ML20095F082
| ML20095F082 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 08/21/1984 |
| From: | Woolever E DUQUESNE LIGHT CO. |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| References | |
| 2NRC-4-130, NUDOCS 8408270165 | |
| Download: ML20095F082 (19) | |
Text
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Duquesne Licjit 2ggg,33 Nuclear Construction Division Telece 6
Robinson Plaza, Building 2 Suite 210 Pittsburgh, PA 15205 August 21, 1984 United States Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Mr. George W. Knighton, Chief Licensing Branch 3 Of fice of Nuclear Reactor Regulation
SUBJECT:
Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 Hydrology /EPP Open Item Response Gentlemen:
This letter forwards responses to the issues listed below. Duquesne Light Company plans to incorporate the responses to the FSAR questions into a future FSAR amendment. The following items are attached: :
Revised response to Outstanding Issue 3 of the Beaver Valley Power Station Unit No. 2 Draft Safety Evaluation Report. : Response to Outstanding Issue 165 of the Beaver Valley Power Station Unit No. 2 Draft Safety Evaluation Report. : List of Emergency Plan changes required to reflect Unit 2 Operation : Copies of instructions and evacuation maps for the public are included for staff review.
DUQUESNE LIGHT COMPANY SUBSCRIBED AND SWdRN TO BEFORE ME THIS
(
eJt/l DAY OF deud
, 1984.
By G '
dp/Lik Ef J. Woolever
?t2[%
4ha)
Vice President Notary Public
. ANITA ELAINE REITER, NOTARY PUBLIC ROBINSON TOWNSHIP, ALLEGHENY COUNTY TJZ/wjs MY' COMMISSION EXPIRES OCTOBER 20,1986 Attachment s cc:
Mr. H. R. Denton, Director (NRR) (w/o)
Mr. D. Eisenhut, Director Division of Licensing (w/o)
Mr. E. A. Licitra, Project Manager (w/o)
Ms. M. Ley, Project Manager (w/o)
Mr. G. Walton, NRC Resident Inspector (w/o) pM S
84082701A5 a4032105000412 i
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r Unitsd Stcteo Nucisar R2gulctcry Commiccion Mr. Gacrg2 W. Knighton, Chicf
.Page 2 COMMONWEALTH.0T PENNSYLVANIA )
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SS:
COUNTY OF ALLEGHENY
)
On this c2dd/.dayof
/ f/
, before me, a Notary Public in and for said Commohealth and ' County, personally appeared E. J. Woolever, who being duly sworn, deposed and said that (1) he is Vice President of Duquasne Light, (2) he is duly authorized to execute and file the foregoing Submittal on behalf of said Company, and (3) the statements set forth in the Submittal are true and correct to the best of his knowledge.
MY A.20 /
Notary Public DUQUESNE LIGHT COMPANY ANITA ELAINE REITER, NOTARY PUDUC ROBINSON TOWNSHIP, ALLEGHENY COUNTY MY COMMISSION EXPlRES OCTOBER 20,1986 J
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ATTACHMENT 1 Response to Outstanding Issue 3 of the Beaver Valley Power Station Unit No. 2 Draft Safety Evaluation Report Draft SER Open Item No. 3 Draf t SER Open Item No. 3 concerns the basis of the technical specifica-t ion limiting plant operation to Ohio River elevation 654 f t, mal. and above and also the ability to shut down the plant if the river level falls below elevation 654 ft. ms1. (OSER Section 2.4.11.2).
Response
The technical specification, described in FSAR Section 2.4.14, was established for BVPS-1 and has been adopted by BVPS-2.
This technical s pecification requires that plant shutdown be initiated when the river level falls to 654 f t. mal.
The basis for the 654 ft. mal, shutdown elevation is described in detail in Applicant Response to NRC Regulatory Staf f Position 1 (7/19/73), BVPS-1 FSAR Section 2.14 (attached).
In summary, the design minimum net positive suction head for the BVPS-1 raw water pumps, which are necessary for normal station ope ration, is reached at 654 ft. mal.
Although the technical specification requires initiating a plant shut-down at river elevation 654 f t.
mal., the intake structure can provide quantities of se rvice water adequate fo r the shutdown and cooldown of BVPS-2 down to the design low river water level of 648.6 f t. mal.
