ML030780522
| ML030780522 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 03/21/2003 |
| From: | Stang J NRC/NRR/DLPM/LPD3 |
| To: | Bakken A Indiana Michigan Power Co |
| Stang J | |
| References | |
| TAC MB6578, TAC MB6579 | |
| Download: ML030780522 (16) | |
Text
March 21, 2003 Mr. A. Christopher Bakken III, Senior Vice President and Chief Nuclear Officer Indiana Michigan Power Company Nuclear Generation Group 500 Circle Drive Buchanan, MI 49107
SUBJECT:
DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2 - PROPOSED EMERGENCY PLAN CHANGES (TAC NOS. MB6578 AND MB6579)
Dear Mr. Bakken:
In your application dated October 22, 2002, as supplemented by letter dated January 24, 2003, and in accordance with 10 CFR 50.54(q), you submitted Revision 18 to the Donald C. Cook (D. C. Cook) Nuclear Plant Emergency Plan for Nuclear Regulatory Commission (NRC) review and approval prior to its implementation. The revision removes the 30-minute augmented staffing positions from the D. C. Cook Emergency Plan, Planning Standard B, Table 1, [Cook Nuclear Plant] CNP Staffing for Radiological Emergencies, and places the augmenting staff either on shift, or in 60-minute augmented staffing positions.
Based on the information provided, the NRC staff has concluded that the Revision 18 to the D. C. Cook Emergency Plan is acceptable in that the changes meet the planning standards of 10 CFR 50.47(b) and the requirements of Appendix E of 10 CFR Part 50.
If you have any questions regarding this matter, I may be reached at 301-415-1345.
Sincerely,
/RA by Mohammed Shuaibi for/
John F. Stang, Senior Project Manager, Section 1 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-315 and 50-316 cc: See next page
ML030780522 OFFICE PDIII-1/PM PDIII-1/LA PDIII-1/SC NAME MShuaibi for JStang LRaghavan for THarris LRaghavan DATE 03/21/03 03/21/03 03/21/03
Donald C. Cook Nuclear Plant, Units 1 and 2 cc:
Regional Administrator, Region III U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, IL 60532-4351 Attorney General Department of Attorney General 525 West Ottawa Street Lansing, MI 48913 Township Supervisor Lake Township Hall P.O. Box 818 Bridgman, MI 49106 U.S. Nuclear Regulatory Commission Resident Inspectors Office 7700 Red Arrow Highway Stevensville, MI 49127 David W. Jenkins, Esquire Indiana Michigan Power Company One Cook Place Bridgman, MI 49106 Mayor, City of Bridgman P.O. Box 366 Bridgman, MI 49106 Special Assistant to the Governor Room 1 - State Capitol Lansing, MI 48909 Drinking Water and Radiological Project Division Michigan Department of Environmental Quality 3423 N. Martin Luther King Jr. Blvd.
P. O. Box 30630, CPH Mailroom Lansing, MI 48909-8130 Scot A. Greenlee Director, Nuclear Technical Services Indiana Michigan Power Company Nuclear Generation Group 500 Circle Drive Buchanan, MI 49107 David A. Lochbaum Union of Concerned Scientists 1616 P Street NW, Suite 310 Washington, DC 20036-1495 Michael J. Finissi Plant Manager Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106 Joseph E. Pollock Site Vice President Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO EMERGENCY PLAN CHANGES INDIANA MICHIGAN POWER COMPANY DONALD C. COOK NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-315 AND 50-316
1.0 INTRODUCTION
In the application dated October 22, 2002, and as supplemented by the letters dated January 24, 2003, and in accordance with 10 CFR 50.54(q), Indiana Michigan Power Company (the licensee) submitted changes to the Donald C. Cook, Units 1 and 2, Emergency Plan (CNP) for Nuclear Regulatory Commission (NRC) review and approval prior to their implementation.
The proposed change is to remove the 30-minute augmented staffing positions from the Emergency Plan and place the staff either on shift or in a 60-minute response position.
2.0 REGULATORY EVALUATION
The regulatory requirements and guidance for which the NRC staff based its acceptance are as follows:
2.1 Regulations
10 CFR 50.47(b)(1) states, in part:... and each principal response organization has staff to respond and to augment its initial response on a continuous basis.
