ML18051A605
| ML18051A605 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/15/1983 |
| From: | Toner K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 NUDOCS 8309230351 | |
| Download: ML18051A605 (24) | |
Text
.-'i consumers Power company General Offices:
1~45*west Parnall Road, Jackson, Ml 49201 * (517) 788-0550 September 15, 1983 Dennis M Crutchfield, Chief Operating Reactor Branch No 5 Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
SUPPLEMENT 1 TO NUREG-0737, MILESTONE ACTIVITY -
REPORT ON DEVIATIONS, EMERGENCY RESPONSE FACILITIES Consumers Power Company's integrated plan and schedule for completing the emergency response capabilities covered in Supplement 1 to NUREG-0737 was submitted April 14, 1983.
A milestone activity addressed in the integrated plan and schedule is to provide the NRC staff with an interim report of the Palisades Plant deviations from the NRC guidance provided for the Emergency Response Facilities initiative.
This submittal provides a final report. provides a detailed evaluation of the Palisades Plant Emergency Response Facilities against the guidelines of Supplement 1 to NUREG-0737.
There are seven attachments to Enclosure 1.
The report supports the following conclusions:
A.
The Technical Support Center (TSC) will satisfy the guidelines of Supplement 1 to NUREG-0737 upon completion of habitability modifica-tion work.
B.
The Operational Support Center currently satisfies the guidelines of Supplement 1 to NUREG-0737.
C.
The Emergency Operating Facility (EOF) and General Office Control Center (GOCC) currently satisfy the guidelines of Supplement 1 to NUREG-0737.
D.
Because the Critical Functions Monitoring System (CFMS) will of fer a diverse means of providing reliable data collection, storage, analysis, and display, Consumers Power Company considers it necessary to enhance the capabilities of the TSC, EOF, and GOCC by implementing a CFMS display terminal at each of these facilities.
~~
8309230351 830915 PDR ADOCK 05000255 F
PDR OC0983-0007AA-NL02
DMCrutchfield, Chief Palisades Plant SUPPLEMENT 1 TO NUREG-0737, MILESTONE ACTIVITY September 15, 1983 2
E.
Evidence of Consumers Power Company's intentions to continue to upgrade the emergency response capabilities of the Palisades Plant is provided in Enclosure 1.
As an example, work has been initiated on the development of a more sophisticated dose assessment capability to enhance the existing capability.
The commitments identified in Enclosure 2 are established to complete Consumers Power Company's response to the guidelines set forth in Supplement 1 to NUREG-0737 for the Emergency Response Facilities initiative.
Consumers Power Company will incorporate changes to the Emergency Response Facilities as the need arises due to the impact of the other initiatives identified in Supplement 1 to NUREG-0737.
Kerry A Toner Senior Licensing Engineer CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Enclosures OC0983-0007AA-NL02
OC0983-0007B-NL02 Consumers Power Company Palisades Plant 50-255 SUPPLEMENT 1 TO NUREG-0737 EMERGENCY RESPONSE FACILITIES REVIEW September, 1983 12 Pages
NUREG-0737 SUPPLEMENT 1 EMERGENCY RESPONSE FACILITY REVIEW TECHNICAL SUPPORT CENTER (TSC) 1.0 NRC POSITION The technical support center shall be located within the site protected area so as to facilitate necessary interaction with control room, OSC, EOF and other personnel involved with the emergency.
LICENSEE ACTION 1
Consumers Power Company has completed an expansion of the TSC to meet the criteria of NUREG-0696.
Work remains to be done on the HVAC system.
Refer to section 4.0 for details on HVAC system. Attachment 1 gives the location and floor plan of the expanded TSC.
The floor plan was submitted to NRC Region III for review prior to completion and NRC recommendations were incorporated.
This layout was tested during PALEX-83 and was demonstrated to be adequate.
As can be seen, the TSC is located immediately adjacent to the plant control room which allows for excellent interaction with the control room and all other emergency response facilities.