The water level of 648.6 ft. mal. is es tab li shed in the March 29, 1973, letter from the U.S.
Army Corps of Engineers (USCOE) to Mr.
R.
J.
McAllister of Duquesne Light Company (attached).
Based on a reasonab le scenario of eve nt s as de sc ribed in the USCOE letter of November 1,1973 (attached),;which was originally agreed to by the NRC in the BVPS-1 SER pages 2-9' and 2-10 (attached), the river level will not drop below the design low water level of the BVPS-2 service water pumps.
Therefore, BVPS-2 will always be able to draw sufficient water to achieve cold shutdosm.
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- egulated ficws using procacility== exceedance frequency as abscissa in your p r e sentati=n.
To substantiate ycur analysis discuss the historical icw ficws recorded in the vicini:y cf
- ne site and the potential future ef fects of ficw :egula:icn.
R e seen se s
icv ficw f requency curve f or the Chic R;ver a* Shipping?c :
as A
shcwn in
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This en:ve
- eprasants
- ne icwest continuous 7
day =ean fiews :na: would ce=ur.
- is based en a s ~. a..i s. '.. ' '
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a s. ; ;
- v. =. 2.- 3 (1929-da te) as mcdified bv.
the present :eservcir system.
A..
instantanecus icu ficw ceuld be slightly 1:wer, but with
- ne large impoundments behind the locks and dams, tne 7 day flew cculd be :.:cvided centinuousiv.
bv.
temc.orarily drawing en t.7 e rive: stcrage when needed.
The icwes-ficw of racerd occurred du=ing the ex :sme d:cugh:
1930.
A minimum cd 1,250 cfs fiewed pasu Shippingpc : in Acqust of that year.
Since tha time eigh rese:voirs vita icw flew
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auementation ca=. abilities have been construered ae ccneemporary..
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Several reservoirs in the authoriced c= planning stages veuld have a substantial influence en low ficws.
In cluded in this g cup are stenewall
- Jacksen, acwlesburg, and St. Petersburg.
Collectively, they would increas e the minimum flew c
i app cximately 6,000 cfs at shippingpert.
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The fellcwing margin remains for saf ety : elated pumps j
in the intake structure:
submergence (f t)
Minimum Ma:qin
- 21. ; ;. '
submergence (Percent)
Requi:ed ( f t)
Pume River Wate:
9 4
100
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Fire Pump 5
t.6 210-bI s
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l 3VPS TS AR Amendmen i
12/7/72 4.s A c neulaterv staff 7 cst i:n 1 (7/19/731 Tho respense
- = ;uestion 2.1 concerning icw-flev cccur-ence en
, tha chic River is act acceptable because your assumption hn tne
- minimum flew re sults f
- cm reservei: regulation, does nce previde l adequate assurance of a dependaele water supply during d:cugh-pe: icds, mo re seve=e taan have occurred historically.
3y 4
en= apelating an unregulated low-flow frequenev for d:cugh-l condi:icns, whien may be., enamacterized as the mest severe i rococnably pessible a.: the plan-
- site, we and cur consultant (Nunn, snyder and Assceiates), believe an instantaneous icw flew of abcut 300 cubic feet per second could occu=.
1 l Thorefore, we require ca ycu p cvide an analysis which indica tes the expected river water levels a: the intake st::-1.c cre
, and which demons rates.no capacility of the sadscy-related pumps l (sc vice ware: and fire wa:er) c p=cvide their required ficw
- .n such a
situatien.
If safsty-related pumps would not be capable
- of perfc= ming their function in a,
plant shutdown mode of operation in such a condition of low flew, provide the bases for
, a nochnica.1 speci Aication wcica requires a plant, shutdown at a
' s (fied conditica cf rive:
wase:
flow that would assure a-
- 1.,
e thi.ty days supply of water.
7:cvide sufficient ec alicw us to make an independen,s review of your s--
p-info rma tien f
i analysis.
l Reseense
( ( To AZC Reg. Staf f Pos. 1 (7-19-7 3) )
the regulation of the New cumberland Pool during j Information on i ext = cme icw ficu ccnditions war requested
'f:cm the Pittsburgh j
I
- District, cc=ps of Ingineers.
