ML19350E039

Forwards Responses to Questions 810.22-810.24,to Address SER Open Item 56.Responses Will Be Provided in Next FSAR Amend Scheduled for 810619

ML19350E039
Person / Time
Site:	Waterford
Issue date:	06/12/1981
From:	Maurin L LOUISIANA POWER & LIGHT CO.
To:	Tedesco R Office of Nuclear Reactor Regulation
References
W3P81-1461, NUDOCS 8106160336
Download: ML19350E039 (10)

Text

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LOUISIANA 242 octAnonos iraEer P O W E R & L 1 G H T! P O. BOX 6000 . NEW ORLEANS. 70174

• LOUIStANA (504) 366-2345 ma:Psva:

June 12, 1981 W3P81-1461 l . Q-3-A29.13.

Q-3-A29.19 3-A45 Mr. R. L. Tedesco Assistant Director for Licensing U. S. Nuclear Regulatory Commission I N Washington, D. C. 20555 ,'

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SUBJECI: Waterford 3 SES Q' V Docket No. 50-382 j$ , gg1# (A Emergency Planning ..

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Responses to Questions @~ s 810.22 through 810.24 oA #p lp ENCLOSURE: Responses to Questions 810.22 through 810.24 .[ p(00'

Dear Mr. Tedesco:

Enclosed please' find our restonses to Questions 810.22 through 810.24.

These responses are provided to address SER open item No. 56 of Mr. Eisenhut's May 15, 1981 letter to Mr. Aswell. These responses will also be provided in the nest FSAR amendment scheduled for June 19, 1981, Your very truly, L. V. Maurin Assistant Vice President Nuclear Operations LVM/MPF/dde cc: Mr. E. L. Blake, Mr. W. M. Steventon fDOIy rh

1. 810818o 336

, l Q 810.22 Planning Standard A. Assignment of Responsibility (Organizational Control)

• Existing agreement letters must be upgraded with respect to access control of the 10-mile EPZ (A.3) 810.1-3 ,

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1. U.S. Coast Guard (USCG) - The agreement letter with  !

the USCG found on page C-1 of the Plan covers only access control of the waterway within the Waterford 3 Exclusion Area and not the 10-mile EPZ. This letter predates the upgraded planning requirements set forth in NUREG-0654. The agreement letter between the USCG and the Louisiana Office of Emergency Preparedness dated October 17, 1980, found in the Louisiana St. ate Emergency Plan, may be ,used as the basis for upgrading the letter between LPSL and USCG with regard to access control of the 10-mile EPZ.

2. Missouri Pacific Railroad Company (MPR Co.) - The agreement letter between LP&L and MPR Co., dated i

November 1,1978, covers only that portion of the railroad right-of-way that traverses the exclusion area. The letter must be upgraded with regard to the access control of the 10-mile EPZ.

3. Lafourche Basin Levee District (LBLD) - Amendment 15 to Waterford 3 FSAR Section 13.3, dated February 1981 (hereinaf ter called the Emergency Plan), contained I

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an agreement letter between LP&L and the LBLD -

Board of Commissioners which referred to Exclusion Area ' Control at Waterford 3 site. Amendment 17 to  !

i the Emergency Plan (item 810.1-3) which deleted the reference of the LBLD from Appendix C to the Plan,  !

states that LBLD does not provide access control on any levees in which it has jurisdiction. Since the l LBLD has jurisdiction over the levee (s) which trans-

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verses the Waterford 3 10-mile EPZ, access control of the levee (s) must be clarified, the agency or agencies having the authority and capability to l establish access control must be identified in the i Emergency Plan, and eppropriate letters of agreemen; .

must be established, maintained and included in,the i Emergency Plan.  !

l Response Question 810.22, Parts A.1 End A.2 f

,I f Based on the laws of the State of Louisiana and the Cod,3 .sf Federal l

Regulations which govern the authority of a licensee to control j

, access, Louisiana Power & Ligt - Company does not have the [

i legal authority to control access outside of the exclusion area.

! All access controls within either St. Charles Parish or St. John ,

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• - the Baptist Parish are the responsibility of each parish and can {

L only be initiated by the appropriate parish officials. Also see '

i t the response to Question No. 810.1-3. I 1

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l Response Question 810.22, Part A.3 The Lafourche Basin Levee District has no authority to control access to properties within their jurisdiction. The on2y responsibilities of the LBLD as they relate to the Mississippi River Levees are as follows:

') vegetation control

2) debris removal

3) minor repairs Also see response to Question 810 .1-3 Q 810.23 Planning Standard e

B. Onsite Emergency Organization

• The Plan does not describe the specific conditions under which utility officials above the position of Plant Manager-Nuclear would succeed to the position of Emergency Coordi-nator. (B.3) 810.2-1.

