ML17250A644
| ML17250A644 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 09/19/1980 |
| From: | White L ROCHESTER GAS & ELECTRIC CORP. |
| To: | Ramos S Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0696, RTR-NUREG-696 NUDOCS 8009300365 | |
| Download: ML17250A644 (28) | |
Text
AUTHOR AFF'ILI ATION Rochester Gas 8 Elect ri c Cor p.
RECIPIENT AFFILIATION Emergency Preparedness Progr am Office REGU 'RY INFORMATION DISTRIBUT 9
SYSTEM (RIDS)
"ACCESSION NBR:8009300365 DOC ~ DATE: 80/09/19 NOTARIZED:
NO FACIL:
AUTH'AME NHITE g L ~ D ~
REC IP ~ NAME RAMOSgS ~ LE DOCKET
SUBJECT:
Forwards comments on NUREG-0696~
"Functional Criteria fo.r Emergency
Response
Facilities' " Detailed criteria requite revision to provide mo,re effectiveness L cost-effective sys.
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'~Ãzrj rum ROCHESTER GAS AND ELECTRIC CORPORATION Lkal oa ~AaoI 1OAE
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89 EAST AVENUE, ROCHESTER, N.Y. I4649 LEON D. WHITE, JR.
YICf PRE SIDS NT TfEfRHDHf AREA CODE 7IS 546-2700 September 19, 1980 Office of Nuclear Reactor Regulation Emergency Preparedness Program Office Attention:
Mr. Steve L.
Ramos Mail Stop Phillips 242 Nuclear Regulatory Commission Washington, D.C.
20555 Sub ject:
Comments on NUREG-0696
Dear Mr. Ramos:
RG&E is pleased to offer comments on NUREG-0696, "Functional Criteria for Emergency Response Facilities."
Comments have been based both on the NUREG and on the clarifying information provided at the workship sponsored by the NRC in Chicago on August 20, 1980.
While the concepts set forth in NUREG-0696 will provide for improved emergency response capabilities, we believe that the detailed criteria require revision in order to provide more effective and more cost-effective systems.
Our detailed comments are provided in the attachment to this letter.
Very truly yours, L. D.
Whz e, Jr.
LDW:bk Attachment
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ATTACHMENT COMMENTS ON NUREG-0696 PAGE 2, PARAGRAPH 6
POS ITION During the early stages of emergency conditions, the TSC will perform the functions of the EOF.
COMMENT Initially, the on duty operating staff will have total responsibility for responding to emergency conditions.
Off site radiation survey assessment may not be provided in the TSC but rather in a nearby Survey Center.
The precise location of various functions may differ depending on particular facility conf iguration.
However, it is clear that plant management, must perform the functions of the EOF until the EOF is staffed.
PAGE 3, PARAGRAPH 1
POS ITION While the TSC function is centered on management of the plant in the mitigation of accidents, the EOF is designed to provide assistance in the decision making process to protect the public health and safety and to control radiological monitoring teams and facilities onsite and offsite.
COMMENT The RGRE presently controls the radiological monitoring teams from the Emergency Survey Center located in the basement of the near-site Information Center.
The emergency plan, SC-1, provides instructions to relocate this Emergency Survey Center to an alternate location in the event of high radiation in the area of the primary center.
We believe that a nearby facility is highly desirable, and in fact necessary, if prompt offsite assessment is to be provided.
During normal working hours, initial offsite surveys would be performed by plant personnel.
To require these people to report to an EOF which is as much as 10 miles distant is not practical.
We agree, though, that the EOF should coordinate these offsite activities.
PAGE 3, SECTION 4
COMMENT A description of the NRC's emergency plan seems out of context in this section addressing the Nuclear Data Link.
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However additional details of the NRC's Emergency
Response
Plan are highly desirable.
This should include additional details of who, besides the Regional Director, will be dispatched to the plant under the four notification categories.
The chain of communications for the NRC should be clearly delineated.
From the brief description provided, it appears that NRC public announcements will be coming from several different locations.
We believe this will only lead to confusion.
