ML17179A912
| ML17179A912 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle |
| Issue date: | 05/19/1993 |
| From: | John Hickman Office of Nuclear Reactor Regulation |
| To: | Farrar D COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 9306020339 | |
| Download: ML17179A912 (5) | |
Text
Docket Nos. STN 50-456, STN 50-457 STN 50-454, STN 50-455
__,,-50-237,~-50-249' "-50-373
/"50-374,v-50-254, 50-265 ana 50-295, 50-304 May 19, 1993 e DISTRIBUTION:
,_--_po_Gkef File~
J. Roe J. Dyer J. Hickman J. Stang C. Patel OGC NRC & Local PDRs J. Zwolinski C. Moore(6)
R. Assa OFC NAME DATE Mr. D. L. Farrar Manager, Nuclear Regulatory Services Commonwealth Edison Company Executive Towers West III, Suite 500 1400 OPUS Place Downers Grove, Illinois 60515
Dear Mr. Farrar:
B. Clayton RI II J. O'Brien, 9Hl5 R. Stransky C. Shiraki ACRS(lO)
PD I II -2 r j f ( 6)
SUBJECT:
REQUESI FOR ADDITIONAL INFORMATION RELATED TO THE PROPOSED GSEP REVISION INCORPORATING THE CORPORATE EOF AS AN INTERIM EOF (TAC NOS. M84864 THROUGH M84875)
By letter dated March 31, 1993, to A. Bert Davis, you submitted a revision to your Generating Stations Emergency Plan (GSEP) which:
(1) changed the designated location for the Zion Station backup emergency operations facil iLy (EOF) from the Corporate Command Center in Chicago to the Corporate Emergency Operations Facility (CEOF) located in Downers Grove, and (2) proposed the use of the CEOF as an interim EOF for all of your nuclear sites. The staff of the Emergency Preparedness Branch of NRR, in conjunction with the Region III DRSS staff, has reviewed your submittal and concluded that additional information is needed to determine whether the revision resolves the NRC concerns with the staffing of the CECo nearsite EOFs.
The details of the request for additional information are enclosed.
The staff's evaluation of your request to relocate the backup EOF for the Zion Station is ongoing and is not addressed in the enclosure.
Tlte reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.
Should you have any questions or comments, please contact me at (301) 504-3017.
9306020339 930519 PDR ADOCK 05000237 P
Enclosure:
Request for Additional Information cc w/enclosure:
See next page
~~10G47 I. D I-2
/JHICKMAN
- $'/17/93 Sincerely, Original signed by:
John B. Hickman, Project Manager Project Directorate III-2 Division of Reactor Projects - III/IV/V Office of Nuclear Reactor Regulation
/D:PDIII-2 iJ'l.Y~)
- ?iif\\//93 V!/
""'r Mr. D. L. Farrar cc:
Mr. William P. Poirier Westinghouse Electric Corporation Energy Systems Business Unit Post Office Box 355, Bay 236 West Pittsburgh, Pennsylvania 15230 Joseph Gallo, Esquire Hopkins and Sutter 888 16th Street, N.W., Suite 700 Washington, D.C.