10 CFR 50.47(b)(2) states, in part: "... adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available, and..."
10 CFR 50.47(b)(9), states: Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.
10 CFR 50.47(b)(11), states, in part: Means for controlling radiological exposures, in an emergency, are established for emergency workers...
2.2 Guidance
Regulatory Guide 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors," Revision 3, states, in part: "The criteria and recommendations contained in Revision 1 of NUREG-0654/FEMA [Federal Emergency Management Agency]-REP-1 are considered by the NRC staff to be acceptable methods for complying with the standards in 10 CFR 50.47 that must be met in on-site and off-site emergency response plans."
NUREG-0654/FEMA-REP-1, Revision 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, states in part:
In Section B. Onsite Emergency Organization, "5. Each licensee shall specify...
functional areas of emergency activity.... These assignments shall cover the emergency functions in Table B-1 entitled, Minimum Staffing Requirements for Nuclear Power Plant Emergencies. The minimum on-shift staffing shall be as indicated in Table B-1. The licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency. This capability shall be as indicated in Table B-1....
In Section I. Accident Assessment, 8. Each organization...shall provide methods, equipment and expertise to make rapid assessments of the actual or potential magnitude and locations of any radiological hazards.... This shall include activation, notification means, field team composition, transportation, communication, monitoring equipment and estimated deployment times.
In Section K. Radiological Exposure, 1. Each licensee shall establish onsite exposure guidelines...for...
In Section O. Radiological Emergency Response Training, 1. Each organization shall assure the training of appropriate individuals The applicable regulation for making changes to a licensee's emergency plan is 10 CFR 50.54(q). This regulation states that licensees may change their radiological emergency plan without NRC approval only if the changes do not decrease the effectiveness of the plan, and the plan, as changed, continues to meet the planning standards of paragraph 50.47 and the requirements of Appendix E to 10 CFR Part 50. The licensee states in their application dated October 22, 2002, that as a result of a full assessment of the CNP Emergency Plan via 10 CFR 50.54(q), 10 CFR 50 Appendix E, and other NRC guidance, the proposed Emergency Plan changes required NRC approval prior to implementation. Therefore, the licensee submitted the proposed changes to the NRC in the application dated October 22, 2002.
3.0 TECHNICAL EVALUATION
The NRC staff has reviewed the licencees regulatory and technical analyses in support of its proposed Emergency Plan changes, which are described in their application dated October 22, 2002, and as supplemented in the letter dated January 24, 2003. The detailed evaluation below will support the conclusion that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the approval of the proposed emergency plan changes will not be inimical to the common defense and security or to the health and safety of the public.
3.1 Revise the minimum on-shift staffing levels and 30-minute response positions The licensee proposes nine specific changes to the on-shift positions assigned emergency response functions. Each of the proposed changes is discussed in the following sections.
3.1.1 Change to Notification/Communication Functional Area - Licensee Justification The present requirement for one plant operator on shift and one augmenting emergency response organization (ERO) member within 30 minutes is changed to two plant operators on shift. The 60-minute capability for two augmenting ERO members is unchanged. Auxiliary equipment operators (AEO) are trained for, and currently perform, the notification/communication function during the initial stages of an event. The change increases the number of on-shift AEOs assigned to the communications position. The total number of personnel assigned to this function on-shift and in augmenting positions is unchanged. This change improves the functional area capability due to the increase of the on-shift staffing assignment.
NRC Staff's Evaluation Guidance provided in Section B of NUREG-0654 states in part procedures have been established for notification, by the licensee of state and local response organizations... In addition, Table B-1 of NUREG-0654 states the function of the communicator is to notify licensee, State, local, and Federal personnel and maintain communication. Adding a communicator on-shift reinforces the expectation to make initial notification and enhances the ability to maintain future communications. The licensee's justification is consistent with this guidance. Therefore, the proposed change is acceptable.
