ML082170840
| ML082170840 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/05/2008 |
| From: | Kalyanam N NRC/NRR/ADRO/DORL/LPLIV |
| To: | Ridenoure R Southern California Edison Co |
| Kalynanam N, NRR/DLPM,415-1480 | |
| References | |
| TAC MD5837, TAC MD5838 | |
| Download: ML082170840 (6) | |
Text
August 5, 2008 Mr. Ross T. Ridenoure 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)
Dear Mr. Ridenoure:
By letter dated June 18, 2007 to the U.S. Nuclear Regulatory Commission (NRC), as supplemented by letter dated June 18, 2008, 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.
After reviewing your request, the 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
August 5, 2008 Mr. Ross T. Ridenoure 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)
Dear Mr. Ridenoure:
By letter dated June 18, 2007 to the U.S. Nuclear Regulatory Commission (NRC), as supplemented by letter dated June 18, 2008, 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.
After reviewing your request, the 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.: ML082170840
- No changes from the staff provided RAI OFFICE NRR/DORL/PM NRR/DORL/LA NSIR/DPR/DDEP/LIB/BC NRR/DORL/BC (A)
NAME NKalyanam GLappert KWilliams JDonohew DATE 8/5/08 8/05/08 8/01/08 8/05/08 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
OFFICE OF NUCLEAR REACTOR REGULATION SUPPLEMENTAL REQUEST FOR ADDITIONAL INFORMATION SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 1, 2, & 3 REQUEST FOR EMERGENCY PLAN CHANGE INCREASE IN EMERGENCY RESPONSE ORGANIZATION AUGMENTATION TIME TAC NOS. MD5837 AND MD5838 After review of the Response to Request for Additional Information (RAI) dated June 18, 2008, and discussions with the licensee per telecom on July 17, 2008, the U.S. Nuclear Regulatory Commission (NRC) staff requests the following clarifications:
In reference to RAI #10(a), Southern California Edison (SCE, the licensee), response states in part, In addition, one of the first duties of the HP [Health Physics] Coordinator as delineated in the EPIPs [Emergency Plan Implementing Procedures], is to call in additional HP Technicians if required to perform tasks called out in Attachment 1 of the procedure.
- 1.
How does this provide for timely augmentation of resources needed to accomplish the required tasks of Attachment 1 during a radiological emergency (i.e., radiological release)?
In reference to RAI #10 (b), SCE response states The HP Coordinator is filled by first line HP Supervisor who possess the skill and knowledge of the HP Technician and are fully qualified in that position.
- 2.
Do personnel assigned to this position maintain self contained breathing apparatus (SCBA) qualifications to allow them to work in a potential radiological release environment and do they receive the same level of emergency response training as the HP technicians?
In reference to RAI #14(c), SCE response states in part Plant Equipment Operators who will be cross-trained to perform minor maintenance activities...
- 3.
Does this impact the implementation of the proposed emergency plan changes (e.g., training operators to use hand held survey meters)?
In reference to RAI #15, SCE response states in part The SRGF [shift rotating general foreman] is cross-trained in the three Maintenance disciplines (Mechanical, Electrical, and I&C
[Instrumentation and Control])
- 4.
Are the SRGF and/or Electrical Maintenance personnel qualified to perform I&C activities (e.g., to provide assistance with logic manipulation, identification, and correction of controller and set point mal-adjustment, calibration, and surveillance necessary for accident mitigation, and/or hands-off troubleshooting)?
- 5.
Are there any I&C required actions in the event of an earthquake that requires event classification and declaration?
In reference to RAI #17, SCE response states in part the HP Supervisor will perform a look-ahead to determine the need for additional HP personnel to assist with the emergency condition. The recalling of additional HP personnel is delineated in EPIPs.
- 6.
How does this provide for timely augmentation of resources needed to accomplish the required tasks of field monitoring during a radiological emergency (i.e., radiological release event)?
- 7.
