ML20004E800
| ML20004E800 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/01/1981 |
| From: | Morisi A BOSTON EDISON CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| 81-121, GL-81-10, NUDOCS 8106150287 | |
| Download: ML20004E800 (12) | |
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BOSTON EpisON COMPANY GEMENAb OFrscss 500 SovkaroN STuser 50STON, MASSACMUGET7 3 Q219 9 A. V. MO RISI June 1,1981 MANAGEm NUCLEAR OPERATIONE SupsPORT DEPARTMENT BECo Ltr. #81-121
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g Mr. Darrell G. Eisenhut, Director D
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I Division of Licensing 6
gO'Y Office of Nuclear Reactor Regulations y'#' gIDl 2 7p g h !-11 U.S. Nuclear Regulatory Coninission
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Washington, DC 20555
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REFERENCE:
(A) NRC Generic Letter 81-10, dated February 18, 1981,
" Post TMI Requirements for the Emergency Operations Facility"
Dear Mr. Eisenhut:
In response to Reference (A), the following information is provided:
Attachment A - Functional Compliance to Minimum Staffing Requirements for Nuclear Power Plant Emergencies.
Attachment B - Pilgrim Station Emergency Response Facilities.
We submit that these attachments outline acceptable methods for meeting related emergency response criteria.
If you require additional infonnation, l
please contact us.
1 Sincerely,
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ATTACHMENT A FUNCTIONAL COMPLIANCE TO MINIMUM STAFFING REQUIREMENTS FOR NUCLEAR POWER PLANT EMERGENCIES (NUREG 0737, Table IIIA.l.2-1)
(NUREG 0654, Table B-1
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Boston Edison has established a well balanced integrated organizational structure to provide for overall management and technical support of the Pilgrim Nuclear Power Station. This support is also specifically indicated in the PNPS Emergency Plan to' accomplish the overall emergency preparedness objectives for l
accident assessment, response, mitigation and recovery efforts.
In developing i
this emergency plan, we have analyzed all of the functions necessary to meet these objectives and fulfilled these functions from the inherent skills and capabilities of our well balanced integrated organization.
Present minimum staffing requirements at Pilgrim Station include one licensed (SRO) Nuclear Watch Engineer; one licensed Nuclear Operating Supervisor (SR0):
one licensed Nuclear Plant Operator (RO): two unlicensed Nuclear Plant Operators; one Nuclear Auxiliary Operator; one Health Physics Technician and one Shift Technical Advisor. Therefore, our present minimum complement is eight (8) individuals.
In addition, we are presently staffed with radiochemistry coverage two shifts / day, five days / week and one shift / day on weekends. Also, instrument and control coverage is presently two shifts / day, six days / week.
.0ur experience demonstrates that the staffing levels described above assure adequate coverage for prompt emergency plan implementation. The present staffing has been reviewed discipline by discipline in terms of the time frame required to activate the emergency organization. This review has demonstrated that although we can meet the intent of the Table A.l.2-1 requirements,we cannot specifically comply with the rigid time requirements.
Although unable to meet your schedule, it has been detennined that all of the emergency functions can be activated in a timely manner so as not to impede the continuity of the immediate assessment, mitigation and response functions. We have examined in practical tenns the locations of the residences of l
all of the plant personnel with immediate emergency responsibilities and have out-I lined on Table 1 the response times from their residence to Pilgrim Station. The response time demonstrated on the Table are realistic estimates based upon the time i
required for an individual awakened from their sleep by a telephone call to get dressed and travel to the station and respond to their emergency assignment.
While Boston Edison endorses the appropriate functions reauired for effec-tive emergency response, we cannot support the response time requirements of Table A.l.2-1.
The imposition of such requirements would force limitations on the housing and behavioral patterns of individuals. More importantly, it begins to impose routine staffing patterns that run contrary to effective and efficient management I
of the utility.
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t Boston Edison submits that it complies with the functional objectives demon-strated by the Minimum Staffing Requirements for Nuclear Power Plant Emergencies as outlined in NUREG 0737, Table IIIA.l.2-1.
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TABLE I ACTIVATION OF EMERGENCY PERSONNEL RANGE OF MAXIMUM RESPONSE TIME TO PILGRIM STATION ON SHIFT 30-40 MIN.
