ML20003E910
| ML20003E910 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 04/14/1981 |
| From: | Heider F VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| TASK-3.A.1.2, TASK-TM FVY-81-65, GL-80-10, NUDOCS 8104170487 | |
| Download: ML20003E910 (10) | |
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l VERMONT Y ANICEE N UCLEAR POWER CORPOR ATION SEVENTY SEVEN GROVC sTREcT 2.C.2.1 RUTLAND. VEMMONT 05701 FVY 81-6.7
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ENGINEERING OFFICE is7 w ncESrEn noAo April 14, 1981FR AMINGH AM. M ASS ACH USETTS O170' TELEPHONE S17 872-8100 United States Nuclear Regulatory Commission Washington, D. C.
20555 Attention:
Mr. Darrell G. Eisenhut. Director Office of Nuclear Reactor Regulation
References:
(a)
License No. DPR-28 (Docket No. 50-271)
-9 (b) USNRC Generic Letter 80-10, dated February 18, 1981 (c) USNRC Ceneric Letter #17, dated March 5,1981 (d)
" Realistic Estimates of the Consequences of Nuclear
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Accidents," Levenson, M. and Rahn, F.
Subject:
TM1 Action Plan item III.A.I.2
Dear Sir:
Ref erence (b) provided clarification of TMI Action Plan Item III. A.l.2 -
Upgraded Emergency Support Facilitics, and requested confirmation that the implementation dates indicated would be met.
This letter responds to this request and provides descriptions of the functional compliance to (1) the shift staffing and augmentation capability and (2) the emergency operations facility requirements. This information is provided below.
A.
Shift Staffing and Augmentation Enclosure A provides a description of our plans to comply with the functional intent of the shift staffing requirements.
Our experience in nuclear operations supports our conviction that the staffing levels described in Enclosure A assures adequate coverage for prompt emergency plan implementation.
B Emergency Response Facilities The conceptual design information as requested will be provided by June 1, 1981.
Enclosure B provides a description of the Emergency Operations Facility (EOF) arrangement we intend to implement by October 1, 1982. This arrangement has been reviewed against the NRC guidelines and we conclude that no additional modifications to the G
near site E0r are necessary since we meet the functional intent of
.e guidelines.
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United States Nuclear Regulatory Commission April 14, 1981 Office of Nuclear Reactor Regulations Page 2 We trust this infor... tion will be satisf actory for your review. Although Enclosures A and B describe Mternative proposals, we believe the functional intent of Reference (b) has been met.
If you desire additional information or have any questions.
.ase contact us.
Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION
/
L. H. Haider Vice President l
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f Enclosure A Description of Functional Compliance to Shift Staffing and Augmentation Capability Vermont Yankee Nuclear Power Corporation Vernon, Vermont Vermont Yankee Nuclear Power Corporation is, in principle, in agreement with the shift staffing outlined in Table III.A.1.2-1.
We feel that our approach to shift staffing is f unctionally consistent with the NRC position and, additionally, is a more ap; ropriate and eff ective use of personnel.
In addition to our own operating experience, Vermont Yankee is able to draw on the resources of the Yankee Atomic Electric Company in this area. The Yankee organization has had over 20 years of experience in operating and staffing the 7
Yankee plant at Rowe.
Until last year, the back shif ts at both Vermont Yankee and Yankee Rowe have typically been manned by 5 professionals - 3 licensed individuals and two auxiliary operators.
Last year the nominal shif t was increased by two - a shif t technical advisor and a health physics and chemistry technician.
By July of 1982, an additional licensed individual will 4
be put on shift thus increasing the total complement of shif t personnel to 8.
Our experience in nuclear operations supports our conviction that the staffing levels described above assures adequate coverage f or prompt emergency plan implementation and, although it may appear diff erent than outlined in the table, the difference is more in f orm than in substance. The following specific comments are provided to demonstrate how we comply with the f unctional intent of shif t staffing requirements.
Emergency Health Physics and Chemistry Table III. A.1.2-1 requires an health physics technician and a rad / chem technician to be part of the on-shift staff.
The aggregate of capabilities of our on-shift health physics and chemistry i
I technician and the basic health physics knowledge of other shif t personnel make the addition of an on-shift rad / chem technician unnecessary.
Our on-shift health physics and chemistry technician will be trained and qualified to implement the immediate radiological response actions necessary in an eme rgency. The specific actions would be immediately prioritized to respond to the particular radiological needs dictated by the emergency condition.
Typical immediate duties performed by our health physics and chemistry technician.would include radiological habitability assessment of the Control Room, assistance in radiological release assessment, health physics guidance and support to shift personnel assigned emergency duties outside the Control Room, and certain chemistry analysis that may be needed early in the accident.
