ML18054A404
| ML18054A404 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/01/1988 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Bradley Davis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8811070349 | |
| Download: ML18054A404 (7) | |
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PllWERINli lllllCHlliAN-S PIUlliRESS General Offices: 1945 West Parnell Road, Jackson, Ml 49201 * (517) 788-1636 November 1, 1988 Mr Bert Davis US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
CHANGE REQUEST FOR PALISADES SITE EMERGENCY PLAN Kenneth W Berry Director Nuclear Licensing Enclosed is a requested change to.the Palisades Site Emergency Plan.
The need for this change was identified during an internal review of Consumers Power Company's ability to meet the present Palisades Site Emergency Plan staffing requirements.
During this review it was determined the on-shift staffing requirements specified in Figure 5-6 of our Site Emergency Plan should be.
revised in order to accurately reflect the present staffing.
This internal review also conc1uded that an increase of on-shift staffing was not necessary to maintain our ability to respond to an emergency condition.
This conclusion was based on the p'erformance of our on-call and telecomputer system.
This change has become necessary as a result of changing training requirements and qualifications for Auxiliary Operators, Health Physics and Chemistry Technicians, and repairmen over a period of two to three years that prohibits us from taking credit for previous cross training that allowed people to fill-in during the first 30 minutes of the emergency.
Additional discussion and justifications for this change a!e included in the attached change.
The change request reduces the commitment in our plan but does not reduce the effectiveness of our emergency response organization nor the number of on-shift personnel that have always been available to respond _to an emergency as defined in 10.CFR 50.47 and 1.0 CFR 50 Appendix E~
Because of this OC1088-0176-NL02
e Nuclear Regulatory Commission
- 2 Palisades Nuclear Plant Site ~mergency Plan
- November 1, 1988 determination, we are submitting this change for NRC approval as required by 10 CFR 50.54(q).
A check for $150.00 is included as required by 10 CFR 170.12.
Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, NRC NRC Resident Inspector - Palisades Document Control Desk - Washington Attachment OC1088-0176-NL02
CONSUMERS POWER COMPANY Docket 50-255 Request for Change to the Site Emergency Plan License DPR-20 Consumers Power Company requests that the Palisades Site Emergency Plan be changed regarding the minimum staffing levels for the positions of Mechanical Maintenance Repairman, Electrical Maintenance Repairman, Chemistry Technician and Health Physics Technician.
The changes, discussion and conclusion sections for the proposed changes to the Palisades Site Emergency Plan are as follows:
I. Change (s)
A.
Revise Figure 5-6 Palisades Site Emergency Plan Change Figure 5-6, page 2 of 4 for Chemistry Technicians in the column for On-Shift and Staff Augmentation Capability and Approximate Response T~me, from "1" on shift and 110" on 30minute response to "a" and "1 " respectively.
Change.Figure 5-6 page 2 of 4 for Mechanical Maintenance Repairman in the column f.or On-Shift and Staff Augmentation Capability and Approximate Response T~me from 11 1..- on shift ~nd "O" on 30 minute re.i?ponse to "b 11 and 111 11 re~pectively.
Change Figure 5-6, page 2 of 4 for Electrical.Maintenance Repairman in the columns for On-Shift* and Staff Augmentati"c'm Capability and Approximate Response Ti~e, from 11111 on shift and 111" on 30 minute re.sponse to 11c 11, *and 112 11 respectively.
Change Figure 5-6, page 3 ~f 4 for Health Physics Technicians in the columns for On-,.Shift and Staff Augmentation Capability and-Approximate Re~ponse T~e, from 112 11 on-shift and 112 11 on 30 minute response to 111 11 and 113*
11 respectively.
Add to Figure *5..,.6, page 2 of 4 the following notes:
a b
c d
MI1088-0166A-NL02 Staffed two 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> shifts, 7 days a week excluding holidays.
Staffed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, 5 days a week, excluding holidays.
Staffed two 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> shifts, 5 days a week; excluding holidays.
30 minute response augmentation reduced by one if the on shift person is present.
/...,
Add to Figure 5-6, page 3 of 4 the following note:
e f
II.
Discussion Staffed with one additional technician for two (2) eight hour shifts, 5 days a week, excluding holidays.
30 minute response augmentation reduced by one if the additional person is on shift.
2 The following is a discussion regarding Palisades ability to meet Figure 5-6 as it presently stands and the reasons and justifications for the proposed changes.
Auxiliary Operators (AOs) were originally allowed and expected to do certain repair activities and were, therefore, counted as filling the electrical and mechanical repairmen requirements.
Over time, the training requirements for AOs and repairmen were further defined (as directed by INPO) and the qualifications for an AO no longer justify using AOs for repair activities.
This has been a progressive reduction over the.last 2 to 3 years and not a single event with an identifiable date.
The Health Physics and Chemistry Departments were at one time one department and the training requirements for a technician were essentially the same.
The Chemistry/Health Physics Department decided to reduce the health physics technician minimum staffing to one, and take credit for
- the chemistry technician for the second health physics technician.