A copy cf the request and the 8
, coryc' answering letter are attached.
i At a
ficw of 800 CTS coincident with lock damage which eccid l roasenably be expected to eccur ::e pool would d:cp t.5 ft sc
- olevazion 66 2.7 f ee
- h. s. :..
- l Tho New Cumberland Pcci is naintained at Il 664.5 through the use cf Iceks, dams,.
and storage reservei=s in the river basin.
l Records indicate that this elevation can be maintained at flows up to 20,000 cfs i
l Normal plant operatica can be continued at river levels between Il 695 and Il 658 At Il 695 ene plant is shutdcwn as discussed l
in Response 2.16.
At Il 65u, the river water, raw water, and j
f water pumps still have' adequate NPSR to meet design r
irements as summarized belew:
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3';ps Ts;.R A.mendmen t 5 12/7/73 J
Minimum Submergence subnergence (7t) 7".me Recuired (7t) at Il 653 13.4 River wata=
4 Fire T.6 10.1 Raw water 5
5 s
Since the raw wata=
pumps design minimum N7sE is reached at Il 6 5 n, Un it 1 shutdewn wili be initiat ed.
"'h e occu:Tence cf river levels belev Il 554 is highlf imp cbable.
It is ft: her concluded that when the.:ect lavel declines below Il 559, an unusual ec :::ence is taking pla ce.
In this situati:n,
.h e cp rat== will centac the New cummerland Oam icek Master determine the pessible cause of ne pool level,excursten.
If the pect level canne be maintained ahove Il 654, the ope ra==
will initia:a a Unit t shu dcwn.
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DEPARTMEAT Ok THE ARMY g
PETTB8URGM OtSTRICT. CORPS OF ENGINEERS
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j PETTSBURGM. PENNSYLVANIA 1512a ORPED o 29 March 1973
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Mr. Robert J. McAllister Structural Engineer Duqueene I.ight Company 435 Sixth Aveme Pittsbe gh, Pennsylvenia 15219 Minimam River Flows at the
Dear Mr. McAllister:
Beaver Valley Power Station We have made a reanalysis of low flows in the Ohio River.
Co=putericed sicalation models were developed to reproduce the hydrologic system of the Pittsbe gh District. Included in this system were a'1 of the reservoirs that no:r. ally aupent low flows.
The model was then used to si= alate regu-lated strean flows for the period of record (1929-1966) accord 4"g to the operating schedules adopted for each reservoir.
\\
Results of these computer analyses show that, with the contempora.ry syste=
cf reservoirs, a ad * = flow of 4000 c.f.s. would have occurred at Shippingport daring the record d:cusht of 1930.
This value supersedes the mini =m value of 4700 c.f.s. famished several years ago.
The correspond-ing mini =a= vater surface elevation at the Beaver Valley Power Station site would be 6.],S.6 instead of 649 0.
Sincerely, 4
DAN A. CO MER Major, Cons of Engineers Acting District Engi.neer i
Copy furnished:
!!r. Richard C. Miller l
Hydraulic-Environmental Engineer Stone & Webster Engineering Corp.
225 Franklin Street Boston, Mass.
02107 Q 2.14-4
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DEPARTMENT OF THE ARMY g
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49 mTTssVRGH. PfMMSYL.YANtA 15212
-g 1 November 1973 ORPE M I
Pz. Richard.C. Miller Senior Hydraulic-Environmental Engineer Stone & Webster Engineering Corporation P. O. Box 2325 Boston, Massachusetts 02107 Beaver Valley Power Station -
Dear Mr. Miller:
Ioss of Pool In response to your letter of 2 October 1973, we are submitting the follow-ing info =ation relative to the possibility of a drop in the New Cumberland normal pool leve1 during extreme low flow conditions.
Should such an event occur or be anticipated, the Pittsburgh District The Center v"1 then be responsible for Emergency Center will be alerted.
directly notifying the Beaver Valley Power Station, landings, intakes and pq It v411 also other interested parties affected by a drawdown in the pool.
4 notify the public through press releases to the various news media.
During any low C.ow period, navigation pools such as New Cumberland would not be intentionally lowered.
Iocking activities could be continued at normal rates without any drawdown of the pool, evan if the flow was at the i
minimr.m rate of 800 c.f.s. stated in your letter.
The only lock or tainter gate damage reasonable to assume during a drought period would be the loss of a lock gate due to a navigation accident.
