W3P83-2494, Forwards Response to NRC Re Emergency Plan
| ML20077F238 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 07/28/1983 |
| From: | Drummond F LOUISIANA POWER & LIGHT CO. |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| References | |
| W3P83-2494, NUDOCS 8308010302 | |
| Download: ML20077F238 (19) | |
Text
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. no sox eOOe P O W E R & L i G H T! NEW OALEANS LOUGANA 70174-6000 e (504}368-2345 EEE0$IYS July 28, 1983 W3P83-2494 3-A45.08 Director of Nuclear Reactor Regulation Attention:
Mr. G. W. Knighton, Chief Licensing Branch No. 3 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C.
20555
SUBJECT:
Docket No. 50-382
REFERENCE:
Your letter dated June 27, 1983
Dear Sir:
Enclosed in response to the above referenced correspondence is LP&L's reply to the questions your staff has raised.
The NRC will be kept informed of our progress in the above mentioned areas through contact with Region IV and headquarters staff.
If you have any questions, please do not hesitate to call.
Yours very truly,
&m F. J. Drummond Manager Engineering & Technical Services FJD/RJP/sm Enclosure cc:
E. L. Blake, W. M. Stevenson, J. Wilson, J. T. Collins, G. L. Constable, G. Groesch
' I r308010302 830728 PDR ADDCK 05000382 F
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4 LOUISIANA POWER & LIGHT COMPANY RESPONSE TO NRC LETTER DATED JUNE 27, 1983
- 1. - The improvement items on page 7 of the LP&L evaluation do not specifi-u cally. address the aspect of sheltered assembly as indicated in item 2 on page 6 of the evaluation. Assembly areas discussed in the Waterford 3 Emergency Plan are in an open parking lot.
The evaluation i
also did not address accountablity of all onsite personnel.
Ac-countability was identified as an incomplete area during the EPIA.
Picase provide this information.
LP&L Response:
We are presently developing Revision 5 of the Waterford 3 Emergency Plan. Specifically, section 6.6 " Protective Actions" will be re-vised to incorporate the concept of sheltering as a protective measure.
This concept will also be reflected in Implementing Procedure EP-2-071
" Site Evacuation". Additionally, EP-2-190 " Personnel Accountability" which addresses accounting for all onsite personnel has been developed and submitted to NRC for staff review.
Revision 5 of the Waterford 3 Emergency Plan and Revision 3.to.EP-2-071
" Site Evacuation" is scheduled to be submitted for staff review by October 14, 1983.
2.
Agreement letters with industries (for updating toxic' chemical inventories), discussed in SSER 2, Section 2.2.1, have not been r
submitted to the emergency planning staff for review and evaluation.
LP&L Response:
Such Ictters have been requested from the 12 industries within 5 miles 4
of Waterford 3 which may.have toxic chemical inventories. These industries are those listed in Table 2.2-3 of the Waterford 3 FSAR,
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with the exception of: LP&L's Little Gypsy SES'and Waterford 1 & 2 SES L
which do not produce toxic chemicals; -Argus Chemical lwhich'is a sub-3 sidiary of the Witco Chemical Company and is_ covered by the'Witco. letter:
of agreement; and the Chevron Oil Company which is a laboratory testing.
facility which deals with relatively small quantities of materials.
Kaiser Aluminum and Chemical Corporation of Norco, Louisiana indicated that-they do not have toxic' chemicals on site.
The industries were asked to provide 11etters agreeing to inform LP&L of future changes in their hazardous' materials inventory _and to t inform Waterford 3, through Parish authorities, of the release of toxic materials in hazardousiconcentrations beyond their plant boundaries.
-Ten of the 12 industries have'provided letters of agreement.1JThese
-letters are' included as Attachment-1:to this response..
'LP&L will recontact the remaining industric s and will. submit the 1etters-
.when they.become.available.
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I l 3.