40-50 MIN.
50-60 MIN.
I&C Supervision 1
0 1
3 Technician 2
5 7
Maint. Supervision 1
1 7
Mechanical 1
4 8
Electrical 0
2 2
Health Physics Supervision 0
6 0
Technicians 1
4 6
0 Operations Personnel 5
1 16 19 Reactor Engineering /STA's
.1 0
5 5
Technical Support 0
2 1
l Plant Management 3
1 1
Plant Support (Stores, Admin. )
5 6
9 i
l Chem. Supervision 1
1 l
Technicians 1
1 2
1 i
ATTACHMENT B PILGRIM STATION EMERGENCY RESPONSE FACILITIES This submittal describes the PNPS-1 Emergency Response Facilities and equipment including the Control Room, On-site Technical Support Center, On-site Operational Support Center, and near site and alternate Emergency Operations Facility.
These facilities and equipment enhance the Boston Edison Company's ability to:
1.
Identify, classify and mitigate the consequences of an abnormal plant condition.
2.
Mobilize the emergency response and recovery organization.
3.
Provide technical staff in addition to and in support of Control Room personnel.
4.
Provide personnel to perfonn maintenance and other plant service activities in support of Emergency Operations.
5.
Assess the radiological consequences to plant personnel on-site and make recommendations for their protection.
6.
Assess the environmental and radiological consequences of the plant condition to the general public and make recommendations to state and
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local officials concerning protective actions.
Each facility is provided with adequate equipment and infonnation to assure that the response and recovery functions of the Emergency Organizations will be fully accomplished.
Activities, in response to emergencies, at Pilgrim Nuclear Power Station are l
l directed and controlled from two locations.
Initially, activities are directed from l
the Main Control Room; however, if the situation escalates to an Alert, Site Emergency or General Emergency, the near site Emergency Operations Facility and Technical Sup-port Center are activated as described in the Emergency Plan. The following sub-i sections describe the Emergency Control and Support Facilities and Equipment for the Pilgrim Nuclear Power Station (PNPS).
CONTROL ROOM The Control Room is designed to remain habitable under conditions which could result from the most severe design basis accident analyzed in the PNPS-1 FSAR.
Nuclear plant instrumentation is provided in the Control Room to give early warning of a potential emergency and provides for a continuing evaluation of the emergency l
situation. The Control Room contains the controls and instrumentation necessary for operation of the reactor and turbine generator under normal and emergency situations.
2-Additional equipment such as portable radiation survey instruments for initial on-site survey, meteorological instrumentation displays and comunication equip-ment is available in the Control Room. The Meteorological Data Acquisition Computer (MDAC) located in the EOF, is used to compile data from the meteorological instru-mentation and will have a display device installed in the Control Room. The MDAC is al-Self-con' ained breathing apparatus is so used to estimate off-site projected doses.
t maintained in the Main Control Room.
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Direct radio and telephone comunications capability is maintained in the Control Room to provide prompt alerting of and immediate information to federal, state and local officials. Until the Emerge _ncy Operations Facility is activated, the Main
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Control Room is the focal point from which all energency activities are directed and controlled by the Emergency Director.-
Location:
The existing Technical Support Center (TSC) is located on the lower level of the Main Guard House within the protected area of the plant. This facility meets all of the guidelines discussed below with the exception of size, habitability and technical data.
BECo intends to provide an upgraded TSC considering the guidelines contained in NUREG 0696. We have evaluated several locations for the upgraded TSC, but due to the uncertainties of local permit procedures, we cannot commit to an exact location at this time.
2.
Function:
The Technical Support Center (TSC) allows TSC personnel to perfonn the following functions:
analyze current and projected plant status through communications with the Emergency Director and Watch Engineer, l
provide technical support and recommendations regarding emergency actions l
analyze and resolve mechanical, electrical and instrument and control problems
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- analyze and resolve thermohydraulic and thermodynamic problems l
- analyze and develop guidance on the protection of the core to assist l
operations personnel i
3.
Staffing and Training:
l Whenever an alert, site or general emergency is declared, the following personnel l
will immediately report to the TSC and assume their duties:
1.
TSC Supervisor 6.