3.1.2 Change to Radiological Accident Assessment and Support Functional Area (Offsite Dose Assessment) - Licensee Justification The present requirement for one person with health physics (HP) expertise augmenting at 30 minutes is changed to one reactor operator on shift with the Environmental Assessment Director augmenting this position at 60 minutes. Reactor operators receive extensive training on dose assessment to facilitate making protective action recommendations as part of the offsite notification requirements. The offsite dose assessment is performed using a windows-based computer program that performs all necessary calculations with initial conditions provided by the operator. The dose assessment function is augmented by the Environmental Assessment Director assigned to the Emergency Operations Facility (EOF).
This change increases the capability of the functional area by providing for on-shift dose assessment and is consistent with NRC EPPOS No. 3, Emergency Preparedness Position (EPPOS) on Requirement for On-shift Dose Assessment Capability, dated November 8, 1995.
In the supplemental letter dated January 24, 2003, the licensee stated additional training will be provided to the reactor operators to enhance their ability to assess meteorological conditions and make adjustments to protective action recommendations (PAR) based on complicating factors associated with the weather. Also, the training will address other factors that may necessitate placing constraints on PARs, such as affected institutions, plume transit time and evacuation times. This training will be the same training given to the Environmental Assessment Directors for dose assessment and will be satisfactorily completed prior to implementation of CNP Emergency Plan, Revision 18".
NRC Staff's Evaluation Senior HP expertise is referenced in NUREG-0654 as required in 30 minutes to perform dose assessment in order to provide timely information to offsite authorities. The licensee stated that the 30-minute position for dose assessment will be supplemented by an on shift reactor operator. The concern is whether the reactor operator has the knowledge level of the Environmental Assessment Director. The licensee stated in their letter of January 24, 2003, that they are committed to providing the reactor operators the same training as the Environmental Assessment Director prior to implementation of Revision 18. In addition, the Environmental Assessment Director will respond in 60 minutes to relieve the reactor operator from performing dose assessment. The proposed change is therefore acceptable.
3.1.3 Change to Radiological Accident Assessment and Support Functional Area (Offsite Surveys) - Licensee's Justification The present requirement for one Radiation Protection (RP) technician within 30 minutes is changed to one RP technician on shift. The 60-minute capability is unchanged at three RP technicians. Offsite survey teams are dispatched from the plant upon declaration of an Alert or higher classification, and they proceed on a pre-determined survey route to locate and track any radioactive release. The EOF, once activated, guides the offsite survey teams to the approximate location of a radioactive plume based on the radioactive release characteristics and meteorological conditions. Maintaining an RP technician in an on-shift position, versus a 30-minute augmenting position, increases the offsite survey capability by decreasing the time required to begin offsite surveys. Having three RP technicians augmenting the offsite survey function at 60 minutes coincides with the activation of the EOF, which provides command and control for the offsite survey.
NRC Staff's Evaluation The NRC has determined that the use of RP Technicians is the best method of responding to an emergency. In the submittal of October 22, 2002, the licensee stated the RP Technician is on-shift and is available to perform the tasks for this position. There was a concern regarding the field team composition being a one person team. In the letter of January 24, 2003, the licensee stated they have a Conduct of Operations procedure that results in a Contingency Team composed of on-shift personnel (RP Technician, Chemistry Technician, and other operations personnel) not assigned other duties that is available to assist with the response effort. In addition, a survey team consists of two individuals, a driver and a RP Technician. The licensee stated in the January 24, 2003, letter that the RP Technician would not normally be dispatched by himself. The licensee also stated that if a driver is needed and has not responded within the 60-minute time frame a driver would be assigned from available resources in the contingency team or the Operations Support Center (OSC) responders. The licensee will, add a statement to the Emergency Plan documenting the expectation that personnel on call or called will report to their facility immediately after receiving the notification to respond. In addition, the licensee has stated that there will be three RP Technicians responding in 60 minutes. The proposed change is therefore acceptable.
3.1.4 Change to Radiological Accident Assessment and Support Functional Area (Onsite Surveys) - Licensee Justification The present requirement for two RP technicians within 30 minutes is changed to one RP technician on shift. The 60-minute capability is unchanged at one RP technician.
Table B-1 of NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, identifies one 30-minute and one 60-minute augmenting position with no specific expertise for this task. The CNP Emergency Plan uses RP technicians to perform this function.
