ML081260004
| ML081260004 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/08/2008 |
| From: | Kalyanam N NRC/NRR/ADRO/DORL/LPLIV |
| To: | Rosenblum R Southern California Edison Co |
| Kalyanam N, NRR/DORL/LPL4, 415-1480 | |
| References | |
| TAC MD5837, TAC MD5838 | |
| Download: ML081260004 (8) | |
Text
May 8, 2008 Mr. Richard M. Rosenblum Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128
SUBJECT:
SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 1, 2 AND 3 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION - REQUEST FOR ADDITIONAL INFORMATION ON THE REQUEST FOR EMERGENCY PLAN CHANGE, INCREASE IN EMERGENCY RESPONSE ORGANIZATION AUGMENTATION TIME (TAC NOS. MD5837 AND MD5838)
By letter dated June 18, 2007 (Agencywide Documents Access and Management System Accession No. ML071700672), Southern California Edison (the licensee) submitted an Emergency Plan change which requested an extension to the time goal for the augmented staffing of Emergency Response Organization positions designated as minimum staff positions in each of the Emergency Response Facilities at the San Onofre Nuclear Generating Station, Units 1, 2 and 3 and Independent Spent Fuel Storage Installation. The proposed change would increase the response time goal from 60 minutes following initiation of the callout process to 90 minutes following initiation of the callout process.
After reviewing your request, the U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information outlined in the enclosure is needed to complete the review. The NRC staff discussed this information with your staff by telephone and they agreed to provide the additional information requested within 45 days of the receipt of this letter.
If you have any questions, please contact me at (301) 415-1480.
Sincerely,
/RA/
N. Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-206, 50-361, 50-362, and 72-41
Enclosure:
Request for Additional Information cc w/encl: See next page
May 8, 2008 Mr. Richard M. Rosenblum Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128
SUBJECT:
SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 1, 2 AND 3 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION - REQUEST FOR ADDITIONAL INFORMATION ON THE REQUEST FOR EMERGENCY PLAN CHANGE, INCREASE IN EMERGENCY RESPONSE ORGANIZATION AUGMENTATION TIME (TAC NOS. MD5837 AND MD5838)
By letter dated June 18, 2007 (Agencywide Documents Access and Management System Accession No. ML071700672), Southern California Edison (the licensee) submitted an Emergency Plan change which requested an extension to the time goal for the augmented staffing of Emergency Response Organization positions designated as minimum staff positions in each of the Emergency Response Facilities at the San Onofre Nuclear Generating Station, Units 1, 2 and 3 and Independent Spent Fuel Storage Installation. The proposed change would increase the response time goal from 60 minutes following initiation of the callout process to 90 minutes following initiation of the callout process.
After reviewing your request, the U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information outlined in the enclosure is needed to complete the review. The NRC staff discussed this information with your staff by telephone and they agreed to provide the additional information requested within 45 days of the receipt of this letter.
If you have any questions, please contact me at (301) 415-1480.
