA Emergency Worker and Lifesaving
Activity Protective Actica Guides.
The licensee has established onsite exposure guidelines consistent with EPA
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standards, has provided an onsite radiation protection program and identified
individuals by position who can authorize exposures in excess of 10 CFR 20
limits.
The plan provides for 24-hour a day capability to determine the radiation
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dose received by emergency workers; distribution of dosimeters and main-
tenance of dose records; decontamination of personnel, supplies, instru-
ments and equpment and onsite contamination control.
Deficiencies
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The plan should address the use of decontaminants to be used in the event
of radiciodine contamination of the skin.
2.
The plan should specify the criteria for returning contaminated items and
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areas to normal use.
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MEDICAL AND PUBLIC HEALTH SUPPORT
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Planning Standard
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Arrangements are made for medical services for contaminated injured individuals.
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Arrangements have been made with a local and backup hospital for the' treat-
ment of individuals involved in a radiological accident.
Onsite first aid capability is provided, including an individual onsite at
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all times who is trained in first aid techniques.
Arrangements have been made for the transportation of victims of radiological
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accidents to the medical support facilities.
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RECOVERY AND REENTRY PLANNING AND POSTACCIDENT OPERATIONS
Planning Standard
General plans for recovery and reentry are developed.
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Gene.ral plans and procedures for reentry and recovery have been developed,
and the means by which decisions are made to relax protective measures are
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addressed.
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The Recovery Manager will be the senioh ' manager of the recovery organiza-
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tion.
The title, authority, and responsibilities for maintaining contact
with State and local governments and keeping them apprised of plant and radio-
logical conditions .through the recovery oprations.
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A method for periodically estimating total population exposure has.been
established.
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N.
EXERCISES AND DRILLS
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Planning Standard
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Periodic exercises are (will be) conducted to evaluate major portions of emergency
response capabilities, periodic drills are (will be) conducted to develop and
maintain key skills and deficiencies identified as a result of exercises or drills
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An emergency preparedness exercise will be conducted as set forth in the
NRC Rule.
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A joint exercise involving the mobilizat'on of Pennsylvania, Ohio, and
West Virginia agencies, as well as coun>.y and local personnel and resources
is provided.
The scenarios of the exercises will be varied from year to year such that
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all major elements of the emergency response plan and its procedures are
evaluated every five years.
Additionally, exercises will be scheduled so
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as to be conducted at differing times of day.
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The plan provides for a critique of the annual exercise by Federal, State,
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and local officials.
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Quarterly fire drills will be conducted.
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Annual medical emergency drills will be conducted.
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Annual radiological monitoring drills wjll be conducted.
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Semiannual health physicals drills involving airborne and liquid samples
and direct radiation measurements in the environment will be conducted,
and-annual health physics drills involving analysis of in plant liquid
samples with simulated elevated radiation levels will be conducted.
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The scenarios to be used in the exercises and drills will include:
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basic objectives of the exercise or drill including evaluation criteria;
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(2) data, time period, and participating agencies; (3) events to bb'
simulated; (4) approximate time schedule of real and simulated events; (5)
a narrative summary description of the conduct and organization exercise
or drill; and (6) arrangements made for qualified observers, and evalu-
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ation criteria.
Provisions are made for a critique following each drill or exercise.
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An Emergency Plan corrective action report will be entered into the
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stations computerized coamitment control system to track followup actions
to exercise deficiencies.
Deficiencies
1.
Communications with the NRC and States and countries within the plume EPZ
shall be tested monthly in accordance with paragraph E.9.d of Appendix E
to 10 CFR 50; communications with the Federal response organizations and
States within the ingestion pathway should be tested quarterly.
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RADIOLG01 CAL EMERGENCY RESPONSE TRAINING
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The plan provides for the initial training and retraining of company and
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offsite personnel who will respond to an accident or emergency in the
functional areas of emergency response.
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Training will include classroom as well as practical drills to ensure that
personnel are cognizant of and acquainted with their duties and responsi-
bilities.
Licensee sponsored traiing will be conducted for police, fire, medical,
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and rescue organizations which may be called upon to respond to an
emergency.
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Deficiencies-
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The plan should address the training"provided for those personnel responsible
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for the transmission of emergency information and instructions (see Table B-1,
NUREG-0654," Notification / Communication").
2.
Training should be established for personnel performing key functions in
the Emergency Operations facility.
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RESPONSIBILITY FOR THE PLANNING EFFORT
Planning Standard
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Responsibilities for plan development and review and for distribution of'emer-
gency plans are' established, and planners are properly trained.
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The Supervisor, Emergency Preparedness, will receive' periodic training on
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emergency planning matters and regulations,
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Updated plans will take into account changes identified in drills and
exercises and be certified on an annual basis to be current.
Control:ed copies shall be used to keep the emergency organization cognizant
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of changes to the Plan and the Emergency Procedures Document.
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A listing of the procedures required to implement the plan and the section.
of the plan to be implemented by each is provided as part of the emergency
plan.
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An audit of the emergency preparedness program is performed by the Offsite
Review Committee biannually.
The Onsite Safety Committee performs annual
reviews of the BVPS' Emergency Plan.