Chemical Engineer l
2.
Reactor Engineer 7.
Main'tenance Engineer i
3.
Health Physics Engineer 8.
I&C Engineer 4.
Shift Technical Advisor (Off-Duty) 9.
Computer Engineer S.
Operations Engineer
- 10. Administrative Assistant I
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. The TSC Supervisor coordinates activities in the TSC and interfaces with the Control Room, OSC and E0F. All personnel associated with the TSC receive training describing their responsibilities during the emergency situation.
In addition, all personnel participate in periodic drills.
4.
Size:
The total floor area of the existing TSC is about 500 ft.2 The total area of the upgraded TSC will be approximately 4000 ft.2 Included in this space will be approximately 1500 ft.2 for mechanical, electrical and filtering equipment; 1000 ft.2 for data system equipment, processing, displaying and transmission of data; communication system; repair and maintenance of all the above equipment; 1500 ft.2 for working space, including NRC consultation room and toilet facilities.
5.
Structure:
Both the existing TSC and the upgraded TSC will be able to withstand the most adverse conditions reasonably expected during the design life of the plant, in-l cluding adequate capabilities for (1) earthquakes, (2) high winds and (3) floods.
The upgraded TSC will not be seismic Category I or be qualified as an engineered safety feature (ESF).
6.
Habitability:
i The existing TSC does not meet the habitability criteria specified in General l
Design Criteria (GDC) 19. The upgraded TSC will provide personnel with pro-tection from radiological hazards, including direct radiation and airborne radioactivity from inplant sources under accident conditions in accordance with l
GDC 19, SRP 6.4 and NUREG 0737, Item II.B.2.
The upgraded TSC ventilation system shall function in a manner comparable to the l
Control Room ventilation system but will not be seismic Category I qualified, I
redundant, instrumented in the Control Room, or automatically activated.
It will i
include high-efficiency particulate filters, and charcoal filters. Sufficient potassium iodide shall be provided for use by TSC personnel.
l Continuous radiation monitors either installed or portable, will be provided for the protection of TSC personnel. These systems shall continuously indicate radiation dose rates and airborne radioactivity concentrations inside the TSC while it is in use during an emergency.
Local alarms with trip levels set to provide early warning to TSC personnel of adverse conditions will be incorporated into the design.
Protective equipment will be provided in the TSC for staff who must travel between the TSC and the Control Room or EOF under adverse radiological conditions. This equipment will be properly maintained to assure availability during an emergency.
7.
Comunication:
The existing Technical Support Center is provided with reliable voice communica-tion to the Control Room (CR), Operations Support Center (OSC), Emergency Opera-tions Facility (EOF), NRC, and state and local operations centers.
The upgraded TSC will also have reliable voice communications including:
a) Hotlines to the NRC b) Dedicated telephones to the CR, OSC and E0F c) Dial telephones
d)
Intercom between parts of the TSC (if separated) e) Communications with mobile monitoring teams f) Communications with state and local Operation Centers g) Designated telephones to the NRC (2) h) Facsimile transmission capability to E0F and NRC Operation Centers 8.
Instrumentation, Data System Equipment and power Supplies:
The existing TSC has access to data needed to analyze plant conditions. A description of this equipment is provided in the following section. Plans for upgrading this equipment are discussed under the section on ERFIS. The TSC is and will continue to be equipped with a diesel generator which provides a backup power source to the normal 'poweFsi2pply.
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Technical Data and Data System:
The existing TSC is equipped with the following devices:
A repeat of the plant computer's Data NET 760 Video Display, with 6 lines dedicated to trending variables which can display all data presently input to the plant computer.
A monitor for a monochrome, 32-320mm pan / tilt / zoom camera, mounted in the CR, controlled from the TSCproviding clear views of Control Room instru-ments down to 1/8" resolution.
- Two dual channel. strip chart recorders for trending selected computer points.
- Remote operators console for accessing, displaying and printing various plant parameters via the process computer.
Upgrade of the present instrumentation and data display capabilities at PNPS is under evaluation.
Details on these plans are addressed under the section on ERFIS, 10.