20006 Regional Administrator U. S. NRC, Region III 799 Roosevelt Road, Bldg. #4 Glen Ellyn, Illinois 60137 Ms. Bridget Little Rorem Appleseed Coordinator 117 North Linden Street Essex, Illinois 60935 Mr. Edward R. Crass Nuclear Safeguards and Licensing Division Sargent & Lundy Engineers 55 East Monroe Street Chicago, Illinois 60603 U. S. Nuclear Regulatory Commission Resident Inspectors Office Rural Route #1, Box 79 Braceville, Illinois 60407 Mr. Ron Stephens, Director Illinois Emergency Services and Disaster Agency 110 East Adams Street Springfield, Illinois 62706 Robert Neumann Office of Public Counsel State of Illinois Center 100 W. Randolph, Suite 11-300 Chicago, Illinois 60601 EIS Review Coordinator Environmental Protection Agency Region V 230 S. Dearborn Street Chicago, Illinois 60604 Attorney General 500 South 2nd Street Springfield, Illinois 62701 Common~lth Edison Company U. S. Nuclear Regulatory Commission Byron Resident Inspectors Office 4448 North German Church Road Byron, Illinois 61010 Ms. Lorraine Creek Rt. 1, Box 182 Manteno, Illinois 60950 Mrs. Phillip B. Johnson 1907 Stratford Lane
- Rockford, Illinois 61107 Douglass Cassel, Esquire 17 East Monroe Street, Suite 212 Chicago, Illinois 60603 U. S. Nuclear Regulatory Commission Resident Inspectors Office 105 Shiloh Blvd.
Zion, Illinois 60099 George L. Edgar Newman & Holtzinger, P.C.
1615 L Street, N.W.
Washington, D.C.
20036 Commonwealth Edison Company Byron Station Manager 4450 North German Church Road Byron, Illinois 61010 Illinois Dept. of Nuclear Safety Office of Nuclear Facility Safety 1035 Outer Park Drive Springfield, Illinois 62704 Commonwealth Edison Company Braidwood Station Manager Rt. 1, Box 84 Braceville, Illinois 60407 Chairman, Ogle County Board Post Office Box 357 Oregon, Illinois 61061 Chairman Will County Board of Supervisors Will County Board Courthouse Joliet, Illinois 60434
'(.....
Michael I. Miller, Esquire Sidley and Austin One First National Plaza Chicago, Illinois 60690 Mr. C. Schroeder Plant Manager Dresden Nuclear Power Station 6500 North Dresden Road Morris, Illinois 60450-9765
- U. S. Nuclear Regulatory Commission Resident Inspectors Office Dresden Station 6500 North Dresden Road Morris, Illinois 60450-9766 Chairman Board of Supervisors of Grundy County Grundy County Courthouse Morris, Illinois 60450 Phillip P. Steptoe, Esquire Sidley and Austin One First National Plaza Chicago, Illinois 60603 Assistant Attorney General 100 West Randolph Street Suite 12 Chicago, Illinois 60601 Resident Inspector/LaSalle, NPS U. S. Nuclear Regulatory Commission Rural Route No. 1 P. 0. Box 224 Marseilles, Illinois 61341 Chairman LaSalle County Board of Supervisors LaSalle*County Courthouse Ottawa, Illinois 61350 Dr. Cecil Lue-Hing Director of Research and Development Metropolitan Sanitary District of Greater Chicago 100 East Erie Street Chicago, Illinois 60611 Robert Cushing Chief, Public Utilities Division Illinois Attorney General's Office 100 West Randolph Street Chicago, Illinois 60601 Mr. G. Diederich LaSalle Station Manager LaSalle County Station Rural Route 1 P. 0. Box 220 Marseilles, Illinois 61341 Chairman Illinois Commerce Commission Leland Building 527 East Capitol Avenue Springfield, Illinois 62706 Mr. Stephen E. Shelton Vice President Iowa-Illinois Gas and Electric Company P. 0. Box 4350 Davenport, Iowa 52808 Mr. Richard Bax Station Manager Quad Cities Nuclear Power Station 22710 206th Avenue North Cordova, Illinois 61242 Resident Inspector U. S. Nuclear Regulatory Commission 22712 206th Avenue North Cordova, Illinois 61242 Chairman Rock Island County Board of Supervisors 1504 3rd Avenue Rock Island County Office Bldg.
Rock Island, Illinois 61201 Mayor of Zion Zion, Illinois 60099
ENCLOSURE REVIEW OF GSEP REVISION 93-01 The following additional information is requested to determine whether Commonwealth Edison Companys (CECo) plans for staffing of their nearsite EOFs meet the intent of 10 CFR 50.47 in regards to timely augmentation of the emergency response capability.