The described change reduces the number of RP technicians assigned for this task, but is consistent with the total number of individuals assigned in Table B-1 of NUREG-0654/FEMA-REP-1. The use of an RP technician on shift, versus a 30-minute augmenting position, improves the functional area capability for onsite surveys. The function is easily performed by one RP technician, considering the methods available to monitor and detect releases.
The in-plant radiation monitoring system (RMS) provides monitoring in areas that are potential sources of a release (e.g., residual heat removal (RHR) rooms, charging pump rooms, safety injection (SI) pump rooms, etc.). These monitors alarm in the control room to alert the control room staff of potential releases. The ventilation exhaust through the unit vents is continuously monitored and will provide an alarm and indication of a release. The air ejector and gland steam exhaust monitors will also provide alarm and indication functions for releases via the secondary plant. The personnel radiation monitors located at the protected area access and auxiliary building entrances are highly sensitive and will alarm at radiation levels far below emergency plan action levels and would provide an alarm function indicating a release was in progress.
NRC Staff's Evaluation In the past, licensees have discussed and proposed the use of technological advances in radiation monitoring, instead of relying on effective on-scene RP Technician job coverage for emergency entry teams. However, the NRC has determined that the use of RP Technicians is the best method of responding to an emergency. In the submittal of October 22, 2002, the licensee stated the RP Technician is on-shift and is available to perform the tasks for this position. There was a concern regarding the field team composition being a one person team.
The licensee stated in the letter of January 24, 2003, that they have a Conduct of Operations procedure that results in a Contingency Team composed of on-shift personnel (RP Technician, Chemistry Technician, and other operations personnel) not assigned other duties that is available to assist with the response effort. The licensee also will add a statement to the Emergency Plan documenting the expectation that personnel on call or called will report to their facility immediately after receiving the notification to respond. The licensee also stated that there will be a RP Technician responding in 60 minutes. The proposed change is therefore acceptable.
3.1.5 Change to Radiological Accident Assessment and Support Function (In-plant surveys) -
Licensees Justification The present requirement for one RP technician within 30 minutes is deleted. The on-shift and 60-minute capability is unchanged at one and two RP technician(s), respectively. As described previously, the in-plant RMS provides alarm and indication functions for areas in the auxiliary building. The areas include those discussed previously, along with the radioactive waste area, nuclear sampling room, and hallways in the various elevations of the auxiliary building.
Significantly-elevated radiation levels would be detected, causing alarms in the control room that would alert operators of abnormal radiation conditions. The control room would then control access to the affected areas of the auxiliary building using the plant public address system or the nuclear emergency alarm (NEA). Plant personnel are trained to report to office building assembly areas when directed by the public address system or when the NEA annunciates.
Continuous air monitors and local area monitors located throughout the auxiliary building provide local alarm and indication functions to warn personnel in the auxiliary building of changing radiological conditions. RP personnel obtain information on plant radiation conditions using the plant computers (e.g., RMS and plant process computer) without having to perform local surveys. This information is then used to brief personnel that are dispatched to the auxiliary building. These capabilities facilitate efficient use of RP resources.
The need for in-plant surveys would coincide with activities to restore plant equipment after the control room staff implements the Emergency Operating Procedures, placing the plant in a safe condition. Also, in-plant surveys for maintenance activities would not likely be required within 60 minutes of an event. The RMS system provides adequate radiological information for controlling other activities in the early stages of an event. The use of this alternative method allows deleting the 30-minute augmenting position for in-plant surveys without affecting the plants response to an event.
NRC Staff's Evaluation Adequate [meaning in number and qualification/expertise] backshift coverage by fully-qualified RP Technicians is essential for a successful response at the onset of an emergency. The initial facility response personnel capabilities and timely actions can be vital to the overall success of responding safely and appropriately to emergencies. Given that timely staff augmentation will occur within the prescribed time (within at least 60 minutes) at the onset of the emergency, a sufficient number of qualified RP Technicians are required to support necessary plant staff actions to assess conditions and take mitigation actions. These mitigation assessments and actions will likely involve entry into plant areas with unknown and potentially changing hazardous conditions. These entries may involve various functions (or combinations) including search and rescue, and systems actions (local manual operations). As a function of the accident and its severity, plant areas, while benign during normal operations, could present elevated levels of airborne/external radiation levels as well as immediately dangerous to life and health (IDLH) industrial hazards (e.g., explosive mixtures, smoke, toxic gas, oxygen deficiency).