Records Availability and Management:
Personnel in the upgraded TSC will have access to the following:
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- Plant technical specifications
- Plant operating procedures Emergency operating procedures Final Safety Analysis Report
- Plant operating records
- As-built drawings P&ID's OPERATIONAL SUPPORT CENTER 1.
Functions:
The on-site Operations Support Center (OSC) is located in the PNPS-1 Maintenance 4
Office Area and will be staffed by Auxiliary Operators, Health Physics Tech-nicians, Maintenance and other plant personnel. These personnel are available
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to support the station operation and recovery functions as directed by the Control Room.
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Habitability:
The OSC is located outside of the Reactor Building atmosphere boundary.
However, in the event that the OSC becomes uninhabitable, an area within the I&C Lab (adjoint to the Control Room) may be designated as the alternate OSC.
3.
Comunications:
The OSC will be provided with a comunication system consisting of one dedicated extension to the Control Room, one dedicated extension to the TSC, and one telephone capable of reaching on-site and off-site locations.
EMERGENCY OPERATIONS FACILITY 1.
Functions:
The near site Emergency Operations Facility (EOF) is five separate yet integrated units whose function is to assist Boston Edison to effectively and efficiently manage the overall licensee response to emergencies at PNPS. Each unit has been designed primarily to fulfill the following fdnctions respectively:
(1) Radiological and Environmental Assessment (2) Comunications (3) Logistic Support (4) Decontamination and First Aid (5) Discussion and Briefing Area This EOF will provide a means for high level interaction and comunication among key personnel to include licensee, local, state and federal agencies as well as other support groups.
2.
Location, structure and habitability:
The E0F is located approximately a quarter of a mile west of tae reactor build-ing, and consists of pennanently installed mobile offices.
The habitability of this facility has been carefully evaluated. Detailed analysis (available for your review) has led to the detennination that the EOF would be habitable under conditions that would exist during the Design Basis / Loss of Cool-and Accident as analyzed in the PNPS Unit #1 Safety Evaluation Report. The results of these analyses indicate that th total thirty-day dose to occupants of the E0F, following a LOCA, is about 3.1 Rem to the total body and about 5.6 Rem to the thyroid. These calculated doses are well below the limits specified in GDC 19 for dose limits to Control Room Operators following an accident.
These calculations do not consider ground level concentrations resulting from seabreeze fumigation because, due to the short distance from the shoreline to the E0F, it is very unlikely that the Thennal Inversion Boundary Layer would enlarge enough to intercept even a very unstable plume being released from the 335 ft elevation of the main stack.
. In the unlikely event the EOF is uninhabitable, an alternate E0F has been
- designated in Bridgewater at the Massachusetts Civil Defense Agency Area II Headquarters roughly 20 miles from PNPS. This is the location from which the state would coordinate emergency operations for Southeastern Massachusetts in the event of an emergency at PNPS Unit #1. This would co-locate Boston Edison, state and federal agencies in the spacious Emergency Operating Center routinely utilized by all the state agencies involved in emergency response and will pro-vide all of the necessary facilities and equipment to assure uninterrupted high level interaction and coordination among all key personnel. This will provide continuity of dose projections and availability of imediate actions for public protection.
3.
Staffing and Training:
The Emergency Operations Facility is staffed t,y qualified members of the plant staff and other such qualified personnel as may be designated by plant and corporate management. This staff includes, but is not limited to:
Emergency Director Radiation Emergency Team Coordinator Monitoring Team Leaders and Members Environmental Assessment Engineers Public Information Director Administrative Assistants Physicians Assistant The E0F staff has received training in their areas of responsibility and have participated in E0F activation drills conducted periodically in accordance with the Emergency Plan for PNPS Unit #1.
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Size:
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The primary E0F provides over 4000 sq. ft. of working space. This provides I
adequate space for the personnel, records, and equipment required to assess the conditions within the plant and the surrounding environments.
5.
Radiological Monitoring:
To ensure adequate radiological protection of E0F personnel, radiation monitoring systems are provided in the E0F. These monitoring systems are composed of dedica-ted portable monitoring equipment which will continuoudy indicate radiation dose rates and airborne radioactive contamination inside the E0F while it is in use d wing an emergency.
6.
Comunications:
The E0F has reliable voice communications facilities to the NRC, the Control Room, and state and local emergency operations centers.
