ML19345G515

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Forwards Response to 810218 Ltr Re Schedule for Implementation of post-TMI Requirements for Upgrading Emergency Response Facilities
ML19345G515
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 04/02/1981
From: William Jones
OMAHA PUBLIC POWER DISTRICT
To: Eisenhut D
Office of Nuclear Reactor Regulation
References
NUDOCS 8104070424
Download: ML19345G515 (3)


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Omaha Public Power District 1623 HARNEY O M AN A. NEBRASKA 68102 TELEPHONE 536-4000 AREA CODE 402 April 2, 1981 Mr. Darrell G. Eisenhut, Director U. S. Nuclear Regulatory Comission Office of bciear Reactor Regulation Division of i.icensing Washing'.an, D.C. 20555

Reference:

Docket No. 50-285

Dear Mr. Eisenhut:

In response to the Comission's letter dated February 18, 1981, Omaha Public Power District's schedule for implementation of the post-TMI requirements for upgrading emergency response facilities and staff-ing levels for emergencies is attached.

Sincerely, W. C. Jones Division Manager Production Operations WCJ/KJM/TLP:jmm Attachment cc: LeBoeuf, Lamb, Leiby & MacRae

1333 New Hampshire Avenue, N.W.

! Washington, D.C. 20036

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o Commission's Requirement For operating reactors, the upgraded emergency response facilities conceptual design shall be submitted by June 1, 1981. For operating license applications, such design information should'be provided in connection with the OL review process. The upgraded facilities shall be operational by October 1,1982, for all facilities licensed for oper-ation prior to that date. For OL expected to be issued after October 1, 1982, the upgraded facilities shall be operational prior to receiving an operating license.

District's Response The conceptua' design for the Fort Calhoun Station's upgraded emergency response facilities will be submitted to the Commission by June 1, 1981. However, it is anticipated that the facilities will not be fully operational until June,1983.

The onsite Technical Support Center (TSC) building is presently near completion. The Emergency Operations Facility (EOF) building should be completed by October 1, 1982. Hardware for data display and acquisition should be onsite by October 1, 1982. However, integration of the emergency response data instrumentation with the existing plant process and safety circuitry will require the plant to be at cold shut-down for at least two mo6ths. Therefore, the District intends to com-plete installation of the data display systems for the emergency re-sponse facilities coincident with the refueling outage scheduled to start November,1982, and finish February,1983.

Another four months should be allowed to debug the data systems prior to imposing Technical Specification limits on availability and operability. Therefore, the earliest date the emergency response facilities can be expected to be fully operational is June,1983.

It should be noted that the time estimates provided above are based upon the assumption that Fort Calhoun's existing instrumentation is adequate and that a commercial grade computer system will meet the data acquisition and display requirements of NUREG-0696.' If existing in-strumentation must be fully upgraded to Regulatory Guide 1.97 criteria, the' schedule may be delayed.

Commission's Requirement Table III.A.1.2-1 (Table B-1 to NUREG-0654, Revision 1) establishes staffing levels for_ emergency situations. The revision of NUREG-0654 establishes staging of staffing for 30 to 60 minutes rather than re-quiring capability for required augmentation at -30 minutes. The imple-mentation schedule for licensed operators and STA on shift shall be as specified in Task Action Item I.A.1.3. Any deficiencies in the other staffing requirements of the table must be capable of augmentation within-30 minutes _by September 1, 1981, and such deficiencies must be fully removed by July 1, 1982.

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District's Response The District has evaluated the staffing requirements detailed in Table B-1 of NUREG-0654, Rev.1, against the numbers and qualifications of people presently employed at the District. As a result of this evaluation, the District is unable to commit to the Commission's schedule for full implementation of the Table B-1 staffing requirements.

The District presently has eight employees on shift full time, excluding security personnel. The District is presently investigating required training and staffing needs to meet the requirement for ten people to be on shif t full time by July 1,1982. The District will advise the Commission of any problems in meeting this schedule.

The requirement to ensure an additional 11 men can be on site within 30 minutes and another 15 on site within the next 30 minutes is

, presently beyond the District's capabilities. In total numbers, there are qualified people available to augment.the plant staff in all of the functional areas identified. However, to meet tne minimum staffing capability required within 30 minutes with 100% certainty, the District would be required to take some measures that are higniy impractical, if not impossible. The number of personnel qualified to perform the functions required by Table B-1 and also living within 30 minutes of the plant is minimal. For example, Table B-1 requires a total of five Health Physics / Rad. Chem. Technicians be on site within 30 minuter.

There are presently only four. qualified technicians living within 30 minutes of'the plant. To ensure availability of these four technicians, they would have to be on call at all times. The other option would be l

to require other. technicians to move closer to the plant. Either option is highly undesirable, if not infeasible, given the constraints existing with the current labor contracts. A third option evaluated was to train additional people, but for several functions (e.g., Health Physics / Rad.

Chem. Technicians) a high level of expertise is required and training of inexperienced people would dilute the expertise required and, although the letter of the law could be met, the intent would be defeated.

Therefore, the District is unable to cocait to the augmentation re-quirements imposed by Table B-1 and ~ recommends the Commission re-evaluate their criteria to establish more realistic-requirements. Given the location of most plants relative to papalation centers, and especially the staffing available at a single unit plant, the District finds the Commission's present staffing requirements untenable. Allowing 60 minutes for augmentation would be much more realistic, although the

, District's evaluation has identified some concerns in the ability to achieve a 60 minute on site augmentation for all functions.

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