ML17310B094
| ML17310B094 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 02/25/1994 |
| From: | Good G NRC Office of Inspection & Enforcement (IE Region V) |
| To: | Pate R NRC Office of Inspection & Enforcement (IE Region V) |
| References | |
| NUDOCS 9403150147 | |
| Download: ML17310B094 (14) | |
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UNITED STATES NUCLEAR REGULATORYCOMMISSION REGION V 1450 MARIALANE WALNUTCREEK, CAUFORNIA94596-5368 FEB 3 5 1994 MEMORANDUM FOR:
THROUGH:
FROM:
SUBJECT:
EP File 2.3.1 Robert J.
- Pate, Chief Safeguards, Emergency Preparedness, and Non-Power Reactor Branch Gail H.
Good Emergency Preparedness Analyst PROPOSED REVISION 13 TO THE PALO VERDE NUCLEAR GENERATING STATION (PVNGS)
EMERGENCY PLAN Back round By letter dated November 16, 1993, Arizona Public Service Company (APS) submitted proposed Revision 13 to the PVNGS Emergency Plan.
APS requested prior approval of Revision 13 in accordance with 10 CFR 50.54(q).
The proposed revision changed the reporting times for certain emergency response personnel from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 1-2 hours.
APS's dt,scription and justification for the proposed changes are attached to this memorandum.
Results Proposed Table 4.2-4, "Minimum Staffing Requirements for PVNGS for Nuclear Power Plant Emergencies, was compared against NUREG-0654, Table B-1.
Table B-1 identifies 24 positions which are required to be filled within 30 minutes.
Proposed Revision 13, Table 4.2-4, identifies 34 onshift positions, 10 positions over the Table 8-1 30-minute minimum.
Task coverage appeared adequate.
Table 8-1 identifies 36 positions which are required to be filled within 60 minutes (includes the 30-minute minimum).
Table 4.2-4 identifies 7
positions (in addition to the 34 onshift positions) which would be filled within 1-2 hours, bringing the minimum level to 41.
On February 17,
- 1994, I contacted Joe Napier to obtain additional clarification on some of the proposed changes.
The following issues were discussed:
1.
The position with the responsibility to perform core/thermal hydraulics was not clearly identified.
Proposed Section 4.2,1.13, Shift Technical Advisor STSC," stated that the STA would be relieved by the Reactor Analyst.
It did not mention that the STA had this responsibility until relieved.
There are three STAs onshift.
Proposed Revision 13 did not include a description of the Reactor Analyst's responsibilities, nor was this position identified in the current emergency plan (Revision lli. Also, Table 4.2-4 did g~cf not list a Reactor Analyst as one of the augmented (1-2 hour) positions.
0800',i 5 9403150147 940225 REG5 ADOCK 05000528 CF
~Res onse:
Joe said that Reactor Analyst was a new position title introduced in Revision 12.
The title used to be Reactor Engineer.
Revision 12 had not been submitted yet, but Joe said that it would be soon.
PVNGS planned to implement Revision 12 without prior approval in accordance with 10 CFR 50.54(q).
Joe faxed the applicable Revision 12 pages on February 22, 1994.
Regarding Table 4.2-4, Joe agreed to add a Reactor Analyst position which would be filled within 1-2 hours.
This response was considered acceptable.
2.
Although APS'ustification explained that "drivers" (non-RP Technicians) would be counted as two of the four positions needed to perform offsite surveys, these positions were not identified on Table 4.2-4.
~Res onse:
Joe agreed to add two drivers to the table.
This response was considered acceptable.
A replacement Table 4.2-4, with the agreed upon changes, was transmitted in a
The revised table brought the number of onshift positions to 36 and the total minimum augmented (1-2 hour) positions to 44.
Conclusion The proposed changes to the PVNGS Emergency Plan were consistent with NRC approved changes to the Davis Besse and South Texas Emergency Plans.
Copies of these changes were provided by Dan Barss, NRR/PEPB.
I discussed the proposed PVNGS Emergency Plan changes with Dan Barss on February 17, 1994.
I notified Dan of our intention to approve the proposed changes based on PEPB's approval of similar changes, PVNGS'nshift staffing and task coverage, and the remoteness of the plant.
Dan concurred with the Region's position.
o@naf signad by Gai1 H.
Good Emergency Preparedness Analyst Attachments:
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DES RIPTl N AND TIFlCATIO OF THE PROPOSED REVlSl N TO THE EMERGENCY PLAN Descrf tlon of he Pro osed Revision Proposed Revision 13 to the PVNGS Emergency Plan is being submitted to the NRC for review and approval pursuant to 10 CFR 50.54(q).
Emergency Plan Table 4.2-4 has been rewritten to better describe our staffing augmentation (See Enclosure 2, Emergency Plan Table 4.2-4).
The current version of Table 4.2-4 mimics staffing goals listed in NUREG-0654 Table B-1. This format does not identify to which emergency facilities these positions are expected to report, reflect the positions required to be staffed for a type of Emergency ClassiTication, nor reflect the response times for emergency personnel to report to the PVNGS site.