By what criteria does the HP Supervisor determine the nature and extent of the radiological emergency in order to provide a basis to determine the number of additional personnel required?
In reference to RAI #21, Radiological Accident Assessment, SCE response states in part Offsite SurveysThe 60 minute capability (2) is filled by On-shift HP Technician #1 and Pressurized Ion Chambers (PICs) and local Offsite Response Organization (ORO) offsite field survey teams.
- 8.
Does the response mean that the On-shift HP technician #1 augments himself, augmentation involve the addition of personnel?
- 9.
Please discuss the basis for taking credit for the PICs if they (as provided by SCE responses) are not accurate for all stability classes, are not located at the Exclusion Area Boundary (EAB) and available for manual dose calculation if needed, and can only be accurately used for dose assessment input when the plume is directly overhead?
- 10.
Please discuss the basis for taking credit for the ORO field survey teams if they (as provided by SCE responses) are non-SONGS staff, and are directed and communicated with by an offsite group whose function is to make independent offsite environmental assessments and measurements, radiological evaluations and Protective Action Recommendations (PAR).?
- 11.
Please explain how does this staffing and augmentation meet NUREG-0654 Evaluation Criterion I.7 which states, Each organization shall describe the capability and resources for field monitoring within the plume exposure Emergency Planning Zone which are an intrinsic part of the concept of operations for the facility?
In reference to RAI #21, Radiological Accident Assessment, SCE response states in part Onsite (Out-of-plant) 30 minute capability (1) is filled by On-shift HP Technician #1 (This person is sent to the Exclusion Area Boundary in the plume direction, satisfying both Onsite (out-of-plant) and Offsite Survey Functions).
- 12.
How does this person perform surveys Onsite (Out-of-plant) if he/she is directed to the EAB and radiological conditions are potentially changing?
In reference to RAI #21, Radiological Accident Assessment, SCE response states in part Onsite (Out-of-plant)The 60 minute capability (1) is filled by the augmented Technical Service Center (TSC) HP Leader (who relieves the HP Supervisor).
- 13.
Does the HP Supervisor now assist the HP Technician #1 in performing these Onsite (Out-of-plant) surveys and the TSC HP Leader now performs the Dose Assessment?
In reference to RAI #21, Plant System Engineering, SCE response states in part Electrical MaintenanceThe 60 minute capability (1) is filled by On-Shift Primary NPEO #2.
- 14.
Is this person qualified to fill this position? See RAI #3.
- 15.
Does this person have any competing priorities required by station procedures?
In reference to RAI #21, Plant System Engineering, SCE response states in part Instrument and Control (I&C) TechnicianThe 30 minute capability (1) is filled by a combination of on-shift electricians and the On-Shift Shift Rotating General Foreman (SRGF) who is cross-trained in all disciplines.
- 16.
Is this person qualified to fill this position? See RAI #4 & 5.
In reference to RAI #21, Protective Actions (In-Plant), SCE response states in part The 30 Minute capability (2) is filled as follows:
Access control: REP access control computer (IHPS)
HP Coverage: HP Tech #3 and/or HP Tech #2 and HP Supervisor depending upon plant conditions Personnel monitoring: Operator training using survey instruments Dosimetry: PEDs The 60 Min capability (2) is filled in the same manner as the 30 minute capability.
- 17.
According to the SCE response, HP Tech #2 is performing in-plant surveys and also fills the 30 minute capability. How does HP Tech #2 also perform the 30 minute capability for Protective Actions (In-Plant)?
- 18.
According to the SCE response, the HP Supervisor performs 60 minute augmentation of the Onsite (Out-of-plant) surveys when relieved by the TSC HP Leader. How does HP Supervisor also perform the 30 minute capability for Protective Actions (In-Plant)?
- 19.
According to the SCE response, for personnel monitoring, it is performed by self coverage trained operators. Are there any other personnel that need HP coverage, i.e., repair, corrective actions, search and rescue, first aid and firefighting activities? Who performs this coverage at 30 and 60 minutes, respectively?