ML19347D945
| ML19347D945 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 04/01/1981 |
| From: | Garrity J Maine Yankee |
| To: | Clark R Office of Nuclear Reactor Regulation |
| References | |
| TASK-3.A.1.2, TASK-TM FMY-81-52, JHG-81-129, NUDOCS 8104140512 | |
| Download: ML19347D945 (6) | |
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2.C.2.1 JHG 81-129 EDISON DRIVE MAIRE
. HARHEE Arom/CPOWERCOMPARH*
AuausrA, urlNe osaas (207) 623-3521 O
April 1, 1981 FMY 81-52 D
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Lnited States MJclear Regulatory Commission
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Washington, D. C.
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Attention: Division of Licensing Q
A Office of Nuclear Reactor Regulation Mr. Robert A. Clark, Chief O-
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Operating Reactors, Branch #3
References:
( A) License No. DPR-36 (Docket No. 50-309)
(B) USNRC Letter to MYAPCo, dated July 31, 1980 (C) MYAPCo Letter to USNRC (WMY 80-142), dated Octooer 21, 1980 (D) USNRC Letter to MYAPC, dated February 18, 1981
Subject:
Post-TMI Requirements for Emergency Response
Dear Sir:
Your letter, Reference (D), transmitted finalized NRC positions on emergency operations facility location, habitability, and staffing levels for emergency situations.
Those positions were set forth in detail in the
" clarification" enclosed.
You requested confirmation that the implementation dates of your enclosure 1 would be met.
EOF habitability and location Maine Yankea will submit a conceptual EOF design by June 1, 1981 and have the EOF described therein operable by October 1,1982, except that the date of operability will of necessity slip if NRC's preimplementation review of the EOF conceptual design is simultaneously unfavorable and untimely.
Staffing Maine Yankee met with your staff to discuss the matter of shift staffing and response time. During our meeting we provided justification for our intention based upon our operating background and experience.
Your staff agreed that our positions were functionally equivalent to those of the staff's i
Table III.A.l.2-1, and that we submit these arguments formally.
Attachment A provides the requested discussion of our position as detailed at the meeting.
l We have previously committed (Ref. C) to meeting the minimum shift manning implementation schedule, Ref. (B), whicn became action plan item A.1.3.
Maine Yankee personnel presently assignec to the plant are collectively capable of covering all major functional areas, carrying out all major tasks, and are vested with the equivalent of all positions, titles, and expertise shown in the first three columns of the new table III. A.l.2-1.
Adcitional 0 164140
I gr MAINE YANKEE ATOMIC POWER COMPANY United States Nuclear Regulatory Commission April 1, 1981 Attn: Mr. Robert A. Clark Page 2 Office of Nuclear Reactor Regulation expertise and personnel assigned to the corporate offices in Augusta, Maine,
- 32 road miles from the plant site, are readily available. Further, all these personnel, with possibly a very few exceptions, reside within a one hour commute of the plant and contemplated offsite emergency response facilities.
Over the years, we have had good experience in bringing about timely response of off duty personnel to cover unusual circumstances at the plant.
Looking to the future, there are no unusual constraints in the Maine Yankee site area which would discourage or prevent company personnel from living within a reasonably convenient, economical, and desirable commuting distance from the plant. Residence is not prohibited beyond the 610 meter exclusion area boundary, residential property is readily available, and from the perspective of desirability, the region is sufficientity attractive to draw large numbers of seasonal visitors.
In addition, access to the plant site can be gained from a variety of directions via a variety of routes, so no credible transportation problem would block all personnel from traveling to the plant to respond to emergencies.
Thus there is no reason to expect our personnel would be driven in the future to overcome the natural tendency to live close to their work location to minimize commuting time and expense, and by happy coincidence, to be available in the event they are needed at the site to deal with an emergency.
Maine Yankee is in the process of installing a radio paging system capable of extended area coverage to bring about an even more rapid response by company personnel for maintenance or emergency activities. When this system is operational (probably in the early summer of 1981) tne emergency plan and emergency plan implementing procedures will be revised appropriately, and a significant reduction in response time will have been achieved.
We trust this information is sufficient to demonstrate a sufficient capability to augment minimum onsite staff capability under emergency conditions.
We note that, at least to the best of our ability to determine, our approach, in which we commit to making best efforts to augment on site personnel in as timely a fashion as is achievable with existing or planned call in systems.without relocating personnel or imposing upon them unreasonable standby requirements, is consistent with NRC's policies for NRC's own emergency response personnel.
We trust you find this information satisfactory; however, if you have any QJestion, please do not hesitate to contact us.
Very truly yours, MAINE YANKEE ATGMIC power CCMPANY
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M Clu }j\\ Vd.^rVj John H. Carrity, Director Nuclear Engineering & Licensing JHC/plb
h April 1, 1981 Attachment PRIMARY ASSIGNMENTS Since startup in 1972, Maine Yankee has provided minimum shift staffing of five operations personnel (three licensed operators and two auxiliary operators) and security.
In 1980 the minimum shift complement was augmented by two additional personnel, the shift technical advisor and a chemistry /
health physics technician.
Another licensed operator is scheduled to be added to the minimum shift complement by JJ1y of 1982.
As matters now stand, the minimum shift complement as of July 1982 will be:
Plant Shift Superintendent (SRO) 1 Licensed Operator (SRO) 1
' Licensed Operator (RO) 2 Auxiliary Operators 2
Chemistry / Health Physics Technician 1
TOTAL 8
Security per security plan This staffing level and distributicn of qualifications differs from that suggested by Table III. A.l.2-1 in the following ways:
a)
The Maine Yankee staffing concept does not include an individual dedicated to notification / communications.
b)
The Maine Yankee staffing concept utilizes one individual qualified as both a chemistry technician and as a health physics technician rather than two technicians one of whom is qualified in chemistry and one of whom is qualified in health physics.
