ML19260D384
| ML19260D384 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 02/06/1980 |
| From: | Peoples D COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8002080640 | |
| Download: ML19260D384 (20) | |
Text
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O one First Nabonal Plaza. Chicago. Illinois Commonwealth Edison Address Reply to: Post Office Box 767 Chicago. Ilknois 60690 Docket No. 50-295/304 February 6, 1980 Dr.
H. R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Dear Dr. Denton:
As a result of an NRC request on December 5, 1979, Commonwealth Edison has developed, together with Consolidated Edison and the Power Authority of the State of New York, an extensive, coordinated Near Site Study of the Zion and Indian Point facilities.
This study addresses both the mitigation of consequences of a severe accident and the reduction of the probability of a severe accident.
As a result of our studies and further discussion with the NRC, Commonwealth Edison proposes the following interim actions which we believe are worthwhile with respect to reducing the potential risk to the populace.
Edison wishes to make it clear, however, that Zion Station, as currently licensed, has and continues to operate safely.
The suggestion that interim measures be taken does not imply otherwise.
It is our estimate, however, based upon preliminary probabilistic risk assessment, that the relative risk may be reduced by an order of magnitude by taking the interim actions stated in this letter.
Commonwealth Edison proposes to take the following interim actions at Zion Station after receipt of the NRC confirmatory order:
Immediate Actions 1.
Ensure no gross containment leakage prior to any startup from cold shutdown conditions by performing the following actions:
A.
Ensure that containment penetration and weld channel pressurization system leakage is within Technical Specification limits.
The function of the containment penetration and weld channel pressurization system is to prevent leakage of containment ai-through penetrations and liner welds under all conditions by supplying air above the containment post accident design pressure to the positive pressure zones incorporatedi,nthepenetrationandweldchanneldesign.p 00 b i
1934 188 r
I f
soonos o (;> t / d
. The system also provides a means of continuously monitoring the leakage status of the containment.
The cantainment purge valves and airlock door seals are included in this system.
B.
Perform local leak tests of containment isolation valves not included in the following categories:
1.
Those valves continuously pressurized and monitored for leakage by the penetration pressurization system.
2.
Those valves which, under post-accident containment isolation conditions, are expected to be maintained con-tinually at a pressure equal to or greater than the containment peak accident pressure.
This includes valves under isolation valve seal water and those in systems required for post-accident service if such systems operate at pressures above containment peak accident pressure.
2.
Maintain at least two senior reactor operators (SR0s) (one of whom may be the shift supervisor) in or near and immediately available to the control room at all times during power operation or hot standby.
The second SR0 shall be allowed to leave the immediate vicinity of the control room as duties may require, but shall be available to respond to an emergency in the control room at least within a 10 minute period.
3.
Conduct testing to assure that the LPI/RHR check valves are in fact installed correctly and functioning as pressure isolation barriers when the plant is at pressure and producing power.
Verification of valve operability shall be performed prior to plant restart if shutdown at the time of receipt of the NRC confirmatory order and thereafter whenever RCS pressure has decreased to within 100 psig of RHR system pressure.
Within 60 Days 1.
Commonwealth Edison will investigate possible co-impregnation of the charcoal in the plants' air effluent filtration systems with an amine such as TEDA (triethylene-diamine) to improve the iodine removal capability of these systems.
The results of this review shall be submitted to the NRC within 60 days after receipt of the NRC confirmatory order.
1934 i89
. 2.
Commonwealth Edison will examine the parameters and response to ATWS conditions at Zion including:
1.
Operate the plants with the most favorable moderator temperature coefficient (MTC) so that the peak pressure resulting from an ATWS transient is limited to upset conditions.
2.
Modify (if necessary) the procedures so that immediate manual scram, immediate manual tripping of the turbine, immediate actuation of AFWS, and early actuation of HPSI are required.
Within 90 Days Commonwealth Edison will commit to meet the onsite emergency preparedness manning levels contained herein as Table 1.
Within 120 Days 1.
Commonwealth Edison will assure that DC powered lighting is available at the steam-turbine driven auxiliary feedwater pump.
2.
