ML082740060
| ML082740060 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 09/24/2008 |
| From: | Scherer A Southern California Edison Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML082740060 (34) | |
Text
SOUTHERN CALIFORNIA A. Edward Scherer FI EM ON September 24, 2008 Director Nuclear Regulatory Affairs An EDISON INTERNATIONAL Company U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
Subject:
Docket Nos. 50-206, 50-361, 50-362, and 72-41 Response to Request for Additional Information Regarding Request for Emergency Plan Change Increase in ERO Augmentation Time San Onofre Nuclear Generating Station, Units 1, 2 and 3 and Independent Spent Fuel Storage Installation
Reference:
(1)
Letter from B. Katz (SCE) to Document Control Desk (NRC), dated June 18, 2007,
Subject:
Docket Nos. 50-206, 50-361, 50-362, and 72-41, Request for Emergency Plan Change, Increase in ERO Augmentation Time, San Onofre Nuclear Generating Station, Units 1, 2, and 3, and Independent Spent Fuel Storage Installation.
(2)
Letter from A. E. Scherer (SCE) to Document Control Desk (NRC),
dated June 18, 2008,
Subject:
Docket Nos. 50-206, 50-361, 50-362, and 72-41, Response to Request for Additional Information Regarding Request for Emergency Plan Change, Increase in ERO Augmentation Time, San Onofre Nuclear Generating Station, Units 1, 2, and 3 and Independent Spent Fuel Storage Installation (3)
Letter from N. Kalyanam (NRC) to R. T. Ridenoure (SCE) dated August 5, 2008,
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 Sir or Madam:
By letter dated June 18, 2007 (Reference 1), Southern California Edison (SCE) submitted a proposed change to the Emergency Plan for San Onofre Nuclear Generating Station (SONGS), which requested an extension to the time goal for the augmented staffing of Emergency Response Organization minimum staff positions.
P.O. Box 128 San Clemente, CA 92674
Document Control Desk September 24, 2008 By letter dated June 18, 2008 (Reference 2), SCE responded to a request for additional information from the U. S. Nuclear Regulatory Commission (NRC) regarding SCE's proposed Emergency Plan change.
By letter dated August 5, 2008 (Reference 3), the NRC provided additional questions regarding SCE's proposed Emergency Plan change and the responses to previous questions included in Reference 2. SCE discussed the questions with the NRC staff in a phone call on August 20, 2008 and received further clarification on the questions included in Reference 3. of this letter is a response to the questions contained in Reference 3 as clarified in the August 20, 2008 phone call. Enclosure 2 is a list of regulatory commitments resulting from this letter.
Should you have any questions, please contact Ms. Linda T. Conklin at (949) 368-9443.
Sincerely,
Enclosures:
as stated cc:
E. E. Collins, Regional Administrator, NRC Region IV N. Kalyanam, NRC Project Manager, San Onofre Units 2 and 3 J. C. Shepherd, NRC Project Manager, San Onofre Unit 1 G. G. Warnick, NRC Senior Resident Inspector, San Onofre Units 2 and 3 Response to NRC Questions Regarding Proposed Emergency Plan Change to Increase Emergency Response Organization Augmentation Time San Onofre Units 2 and 3 Response to NRC Request for Additional Information Regarding SONGS Proposed Emergency Plan Change Introduction As discussed with the NRC staff in a telephone conversation on August 20, 2008, to respond to the NRC concerns described in the questions below, Southern California Edison (SCE) is committing to increase Emergency Planning staff requirements.
Specifically, prior to implementation of SCE's proposed Emergency Plan Change, SCE will add nine (9) qualified Health Physics (HP) Technicians, one (1) Electrical Maintenance Technician, and one (1) Instrument and Control (I&C) Technician to the automatic recall system, and ensure that either an I&C Technician or a Shift Rotating General Foreman (SRGF) is on-shift at all times. Personnel who are automatically recalled will be required to respond as soon as possible but in all cases within 90 minutes of recall notification.
The responses to individual NRC questions below are based on the inclusion of these additional personnel. The inclusion of these additional personnel has changed aspects of SCE's original request that were the basis for the several of the NRC's questions.
In addition, SCE has provided as Attachments to this Enclosure comparisons of the proposed San Onofre Nuclear Generating Station (SONGS) Emergency Plan Staffing that reflect the addition of these personnel. Attachment 1 is a comparison of SONGS proposed staffing to SONGS current Safety Evaluation Report (SER)-approved staffing. is a comparison of SONGS proposed staffing to that described in NUREG-0654, Table B-1. provides an analysis of the changes between SONGS SER-approved Emergency Plan Staffing and SONGS proposed Emergency Plan staffing to demonstrate that the changes do not result in a decrease in effectiveness. provides a revision to proposed Emergency Plan page 5-28. The revised page provides a new Table 5-5(a) to reflect the additional personnel that will be recalled.
Page 1 of 10
NRC Questions and SCE Responses In reference to RAI #10 (a), SCE response states in part, "In addition, one of the first duties of the HP Coordinator as delineated in the EPIPs, 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)?
SCE Response:
As described in the introduction above, SCE commits to recall additional HP qualified personnel beyond what was described in our original submittal. Timely augmentation of resources will be accomplished through the automated recall of nine (9) additional personnel to satisfy the requirements of Table B-1 of NUREG-0654. Six (6) of these additional personnel will be available within 90 minutes to perform Offsite Surveys, Onsite (out-of-plant), and In-plant Surveys to satisfy the requirements of Table B-1 of NUREG-0654. During the first 90 minutes, on-site radiological monitoring will be supported by the dispatch of on-shift HP Technicians under the direction of the HP Supervisor.