Revised Table 4.2-4 has two primary headings based on the emergency classification.
The first column heading is for positions activated during a Notification of Unusual Event (NUE). The second column heading is for positions activated for all other higher emergency classifications.
The revised table is also subgrouped by Emergency Response Facility to clearly define which positions are expected to be staffed in each facility for the different emergency classifications and their corresponding activation time.
The revised Table 4.2-4 also contains new activation times for emergency personnel to report to their assigned emergency facility in the event of an emergency at PVNGS.
Since APS has three operating units, our onshift staffing exceeds the onshift and 30 minute staffing requirements set forth in NUREG-0654 Table B-1 at all times.
Conversely, the remoteness of the PVNGS makes off hours staffing augmentation in less than an hour difficultto achieve.
Therefore, the proposed changes have essentially two response times:
immediate - For the Control Room, Satellite Technical Support Center (STSC), and most Operations Support Center functions, these positions are staffed with onshift 1 of9
personnel from the affected or unaffected unit. These positions meet or exceed the goals'set forth in NUREG-0654 Table 8-1 for onshift and thirty minute staffing as follows:
Ten people are required to be present within thirty minutes of activation, but PVNGS staffs these positions immediately (onshift positions); and Eight people are required to be present within sixty minutes of activation, but PVNGS staffs these positions immediately (onshift positions).
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Operations Facility, and remaining Operations Support Center functions, these positions would be staffed within sixty minutes with either onsite personnel during normal work hours or within one to two hours with offsite personnel during off normal-work hours.
Seven positions are required to be present within sixty minutes of activation by NUREG 0654, but PVNGS is requesting one to two hours to staff these positions during off normal hours.
These seven positions are:
Technical Su ort Electrical (in Technical Support Center (TSC)), and Technical Su ort Mechanical (in TSC).
Electrical and mechanical technical support will be provided by the onshift STAs as needed until these positions are staffed by oncoming personnel.
2.
Emer en 0 erations Director in Emergency Operations Facility (EOF).
This position will be staffed by the Emergency Coordinator in the STSC until relieved by oncoming personnel.
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3.
Two Offsite Notification ommunicators (Government Liaison Engineer and
= Technical Analysis Supervisor in EOF). These positions vnil be staffed by both Communicators in the STSC until relieved by oncoming personnel.
4.
Two Radiolo ical Protection RP Technicians.
These positions will be staffed by existing onshift Operations Support Center RP technicians until supplemented by oncoming personnel.
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Justification f r the Pro osed Revision Emergency Plan Table 4,24 Revision 13 contains these new activation times which are similar to Revision 16 of the Davis-Besse plant's Emergency Plan.
The Davis-Besse activation times, which are approved by the NRC, are listed as '1-2 hours" for certain EOF and TSC personnel which includes the statement that "all time requirements are based on optimum response conditions." APS requests similar relief from NUREG-0654 based on the justification for each position as follows:
Technical Su ort Electrical and Technical Su ort Mechanical are positions required in the TSC which will be staffed by oncoming personnel.
In the event that electrical or mechanical technical support is necessary, one or more of the STAs in the STSC will provide the technical support or contact the appropriate engineering personnel as directed by the Emergency Coordinator.
The STAs are qualified to provide technical guidance in both electrical and mechanical engineering.
The training program for the STAs, which is approved and INPO accredited, requires educational certification or demonstra'.ed competency in these engineering disciplines through examination.
The STAs routinely perform an Operation/Engineering interface function by contacting engineering personnel during. normal and off normal work hours to resolve technical concerns such as operability of safety related components.
The three STA positions are staffed by the STA onshift and from the two unaffected units.
Since the onshift STAs at PVNGS are already onsite and familiar with plant operations and equipment concerns, APS has concluded that the STA can provide the necessary technical support until this position is staffed by offsite personnel.
2.
Emer en 0 erations Director (in EOF) will be staffed by the Emergency Coordinator in the STSC until relieved by oncoming perscnnel.
The Emergency Coordinator in the STSC is one of the unaffected unit's Shift Supervisors.
This individual is fully qualiTied to perform the functions necessary until relieved.
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Similar to the STA discussed above, the Shift Supervisor is also onsite and would be familiar with plant conditions.
Two Offsite Notification Communicators (Government Liaison Engineer and Technical Analysis Supervisor in EOF) will be staffed by both communicators in the STSC until relieved by oncoming personnel.
The two communicators in the STSC can provide the offsite notifications, changes in emergency classification, continuous communications, and plant status updates with offsite agencies.
However, the activation of the Emergency Response Data System, within one hour after declaring an Alert, Site Area Emergency, or General Emergency, will lessen the need for continuous status information to be provided.
Two RP Technicians (in the Operations Support Center (OSC)) will be staffed by existing onshift OSC RP technicians until relieved by oncoming personnel.