Commonwealth Edison will review, and strengthen if required, the administrative controls on the manual valve (s) whose misalign-ment can fail all ECCS.
(RWST line)
With_in Six Months 1.
The licensee has conducted a special review of past Licensee Event Reports (LERs) originated at all operating plants.
This study was documented in a report to the NRC dated June 16, 1978.
The purpose of the LER review was to identify design inadequacies at all operating plants (undesirable systems interactions).
Already, the licensee routinely reviews LERs originating at all its plants to identify undesirable trends, common mode failures, procedural and training inadequacies, and man / machine human factor inadequacies, and to apply experience gained at one plant to all the other plants.
The licensee's internal LER review procedures shall be reviewed and revised as appropriate to ensure correction of identified design inadequacies and prompt notification of the NRC where required.
1934 190 2.
The licensee has conducted a study to determine the dxtent to which Zion 1 and 2 vary from current criteria for design and operation of nuclear power plants.
All Division I Nuclear Regulatory Guide and Standard Review Plan requirements were covered in the study.
This study was documented in a report to the NRC dated September 12, 1978.
The report supports the licensee's conclusion that Zion is in substantial conformance with present day standards.
It contains specific information on how the plant meets the intent of each requirement.
The NRC staff proposed numerous additional interim actions in a Telex dated January 28, 1980, and subsequently modified by telephone.
Commonwealth Edison has thoroughly reviewed these proposed items.
In our opinion these actions do not provide a measurable, substantive reduction in potential risk to the populace.
In addition, the activities suggested would cause additional management and bargaining unit personnel overtime, which could be counter-productive to overall plant safety.
Also, the NRC must become aware that the large number of tasks generated by the Le~ssons Learned commitments are at the point of nearly swamping management, engineering, and operating staffs.
Commonwealth Edison has committed to a number of the NRC suggested interim actions in the first portion of this letter.
Other NRC suggestions are listed below with Edison's comment following each.
"The following requirements shall be effective immediately upon issuance of the ORDER:
1.
Immediately reduce reactor power level as necessary such that calculated fuel peak clad temperature does not exceed 20000F under large break LOCA conditions.
2.
Immediately revise plant operating procedures, as necessary, to require a base load mode type of operation only, without load following."
CECO Comment:
1 and 2 Commonwealth Edison's current licensed limit on total peaking factor, current docketed proposed changes on total peaking factor including large break LOCA analyses and current normal mode of base load operation already meets, has met, and will most probably continue to meet not only the peak clad temperature limit of 22000F arrived at 1934 191 through lengthy rulemaking but also the proposed interim action.
Commonwealth Edison nuclear units are normally base loaded except for power reductions required to maintain system load and grid stability, for maintenance (e.g. containment entry, main feed pump repairs, etc.) or as required by Technical Specifications.
"6.
Immediately adopt policies and practices which require that its plant be operated in conditions which provide maximum margin from approach to Technical Specification limits.
This includes operational parameters such as peak power and moderator temperature coefficient, plus minimization of equipment out of service."
CECO Comment:
Commonwealth Edison recommends deletion of this item in its entirety as such a broad scope statement poses problems with respect to implementation and verification.
(NRC agreed to deletion in Telecon of 2-1-80).
In addition, reviews of the specific parameters mentioned are covered in other suggested interim actions (CECO 60 day item).
"7.
All reactor operators and senior reactor operators shall perform simulator training and in-plant walk throughs of the following emergency procedures prior to the next reactor startup following issuance of this ORDER:
a.
Plant or reactor startups to include a range that reactivity feedback from nuclear heat addition is noticeable and heat up rate is established.
b.
Manual control of steam generators and/or feedwater during startup and shutdown.
c.
Any significant (> 10%) power change in manual rod control.
d.
Loss of Coolant (1) including significant PWR steam generator leaks (2) inside and outside containment (3) large and small, including leak rate determination (4) saturated reactor coolant response (PWR) e.
Loss of core coolant flow / natural circulation.
f.
Loss of all feedwater (normal and emergency).
1934 192 g.
Station Blackout.
h.
ATWS 1.
Stuck open relief valve on secondary side.
j.
Intersystem LOCA."