Sabotage is not considered in this evaluatics.
Inclosed is a copy of a letter sent to P. Robert J. McAllister of Duquesne Light Company explain-ing the situations which could cause loss of pool and the resulting measures that could be taken to correct the problem.
In that letter, a flow of L,700 c.f.s. was used for the analysis. Ioss of more than one gate was also discussed.
It was assumed that any such incident would occur during a flood and that repairs would be made within two weeks.
At that time the flow would be no less than 20,0C0 c.f.s. with a corresponding elevation of 651 feet above mean sea level (m.s.l.) at the plant.
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1 Ncvember 1973 ORPED-O Mr. Richard C. M4"ar Our present analysis considers an extre:e dmught with a flow of 800 c.f.s.
Since the mly damage that could reasonably be expected to occur with this flow is the loss of a lock gate, the bulkheads could be installed within four hours and there would be no further loss of pool.
During these four hours of open lock flow, the pool would drop 1.8 feet to elevation 662 7 feet m.s.l.
s Computations were made to evaluate the loss of a tainter gate or lock gate without placing the bulkheads, although we do not consider this a reasonable possibility.
Since you are interested in the rate of fall to your critical elevatia: of 9L8.0 m.s.l., we have included Plate 1 showing the pool recession for these conditions.
Sincerely, 2 Inc1 N. G. DELBRID E As stated Colonel, Cozps of Engineers District 3hgineer gk j
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l To provide assurance that flood protection will be effective for the river water intake l
structure (the only safety related structure that would be affected) we have taken the position that technical specifications limiting plant operation would provide for such situations. Accordingly, the applicants have proposed a technical specification which provides for flood protection in the event of rapid river rises as well as for runoff floods up to and including a Pff. He find this acceptable.
$lte drainage includes the hillside draineqe south of the plant, the plant area it-self, and Pecos Run which parallels the highway road fill, just east of tha plant between the highway and cooling tower area. Although the desion basis selected for site drain-age is substantially less seyere than would be produced by local probable maximum preci.
pitation, the ground in the plant area slopes toward the Ohio River and Pegos Run, and runoff in excess of storm drainage inlet and piping capacity is not espected to Cause water levels greater than a few inches aoove the ground surface. The applicants have concluded, and we concur, that such levels should not constitute a flood threat to safe-ty related f acilities.
Peggs Run is constricted in a deeply incised channel between the highway optanlunent and the cooling tower area at elevations as low as about 670 feet above MSL. A strue.
ture across Peggs Run about 700 feet east of the procosed location of leaver Valley Unit 2 containment provides the base for the railroad track stream crossing serving the plant area. The retiroad crossing and grade in the area is sufficiently below plant grade such that Peggs Run floodino from severe storms, even with the retiroad structure waterway blocked, should not reacn safety related structures located to the west and on hieher
(
nrnunn.
Another potential source of plant flooding of safety related features is associated with the failure of the roofs of buildings. At our request. the applicants have pen.
vided desion bases for roof drainage systems that will prevent rainfall accumulations from escoeding the structural design bases of the roofs of safety related buildings during stores as severe as a local probable maximum storm.
We have also analyzed the potential for ice flooding based upon historical records in the region and consideration of local topograpny. Although such flooding is pcssible at the site the PNF is the controlling flood and was used in establishing the design flood level for the site.
Water will be drawn frors the Ohio River through the intake structure for plant cool-ing purposes. This includes make.us to the cooling tower basins for plant operation (non Safety-relatec). and for safety.related purposes.
A sill at elevation 6% feet above M$L will liaitt the river water Icvel for which water can he supplied to the intake structure sump for plant use. The applicants have proposed a minimum design river level at elevation 649 feet above M$L based on a 4.700 j
Cfs minimum river flow coincident with an arbitrarily postulated downstream dam failure.
The minimum safety reewirements are an emernency river water system flow of 9.000 ca11ons per minute (20 cfs) coincident with fire pump demand of 2."00 gallons per minute (6 cfs).