APS has reviewed the duties of the RP technician positions specified in NUREG-0654 and the results of emergency planning drills and actual plant
- events, APS has determined that the personnel are being effectively utilized such that the required activities are being performed in a timely manner.
Based on these drills and actual events, APS has evaluated each of the RP technician positions specified in NUREG-0654 and concluded that the available onshift staff can accomplish the required duties as described in 8e following table, "RP Technician Staffing Duties." This table is a guideline to aid in understanding how these positions might be staffed.
The actual number of RP technicians performing any given function may vary depending on the circumstances of the event and the priorities set by the Emergency Coordinato. or Radiological Protection Monitor.
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RP TECHNICIAN STAFFING DUTIES NUREG-0654 Positions:
PVNGS Staffin:
Offsrte Dose Assessment 8 lnplant Radiological Assessment, Senior HP Expertise (one position)
This position is immediately (i.e., onshift from either the affected or unaffected unit) staffed by the onshift Radiation Monitoring System/Chemistry Technician (RMSCT) and the RP Monitor.
RMSCT (Offsite dose assessment)-
The affected unit Radiological Monitoring System (RMS) Technician performs dose calculations and interprets and provides RMS airborne and dose rate information for inplant use.
The RP Monitor is the affected unit's'nshift senior RP Technician (1
position) who functions as the RPM.
These functions include the Radiological Protection Coordinator (RPC}/Radiological Assessment Coordinator (RAC) functions until the TSC and EOF are activated.
The RPM is the Senior HP expert in charge of inplant/offsite activity. The RPM is based in the STSC and also performs the habitability survey functions in that 6of9
E position.
This activity in conjunction with assisting the RMSCT meets one of the recommended "RP Technician (Protective Actions)" for the sixty minute response.
Off-Site Surveys (four positions-NUREG-0654 does not mandate RP Technicians)
The two RP Technicians and the two "Drivers (Offsite Surveys)" are staffed immediately.
However, the physical size of the PVNGS site, coupled with the remote location does not require sending out two Radiological Field Assessment Teams (RFAT) immediately.
From lessons learned during the recent Alert for the Unit 2 Steam Generator Tube Rupture, a single RFAT Team composed of an RP Technician and a driver are able to adequately lo~wte and track a plume during the immediate to one to two hour time frame. The plume will have to cover a considerable distance prior to reaching significant population densities.
The open terrain prior to populated areas allows easy mobility for the RFAT Team for tracking and sampling.
Radio communication is excellent over this terrain.
Therefore, the second RP Technician may be utilized elsewhere depending on the specific event.
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On'site '(Out-of-Plant) (two positions)
One position can be staffed immediately with an RP Technician.
This is not a full time activity. One RP Technician would generally suffice.
NUREG-0654 specifies this position to be staffed within thirty minutes.
As noted above, this position is staffed immediately as opposed to the thirty minutes stated in NUREG-0654 which ameliorates the delay of the additional position specified at sixty minutes.
In-Plant Surveys (three positions)
These positions are immediately staffed with three RP Technicians.
These activities are not expected to require three full time RP Technicians.
PVNGS has the improved post TMI shielding, Post Accident Sampling System (PASS)
- systems, RMS systems, etc. to minimize dose within the plant.
APS anticipates that in-plant survey requirements during the initial one to two hours will require no more lhan one full time RP Technician.
This would permit assistance of other RP functions such as onsite surveys or protective actions.
As noted in NUREG-0654, the first two positions for onshift "protective action" staffing "may be provided by shift personnel assigned other functions."
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Protective Actions - Access Control, RP
- Coverage, Dosimetry, etc.
(six positions)
These positions are staffed immediately by the three RP Technicians, the RP Monitor (Protective Actions), and two RP Technicians performing inplant surveys.
As noted above, the RP Monitor in conjunction with the RMSCT perform the offsite dose assessment.
The two RP Technicians performing inplant surveys concurrently perform the function of protective actions.
As noted above and in NUREG-0654, the first two positions for onshift "protective action" staffing "may be provided by shift personnel assigned other functions."
After reviewing the NUREG-0654 staffing requirements, APS has concluded that the required tasks can be performed with proposed staffing specified in Table 4.2-4 as discussed above.
The most compelling fact that offsets the delay in augmenting the two RP Technicians at sixty minutes is that the current staff already on site greatly exceeds both the onshift and thirty minute augmentation goals. In the first thirty minutes, seven additional RP Technicians are onsite above the minimum staffing requirements (not including either driver for the Radiological Field Assessment Team).
ln the following thirty minutes, the onsite staffing exceeds the minimum requirements by two. This represents approximately four and a half additional manhours to offset the requested change which would allow an additional hour for two RP technicians to respond.
The onsite RP Technicians are also already aware of plant conditions and can quickly react to control the radiological conditions.
Less resources are expended informing them of plant conditions, actions being taken, and actions to be taken.
Finally, the full complement of additional RP Technicians will be achieved within an additional hour.
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