Until these areas have been evaluated and sufficiently characterized, entries into unknown hazards areas require the use of adequately trained responders familiar with the facility design who are utilizing self-contained breathing apparatus (SCBA).
Entry into such unknown hazards areas without a proper radiological evaluation (survey) shall not be allowed. Specifically, 10 CFR Part 50.47(b)(11), requires licensees to control emergency workers radiation exposures consistent with EPA Emergency Worker and Lifesaving Protection Action Guides. 10 CFR Part 20 (20.1501) requires licensees to perform reasonable hazards evaluations of work areas to comply with (among other things) worker dose limits. While nothing in Part 20 shall be construed as limiting actions to protect health and safety of the plant and workers (licensees do have the flexibility of 50.54(x)), the fundamental survey requirements of Part 20 do apply relative to entering high and very high radiation areas (with the potential IDLH industrial challenges). How these evaluations are made, consistent with adequately responding to an emergency, while still complying with Part 20, is discussed below.
The licensee proposes to take advantage of technological advances, relative to providing reasonable and effective "job coverage" for entry teams. During the initial response period of an accident, the normal prework RP Technician survey of the work area is, in most cases, not an acceptable method (cant wait for the RP Technician to go perform the survey and then report back to brief the workers). Given the inherent nature of accidents, the work area conditions could have significantly (and unpredictably) changed by the time the workers arrive.
In the vast majority of plant locations, installed radiation monitoring equipment is not adequate (or not present) alone to satisfy the evaluation need; additionally, such equipment may not be operational or reliable. Merely equipping each worker with an electronic dosimeter (but no accompanying RP Technician) is not an adequate, stand-alone method to satisfy the survey requirement. Electron Devices (EDs) do provide dose and dose rate alarms, but experience shows clearly that in high noise areas, these alarms are not easily heard. Workers have ignored these alarms; many ED designs are not qualified for high heat/humidity conditions; their relatively small displays may not be visible in high humidity conditions, and EDS should not be used as survey instruments. During normal, stable operations, the typical plant RP Technician controls for entering and working in high radiation areas do not allow worker entry into areas with unknown radiation levels. EDs do provide an additional level of protection for the worker, by offering an electronic time keeping backup and alerting a worker to a change in radiation levels.
Providing continuous dose telemetry (DT) coverage is one method that would be adequate, as long as the licensee could demonstrate that the DT would function under accident conditions and in all access areas and that communication with the wearer of the device could be maintained. The licensee demonstrated in the January 24, 2003, supplement the DT would function under accident conditions and in all access areas. DT would require a RP Technician at the remote control station, as part of entry team oversight. In the absence of methods that would provide the continuous level of oversight and control of a dedicated RP Technician, licensees should continue to provide direct RP Technician coverage as part of the initial entry teams, responding to plant emergencies. Having a dedicated RP Technician focusing on performing a "as we are entering, real-time" survey/evaluation of the radiological conditions, under potentially IDLH conditions (and thus in SCBA), is considered an essential element of an adequate response team. Once a plant area has been properly surveyed, the licensee is free to decide whether the RP Technician needs to provide continuous coverage based on procedural guidance.
However, compensation to remove the 30-minute response positions for individuals performing these tasks includes: having three RP Technicians on-shift as well as an additional on-shift Chemistry Technician that has the potential to assist with any RP functions, and the licensee will add a statement to the Emergency Plan documenting the expectation that personnel on call or called will report to their facility immediately after receiving the notification to respond.
Therefore, the proposed changes are acceptable.
3.1.6 Radiological Accident Assessment and Support Functional Area (Chemistry Technician)
- Licensee Justification The present requirement for one chemistry technician within 30 minutes is changed to two chemistry technicians on shift. The 60-minute capability is unchanged at one chemistry technician. Changing the chemistry technician to an on-shift position, versus a 30-minute augmenting position, makes additional expertise immediately available to address chemistry issues. This change improves the functional area capability due to the increase of the on-shift staffing assignment.
