ML19250H830
| ML19250H830 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 06/22/1981 |
| From: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0654, RTR-NUREG-654 GL-81-10, NUDOCS 8106260352 | |
| Download: ML19250H830 (7) | |
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Osneral Ctuces: 212 West Michipen Avenws. Jackson. Michipen dG201 * (s17) 7884ss0 June 22, 1981 Director, Nuclear Reactor Regulation At: Mr Dennis M Crutchfield, Chief Operating Reac:crs Branch No 5 US Nuclear Regulatory Co==ission Vashington, DC 20555 e
DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT - RESPONSE TO POST-TMI REQUIPIMENTS FOR THE EMERGENCY CPERATICNS TACILITY (GENP.RIC LIT IR SI-10)
NRC Generic Le::er 51-10, dated February 18, 1961, previded clarification of NUREG-0737, I:e= III.A.I.2.
This Generic Letter included a table, the source ef which was NURIG-0634, specifying the
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'- - staffing recuire=ents for
.icensees fer nuclear power plar crergencies.
In particular, this table identified :ne "en-shift" staffing level as well as additienal persennel that would be z.eeded en site within 30 and 60 =inutes frc= the onset of an accident. Censumers Power Ce=pany letter, dated April 6, 1981, provided notification that these en-shift staffing require =ents will net be fully adhered to because of the s=all size (240 W:) of the Big Rock Point Plant.
~he purpose of this letter is to provide Censu=ers Power Ce:pany's pcsitien with regard to shift staffing levels and a =cre expanded basis for this positien.
NRC Generic Le::er 81-10 and NUREG-0654 established a =ini=u: en-shift staffing level cf 10 persens, co= prised of the following persennel:
1 Shift Supervisor (SRO) 1 Shift Fore =an (SRO) 2 Centrol Roo: Operaters OY L
2 Auxiliary Operators 1 Shift Technical Advisor g
1 HP Technician CD 1 Rad /Che= Technician 1 Individual Respensible for Netificatien/Cc==unicatien
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In ce=parisen, Consu=ers Power intends to =aintain a =ini=u= cn-shif t staff of 7 persons at the Big Rock Point Plant, identified as follovs:
1 Shift Supervisor (SRO) 2 Centrol Roe = Operators (RO) 2 Auxiliary Operators (AO) 1 Shift Technical Advisol - Notification /Co==unicatiens*
J HP - Rad /Che= Technician **
7 MINIMUM TOTAL Tor the reasons listed below, Censumer Power Co=pany fir:1y be?ieves that the
=inimu= en-shift staf fing level described above is = ore than adequate to operate the plant during ner=al operatien and during the first 30 to 60
=inutes following the enset of an e=ergency situation, e
(a) Plant Si=plicity:
Because of its age and sire, the safety syste=s and controls at the 240 MWt Big Rock Point Plant are =uch less co= plex than these of a larger nuclear plant. A co=parison with the Palisades Pl ant (2530 MWt) shows that the Big Roc! Point centrol rec = bas only about 30% of the instru=er.ts and inticators and 50% of the alar =s.
(b) Operating Experience: During the 19 years of cperation, there has never been any need fer extra shif t persennel in addition to these identified above. During events when aeditienal peeple were needed, a " call-up" procedure for required persennel was found to be satisfactory.
(c) Probabilistic Risk Censu=crs Power has concluded that the =ini=u= staf fing Assess =ent (PRA):
listed above is more than adequate to protect the public based en the findings of the PRA study, which show that essentially no acute fatalities "The inclusien of a Shif t Technical Advisor a=eng the on-shift ce=p]e=ent of 7 peeple is previsional. The decisien to =aintain this positien will be made upen cerpletien of an assess =ent of emergency situatien staf fing levels (see dis.cussien later en in this letter).
- Presently, an en-shift EP Technician is not provided.
