CY-96-170, Amends 970501 & 0721 Ltrs to Relocate Alternate EOF from Current Location at Toledo Edison Club to Bay Shore Station. Relocation Is in Response to Directive to Evaluate Corporate Properties for Potential Sale,Secy 96-170 & NUREG-0737
ML20217C099 | |
Person / Time | |
---|---|
Site: | Davis Besse ![]() |
Issue date: | 04/14/1998 |
From: | Jeffery Wood CENTERIOR ENERGY |
To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
References | |
RTR-NUREG-0737, RTR-NUREG-737 SECY-96-170-C, NUDOCS 9804230213 | |
Download: ML20217C099 (18) | |
Text
w
- s Em _ num= Davos Besse Nuclear Power Station
_E EE 5501 North State Route 2 m Oak Harbor.Onoo43449-9760 John K. Wood 419-249-2300 Vice Presodont - Nuclear Fax. 419-32 -8337 Docket Number 50-346 License Number NPF-3 Serial Number 2531 April 14, 1998 United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555-0001
Subject:
Request for Exception from NUREG-0737, Supplement 1," Clarification of TMI Action Plan Requirements, Requirements for Emergency Response Capability", dated January 1983; Approval of Alternate Emergency Operations Facility Location
]
1 Ladies and Gentlemen:
By letter dated May 1,1997, (Serial Number 2461) Toledo Edison requested an exception from the Emergency," Operations Facilities (EOF) Guidance of NUREG-0737, Supplement 1
" Clarification of TMI Action Plan Requirements, Requirements for Emergency Response Capability," dated January 1983, for the Davis-Besse Nuclear Power Station (DBNPS), Unit 1.
The guidance in this NUREG states that a 2ack-up EOF should be provided for facilities with a close-in primary EOF (within 10 miles of the site).
Toledo Edison provided additional information by letter dated July 21,1997 " Response to Request for Additional Information"(Serial Number 2467). Toledo Edison hereby amends the ;
two previous submittals (Serial Numbers 2461 and 2467) to relocate the Alternate EOF from the l current location at the Toledo Edison Club to the Bay Shore Station. The relocation of the Alternate EOF is in response to a directive by FirstEnergy Corporation, the newly formed parent company of Toledo Edison, to evaluate corporate properties for potential sale.
Toledo Edison is requesting approval for an Alternate EOF to be located at the Bay Shore Station Training Center. This request is in accordance with the guidance provided in SECY letter 96-170, dated August 5,1996, entitled " Assessment of Exceptions Granted for Locations and Staffing Times of Emergency Operation Facilities."
The information contained in the enclosure and attachments and the supplemental information contained in previous submittals should provide the information necessary for evaluation and approval of the request for exception to NUREG-0737, Supplement 1, and the location of the 9804230213 980414 ADOCK 05000346 PDR p PDR
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Docket Number 50-346 License Number NPF-3 i Serial Number 253i P. age 2 -
Alternate EOF at the Bay Shore Station Training Center. Toledo Edison requests NRC approval of this exception request by June 1,1998.
Should you have any questions or require additional information, please contact Mr. James L.
Freels, Manager - Regulatory Affairs, at (419) 321-8466.
Very truly yours,
't CAK/laj cc: A. B. Beach, Regional Administrator, NRC Region III S. Campbell, DB-1 NRC Senior Resident Inspector l A. G. Hansen, NRC Project Manager Utility Radiological Safety Boaid l
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Docket Number 50-346 License Number NPF-3 Serial Number 2531 Enclosure Page1 Davis Besse Nuclear Power Station Request for an Exception from NUREG 0737, Supplement 1
" Clarification of TMI Action Plan Requirements, Requirements for Emergency Response Capability", dated January 1983 Toledo Edison hereby requests exception from NUREG-0737, Supplement 1, " Clarification of TMI Action Plan Requirements, Requirements for Emergency Response Capability", dated January 1983, (NUREG-0737, Supplement 1) for the Davis-Besse Nuclear Power Station (DBNPS), Unit 1.