- 1.
Goal for Staffing of Nearsite EOF Attachm~nt A to the March 31, 1993, CECo letter, which transmitted Revision 93-01 to the GSEP, states, "Our approach involves staffing a corporate EOF within the one hour goal while a nearsite EOF is being staffed." In Revision 93-01 to the GSEP, the goal for staffing each of the nearsite EOFs is not stated.
State the goal for staffing the nearsite EOF for each of CECo's nuclear plant sites.
- 2.
Results of Staffing Augmentation Analysis Attachment A to the March 31, 1993, CECo letter indicates that efforts are being made to reduce the time for staffing of the nearsite EOFs, which include modeling of response times.
Provide supporting documentation (time studies and results of actual augmentation drills) which demonstrates that CECo's goal for staffing the nearsite EOFs and the CEOF for each nuclear plant site is reasonably attainable in an actual event.
In addition, provide a "to scale" map or diagram which indicates the location of each of CECo's nuclear plants, EOFs, and the CEOF.
- 3.
CEOF Staffing Goal Attachment A to the March 31, 1993, CECo letter states, "the CEOF can be.
expected to be staffed off hours within the one hour goal (55 to 75 minutes) after callout initiation." It is not clear how the time of "callout initiation" relates to the time the event is declared.
The goal for staff augmentation as provided in Supplement 1 to NUREG-0737 is based upon the time the event is declared.
Provide justification for having a staffing goal for the CEOF based upon the time of "callout initiation" instead of the time an event is declared.
Provide the relationship between the time of "callout initiation" and the time that an event is declared.
- 4.
Minimum Staffing GSEP Section 4.4, "Command and Control Criteria/Essential Activities/ERF Minimum Staffing/Nondelegable Responsibilities," states that the emergency response facility which is in command and control must perform the following essential ~ctivities:
Determine Emergency Action Level classification.
Determine Protective Action Recommendations (PARS).
Notify State, local, and Federal agencies as appropriate.
Maintain communications with their source of information.
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- =**=***-=***=-=*~c=-*=*
- ==:-===c~=~ The GSEP also specifies the minimum staffing level required for each of the emergency response facilities. It is not clear how the "minimum" staff will be able to perform all of the required functions.
For example, the minimum staff for the EOF includes the Manager of Emergency Operations, Protective Measures Director, Technical Support Manager, Advisor Support Manager, Environs Director, or other Director or Communicator.
Provide additional information which demonstrates that the minimum staff will be able to perform the required functions for each of the emergency response facilities, including the CEOF.
In particular, provide information regarding how the CEOF will communicate with Federal agencies, including the NRC.
- 5. Coordination with State and Local Governments The EOF is the interface for coordination of emergency response activities with the State and local governments during an emergency.
The response to an emergency by the State and local authorities could be affected by the time needed to staff the EOF and the use of the CEOF as an interim EOF.
The staff requests information regarding the position of the State or local governments concerning the CECo proposal.
Provide documentation regarding coordination with the affected State and local governments on the time goal for the staffing of the CECo nearsite EOFs and the use of the CEOF as an interim EOF until the nearsite EOFs are staffed.
- 6.
Significant Alert Classification CECo has introduced a new emergency class called the Significant Alert, which is defined as "those Alert Emergency Action Levels (EALs)"whi-c-hi-----
indicate a radiological release or directly affect safety system equipment and are designated in each station's GSEP Annex Section 5."
The staff is concerned whether the complexity added to the emergency response due to the introduction of another emergency class, i.e., the Significant Alert, with the sole purpose of activating the CEOF at a lower class than the Site Area Emergency, is warranted.
It is not clear whether State and local officials will be notified of a "Significant Alert" or "Alert" when the event meets the criteria for a "Significant Alert."
Provide additional justification for incorporating the "Significant Alert"
- classification which addresses these staff concerns.