2.0 NRC POSITION The technical support center shall be sufficient to accommodate and support NRC and licensee predesignated personnel, equipment and documentation in the center.
LICENSEE ACTION The TSC contains 2200 square feet of floor space and as can be seen on Attachment 1, has been subdivided_into specific work areas suffi-cient to accommodate and support NRC and licensee predesignated personnel, equipment and documentation.
3.0 NRC POSITION The technical support center shall be structurally built in accor-dance with the Uniform Building Code.
LICENSEE POSITION The expanded TSC was structurally built in accordance with the Uniform Building Code and meets Seismic Category I criteria.
OC0983-0009B-NL02
4.0 NRC POSITION The technical support center shall be environmentally controlled to provide room air temperature, humidity and cleanliness appropriate for personnel and equipment.
LICENSEE ACTION The TSC's ventilation system is part of the control room's HVAC System and is being installed as part of the control room habita-bility modifications (See NUREG-0737 Item 111.D. 3.4 - Control Room Habitability Requirements).
NRC approval of the Control Room habit~
ability has been given per their April 29, 1983 letter, contingent upon completing the habitability modification work.
It is antici-pated that this work will be completed by the end of the current outage which began the middle of August, 1983.
5.0 NRC POSITION 2
The technical support center shall be provided with radiological protection and monitoring equipment necessary to *assure that radia-tion exposure to any person working in the TSC would not exceed 5 rem whole body, or its equivalent to any part of the body, for the duration of the accident.
LICENSEE ACTION As described in item 4 above, the TSC has been designed to have the same habitability as the control room under accident conditions.
One area monitor is located in the TSC immediately outside the control room.
Portable air sampling and survey equipment are available in the emergency kits stored in the TSC.
6,0 NRC POSITION TSC shall be provided with reliable voice and data communications with the control room and EOF and reliable voice communications with the OSC, NRC Operations Centers and state and local operations centers.
LICENSEE ACTION
-Attachment 2 contains a communication matrix that details all avail-able communication lines between the Consumers Power Company emer-gency response facilities, As can be seen from this Attachment, the TSC has the required communication links consisting of dedicated phones, radio communication, intercom system, intraplant phones, commercial phones, facsimile machines and a sound powered phone system linking the functional groups within the TSC and their con-tacts in the Control Room.
OC0983-0009B-NL02
7.0 NRC POSITION The technical support center shall be capable of reliable data collection, storage, analysis, display and.* communication sufficient to determine site and regional status, determine changes in status, forecast status and take appropriate actions.
The following vari-ables shall be available in the TSC:
(i) the variables in.the appropriate Table 1 or 2 of Regulatory Guide 1.97 (Rev. 2) that are essential for performance of TSC functions; and 3
(ii) the meteorological variables in Regulatory Guide 1.97 (Rev. 2) for site vicinity and National Weather Service data available by voice communication for the region in which the plant is
- located.
Principally those data must be available that would enable evaluating incident sequence, determining mitigating actions, evaluating damages and determining plant status during recovery operations.
LICENSEE ACTION Becaus.e the TSC is located immediately adjacent to the Control _Room and will have the same habitability as the Control Room, the TSC staff has direct access to all plant information displayed in the Control Room. gives the minimum set of information that is routinely tracked by the TSC staff.
The TSC Health Physics staff tracks the radiation monitor readings displayed in the Control Room separately.
If additional information is required, it can be obtained directly from the Control Room readouts.
The logging, trending and analysis of plant information and radiation data.in the TSC was observed by the NRC during the PALEX-83 emergency exercise.
No items of noncompliance, violat1ons or deviations were identified.
As such, the intent of item (i) above has been met.
OC0983-0009B-NL02
4 To enhance the access to, storage of, analysis and trending capabili-ties for the info~ation required in the TSC, the Critical Functions Monitoring System (CFMS) will support a display terminal in the TSC.
This terminal will provide.the TSC staff with color graphical displays and trending capability for plant system information and other appropriate variables.