REGULATORY POSITION NUREG-0737, Supplement I defines the Emergency Operations Facility (EOF) requirements.
Guidance provided in NUREG-0737, Table 1, Emergency Operations Facility, lists two options.
Option 1 is for two facilities: a close-in Primary EOF (within 10 miles) and a Backup EOF.
Option 2 is for one facility at or beyond 10 miles.
NUREG-0737, Supplement I further states that: "These requirements provided a degree of flexibility within which licensees can exercise management prerogatives in designing and building emergency response facilities (ERF) that satisfy specific needs of each licensee. The forecast consideration regarding ERFs is that they provide adequate capabilities of licensees to respond to emergencies."
In SECY letter 81-509,"NUREG-0696, Criteria for Emergency Operations Facilities for Nuclear Power Reactors," dated August 24,1981, (SECY 81-509) the NRC staff discusses EOF exceptions and states:
"An example of a number of requests relating to EOF location and habitability is a specific request (Enclosure 2) for permission to locate an EOF inside the 10 mile EPZ without provisions for a backup EOF. In this case the licensee is building a fully hardened EOF within the 10 mile EPZ with protection factors in excess of 100 and ventilation systems which wini assure a habitable facility even during a core melt accident. The licensee had concluded that a backup EOF is not necessary because in all scenarios there would be no need to evacuate the primary EOF. The staff proposes to approve this proposal with respect to EOF location (other aspects of the design are under review) as it meets the intent and purpose of NUREG-0696 criteria and the requirements of the regulations (10CFR50.47(b)(8) and 10CFR Part 50 Appendix E IV.E) for adequate ;
emergency response facilities near site."
l i
r Docket Number 50-346 License Number NPF-3
, Serial Number 2531 Enclosure Page 2
, It should be noted that Enclosure 2 to SECY 81-509 is Toledo Edison's submitted response to l NRC Generic Letter 81-10, " Post TMI Requirements for the Emergency Operations Facility,"
l dated May 27,1981, for DBNPS, Emergency Response Facilities (Serial Number 719).
NRC memorandum from Chilk to Dircks entitled "SECY-81-509 NUREG 0696 Criteria for Emergency Operations Facilities For Nuclear Power Reactors," dated September 30,1981, in response to SECY letter 81-509, denies the Staff authority to approve deviations without Commission approval, but the Commission agreed that the staff could accept an alternate location in place of a backup EOF where licensees had built a close-in hardened EOF.
NRC memorandum dated October 16,1981, from Steve Ramos to all Operating Reactor and Licensing Branch Chiefs entitled " Modification of the Location and Habitability Criteria for Emergency Operations Facilities," provides further clarification of the September 30,1981 memorandum. Requirements for Emergency Operations Facility location, distance from the plant, and the associated protection factors required are listed.
l l SECY letter 96-170, dated August 5,1996, from Taylor to the Commissioners, entitled l " Assessment of Exceptions Granted for Locations and Staffing Times of Emergency Operations
- Facilities," (SECY 96-170) specifically addresses exceptions, and it states
" Exceptions to the EOF Guidance Criteria:
( Supplement I to NUREG-0737 (at 24) states that " exemptions from or alternative
! methods ofimplementing these requirements should be discussed with NRC staff and in l
some cases could require commission approval.
The guidance contained in NUREG-0737, Supplement 1, does not constitute in itself regulatory requirements for licensees. Accordingly, the " exemptions" referred to in Supplement I to NUREG-0737 are not exemptions as defmed in the regulations (10CFR50.12) but more accurately are described as " exceptions" from the guidance."
SECY 96-170 further states the following:
- " Exceptions to EOF Location Guidance 1
Exceptions to EOF location criteria fall generally into four categories:
l l
- 1. Exceptions to the primary EOF location.