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 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?
SCE Response:
As described in the introduction above, SCE commits to recall additional personnel beyond what was described in our original submittal, changing that aspect of SCE's submittal that was the basis for the NRC's question. As a result of this change, the HP Coordinator will remain in the OSC and perform their duties. SCBA requirements are met with on-shift staffing and nine (9) additional HP Technicians (who are SCBA qualified if medically possible) that will be recalled automatically to satisfy Table B-1 requirements.
However, the HP Supervisors are SCBA qualified to the same degree that the HP Technicians are SCBA qualified.
Page 2 of 10
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)?
SCE Response:
No. Although cross-trained Operators can perform minor maintenance, the performance of these tasks will not impact the implementation of the proposed emergency plan changes. As described in the introduction above, prior to implementation of SCE's proposed Emergency Plan Change, SCE will add one (1)
Electrical Maintenance Technician and one (1) I&C Technician to the automatic recall system, and ensure that either an I&C Technician or an SRGF will be on-shift at all times. This additional responder satisfies the augmentation requirements of Table B-I.
In reference to RAI #15, SCE response states in part "The SRGF is cross-trained in the three Maintenance disciplines (Mechanical, Electrical, and I&C)..."
- 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)?
SCE Response:
The I&C Technician 30 minute capability is satisfied largely by an on-shift I&C Technician, but there are periods when the SRGF is needed to fulfill this position.
All SRGFs have been qualified as multi-discipline supervisors. The multi-discipline initial training program includes: Radiation Monitor Fundamentals, Electrical Checker, Electrical Drawings, Introduction to Mitigating Core Damage, Calibration and Control, Fabrication of Terminations & Splices, Troubleshooting Instruments, and Instrument Filling and Venting. Additionally, all SRGFs have received training on all major plant systems and maintain qualifications on Calibration and Control of M&TE.
The expected initial (i.e., prior to augmentation) I&C response actions would include verification of system flows, tank levels, system pressures, and hands-off troubleshooting. The training that all SRGFs have received ensures that they are able to perform these expected actions during the periods that an I&C Technician is not on-shift. The expected longer term actions required of an I&C Technician, such as calibration of controllers and equipment surveillances would be performed by recalled Technicians meeting the Table B-1 requirements.
Page 3 of 10
SRGF Concurrent Responsibility Discussion (If fillinq 30-minute I&C Role):
Currently, the Shift Rotating General Foreman (SRGF) is not a committed on-shift emergency response position. The SRGFs rotate with the Operations crews to assist the Shift Managers (SM) with any emergent maintenance needs.
Prior to implementation of SCE's proposed Emergency Plan change, SCE will ensure that either an SRGF or I&C Technician will be on-shift at all times. If an SRGF is on-shift without an I&C Technician and an emergency is declared, the SRGF will be available and is qualified to perform any I&C functions until the recalled I&C Technician arrives. The I&C Technician will be recalled by the SONGS Emergency Recall System following a declared emergency. This will ensure that at least one I&C Technician arrives, as soon as possible, but no later than 90 minutes following notification.
If an SRGF is on-shift without an I&C Technician available, the SRGF has an Electrician and a Mechanical Maintenance worker on-shift at all times as a resource until a recalled I&C Technician arrives. The SRGFs remain in communication with the SMs by radio or phone.
SONGS meets NUREG 0654 Table B-1 Repair and Corrective Actions on-shift and 30-minute requirements by having either the SRGF or an I&C Technician on-shift at all times, an on-shift Electrician and on-shift Mechanical Maintenance journeyman (Mechanic, Machinist, Welder or discipline supervisor), an on-shift Radwaste Operator, and on-shift Nuclear Plant Equipment Operators who are provided minor maintenance training (ref. Attachment 1 Section 3.9.2 of June 18, 2007 submittal).
In accordance with NUREG 0654 and to ensure SONGS has an I&C Technician on station within 90 minutes (in the event the 30 minute I&C function is being met by the SRGF), SONGS will recall one Electrician and one I&C Technician who will arrive within 90 minutes of notification.
- 5.
Are there any I&C required actions in the event of an earthquake that requires event classification and declaration?
SCE Response:
No, there are not any I&C required actions in the event of an earthquake that requires event classification and declaration. Seismic alarms received in the Control Room are the basis for seismic event classification and declaration.
Page 4 of 10
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)?
SCE Response:
As described in the introduction above, SCE commits to recall additional personnel beyond what was described in our original submittal. Timely augmentation of resources to perform tasks such as field monitoring during a radiological emergency will be accomplished through the automated recall of nine (9) additional qualified HP Technicians to meet Table B-1 requirements.
- 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?
SCE Response:
As described in the introduction above, SCE commits to automatically recall additional personnel beyond what was described in our original submittal. This includes the recall of nine (9)-qualified HP Technicians in accordance with Table B-1 of NUREG-0654. If an event declaration of Alert or higher is performed, these nine (9) additional qualified HP personnel will be automatically recalled and will respond within 90 minutes.
In addition,.the HP Supervisor determines the nature and extent of radiological emergencies through their initial contact with the Shift Manager (SM) which includes information on plant equipment status and radiation monitor readings, through information provided by HP Technicians dispatched to the affected area, and by performing a gross activity source term in accordance with station procedures.
Page 5 of 10
In reference to RAI #21, Radiological Accident Assessment, SCE response states in part "Offsite Surveys...The 60 minute capability (2) is filled by On-shift HP Technician
- 8.