Identify and provide for staff review, the procedures (as discussed on page 6 of the LP&L evaluation report) that provide instruction on the decision to man the Technical Support Center and/or Emergency 1
Operating Facility depending upon site concentration of toxic chemicals and whether or not the accident occurred during routine.
working hours; the decision to activate the emergency facilities after hours requiring evaluation of the direction of travel of the toxic gas plume as well as the responding personnel; and provisions for appropri-ate arrangements with the local law enforcement agencies to allow access to the plant for such support personnel.
4 LP&L Response:
4 An additional Emergency Plan implementing procedure is being developed to address the items identified in question 3 relating to decisions to man emergency response facilities and arrangements for plant access for support personnel. This new procedure is scheduled to be submitted to NRC staff by October 14, 1983.
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4.
With respect to radiological emergencies at Waterford 3 what means have been employed for interfacing and coordinating local industrial plans with the Waterford 3 emergency plan with regard to time to shutdown chemeial process lines, evaluation of industrial plant non-essential persone,1, and make-up and protection of shutdown crews?
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LP&L Response:
The.St. Charles and St._ John Emergency Plans both assign responsibility for coordination of local induatrial plans to the. local emergency.
1 preparedness director. Further, the Louisiana Department of Commerce and Industry nuclear response implementing procedure includes pro-visions for the~ identification of industrial shut-down times.
Finally, LP&L has~been active in providing information to local industries concerning.the Waterford 3 Emergency Plan. The discussion which follows highlights the steps taken to assure adequate coordin-
'ation of planning efforts.
Tab 7 of both the St. Charles' and St. John Emergency Plans contains -
arrangements for industrial response to an accident at'Waterford 3.
These Plans call for the early notification of._ industry so that' shut-down preparation can be made, and for providing necessary re-i source support to industries to assist with protection of workers
- i during shut-down. The responsibility section of Tab 7, Industry Response, to each Parish Plan includes the following:
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Responsibilities
- 1 A.
The Parish EmergencyLPreparedness Director ~
-or his designee maintains the following responsibilities : in regard _.to the pro-1 tective response of: Parish. industry:
1.
To ensure the coordination of' industrial
' emergency plans with Parish 1 plans'for'ani 4
-accident-at Waterford'3.
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'2.
To provide alert / notification to in-dustries within the risk area at the time of an accident.
3.
To coordinate industry actions with those taken by the Parish in response to an accident.
4.
To coordinate resource requirements of industry at the time of an emergency."
l These resource requirements include providing dosimeters and potassium iodide as necessary in the event of long shut-down times. Procedures are also being established in both parishes to allow access to the risk area for replacement shut-down crew members as needed during an a
emergency.
In addition, the Louisiana Department of Commerce and Industry provides direct assistance to risk parishes providing resource support to assist with industrial shut-down. The Department's implementing j
procedure for response to accidents at nuclear power facilities establishes the following:
i "V, B.
The State Emergency representative will assist 3
j the Parish Emergency Organization by:
3.
Assisting in the identification of industries l
that have time consuming shutdown procedures -
in the risk area.
j 4.
Assisting in the determination of the number of dosimeters required for commercial /in-
.dustrial dosimeter requirements for workers located within the plume exposure pathway involved in emergency shutdown.
5.
Provide estimate of number'of dosimeters required to LOEP RADEF Officer."
t On May 25, 1082 a training seminar was held'at Waterford 3 for all major industries in St. Charles and St. John Parishes.
19 industries were represented. An attendance roster appears as Attachment 2 to
.this response. This seminar presented information on the Waterford 3 Emergency Plan..the emergency classification system, notification,
. radiation terminology, EPA protective action guides and protective
. actions in a radiological emergency.- In addition, a sample industrial emergency plan was given out to' serve as a guide ~in the l
preparation'of industrial' emergency plans.
t
- 5.
In the event of an' accident at Waterford 3 that requires rap'id shut-down~and evacuation of'an industrial plant (s),1what hazards should' be expected (toxic release, production of unstable l materials, un'-
controlled chemical reactions,etc.)?
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. LP&L Response:
Discussions have been held with industries in the Waterford 3 area regarding several aspects of emergency planning, including shutdown.