PAGE 4, PARAGRAPH 2
PAGE 15, PARAGRAPH 2
COMMENT When comparing responsibility statements in these paragraphs it is not clear who has the responsibility of informing
- Federal, State, County and Local agencies of accident status.
PAGE 4, PARAGRAPH 2
POSIT 1ON However, in extreme cases, the NRC may direct the certain operations be performed at the nuclear facility.
COMMENT If the NRC takes direct action, it is our position that such a demand must be presented in writing and that the NRC bear full responsibility for any adverse consequences of such action.
PAGE 5~
PARAGRAPH 3
POSITION The
- SPDS, TSC, EOF and NDL design, development qualification and installation should be independently verified by qualified personnel other then the original designers and developers.
COMMENT The statement that the "SPDS,
- TSC, EOF and NDL design, development shall be independently verified by qualified personnel other than the original designers and developers" appears to require a depth of design review in excess of that required by ANSI N45.2.11.
If the intent was to ensure design review in accordance with N45.2.11, then so state.
As described in the NRC Regional meeting in Chicago, the NRC Staff is under the misconception that a design review satisfying ANSI N45.2.11 may be performed by a non-technical quality assurance person.
It is clear that design reviews must be
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performed by technical qualified people.
The level of design review for safety systems certainly should be adequate for these facilities and systems.
7.
PAGE 5, PARAGRAPH 5
POSITION Signals from sensors providing data for variables specified by R.G 1.97 shall be input directly into the data acquisitions processor(s) for the
These signals shall be transmitted, processed and displayed inde-pendently of any, equipment used for normal plant operations, such as the process computer.
COMMENT To make this requirement unconditional is not in keeping with good engineering practice.
It is possible for example, to upgrade the plant process computer through various hardware and/or software modifications to meet the intent of NUREG-0696.
It is the position of RG&E that use of the plant process computer is acceptable providing the intent of NREG-0696 is met.
8.
PAGE 5, PARAGRAPH 5
POSITION As the
- SPDS, TSC and EOF are important elements in a nuclear power plant's emergency response capability, Limiting Conditions for Operation in the plant Technical Specifications will be established to specify actions to be taken by the licensee when the
It shall be a reportable occurrence if any of these facilities are not operational for any period exceeding the unavailability goal.
, COMMENT It is not clear why the failure of one of the SPDS displays would constitute a reportable occurance since, this system is clearly only a possible operator aid (page 2 paragraph 3
and page 6 paragraph 2) and does not mitigate or alter the consequences of an accident.
- Further, the term "operational" is not clearly defined.
For example, if one of 5 CRT's in the TSC is not operational, does this constitute a reportable incidents Also, it is not clear that additional staffing would serve any useful function under these circumstances.
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PAGE 7, PARAGRAPH C.
POSITION The SPDS display shall be readable from the operating stations of the shift supervisor, control room senior reactor operator, shift technical advisor and at least one reactor operator.
COMMENT Reasonable control room configuration discourages normal visual contact of any one location in the control room from four different operating stations.
It is the position of the RG&E that visual contact by any two of these persons from their normal operating station is sufficient.
1 0.
PAGE 8, SECTION F ~
PARAGRAPH 1 POS ITION The total SPDS need not be Class 1
E or meet the single failure criterion.
The data acquisition system for the SPDS, consisting of sensors and signal conditioners, shall be designed and qualified to Class 1E standards.
Furthermore, the data acquisition system for those parameters of the SPDS which are identical to the parameters specified within R.G.
1.97 shall be designed and qualified to the criteria stated in R.G. 1.97.
The processing and display devices of the SPDS shall be of proven high quality and reliability.
The total system shall be designed to achieve an unavailability goal of.001 for the SPDS.
COMMENT By data acquisition system, it is assumed to include the
- sensors, electrical cabling, termination cabinets, analog input modules and power supplies, but not the analog to digital converters and multiplexing equipment, and that this equipment must meet Class 1E requirements.
Please confirm and clarify in final issue.
The unavailability goal of.001 for the SPDS should be in fact a goal.
It is doubtful that even with today's advanced technology and computer systems capability that this unavaila-bility factor can be obtained.
Please define unavailability.
If the SPDS display unit is inoperable at the Emergency Operations Facility, does this apply to the unavailability factor?