Does the response mean that the On-shift HP technician #1 augments himself, augmentation involve the addition of personnel?
SCE Response:
As described in the introduction above, SCE commits to automatically recall additional personnel beyond what was described in our original submittal. This includes the recall of nine (9) HP Technicians, changing that aspect of SCE's submittal that was the basis for the NRC's question. The Table B-1 requirements of four HP Technicians for Off-site Surveys will be accomplished through the one (1) on-shift HP Technician and the automated recall of three (3) of the additional HP Technicians. In addition, offsite surveys may initially be performed by onsite (out-of-plant) field monitoring personnel taking surveys at the SONGS EAB.
- 9.
Discuss the basis for taking credit for the PICs if they (as provide by SCE responses) are not accurate for all stability classes, are not located at the 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?
SCE Response:
As described in the introduction above, SCE commits to automatically recall additional personnel beyond what was described in our original submittal, changing that aspect of SCE's submittal that was the basis for the NRC's question. The Table B-1 requirements of four (4) HP Technicians for Offsite Surveys will be accomplished through one (1) on-shift HP Technician and the automated recall of three (3) of the additional HP Technicians. In addition, offsite surveys may initially be performed by onsite (out-of-plant) field monitoring personnel. Although not credited, the PICs will continue to be used per the current E-plan.
- 10. 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)."?
SCE Response:
As described in the introduction above, SCE commits to automatically recall additional personnel beyond what was described in our original submittal, changing that aspect of SCE's submittal that was the basis for the NRC's question. The Table B-1 requirements of four (4) HP Technicians for Offsite Surveys will be Page 6 of 10
accomplished through one (1) on-shift HP Technician and the automated recall of three (3) of these additional HP Technicians. In addition, offsite surveys may initially be performed by onsite (out-of-plant) field monitoring personnel.
- 11. Explain how this staffing and augmentation meets NUREG-0654 Evaluation Criterion 1.7 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?"
SCE Response:
As described in the introduction above, SCE commits to automatically recall additional personnel beyond what was described in our original submittal, changing that aspect of SCE's submittal that was the basis for the NRC's question. HP staffing capability for SCE field monitoring teams (Off-site Surveys) will be accomplished through one (1) on-shift HP Technician and the automated recall of three (3) of these additional qualified HP Technicians. The 30 minute capability is performed by an on-shift HP Technician. Attachment 4 of this submittal provides an update to proposed Emergency Plan page 5-28 showing these additional recalled personnel.
In reference to RAI #21, Radiological Accident Assessment, SCE response states in part "Onsite (Out-of-plant)...The 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?
SCE Response:
As described in the introduction above, SCE commits to automatically recall additional personnel beyond what was described in our original submittal. This includes the recall of nine (9) HP Technicians, changing that aspect of SCE's submittal that was the basis for the NRC's question. As a result of this change, the 30 minute capability will be filled by an on-shift HP Technician and one (1) additional qualified HP Technician (not described in our original submittal) will be recalled by the automated system to satisfy the Table B-1 requirement.
Page 7 of 10
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 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?
SCE Response:
The On-shift HP Technician will perform any required on-site surveys, and the HP Supervisor performs the 30 minute dose assessment. The TSC HP Leader will perform Dose Assessments after relieving the HP Supervisor within the proposed 90 minutes. The Table B-1 requirements will be filled by one (1) additional HP Technician recalled by the automated system. Because SCE will recall one (1) HP Technician to meet Table B-1 onsite (out-of-plant) surveys, the onshift HP supervisor, once relieved by the TSC HP leader, is available to assist with offsite surveys.
In reference to RAI #21, Plant System Engineering, SCE response states in part "Electrical Maintenance...The 60 minute capability (1) is filled by On-Shift Primary NPEO #2."
- 14. Is this person qualified to fill this position? See RAI #3.
SCE Response:
As described in the introduction above, SCE commits to recall an additional electrician beyond what was described in our original submittal, changing that aspect of SCE's submittal that was the basis for the NRC's question. The Table B-1 60 minute requirements for Electrical Maintenance will be met by this recalled electrician. The on-shift NPEO, however, can assist until the recalled electrician arrives on site.
- 15. Does this person have any competing priorities required by station procedures?
SCE Response:
In the current and proposed SONGS staffing, SONGS has an on-shift Electrical Maintenance person who performs the on-shift and 30 minute capabilities. If needed to satisfy Table B-1 requirements, an NPEO qualified to perform minor maintenance can assist. Any competing priorities for the NPEO are relieved when the recalled electrician arrives to meet the Table B-1 requirements.
Page 8 of 10
In reference to RAI #21, Plant System Engineering, SCE response states in part "Instrument and Control (I&C) Technician...The 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.
SCE Response:
All SRGFs have been qualified as multi-discipline supervisors. The multi-discipline initial training program includes: Radiation Monitor Fundamentals, Electrical Checker, Electrical Drawings, Introduction to Mitigating Core Damage, Calibration and Control, Fabrication of Terminations & Splices, Troubleshooting Instruments, and Instrument Filling and Venting. Additionally, all SRGFs have received training on all major plant systems, and maintain qualifications on Calibration and Control of M&TE.
The expected initial (i.e., prior to augmentation) I&C response actions would include verification of system flows, tank levels, system pressures, and hands-off troubleshooting. The training that all SRGFs have received ensures that they? are able to perform these expected actions during the periods that an I&C Technician is not on-shift. The expected longer term actions required of an I&C Technician, such as calibration of controllers and equipment surveillances would be performed by recalled Technicians meeting the Table B-1 requirements. During an event that results in a recall, all I&C and Electrical personnel will be recalled using the automated system. Currently, I&C Technicians and Electrical Technicians are scheduled to be on-shift 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, six days per week.