Industries have indicated that rapid shutdowns could involve some loss of product and possible damage to equipment. However, it is unlikely that releases of hazardous materials would result from rapid shutdowns, since the shutdowns are intended to ensure the safety of the plant personnel and public.
It should be noted that during the recent acrolein explosion in the vicinity of Waterford 3 no hazardous materials were released as a result of protective actions taken by local industries.
6.
Emergency Plan Implementing Procedure EP-2-110 is not clear as to how those industries, not on the " Hotline" (Attachment 7.3 of the LP&L report), are going to be notified in an emergency situation.
LP&L Response:
Of the 12 industries identified in Table 2.2-3 of the Waterford 3 FSAR which have potentially hazardous toxic chemical inventories (see response to question 2), 11 are covered by the industrial hot-line and one by industrial mutual aid radio.
Of the 24 major industries within 10 miles of Waterford 3, 18 are covered by the industrial hot-line or industrial mutual aid radio.
All of these industries not covered by the hot-line or by' radio will receive notification by telephone directly from the Parish EOC in the event of an emergency. Also, all of the industries are located in areas covered by the Waterford 3 siren warning system which meets the design criteria established in NUREG-0654 Appendix'3.
In addition, the Louisiana Department.of Commerce and Industry maintains a listing of all' industries ~withinfthe Waterford:3 10 mile EPZ. This Department's implementing procedure for response to accidents at nuclear power facilities states that the Department is responsible for verifying the notification'of industries in the 10 mile EPZ and for assisting in the notification of these industries. This notification will be made to industry by Department representatives via telephone.
Both St. Charles and St. John Parishes will employ fan out warning as a back-up to the primary means of notification. Under this system, sheriff's
-deputies and/or firemen will supplement notification in risk areas by.
using sound equipment to notify _ persons and by going from door-to-door where necessary..As demonstrated in recent emergencies, this system-will be used to supplement notification to industry as well.
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ATTACHMENT 1 LETTERS OF AGREEMEIR g.
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E. I. ou PONT DE NEMOURS E COMPANY IseCORPOR4TfD PONTCHARTRAIN WORKS P. O. Box 2000. LAPLACE. LA. 70068 POLYMER PRODUCTS DEPARTMENT 12 Aug 81 L.
V.
Maurin Assistant Vice President Louisiana Power & Light 142 Delaronde St.
P.O.
Box 6008 New Orleans, Louisiana 70174
Dear Sir:
WATERFORD 3 - EMERGENCY PLAN / HAZARDOUS MATERIAL Some information you requested concerning hazardous materials at this site is attached.
Please respect the confidential nature of the information.
With regard to future information:
1.
We'can provide LP&L with information regarding significant future changes in hazardous material inventory.
2.
The Pontchartrain Works Emergency Plan includes prompt notifi-cation and recommendations to public authorities and to others downwind of the site in the event that hazardous concentrations of toxic materials are expected to extend beyond plant property.
Those to be notified are fence line neighbors, St. John Parish Sheriff's Office,, State Police, and as necessary, Mutual Aid and
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the U.
S. Coast Guard.
Sincerely, uap/
C.
J.
Defiel Staff Engineer CJD/jac Attachment You and Du Pont. There's a lot of good chemistry between us.
GATX TERMINALS CORPORATION RIVER POAD o O BOX 157 GOOCHOPE, LA70079 504 243 25 1 March 19, 1982 Mr. George Bailey Louisiana Power & Light Company Post Office Box B K111ona, Louisiana 70066
Dear Mr. Bailey:
In accordance with our telepnone conversation on March 17, 1982, with reference to notification of Waterford 3, it is our intention to follow our normal procedure for plant emergencies.
When any emergency occurs GATX notifies the St. Charles Parish Emergency Preparedness / Industrial Hot Line System. This will access the emergency system and all areas concerned will be notified.
Very truly yours, GATX TERMINALS CORPURAIION
/.-
[hLW M. R. Monie, Jr.