CECO Comment:
Commonwealth Edison already operates an extensive training and retraining program at Zion Station.
The Zion program utilizes a simulator, located nearby on Edison property, for both initial qual-ifications and retraining.
To expedite this training in the manner suggested by the NRC staff runs counter to previous NRC staff and Nuclear Industry concerns such as preventing excessive overtime for operators.
Therefore, Commonwealth Edison will adhere to its current training / retraining program schedule which includes four days retraining every fifth week for shif,t personnel and annual simulator retraining..
"The following requirements shall be implemented within 30 days of the date of issuance of this ORDER:
1.
A vendor representative should be established on site for engineering consultation on plant operations and maintenance to demonstrably increase plant safety.
This representative may be a NSSS vendor, architect-engineer or startup engineering firm, as appropriate."
CECO Comment:
Commonwealth Edison does not believe that a vendor or AE representative onsite will demonstrably increase plant safety.
None of these representatives would have detailed or first hand knowledge of Commonwealth Edison plant specific procedures, operations, or overall operating philosophy and hence, their consultation would effectively be limited primarily to that of a graduate or degreed engineer.
The current Zion Station Shift Technical Advisor who is both a senior reactor operator and degreed engineer more aptly provides the intended function.
"2.
Control room habitability under accident conditions shall be ensured by re-examining ventilation intakes, locations of potential plant leakage (ingress and egress) and control room filter capabilities.
The results of this review shall be provided to the NRC within 30 days."j g 34 j g 3 CECO Comment:
The ventilation system has been designed to accomodate the Post LOCA plant environment.
The area is supplied with filtered air and maintained at a position pressure.
There is no need for system modification.
"3.
Revise emergency action levels to require notification of the NRC for all events in emergency classes in NUREG-0610."
CECO Comment:
As a matter of policy at all its nuclear plants, Commonwealth Edison has been and will continue to notify the regional NRC office both directly and in-directly through the resident inspectors of all events that have or might have significant interest to the general populace.
"4.
The licensee shall commit to the October, 1979, letter concerning the following interim position on containment purge and vent valve operation:
INTERIM POSITION FOR CONTAINMENT PURGE AND VENT VALVE OPERATION PENDING RL50LUI10N OF 150LA110N VALVE UPERA61 Lily Once the conditions listed below are met, restrictions on use of the containment purge and vent system isolation valves will be revised based on our review of your responses to the November, 1978, letter justifying your proposed operational mode.
The revised restrictions can be established separately for each system.
1.
Whenever the containment integrity is required, emphasis should be placed on operating the containment in a passive mode as much as possible and on limiting all purging and venting times to as low as achievable.
To justify venting or purging, there must be an established need to improve working conditions to perform a safety related surveillance or safety related maintenance procedure.
(Examples of improved working conditions would include deinerting, reducing temperature *, humidity *, and airborne activity sufficiently to permit efficient performance or to significantly reduce occupationsl radiation exposures), and
- 0nly where temperature and humidity controls are not in the present
- design, 1934 194 "2.
Maintain the containment purge and vent isolation valves closed whenever the reactor is not in the cold shutdown or refueling mode until such time as you can show that; a.
All isolation valves greater than 3" nominal diameter used for containment purge and venting operations are operable under the most severe design basis accident flow condition loading and can close within the time limit stated in your Technical Specification, design criteria or operating procedures.
This operability of butterfly valves may, on an interim basis, be demonstrated by limiting the valve to be no more than 300 to 500 open (900 being full open).
The maximum opening shall be determined in consultation with the valve supplier.
The valve opening must be such that the critical valve parts will not be damaged by DBA-LOCA loads and that the valve will tend to close when the fluid dynamic forces are introduced, and b.
Modifications, as necessary, have been made to segregate the containment ventilation isolation signals to ensure that, as a minimum, at least one of the automatic safety injection actuation signals is uninhibited and operable to initiate valve closure when any other isolation signal may be blocked, reset, or overridden."
CECO Comment:
Commonwealth Edison has already committed to meet these requirements per a December 14, 1979, letter to H. R. Denton from D. L. Peoples.
"S.