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."
Page 9 of 10
- 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)?
SCE Response:
As described in the introduction above, SCE commits to automatically recall additional personnel beyond what was described in our original submittal. This includes the recall of nine (9) HP Technicians, changing that aspect of SCE's submittal that was the basis for the NRC's question. Depending upon plant conditions, the HP Supervisor will assign the three (3) on-shift HP Technicians to perform on-site (out-of-plant) surveys, in-plant surveys, and protective action duties until the recall of nine (9) additional HP personnel is complete within 90 minutes.
- 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)?
SCE response:
As described in the introduction above, SCE commits to automatically recall additional personnel beyond what was described in our original submittal. This includes the recall of nine (9) HP Technicians, changing that aspect of SCE's submittal that was the basis for the NRC's question. Depending upon plant conditions, the HP Supervisor will assign the three (3) on-shift HP Technicians to perform on-site (out-of-plant) surveys, in-plant surveys, and protective action duties until the recall of nine (9) additional HP personnel is complete within 90 minutes.
- 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?
SCE Response:
As described in the introduction above, SCE commits to automatically recall additional personnel beyond what was described in our original submittal. This includes the recall of nine (9) HP Technicians, changing that aspect of SCE's submittal that was the basis for the NRC's question. Depending upon plant conditions, the HP Supervisor will assign the three (3) on-shift HP Technicians to perform on-site (out-of-plant) surveys, in-plant surveys, and protective action duties and HP Coverage until the recall of nine (9) additional HP personnel is complete within 90 minutes. In addition, the on-shift SONGS Fire Department crews have emergency PEDs which are worn at all times and activated upon entry into the RCA.
Page 10 of 10 SONGS SER-approved Staffing Correlation to SONGS proposed Staffing
SONG S ER' CRRELATION1T RPSDSAFN Table.~Bi SER Capabilities For Mato
'-Table B-i PstoTitle 6r, Additions I
6-hf Additional SONGS Area S:.-
esoPositton T(tloros-Additions
-'Functional Malor Tasks,(test,(Propose
'Capability inr9 0 Cha ass Notes
-:,:Area SERIii**::io~~*D:*:
-;i 3 min
- 60 min' e~visiones(ro)s Plant Shift Supervisor 1
Operations (SRO) 1
_1 and Shift Foreman Assessment (SRO) 1 2
of Operational Control Room 3
3 Aspects Operators Auxiliar 3
Operators
_3 Emergency Shift Technical Direction Advisor, Shift and Control Supervisor or 1
SED (Emergency designated Coordinator) facility manager Notification/
Notify licensee, Communicati State local and On****
Federal personnel &
1*
1 2
1 4
maintain communication 1
SON~
ER ORELTION TO PROPO ED 4TFFI4G M..orTable.B-i.Oh-Shift 1SER Capabilities For on-shift AdditionalSONGS Functionalt,,
.Maior Tasks Posi erito e
att Adionsb in 90 Changes Notes Exp rti e :*;;*,*
= 30 rain i 60 rin
'Revision)riii tes;l.opos:d ;I Radiological Emergency Accident Operations S
1 CED Assessment Facility (EOF)
Senior Manager CE and Support Director of-Operational Offsite Dose Senior Health Accident Assessment Physics (HP) 1 2
1 3
Assessment Expertise Offsite Surveys 2
2 3
plant)e (out-of-1 I
1 In-plant surveys HP Technicians 1*
1 1*
2 Chemistry/
Rad/Chem.
Radiochemistry Technicians 1*
1 1
1 Plant Technical Shift Technical 1
- System Support Advisor Engineering, Core/Thermal Repair and Hydraulics_
1 Corrective
__ul_
Actions Electrical 1
Mechanical 1
1 Repair and Mechanical Corrective Maintenance Actions Rad Waste Operator Electrical 1
Maintenance 1
2
SOGSS EN*
A SCORRELATIOoN "Td PROPOSED STAFFING Table B-i
.SER Cda~sbilities For' Major A
TabledB-i p
t Ttl or hift I
O it Additiornal SONGS
- .-Area "E
x."ii*.*
-e iis SEll) 30 mmn:i
- 60ri mm l
Revision).
Minutes (Proposed)*!,."
,Functional, Maior Taske osilon ie o (Lats diin (Proposed..
naailt i90Ca s INotes Instrument and Control (I&C) 1 1
1 Technician I
Protective
-Radiation Actions (In-Protection:
Plant) a.Access Control
- b. HP Coverage for repair, corrective
- actions, HP Technicians 2
2 1
3' search and rescue first-aid &
firefighting
- c. Personnel monitoring
- d. Dosimetry I__I Firefighting Local Support 5
Local Support Rescue I
Operations Local Support U
Local Support and First-Aid Site Access
- Security, Security Per Control and firefighti ons Personnel (All IIIPhysical Per Physical Security P-ersonnel communicatins, per Securit "Security Plan Accountabilit personnel plane Scuiy Plan y
accountability Plan)
Total 13 11 13fl 24 24 3
SONGS -'SER -CO--R IR IELATONOPOOEDSAFN Table B-1 Staffing Notes:
Shared between units.
NRC title; actual title may vary.
May be provided by shift personnel assigned other functions and local support.
Provides notification and communication function for all events on Site.
Additional SONGS Staffing Notes:
- 1. The fourth Table B-1 responder is an on-shift HP Technician.
- 2.
