ML17313A779
| ML17313A779 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 02/05/1999 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17313A777 | List: |
| References | |
| NUDOCS 9902110314 | |
| Download: ML17313A779 (10) | |
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~O UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATIONBYTHE OFFICE OF NUCLEAR REACTOR REGULATION RELATEDTO PROPOSED EMERGENCY PLAN STAFFING LEVELCHANGE ARIZONAPUBLIC SERVICE COMPANY PALO VERDE NUCLEAR GENERATING STATION UNITS 1 2 AND 3 DOCKET NOS. STN 50-528 STN 50-529 AND STN 50-530
1.0 INTRODUCTION
By letter dated September 8, 1998, Arizona Public Service Company (APS or the licensee) requested a review and approval of changes to minimum emergency staffing levels for the Emergency Plan for its Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2 and 3. The Emergency Plan changes were submitted for NRC staff review and approval as required by 10 CFR 50.54(q) and 10 CFR 50.4.
2.0 BACKGROUND
On November 16, 1993, APS submitted proposed Revision 13 to the PVNGS Emergency Plan, requesting NRC approval in accordance with 10 CFR 50.54(q).
Revision 13 moved the 30 minute responders on-shift and reduced the number of off-site monitoring teams from two to one. APS committed to place 10 radiological responders on-shift. The staff approved Revision 13 on February 25, 1994, after concluding that the on-shift staffing levels exceeded the staffing guidance in Table B-1 of NUREG-0654/FEMA-REP-1. The staff also considered in its decision the remote location of the site, and also that it is a three unit site. Part of the basis for NRC approval was a commitment from APS to add two drivers (non-radiation protection technicians) to Table 4.2Q of the PVNGS Emergency Plan (now Table 1) which was counted as two of the four positions needed to perform off-site surveys.
3.0 DISCUSSION The pertinent sections of the applicable regulations and guidance on emergency response staffing requirements are discussed below.
10CFR50.47 b 2 On-shift facilitylicensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initialfacilityaccident response in key functional area is maintained at all times, timely augmentation of response capabilities is available and interfaces among various on-site response activities and offsite support and response activities are specified.
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)i 10 CFR 50 A endix IV "Content of Emer enc Plans" The applicant's emergency plans shall contain, but not necessarily be limited to, information needed to demonstrate compliance with the elements set forth below, i.e., organization for coping with radiation emergencies, assessment actions, activation of emergency organization, notification procedures, emergency facilities and equipment, training, maintaining emergency preparedness, and recovery.
In addition, the emergency response plans submitted by an applicant for a nuclear power reactor operating license shall contain information needed to demonstrate compliance with the standards described in 50.47(b), and they willbe evaluated against those standards.
10CFR50 A endixE IV.A "Or anization".
The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an
.emergency.
Re ulato Guide 1.101 "Emer enc Plannin and Pre aredness for Nuclear Power Reactors" Section C "Re ulato Position" The criteria and recommendations contained in NUREG 0654/FEMA-REP-1, Revision 1 are considered by the NRC staff to be acceptable methods for complying with the standards in 10 CFR 50.47 that must be met in onsite and offsite emergency response.
NUREG-0654/FEMA-REP-1 Rev.
1 Criterion B "Onsite Emer enc Or anization" Item 5 Each licensee shall specify the positions or title and major tasks to be performed by the persons assigned to the functional areas of emergency activity. For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table B-1 entitled "Minimum Staffing Requirements for Nuclear Power Plant Emergencies".
The minimum on-shift staffing levels shall be as indicated in Table B-1. The licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency.
This capability shall be as indicted in Table B-1.
NUREG-0737 Su lement No. 1 Clanfication of TMIAction Plan Re uirements" Table 2, "Minimum Staffing Requirements for NRC Licensees for Nuclear Power Plant Emergencies."
(Note: Table 2 of NUREG-0737 is the same information contained in Table B-1 of NUREG4654. While the requirements of Supplement 1 of NUREG-0737 were mandated to the industry by Generic Letter 82-33, the generic letter states that the staffing levels contained in Table 2 are only goais, and not strict requirements.)
4.0 EVALUATION APS currently uses an emergency. staffing scheme that is slightly modified from that provided in Table B-1 of NUREG-0654/FFEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants". The licensee should have the capability to augment their on-shift staff with additional personnel, as indicated in Table B-1 of NUREG-0654, within 30 to 60 minutes of the declaration of an emergency.
APS, because of the remote location of its Palo Verde site, committed to combining the 30 minute responders with the on shift personnel for a total of 10 on-shift radiological responders.
Table B-1 recommends a staffing level of 8 radiological responders for the combined on-shift and 30 minute augmentation positions.
Additional personnel are available to augment the on-shift staff within 60 to 120 minutes.
The licensee proposes to eliminate two on-shift radiological protection (RP) technicians positions and increase the number of RP technicians required to be available for 60 to 120 minute Emergency Plan staff augmentation by two. APS's overall proposal consists of six different staffing changes.
Each proposed change is described and evaluated separately below.
Pro osed Staffin Cha'n e
APS proposes to redefine the role of the radiation protection monitor (RPM) position exclusively for off-site dose assessment.
Currently, the RPM and a radiation monitoring technician combine to fillthe required position for the off-site dose assessment function. NUREG-0654 indicates that this position have "Senior Health Physics (HP) expertise",
This change proposes reassigning this"Emergency Plan task solely to the Radiation Protection Department.
