ML051730638

Request for Additional Information to Support Request for Exception to NUREG-0696 Guidance on Emergency Operations Facility (EOF) Location

ML051730638
Person / Time
Site:	Oconee
Issue date:	06/08/2005
From:	Rosalyn Jones Duke Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NUREG-0696
Download: ML051730638 (15)

Text

f Duke RON A. JONES U[<Powers Vice President A Duke Energy Company Oconee Nuclear Site Duke Power ONOl VP / 7800 Rochester Highway Seneca, SC 29672 864 885 3158 864 885 3564 fax June 8, 2005 U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION: Document Control Desk

SUBJECT:

Request for Additional Information to Support Request for Exception to NUREG-0696 Guidance on Emergency Operations Facility (EOF) Location Oconee Nuclear Station Docket Nos. 50-269, 270, 287 License Numbers NPF-38, NPF-47, NPF-55 In accordance with 10CFR50.54(q), Conditions of Licenses, Duke Energy Corporation (Duke) submitted a request on December 18, 2003, that an exception be granted to the Emergency Operations Facility (EOF) location requirements contained in NUREG-0696 for Oconee Nuclear Station.

Additional information was provided to the NRC on March 25, 2004, December 14, 2004, and April 21, 2005, to support this submittal.

In a conference call on May 12, 2005, the NRC discussed clarifying questions related to the April 21, 2005, submittal. During this conference call, it was determined that certain pages of the April 21, 2005, submittal should be amended to clarify our response. The amended pages are included in Attachment 1. In addition, it was requested that procedure steps be provided that document the process to be used to acquire additional computer resources to support a multi-site event. Attachment 2 provides these draft procedure steps.

There are no new NRC commitments contained within this correspondence. If you have questions, call Rodney Brown at (864)885-3301 or Tina Kuhr at (704)382-3151.

• , j00w1 www. dukepower. corn

U. S. Nuclear Regulatory Commission June 8, 2005 Page 2 Very t uly y urs, R. A. o s, Vice President Oconee Nuclear Site

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U. S. Nuclear Regulatory Commission June 8, 2005 Page 4 R. A. Jones, affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge.

R. A. Jones, President Subscribed and sworn to me:

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My commission expires: -,F/ J-9--P- / 3 1ate /

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U. S. Nuclear Regulatory Commission June 8, 2005 Page 3 xc w/Attachments:

W. D. Travers U. S. Nuclear Regulatory Commission Regional Administrator, Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, GA 30303 L. N. Olshan (Addressee Only)

NRC Senior Project Manager (ONS)

U. S. Nuclear Regulatory Commission Mail Stop 0-8 H12 Washington, DC 20555-0001 M. E. Shannon Senior Resident Inspector (ONS)

U. S. Nuclear Regulatory Commission Oconee Nuclear Site Henry Porter Division of Radioactive Waste Management South Carolina Bureau of Land and Waste Management 2600 Bull Street Columbia, SC 29201

U. S. Nuclear Regulatory Commission June 8, 2005 Page 5 bxc w/Attachments:

J. R. Brown E. M. Kuhr R. L. Gill L. E. Nicholson B. G. Davenport NRIA File/ELL Oconee Master File - ON03DM

ATTACHMENT I REVISED JANUARY 19,2005 RAI RESPONSES (Re: April 21, 2005 Letter)

This attachment contains revisions to the following RAI responses provided to the NRC on April 21, 2005. These pages replace the original pages provided in the aforementioned response. Change bars are included on these revised pages.

RAT Attachment 1, Page 5 of 7 RAI Attachment 1, Page 7 of 7 RAI Attachment 2, Page 3 , Page 2 , Page 3 RAI Attachment 4, Page 5 of 6 RAI Attachment 5, Page I of 2

5. In the response to RAI-17 and Attachment 1 to the December 18, 2003 submittal, the licensee states that power from the diesel generator backup power is supplied to orange electrical outlets located in the various EOF rooms. Identify whether an evaluation has been performed to verify that appropriate equipment will remain energized via orange outlets to support continuing accident assessment functions (e.g., dose assessment) upon a loss of normal utility circuits.

An evaluation of the emergency power supply capabilities for the Charlotte EOF was conducted in March 2005. The evaluation is included as Attachment 4.

This evaluation determined that additional extension cords would be required to connect identified equipment not already on emergency power circuits. This action would have a minimal impact on EOF operations until emergency power is made available to the designated equipment. During this brief interruption in EOF operations, the TSC would assume event responsibilities until the EOF is determined to be functionally operable.