Initially, the STA performs the Core / Thermal Hydraulics function and after augmentation the Assessor performs the Core / Thermal Hydraulics function. Following core damage assessment, which is not a full-time task, the Assessor assists the Mitigator in other Assessment and Mitigation activities.
4 SONGS Proposed Staffing Correlation to NUREG-0654 Table B-1 Staffing
SONGS PROPOSED STAFFING TO NUREG 0654 TABLE B-1 aTble B.1 ib l'.
TableB-i i Position Title or Expertise able B-1 Available SONGS
- Maior Functional"
____ao__"_______
i Area."
~
Maiof Tasks Talb-aabilities' Capability in90l Titl&On-shit SONGS OnShf I f0M 6 M iue Plant Operations Shift Supervisor 1
1 1
1 on-shift and Assessment of (SRO)
Operational Apects Shift Foreman 1
22 on-shift Aspects (SRO) 1 2
2 Control Room 2
32, 3 33 on-shift Operators Auxiliary 2
32, 4.
33 on-shift Operators Emergency Shift Technical Direction and Advisor,cShift Control S
r or1
.5 1 1on-shift (Emergency Supervisoror-1
-si Coordinator)***
designated facility manager Notification/
Notify licensee, State Communication****
local and Federal personnel & maintain 1
1 33 51 on-shift, 4 augmented communication 1
SONGS PROPOSED STAFFING TO NUREG 0654 TABLE B-1 Table B-1-i M *ajor Funcio a Tab
++ i "~ le B-i
+* :I;+i'
-:~+++ii+:l iPosition Title or Expertise ;i
+,:++
+++:+:+?+Table B-i
+.
+....
'+
? Available+*...SONGS" Arear.
M.alora
+.Capabilities.
CapabilitV in+90
- , *+°Area +
+
Maior,,Ta*
sks;
" ;T b eB 1 *
- +... *+ *
-itle Table B-i SONGS on-shift;
'30]Min /60 Min. -.
- Minutes, Ori-sh*.
Radiological Emergency Operations Senior Manager 1 augmented Accident Facility (EOF) Director Assessment and Support of Offsite Dose Senior Healthd Operational Assessment Physics (HP) 16133 augmee Accident Expertise Assessment Offsite Surveys
.7 4Note 8; 3 augmented Onsite (out-of-plant) 2 21 on-shift, i augmented' In-plant surveys HP Technicians 1
1 2
31 on-shift, 2 augmented Chemistry/
Rad/Chem.
Note% 1 Radiochemistry T
a ns1C1e1 2
on-shift, 1 augmented
+
Technicians Plant System Technical Support Shift Technical 110 1 t on-shi Engineering, Advisor Repair and Corrective Actions Core/Thermal
. o ito 1 Note 11;laugmented Hydraulics Electrical 1
---t Mechanical 1
11 augmented Repair and Corrective Mechanical 1 **2 1
1 12, on-shift Actions Maintenance Rad Waste 1 4 on-hift Operator Electrical 2
21°n-shift' o
augmented Maintenance 2
SONGS PROPOSED STAFFING TO NUREG 0654 TABLE B-1 Tal B
able "11 Position Titlewo ExOets' a____
GS______
Ma-or Tasks.
Table -
i AvailableSONGS Instrument and Control (l&C) 114 1
2lon-sl, 1 augmnented Technician Protective Actions Radiation Protection:
(In-Plant)
- a. Access Control
115 415 4 1 on-shift, 3 augmented rescue first-aid &
firefighting
- c. Personnel monitoring
- d. Dosimetry Firefighting Fire Brigade per 5
Local Support Local Support Tech. Specs Rescue Operations 2**
516 Local Support Local Support and First-Aid Site Access Control Security, firefighting Security Security Shift and Personnel communications, Personnel (All per Commander, Security Per Security Plan Accountability personnel Supervisor and accountability Security plan)
Security Officers Total 10 24 26 48 Table B-1 Staffing Notes:
For each unaffected nuclear unit in operation, maintain at least one shift foreman, one control room operator and one auxiliary operator except that units sharing a control room may share a shift foreman if all functions are covered.
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SONGS PROPOSED STAFFING TO NUREG 0654 TABLE B-1 May be provided by shift personnel assigned other functions.
Overall direction of facility response to be assumed by EOF director when all centers are fully manned. Director of minute-to-minute facility operations remains with senior manager in technical support center or control room.
May be performed by engineering aide to shift supervisor.
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SONGS PROPOSED STAFFING TO NUREG 0654 TABLE B-1 Additional SONGS Staffing Notes:
1 One Control Room Supervisor will be maintained on the unaffected unit unless all functions are covered per Note
- for Table B-I. However, a 2 nd Control Room Supervisor is not required when both units are in Modes 5 or 6.
2 One Control Operator and one NPEO will be maintained on the unaffected unit per Note
- for Table B-1.
3 Control Operator # 3 fulfills the 30 min requirement for Notification/ Communication (Ref. submittal Section 3.7).
4 NPEO #3 fulfills the 60 minute requirement for the Radwaste Operator.
5 Position filled by the Shift Manager until relieved by the Station Emergency Director (SED).
6 The HP Supervisor can perform the 30 min capability for offsite dose assessment and offsite surveys, and following recall, offsite surveys.
7 Monitoring of the installed plant radiological instrumentation is sufficient for the first 90 minutes of an accident with on-site, out-of-plant surveys used for verification as needed.
8 When the augmented senior HP expertise arrives the HP Supervisor is available to perform off-site surveys.
Because dose assessment takes approximately 15 minutes, the HP Supervisor will be available to perform other HP functions during the first 90 minutes of an event.