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PAGE 8, SECTION F, PARAGRAPH 3
POSITION Since the function of the SPDS is to aid in the detection and monitoring of transients and accidents, the SPDS shall be capable of functioning during and following events expected to occur during the life of the plant, including the Operating Basis Earthquake and other natural phenomena.
Emergency operating procedures shall specify the limitations of the SPDS.
COMMENT The only way to ensure this requirement is to qualify the equipment to IEEE-344-1974.
This standard, however, is really concerned with seismic qualification to the SSE and not the OBE.
If the system does not have to meet Class 1E requirements, why this qualification?
By imposition of this requirement, the NRC may be severely restricting the capability to provide useful information to the operator by restricting the equipment which may be used.
We believe this requirement, therefore, to be counter productive.
Staff comments at the Chicago Regional meeting indicated that certain suppliers had stated informally that they could meet this requirement for computer systems and that the Defense Department suppliers could meet this requirement.
Depending on the type of certification required and the type of qualification testing (seismic response spectrum testing versus a simple single shock test), previously supplied equipment may not be adequate.
1 2.
PAGE 9, PARAGRAPH 4
POSITION The TSC and EOF data system shall have interactive terminal and display capability. It may be desirable to provide interactive terminal and display capability between the plant emergency facilities and NRC headquarters to aid emergency management.
COMMENT It is not clear what the interactive display discussed in this paragraph is displaying.
Plant data will be provided to the TSC,
- EOF, and NRC as required elsewhere in NUREG 0696.
Does the NRC envision an additional
Apart from the technical rami-fications of such a computer system that this proposal may cause (other agencies may also request this capability) it appears only to add an additional level of confusion.
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1 3.
PAGE 9, PARAGRAPH 6
POSITION Limiting Condition for Operations in the plant Technical Specifications will specify actions to be taken by the licensee when the TSC is not operational.
It shall be a
reportable occurrence if the TSC is not operational for a period exceeding 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
The special occurrence report shall state compensatory
- measures, such as additional staffing, taken during the time the TSC is not operational.
COMMENT See comment 8.
1 4.
PAGE 11 g
PARAGRAPH 2
POSIT ION A predetermined number of licensee personnel with expertise in plant design and operation will be assigned to report to the TSC in accordance with licensee's emergency plan.
In some cases consultants designated by the licensee may be used to augment utility resources in the TSC.
From the above considerations, the TSC shall be sized for at least 25
- persons, including five NRC personnel.
As general guidance for designers, a typical TSC size is approximately 1875 square feet.
COMMENT The ratio of NRC (5) personnel to Utility and Consultant personnel (20) does not seem realistic especially since the functions required of the Utility are more numerous than that of the NRC.
Further, it is quite possible that due to the functional responsibilities of other agencies, they also may request space.
The composition of the NRC team should be described in NRC Emergency Plans.
It should be noted that. the TSC manager will have the authority to limit NRC presence to 5 people.
15.
PAGE 11, PARAGRAPH E POS ITION The TSC facility must be able to withstand the most adverse conditions reasonably expected during an accident.
While the TSC and its equipment need not meet Seismic Category I criteria, it shall be a well engineered structure expected to withstand earthquakes, and capable of withstanding high winds (other than tornadoes) and flood levels.
Winds and floods with a 100 year reocurrence frequency are acceptable as a design basis.
The TSC need not be qualified as an Engineered Safety Feature.
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COMMENT The imposition of these new requirements at this late date is counterproductive.
The NRC specified TSC requirements nearly a year ago with the requirement that the facility be completed by January 1, 1981.
In good faith, RGsE committed several million dollars to design and construct a facility with the 1979 requirements.
To now impose such ill-defined concepts as "expected to withstand earthquakes" and "winds and floods with a 100 year reocurrence frequency" is clearly uncalled for by any reasonable cost-benefit analysis.
TSC requirements stated in NUREG-0696 should be identical to previous requirements.
1 6.
PAGE 1 2, PARAGRAPH 5
POS ITION The TSC shall have designated telephones which NRC personnel in the TSC can use to communicate with the NRC personnel in the EOF and with outside locations.