The differences between the MY minimum shift staffing level and that of Table III.A.l.2-1 are discussed below.
. Operations /STA Same as Table III.A.l.2-1
. Notification / Communications Notification of state and local government personnel of the existance of an emergency condition at Maine Yankee, described in detail in the Maine Yankee emergency plan, is accomplished through a single short message to the Maine State Police.
The Maine State Police in turn, in accordance with the State Emergency Plan, activate a notification process which extends to the appropriate state and local levels independent of further action by Maine Yankee.
The message from Maine Yankee ta the State Police can be transmitted and verificd within one minute.
Notification of the Federal Government by Maine Yankee is accomplished by the hotlines installed in the control room.
This initial notification can also be carried out very rapidly.
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April 1, 1981 Notification of Maine Yankee personnel is, as explained in the cover letter,:to be accomplished by radio pager messages to key personnel.
The paging system is such that with one telephone call utilizing the in plant PBX the notifier can select one of many predesignated subsets of all Maine Yankee pagers and record a short message for automatic broadcast.
Notification of corporate headquarters personnel and affiliated company personnel is initiated by a call to the system dispatcher via a control room microwave link.
Notification of Nuclear Services Division personnel is accomplished by a single telephone call to the NSD radio pager dispatching equipment.
Thus all necessary initial notifications can be accomplished in the equivalent of five or less telephone calls each of very short duration which can be carried out from the control room.
The notification message transmitted in each case described above will contain information directly relating to the severity of the emergency condition and the degree of mobilization required.
Preplanned response capability mobilization can be implemented without recourse to further information.
Following initial notification, some finite time is required to bring about mobilization to the point where preplanned actions leave off and action options must be selected based on additional informtion.
At this time continuous communications with decision makers may be needed.
However, the capability to continuously provide information need not be present until there is also present the capability and necessity to use it.
In summary, initial notification can be accomplished expeditiously by on shift personnel and heavy follow up traffic will not be needed until after offsite personnel can be brought in.
It should also be noted that a telephone talker does not require much specialized training, so essentially the first person available could do the job if necessary, although it is highly desirable that a knowlegable individual be assigned so the quality of information passed on is assured.
The requirement to man the NRC hotline can be covered by control room personnel until relieved.
It does not appear that there is a need to have an individual on shift at all times whose primary mission is to provide continuous communications capability in the event of an emergency condition, but who is not really needed in normal circumstances.
. Chemistry / Health Physics Technician The technician currently assigned to each shift is qualified as both a chemistry and health physics technician and is thus able to render needed assistance or support in these areas. Since these personnel are already trained, cross trained, and in place, we would prefer to leave tnis undisturbed.
SECONDARY ASSIGWENTS
. Emergency Direction and Control.--.
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April 1. 1981 The Maine Yankee emergency plan assigns _ emergency coordination 1
~ responsibility to the Plant-Shift Superintendent until he is relieved by i
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. another EC qualified individual arriving on site.
. Plant. System Engineering, Repair, and Corrective Actions Auxiliary operators acting under the direction of licensed operators are.
responsible for alignment and operation of plant components, subsystems and systems.
To the extent that corrective actions can be accomplished within this scope these individuals would carry them out.
The auxiliary operators operate radwast systems.
Maintenance at a nuclear power plant is a very precise, controlled, and well supervised activity, conducted in accordance with standard or special procedures and focused at assuring quality work. We are reluctant to accept the placement on shift of a maintenance individual, because this addition carries with it the inherent implication that there would be maintenance activities conducted on shift that may be somewhat spontaneous or reactive in nature.
It has been our experience that preparation for maintenance work requires time to permit system line-up, tag out, radiation work permit preparation, and sometimes material issue.
Again, our experience is that the standard call-in response which has been used to satisfy our maintenance needs in the past provides a full complement of individuals necessary to execute a maintenance function in less time than is required to prepare the plant as
_ suggested above.
1 Since the plant is designed with an inherent redundancy in safety systems, there is no need for spontaneous maintenance activities on shift.
There is l
substantial down-side risk in having single maintenance individuals performing i
any but the most rudimentary tasks. -Reaction type maintenance, done hurriedly, without supervision, with inadequate numbers of people is definitely not beneficial. While the potential for quick maintenance and repair sounds appealing, experience shows that any maintenance and repair i
without proper review, qualified supervisors, and quality assurance can create more problems than it solves.
Practically, maintenance functions in the I&C, electrical and mechanical areas are special deciplines. During an emergency situation, little meaningful work can be done by a single individual. Should maintenance be required, additional personnel would be called on site.
An on-shift j
maintenance capability is not necessary for emergency response since meaningful maintenance assistance is available on short notice through call in, i
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. Protective Actions (in plant)
Auxiliary operators and licensed operators are qualified in use of survey instruments carried by plant personnel when entering high radiation areas in
- the course of carrying out their normal duties and have a working knowledge of access control, personnel monitoring, and dosimetry.
In emergencies involving contamination of plant areas these personnel are able to apply their knowledge 4
j-to determine the extent of contaminated areas and could limit access to these l
. ares by various means as needed.
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g April 1, 1981
. Firefighting-Covered in technical specifications
. Rescue and First Aid
' The emergency coordinator directs rescue operations which can be carried
. out by chemistry / health physics technicians, operation personnel, and security personnel.
There is at least one individual on each shift qualified for first aid through completion of Red Cross Multi Media first aid course.
OTHER
. Site Access Control Aid Personnel Accountability The Maine' Yankee security plan describes the minimum security force on-each shift.
The security force will carry out emergency activities including
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personnel accountability and plant or site access control in accordance with security procedures.
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