9 An additional Chemistry Technician is normally on-shift to provide augmented response capability. The Chemistry Coordinator meets this requirement during times when this additional capability is not on-shift (due to illness, etc.).
lo The Shift Technical Advisor position also performs core/thermal hydraulic assessment until the TSC is activated.
11 Initially, the STA performs the Core / Thermal Hydraulics function and after augmentation the Assessor performs the Core / Thermal Hydraulics function.
Following core damage assessment, which is not a full-time task, the Assessor assists the Mitigator in other Assessment and Mitigation activities.
12 On-shift 24/7 Mechanical Maintenance is available, and in addition, minor maintenance can be performed by NPEOs.
13 An on-shift 24/7 Electrician, plus a recalled Electrician within 90 minutes, coupled with NPEOs trained in minor maintenance meets the Table B-1 requirements.
14 The SRGF or I&C Technician is available 24/7.
15 Individuals who are radiation worker qualified meet the requirements of items (a) and (d). Operations personnel have been trained in the use of survey instruments to support individual response activities. HP Technicians will perform HP coverage for repair, corrective actions, search and rescue, first-aid & firefighting.
16 Fire Department personnel are also trained and qualified as EMTs.
5 Analysis of SONGS SER-approved Staffing Versus SONGS Proposed Staffing
SONGS SER versus Current Staffinq Analysis SONGS reviewed its proposed staffing against its latest SER staffing. Comparisons of the staffing differences are available in Attachments 1 and 2 of this submittal. In short, SONGS will recall nine (9) additional HP Technicians, one (1) additional I&C Technician and one (1) additional Electrician sufficient to meet Table B-1 augmentation requirements (when coupled with our on-shift staffing). These personnel will be recalled using our automated recall system and will be onsite within 90 minutes following notification. In addition, SCE will ensure that either an I&C Technician or a Shift Rotating General Foreman (SRGF) is on-shift at all times. SONGS current and proposed on-shift staffing is more than required by SONGS latest SER. This staffing, as was discussed in our original submittal and first response to NRC additional questions, is sufficient to meet Table B-1 functions during the first 90 minutes of an emergency, therefore, SONGS will continue to meets it SER commitment and there is no decrease in the effectiveness of the emergency plan as a result of implementing this change. Below is an analysis of Table B-1 functions and how SONGS continues to meet these functions with its proposed on-shift and augmented staffing.
Plant Operations and Assessment of Operational Aspects:
For this functional area, SONGS has on-shift staffing of nine (9) personnel which is greater than the SER approved staffing of eight (8). Therefore, there is no decrease in effectiveness of the SONGS Emergency Plan as a result of this change. There areino 30 or 60 minute requirements for this functional area.
Emergency Direction and Control (Emergency Coordinator):
For this functional area, the SONGS on-shift Shift Manager is the Emergency Coordinator until relieved by the recalled Station Emergency Director. Therefore, there is no decrease in effectiveness of the SONGS Emergency Plan as a result of this change. There are no 30 or 60 minute requirements for this functional area.
Notification / Communication:
For this functional area, SONGS has on-shift staffing of one (1) person which is equivalent to the SER approved staffing of one (1). The 30 and 60 minute SER additions are one (1) and two (2) respectively and SONGS recalls four (4) additional personnel. On-shift Control Operator #3 fills the Emergency Notification System 30 minute Table B-1 function.
Therefore, there is no decrease in effectiveness of the SONGS Emergency Plan as a result of this change.
HP Onshift and Augmentation Summary:
SONGS has four (4) HP on-shift resources. These resources cover all Table B-1 radiological accident assessment and plant protective action functions during the first 90 minutes of an emergency. SONGS SER on-shift HP staffing was one (1) HP technician with augmented resources covering the Table B-1 30-minute and 60-minute requirements.
Since the original SER (early 1980s), technological advancements in RCA access and electronic dosimetry have allowed rad worker qualified individuals to safely access RCA areas without needing HP resources for dosimetry and access control. This allows SONGS 1
on-shift HP resources to more fully cover the areas of in-plant and onsite (out-of-plant surveys), offsite dose assessment and any HP job coverage requirement that may occur.
A comparison of SER committed resources against SONGS proposed staffing in each of the Table B-1 functional areas follows:
Radiological Accident Assessment and Support of Operational Accident Assessment:
For this functional area, SONGS has on-shift staffing of four (4) personnel (two (2) HP Technicians, one (1) HP Supervisor [HP qualified], and one (1) Chemistry Technician) which is greater than the SER approved on-shift staffing of two (2). These three (3) on-shift HP resources provide for HP capabilities up to 90 minutes.
SONGS original SER staffing had four (4) HP Technicians recalled at 30 minutes. SONGS on-shift staffing of two (2) HP Technicians and one (1) HP Supervisor is sufficient to meet Table B-1 functional requirements (which are equivalent to its SER requirement) because, as discussed below, installed radiological instrumentation, coupled with one (1) Technician verifying any radiological data in the field, is sufficient for the first 90 minutes of an emergency.
Offsite Dose Assessment:
Thirty (30) minute offsite dose assessment is the responsibility of the on-shift HP, Supervisor until it is turned over to HP personnel in the TSC or the EOF. The HP Supervisor is the senior HP expertise on-shift, and therefore meets the 30-minute SER requirement for offsite dose assessment capability.
Offsite Surveys / Onsite (out-of-plant) Surveys:
The SER-approved staffing for these areas at 30 minutes is three (3) people.