In addition to the health physics capability of our on-shift health physics and chemistry technician, our operators have knowledge and capabilities in basic radiation protection.
This includes f amiliarity with the use of survey instruments to support their activities in an emergency.
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e The necessity of performing more radiological duties than can be supported by l
our current on-shif t staff does not exist in the early time f rame f ollowing an l
accident. More radiological functions would be initiated as the on-shif t staff is augmented by additional personnel as they arrive at the TSC and EOF.
Emergency Notification / Communications j
According to our Emergency Plan, the Plant Emergency Director (typically the j
Shif t Supervisor) must assure that the NRC and the states are notified of the emergency condition. In our shif t structure, an initial notification to the i
NRC will be conducted by an individual with the experience and level of,
understanding and knowledge of the plant such that he could fully apprise the NRC of the status of the plant (i.e., the Shift Supervisor). Following the j
initial notification, we will maintain an open line using a diff erent individual whose role will be to act as a " phone holder" and as such would relay messages between the Shif t Supervisor and the NRC.
One of the people summoned to the control room would be assigned this task until relieved, in a short time, by plant staff activating the Technical Support Center.
Realistically, NRC could not do anything to assist the plant on such short notice in any case.
Once the TSC and EOF are established, as well as the NRC Emergency Response Center, the flow of communications between these locations l
will take place.
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State notification procedures called for in the Emergency Plan also require prompt notification of the emergency classification, dose rate projections, I
and recommended protective action.
The Emergency Director assures this contact is made to the designated state agency so that the state may activate its emergency response plan at a level corresponding to the emergency classification. Following the initial contact, state health department officials would then call into the plant for additional emergency information which would be supplied by a qualified individual.
In the short-te rm, little additional inf ormation will. be required by the state I
since according to the new Emergency Plan, the emergency classification system is designed to indicate level of necessary response.
By the time th,e state is mobilized to deal with the emergency, an EOF will be established near the site and direct communications dealing with off site radiological consequences will have been established.
Thus, due to the nature and objective of the new emergency planning philosophy which calls for emergency classifications to clearly indicate level of emergency response, there is no need nor basis f or separate on-shif t communications person to handle immediate notification / communication l
requirements called for in our Emergency Plan.
In addition, we strongly believe that based on the TMI experience, that the quality information is
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extremely important and it is our intention that only qualified and knowledgeable persons respond to NRC and state inquiries in the short tere from the Control Room and in the longer term from the TSC and E0r.
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Emergency Maintenance Since maintenance (i.e. mechanical, electrical, instrumentation and control) at our plant is a very precise, controlled, and well supervised activity which is conducted in accordance with standard or specially prepared procedures and f ocused at assuring quality work, we do not accept the desire to have on-shift capability for maintenance " repair and corrective action".
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 in the years of plant operation that preparation f or maintenance work requires time to permit system line-up, tag out, radiation protection considerations 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.
Since the plant is designed with an inherent redundancy in safety systems, there is no need for spontaneous maintenance activities on shif t.
There is substantial down-side risk in having single maintenance individuals performing 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 to the NRC, Vermon Yankee's experience shows that any maintenance and repair without proper review, qualified supervision, and quality assurance can create more problems than it solves.
Practically, maintenance functions in the I6C, electrical and mechanical areas are special diciplines.
During an emergency situation, little meaninF ul work f
can be done by a single individual.
Should minor repair, alignment ata or operation of plant components be required, auxiliary operators under direction of a licensed operator would perform the necessary actions.
Should significant emergency maintenance be required, additional personnel would be called on site.
During their travel time, the plant could be making preparations for their prompt access to effect repai r of aff ected systems.
Thus, based on our experience, an on-shif t maintenance capability is not necessary for emergency response since meaningf ul maintenance assistance is I
available on a call-in and timely basis as the next section f ully describes.
Augmentation Capability in Emergencies We f ully agree that emergency conditions require rapid plant staff I
augmentation to the on-shift personnel.
Our Emergency Plan and implementing procedures recognize this directly as we call for plant staff notification as an immediate action following the declaration of an emergency.
This notification is done by radio pager activation f or the top level plant staff and by telephone contact f or the remaining staff needed.
All notified staff l
would respond to activate the TSC, OSC, and EOF emergency organizat ions and f unctions.
As can be seen on Table 1, the travel times to Ve rmont Yankee, based on d
existing housing patterns support the NRC objective of 30 and 60 minute augmentation capability as identified in Table III.A.l.2-1.
While we wholeheartedly endorse the response times as goals, we feel that making them a requirement subject to I&E enforcement actions goes beyond reasonable reg ula t ion.
Consequently we are opposed in principle to NRC regulations that f orce specific housing and behavior patterns on individuals.