NRC Staff Evaluation
The licensee proposes to add a Chemistry Technician on-shift for a total of two on-shift Chemistry Technicians to augment their response effort. NUREG-0654 requires that there be a Rad/Chem Technician on-shift and 1 in 60 minutes. Having two Chemistry Technicians on-shift would add to the response effort. Therefore, the changes are acceptable.
3.1.7 Plant System Engineering, Repair and Corrective Actions Functional Area (Technical Support) - Licensee Justification The present requirement for 30-minute Core/Thermal Hydraulics capability is changed to on shift, with the function performed by the on-shift, Shift Technical Advisor (STA) with one additional position at 60 minutes. The STA is specifically trained to perform this function as part of the STAs duties in the control room following an event. The STAs primary duties include monitoring the Critical Safety Function Status Trees and recommending necessary procedure transitions to the shift manager based on status tree monitoring. Core and thermal hydraulic conditions are monitored by the critical safety function status trees. Since the STAs duties already include status tree monitoring, this change is not a reduction in effectiveness of the Emergency Plan. Changing the Core/Thermal Hydraulic position to on-shift from a 30-minute capability will make the expertise immediately available to address related issues. The addition of a position to the 60-minute capability for Core/Thermal Hydraulics will make additional personnel available to perform this function. The change will also provide relief for the STA of this responsibility.
NRC Staffs Evaluation The role of the STA is to participate in the normal shift duties such as review logs, shift turnover, participate in shift training, crew briefs. In addition, the STA is to provide engineering and accident assessment expertise to the Shift Supervisor/Manager in the event of an abnormal or emergency event. The staffing level proposed by the licensee does not meet the guidance of NUREG-0654 Table B-1 in regards to core/thermal hydraulics expertise within 30 minutes position. Since the STA duties normally encompass the core/thermal hydraulics function, it is reasonable to assume the STA would perform that function for another 30 minutes until augmentation staff arrives. The licensee will add a statement to the Emergency Plan documenting the expectation that personnel on call or called will report to their facility immediately after receiving the notification to respond is considered along with the capability of the on-shift STA to provide core/thermal hydraulics expertise, therefore, the proposed change is acceptable.
3.1.8 Repair and Corrective Actions - Licensees Justification The present requirements for one Electrical Maintenance, one Mechanical Maintenance, and one Instrument and Control technician within 30 minutes are changed to on-shift positions with an additional Electrical Maintenance position. The Mechanical Maintenance and Electrical Maintenance positions are designated as positions that may be provided by personnel assigned other functions. In addition, a note was added to explain that one of the Electrical Maintenance positions may be filled by an Electrical or Instrument and Control technicians. Also, the one Radiological Waste Operator (RWO) on-shift position that may be filled by personnel assigned other functions is changed to one radiological waste position within 60 minutes. By designating the Electrical and Mechanical positions capable of being provided by personnel assigned other functions, and adding the Electrical Maintenance position, the Emergency Plan will exceed the guidance in NUREG-0654/FEMA-REP-1. Changing the Mechanical Maintenance, Electrical Maintenance and Instrument and Control technician positions to on-shift from a 30-minute capability and adding one Electrical Maintenance position on shift, will make the expertise immediately available to address maintenance issues. The added note clarifies the numbers required for the electrical position.
Changing the RWO from an on-shift to a 60-minute augmenting position aligns Table 1 with NUREG-0654/FEMA-REP-1, Table B-1. Normal operation of the radiological waste processing system is scheduled and controlled by the plant staff and is a collateral duty for AEOS. The operation of the radiological waste processing system is not essential during the initial stages of an emergency. Providing a 60-minute augmenting waste operator, versus an on-shift operator, allows an AEO to be completely available for plant response.
NRC Staff Evaluation
NUREG-0654 Table B-1 specifies that the Mechanical and Electrical functions may be performed by shift personnel assigned other functions. However, Table B-1 specifies that there must be two Electricians/I&C Technicians within 30 minutes. The licensee has placed the Electrician on-shift as adequate compensation for the 30 minute response position. In the supplemental letter dated January 24, 2003, the license stated that the 30-minute I&C Technician is an on-shift position as part of the Work it Now (WIN) team. The NRC staff finds this to be adequate compensation for the 30-minute I&C Technician response position. In addition, the Mechanical function can also be conducted by the WIN team as there is 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, 7 days per week coverage for maintenance.
