NRC-11-0008, Response to Request for Additional Information Regarding Request for Approval of Revision to the Radiological Emergency Response Preparedness Plan to Change Staff Augmentation Times

Response to Request for Additional Information Regarding Request for Approval of Revision to the Radiological Emergency Response Preparedness Plan to Change Staff Augmentation Times

ML110660050
Person / Time
Site:	Fermi
Issue date:	03/04/2011
From:	Plona J Detroit Edison, DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-11-0008
Download: ML110660050 (12)

Text

Joseph H. Plona Site Vice President 6400 N. Dixie Highway, Newport, MI 48168 Tel: 734.586.5910 Fax: 734.586.4172 DTE Energy 10 CFR 50.90 March 4, 2011 NRC-11-0008 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington D C 20555-0001

References:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43

2) Detroit Edison's Letter to NRC, "Request for Approval of Revision to the Fermi 2 Radiological Emergency Response Preparedness Plan to Change Staff Augmentation Times,"

NRC-10-0001, dated September 24, 2010

Subject:

Response to Request for Additional Information Regarding Fermi 2 Request for Approval of Revision to the Radiological Emergency Response Preparedness Plan to Change Staff Augmentation Times In Reference 2, Detroit Edison submitted a request for approval of a revision to the Fermi 2 Radiological Emergency Response Preparedness Plan to change staff augmentation times for the Technical Support Center related functions from 30 to 60 minutes and for the Emergency Operations Facility related functions from 60 to 90 minutes.

In an e-mail from Mr. Mahesh Chawla to Mr. Alan Hassoun dated January 24, 2011, the NRC requested additional information regarding the proposed change to the staff augmentation times.

The additional information requested by NRC staff is provided in Enclosure 1 to this letter.

USNRC NRC-11-0008 Page 2 As a result of the response provided in Enclosure 1, the proposed revision to Table B-1 of the RERP Plan submitted in Reference 2 has been updated. The updated proposed revision to this Table is provided in Enclosures 2 and 3 to this letter.

There are no new commitments included in this document.

Should you have any questions or require additional information, please contact Mr.

Rodney W. Johnson of my staff at (734) 586-5076.

Sincerely, Joseph H. Plona

Enclosures:

1. Response to Request for Additional Information

2. Marked-Up Emergency Plan Table B-I

3. Clean Copy Emergency Plan Table B-1 cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 4, Region III Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission

USNRC NRC-11-0008 Page 3 I, J. Todd Conner, do hereby affirm that the foregoing statements are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.

J.

dd Conner

-Director - Nuclear Production On this I

day of c* -vh

, 2011 before me personally appeared J. Todd Conner, being first duly sworn and says that he executed the foregoing as his free act and deed.

Notary Public SHARONS. MARSHALL OTARY PUBUO, STATE OF COUNTYOF MONROE IMYCOMMISSIONEVPF 14E0X ACTINe IN COUWtyopF M 144201 to NRC-11-0008 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Response to Request for Additional Information Regarding Fermi 2 Request for Approval of Revision to the Radiological Emergency Response Preparedness Plan to Change Staff Augmentation Times to NRC 11-0008 Page 1 Introduction Based on review of the RAIs, the proposed augmentation times provided in Reference 2 are being revised such that all Technical Support Center (TSC) and Operational Support Center (OSC) responders will be required to report within 60 minutes and all Emergency Operations Facility (EOF) responders will report within 90 minutes. These proposed changes are shown in to this letter, "Marked-Up" Emergency Plan Table B-l and Enclosure 3, "Clean copy" Emergency Plan Table B-I.

Additionally, Enclosures 2 and 3 include a clarification to the reporting location of the "RET Sampler or RP Technician" responders assigned to perform offsite surveys. As shown in the updated Table B-1, the first two responders are assigned to the OSC and the second two responders are assigned to the EOF.

The following table highlights the changes from the previous proposed changes included in Reference 2.

Task Locatio:n

Title:

Original Proposal Revised Proposal Offsite Surveys OSC RET Sampler or 2 at 60 minutes 2 at 60 minutes RP Technician (clarification only)

Offsite Surveys EOF RET Sampler or 2 at 90 minutes 2 at 90 minutes RP Technician (clarification only)

Onsite (out of OSC RET Sampler or 1 at 60 minutes 2 at 60 minutes plant) Surveys RP Technician 1 at 90 minutes In plant Surveys OSC RP Technician 1 at 60 minutes 2at 60 minutes 1 at 90 minutes Repair and OSC Damage Control 2 at 60 minutes 5 at 60 minutes Corrective Actions and Rescue Team 3 at 90 minutes Members Radiation OSC RP Technicians 2 at 60 minutes 4 at 60 minutes Protection 2 at 90 minutes to NRC 11-0008 Page 2 Response to Request for Additional Information Regarding Fermi 2 Request for Approval of Revision to the Radiological Emergency Response Preparedness Plan to Change Staff Augmentation Times:

RAI# 1:

The application letter states in part, "a copy of the application, with attachments, is being provided to the designated Michigan State Official."