Offsite surveys will be available when the emergency response facilities are fully activated through the augmentation of three (3) HP Technician resources and an on-shift HP resource.
Monitoring installed plant radiological instrumentation, in conjunction with a survey performed (if needed) by the onsite (out-of-plant) survey HP Technician to verify radiological conditions, is sufficient for the first 90 minutes of an accident on site.
As discussed above, the offsite survey SER capabilities for Offsite Surveys are satisfied by three (3) additional recalled personnel at the proposed 90 minutes and the HP Supervisor who is relieved of dose assessment responsibilities within 90 minutes by the TSC HP Leader. This provides for four (4) HP resources to cover SONGS SER and Table B-1 30 and 60-minute offsite survey requirements.
For onsite (out-of-plant) surveys, the on-shift HP Technician roves the Owner Controlled Area out to the EAB boundary (approximately 1960 feet from the middle of each unit's containment).
Additionally, one (1) HP Technician will be recalled at 90 minutes to perform the onsite (out-of-plant) surveys to satisfy the 60 minute SER and Table B-1 functions.
2
In-Plant Surveys:
The required on-shift capability is satisfied by an on-shift HP Technician. Normally, one (1) HP Technician can perform all needed In-plant surveys for the first 90 minutes of an emergency. If necessary, the on-shift HP Supervisor can reallocate the other on-shift HP Technician resources to assist with In-plant surveys as plant conditions warrant.
The 30 and 60 minute capabilities are satisfied by two (2) additional recalled personnel at the proposed 90 minutes which provides for SONGS fully meeting Table B-1 and its SER In-plant survey requirements.
Chemistry / Radiochemistry:
As discussed in the June 18th, 2007, Request for Emergency Plan Change, Increase in ERO Augmentation Time, Attachment 1, Section 3.8.6, and RAI # 11, SCE has one (1)
Chemistry Technician on-shift and one (1) Chemistry Technician capable resource is recalled at 60 minutes (proposed 90 minutes) which meets the SER and Table B-1 requirements.
Plant Systems Engineering, Repair and Corrective Actions:
Technical Support:
For this task, SONGS has on-shift staffing of one (1) person which is equivalent tothe SER approved staffing of one (1). The 30 and 60 minute SER additions are one (1) and two (2) respectively and SONGS recalls two (2) additional personnel. The 30 minute function for Core/Thermal Hydraulics is performed by the on-shift STA until the TSC is activated. The Electrical and Mechanical 60 minute SER functions are performed by the TSC Assessor and the TSC Mitigator after the Assessor performs the Core Damage Assessment, which is not a full time task. Therefore, there is no decrease in effectiveness of the SONGS Emergency Plan as a result of this change.
Repair and Corrective Actions:
SONGS meets NUREG 0654 Table B-1 Repair and Corrective Actions on-shift and 30-minute requirements by having either the Shift Rotating General Foreman (SRGF) or an I&C Technician on-shift at all times, an on-shift Electrician (Electrician, I&C Technician, Test Technician, HVAC Technician, or discipline Supervisor) and on-shift Mechanical Maintenance journeyman (Mechanic, Machinist, Welder or discipline supervisor), an on-shift Radwaste Operator, and on-shift Nuclear Plant Equipment Operators who are provided minor maintenance training (ref. Attachment 1, Section 3.9.2, of June 18, 2007 submittal).
SONGS SER approved staffing did not include on-shift Electrical or Mechanical Maintenance personnel (ref. Attachment 2, Figure 1, of June 18, 2007 submittal). For augmented Repair and Corrective Actions positions, SONGS agreed to recall personnel to meet NUREG-0654 Table B-1 requirements (Reference 8 of June 18, 2007 submittal).
SONGS current staffing includes one (1) Electrical Maintenance person and one (1)
Mechanical Maintenance person on-shift at all times. SONGS proposed staffing includes the current Electrical and Maintenance craft and either an SRGF or an I&C Technician on-shift at all times. SONGS will recall one (1) additional Electrical Maintenance person (craft qualified) and one (1) additional I&C Technician (or craft 3
qualified Supervisor) within 90 minutes, which will meet Table B-1 60-minute augmented requirements for Electrical Maintenance and 30 minute augmented requirements for I&C, if an I&C Technician is not already on-shift.
SONGS currently exceeds its SER approved staffing for on-shift staffing. With the proposed commitment of having an SRGF or an I&C Technician on-shift at all times we will meet our SER approved augmented staffing because we will have electrical and instrument control skill sets available within 30 minutes. In addition, we will be automatically recalling one (1) Electrician and one (1) I&C Technician so that they will arrive within 90 minutes of notification. Because a mechanical maintenance person is on-shift, SONGS will continue to meet its SER approved staffing in the area of Repair and Corrective Actions for on-shift, 30 minute and 60 minute responders.
Because this proposed staffing meets the requirements of NUREG-0654 Table B-1 and meets that of the original SER-approved staffing, this proposed change does not result in a decrease in effectiveness.
Protective Actions (In-Plant):
For this functional area, SONGS has on-shift staffing of one (1) person which is greater than the SER approved staffing of none required. The approved SER staffing required two (2)
HP Technicians at 30 minutes and an additional two (2) HP Technicians at 60 minutes. The proposed SONGS staffing will have three (3) additional HP Technicians available at..90 minutes which, combined with the on-shift HP Technician and the technological aids, described below, meets the SER-approved staffing levels.
Radiation Protection:
- a. Access Control - Worker access control is automated because HP work processes have been computerized. The RCA access portion of the Integrated Health Physics System (IHPS) computer verifies worker access, qualifications, and radiological controls.