The Radwaste Operator who was on-shift, is now a 60 minute response position and the duties, if needed, are fulfilled by an AEO. NUREG-0654 Table B-1 states that the duties of the Radwaste Operator can be fulfilled by other personnel fulfilling other duties. In the submittal of October 22, 2002, the licensee stated that the AEO will conduct the RWO duty. In addition, in the letter dated January 24, 2003, the licensee stated that the Radwaste Operator function is a normal duty of the AEOs and the Radwaste Operator was not placed on shift as a result of a regulatory action or inspection. Therefore, this function is maintained and a 60-minute response by a Radwaste Operator is acceptable.
3.1.9 Change to Protective Actions Functional Area - Licensee's Justification The present requirement for one RP technician on shift is changed to two RP technicians on shift that may be provided by personnel assigned other functions. The two 30-minute augmenting positions are combined with the two 60-minute augmenting RP technicians for a total of four RP technicians within 60 minutes.
The change from one RP technician on shift to two RP technicians on shift that may be provided by personnel assigned other functions aligns Table 1 with NUREG-0654/FEMA-REP-1, Table B-1. Protective actions are performed by one of the three RP technicians that are on shift until additional RP personnel arrive in conjunction with the activation of the OSC within approximately 60 minutes.
The in-plant RMS provides alarm and indication functions for areas in the auxiliary building.
These areas include the RHR rooms, charging pump rooms, SI pump rooms, radioactive waste area, and nuclear sampling room, as well as hallways in the various elevations of the auxiliary building. Significantly elevated radiation levels would be detected and alarmed locally and in the control room to alert operators of abnormal radiation conditions. The control room can control access to the auxiliary building via the plant public address system and by using the NEA. Plant personnel are trained to report to office building assembly areas when directed by the public address system or when the NEA annunciates. The public address system is also used to direct personnel to assembly areas via specific routes based on RMS indications of potentially-hazardous areas.
RP technician assistance is not required for workers entering the auxiliary building during an emergency. An emergency radiation work permit (RWP) is maintained at the auxiliary building entrances for quick access in the event of an emergency. Worker access control is essentially automated since RP work processes have been computerized. Specifically, this includes an RWP access control computer system and the Electronic Alarming Dosimeter (EAD). The RWP access control and EADs work together to provide a fully-integrated system allowing workers to sign in on their emergency RWP and to self-issue EADS. The access control computer system has been on line and used by plant workers for several years. Worker dose margins and radiation worker training qualifications are also automatically verified when workers use the RWP access control system. During the log-in process, workers acknowledge their EAD alarm setpoints and that they have read and understand their RWP. The EAD provides the worker with a continuous indication of dose received and will alarm at a pre-set dose or dose rate. The use of EADS facilitates not sending RP technicians into the plant with all teams, prior to OSC activation, to provide RP coverage while preserving the as low as reasonably achievable concept.
Personnel are required to monitor themselves using automated contamination monitors or hand-held friskers whenever they exit any contaminated area. No RP involvement is necessary during frisking since workers are trained to and routinely perform this task without RP supervision. While wearing EADS, workers monitor their dose received and in the event that their EAD alarms, they are trained to leave the area and immediately contact Radiation Protection.
Highly-sensitive personnel monitoring equipment is provided at the exits from the auxiliary building that will alarm if personnel contamination is detected. In addition, portable frisking equipment is located at the exits of the auxiliary building and in the assembly area near the OSC area for use in detecting personnel contamination. Also, the process and area radiation monitoring systems can be remotely monitored from the control room and may be monitored periodically by an RP technician at the auxiliary building entrance. In addition, remote monitoring is available at the OSC via the Plant Process Computer. This remote monitoring capability allows the available RP staff to be used more efficiently to monitor onsite radiological conditions.