The on-shift RPM willfillthis position exctusively. The RPM is an ANSI 3.1 senior health physics technician who willbe fullyqualified to independently perform off-site dose assessment.
Staff Evaluation The dedication of a single individual with the required radiological expertise to perform off-site dose assessment does not degrade off-site response, therefore this specific proposal is acceptable.
ro osed Staffin Chan e
APS proposes to redefine the role of the current radiation monitoring technician positions required to perform the in-plant survey functions.
Staff Evaluation Currently, RP technicians fillboth required on-shift in-plant survey positions.
NUREG/CR-5569, HPPOS-238 states "Health Physics Technicians (HPTs) are allowed to perform (without supervision) specific tasks or job assignments (i.e., radiation surveys, swipe surveys, air samples and survey meter calibrations) ifthey meet the required prerequisites and complete the required task qualifications of their plant training program," Atask qualified technician is
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acceptable to perform in-plant surveys as described by HPPOS-238.
This proposal is acceptable.
Pro osed Staffin Chan e
APS proposes to assign the second in-plant survey function to either a second radiation monitoring technician, task qualified to perform in-plant surreys or a qualified RP technician.
The current staffing is for two RP technicians.
Staff Evaluation NUREG/CR-5569, HPPOS-238 states "Health Physics Technicians (HPTs) are allowed to perform (without supervision) specific tasks or job assignments (i.e., radiation surveys, swipe surveys, air samples and survey meter calibrations) ifthey meet the required prerequisites and complete the required task qualifications of their plant training program." A task qualified technician is acceptable to perform in-plant surveys as described by HPPOS-238.
This proposal is acceptable.
Pro osedStaffin Chan e
APS proposes to establish an Emergency Plan driver position to perform driving functions in support of off-site surveys.
Staff Evaluation NUREG-0654 requires that two off-site field monitoring teams be staffed.
Due to the remote location and open terrain surrounding the PVNGS, APS had received prior NRC approval to dispatch only one field monitoring team.
However, APS kept the two RP technicians positions that had been assigned to the off-site survey teams.
In this submittal, APS proposes to eliminate one of the two RP technicians that had been assigned to the offsite team. An Emergency Plan driver position willbe established.
This change re-assigns one position from the RP Department and clarifies that an off-site survey team willconsist of one RP technician and one Emergency Plan driver. NUREG-0654 does not require specific expertise for these positions and the guidance provided in NURGEG/CR-5569, HPPOS 238 states that only the survey team leader needs to possess Health Physics experience.
This proposal to staff the off-site monitoring team with a qualiTied RP technician and an Emergency Plan driver is acceptable.
Pro osed Staffin Chan e
Reassign the on-site (out-of-plant) survey position to a task-qualified individual outside the RP organization, that is on-shift but does not currently have Emergency Plan responsibilities.
Staff Evaluation NUREG-0654 requires one on-site, (outcf-plant) survey team be staffed.
NUREG-0654 does not require specific expertise for this position. NUREG/CR-5569, HPPOS-238 states "Health Physics Technicians (HPTs) are allowed to perform (without supervision) specific tasks or job
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assignments (i.e., radiation surveys, swipe surveys, air samples and survey meter calibrations) ifthey meet the required prerequisites and complete the required task qualifications of their plant training program." Atask qualified technician is acceptable to perform on-site, out-of-plant surveys as described by HPPOS-238.
This position would be re-assigned from the RP Department to a RP task-qualified person from another site organization.
This proposal is acceptable.
Pro osed Staffin Chan e
APS proposes to reassign the remaining two RP technician positions, which are over-complement, from on-shift positions to 60 to 120 minute augmentation positions. This increases the total 60 to 120 minute augmentation positions from four to six RP technicians.
Staff Evaluation
This change will reduce by two the number of RP related positions required to be on-shift at all times for Emergency Plan purposes and willincrease by two the number of RP technicians required to be available for staffing argumentation within the 60 to 120 minute time commitment. The overall number of RP related positions required to be available to support emergencies is unchanged.
APS, due to its remote location, eliminated the 30 minute response requirement by putting those personnel on-shift.. Table B-1 of NUREG-0654 suggests a total of 8 radiological positions for combined on-shift and 30 minute response.
With the re-arrangement of staffing, APS willhave the indicated number of personnel on-shift. Removing the two RP technicians from on-shift to augmented positions, and having task qualified personnel who are already on-shift and not part of the Emergency Plan organization fillthose slots, does not decrease the effectiveness of the PVNGS emergency response effort.
Additionally, as a three unit site, the on-shift staffing exceeds the on-shift and 30 minute staffing requirements set forth in Table B-1 at all times. Therefore, this proposal is acceptable.
5.0 CONCLUSION
The revision to the Emergency Plan would result in two less radiation protection positions immediately available during emergencies.
PVNGS is presently staffed with 10 on-shift radiological response positions. The staffing guidance in Table B-1 of NUREG-0654/FEMA-REP-1 has a total of 8 on-shift/30 minute radiological responders.
The two radiation protection positions slated for removal from the on-shift response would be placed on the augmented staffing response, so that the total number of radiological responders available for emergencies would not change.
Because PVNGS is a multi-unit site, the on-shift staffing exceeds the on-shift and 30 minute staffing recommendations ofTable B-1 at all times. Therefore, the staff concludes that the proposed staffing changes are acceptable.
Principal Contributor: P. Milligan, PERB/NRR Date:
February 5, 1999
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