Current practice involves
" call-up" of required persennel who can aug=ent the en-shift staf f within 60 Censu=ers Power intends to provide an en-shif t HP Rad /Che= Techni-einutes.
cian by November 1, 1982. The basis for providing only one technician is that the health physics and chemistry technician #:nctiens have been ::aditienally ce=bined and this is reflected in our Site E=ergency Plan I=ple=enting Pro-cedures.
It should be noted that the actions required of this technician for e=ergency situatiens are quite li=ited in the first few hours of E=ergency Plan i=ple=entation.
oc0681-0347a-43
3 will occur as a result of a reactor core damage event, using the current operatiens personnel shift staffing, exclusive of the Shift Tecnnical Advisor, to imple=ent the existing e=ergency eperating procedures.
The significant differences between our position and that requested by Generic Letter 61-10 involve the lack of a second SRO en-shift and the co=bination of duties for the HP Techrician and Rad /Che= Technician into one position. The basis for providing only ene SRO on-shift involves the plant simplicity and past operating experience and the PRA study which did not identify any need for a second SRO ca-shift at tLe,lant.
Further, the Cost-Benefit Analyses reported in the FRA letter of trans=ittal dated March 31, 1961 evaluated the
=axi=u= expenditure which cha be justified to reduce the risk fre= the Big Rock Pcist Pl ant. Tha cost-benefit criteria applied in that analysis was de ived from the decision rules published in NUREG-0739. Based en this analysis, the =axi=um expenditure which can be juscified to ce=pletely eli=inate the residual risk fro = Big Rock Point (after the design changes rece== ended by Censu=ers Power Co=pany have been i=T e=ented), including on-l site occupatienal expesure is approxi=ately 33,500 dellars per year. The esti=ated cost of adding a second SRO en-shift is 250,000 dellers per year.
Since it is clear that the additien of a second SRO en-shift would not eli=inate all of the residual risk, this action is not censidered to be cost effective based en NUREG-0739 criteria. The basis for providing a single technician for HP and Rad /Che= duties likewise involves the plant si=plicity and operating experience as noted previously. Therefore, our abeve positiens with respect to a secend SRO en-shift and co=bining of the HP and Rad /Che=
Technician duties are censidered per=anent.
Censu=ers Power Cc=pany feels that these bases,revide sufficient justifica-tien for our positien regarding the =ini=u= en-shif t staffing level at the Big Rock Peint Plant. Nevertheless, Censu=ers Power also und rstands the intent of the NRC staffing require =ents and recognizes'the need to ccrefully consider adding extra persennel en-shift, exclusive of a second SRO. Ter'these rensens, Cens==ers Power is i=ple=enting a program to evaluate in detail the following aspects of personnel needs in the event of an t_ergency:
- Nu=ber of People Required
- Necessary Skill Levt1 ef the Required People
- The Feint 15 Ti=e When These Required Pecple are Needed On Site This evaluation, which is briefly described in Attach =ent I, will use the de=inant accident sequences identified by the PRA study as a starting point.
The resnits of this evaluation will previde the fol)owing infer =atien:
1.
An assess =ent of the adequacy of the =ini=u= en-shif t staf fing described in this letter, as well as the current capability to aug=ent this staff level en a " call-up" basis.
oc0681-03L'a-43
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2.
Identification of the additional personnel needed after the start of an e=ergency situatica and the ti=e at which tiese extra people are needed on site.
3.
An assess =ent of the role of Shift Technical Advisor (STA) before and during an accident event, thereby identifying whether or not an en-duty STA is indeed necessary.
This evaluation will F co=pleted and submitted to the NRC hv.. arch 31, 1982.
At ths". ti=e, Censu=ers Power will make
..y final adjust =ents to the =ini=u=
cn-shift staffing level and establish additional staffing require =ents based en the need to =itigate accident sequences or consequences. Censu=ers Power Cc=pany is confident that the =ini=u= en-shift staff delineated in this letter and the current " call-up" progra= of calling in required off-shift rig Rock Point persennel previde adequate assurance that the necessary =anpower will be available in the event of a site e=ergency. Accordingly, Censumers Power Co=pany believes that our position regarding plant e=ergency staffing for Big Rock Point =eets the ir
- en of NRC Generic Letter 81-10.