Plant personnel shall be trained / retrained in the following areas within one month, or prior to startup if required by the Lessons Learned implementation schedule.
Plant personnel should also be retrained in the followiag areas within one month of the time that there are significant changes to the following procedures or requirements:
1934 195
9 Containment and Degraded Core Sampling Degraded Core - Training Emergency Power for Pressurizer Heaters and Decay Heat Removal Containment Isolation Containment Purge / Purge Valve Operation Subcooling Meter Operation Technical Support Center Onsite Operational Support Center Near-Site Emergency Operations Center Emergency Preparedness Plans In-Plant Area Airborne Radioiodine Monitors Surveillance Testing of Non-ESF Filtration System" CECO Comment:
Commonwealth Edison's training / retraining program covers, or will cover when equipment or facilities are installed, these items (except surveillance testing of non-ESF filtration system which is not applicable to Zion).
Additional training in a 30 day time frame will cause more overtime to be worked, without a subsequent gain in expertise.
Commonwealth Edison employs a 5 shift rotation for its operators and provides its shift personnel with special shift folders describing any significant changes in plant operations / procedures upon their return to shift work.
In addition, Commonwealth Edison promptly incorporates these changes in its retraining program.
"6. Requirements regarding reactor operator qualifications shall be revised to incorporate, the following:
a.
The following experience shall be required for senior operator applicants:
Applicants for senior operator licenses shall have 4 years of responsible power plant experience.
Responsible power plant experience should be that obtained as a control room operator (fossil or nuclear) or as a power plant staff engineer involved in the day-to-day activities of the facility, commencing with the final year of construction.
A maximum of two years power plant experience may be fulfilled by academic or related technical training, on a one-for-one time basis.
Two years shall be nuclear power plant experience.
At least six months of the nuclear power plant experience shall be at the plant for which he seeks a license.
1934 196 b.
The hot training programs shall be modified so that the training concentrates on the responsibilitios and functions of the operator, rather than the senior operator.
All individuals who satisfactorily complete this hot training program will be allowed to apply for an operator license, but must have at least one years' experience as a licensed operator before applying for a senior operator license.
c.
The three-month continuous on-the-job training for hot operator applicants shall be as an extra man on shift in the control room.
The hot senior operator applicants shall have three months continuous on-the-job training as an extra man on shift in training.
d.
In addition to the presently approved training programs, all replacement applicants shall participate in simulator training programs.
e.
Phase II, III, and IV cold training program instructors and all hot training program instructors that provide instruction in nuclear power plant operations shall hold senior operator licenses and be required to successfully participate in applicable re-qualification programs to maintain their instructor status.
f.
In addition to the present operator requalification program requirements, all licensecs shall participate ir, periodic retraining and recertification on a full scope simulator representative of their facility.
The frequency of training shall be on an annual basis.
g.
The content of the existing written examinations shall be expanded to include more selective essay type questions on thermodynamics, hydraulics, fluid flow, and heat transfer.
This shall be done by creting new categories for the R0 and SR0 examinations as appropriate.
The length and complexity of the written examinations shall be increased.
h.
Part of the oral / operating test shall be administered using exist'ng nuclear power plant simulators.
i.
The overall passing grade for operator and senior operator written examinations shall be increased to 80% and at least 70% in each category."
1934 197 CECO Comment:
Commonwealth Ed. son's Reactor Operator / Senior Reactor Operator training program is well developed and extensive.
It already provides for on-shift experience prior to assuming duties on a panel or as a supervisor.
Item 6 would, in some cases, impose additional training or experience requirements.
While the imposition of these requirements may, in the long term be worth-while, they would not appear to offer any immediate, interim improvement in the training program.
Additionally, Commonwealth Edison offers the following specific comments.
6c:
The word
" continuous" should be changed to " consecutive (normal shift work with allowances for sickness, personal problems, etc.)" to avoid an interpretation hassle with I&E.
6e:
Delete, as this requirement carnot be met in less than four years given the present shortage of SR0s and tne new requirements for SR0 license applications.
"The following requirements shall be completed within 60 days of the date of issuance of this ORDER:
The following requirements shall be completed within 60 days of the date of issuance of this ORDER:
1.