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Docket Number 50-346 License Number NPF-3 Serial Number 2531 l Enclosure Page 3
- 4. Exceptions to the near-site EOF concept in Supplement I to NUREG-0737 (Attachment 2, Notes B and D)
Hardened EOF - located within the 10 mile emergency planning zone with protection factors much greater than 5 and ventilation systems that will ensure a habitable facility even during a core-melt accident." ;
l SECY 96-170 Attachment 2, Note A states: '
"In response to SECY-81-509, the Commission authorized the staff to approve an ,
alternate location in place of a backup EOF where licensees had built an EOF with a high l degree of habitability within 10 miles of the plant. An alternate location is defined by the l Commission as a facility located between 10 and 20 miles of the plant site where utility and Govemment officials can meet to discuss plant status and appropriate public protective actions, and arrangements have been made to communicate with the Technical 4 Support Center. The seven currently operating sites which have hardened EOFs include Artificial Island, Haddam Neck, Pilgrim, Vermont Yankee, Brunswick, Harris, and WNP2." j EXCEPTION SOUGHT Toledo Edison seeks exception to the EOF guidance criteria specified in NUREG-0737, Supplement 1. Specifically, Toledo Edison requests an exception to allow for the use of an Alternate EOF located 18 straight-line miles from the primary EOF.
By letter dated May 27,1981, (Serial Number 719), Toledo Edison described the centralized management philosophy which located the emergency response facilities in the Davis-Besse Administration Building (DBAB). The DBAB, which houses both the Technical Support Center (TSC) and the primary EOF, is located at the site boundary. The habitability of the combined TSC and EOF is designed to meet the radiation protection requirements of 10 CFR 50 Appendix A, General Design Criteria 19. " Control Room." The DB AB is outfitted with a Central Control and Monitoring System (CCMS) that will, upon initiation, bring the outside and recirculating air filtra-tion units into operation. The air filtration units are equipped with high efficiency air particulate l (HEPA) filters. The details of the primary EOF habitability, security and communication functions are more completely described in Serial Number 719.
SECY 81-509, describing Davis-Besse's facility, states "the licensee is building a fully hardened l EOF within the 10 mile EPZ with protection factors in excess of 100 and ventilation systems which will assure a habitable facility even during a core melt accident."
By letter dated June 9,1988, (Serial Number 1532), Toledo Edison requested approval for the location of the TSC outside the site protected area. In response to that request, by letter dated I
~ 1 Docket Number 50-346 ' I License Number NPF-3 Serial Number 2531 Enclosure Page 4 June 9,1989, (Log Number 2955), the NRC approved the request, stating that "...the TSC meets
- the functional requirements of Supplement I to NUREG-0737 even though the TSC is located outside the site protected area." The DBNPSs Primary EOF is located in the same structure as the fully hardened TSC.
By letter dated May 1,1997, (Serial Number 2461), Toledo Edison requested an exception from i
NUREG-0737, Supplement I and by letter dated July 21,1997, (Serial Number 2467) provided additional information related to the Request for Exception submittal. Toledo Edison wishes to amend these two submittals (Serial Numbers 2461 and 2467) to relocate the Altemate EOF to the Bay Shore Training Center. The request to relocate the Alternate EOF is in response to a directive to evaluate Corporate properties for potential sale by FirstEnergy Corporation, the s parent company of Toledo Edison formed during the recent merger of Ohio Edison Company and Centerior Energy Corporation.
The purpose of the DBNPS Alternate EOF is to provide a meeting room (seating capacity for approximately 30 individuals) to conduct technical briefings with offsite agency officials using current plant data, and to have the ability to communicate directly with senior management l personnel in the Technical Support Center (TSC) and Emergency Control Center (ECC).
Accident assessment, mitigation, dose assessment, classification and emergency organization management will not move from the existing facilities at DBNPS when the Alternate EOF is
- activated.
The Davis-Besse Alternate EOF will only be staffed when both of the following conditions exist:
- 1. Davis-Besse is in a General Emergency.