Terminal Manager MRM,Jr./gJ cc: J. Fish f
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Letter of Agreement Mr. L.V. Maurin Assistant Vice President-Nuclear Operations Louisiana Power & Light Co.
Waterford 3 SES P.O. Box B Killona, La. 70066
SUBJECT:
Waterford 3 SES Emergency Plan
Dear Mr. Maurin:
This letter will serve to confirm an agreement between GHR Energy Corp. and Louisiana Power & Light Company, regarding Emergency l
Planning at the Waterford 3 Nuclear Plant.
GHR Energy Corp. agrees to:
a.
Provide PL&L with information regarding significant changes in inventory of hazardous materials which could affect the safety analysis of Waterford 3, and b.
Promptly notify Waterford 3 f f a release of hazardous material which could affect Waterford 3 occurs at our facility.
This notification would be via the St. J'.harles Parish Emergency Preparedness / Industrial Hot line System or via phone.
Yours ery tryJ,
l David G. Griffin /
Manager of Enviro'nmental Engineering-DGG/ cgs
P.O.
BOX 74, H A H N VILLE, LOUISI A N A 70057 PHONE (504) 783-6661 August 14, 1981 Mr. L. V. Maurin Assistant Vice President - Nuclear Operations Louisiana Power 6 Light Co.
Waterford 3 SES P. O. Box B Killona, Louisiana 70066 Re:
Waterford 3 SES Emergency Plan
Dear Mr. Maurin:
This letter will serve to confirm an agreement between Hooker Chemicals and Plastics Corp., Taft plant, and Louisiana Power 6 Light Company, regarding Emergency Planning at the Waterford 3 Nuclear Plant.
Hooker Chemicals and Plastics Corp., Taft plant, agrees to:
a.
Provide LP6L with information regarding changes in inventory of hazardous materials which could affect the safety analysis of Waterford 3, and b.
Promptly notify Waterford 3 if a release of hazardous material which could affect Waterford 3 occurs at our facility. This notification would be via the St. Charles Parish Emergency Preparedness / Industrial Hot Line System or via phone.
Very truly yours, HOOKER CHEMICALS S PLASTICS CORP.
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J. L. Hurst III Works Manager JLif/dbb
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l OCCIDENTAL CHEMICAL COMPANY e
P. O. Box 74, Hahnville, Louisiana 70057 (504) 783-6661 March 8, 1982 Mr. L. V. Maurin Assistant Vice President Nuclear Operations Louisiana Power and Light Companf Waterford 3 SES P.O. Box B Killona, Louisiana 70066
SUBJECT:
Waterford 3 SES Emergency Plant
Dear Mr. Maurin:
This letter will serve to confirm an agreement between Occidental Chemical Company and Louisiana Power and Light Company (herein "LP&L"), regarding LP&L's Emergency Planning at the Waterford 3 Nuclear Plant.
Occidental Chemical Company agrees to use its best reasonable efforts, as follows:
a.
To provide LP&L with information, as may be reasonably requested by LP&L from time-to-time, regarding changes in storage capability for hazardous materials which could affect the safety analysis of Waterford 3, and
~
b.
To promptly notify appropriate civil authorities if a release of ammonia exceeding 100 pounds occurs at our Taft Ammonia l
Plan: facility located at Hahnville, Louisiana.
This notification would be acc.omplished by telephone notice to the St. Charles Parish Emergency Preparedness / Industrial Hot Line System.
Very truly yours, O CIDENTAL CHEMICAL COMPANY ff h'
u Jesse N. Payne
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Shell Oil Company. Shell Chemical Company A owmon of shou os company Norco Manufacturing Complex P.O. Box 10 Norco, Louisiana 70079 LETTER OF AGREEMENT January 11, 1982 Louisiana Power & Light Company ATTN Mr. L. V. Maurin Assistant V.P. - Nuclear Operations Waterford 3 SES Nuclear Plant P. O. Box B Killona, LA 70066 Gentlemen:
SUBJECT:
HAZARDOUS MATERIALS CAPABLE OF AFFECTING WATERFORD 3 SES NUCLEAR PLANT AT KILLONA, LA.