Sincerely,
/RA/
N. Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-206, 50-361, 50-362, and 72-41
Enclosure:
Request for Additional Information cc w/encl: See next page DISTRIBUTION:
LPLIV r/f RidsAcrsAcnwMailCenter RidsNrrDorlDpr RidsNrrDorlLpl4 RidsNrrDeEicb RidsOgcRp RidsNrrLAGLappert RidsNrrPMNKalyanam RidsRgn4MailCenter MNorris, NSIR ADAMS Accession No.: ML081260004
- No changes from the staff provided RAI OFFICE NRR/DORL/PM NRR/DORL/LA NSIR/DPR/DDEP/LIB/BC NRR/DORL/BC NAME NKalyanam GLappert KWilliams THiltz DATE 5/5/08 5/5/08 4/29/08 5/8/08 OFFICICIAL RECORD COPY
San Onofre Nuclear Generating Station Units 2 and 3 cc:
Douglas K. Porter, Esquire Southern California Edison Company 2244 Walnut Grove Avenue Rosemead, CA 91770 Dr. David Spath, Chief Division of Drinking Water and Environmental Management California Dept. of Health Services 850 Marina Parkway, Bldg P, 2nd Floor Richmond, CA 94804 Chairman, Board of Supervisors County of San Diego 1600 Pacific Highway, Room 335 San Diego, CA 92101 Mark L. Parsons Deputy City Attorney City of Riverside 3900 Main Street Riverside, CA 92522 Mr. Gary L. Nolff Assistant General Manager - Resources Riverside Public Utilities City of Riverside, California 3901 Orange Street Riverside, CA 92501 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Mr. Michael L. De Marco San Diego Gas & Electric Company 8315 Century Park Ct. CP21G San Diego, CA 92123-1548 Resident Inspector San Onofre Nuclear Generating Station c/o U.S. Nuclear Regulatory Commission Post Office Box 4329 San Clemente, CA 92674 Mayor City of San Clemente 100 Avenida Presidio San Clemente, CA 92672 Mr. James T. Reilly Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 Mr. James D. Boyd California State Liaison Officer Vice Chair and Commissioner California Energy Commission 1516 Ninth Street, MS 31 Sacramento, CA 95814 Mr. Gary Butner Acting Branch Chief Department of Public Health Services Radiologic Health Branch MS 7610, P.O. Box 997414 Sacramento, CA 95899-7414 Mr. Ross T. Ridenoure Vice President and Site Manager Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 Mr. A. Edward Scherer Director, Nuclear Regulatory Affairs Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128
REQUEST FOR ADDITIONAL INFORMATION SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 1, 2, & 3 REQUEST FOR EMERGENCY PLAN CHANGE INCREASE IN EMERGENCY RESPONSE ORGANIZATION FOR WELD OVERLAY AUGMENTATION TIME TAC NOS. MD5837 AND MD5838 Item Location Description 1
General Request applicant provide evidence that the proposed change to the E-Plan for extending the Emergency Response Organization (ERO) augmentation time at San Onofre Nuclear Generating Station (SONGS) has been reviewed by applicable State and local response organizations 2 -
Page 2 It states The adoption of a 90-minute response time will provide an increased pool of available resources that currently exceed the 60-minute response time capability. Approximately how many additional personnel will be added to pool of available resources to staff the minimum staff positions and is there any additional compensation for the increase in response time?
3 -
Page 15 Para 3.8.3 Offsite Surveys (1) This paragraph discusses that nine (9) fixed site detectors are 1 km from SONGS. How do these detectors provide a complete coverage area to detect all off-site radiation effluents? Are these detectors accurate for all stability classes (see precaution 4.8 in SO123-VIII-40)? Do these detectors have the capability to monitor Iodine for emergency class determinations for Site Area and General Emergencies? What are the positions of these detectors relative to the Exclusion Area Boundary?
(2) In addition, the paragraph further states the information obtained from these detectors provide data to support dose assessment calculations using the Raddose-V computer program. Does this program utilize these detectors as an input to generate dose projections?
(3) In addition, the paragraph states SONGS is in the process of developing a calibration protocol for these units and that SCE commits to implement the new calibration protocol prior to the implementation of the E-Plan Change. How long have these PICs been in service, how is their reliability, what are their power sources (primary and backup, if applicable) and by what process will they be maintained (calibrations,
Item Location Description surveillances, preventive maintenance, etc)? If this protocol is not completed successfully, what impact will this have on the implementation of the proposed E-Plan changes?
(4) The next paragraph states Following activation of the offsite agency and government emergency organizations the local agencies will be responsible for the offsite monitoring with the overall direction and coordination from the Offsite Dose Assessment Center in the EOF. What is response time for the local government agencies to staff their off-site monitoring teams? Do these off-site radiation monitors meet the training requirements in accordance with station procedures (Technical Specifications, SO123-XXI-1.11.3, SO123-VIII-0.200 or any other applicable procedures) and 10 CFR 50.120? How does the licensee direct the off-site, non-SONGS staff to conduct radiation monitoring required to accurately assess the radiological release to determine event classification and development of PARs? By what process does the licensee evaluate these monitoring teams and equipment to assure preparedness and qualifications?