The licensee snall review the steady state steam generator operating level and propose maintaining optimizing the maintained steady state level witi the intent of maximizing dryout time and minimizing overfill considerations.
The results of this study shall be provided to the NRC witnin 60 days."
CECO Comment:
Westinghouse steam generator levels have already seen optimized for plant safety and reliability.
Any change to steam generator level program to increase dryout time would have a detrimental effect on other transient results and would require setpoint changes.
Therefore, Commonwealth Edison cu.7 curs with the NRC Probabilistic Analysis Staff's appraisal quoted below.
(See January 25, 1980, memorandum from Frank H. Rowsome ta ll. R. Denton):
... we also recommend against tampering with reactor parameters or safety feature actuation setpoints.
Doing so might increase nuisance trips, and thus some risks, by as much or more than the increased margins are worth."
"3.
The licensees shall evaluate the following power reduction measures and limitations of operating parameters:
a.
Determine potential effects on grid stability of reducing power by as much as 50% in both units.
Treat power as a parameter.
b.
Determine effects on plant systems stability impact if power is reduced as much as 50%, treat power as a para-meter.
For example, examine feedwater flow automatic control.
c.
Examine operation of the subject plants under conditions most favorable to ATWS response.
This involves both parameters and response to ATWS conditions, including:
1.
Operate the plants with the most favorable moderator temperature coefficient (MTC) so that the peak pressure resulting from an ATWS transient is limited to upset conditions.
2.
Modify (if necessary) the procedures so that immediate manual scram, immediate manual tripping of the turbine, immediate actuation of AFWS, and early actuation of HPSI are required.
d.
Examine methods of establishing the highest reliability for the IP2 gas turbine.
e.
The licensee shall expedite full compliance with NRC letters concerning AFWS reliability improvements, including for example, bearing cooling dependence on
?.C power."
CECO Comment:
For Items 3.a and 3.b Commonwealth Edison concurs with the NRC Probabilistic Analysis Staff in that risks do not decline any faster with power level than do the benefits.
Therefore, consideration of 50% power reductions at Zion Station will not, in Commonwealth Edison's opinion, reduce the potential risk to the populace.
Item 3.c will be examined as discussed earlier.
Item 3.d is not applicable as Zion Station has no gas turbines.
With regard to Item 3.e Commonwealth Edison already committed in a December 18, 1979, letter from D. L. Peoples to D. G.
Eisenhut to expedite from January 1, 1981, to May 1, 1980, a modification to provide AC independency.
1934 199
. The following requirements shall be implemented within 90 days of the date of issuance of this ORDER:
"2.
The licensees of Indian Point 2 and Indian Point 3 shall jointly identify and review the significant differences between Unit 2 and Unit 3, and shall evaluate these differences in light of present regulatory standards and requirements.
The licensees shall provide a justification for the current design, or provide design change recommendations."
CECO Comment:
This item is only applicaole to Indian Point 2 and 3.
"3.
The licensee shall establish an onsite interdisciplinary review group consisting of, as a minimum, an NSSS vendor representative, an architect-engineer representative, plant maintenance and operations personnel.
This review group will review and approve all existing plant emergency procedures.
This group will also review and approve emergency procedure changes.
Urgent procedural changes may be approved in accordance with current licensee requirements to be subsequently approved by the review group."
CECO Comment:
Commonwealth Edison already has On-site and Off-site Review Groups which provide for multi-disciplinary review and approval of procedures by engineers.
The addition of NSSS vendor and architect-engineer representatives would not add plant specific knowledge nor substantive additional engineering expertise to the review process.
Were Zion Station required to add such personnel, the station management would be forced to take some time away from station operations control to integrate these support persons into station activities.
1934 200 The following requirements shall be completed within 120 days of the date of issuance of this ORDER:
1.
The licensee shall examine key plant system vulnerability areas and possible operator dependent areas within the intent of maximizing the reliability in the subject areas.
Areas that should be specifically examined are as follows:
a.
Verify that the sump for ESF recirculation is free of debris and determine if flow tcst verification was initially performed.
If not, explore means to verify.