It is anticipated that this capability will be implemented by the next Palisades emergency exercise in August, 1984 for those parameters currently available in the CFMS.
The parameters currently available on the CFMS and those that are proposed have been identified in the Supplement 1 to NUREG-07.37, Milestone Activity, Regulatory Guide 1.97 Interim Report of Devia-tions, submitted September 13, 1983.
Additional parameters may be added based on the recommendations of the Regulatory Guide 1.97 activity and/or on the Supplement 1 to NUREG-0737, Milestone Activity, Comparison of the Safety Parameter Display System Requirements and the CFMS.
Onsite meteorological data is provided to the TSC from the dedicated printer in the control room.
In addition, onsite meteorological data can also be provided to the TSC via remote interrogation to the onsite meteorological monitoring system.
Both current averages as well as historical averages of all meteorological parameters measured onsite are available to the TSC.
Regional National Weather Service data as well as meteorological forecasts are available to the TSC via remote interrogation to the Weather Services International computer system.
The display of meteorological information in the TSC was observed by the NRC during the PALEX-83 emergency exercise.
No items of noncom-pliance, violation or deviations were identified.
As such, the intent of item (ii) above has been met.
To enhance the reliability of the on-site meteorological data, a complete upgrade to the on-site meteorological monitoring system has been initiated.
This upgrade includes:
- 1.
Installation of a new computer system at the base of the tower.
The computer system is supported with a vendor maintenance agreement.
- 2.
Installation of optical isolation between the computer system and the data input lines and telephone modems.
This equipment is in addition to the previously installed surge protection equipment.
- 3.
Installation of two electrical grounding wells and tying them into the existing grounding mat below the meteorological tower.
OC0983-0009B-NL02
i I.
8.0 NRC POSITION The technical support center shall be provided with accurate, com-plete and current plant records (drawings, schematic diagrams, etc.)
essential for evaluation of the plant under accident conditions.
LICENSEE ACTION A complete set of plant records (drawings, schematic diagrams, procedures, etc.) is maintained in the TSC.
These records include:
0 Plant Operating Procedures 0 Emergency Operating Procedures
°FSAR 0 Site Emergency Plan (SEP) 0 Site Emergency Plan Implementing Procedures (SEPIP) 0 Plant Technical Specifications 0 GOCC/EOF Emergency Implementing Procedures 0 Emergency Off Normal Procedures 0 INPO Emergency Resources Manual 0 Public Affairs Nuclear Plant Emergency Public Information Policies and Procedures
°Federal, State and Local Emergency Procedures 0 Plant drawings and schematic diagrams 9.0 NRC POSITION 5
The technical support center shall be staffed by sufficient tech-nical, engineering, and senior designated licensee officials to provide needed support, and be fully operational within approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after activation.
LICENSEE ACTION gives the TSC organization and corresponding interfaces to the groups in the other emergency response facilities. It is the goal of the Palisades plant to have the TSC operational within approximately one hour after activation.
10.0 NRC POSITION The technical support center shall be designed taking into account good human factors engineering principles.
LICENSEE ACTION The TSC was designed to take into account the TSC organization and their functional duties.
Through the process of conducting facility walk-throughs and emergency drills, the TSC has been arranged to provide maximum efficiency to all groups within the TSC and to those in the other emergency response facilities.
OC0983-0009B-NL02
OPERATION SUPPORT CENTER (OSC) 1.0 NRC POSITION When activated, the OSC will be the onsite area separate from the control room where predesignated operations support personnel will assemble.
A predesignated licensee official shall be responsible for coordinating and assigning the personnel to tasks designated by control room, TSC and EOF personnel.
LICENSEE ACTION The OSC organization is provided in Attachment 4.
As can be seen from this chart, the OSC has a predesignated person to control and coordinate the operation of the OSC as well as predesignated support personnel with well defined functions.
2.0 NRC POSITION 6
The operational support center shall be located onsite to serve as an assembly point for support personnel and to facilitate performance of support functions and tasks.