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The updating of telephone numbers in the Emergency Procedures Document
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will be verified on a quarterly basis.
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Deficiencies
1.
The plan should contain a detailed listing of all supporting plans and
their source.
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CONCLUSION
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Based on our review, we conclude that the Beaver Valley Power Station Emergency
Plan, upon satisfactory correction of the previously identified deficiencies,
will meet the planning standards set forth in NUREG-0654, Revision 1, " Criteria
for Preparation _and Evaluation of Radiological Emergency Response Plans and
Preparedness in Support of Nuclear Power Plants," November 1980.
The NRC evaluation on the overall state of emergency preparedness for the
Beaver Valley site will be made following review of the findings and determin-
ations made by FEMA on the State and local emergency response plans, and the
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review of the joint exercise held to demonstrate the capability to implement the
onsite and offsite plans.
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
REG 12NI
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631 PARK AVENUE
KING OF PRUSSI A, PENNSYLVANI A 19406
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Docket No. 50-334
Duquesne Light Company
ATTN: Mr. J. J. Carey
Vice President
Nuclear Division
Post Office Box 4
Shippingport, Pennsylvania 15077
Gentlemen:
This letter refers to a meeting between Mr. J. J. Carey, Vice President
and members of his staff, and Mr. S. H. Chesnut, Team Leader, and other
members of the NRC Emergency Preparedness Implementation Appraisal Team,
which was held at the Beaver Valley Power Station on October 15, 1981,
and to a telephone conversation Mr. Kenneth Grada of your staff and Mr.
G. L. Snyder of my staff on October 28, 1981. With regard to the matters
relating to emergency preparedness discussed at that meeting, we understand
that you will undertake and complete the following actions:
1.
Revise the emergency organization, the BVPS Emergency Planfand
implementing procedures to provide for performing required
emergency functions at your Emergency Operations Facility
(EOF).
Specifically, the EOF staff should be responsible for
performing the functions of (a) overall management of,your
emergency response, (b) radiological / environmental assessment
and (c) offsite protective action recommendations. '
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These actions will be completed by December 1, 1981, with the
exception that the performance of the function of radiologi-
cal / environmental assessment from the EOF will be implemented
by December 31, 1981.
2.
Pursuant to the requirements of the generic letter dated
February 18, 1981 to all licensees from Mr. D. Eisenhut, NRR,
regarding the minimum staffing requirements for nuclear power
plant emergencies, a study shall be performed to determine how
the augmentation of the onshift staff can be achieved within
the 30 and 60 minute goals of NUREG 0654, Table B-1 after the
declaration of an emergency.
The results of this study will
be documented and forwarded to the NRC for review and evaluation
along with a description of compensatory measures for any
augmentation goals not met.
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Duquesne Light Co.
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The results of the study will be made available no later than
December 31, 1981.
3.
Complete implementation of the planned emergency preparedness
training program.
Specifically, complete the preparation of
lesson plans and conduct the specialized emergency training
outlined in the BVPS Emergency Plan for your personnel and
offsite support organizations.
The portions of this training program designed for your Emergency
Directors, Emergency Recovery Managers, Dose Projection Coordinators,
and Shift Communications Coordinators will be completed by
December 1, 1981.
The remainder of the required training will
be completed by February 15, 1982.
4.
Identify techniques which can compensate for uncertainty
associated with plume trajectories in the BVPS environs and
incorporate them into the dose calculation methodology.
Additionally, training in this methodology shall be completed
for all shift personnel who would be responsible for making
dose assessments.
This will be accomplished by December 1, 1981.
5.
Finalize plans for and make operational your interim Emergency
Operations Facility, including communications equipment,
decisional aids and reference materials.
These plans should
also include provisions to reduce the potential for congestion
in the Control Room / Emergency Coordination Center area by
performing non plant mitigation / operation functions in the
Technical Support Center and EOF.
The interim Emergency Operation Facility will be made functional
no later than December 1, 1981 with the exception of the dose
assessment facilities which will be operational no later than
December 31, 1981.
6.
Revise the notification procedures to provide for prompt
notification of your offshift emergency response organization
and offsite agencies.
Individuals on each shift shall be
trained in the use of the revised procedures and any equipment
changes.
These revisions and actions will be implemented no later than
December 31, 1981.
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Duquesne Light Co.
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In addition to the above actions, please inform this office in writing,
when the aforementioned actions have been completed.
If our understanding of your planned actions described above is not in
accordance with your actual plans and actions being implemerted, please
contact this office by telephone (215) 337-5000, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Your cooperation with us on this matter is appreciated.
Sincerely,
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Ronald C. Hayne
Director
cc:
F. Bissert, Manager, Nuclear Support Services
R. Washabaugh, QA Manager
H. P. Williams, Station Superintendent
W. S. Lacey, Chief Engineer
R. Martin, Nuclear Engineer
K. Grada, Superintendent of Licensing
J. Sieber, Manager, Nuclear Safety and Licensing
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T. D. Jones, Manager, Nuclear Operations
R. M. Mafrice, Nuclear Engineer
N. R. Tonet, Manager, Nuclear Engineering
Public Document Room (POR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
Commonwealth of Pennsylvania
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