COMMENT It is necessary that the NRC specify the number of telephones required and the basis for this determination.
- Further, depending on local telephone conditions, the potential number of dedicated lines may be limited.
1 7.
PAGE 13, PARAGRAPH 3
POSITION Signals from sensors providing data of variables specified in R.G.
1-.97 shall be input directly into the data acquisition processor( s) for the
- EOF, and NDL.
These signals shall not be transmitted through a plant process computer prior to input into the emergency facilities data processor(s)
The TSC data accuracy shall not be significantly less than the accuracy of the comparable main control room information.
COMMENT As described previously, to imply that the plant process computer signals can not be used for other data acquisition points associated with the accident, is unnecessarily restrictive if software security and unavailability goals are met.
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PAGE 15, PARAGRAPH 5
POSITION Limiting Conditions for Operation in the plant Technical Specif ications will specify actions to be taken by the licensee when the EOF is not operational.
It shall be a
reportable occurance if the EOF is not operational for a period exceeding 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
The special occurence report shall state compensatory
- measures, including additional staffing, taken during the time the EOF is not operational.
COMMENT See comment 8.
19.
PAGE 1 7, PARAGRAPH 1 POSITION The EOF shall be large enough to provide working space and facilities for the personnel assigned to the EOF at the maximum level of occupancy without crowding.
The size of the EOF shall be sufficient to provide room for all functional displays and to provide easy access to data displays, to plant records and historical data, and to communications equipment.
The EOF shall be sized for at least 35 persons including ten NRC personnel.
One separate office to accommodate at least three NRC personnel shall be provided in the EOF.
As general guidance to designers, a typical EOF size is approximately 2625 square feet, excluding space for briefings.
COMMENT The ratio of NRC personnel (10) to other responsible groups of personnel (25 personnel) is unrealistically large.
Consequently the recommended floor space requirements are unrealistic.
20.
PAGE 17, PARAGRAPH 2
POSITION A meeting room with space to accommodate at least 20 persons shall be available in close proximity to the EOF.
This meeting room need not meet the EOF structural or habitability requirements.
The meeting room may have facilities to conduct press briefings.
COMMENT It appears that a meeting room is a logical requirement for EOF personnel.
- However, a meeting room with facilities to conduct press briefings would seem to require a more expansive area than that used by 20 people in a meeting.
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PAGE 20, PARAGRAPH J POSITION Additional up-to-date records related to licensee,
- State, and local emergency response plans, radiological records, onsite personnel control, offsite population distribution, and evacuation planning must be readily available in the EOF.
COMMENT It is not. clear what is meant by radiological records.
If these are plant radiological records, which records and to what extent?
If they ary personnel radiological records, to what extent and what is 'the basis of this requirement?
If this requirement addresses personnel radiological records, the RG&E will take exception to maintaining these records current at the EOF.
2 2 ~
PAGE 2 1 g PARAGRAPH b POSITION The licensee shall provide the multiplexing, digitizing, unit conversion (using units as specified in Appendix A of NUREG/CR-1451), calibration and formatting, using a separate and independent data acquisition system for all R.G.
1.97 variables which is interfaced to properly condition and isolate transducer outputs.
This data acquisition system can also provide data to the TSC, SPDS and EOF systems.
COMMENT It is RGEE's position that the requirement to provide an interfacing unit for signal transmission to the NRC is not viable until such time that the NRC provides specifications for their portion of the system.
22.
PAGE 21, PARAGRAPH C-1 POSITION Each NDL parameter specified shall be sampled at a sampling rate of once per minute with a minimum of 12 bit resolution.
Each reading shall be time tagged with an absolute time tag of 1 second.
COMMENT This requirement seems to be unduly severe.
Chapter IV, page 67 of NUREG CR-1451 by Sandia states that there is no guarantee that the time tag accuracy of 1 second on data measurements will be met.
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23.
SECTION V COMMENT From Section V of NUREG-0 696 and the Sandia Report it is apparent that the NRC will supply each site with a terminal for the Nuclear Data Link.
What is not clear is the responsible organization for installation and maintenance of the phone line(s).
A clear delineation of responsibility is necessary.