This letter will serve to confirm an Agreement between Shell Norco Manufacturing Complex and Louisiana Power & Light Company (L.P.&L.),
concerning L.P.&L. emergency planning at their Waterford 3 Nuclear Plant located at K111ona, Louisiana.
Shell Norco Manufacturing Complex agrees to:
1.
Advise L.P.&L. periodically regarding significant changes in hazardous materials inventory that could affect the safety analysis of Waterford 3 Nuclear Plant at Killona, Louisiana, and 2.
Promptly notify Waterford 3, via the St. Charles Parish Civil Defense Emergency Operations Center " hot line" telephone system, if a hazardous material release occurs at our facility that could affect the Waterford 3 Nuclear Plant.
In agreeing to undertake the foregoing action, Shell does not assume any additional liability, beyond that which it might otherwise have, for any release of a hazardous material at the facility.
Very truly yours, f
L $ ant.f H.
. Bettencourt Manager DRC/ dad
Shell Oil Company One Shell Square P. O. Box 61555 d**"**"*"***'
DATE: JANUARY 12,1982 Onshore Division
- [#@g Louisiana Power & Light Co.
NS Waterford 3 SES g
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P. O. Box B O
Killona, LA 70066 e
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k@'#%vi ATTENTION: MR. L. V. MAURIN c
.sO ASSISTANT VICE-PRESIDENT, NUCLEAR OPERATIONS 33 RE:
HAZARDOUS MATERIAL QUESTIONNAIRE - CRAWFISH PLANT GENTLEMEN:
Attached is our response to the questionnaire included in your letter dated July 23, 1981.
We regret the delay; your original letter was not received at the plant.
If you require additional information, contact Mr. S. J. Kaiser (504-588-7487).
We foresee no hazardous material inventory changes at the Crawfish Plant.
Should we significantly revise the plant's design or operating procedures, you will be notified.
The Crawfish Plant is tied into the St. Charles Parish Emergency Hot Line; notification of an accidental release of a significant amount of hazardous material would be given over this system.
Very truly yours, h$
M. L. Mardick Division Production Manager SJK/CL0 ATTACHMENT w
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%id UNION CAR 8IDE CORPORATION pour esses sox, so.HAMNVfLLE.LCLUSIANA 70C57 POLYCLERNS CIVISION - STAA PLANT ilanuary 20, 1982 Mr. L. V. Maurin Assistant Vice President - Nuclear Operations Louisiana Power and Light Company Waterford 3 SES Post Office Box B Killona, Louisiana 70066
SUBJECT:
Waterford 3 SES Emeroency Plan
Dear Mr. Maurin:
This letter will serve to confirm an agreement between Union Carbide Polyolefins Star Plant and Louisiana Power and Light Company, regarding Emergency Planning at the Waterford 3 Nuclear Plant.
Union Carbide Polyolefins Star Plant agrees to:
a)
Provide LP&L with information regarding changes in inventory of hazardous materials which could effect the safety analysis of Waterford 3, and b)
Promptly notify Waterford 3 if a release of hazardous material which could affect occurs at our facility.
This notification would be via the St. Charles Parish Emergency Preparedness /
Industrial Hot Line System or via phone.
Yo s very truly, i
J. M. Cockrell Plant Manager JMC:ls
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MBB UNION CAR 8IDE CORPORATION P. O. BOX 50. HAHNVILLE. LOUISIANA 70057 Ethylene Oxide / Glycol Division September 8,1981-Mr. L. V. Maurin Assistant Vice President-Nuclear Operations Louisiana Power and Light Company Waterford III SES P. O. Box B Killona, Louisiana 70066
Subject:
Waterford III SES Emergency Plan
Dear Mr. Maurin:
This letter will serve to confirm an agreement between Union' Carbide.
Ethylene Oxide / Glycol' Taft Plant and Louisiana Power and Light Company, regarding emergency' planning at the Waterford III nuclear plant. ' Union Carbide Ethylene Oxide / Glycol Taft Plant agr.ees to:
~
- a. Provide LP&L with information regarding increases in inventory of' hazardous snaterials of a significant nature which'could affect the safety ana. lysis of
~
Wa terford 'III.
