ML19320C041
| ML19320C041 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 07/03/1980 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | Harold Denton, Grimes B Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0654, RTR-NUREG-654 NUDOCS 8007150682 | |
| Download: ML19320C041 (6) | |
Text
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wisconsin Electnc ecua cour>ur 231 W. MICHIGAN. P.O. BOX 2046. MILWAUKEE, WI 53201 July 3,1980 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. NUCLEAR REGULATORY COMMISSION Washington, D. C.
20555 Attention: Mr. Brian K. Grimes, Director Emergency Preparedness Task Group Gentlemen :
COMMENTS ON NUREG-0654 In January 1980, the NRC and FEMA jointly published for interim use and comment a document containing minimum acceptance criteria for radiological emergency planning and preparedness.
That document is MUREG-G654/ FEMA-REP-1, " Criteria for Preparation and Evaluation of Radiological Plants". Since its publication, we have had the opportunity to first review cnd than utilize this document as an aic to preparing a draft revisica to tae Emerger.y Plan for our Point Beach Nuclear Plant.
This draft revision was 1
prepared in response to the NRC's proposed rule on emergency planning and was discussed with the NRC Emergency Planning Review Team during their visit to the Point Beach site on May 21 and 22, 1980.
i Although there are several areas of the interim guidance wnich can be considered excessive and unrealistic, we have specific ccr.ents on two particular objectionable items in this NUREG.
These items are the requirement to provide capability for 15-minute public notification and the requirements for minimum shift staffing as contained in Table B-1.
Wa believe the 15-minute time frame proposed to complete a public notification is inappropriate for the risk concerned. Although we support the concept of advanced planning to provide for public notification or evacuation when such becomes necessary, we cannot foresee a situation which would mandate that this notification take place within the first few minutes of nuclear incident situation. We are much concerned with the unfounded stress and misunderstanding this unreasonably rapid notification would undoubt-edly generate. We note that the Advisory Committee on Reactor Safeguards in their letter to the Commission dated May 6,1980, expressed a number of concerns with this proposed public notification requirement. We concur with the ACRS concerns.
Of all the many potential risks that accompany various facets of [h 8007150 @ 7-jo
'Mr. Harold R. Denton July 3,1980 modern technology, the radiological hazard associated with potential nuclear plant accidents is perhaps the most benign, since it affords adequate time for response.. The. urgency for immediate action, such as that accompanying plane crashes, chlorine tank explosions, and other similar catastrophes, does not. exist in the case of a realistically considered radiological en,ar-gency. A small or moderate dose is not harmful, and the goal of evacuation 4
planning is to move surrounding residents to avoid the buildup of dose over a period of time. The point is that time is available to act in an orderly and reasoned manner, and a need for the immediacy implied by the proposed 15-minute notification does not exist. Hence, implementation of a 15-minute notification appears to be-an inappropriate c.llocation of societal resources.
Conversely, if such notification were deemed appropriate for radiological emergencies, numerous other technological hazards would require similar attention on a priority basis.
For all these reasons, we object to the provision of a 15-minute notification requirement.
We.are also concerned about the propriety of the minimum shift staffing requirements proposed in Table B-1 of NUREG-0654. The proposed minimum shift complement for a two-unit station is listed as 13.
This includes one shift foreman, one control operator, and one auxiliary operator for the unaffected unit. This proposed minimum shift would necessitate the addition of five people to che present Point Beach Nuclear Plant minimum shift staffing of eight people. Table B-1 fails to recognize that all facil-ities are.not alike and that specific plants have significant differences which may not necessitate this expansive plant staffing. At Point Beach we do not believe that any additional shift personnel are necessary. The Point Beach units have a common control room and duplicate or shared facilities in a common auxiliary building. Thus, there is no necessity for three additional people to continue operation of the unaffected unit. As suggested by the NUREG, one person may fill more than one function as long as the individual does not become so overburdened that his tasks become unmanageable. Thus, where the table lists a separate individual whose sole function would be to notify _ licensee, state, local and federal' personnel, we believe this function can be adequately handled by shift personnel until the on-call superintendent arrives on site. Similarly, there should be no necessity to maintain separate health physics and radiochemistry technicians on shift if the shift auxiliary operators have been adequately trained to perform survey, sampling and other health physics functions.
The proposed guidance also fails to consider assign-ments for these extra people specified for the minimum shift during normal plant operations. The prospect of having idle or underutilized personnel on shift is demoralizing to the personnel involved, and unnecessarily, expensive.