24.
FIGURE 1
POSITION Block diagram of Figure 1.
COMMENT It should be emphasized in the text that this diagram represents discreet functions and their interrelationships.
Actual hardware configuration for a specific site would probably vary.
In terms of the text, "EOF processor" may be misleading; a more appropriate term could be EOF System.
2 5.
GENERAL NUREG-0 654 established the initial guidelines for. emergency center types, their functions and requirements.
Emphasis was placed on need for back up centers and need f'r an Emergency News Center.
RGaE pursued vigorously a plan to satisfy the guidelines as set forth by NUREG-0 654.
RG6E is presently engaged in the construction of a shielded, habitable Technical Support Center.
The construction of the building (5,000 square foot adjacent to the control room) is sixty percent complete.
An on-site operations center has been established.
A cost study and preliminary design was completed for an offsite Emergency Recovery Center.
Com-munications circuits were installed from the TSC to the Recovery Center completing an inter-emergency center com-munications network.
Preliminary cost analysis and design for an Emergency News Center and back-up Emergency Recovery Center was completed.
Negotiations for a back-up Emergency News Media Center are in progress.
Briefly, the RGSE off-site emergency plan to date included the following:
A.
An Emergency Survey Center located is in the basement of the on-site Information Center.
This center has been in operation for the last 10 years.
In the event of a plant evacuation situation, this center is activated by plant management.
Its function (described in detail in plant emergency procedure SC-1) is to oversee plant 10
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evacuation, dispatch and supervise radiological survey monitoring teams, collect and evaluate meteorological and radiological data, assess results and appraise Plant management, Utility management,
- Federal, State, and Local agencies of accident conditions.
In the event of unfavorable conditions, this center is backed up by an alternate Survey Center.
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An Emergency Recovery Center located on the ground level of the on-site Information Center.
The function of this center, is to provide Utility management a base of operations from which to evaluate and manage the overall effects and consequences of the accident on total Utility operation.
This center would provide outside agency management the same type of capability.
In the event of unfavorable conditions, this center is backed up by a alternate Emergency Recovery Center.
An Emergency News Media Center contemplated to be approximately 44 miles away from the plant in a direction opposite to the prevailing winds.
This center is intended to accommodate the RG&E Public Relations department personnel and an undetermined but large number of news media.
Provisions were being incorporated into the design that will permit this location to serve as a back-up to both the Recovery Center and Survey Center.
D.
A back up Emergency News Center.
In the event that the primary Emergency News Center is occupied by Emergency Survey Center and Emergency Recovery Center personnel it is conceivable that the news media would better be located at some other site.
The RG&E has made pre-liminary studies and contacts for the center location.
NUREG-0696 conspicuously avoids addressing back-up centers and an Emergency News Media Center while subtly fusing the Emergency Survey Center, as established by older plants, into the Emergency Operations Facility in combination with what was formerly called the Emergency Recovery Center.
By reading between the lines of the guide, there also seems to exist the possibility of a future requirement for locating an Emergency News Media Center in the same complex.
If this is the the case, the RG&E has great concern for continuing efforts and planning with the latest guidelines set forth by NUREG-0 696 for fear they may change yet again.
- Further, the abandonment of the existing Emergency Survey Center presents a major effort in addition to the apparent prodigious effort.
required to meet the remaining guidelines as they presently read.
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Another concern of the RGEE is schedule for implementation especially in the area of instrumentation.
NRC review and approval of conceptual design is scheduled for the first quarter 1981.
Hardware procurement can not begin until design has been approved.
With many utilities now required to implement the computerized data collection and display
- system, vendor's manufacturing capacity will be taxed.
The indicated 10 month procurement cycle is overly optimistic, even under present circumstances; the impact of NUREG-0696 will cause this cycle to approach 18-24 months.
Also disturbing was a comment by a member of the Staff at the Chicago Regional meeting that criteria set forth in NUREG 0696 were, in general, more severe than much of the Staff felt necessary because otherwise the utilities would not comment or the criteria would be "too easy".
If true, this is an abdication of Staff responsibility.
Criteria should be based on need, not on desire to look tough or get.
comment.
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