The inventory of extension cords required to support equipment identified in Attachment 4 will be maintained by incorporating them in SR1OB/46001086, Standard Procedure For Periodic Verification Of EOF Communication Equipment Operation And Equipment/Supply Inventory.

Equipment requiring use of extension cords identified in Attachment 4 will be incorporated in EP Functional Area Manual (FAM) Section 3.8, EOF Data Coordinator Reference Manual.

SR/0/B/2000/003, Activation Of The Emergency Operations Facility, Enclosure 4.17, EOF Emergency Planner Checklist, will incorporate a new step that includes the following or equivalent statement: "If backup power is being supplied to the EOF, then refer to EP FAM Section 3.8 for additional guidance on supplying power to identified EOF Equipment."

RAI Attachment 1 Page 5 of 7

7. In response to RAI-36 the licensee states, "If the decision is made to send the site team to Oconee Nuclear Station, then accommodations would be made on a case by case basis." Discuss what accommodations/contingencies have been identified/considered and will ERO members be trained to accommodate a request to be located to the site.

If the decision is made to augment NRC response by sending a site team to Oconee Nuclear Site, then the legacy EOF located in Clemson, SC, would continue to serve this function as long as Duke Power retains ownership. This facility was designed, in accordance with NUREG 0696, to accommodate the site's EOF responders as well as State, FEMA, and the NRC's site team during an emergency event. The equipment (fumiture/phones/HVAC) necessary to support at least 10 members of the NRC's site team would continue to be maintained for this purpose. This would also include ENS, HPN, RSCL, OCL, PMCL, and MCL phones. The legacy EOF is also the location of the Oconee JIC. At this location, NRC personnel would have access to Public Information Officers from Duke Power, SC State, Oconee and Pickens Counties, as well as TV, radio, and newspapers.

The capabilities of the legacy EOF will be maintained for the foreseeable future. If a future decision is made to sell this facility or otherwise render it unsuitable for NRC use, then an equivalent facility would be provided for the response of additional NRC personnel.

The EOF would inform the TSC of the decision to augment the NRC response to the site. The TSC would be responsible for accommodating this request. Currently, the TSC NRC Communicator is tasked with facilitating the response of NRC personnel to the site.

RAI Attachment 1 Page 7 of 7

TRAINING

SUMMARY

COURSE DESCRIPTION NUMBER HS0537 Emergency Plan Exercise/Drill HS0556 Severe Accident Management Guideline (SAMG) Annual Drill TTN386 ERO Training for non-badged individuals (GO Personnel at EOF)

TTN366 FFD Training for non-badged individuals (GO Personnel at EOF)

OC7227 Severe Accident Management Guideline (SAMG) Introduction & Overview OC7228 Severe Accident Assessment & Mitigation OC7229 Severe Accident Management Guideline (SAMG) CBT OC7231 Severe Accident Management Guideline - Table Top Drill UAOLII Initial Radiation Worker Training UALIIB Radiation Worker Training Bypass TTC135 Notification of States and Counties from the Emergency Operations Facility (SR/O/B/2000/004) - review of procedure changes TTC136 Common EOF Overview; ONS Meteorology; Activation of the Emergency Operations Facility (SRIO/B/2000/003) - review of procedure changes Common EOF Overview; ONS Meteorology; Activation of the Emergency TTC137 Operations Facility (SR/0/B/2000/003) - review of procedure changes; Field Monitoring Coordinator (SH101B/2005/002) - review of procedure changes; Oconee Environmental Monitoring for Emergency Conditions (RPSM 11.7)

Common EOF Overview; Oconee Systems Overview; Oconee specific release rate variables, pathways, dose calculations; ONS Meteorology; Activation of the Emergency Operations Facility (SR/O/B/2000/003) - review TTC138 of procedure changes; ONS Emergency Classification (RP/O/B/1000/001) -