Response to Question 810.2-1 states, that the criteria for higher leve1' officials assuming the function of emergency coordinator are identified in revised Subsection 13.3.4.2.1.2.

The revised Subsection 13.3.4.2.1.2 doec not address higher level utility officials (i.e. higher than the Plant Manager-Nuclear). -

Responae Question 810.23 See revised FSAR Subsection 13.3.4.2.1.2, " Emergency Coordinator".

Q 810.24 Planning Standard D. Emergency Classification System

• The initiating conditions for Unusual Event. Alert and Site Area Emergency do not include security emergencies. (D.1.2) 810.4-1, 4-2, 4-3.

Your response indicated .that security threats, attempted entry, attempted sabotage, etc. are ade-quately addressed in the Waterford 3 Physical Security Plan, Safeguard Contingency Plan and Pro-cedures and shou'ld not have to be repeated in the Emergency Plan.

It is our position that security energencies be included in the Emergency Plan EAL's in order to assure prompt notification and immediate response, including offsite support. References may be made -,

to the Security Plan or Contingency Plan (ex. Alert - -

a security emergency has been called by the security ,

. force as defined in the Safeguards Contingency Plan) .

However, it must be addressed in the Emergency Plan i

in such detail that the reviewer can ascertain whether the requirements of NUREG-0654 have been met.

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• The initiating conditions for the Site Area Emergency Class do not include " entry of uncontrolled flausnable  ;

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^ gases into vital areas: and " entry of uncontrolled toxic  !

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gases into vital areas where lack of access to the area constitutes a safety problem".  ;

Response Question 810.24 {

See revised FSAR Subsections 13.3.3.1.1 " Unusual Event",

i 13.3.3.1.2 "Alart", and 13.3.3.1.3 " Site Emergency". t i

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WSES-FSAR-UNIT-3 l17

14) Natural phenomena beyond usual levels:

(a) Any earthquake 2 0.01 g as indicated by the seismic instrumentation (b) Water level at the levee fronting the site above el

+ 24 ft. MSL USGS datum 10 (c) Tornado warning issued for near site area (d) Hurricane warning issued for area including St Charles Parish l

15) Other hazards l 17 (a) aircraft crash onsite (b) train derailment onsite 10 (c) onsite explosion (d) near or onsite toxic or flammable gas release which requires plant evacuation by non-essential personnel

16) Evacuation of control room anticipated or required with control of shutdown systems established at remote shutdown panel.

, 17 17 ) Transportation of a contaminated individual fr.on onsite 4

to an offsite hospital.

l8) SEC.UAWy CeH t 75 AV L E VE L.

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cediuso in me seasonaos cour>xc.aaey . li PLnn*).

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. WSES-FSAR-UNIT-3 1

8) Loss of capability to achieve cold shutdown. g

9) Failure of the reactor protection system to initiate or complete a reactor trip which brings the reactor suberitical l 10

10) Fire potentially affecting reactor safety

11) Most or all annunciator loss for longer than five minutes with the plant not in cold shutdown 17

12) Radioactive effluents result in concentrations in excess of 10 times the 10 CFR 20 App B Table 2 limits l 15

13) Severe natural phenomena l 17 (a) Any earthquake 20.05 g as indicated by the se* *W.c 10 instrumentation (b) Water level at the levee fronting the site above El. l IS

+ 27 ft. MSL USGS datum (c) ~Any tornado striking the facility

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(d) Sustained hurricane force winds onsite near design

. basis level

14) Other hazards .

17 (a) Aircraf t crash or missile impact on fa ility within the protected area (b) Explosion damage to facility affecting plant operations 10 ,

(c) Near or onsite toxic or flammable gas release affecting s plant operations

( %* Alert emergency 'can also be declared by the Emergency Coordinator any ,

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time he judges the status of the plant warrants it. The Emergency Coordi.

nator shall specifically consider escalation from the Unusual Event to the f0 Alcrt class if, in his judgement, the situation is not likely to be re-solved rapidly or is likely to deteriorate.