.b. Promptly notify Waterford III if a release of haza'rdous material which could affect'Waterford III~ occurs at our facility.
This notification would be via the~ St.
Charles ~ Parish Emergency' Preparedness Industrial Hot' j
Line System or'via phone.
~
4 Very truly yours, r
I Y
Wateo Chemical Mr. L. V. Maurin Assistant Vice President-Nuclear Operations Louisiana Power & Light Co.
Waterford 3 SES P.O. Box B Killona, La.
70066 l
SUBJECT:
Waterford 3 SES Emergency Plan
Dear Mr. Maurin:
This letter will serve to confirm an agreement between (Witco Taf t Plant) and Louisiana Power & Light Company, regarding Emergency Planning at the Waterford 3 Nuclear Plant.
(Witco Taf t Plant).
Provide LP&L with information regarding changes in inventory of hazardous a.
materials which could affect the safety analysis of Waterford 3, and b.
Promptly notify Waterford 3 if a release of hazardous material which could affect Waterford 3 occurs at our facility. This notification would be via the St. Charles Parish Emergency Preparedness / Industrial Hot Line System or via phone.
Yours very truly,
(
t>/N' J.R. Daley I
Vice President f
Mfg. and Engineering j
9 Argus Chemical Corporation suboidiary of Witco Chemical Corporation P.O. Box 310, Hahnville, Louisiana 70057 Area Code 504 Telephone 783-6201
ATTACHMENT 2 EMERGENCY PLAN TRAINING ATTENDANCE ROSTER
EMERGENCY PLAN TRAINING ATTENDANCE ROSTER 5/25/82 NAME COMPANY DEPARTMENT Wayne M. Melancon 3 Clark Oil Safety Roseann T. Novasel 1 Kaiser Safety Phil Lem 1 Union Carbide Employee Relations C. M. Duhon 1 Shell Oil Health & Safety Art James 1 Union Carbide Safety Weldon M. Danos 1 Hooker Chemical Saf. & Ind. Hygiene Darrell Horn 2 Monsanto Safety R. Fernandez 1 Shell Chemical Safety James Delaune 1 Shell Chemical Training 1
David R. Pakarinen Shell Chemical Environmental Tom Jones 1 Union Carbide Safety / Health Barton Coccaro 1 Occidental Chem.
Technical John Carnall 3 Amer. Cyanamid Safety Jesse Payne 1 Occidental Chem.
Manager Ikey Lucas St. Charles Parish E.P. Director Leonard E. Culotta 2 Texaco (Gas)
Harold L. Hebt:ct 2 Texaco (PGPP)
W. H. Hebert 2 Texaco (Gas)
C. Rennick l' Argus-Witco Safety Dennis Humphrey 1 Witco Engr.
Peter J. Champagne 2 Cargill Plant Supr.
Michael J. Moran 2 Cargill Plant Engr.
B. F. Lewis 2 Marathon Oil Technical Ruth Smith 2 Farmers Export Safety Howard Troutman 2 Farmers Export Plant Mgr.
Edward Fuselier 1 Waterford 1 & 2 Ops. Super.
A. J. Landry 1 Shell Oil Health & Safety
~F. L. Sospenzi 3 Nalco Chem.
Plant Mgr.
E. P. Gauthier 3 Nalco Chem.
Safety F. L. Irle 1 Union Carbide-Star Emergency Coord.
M. R. Monie 1 GATX
-Terminal Mgr.-
1 T. W. Gray GATX Safety Dir.
1 Tommy Vanacor Good Hope Energy Safety Dir.
Woody Powell 1 Good Hope Energy Sr. Safety' Engr.
Bertram Madere St'. John Parish-C.
D., Director A. J. Landry 1-
_Shelll0il
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1 - FSAR Industry 2 - Non-FSAR Industry within 10 miles of Waterford 3 3 - Industry beyond 10 miles of Waterford 3
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