review of procedure; SH/0/B/2005/001 - review of procedure changes; Field Monitoring Coordinator (SH/0/B/2005/002) - review of procedure changes; HP/0IB/1 009/018 - review of procedure; review of RPSM 11.1 and 11.3 Common EOF Overview; Oconee Systems Overview; Activation of the TTC139 Emergency Operations Facility (SR/0/B/2000/003) - review of procedure changes; ONS Emergency Classification (RP/0/B/1000/001) - review of procedure TTC140 Common EOF Overview; Oconee Systems Overview; Activation of the Emergency Operations Facility (SR/O/B/2000/003) - review of procedure changes; ONS Emergency Classification (RP/0/B/1000/001) - review of procedure I TTN213 Emergency Operations Facility (EOF) Facility Specific Training TTN214 EOF Emergency Planner Position TTN217 EOF Log Recorder Position Specific TTN388 Initial EOF Offsite Agency Communicator TTN390 TSC/EOF Dose Assessor Position TTN391 Initial EOF Director Position TTN392 EOF Field Monitoring Coordinator TTN393 EOF Radio Operator Position Specific MC3077 Position Specific Accident Assessment Manager MC3090 EOF Radiological Assessment Manager Position Specific MC3092 EOF Accident Assessment Interface Position Specific RAI Attachment 2 Page 3

FIGURE B-li DUKE ENERGY COMPANY OCONEE NUCLEAR SITE Common EOF Multi-Site Event Staffing l Accident l Assessment Manager (2)_

I l Accident Assessment CNSMNS Opse l

- interface I Interface (2) 1(1)

1. Pagers activated for second unit - all call response

2. Assistant EOF Director assumes responsibility as lead manager for designated site

3. Additional Log Keeper retained to support 2"d Sie

4. AdditIonal Accident Assessment Manager retained to support 2"d Sie

5. AdditIonal Dose Assessor retained to support 2"4 Sie

6. Additional FMT Coordinator retained to support 2"4 Sie 7 Additional FMT Radio Operator retained to support 2"d Site

8. Four additional Offsite Communicators as needed to support both sites

9. Additional Emergency Planner as needed to support 2" Sie 10.

11.

12.

13 Additional Radiological Assessment Manager as needed to support 2"d Sie Additional Assistant EOF Director as needed to support ' Sie OconeeOps Interface position Is staffed Inthe ONS TSC Additional Accident Assessment Interface as needed to support 21d Sie DRAFT

. - .. ..... - . - - --- . I . I I. . ... - . - . - - - , - . . . - _ . .. . . . . .. .... . . - - - -- -- . _ -

Page 2

H. EMERGENCY FACILI IES AND EQUIPMENT (Continued)

H.2 Emergency Operations Facility The Emergency Operations Facility (EOF) is located in the Power Building which is part of the Charlotte General Office in North Carolina. The facility is located approximately 120 miles from the Oconee Nuclear Site. See Figures H3A thru H3-E.

Two utility circuits feed the Power Building where the EOF is located. Primary power to the Power Building is provided by commercial power. Backup power is provided by two Diesel Generators. These generators provide backup power for life safety, telecommunications loads, and the orange electrical outlets that are in the EOF. The swap to the Diesel Generators is an auto swap. There is adequate egress lighting in all normally occupied areas of the EOF. The lighting that is available would sustain a work I environment in the EOF.

Attachment 3 Page 3

PCs and Backup Power PC Primary Application Backup Power desired?

EOF Log keeper Autolog (Log keeper) Yes - Could keep typed log on Microsoft Word stand alone

• EOF Emergency Planner and Autolog (For display No - Projectors not on backup Extron Box purposes) power Accident Assessment Manager OAC/SDS No - Not useful without LAN connectivity for Data Transmittal Rad Assess. Mgr. RADDOSE V Yes - could serve as backup to Dose Assessor PC Public Affairs Microsoft Word (News Yes - could type on Microsoft Releases) Word stand alone; could not send documents to JIC through LAN, but could send via Fax

• Accident Assessment # 1 and OAC/SDS Already on backup power -

Extron Box Could use PC for Excel spreadsheets (e.g. Boil off or Ice Melt Calcs)

• Accident Assessment # 2 and OAC/SDS No - Not useful without LAN Extron Box connectivity for Data Transmittal

• Data Coordinator PC #1 and Various No -Not useful without LAN Extron Box connectivity for Data Transmittal

• Data Coordinator PC #2 and Various No - Not useful without LAN Extron Box connectivity for Data Transmittal

• Dose Assessor RADDOSE V RADDOSE V Yes - Run Raddose Stand and Extron Box alone. Could use Parallel cable to give local printing capability.