These access control parameters are conveyed to all radiation workers entering the RCA via the Radiation Exposure Permit (REP). IHPS can provide this information without HP Technician support.
- b. HP Coverage for Repair, Corrective Action, Search and Rescue, First Aid and Firefighting - HP support is available and assigned to these activities as needed. The on-shift HP Supervisor will determine the necessary level of support based on conditions assessed through the use of installed Area Radiation Monitors (ARMs) located throughout plant areas, and through the information provided by surveys conducted in the affected area. The HP Supervisor will allocate on-shift HP resources to provide any job coverage needs. This may involve reducing some onsite (out-of-plant) or in-plant surveys based on actual plant conditions pending recall of staff; however, based upon a review of actions during the early phases of potential events, four (4) on-shift HP resources can adequately implement Table B-1 and SER HP functions. SONGS will recall three (3) HP Technicians to perform the Protective Actions (In-plant). Table B-1 on-shift double-asterisked (**) positions in this area are met by access only being granted to rad-worker qualified personnel who will use the IHPS entry system and electronic PEDs. Also, in the event it is necessary, Nuclear Plant Equipment Operators have been trained on self-monitoring. In addition to augmented HP Technicians, the HP Coordinator (upon arrival in the OSC) provides expertise regarding in-plant protective actions to teams dispatched from the OSC.
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- c. Personnel Monitoring - As discussed in the HP on-shift and augmentation summary, SONGS utilizes PEDs to monitor the dose for personnel entering the RCA during routine and emergency conditions. The PEDs provide several capabilities that enable ERO personnel to monitor their accumulated dose and dose rate in the areas they are working in or traversing through. The use of PEDs ensures that the dispatched team does not exceed exposure limits set for the activity to which they are assigned. Personnel are required to self-monitor whenever they are in the RCA and also when they exit the RCA.
No HP involvement is necessary for self-monitoring or exiting the RCA since the workers are trained to perform this task without HP supervision.
- d. Dosimetry - No HP involvement is necessary for dosimetry. Members of the ERO are assigned TLDs which are matched against workers security badges during RCA access by the computer system. PEDs are self issued and PED limits are set by the IHPS computer system according to the REP which is signed on to. Upon recall of additional HP personnel at 90 minutes, the OSC will provide any additional dosimetry needs.
Firefightincg:
For this functional area, SONGS has on-shift staffing of five (5) personnel which is greater than the approved staffing of none required. The 30 minute SER addition is "LocalSupport" and SONGS recalls "Local Support" to satisfy this capability. Therefore, there is no decrease in effectiveness of the SONGS Emergency Plan as a result of this change.
Rescue Operations and First Aid:
For this functional area, SONGS has on-shift staffing of five (5) personnel which is greater than the approved staffing of none required. The five. (5) on-shift firefighters perform firefighting, rescue operations, and first aid. The 30 minute SER addition is "Local Support" and SONGS recalls "Local Support" to satisfy this capability. Therefore, there is no decrease in effectiveness of the SONGS Emergency Plan as a result of this change.
Site Access Control and Personnel Accountability:
For this functional area, SONGS has on-shift staffing per the Physical Security Plan and additional capabilities at 90 minutes are also provided by the Physical Security Plan.
Therefore, there is no decrease in effectiveness of the SONGS Emergency Plan as a result of this change.
5 Proposed Emergency Plan Section 5.0 Replacement Page 5-28
TABLE 5-5 EMERGENCY RESPONSE ORGANIZATION MINIMUM STAFF POSITIONS (POSGTGONS TO BE STAFFED WGTHGN 90 MGNUTES FOLLOWGNG INOTDATDON OF CALLOUT PROCESS)
Emergency Operations Facility Technical Support Center Operation Support Center Emergency News Center Corporate Emergency Director Station Emergency Director Emergency Group Leader Operations ENC Director Emergency Advisor, Notifications Emergency Advisor, Operations Coordinator Emergency Services Emergency Advisor, Offsite Emergency Advisor, Notifications Coordinator Emergency Planning Emergency Planning Coordinator Emergency Planning Coordinator Red Coordinator Chemistry Coordinator Yellow Phone Communicator Phone Communicator Administrative Maintenance Coordinator Security Technical Leader Security Director Leader Security Leader Health Coordinator Health Physics Security Liaison Health Physics Physics Leader Assessor Mitigator Coordinator Leader Operations Leader Shift Communicator Table 5-5(a) Emergency Response Organization 90 Minute Responders Functional Area Type of Responder Min. Recalled Radiological Accident Assessment and Support Health Physics Technician Qualified Personnel 6
Protective Actions (In-plant)
Health Physics Technician Qualified Personnel 3
Electrical Maintenance Electrician Qualified Personnel 1
Instrument and Control Instrument and Control Qualified Personnel 1
Note: 90 Minute Responders are required for Facility Activation 5-28 List of Regulatory Commitments
List of Regulatory Commitments Prior to implementation of SONGS' proposed Emergency Plan Change, SCE will:
- 1. Add nine (9) qualified Health Physics (HP) Technicians, to the automatic recall
- system,
- 2. Add one (1) Electrical Maintenance Technician, to the automatic recall system,
- 3. Add one (1) Instrument and Control (I&C) Technician to the automatic recall system,
- 4. Ensure that either an I&C Technician or a Shift Rotating General Foreman (SRGF) is on-shift at all times.
- 5. Change the facility activation requirements for the Operations Support Center to include the additional 90 minute responders described in the above items 1, 2, and 3.