- 2. Offsite agency officials wish to meet with company executives, or senior station L management outside the 10 mile EPZ l
The DBNPS Alternate EOF will be relocated to the Bay Shore Station (a FirstEnergy Corporation fossil-fuel electric generating plant), Training Center in Oregon, Ohio. Bay Shore Station is outside the 10 mile EPZ . The driving distance to Bay Shore from DBNPS is 25 miles, {
with a straight line distance of 18 miles. Under normal traffic and weather conditions, driving l l time is approximately 30 minutes. The attached map (Attachment 1) shows the location of the i Lucas and Ottawa County Emergency Operations Centers (EOCs), the proposed Alternate EOF !
and the DBNPS. The Bay Shore Station Training Center provides adequate space to conduct briefings, as well as space for a staff work area (Attachment 2). The structure is within the fenced area of the power plant allowing for security of the Alternate EOF (Attachment 3). ]
The Bay Shore Station telephone system is part of the Company wide Centrex telephone network. The DBNPS utilizes the Centrex directly via both company fiber optic and microwave system. The Alternate EOF Communication System is depicted in Attachment 4. Both systems
Docket Number 50-346 License Number NPF-3 Serial Number 2531 Enclosure Page 5 are used daily and have demonstrated a high degree of reliability. Company radio systems are available at both sites as well.
The DBNPS Emergency Director will designate a team ofindividuals to staff the Alternate EOF who are not currently involved in mitigating the event. As a minimum, this team will be comprised of a qualified Emergency Director (Vice President or his representative), a radiation protection specialist, an operations specialist and a technical communicator. This guidance is currently provided in DBNPS procedure RA-EP-02010, " Emergency Management," Attachment 1, Emergency Management Guideline for Emergency Director (Attachment 5, RA-EP-02010). This l procedure is being revised to indicate that the Alternate EOF is now located at the Bay Shore Station Training Center. Guidance will be provided for the setup and operations of the Alternate EOF (Attachment 6, Alternate EOF Setup and Operations).
l Equipment and supplies will be stored and maintained at the Bay Shore Station Training Center to provide for the operation of the Alternate EOF. These resources will be inventoried quarterly l
in accordance with RA-EP-00600, Emergency Facilities and Equipment Maintenance Program (Attachment 7, Alternate EOF Inventory List).
l The plans to relocate the Alternate EOF at the Bay Shore Station Training Center have been l discussed with the State of Ohio and Ottawa and Lucas County officials. Attached are copies of l, the Letters of Acceptance (Attachments 8,9, and 10).
The proposed Alternate EOF will provide a functional facility that would compliment the DBNPS emergency response organization should the need arise. This request for exception from l NUREG-0737, Supplement 1, is in accordance with SECY 96-170 and other cited NRC guidance l and is similar to exceptions granted to other facilities cited in SECY 96-170.
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Docket Number 50-346 License Number NPF-3 Serial Number 2531 Enclosure Page 6 ATTACHMENT LISTING Attachment 1, Map of Area depicting DBNPS, proposed Alternated EOF and County EOC's Attachment 2, Alternate EOF Floor Plan Attachment 3, Bay Shore Station Map Attachment 4, Alternate EOF Communications Attachment 5, RA-EP-02010, Emergency Management Procedure, Emergency Director Attachment 6, Alternate EOF Setup and Operating Instructions Attachment 7, Alternate EOF Inventory List l
Attachment 8, Ottawa County Letter of Acceptance l
Attachment 9, Lucas County Letter of Acceptance I Attachment 10, State of Ohio Letter of Acceptance i
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Docket Number 50-346 License Number NPF-3 Serial Number 2531 Attachment 5 RA-EP-02010, Emergency Management Procedure, Emergency Director Section N. IE it becomes desirable or necessary to meet with offsite agency officials at a location outside the Plume Exposure Emergency Planning Zone (10-mile EPZ).
THEN perform the following:
- 1. Notify the Bay Shore Management that the Alternate Emergency Operations Facility (AEOF) is being activated by (by callinn?)
- 2. Notify the Emergency Security Manager in the TSC that the AEOF is being activated and direct him/her to make appropriate arrangements to address AEOF security needs.'
- 3. Inform the offsite authorities that the Alternate Emergency Operations Facility (AEOF) is being established at the Bay Shore Power Station Training Center.