Strengthen existing procedures and training on recire alignment and RWST refill.
b.
Strengthen administrative check and verification procedures for assuring that the two single failure points (manual valves) in AFWS supply line are in the correct position.
c.
Impose diesel generator testing according to Regulatory Guide 1.108 with a corresponding change in the allowable outage time stipulated in the Limiting Conditions of Operation as follows:
Number of DG Failures Test Interval Allowable in Prior 100 Tests (R.G. 1.108)
Outage Time 0 or 1 30 As Is 2
14 As Is 3
7 As Is 4
3 32 hr.
5 3
8 hr.
6 or more 3
None*
(moved to 30 day items per telecon) d.
Impose an LC0 stipulating expeditious shutdown whenever the AC independent train of the auxiliary feedwater system and any one of the following are inoperable:
all backup sources of offsite power, one diesel generator, or the other diesel generator, either of the other trains of the auxiliary feedwater system.
e.
Develop station blackout procedures addressing:
1.
grid dispatcher actions 11.
reactor operator actions
)934 20}
iii.
diesel generator repair procedures
- Plant must achieve hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, etc.
. g.
Verify that the gas turbine station has black-start capability.
h.
Explore causes for, procedures for, and operator training required to deminish the overall number or reactor and main feedwater trips.
i.
Develop or review procedures to restore main feedwater promptly after a trip, and procedures /
training on human actions required for ATWS events (e.g., emergency boration and CVCS control).
j.
Strengthen administrative controls on the manual valve (s) whose misalignment can fail all ECCS (RWST line)."
CECO Comment:
la.
Zion Station already verifies the sump free of debris as part of a plant startup from cold shutdown check list.
Flow verification was initially performed as a pre-op test.
Recirc alignment procedures were recently reviewed as part of the Lessons Learned work.
The RWST fill procedure has been reviewed and approved in accordance with approved administrative procedures.
The procedure is used routinely and thus is proven valid.
Ib.
Zion Station already has a procedure for management verification of critical valve / breaker positions.
Ic.
Commonwealth Edison submitted a study on AC power reliability to the NRC.
Id.
Multiple diverse AFW pumps and multiple (3) diesel generators are installed to provide assurance that feedwater will be available whenever required.
le.
Commonwealth Edison grid dispatchers already have instructions for grid blackout and subsequent restoration of power to stations and the public.
Reactor operator actions in a total station blackout are defined as subparts of a series of procedures including RCS natural circulation, steam driven AFW pump operation, manual start of diesel generators, etc.
If.
See Commonwealth Edison commitment in first section of this letter.
1934 202
% 1.
Applicable to Indian Point only.
9 Ih.
Commonwealth Edison has an ongoing reliability improvement program, coordinated by our Station Nuclear Engineering Department, to accomplish just such action.
11.
Procedures for feeding water to steam generators following a trip and other actions required to remove decay heat already exist and have been thoroughly reviewed.
Procedures and training exist related to ATWS events, specifically for failure of rods to insert, e.g.,
emergency boration, lj.
Commonwealth Edison already has a management verification policy at Zion Station.
"2.
A review of control room emergency procedures shall be conducted with the purpose of improving these procedures from a human factors engineering standpoint.
Control room displays shall also be reviewed and improved wherever such improvements will tend to increase the operators' ability to assess plant conditions."
CEC Comment:
This project is, by the nature of its complexity, a longer term action and does not fit the category of " interim".
"The following requirement shall be implemented within six months of the date of issuance of this ORDER:
2.
The meteorological acceptance criteria for emergency preparedness as contained in Appendix I of this ORDER shall be met."
CECO Comment:
Commonwealth Edison already maintains an extensive meteorological network with real time access available at the 1934 203 General Office.
However, all data requested by the NRC is not currently available (e.g., ground level precipitation) and because of equipment procurement might not be available within the suggested six months time frame.
Commonwealth Edison has committed tn install additional meteorological and radiological monitoring equipment as part of its follow-up to TMI-2.
"4.
The licensee shall evaluate the reliability and failure modes of selected systems / components as follows:
Failure Mode Effect Analysis:
Examine the failure modes (random failures and consequences of outages in support systems) of the active components on the reactor coolant pressure boundary.