• Dose Assessor and Extron Box OAC/SDS No -Not useful without LAN connectivity for Data Transmittal Dose Assessor Dual Site Spare' RADDOSE V No - Not unless local printer installed Dose Assessor Dual Site Spare and OAC/SDS No - Not useful without LAN Hub connectivity for Data Transmittal Offsite Monitoring Various (Met Data) No - Not useful without LAN connectivity 2 NIT has installed 2 PCs permanently in Dose Assessor Area for Dual Site event use rather than committing Laptops, since this is where the need is greatest.

• Display projectors not on backup power. Extron Switching Equipment is, as are some Data Monitors.

RAI Attachment 4 Page 5 of 6

RAI ATTACHMENT 5 Charlotte EOF Relocation Plans Duke Energy Corporation (Duke) submitted a request on December 18, 2003, that an exception be granted to the Emergency Operations Facility (EOF) location requirements contained in NUREG-0696 for Oconee Nuclear Station. Shortly after this submittal, Emergency Planning was informed by Duke Energy Corporate Real Estate Services (CRES) that Duke Energy would be vacating the Power Building, where the existing EOF is located, by March 2006. CRES' goal is to relocate the Emergency Operations Facility from the Power Building by the end of 2005.

In February 2004, the decision was made that the new location for the EOF would be in Duke Energy's Energy Center at 526 South Church Street, Charlotte, North Carolina. The Energy Center is located across the street from the Power Building, and is also the current location of the Joint Information Center (JIC) for McGuire and Catawba Nuclear stations. The room arrangement for the new EOF was approved by Duke Power management in October 2004.

The size of the new EOF is approximately 7,414 square feet. This is equivalent to the existing location in the Power Building. Detailed design work is currently in progress. The facility is being designed in light of the requirements of NUREG-0696, with the intent of being equivalent to or better than the existing EOF in terms of equipment and function. The proposed EOF relocation does not alter the basic functions of the EOF and will not affect EOF staffing or training. Equipment from the Power Building EOF for the acquisition, display, and evaluation of radiological, meteorological, and plant system data used to determine offsite protective measures/plant status will be relocated to the new facility. The plant records, including emergency response procedures and plans, currently stored in the Power Building EOF will also be relocated to the EOF in the Energy Center. The following equipment located in the Power Building EOF will be relocated to the new facility in the Energy Center:

. Desks/tables

. Phones

. Computers

• Projection Systems

• Status Boards

. Maps

• Sign-In Boards

• Satellite Clocks

• Video Display Systems controllers/switches

• Communications Equipment (identified in earlier submittals and observed during the dual-site drill on March 23, 2005):

• Duke Telephone System

• Selective Signaling System (state/county notifications)

• Decision Line (discussion/coordination of PARs)

• Commercial Phones from Charlotte Switch Network

• Field Monitoring Team Radios

• North Carolina State Satellite Radio

• South Carolina Local Government Radio

• NRC Emergency Telecommunications System Phones

• Telecopiers Once the move to the new facility is completed, all equipment will be tested for operability in accordance with existing test procedures. The facility will not be declared operational until this testing is completed satisfactorily. During the transition, contingencies have been established to RAI Attachment 5 Page 1of 2

ATTACHMENT 2 ADDITIONAL COMPUTER RESOURCES TO SUPPORT A MULTI-SITE EVENT The following information in this attachment provides draft procedure statements to address the use of additional computer resources to support a multi-site event.

AITACHMENT 2 Additional Computer Resources to support a Multi-Site Event The demonstration drill conducted on March 23, 2005 identified the need for additional computer resources to support a multi-site event. Specific areas needing additional computer resources include the following: Accident Assessment Manager, Radiological Assessment Manager, and Public Affairs.

To support the need for additional computers for the Accident and Radiological Assessment Managers, the following (or equivalent step) will be added to Enclosure 4.19, EOF Data Coordinator Checklist, of SR1/B1/2000/003, Activation of the Emergency Operations Facility:

IF another site declares an emergency requiring activation of the EOF for support, acquire two additional computers (laptop or PC) within one hour for use by the Accident Assessment Manager and the Radiological Assessment Manager.

To support the need for additional computers for Public Affairs, the following (or equivalent)

Note will be added to Enclosure 4.3, Public Information Coordinator Activation Checklist, of SRI0/B/2000/001, Standard Procedure For Public Affairs Response To The Emergency Operations Facility:

NOTE: If additional computers are needed to support public affairs EOF response, contact the Admin & Logistics Manager (704-382-0548) in the JIC to request additional computers be sent to the EOF.

Attachment 2 Page 1 of 1