LICENSEE ACTION The OSC is located onsite in the following two.areas:
Area 1 Lunch Room.
This area provides OSC command and control and chemistry/health physics support.
Area 2 Main Locker Room.
This area provides a manpower reserve, specifically plant maintenance personnel.
3.0 NRC POSITION The operational support center shall be capable of reliable voice communications with the control room, TSC and EOF.
LICENSEE ACTION shows the communications links between the OSC and the other emergency response facilities.
As can be seen from this communication matrix, the OSC has a highly reliable communication link to the other emergency response facilities consisting of dedi-cated phones, radio communication, intercom system, intraplant phones.
OC0983-0009B-NL02
EMERGENCY OPERATIONS FACILITY (EOF) 1.0 NRC POSITION The emergency operations facility shall be located and provided with radiation protection features as described in Table 1 (previous guidance approved by the Commission) and with appropriate radiological monitoring systems.
LICENSEE ACTION 7
The Palisades Plant EOF is located in the South Haven Conference Center which is located 10 miles from the plant site.
As such, no special radiation protection equipment, other than anti-contamination clothing and respirators, has been installed. Radiation monitoring equipment consists of portable air sampling equipment and survey equipment.
2.0 NRC POSITION The emergency operations facility shall be sufficient to accommodate and support federal, state, local and licensee predesignated per-sonnel, equipment and documentation in the EOF.
LICENSEE ACTION gives the floor plan for the EOF.
As can be seen, there is sufficient room in the EOF to accommodate federal, state, local and licensee predesignated personnel, equipment and documentation.
3.0 NRC POSITION The emergency operations facility shall be structurally built in accordance with the Uniform Building Code.
LICENSEE ACTION The building that the Palisades Plant EOF is located in was built in accordance with the BOCA (Building Officials and Code Administrator)
Code which was the building code of the State of Michigan at the time of construction.
OC0983-0009B-NL02
8 4.0 NRC POSITION The emergency operations facility shall be environmentally controlled to provide room air temperature, humidity and cleanliness appropriate for personnel and equipment.
LICENSEE ACTION The HVAC system installed in the EOF has demonstrated in the recent drills and exercise that it can maintain the appropriate environment in the EOF with a fully staffed and functioning facility.
5.0 NRC POSITION The emergency operations facility shall be provided with reliable
- voice and data communications facilities to the TSC and* control.room, and reliable voice communication facilities to OSC and to NRC, State and local emergency operations center.
LICENSEE ACTION contains a communication matrix that details all avail-able communication lines between the EOF and other emergency response facilities.
As can be seen from this attachment, the EOF has the required communication links, consisting of dedicated phones, radio communication, intraplant phones, commercial phones and facsimile machines.
6.0 NRC POSITION The emergency operations facility shall be capable of reliable collection, storage, analysis, display and communication of infor-mation on containment conditions, radiological releases and meteoro-logy sufficient to determine site and regional status, determine changes in status, forecast status and take appropriate actions.
Variables from the following categories that are essential to EOF functions shall be available in the EOF:
(i) variables from the appropriate Table 1 or*2 of Regulatory Guide 1.97 (Rev. 2), and (ii) the meteorological variables in Regulatory Guide 1.97 (Rev. 2) for site vicinity and regional data available via communication from the National Weather Service.
LICENSEE ACTION Plant system information and other appropriate variables essential to the ~OF functions are provided to the EOF staff via the TSC.
A minimum set of plant parameters (Attachment 7) as well as appropriate radiation monitor readings are transmitted to the EOF by facsimile OC0983-0009B-NL02
machine on a routine basis.
Additional information as may be required is obtained from the TSC by direct telephone communications to the various support groups within the TSC.
The logging, trending and analysis of plant information and radio-logical data in the EOF was observed by the NRC during the PALEX-83 emergency exercise.
No items of noncompliance, violation or devia-tions were identified.
As such, the intent of item (i) above has been met.