The above position state =ents pertaining to shift staffing =odify cur previous ce==it=ents =ade by sub=ittals dated October 31, 1980 (respense to NRC letter dated July 31, 1980) and Dece=ber 19, 1980 (respense to NRC letter dated October 31, 1980 - NURIG-0737, Ite= I.A.1.3).
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David P Hoff=an Nuclear Licensing Ad=inistrator CC Directer, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforca=ent NRC Rer'. dent Inspector-Big Rock Point I
oc0681-0347a-43
CONSUMERS PO'GR COMPANY Big Rock Point Plant RESPONSE TO POST-TMI REQ"IREMENTS FOR THE EMERGENCY OPERATIONS FACILITY (GENERIC LETTER 81-10)
Docket No 50-155 License No DPR-6 At the request of the Co==ission and pursuant to the Ato=ic Energy Act of 1954, and the Energy Reorganination Act of 1974, as a= ended and the Co==is-sion's Rules and Regulations thereunder, Censu=ers Power Co=pany sub=its our response to Generic Letter 81-10, dated February 18, 1981, entitled " Post-TMI Require =ents for the E=ergency Operations Tacility," pertaining to shift
=anning.
Censu=ers Power Cc= pari s response is dated June 22, 1981.
e CONSDERS PC'ER CC"PANY By
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'R B DeWitt, Vice President Nuclear '.'pt:stions Sworn t.nd subscribed to before =e this 22nd day of June 1961.
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Helen I De=pski, Notary Gublic Jackson County, Michigan My ce==ission expires Dece=ber 14, 1983.
nu0681-0347c-43
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ATTACEMENT I PRA - BASED PROGRAM TO EVALUATE SHIFT STAFFING REQUIREMENTS FOR BIG ROCK POINT The purpose of the progra= described herein is tF*eefold: To evaluate the adequacy of the current plant shift staffing anc call-up programs to address site e=ergencies, to identify additional staff needs ence a site e=ergency has been declered and to assess the necessity of having a Shift Technical Advisor en duty to =itigate accident sequences or censequences. The approach to be taken will utilize the de:inant accident sequences described in the recently sub=itted Big Rock Point FRA study as the nest current and co=plete descrip-tion of accidents with potential to affect public health and safety. These sequences will be e= ployed in the following =anner:
(a) Operator action event *rees will be prepared sfer all de=inant accident sequences. These operator action event trees, which will be si=ilar in concept to these developed in NUREG-CR-1440, will be used to define eperator and =aintenance action which =ight be taken either to ter=inate the sequence er to =itigate its censequences.
(b) The de=inant accident sequences will be reviewed to define character-istics which would be expected to produce si=ilar de= ands for =anpower en si=ilar ti=e f r a=e s. Sections of operator action event trees which are si=ilar will be e=pleyed as =odules to si=plify censtruction of the trees.
(c) Fre= a ec=plete set of operator action event trees, a listing of poten-tially usefu] actiens will be developed. These actions will then be evaluated to define the following para =eters:
- The ti=e when the actions are required.
- The skill level required to perfer= the actions.
- The duratien of the actien including the ti=e required to diagnose the proble=.
- The enviren=ent in which the action =ust be carried out.
(d) Fre= this listing pf useful actiens and actics para =eters, an evaluation will be =ade of the de= ands en plant staff at various skill levels so that an esti= ate of the =anpower require =ents can be cade.
Included in this esti= ate will be people whose respensibilities are to provide effec-tive ce==unication with ex plant persennel respensible for e=ergency canage=ent. Experience gathered in the site e=ergency drills will be f actored in at this stage.
Standard =aintenance scheduling techniques will be e= ployed in this assess =ent.
(e) An evaluatien of the ti=ely availability of the required staff for each of the accident sequences will be =ade censidering current plant staffing and call-up precedures. Various weather conditiens and occurrence ti=es will be censidered.
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2 (f) Suggestions fer changes to the current plant shift staffing and call-up procedures will be developed where appropriate based on the analysis above.
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