The EOF voice communication equipment includes:
- Hotline telephones (ENS) and HPN
- Dedicated telephones to TSC and CR
- Inter communications between work areas of EOF
- Radio communications to licensee mobile monitoring team Comunications to state and local operations centers
- NRC office space has adequate telephone capabilities l
4 The backup to this communication network includes radio communications with local and state police and local state and federal emergency management agencies.
7.
Instrument, Data System Equipment and Power Supplies:
Equipment is provided in the EOF to gather, store and display data needed in the EOF to assess the environmental impact of the emergency as it develops.
The EOF data system performs its function without degrading or interfering with Control Room functions.
The EOF electrical equipment load is normally powered from off-site power. A backup source of power is supplied by the security system diesel generator.
Circuit transients or power supply failures and fluctuations do not cause a loss of stored data.
8.
Technical Data and Data System:
The E0F is presently equipped with digital displays of wind speed and direction, temperature and delta temperature as measured at the 33 foot and 220 foot eleva-tions of the PNPS-1 meteorological tower. The EOF is also provided with a meteorological data acquisition system minicomputer system which records, analyses and displays the data. Equipment will be installed for the purpose of displaying meteorological data from the 160 foot PNPS-2 meteoro-logical tower in the EOF.
Additional EOF data requirements are being addressed with the TSC data requirements under ERFIS.
9.
Records Availability and ".anagement:
The EOF records shall include:
Plant technical specifications
- Plant operating procedures
- Emergency operating procedures FSAR Emergency Plan (BECo, state, local)
- Off-site population distribution data
- Evacuation Plans
- Radiological monitoring records
- Employee rtdiation exposure history
- P&ID's As-built plait drawings
EMERGENCY RESPONSE FACILITY INFORMATION SYSTEM The Main Control Room contains all controls and instrumentation consistent with our existing design basis for quality, reliability, and accuracy necessary for the safe operation of the Station under all normal and anticipated abnormal operating conditions.
In addition, the instrumentation described in the above sections on the TSC and E0F extends the Control Room information base to these facilities.
Boston Edison is actively traluating the options available to improve the present technical data and data acquisition / distribution capabilities at PNPS considering the guidance provided in NUREG 0696 and Regulatory Guide 1.97.
We believe the best approach to incorporating the data requirements of these documents into the Control Room, TSC, and EOF is through a fully integrated system (ERFIS).
An integrated approach is essential to ensure the final product provides reliable, accurate and useable data to key personnel.
Improved integrated systems gather, store and process data, generate visual displays for operator use, provide printed records of transient events and have the capability to transmit vital information to the NRC.
A significant part of our evaluation process consists of participation in several industry sponsored programs addressing the requirements of NUREG 0696 ana Regulatory Guide 1.97, and the numerous documents associated with Human Engineering and Control Room Evaluations. These groups include:
1.
BWR Owner's Group Subgroup on Regulatory Guide 1.97 selection of which variables are required 2.
BWR Owner's Group Subgroup on Control Room Improvements 3
BWR Owner's Group Subgroup on Emergency Procedures 4.
The SPDS Display Validation program being sponsored by Sandia Labs and General Electric Work in these groups is in progress, the results of which will be incorporated into the ERFIS System adopted by Boston Edison.
In additio1, we are also integrat-ing the requirements of replacing the plant process computer into our ERFIS design.
Integration.of the industry and in-house efforts must be achieved to provide a use-ful system to all personnel involved in normal ~and emergency operations at PNPS Unit #1.
,o TENTATIVE SCHEDULE TSC The existing TSC is functional and will continue to be utilized until the upgraded TSC can be completed.
An implementation schedule shall be pro-vided upon resolution of the permit uncertainties previously identified.
E0F Pilgrim Nuclear Power Station, EOF is fully operational with an adequate alternate facility.
The EOF equipment, other than ERFIS, will continue to be improved in accordance with current guidance to meet October of 1982.
Emergency Response Facility Information System (ERFIS)
The existing system provides sufficient information to the Control Room, EOF and TSC for these centers to perform their emergency functions. However, we are evaluating options available to improve the present capabilities and will provide a detailed description of proposed modifications, if any, and a schedule for implementation by January 1,1982.
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