In examining the analysis of potential low river flows, it was determined that the 4.700 cfs mintmum river finw Assumed by the applicants was pr0d1CatC6 on the ability of upstre n re w voirs to au-aent Inw river finas. $1nce tne dependability of such auseen.
tatlos. Is t.ncJ r.n 6tprs piovidinn acm voir storaete for accrostautely a drought of record, we ac our consultant (Munn. $nyder and Associates) analytre the rutential river flow that could he espect"o ua.ner very severe drouant concttions, g
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He estimated that the minimui river flow rate could be as low as 800 cfs. This flow rate is considered adeouate for safety-related plant water supply. We had originally detemined that such a ' low flow could result in a river level well beim the minimum design level selected by the applicants. On this basis we informed the applicants that we required an analysis to demonstrate the long tem residual heat renoval capability for river flows as low as 800 cfs. the* lowest river flow considered reasonable possible of occurrinn. We have reviewed and concur with the applicants' analysis which shows that under reasonably severe river condf tions that could be expected with flows as low as 800 cfs the river wat6r levc:1 can be maintained above the minimum design level selected by the applicants.
The potential for channel diversion or blockage of the Ohio River such that safety-related water supplies would not be avanable is not considered credible because of the lack of adverse floodplain topograpny along the river where diversion or blockage could adversely affect the plant.
Operating procedures employing the use of technical. specifications to limit plant operations are required for severe floods to assure the operability of safety-related eouipment. At the recuest of the staff, the applicants have provided the bases for a technical specification that contains the following elements:.(1) provisions for a flood alert at river levels of 690 feet MSL or above. (2) provisions for plant operating personnel to maintain contact with operators of upstream dams. (3) imediate plant shut-down to be undertaker. and protection of required safety-related equipment to be initiated
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developed for such situaticns.
The site is on a predominantly permeable sand and gravel terrace, underlain by bed-rock at about elevation 630 feet above MSL. Althougn some ground water migrates in bec-ding and joint planes and some permeable seams in the bedrock, the major movement of ground water at the site is through the permeable surface terrace materials toward a direct hydraulic connection with the river. Ground water levels because of the direct hydraulic connection, can be expected to De slightly higher than river levels, except enere influenced by well pumping.. The only wells withti the influences of the operating plant are tw wells at the adjacent Shippingport Atomic Power Station and two temporary Deaver Valley plant construction wells.
We have concluded that aceeutable flood design bases have been provided, that an acceptable water supply can be assured for safety-related purposes, and that ground water flow is not intercepted by any wells beyond the control of the soplicants before reachino the Ohio River. Acceptahic bases for technical specifications which limit plant operation during high river water levels have been theorporated in the application, and acceptable hydroloqically-related design bases for the auxiliary river water system (furthur discussed in Section 9.3.4 of this report) nave been establisned.
2.5 Geoloov and Seismoloev We and our advisor the U.S. Geoloqical Survey (USCS). reviewed the geology of the site as presented in the PSAR and its amenoments for Unit I at the construction permit s tane of our review. c'd co-care: this infor Mica wi th the avalla.ble literat' era.
The USCS :.; a t ed. an1 u e enc o-ecci, th.st the analysis apacared to be carefully ceriv.'d and to a
k present an attecwatr rpraisal of thn'.c aspects of the ecolony inat would be pertinent to an enett neerir.q evalvtion cf tha ti te.
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ATTACHMENT 2 Response to Outstanding Issue 165 of the Beaver Valley Power Station Unit No. 2 Draft Safety Evaluation Report Draf t SER Open Item No.165:
Section 13.3.2, " Evaluation of the Applicant's
- Onsite Emergency Plan," and Section 13.3.3, " Conclusions" Item 1: Page 120, Section 13.3.3, Reference Section-13.3.2.1 Revise the emergency plan to include Unit 2 as an operating unit vice a construction site.
Response
A list of changes to show Unit 2Las an operating unit has been compiled (At tachment 3).
These ch anges will be included in the scheduled February,1985, and April,1985, submittal of the revised
~ Emergency Preparedness Plan and-Implementing Procedures, respectively.
Item 2: Page 120, Section 13.3.3, Reference Section 13.3.2.3 j
The plan' should specify the persons, by title, who are' authorized to request Federal assistance (C.1.a).
Response
A statement assigning this responsibility has been added to Section 5.5.2.1, " Emergency Director Responsibilities," 'and Section 5.2.2,-
" Emergency Recovery Manager Responsibilities," of Issue 8 of the BVPS-1 Emergency Preparedness Plan (EPP) due to be issued in August 1984.