9 In order to minimize the impact on the TSC staff for providing information to the EOF and to enhance the storage of analysis and trending capabilities for the information required in the EOF, the Critical Functions Monitoring System (CFMS) will support a display terminal in the EOF.
This terminal will provide the EOF staff with the same information and display capabilities as that of the TSC.
It is anticipated that this capability will be implemented by the next Palisades emergency exercise in August 1984 for those parameters currently available in the CFMS.
Onsite meteorological data is provided to the EOF via remote interro-gation to the onsite meteorological monitoring system.
Both current averages as well as historical averages of all meteorological para-meters measured onsite are available to the EOF.
Regional National Weather Service data as well as meteorological forecast are available to the EOF via remote interrogation to the Weather Services internal computer system.
The display of meteorological information in the EOF was observed by the NRC during the PALEX-83 emergency exercise.
No items of noncom-plianc~, violation or deviations were identified.
As such, the intent of item (ii) above has been met.
7.0 NRC POSITION The emergency operations facility shall be provided with up-to-date plant records (drawings, schematic diagrams, etc.), procedures, emergency plans and environmental.information (such as geophysical data) needed to perform EOF functions.
LICENSEE ACTION The reference material stored in the EOF includes:
0 Plant Operating Procedures 0 Emergency Operating Procedures
°FSAR 0 Site Emergency Plan (SEP) 0 Site Emergency Plan Implementing Procedures (SEPIP) 0 Plant Technical Specifications OC0983-0009B-NL02
0 GOCC/EOF Emergency Implementing Procedures 0 Emergency Off Normal Procedures 0 INPO Emergency Resources Manual 0 Public Affairs Nuclear Plant Emergency Public Information Policies and Procedures
°Federal,.State and-Local Emergency Procedures 10 0 Population Distribution and Evacuation Time Estimates Document 0 P&ID Drawings These records are maintained current by the plant's Document Control Center and Emergency Planning Qoordinator.
- 8. 0.
NRC POSIT ION The emergency operations facility shall be staffed using Table 2 (previous guidance approved by the Commission) as a goal.
Reasonable exceptions to goals for the number of additional staff personnel and response times for their arrival should be justified and will be considered by NRC staff.
LICENSEE ACTION Consumers Power Company currently uses its General Office staff to
~
man the EOF.
To meet the intent of the EOF staffing requirement of Table 2 of Supplement 1 to NUREG-0737, Consumers Power activates a General Office Control Center (GOCC) at the Alert classification.
Activation at the Alert classification is done to-permit the acti-vation of the near-site EOF with General Office staff within a reasonable response time should conditions warrant.
GOCC/EOF Emer-gency Implementing Procedures require mandatory activation of the near-site EOF by the General Office staff at the Site Area Emergency classification.
Activation of the near-site EOF at the Alert class-ification may be done if conditions warrant.
The GOCC will function as an EOF only until a selected group of General Office staff can travel to the near-site EOF and activate that facility. gives the floor plan of the GOCC as well as the support teams that will man the facility.
As can be seen from the attach-ment, all required communication links, except for the direct commun-ication to the offsite monitoring teams, are available in the GOCC.
The TSC will maintain communication to the off site monitoring teams until the near-site EOF is activated.
As can be seen by comparing and 6, the EOF and GOCC facilities and support staff are very similar.
Activities are currently underway to review the existing GOCC/EOF concept and to come up with alternative approaches to meeting the EOF staffing requirements of Table 2 of Supplement 1 to NUREG-0737.
OC0983-0009B-NL02
9.0 NRC POSITION The emergency operations facility shall be provided with industrial security when it is activated to exclude unauthorized personnel and when it is idle to maintain its readiness.
LICENSEE ACTION 11 When activated, the EOF is provided with security personnel from the Company's security force.
When the facility is not activated, it is used as a conference center and has a full-time caretaker.
10.0 NRC POSITION The emergency operations facility shall be designed taking into account good human factors engineering principles.