Assess the acceptability of these failure modes.
Implement Failure Mode Effects Analysis for minor departures from operating, maintenance and emergency procedures.
Explore ways to improve the reliability of those components with a particularly high failure rate as delineated in NUREG/CR-1205."
CECO Comment:
Commonwealth Edison already evaluates Zion Station performance and reliability in some detail.
A special Reliability Engineering Group in our Station Nuclear Engineering Department evaluates causes of outage time and specific component failure histories.
The Off-Site Review Group researches and publishes an annual report summarizing the causes of all LERs.
Each nuclear station is evaluated and cross-station trends are also identified.
Failure mode effect analysis will best be integrated with the probabilistic risk assessment work being performed as part of the Indian Point / Zion Near Site Study.
1934 204
d 18 -
In summary, Commonwealth Edison proposes to take those interim actions which will be meaningful and may offer a substantive reduction in potential risk to the populace.
Commonwealth Edison has reviewed the other NRC suggestions and, as described above, does not find that these actions would provide measurable, substantive reduction in potential risk and could, in fact, be counter-productive to overall plant safety.
Very truly yours, D. L. Peoples Director of Nuclear Licensing 1656A 3934 205
Table 1 STAFFING REQUIREMENTS CECO / ZION STATION FOR NUCLEAR POWER PLANT EMERGENCIES Unit in Additiont Position Title Coerating Mode Within Major Functional Area Major Tasks or Expertise (4) 1 nr 2 1 & 2 One Hour Plant Operations and Assessment of Shift Supervisor (SRO) 1 1
Operational Aspects Shift Foreman (SRO) 1(2) 1(2)
Control Room Operators 2
3 Equipment Operator /
Attendant 3
4 Emergency Direction and Control Shif t Technical Advisor 1(2) 1(2)
(Emergency Coordinator)
Shift Supervisor or designated facility manager Notification / Communication Notify licensee, notify 1(2) 1(2) 1 state local and Federal 1(S) personnel & maintain communication Radiological Accident Assessment Command Center (CC) and Support of Operational Director Senior Manager 1(5)
Accident Assessment (3)
CC Offsite Dose Senior Health Physics 1(5)
Assessment (HP) Expertise Offsite Surveys 4(2)
Onsite (out-of-plant) 2(2)
In-plant surveys Chem /Radchem Sampling Rad / Chem Technicians 2
2 3
Radiochemistry Analysis Chemist 1
Plant System Engineering, Repair Technical Support Shif t Technical Advisor 1(2) 1(2) and Corrective Actions Core 1
Electrical 1
Mechanical 1
NO
'N Repair and Corrective Mechanical Maintenance /
4*
Actions Rad Waste Operator 1(2) 1(2) 2 Electrictl Maintenance /
Instrumer and Control cc)
(I&C) Tec 2ician 1(2) 1(2) 2 CK
Table 1 (Contd.)
Unit in Addition Position Title Operating Mode Within Major Functional Area Major Tasks or Expertise 1 or 2 1& 2 One Hour Protective Actions (In-Plant)
Radiation Protection:
Rad / Chem Technicians 2(2) 2(2) 4 NO
- a. Access Control U
b.
RCT Coverage for 4"*
repair and corrective p) actions.
CD
- c. Personnel monitoring sa d.
Dosimetry Firefighting Fire Brigade Local per Technical Support Specifications Rescue Operations and First-Aid 2(2) 2(2)
Local Support Site Access Control and Security, firefighting Security Personnel All per Personnel Accountability communications, personnel Security plan accountability Total 10 13 25 Minimum (l) 9 12 Notes:
(1)
The minimum number refers only for the case of shift shortage, caused by a sudden sickness or home emergency.
(2)
May be provided by shift personnel assigned other functions.
(3)
Overall direction of facility response to be assumed by Command Center director when all centers are fully manned.
Director of minute-to-minute facility operations remains with senior manager in onsite technical support center or control room.
(4)
During the weekdays, management, technical support, health physics, chemist, and maintenance personnel are available on-site.
(5)
Command Center function.