- 4. Determine which functional areas from the ERO should attend this conference. As a minimum, it is suggested that the following functional areas be included:
- Emergency Director e Emergency Offsite Manager e Radiation Protection Management
. Operations Management e Technical Communicator
- 5. Use the Emergency Plan Telephone Directory to call out the desired additional personnel and direct them to report to the AEOF at Bay Shore to consult with offsite officials.
- 6. Notify the Company Spokesperson and the JPIC Manager that the AEOF is being established.
- 7. Direct the EOM to begin collecting information and data to fax to the AEOF once it is activated.
' Highlight information is changes to what is currently in the approved procedure.
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Docket Number 50-346 License Number NPF-3 Serial Number 2531 Attachment 6 AEOF Setup and Operating Instruction
- Commandeer 6 company phones and designate them as follows:
- 1. 1 - Technical Loop Communicator
- 2. 1 - Fax machine
- 3. 1 - Senior Management Phone
- 4. 3 - General usage telephones Utilize the Emergency Plan Telephone Directory to enter the Technical Data Loop and establish communications with DB and maintain a open line
- Setup the Fax and communicate to the ECC the phone number of the F-
- Request current data to be faxed on the following issues:
- 5. Offsite release values, effected sub-areas and projected duration
- 6. Plant status
- 7. Safety system status Setup the senior manager's speaker phone and have him/her obtain a briefing from the Emergency Director (ED) or his/her representative.
- Setup the large meeting room in a "round table" arrangement
- Setup the projector and verify operations Arrange for parking by having the " Contractor Parking Lot Access Gate" opened.
- Setup signs to direct individuals to Alternate EOF
- Advise ED at Davis-Besse that the AEOF is activated Briefing Guidelines Use tent cards to indicate name of representative and organization represented Address only utility actions and response to the event. Direct non-utility questions to the appropriate entity.
Have an individual record questions and request for additional information for follow-up.
- Maintain a log ofindividuals and representatives who are in attendance i
Docket Number 50-346 License Number NPF-3 Serial Number 2531 Attachment 7 Alternate EOF Inventory List2 Phones 1 - Senior Utility Representative Phone 1 - Technical Communicator Link 1 - FAX machine line 3 - General usage lines Documents 1 - Set of F.mergency Planning Procedures 1 - DBNPS Emergency Plan 1 - EAL Reference Manual 1 - Emergency Plan Telephone Directory Equipment 1 - FAX (Plain paper) 1 - Overhead projector with spare bulb 1 - Plain Paper Projector with spare bulb 1 - Telephone Headset 1 - Speaker phone 1 - 10 Mile EPZ Map Supplies 50- Tent Cards 10- pads of writing paper 1 - box of black pens 1 - box of dry board markers 2 - reams of copy machine paper 2 - Black marking pens Miscellaneous 1 - Facility Sign 2
This equipment list will be refined and added to the ERF inventories that are performed quarterly in accordance with RA-EP-00600.
Docket Number 50-346 License Number NPF-3 sertal Number 2531 OTTAWA COUNTY COMMISSIONERS . Court House l BOARD MEMBERS 315 Madison Street Room #103 Elmore: (419) 862-3232 Steven M. Arndt PORT CLINTON, OHIO 43452 1993 Genoa: (419) 855-8134
, Carl Koebel Chris Redfern March 24,1998 Oak Harbor: (419) 896-773; CLERK OF THE BOARD Port clinton: (419,734-67;;
Barbara J. Hermes Facsimile: (419)734-6898 James L. Freels, P.E.
Manager-Regulatory Affairs Edison Plaza
@' g~ d 300 Madison ' Avenue ,
Toledo, Ohio 43652
Dear Mr. Freels:
Ottawa County has no objections to Toledo Edison Company establishing an Alternate Emergency Operations Facility (AEOF) at the Bay Shore Power Plant in Oregon, Ohio. We understand that the intended purpose of this facility is to provide a predesignated meeting place outside .of the Plume Exposure Pathway (10 miles) Emergency Planning Zone for governmental officials to meet with senior utility personnel to discuss the event at the station. It is also understood that this additional facility would only be activated when travel to the station has become limited or restricted during an emergency.