LICENSEE ACTION The EOF was designed to take into account the EOF organization and their functional duties.
Through the process of conducting facility walk-throughs and emergency drills, the EOF has been arranged to provide maximum efficiency to all groups within the EOF and to those in the other emergency response facilities.
DOSE ASSESSMENT CAPABILITIES Consumers Power Company, Detroit Edison Company, American Electric Power Services Corporation and the State of Michigan have developed a common dose assessment procedure.
This method incorporates the following characteristics:
0 straight line gaussian dispersion methodology 0 finite cloud correction factors 0 building wake correction (ground level releases only) 0 radionuclide mixture correction The procedure has been programmed on a hand-held calculator and an appropriate software QA program developed.
Programmed calculators have been provided to the Palisades Plant.
The plant Site Emergency Plan Implementing Procedures have been modified to include instructions for using the calculator dose assessment program.
Training has been completed on the new procedures and their use demonstrated to the NRC during the recent PALEX-83 emergency exercise.
Consumers Power Company has initiated work on the development of a more sophisticated dose assessment model for the Palisades Plant.
This model will be used to supplement the hand-held calculator model.
The more sophisticated model incorporates the following characteristics:
OC0983-0009B-NL02.
- e.
0 segmented gaussian dispersion _methodology 0 radioactive decay 0 building wake correction. (ground level releases only) 0 ground level or elevated release option 0 terrain interaction 0 dry deposition 0 treatment of lake-induced meteorological effects 0 calculation of source terms by
- 1.
actual noble gas release rate from the plant, coupled with the radionuclide spectrum file.
- 2.
use of a hypothetical source term file.
- 3.
use of measured or assumed noble gas release rate and applying an average energy factor.
12 The results of the model calculations will be presented in both tabular and graphical form.
Tabulated results will contain current average and cumulative values for both whole body and thyroid inhalation doses at all specified radial distances and special interest receptors.
The model will be installed and run on the Corporate Office main frame computers~ The model will be run on color graphic display terminals and associated printers installed in the plant's technical support center, emergency operations facility, and General Office Control Center.
Graphical results will.provide color displays of plume location and isopleths for current and cumulative doses.
It is anticipated that work on this model including procedure preparation and training will be complete by the next Palisades emergency exercise in August 1984.
ATTACHMENT 1 Technical Support Center Layout and Phone Locations 368 372 376
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Operations Support Group
- Control Room Technical Support Group Engineering Support Center (ESC)
Conf Rm 113&4 ATTACHMENT.3 TECHNICAL SUPPORT CENTER ORGANIZATION AND INTERFACES Maintenance Support Group Maintenance Support Center (MSC)
Main Locker Rm Lunchroom Site Emergency Director (SED)
Chemistry/Health Physics Support Group Operational Support Center (OSC)
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D 12. Cool Down Rate 0f/hr 015. Charging and Letdown Flow Mismatch_-__ gpm 016. PORV Position 0 Closed D Open Temp. __
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_ __ (mR-R/hr)
Instr.# __ _
D 31. Containment Hz Cone. __ %
D 32. Integrity Maintained PCS Oves 0No Containment D Yes D No 0 33. Time Reactor s*cram ---
OC0983-0007B-NL02 Consumers Power Company Palisades Plant 50-255 SCHEDULE TO RESOLVE SUPPLEMENT 1 TO NUREG-0737 EMERGENCY RESPONSE FACILITIES September, 1983 1 Page
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SCHEDULE TO RESOLVE SUPPLEMENT 1 TO NUREG-0737 EMERGENCY RESPONSE FACILITIES ACTIVITY DESCRIPTION Complete the habitability modification work on the Technical Support Center Implement a Critical Functions Monitoring System display station, with corresponding procedures and training, in the Technical Support Center Emergency Operations Facility, and General Office Control Center OC0983-0007C-NL02 SCHEDULED COMPLETION DATE End of 1983 Refueling Outage August 1984 (The next Palisades Plant emergency exercise drill)