13.3.3.1.3 Site Emergency I

c) Description

Events are in process or have occurred which involve * .tual or l15 likely major failures of plant functions needed fo. protection c 65) s e e viary cniiriou u e v e u y s e n ~ ( a s o a ,,n a o , 3 l IN TNG "$RFK6URAD$ CON TtH G.EN cf ON")

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&n4ITE R45ST~RNcg by LLy g,

,9 G/e9 l 13.3-16 Amendment No. )/[,# (M86 3 e

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p(d) ENTAf Of UNCONTROL. LEO FwMMRCVa.K dot. TOK'C- 046 '"M

. l *l voym. nases n.novon.oxa, usatarm or c.wrn.ou rzoont . y gamma using adverse meteorology (b) A valid count rate on any iodine effluent monitor that cor-responds to a projected dose to a child thyroid at the site boundary 2250 mr/hr for 30 consecutive minutes or 2500 mr/hr II using adverse meteorology (c) A valid count rate on the reactor building high range 10 monitor that corresponds to a projected whole body dose rate 2 500 ar/hr gamma at the site boundary using adverse l17 meteorology and reactor building design leak rate l15

_(d) Offsite radiological monitoring reports > 500 ar/hr 17 gamma at any location 1,2) Severe natural phenomena .

l17 (a) Any earthquake 2*0.1 g as ind'.cated on the seismic instrumentation (b) Water level at the levee fronting the site reaches el + 30 ft MSL USGS datum 10

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(c) Severe wind damage to a vital plant structure

13) Aircraf t crash or missilos causing structural damage whic,h affects reactor safety ce safe shutdown equipment by '.mpact,

. fire, or explosion 17

14) Evacuation of control room is required and control of shutdWn systems has not been established at the remote shutdown panel within 15 minutes In addition, the Emergency Coordinator shall declare a Site Emergency when in his judgement' plant conditions exist that 10 -

warrant the activation of emergency response centers and pre- l l 315  :

IS) cautionary publics notification.$gconjyy caug' n ytem 's.gygg *ggsp"(g onrrs*: aro 13.3.3.1.4 General Emergency gMff6044.05 CO N~ri n gsvg. p4f n O  !

c) Description 10  ;

Events are in process or have occurred which involve actual or  !

imminent substantial core degradation or melting with potential for .

less of containment integrity. Ralease of radioactive material to  !

the environment is occurring or may occur for which the projected 17 j dose to an ir.dividual at the EAB (using actual meteorology) exceeds the lower limits of EPA PAGs, i.e. ,1.0 rem to the whole body and/or 5.0 rem to the thyroid.  ;

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-Purpose 15 Purpose of the general emergency declaration is to (1) initiate predetermined prote:tive actions for the public, (2) provide con-

/ y, {&/Bl) 13.3-18 Amendment No.)//*, (4f6.L),

WSES-FSAR-UNIT-3 13.3.4.2.1.2 Emergency Coordin , r The personnel assigned the responsibilities of the Emergency Coordinator are listed in descending order of preference:

I a) Plant Manager-Nuclear  !

b) Plant Services Assistant Plant Manager-Nuclear 15 c) Technical Support Superintendent d) Operations Superintendent-Nuclear e) Nuclear Operations Supervisor Following the initial declaratien of an emergency by the NOS, the position of Emergency Coordinator will be assumed by the most preferable of the other 17 four individuals aborne who is present in the Technical Support Center.

The responsibilities of the Emergency Coordinator are listed as follows: 15 a) Activate the.Onsite Emergency Organization shown in Figure 13.3-3, 10 b) Augment the Operations Shift with necessary additional staff (Table 17 13.3-4a),

l c) Initially make the decision to notify and make recommendations to 10 LP&L personnel and offsite organization and agencies. These respon-sibilities shall riot be delegated to other personnel of the emergency

" l 15 organization. ,

d) Provide support to the Nuclear Operations Supervi'sor. ,

e) Assign a mer:ber of the plant staff to act as the Emergency Communi-Cator.

f) Request assistance from onsite and offsite personnel and agencies.

le g) Organize , direct, and coordinate onsite emergency teams.

h) Review and evaluate updated information and data, i) Relay significant information and data to onsite and of faite 15 l organizations.

j) Implement protective measures to be taken by personnel performing emergency efforts including those individual assigned to the main control room, Technical Support Center and the Operational Support 10 l

1 Center, k) Authorize emergency radiation exposure criteria. 15

1) Communicate with the Site Support Manager.

N N6bPCU $i8 1*IE S 64 THE KMggni,gpcy UOAbMA97*OR. WiAL, y 9

Nor se msunen so nuy anaesemaar pensaunst. M**e seme*y- \

TNJPa/ A, y m/p4/4 gr 13,3_39 Ac>endment No. ,

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