(5) The County of Orange Nuclear Power Plant Emergency Plan, Part Two, Annex A-2 states The Offsite Dose Assessment Center (ODAC) functions as the technical offsite center to coordinate and make independent offsite environmental assessments and measurements, radiological evaluations and Protective Action Recommendations (PAR). By what agreements or procedures does the ODAC direct the off-site monitoring teams to obtain and communicate survey results to the Emergency Coordinator to determine event classification and the development of PARS?
4 -
Page 16 Para 3.8.6 Chemistry / Radiochemistry (1) This paragraph states an additional Chemistry Technician is normally on-shift to augmented response capability and ensure chemistry/radiochemistry related tasks in support of accident assessment are performed. Should this be reflected in the proposed SONGS shift staffing if it is needed to ensure these tasks are performed?
5 -
Page 17 - 18 Para 3.10 Protective actions (in-plant)
(1) This paragraph discusses the use of the REP access control computer system. Are there typically emergency REPs active for use in case an event occurs? Do plant procedures require HP briefs prior to access into high radiation areas?
Who would provide additional information regarding entry into the RCA during a radiological release (e.g., steam generator tube rupture) if the HP Supervisor is performing dose assessment and HP technicians are performing on-and off-site surveys?
Item Location Description 6 -
Page 18 Para 3.10.2 HP coverage (1) This paragraph discusses that the Primary PEOs will be trained on the use of handheld survey instruments to allow them to self-monitor. Later it states This training will be made available following approval of this proposed change.
What level of training will the Primary PEOs receive (i.e., air sampling, contamination surveys, protective clothing requirements, respiratory protection requirements, etc) and have will that aid in the response effort?
7 -
Page 1 Summary (1) The last sentence in the first paragraph states Note that there are no changes being proposed to augmented ERO staffing other than increasing the response time goal., Table 1 additional notes #3 and #4 clearly shows that the numbers of HP technicians are reduced. Is this an accurate statement or is there additional information that will be provided for review?
8 -
Table 1 Offsite survey (1) No 30-minute or 90-minute responders in the proposed SONGS staffing. Please justify why the on-shift staffing is not augmented as reflected in Table B-1.
9 -
Table 1 Onsite (out-of-plant)
(1) The augmented SONGS position is the HP Leader (TSC).
How is a person designated for this position available to perform onsite (out-of-plant) surveys when there are procedurally required duties in the TSC? Does this position maintain the training and qualifications to perform these surveys in place of a HP Technician? The augmented position in Table B-1 is a HP Technician. Please justify why the on-shift staffing is not augmented as reflected in Table B-
- 1.
10 -
Table 1 In plant surveys (1) The augmented SONGS position is the HP Coordinator.
How is a person designated for this position available to perform in-plant surveys when there are procedurally required duties in the OSC? Does this position maintain the training and qualifications to perform these surveys in place of a HP Technician? The augmented position in Table B-1 is a HP Technician. Please justify why the on-shift staffing is not augmented as reflected in Table B-1.
11 -
Table 1 Chemistry/Radiochemistry (1) The augmented SONGS position is the Chemistry Coordinator. How is a person designated for this position available to perform chemistry/radiochemistry functions when there are procedurally required duties in the OSC? Does this position maintain the training and qualifications to perform these activities in place of a Chemistry Technician? The augmented position in Table B-1 is a Chemistry Technician.
Item Location Description Please justify why the on-shift staffing is not augmented as reflected in Table B-1.