Has this proposed change been discussed and coordinated with State and local response organizations?

What are the activation times of State and local response organizations' facilities and how does that relate to the requested change to extend the activation time of the Fermi EOF to 90 minutes?

If activation times of the State and local response organizations' facilities are less than the requested change to 90 minutes, how will the coordination with these organizations be performed?

Response

The proposed changes have been discussed and coordinated with State and local emergency response officials.

There is not a direct relationship between the State and local response organizations' activation times and the proposed change of the Fermi 2 EOF activation time to 90 minutes. Activation times for the State and local response organization facilities are not correlated to the declaration of event classifications. The timeframe for activation after a decision has been made to mobilize is not pre-designated. The expectation is that activation will occur as quickly as possible considering the activities that may be in progress and the actions that may be necessary to activate.

RAI # 2:

The application states in part, "will increase the staff augmentation times for Technical Support Center-related functions from 30 to 60 minutes and for Emergency Operations Facility-related functions from 60 to 90 minutes." The proposed Table B-1 includes OSC responders as 90 minute responders, specifically six RP Technicians, and three Damage Control and Rescue Team Members. What EOF-related functions do these OSC responders perform?

Response

There are no EOF-related functions performed by the OSC responders.

to NRC 11-0008 Page 3 As shown in the updated version of Table B-1 in Enclosures 2 and 3, all OSC responders are now proposed to be 60 minute responders.

RAI # 3:

The application states, "On-site, out of plant field teams and off-site field teams are typically used to verify the status of a potential release, but are not relied upon for timely indication.

Installed effluent radiation monitors and in-plant radiation monitors would be able to detect any radioactive release quickly and accurately." Additionally it states, "Although off-site survey data is available after the emergency response facilities are activated, monitoring of installed plant radiological instrumentation is sufficient for the first 90 minutes of an accident." Please provide justification for the increase in augmentation times for RP staff performing offsite and onsite (out of plant) surveys from 60 to 90 minutes with regard to the timely indication of a radiological release from an unmonitored release point.

Response

"RET Samplers or RP Technicians" assigned to the OSC for offsite and onsite (out of plant) surveys can perform these tasks until the EOF is activated at 90 minutes. The increase in the augmentation time for the EOF from 60 to 90 minutes does not significantly impact the capability to obtain timely indication of a radiological release from an unmonitored release point.

There are two "RET Sampler or RP Technician" responders to support offsite surveys assigned to the OSC which have a proposed augmentation time of 60 minutes. In addition, there are two "RET Sampler or RP Technician" 60 minute responders to support onsite (out of plant) surveys assigned to the OSC as shown in the updated Table B-1 in Enclosures 2 and 3.

These personnel and the two on-shift In-plant Survey RP Technicians, can also be used to identify areas where an unmonitored release occurs. These areas can be determined by reviewing the accident sequence and its correlation to installed in plant area radiation monitors.

This will support the identification of areas of potential release points should the primary or secondary containments fail.

RAI # 4:

Please provide the make-up of the on-shift Fire Brigade, and discuss whether they have any collateral Emergency Plan functions/responsibilities affected by proposed Plan change.

Response

As stated in Reference 2, Enclosure 1, Section 5.7, there are no proposed changes to this area.

to NRC 11-0008 Page 4 The on-shift Fire Brigade is assigned this task throughout the emergency.

The on-shift Fire Brigade consists of a minimum of five qualified personnel (e.g. one Fire Brigade Leader and four operators).

The on-shift Fire Brigade has no collateral Emergency Plan functions/responsibilities.

RAI # 5:

The current Fermi Table B-l has the six RP Technicians, and three Damage Control and Rescue Team Members responding at 60 minutes with all other on-site 60 minute emergency response facilities responders. With the proposed changes in the staffing times for these responders, the OSC would only have approximately half of the personnel in these positions at 60 minutes while the TSC would be staffed. Please provide justification for the increase in augmentation times to 90 minutes for the OSC 60 minute responders, specifically the six RP Technicians, and three Damage Control and Rescue Team Members with the TSC staffed/activated at 60 minutes.

This justification should include any potential impacts to the ability of the OSC to support the TSC.