During past evaluated exercises and drills communications between our Emergency Operations Center and the utility Emergency Control Center has been considered a strength. Additionally, the EOC utility Technical Liaison and the ECC County Liaison has assured a timely and accurate exchange of information between the ECC and the EOC.
Therefore, Ottawa County is supportive of this concept.
Sincerely, A $
Carl Koebel M I V
Chris Redfern
/
Steven M. Arndt Board of County Commissioners Ottawa County, Ohio jh cc: James Greer Broce Cope Reggie Strauss J. Mitch Teal File The Ottawa County Commissioners do not discriminate in provision of services or employment because of race, color, national origin, sea age, religion, or disability. e asgas.
MTIP;//WWW.CfC. OTTAWA.ON.US
Docket Number 50-346 Attachment 9 Licerfse' Number NPF-3
" Serial Number 531
[uM1F Co g COUNTY OF LUCAS
}j,5 Emergency Management " cou
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4* counst ,# Agency SANDYiSENBERG President BILL COPELAND l March 26,1998 MARK L PIETRYKOWSKI EDWARD J. CIECKA Administrator
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NANCY POSKAH Clerk WILLIAM S. HALSEY James L. Freels, Regulatory Affairs Manager mA oirector Davis-Besse, Oflice ofRegulatory Affairs jjg 2;sgg2 5501 N. State Route 2 t r. >
Oak Harbor, Oli 43449
Dear Mr. Freels:
In order to meet a requirement of the Nuclear Regulatory Commission, Toledo Edison officials have designated the Bayshore Power Station,4701 Bayshore Road, in the City of Oregon, Ohio to serve as the alternate Emergency Operations Facility in support of the Lucas County Radiological l Emergency Response Plan.
The intended purpose of this facility is to provide a predesignated meeting place outside of the Emergency Planning Zone for governmental officials and senior utility personnel to discuss any r emergency event at the Davis-Besse Nuclear Power Station.
It is also understood that this back-up facility would only be activated when travel to the station has l been limited or restricted during an emergency.
l If you have any questions, please call me.
l l
Sincerely,
/ fake ~
I Thomas E. Barnhizer Deputy Director TEB/bep cc: J. Mitch Teal, Davis-Besse Darryl Walden, OEMA 2144 MONROE STREET = TOLEDO, oHlo 43624 An Eeuer owanurwr vnuume
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Docket Number 50-346
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Licensd' Number NPF-3 oeorge V.Voinovich, Governor N rncy P. Hollister, Lt. Governor Mitchell J. Crown, Diref. tor S6 rial Number 2531s s Attachment 10 Dale Shipley Deputy Drector OHIO DEPARTMENT OF PUBLIC SAFETY e Admtnistraton oNo Etnergency Management e oNo State Nghway Patrol
- 2855 West Duthn-Grenvllie Road Coeumbus, oH 43235-2200 e Bureau of Motor VeNcies e Dmason of Emergency Medical Sene.es (fl14) 889-7150 e Emergency Management Agency
'RAIc 98- %
y 7, yg g y March 24,1998 James L Freels, Regulatory AfTairs Manager Davis-Besse, Regulatory Affairs 5501 North State Route 2 Oak Harbor, Ohio 43449 RE: Relocation of Alternate Emergency Operations Facility - Davis-Besse
Dear Mr. Freels:
The exchange ofinformation between the Ohio Emergency Operations Center (EOC) and the Davis-Besse Emergency Control Center (ECC) has been excellent during past drills and exercises.
The availability and use of the utility Technical Liaison has also assured timely and accurate coordination.
The movement of the alternate Emergency Operations Facility (EOF) to the Bay Shore Facility will ensure that communications between governmental officials and the utility is maintained.
We understand that the facility will provide a predesignated meeting place outside of the ten-mile Emergency Planning Zone (EPZ) for governmental officials to meet with senior utility personnel in the event of an emergency at Davis-Besse. We also enderstand that this alternate facility will orJy be used when the primary EOF is unavailable.
Sincerely,
\ '
u C6 DALE W. SHIPLAY b l i $ $ . ' 3 %' #
Deputy Director h
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