In 1984 the Chemistry and Health Physics Departments, were separated and, therefore, the technicians no longer received the same training.
At that time, the chemistry technicians were s.till qualified in health physics, but as new technicians were hired, the chemistry technician could no longer be considered qualified for health physics duties.
The proposed changes in Figure 5-6 of the Site Emergency Plan would reduce the requirements of the plan and allow Palisades to meet them with present staffing, but would not reduce Palisades' ability to respond to an emergency condition due to our on-call and telecomputer systems.
Palisades has been successfully using an on-call system where a list of on-call _personnel is maintained in the Shift Supervisor's offi.ce for chemistry, electrical maintenance, and mechanical maintenance.
The on-call list for additional health physics support is maintained by the on-shift radiation safety technician.
With the use of the on-call list and beeper telephone paging system, the required people will respond within 30 minutes.
In addition to the on-call system, Palisades maintains a trained emergency staff that may be activated by using a system of telecomputers or a manual call-out list. The telecomputers are machines capable of calling personnel and giving them a prerecorded message asking if they are available to respond to a plant emergency.
MI1088-0166A-NL02
This system was used in February, 1988 to augment staff for an unannounced backshift drill. *The response to the telecomputers was excellent and the NUREG-0654 requirements for emergency staff augment-ation were met.
These proposed changes would not affect our ability to meet on-shift requirements for operations, firefighting, rescue operations, security or in-plant survey radiation safety technicians.
III. Conclusion 3
The Palisades Plant Review Committee has reviewed this change request to the Palisades Site Emergency Plan and has determined that this change reduces the emergency preparedness commitment fn our Plan but does not reduce the effectiveness of our emergency response organization to respond to an emergency as defined in 10 CFR 50.47 and 10 CFR 50 Appendix E.
This change has been reviewed under the cognizance of the Nuclear Safety Board.
MI1088-0166A-NL02
MAJOR FUNCTIONAL AREA Plant System Engineering, Repair and Corrective Actions PALISADES NUCLEAR PLANT SITE EMERGENCY PLAN FIGURE 5-6 PLANT STAFFING AND AUGMENTATION GUIDELINES MAJOR TASKS Off site Surveys Onsite (out-of-plants)
In-plant Surveys Chemistry/Radio-chemistry Technical Support Repair and Corrective Actions POSITION TITLE OR EXPERTISE Rad Safety Technicians Chem Technicians Shift Engineer/
Shift Technical Advisor/
Operations Support Supervisor Core/Thermal Hydraulics Electrical Mechanical Mechanical Maintenance Radwaste Operator Electrical Maintenance Instrument and Control.
(I&C) Technician NOTES:
a b staffed two 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> shifts, 7 days a week excluding holidays.
staffed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a days, 5 days a week, excluding holidays.
c ON SHIFT 1
a b
c I:
j'.
SECTION 5 Revision BA Pa.ge 2 of 4 STAFF AUGMENTATION*
CAPABILITY AND APPROXIMATE RESPONSE TIMES 30 Min 60 Min 2
2 1
1 e ld 1
1 1
1 1
1 ld 1
2d 1
1 1
e d staff two 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> shifts, 5 days a week, excluding holidays.
30 minute response augmentation reduced by one if the on shift person is present.
- Augmentation List maintained for special contingencies.
- There shall be two individuals with Senior Reactor Operator licenses qn Shift. If the Shift Engineer is on Shift, or either SRO on Shift Satisfies the Shift Technical Advisor Qualification requirements, then the Shift Technical Advisor does not need to be Stationed.
MI1088-0166A-NL02 I I
MAJOR FUNCTIONAL AREA Protective Actions (In-Plant)
Firefighting Rescue Operations and First-Aid PALISADES NUCLEAR PLANT.
SITE EMERGENCY PLAN FIGURE 5-6 PLANT STAFFING AND AUGMENTATION GUIDELINES MAJOR TASKS Radiation Protection:
- a.
Access Control
- b.
HP Coverage for re-pair, corrective actions, search &
rescue first-aid &
firefighting
- c.
Personnel monitoring
- d.
Dosimetry POSITION TITLE OR EXPERTISE HP Technicians ON SHIFT J.
SECTION 5 Revision BA Page 3 of 4.
I:
STAFF AUGMENTATION*
CAPABILITY AND APPROXIMATE RESPONSE TIMES 30 Min 60 Min 2
Fire Brigade**
per Technical Specifications Local Support 2**
Loe.al Support NOTES:
~ staffed with one additional technician for two (2) eight hour shfits, 5 days a week, excluding holidays.
30 minute response augmentation* reduced by one if the additional person is on shift.
- Augmentation List maintained for special contingencies.
- There shall be two individuals with Senior Reactor Operator licenses on Shift. If the Shift Engineer is on Shift, or either SRO on Shift Satisfies the Shift Technical Advisor Qualification requirements, then the Shift Technical Advisor does not need to be Stationed.
MI1088-0166A-NL02 I.
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