12 -
Table 1 Core/thermal hydraulics (1) There is no augmented SONGS position for this Table B-1 position. Credit can be given to move this position from the 30-minute to a 60-minute responder based on the capabilities of various on-shift personnel to recognize core damage indications, and technological advances since the implementation of NUREG-0654/FEMA-REP-1, Revision 1 (i.e., Severe Accident Mitigation Guidelines, core damage assessment methodology, etc.). Note #11 in Attachment 2, Table 1 (Page 27 of 28 in the licensee submittal) states that the core/thermal hydraulics assessment will be performed by the TSC Assessor when the TSC is activated. If this assessment is being performed by a designated position when the TSC is staffed, should it be included in the augmented staffing? The augmented position in Table B-1 is a Core/thermal hydraulics Engineer on-shift or within 30 minutes. Please justify why the on-shift staffing is not augmented as reflected in Table B-1. Please justify why the on-shift staffing is not augmented as reflected in Table B-1.
13 -
Table 1 Technical Support (Electrical and Mechanical)
(1) The augmented SONGS position is the Assessor or Mitigator.
What are the qualifications/expertise for personnel designated to staff these two titles?
14 -
Table 1 Mechanical Maintenance (1) The augmented SONGS position is the Maintenance Coordinator. How is a person designated for this position available to perform repair and corrective actions when there are procedurally required duties in the OSC? Does this position maintain the training and qualifications to perform these repair and corrective actions in place of a Mechanical Maintenance? The augmented position in Table B-1 is a Mechanical Maintenance. Please justify why the on-shift staffing is not augmented as reflected in Table B-1.
15 -
Table 1 Electrical Maintenance/I&C Technician (1) The proposed SONGS staffing is has one I&C Technician position filled by Electrical Maint. Personnel and a note #10 (May be provided by other shift personnel) for the Electrical Maintenance position. There is no proposed augmented staffing for these positions. Table B-1 lists an on-shift (**May be provided by other shift personnel) with an additional two 30-minute and one 60-minute responders. Please justify why the on-shift staffing is not augmented as reflected in Table B-1.
Item Location Description 16 -
Table 1 Protective actions (1) The proposed SONGS staffing has a note #8 Personnel will be trained in the use of survey instruments to support individual response activities. There is no proposed augmented staffing for these positions. Table B-1 lists two on-shift (**May be provided by other shift personnel) with an additional two 30-minute and two 60-minute responders. It was discussed earlier that the PEOs would receive handheld survey instrument training; will any other plant ERO personnel receive this training? Who will provide HP coverage for repair, corrective actions, search and rescue, first aid and firefighting activities after the on-shift staff is augmented?
Please justify why the on-shift staffing is not augmented as reflected in Table B-1.
17 -
Page 3 Synopsis of proposed changes (1) The proposed emergency plan wording states, additional field monitoring personnel are available with the activation of the Operations Support Center. This is not reflected in the Table 1 note #3 as it discusses the surveys performed by personnel from offsite respond agencies. Who are the additional field monitoring personnel as discussed in the proposed emergency plan wording?
18,
Pages 5-16 and 17 SONGS Emergency Plan, Section 5.4.2 Federal Agencies.
References to the Federal Radiological Emergency Response Plan need to be revised. The FRERP was superseded in 2004 by the National Response Plan, and specifically the Nuclear-Radiological Response Annex addresses actions in support of emergencies at a nuclear power plant. Currently the NRP is being superseded by the National Response Framework (NRF) and its supporting annexes.
Please revise accordingly.
19 -
Page 5-28 Table 5-5 (1) There are no HP technicians, mechanical and electrical maintenance or I&C technicians listed in this table. Does the proposed SONGS shift staffing include any additional working level staff personnel to augment the on-shift staff and if so, should it be listed on the minimum staffing list?
20 Please provide any plan, procedure or document that describes or conducts the current ERO augmentation process and lists the personnel recalled.
21 Please describe how the current SONGS ERO augmentation meets the minimum staffing positions as specified in Table B-1 of NUREG 0-654, Revision 1 within 60 minutes.