.We have attached for your review a modified Table B-1 based on our present shift staffing which meets the requirements for responding to nuclear power plant emergencies. This table also modifies the numbers and response times of the reconinended backup personnel. Except for the duty and call superintendent, who is available and needed within 30 minutes, we believe
. that backup staffing within 60 minutes is sufficient for plant emergency response.. We would further' point out that the _ rural location of Point Beach
'and other nuclear plant. facilitates a rapid response time to plant recalls.
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-u Mr.' Harold R. Denton July 3, 1980 Plant employees are located within minutes of the site and in general have a selection of several direct, hazaro free and well maintained travel routes to the site. Thus, the ability to have additional personnel at the site in a very short time'is not impeded by transportation problems or traffic delays and the requirement to maintain additional staff on-site is unnecessary.
We appreciate this opportunity to comment on this interim guidance.
We trust you will consider these comments, and the many other comment letters you have received, in arriving at a more realistic and practical guidance on emergency planning criteria.
Very truly yours, C. 'J. Fay, Director Nuclear Power Department Attachment 4
1 tl POINT BEACH NUCtEAR PLAtli STAFFING Position Title on
-Major Functional Area Major Tasks or Expertise Site Within 60 Minutes 2 a.
Plant Operations -
Shift Supervisor (SRO) 1 Operating Supervisor (SR0/RO) 1
- b. ' Assessment of Control Room Operators (RO) 2 Operational Aspects Auxiliary Operators 3
- a.
Assessment of Emergency Duty Technical Advisor I
and Classificatfor, b.
Notification /
Notify State, local and Shift Supervisor I-Comunication Federal personnel and maintain coumunication links c.
Emergency L..ection Duty and Call Superintendent I (within 30 minutes) and Control a.
Radiological Accident Technical Support Center Duty and Call Superintendent II (within 30 min.)
Assessment Director Off Site Dose On Call Chemistry & llealth Assessment Physics Supervisor 3 1
b.
Support of Operational Off Site Surveys Off Shif t Auxiliary Operators 2
Accident Assessment On Site (out of plant) and/or IIcalth Physics Callout 1
In Plant Surveys Auxiliary Operator 11 Chemistry / Radiochemistry Rad /Cinem fechnicians 1
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Point Beach Nuclear Plant Staffing Page 2 Position Title Ort I
Major Functional Area Major Taske or Eppe s tlee Site within 60 Minutma Plant System Engineering, Tecimical Sqport Duty Tactmical Advloor 1
w pair and Correct!=e core, t;tectrical, Hochanical 2
Awtlone (Other Tacimical Advisore and/or Duty & Call Sgt.)
Depair and Corrective Hect.anical Maintenance" 2
Action it.hl Waste Ogeratur (Aua111ery c,.oratos) 13 Electrical Maintenance %
21 Instrumm:nt & Control it & C)
Tect.nician 1
s Protect 1we Actions Radiation Protection lleenth Ptiyeice Technician II 4
I (In-Plant)
- a. Access control
- b. Health Physica coverage for repair, corrective actione, nearch and rescue, first aid, and firefighting
- c. Personnel sonitoring d.
Doelmetry rarefighting Fire Brigade Eeergency callout and per Tecimical Two Creeke volunteer Specificatione Fire thrpartment
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I Polsat Beach Nuclear Plant Staffing Page 3 Positions Title On Major Punctional Area Major Taske -
or Empestime S!ts Within 60 Minutest Descue Operatione anJ At least one security force g
First A1d pes son and one gerson on shift 2I Local suggert Site Access' Control and Security, firefighting, Security persosanel Personnel Accountability commustications, persosenel accountability 1EFTAL 8
15 tams I May be provided I,y personnel assigned other functions.
2 ft.e additional people are not c=ltted other than the raaty s call..u... a l s.t
..de nt.
Tin,. siusters of additional people are conservative estimates of people availab!!1ty based on previous caltuut emp4; esa c.
3 Auxiliary Operatore are qualified Isaalth Physics Technicians.
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b All Maintenance personnel ase qualified far both mechanical ased electa ncel s.43..at re.
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Table B-1 aug< pests an additional Operating Steervisor, Contaul Operator, and Aaamillary Operator for the unaf fected unit. Point Beach fluclear Plant, with its combined control room and cospied fac111 ties, does swt requisu edditional staff to continue operating the unaf fected unit.
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