Item 3: Page 121, Section 13.3.3, Reference Section 13.3.2.3 The plan should specify licensee,- State, and Local resources avail-able to support the Federal response (C.1.c).
Response
j-A reference to the Greater Pittsburgh International Airport and its location will be added to Section 2.
Also included in Section 2 will be a statement referencing the Resource Manuals developed by the three counties in the EPZ.
The other examples ment ioned in Section C.I.c of NUREG 0654 are currently addressed in the plan.
4 Item 4: Page 121, Section 13.3.3, Reference Section'13.3.2.4 Correct the de ficiencies in the EAL sets as listed in Section 13.3.2.4.
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. Response:
The EAL's will be reviewed and revised as necessary.
The revised EAL's will be included in the February 1985 revision'of the EPP.
Item 5: Page 121, Section 13.3.3, Reference Section 13.3.2.7 The printed instructions and evacuation maps for the public shall be developed and submitted for staff review (G.1).
Response
The instructions and evacuation maps ( Annual Mailer) are reviewed annus11y by Pennsylvania, Ohio, and West Virginia, and Beaver,
Hancock, and Columbia Counties and approved by each.
Comments are incorporated and copies are sent to the applicable FEMA regions. A copy'of the instructions. and evacuation maps (Attachment 4) have been included for staff review.
Item 6: Page 121, Section 13.3.3, Reference Section 13.3.2.11 The plan should' specify methodology for initial accountability (to be accomplished within 30 minutes) and the methodology to be used to maintain accountability on a continued basis (J.5).
Response
Statements addressing the 30 minute criteria and the detailed accountability Emergency Implementing Procedure have been included in Issue 8 of the EPP.
Item 7: Page 121, Section 13.3.3, Reference Section 13.3.2.12 The plan lacks a letter of agreement for ambulance service (A.3).
Response
A let ter of agreement with Medic Rescue ambulance service (ef fec-tive April 3,1984) has been included in Issue 8 of the EPP.
Item 8: Page 121, Section 13.3.3, Reference Section 13.3.2.12 Licensee shall certify annually as to the currency of the letters of agreeir.ent (P.4).
Response
The letters of agreement are addressed in Section 2.6 of the plan.
A. statement has been included in Issue 8 of the EPP stating that the le tters of agreement will be reviewed and certified to be current on an annual basis.
ATTACHMENT 3 Emergency Plan Changes Needed to Incorporate Unit 2 Section 1
. 1.
Definitions - #5 eliminate Unit 2 "jobsite."
Section 2
~
1.
Remove statement in first paragraph concerning construction of Unit 2.
Section 4
~
1.
Section 4.2, " Spectrum of Postulated Accidents," will need revised due to major dif ferences between BVPS-1 and BVPS-2 FSAR assumptions and parameters.
2.
Table 4.1,
" Action Level Criteria for Classification of Emergency Conditions," will need revised due to possible Technical Specifica-tions changes for BVPS-2.
3.
Table 4.2, " Radiation doses Resulting from Postulated Accidents," will need' revised due to the same reasons as #2 above.
2 Section 5 1.
Section 5.4.2, "BVPS Construction Organizations," will need revised.
Section 6-1.
Section 6.7, " Protective Actions," needs to have references to Unit 2 construction forces eliminated.
2.
.Section 6.7.1, "Onsite protective Actions," will need revised due to various references to Unit 2 "jobsite."
Also, inclusion of Unit 2. in write-ups with modifications of protective areas.
3.
Table 6.2, "Notifica tion Matrix," needs to be revised to eliminate BVPS-2 Construction section.
i Section 7 f
1.
Section 7.4.3.2, " Seismic Equipment " may need possible modification based on Unit 2 location and instruments.
2.
Section 7.5.2, " Station Assembly Areas," will need added for Unit 2.
' 3. ' Section 7.5.2.3, "BVFS Unit 2 Jobsite," will be eliminated.
4.
Section 7.6.1, " Bell of Pennsylvania Telephone System," will need to eliminate BVPS-2 Construction Offices.
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Appendix D,
Enclosures 8,
9, and 10
" Process' Ef fluent Radiation-Monitoring System," will need revised to reflect ' Unit 2.
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