Response

As previously discussed, Detroit Edison is modifying the proposed change for all OSC responders to now have a 60 minute augmentation time. Therefore, justification for the increase in augmentation time from 60 to 90 minutes for OSC positions is no longer applicable. The proposed updated change eliminates the potential impact of a partially staffed OSC supporting a fully staffed TSC.

to NRC-11-0008 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Marked-Up Emergency Plan Table B-1 Affected Page:

RERP Plan Page B-3

RERP Plan Revision 38 Page B-3 TABLE B-1 STAFFING FOR FERMI 2 EMERGENCY RESPONSE ORGANIZATION Major Functional Area Major Tasks Locations Emergency Response On Alert (or Alert (or Organizational Title Shift hel.)-

-l$,gr---

+38

+69 60 m__in 90 min Plant Operations and Plant Operations and CR Control Room 1

Assessment of Operational Assessment, Accident Supervisor Aspects Mitigation, Corrective Actions, Damage Assessment CR Nuclear Supervising 3

Operator CR Non-Licensed Operator 5

Emergency Direction and CR Emergency Director 1

Control TSC Emergency Director Notification/

Notify ERO, State, Local and CR Communicator I*

Communication Federal Authorities, Maintain Communications TSC Communicator EOF Communicator 2

Radiological Accident Emergency Officer EOF Emergency Officer 1

Assessment and Support of Operational Accident Offsite Dose Assessment CR/OSC Chemistry Technician 1*

Assessment TSC Radiation Protection 1

Advisor EOF Radiation Protection Coordinator Offsite Surveys OSCBQF RET Sampler or RP 2

2 Technician EOF RET Sampler or RP 2

Technician I

l--l Onsite (out of plant) Surveys OSC RET Sampler or RP 1-2 I I 4 Technician In plant Surveys OSC RP Technicians 2

4-12 4-Chemistry/Radiochemistry OSC Chemistry Technician 1

Plant System Technical Support CR Shift Technical Advisor 1

Engineering, Repair and Corrective Actions TSC Technical Engineer or 1

4-Nuclear Safety Advisor TSC Support Engineer 1

4-OSC OSC Coordinator 1

Repair and Corrective Actions OSC Damage Control and 2

2-15 Rescue Team Members Protective Actions Radiation Protection:

OSC RP Technicians 2*

2-4 2

(In Plant)

1. Access Control

2. HP coverage for repair, corrective actions, search and rescue, first-aid and fire-fighting

3. Personnel monitoring

4. Dosimetry Fire Fighting

____O OSC Fire Brigade UFSAR Rescue Operations and OSC Damage Control and 2*

First Aid Rescue Teams Site Access Control and Security and Personnel Per Security Nuclear Security Force Per Personnel Accountability Accountability Plan Security Planit Total 16 12-21 6

• May be provided by shift personnel assigned other functions and not included in the total.

to NRC-11-0008 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Clean Copy Emergency Plan Table B-l Affected Page:

RERP Plan Page B-3

RERP Plan Revision 38 Page B-3 TABLE B-1 STAFFING FOR FERMI 2 EMERGENCY RESPONSE ORGANIZATION Major Functional Area Major Tasks Locations Emergency Response On Alert (or Alert (or Organizational Title Shift higher) higher) 60 min 90 min Plant Operations and Plant Operations and CR Control Room 1

Assessment of Operational Assessment, Accident Supervisor Aspects Mitigation, Corrective Actions, Damage Assessment CR Nuclear Supervising 3

Operator CR Non-Licensed Operator 5

Emergency Direction and CR Emergency Director 1

Control TSC Emergency Director 1

Notification/

Notify ERO, State, Local and CR Communicator 1*

Communication Federal Authorities, Maintain Communications TSC Communicator 1

EOF Communicator 2

Radiological Accident Emergency Officer EOF Emergency Officer Assessment and Support of Operational Accident Offsite Dose Assessment CR/OSC Chemistry Technician 1*

Assessment TSC Radiation Protection 1

Advisor EOF Radiation Protection Coordinator Offsite Surveys OSC RET Sampler or RP 2

Technician EOF RET Sampler or RP 2

Technician Onsite (out of plant) Surveys OSC RET Sampler or RP 2

Technician In plant Surveys OSC RP Technicians 2

2 Chemistry/Radiochemistry OSC Chemistry Technician I

Plant System Technical Support CR Shift Technical Advisor I

Engineering, Repair and Corrective Actions TSC Technical Engineer or 1

Nuclear Safety Advisor TSC Support Engineer OSC OSC Coordinator Repair and Corrective Actions OSC Damage Control and 2

5 Rescue Team Members Protective Actions Radiation Protection:

OSC RP Technicians 2*

4 (In Plant)

1. Access Control

2. HP coverage for repair, corrective actions, search and rescue, first-aid and fire-fighting

3. Personnel monitoring

4. Dosimetry Fire Fighting OSC Fire Brigade UFSAR Rescue Operations and OSC Damage Control and 2*

First Aid Rescue Teams Site Access Control and Security and Personnel Per Security Nuclear Security Force Per Personnel Accountability Accountability Plan Security Plan Total 16 21 6

• May be provided by shift personnel assigned other functions and not included in the total.