The 60-minute reporting time for the four RP technicians will coincide with the 60-minute activation time of the OSC and will allow for full support of the repair or rescue teams that are dispatched. Changing the protective actions (in-plant) RP technician from one on shift to two that may be provided by personnel performing other functions, and combining the 30-minute augmenting positions with the 60-minute positions, will not affect the ability to protect plant personnel during an event.
NRC Staff Evaluation
As discussed Section 3.1.5, licensees have discussed and proposed the use of technological advances in radiation monitoring, instead of relying on effective on-scene RP Technician job coverage for emergency entry teams. The NRC has determined that the use of RP Technicians is the best method of responding to an emergency. However, compensation to remove the 30-minute response positions for individuals performing these tasks includes:
having three RP Technicians on-shift as well as the additional on-shift Chemistry Technician that has the potential to assist with any RP functions, and the licensee will add a statement to the Emergency Plan documenting the expectation that personnel on call or called will report to their facility immediately after receiving the notification to respond. In addition, the RP Technician was not placed on shift as a result of a regulatory action or inspection. Therefore, the proposed changes are acceptable.
3.1.10 Summary of on-shift staffing changes In the supplemental letter dated January 24, 2003, the licensee added two positions over that proposed in their original application. In addition, the licensee made a commitment to train the reactor operators to the level of the Environmental Assessment Directors in regards to dose assessment. These additions increase the total number of on-shift individuals in their proposed CNP Emergency Plan to 18 personnel that are available to respond to an emergency event (excluding Fire Brigade personnel and Security personnel). In addition, the licensee will add a statement to the Emergency Plan documenting the expectation that personnel on call or called will report to their facility immediately after receiving the notification to respond. Therefore, the staffing levels proposed (see attachment) for CNP Emergency Plan Revision 18, Table 1, are acceptable.
4.0 CONCLUSION
The NRC staff has determined that the licensees proposed CNP Emergency Plan changes in its application dated October 22, 2002, and as supplemented by the letter dated January 24, 2003, are acceptable. The NRC staff also finds that the CNP Emergency Plan changes meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E of 10 CFR Part 50. Therefore, the Commission concludes, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the approval of the proposed emergency plan changes will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: K. Williams TABLE 1 CNP Staffing for Radiological Emergencies Functional Area Tasks Position On-Shift 60 mins.1 Plant Operations Shift Manager Assistant Shift Manager/WCC-SRO Unit Supervisor Control Room Operator Auxiliary Equipment Operator 1
1 2*
4*
4*
Emergency Direction and Control Shift Manager Senior Manager (SEC) 12 1
Notification/
Communication Notify County, State, Federal Agencies and Plant Staff and maintain required communications Plant Operators Augmenting ERO members 2
2 Radiological Accident Assessment and Support Direction and Control Offsite Dose Assessment Offsite Surveys Onsite Surveys In-Plant Surveys Chemistry Emergency Director (EOF)
Reactor Operator/EAD RP Technician RP Technician RP Technician Chemistry Technician 12 1
1 1
2 1
1 3
1 2
1 Plant System Engineering, Repair and Corrective Actions Technical Support Repair and Corrective Actions STA Core/Thermal Hydraulics Electrical Mechanical Mechanical Maintenance Electrical Maintenance Instrument & Controls Maintenance Radiological Waste 1
12 12 22,3 1
1 1
1 1
1 1
1 Rescue and First-Aid 22 Local support Protective Actions Radiation Protection RP Technicians 22 4
Fire Protection Fire Fighting Fire Brigade As per ATR-12-F P-8 Local support Access control &
accountability Security, Communications, Personnel Accountability Site Protective Services personnel As per Security Plan As per Security Plan Total (not including Fire Brigade or Site Protective Services personnel) 21 23 1.
The augmentation times presented in this table are goals developed from the guidance of Table B-1 in NUREG-0654, FEMA-REP-1, Rev. 1 "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants."
2.
May be provided by shift or other personnel assigned from other functions. Not included in the total.
3.
One of the two positions may be an Electrician OR an I&C Technician.
The number indicated is for two operating units. With the unaffected unit in operation, maintain at least 1 Unit Supervisor, 1 Control Room Operator, and 1 Auxiliary Equipment Operator assigned to the unaffected unit.