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In addition, we f ail to see the need for going beyond the goal formulation of the objective.
Due to the presence of the STA and improved operator training we can see no measurable impact on accident control or restoration if a person arrives in 35 or 45 minutes. Thus, while we can support the goal and objective of 30 and 60 minute augmentation capability, we fail to see any need l
to make it a requirement and in so doing negatively impacting morale and unnecessarily intruding in the private lives of plant employees particularly if our demographics and past experience indicate that we can achieve the goal.
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TABLE 1 TRAVEL TIME TO VERMONT YANKEE PERSONNEL AVAILABLE WITHIN SPECIFIED TIME Position 15 Min.
30 Min.
45 Min.
I&C Supervision 1
1 Technician 4
2 Maintenance Supervision 4
2 2
Mechanical 4
5 Electrical 1
2 Chemistry & Health Physics Supervision 3
1 Technicians 6
2 1
Operations Personnel 16 17 5
Reactor Engineering / STAS 4
5 1
Technical Support 8
9 2
Plant Management 2
1 Plant Support (stores, admin.)
8 12
Enclosure B Description of Functional Compliance to Emergency Operations Facility Requirements Vermont Yankee Nuclear Power Corporation Vernon, Vermont The current emergency preparedness arrangements for Vermont Yankee include the designation and use of a primary EOF located in an existing structure 1350 feet from the plant.
It is our intent to modify our procedures to designate as the alternate EOF the Vermont Yankee Operations Office in West Bra tt le boro,
The Vermont Yankee Operations Office is located approximately 7 miles f rom the plant. As can be seen on the enclosed topographical map, this location would provide greater protection f rom airborne releases than would an EOF located 10 miled f rom a station with flat intervening terrain.
Vermont Yankee is located in the Connecticut River Valley which runs essentially north-south past the station. The valley walls rise 600-700 feet above the river and the predominant wind flows, as observed by the meteorological monitoring system at the site, are up and down valley flows.
The West Brattleboro office is approximately 3 miles due west of the Connecticut River, at its closest point, and is outside of the valley boundaries.
It is believed, theref ore, that this alternate location would meet the intent of the NRC's 10 mile separation criterion.
Our emergency f acility use plan will call for early activation of the alternate EOF for any Site Area, or General emergency.
Under this concept our emergency implementing procedures would provide for activation of the alternate EOF communications and dose projection capabi'ities.
Should a transfer f rom the near site EOF be required in the extreme condition of an accident beyond the Design Basis Accident, no lapse in dose projection information or communications would occur.
The near site EOF contains radiation monitoring equipment.
Procedures exist to continuously assess EOF habitability. This radiological surveillance provides early warning of any need to transfer the critical EOF functions of dose projection and communications to the alternate EOF.
Should the extremely unlikely Class 9 type accident occur - a General Emergency with potential loss of containment - it is our intent that the alternate EOF would be f ully activated directly. Should a Site Area emergency degrade to a General Emergency with potential loss of containment functions, there is sufficient time and continuity based on simultaneous activation described earlier to transfer locations without interruption of the flow of vital information. The conclusions of the Reactor Safety Study support the warning time necessary to eff ect a transfer to the alternate EOF.
Control Room instrumentation provides sufficient information to determine whether direct activation of the alternate EOF is required.
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The concept of our EOF facility u e plan, which does not call for using the near site EOF for Class 9 accident, makes the issue of near site EOF protection factors and ventilation isolation with HEPA filters moot.
Under Design Bases Accident Conditions, the 30-day plume exposure whole body dose at the near site EOF is less than 10 rems (neglecting protection f actors). This is well below the 25 rem emergency worker PAG identified in NUREG-0654 (Planning Standard K).
An additional justification for eliminating the HEPA requirement is found in an EPRI report by Levenson et a1 [ Reference (d) of the cover letter].
this report concludes that, based on actual reactor accidents and controlled experiements, the predicted release of iodine and particulates are greatly reduced relative to the noble gases. This report goes on to point out that the fission product behavior models in WASH-1400 neglected s,ignificant ae rosol removal mechanisms, such as particulate aglomeration and wall deposition, in predicting particulate releases. The reasoning that resulted in eliminating the requirement for a charcoal filter should likewise be applied to the HEPA filter. We do not feel that any filtration system is warranted in the near site EOF.
For a vast majority of accidents therefore, the primary EOF as-built is expected to be habitable for the duration of any significant radiological release. The conclusion of our evaluation of the near site EOF, based on our approach, against the NRC's guidelines is that no additional modifications such as upgrading to achieve facility protection factor increase and augmented filtration ventilation systems are necessary because we satisfy the f unctional intent of the guidelines.
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