ML20010C749
| ML20010C749 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/10/1981 |
| From: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | Clark R Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0654, RTR-NUREG-0737, RTR-NUREG-654, RTR-NUREG-737, TASK-3.A.2.2, TASK-TM GL-81-10, NUDOCS 8108200376 | |
| Download: ML20010C749 (3) | |
Text
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bM CHARLES CENTER P.O. BOX 1475 BALTIMORE. MARYLAND 21203 y
ARTHUR E. LUNOVALL, JR.
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va emu,o August 10,1981 sm Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Mr. Robert A. Clark, Chief Operating Reactors Branch #3
SUBJECT:
Generic Letter No. 81-10
" Post-TMI Requirements for the Emergency Operations Facility" Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2, Docket Nos. 50-317 & 50-318 R EFERENCES:
a) 10 CFR 50.54 (s)(2) b)
NUREG 0737, Item Ill. A.2 c)
NRC Letter dated 02/18/81 from D.
G.
Eisenhut to All Licensees, Post-TMI Requirements for the Emergency Operations Facility d)
Letter to R. A. Clark dated March 30,1981
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Gentlemen:
On March 30, 1981, I responded to Mr. Darrell Eisenhut's Generic Letter 81-10 of February 18, 1981, concerning post-TMI requirements in the emergency preparedness area. In part, I stated that we intended to meet the staffing levels and implementation dates as specified in Table B-1 of NUREG-0654, Revision 1, by September 1,1981. The purpose of this letter is to modify the statement made in my initial response based on i
recent experiences and further delibration.
I Specifically, Table B-1 requires on-shif t coverage by three Health Physics Technicians to provide capability for in-plant surveys and other facets of radiation protection.
Additionally, it requires one Chemistry Technician for the performance of tasks in the Chemistry /Radiochem'stry area. Although our existing complements in the Chemistry and Health Physics areas were not based on providing on-shif t coverage seven days a week, we expected to be able to meet this objective by September 1,1981. Howe ver, due to attrition over the last several months and the difficulties we have experienced in hiring qualified replacement personnel, we anticipate that we will have insufficient qualified personnel on our staff by September 1,1981, to fully provide these capabilities on all shif ts. A more detailed review of the typical tasks that must be performed by the designated Health Physics Technicians during the first hour of a plausible accident
//g indicated that one Technician can provide this capability. Consequently, we intend to
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staff each back shif t and weekend shif t with one Health Physics Technician and will augment this coverage with ten additional Health Physics personnel having the requisite capabilities within approximately 60 minutes of identifying a need for their presence.
jp Until sufficient Chemistry personnel with the necessary qualification and expertise in the Chemistry and Radiochemistry areas are available, we will provide back shift and week-0108200376 810810 PDR ADOCK 05000317 F
Mr. Robert A. Clark 2
August X),1981 end shif t coverage within approximately 60 minutes of identifying the need. However, by July 1,1982, we expect to have sufficient qualified personnel to provide on a permanent basis each shif t with an individual having the requisite expertise.
Table B-1 also requires on-shif t capability for a Mechanical Maintenance / Rad-Waste Operator and an Electrical Maintenance / Instrument and Control Technician. We will continue to staff each shif t with one Rad-Waste Operator who has basic mechanical maintenance capabilities by virtue of his equipment and concomitant mechanical knowledge gained through his operator qualifications and training. However, we believe it to be ill advised to staff each shif t with an individual possessing expertise in the areas of mechanical electrical / instrument and controls maintenance for the following reasons:
a.
In less than one hour, only a diagnosis can be made on the average maintenance problem requiring action on a timely basis.
In most cases operating personnel can diagnose the problem sufficiently to call the appropriate maintenance supervisor. Operating personnel are also capable of correcting small problems if timely action is required. On this basis the need for on shif t maintenance personnel is questionable at best. Any significant problem requiring correction in a timely manner will likely involve support personnel from one or more maintenance shops (often more than one person from any g;ven shop), the quality control group, the storeroom and other supporting groups as well as appropriate supervision.
The mos+ satisfactory maintenance support can be provided by on-call personnel. Using an on-call procedure the most experience and knowledge relative to the specific problem can be ap(.ied to solve the problem in the most efficient and timely manner. Certai.ily any problems requiring timely action would be better handled when ap.opriate supervision is aware and can assess the situation in terms of what resturces are required to deal with it. If maintenance technicians are on-shif t th< time spent in early diagnosis and attempted repair may only serve to delay 'epair when the complexity and/or size of the problem is beyond the technicia i's scope.
b.
Another more subtle reason for requesting exception is the increased attrition among maintenance personnel.
Many of our maintenance personnel have choun to work in the maintenance field in order to avoid regularly scheduled shut work.
If shift work requirements are imposed on our maintenance per:annel, tne result would most probably be a reduction in the experience level of our maintenance work force.
The less experienced work force providing shif t coverage would only dilute our ability to fulfill the intended function.
Based on the above reasons, we believe it is prudent to provide the Mechanical, Electrical, Instrument and Controls Maintenance capability through the use of call-in.
By September 1,1981, we will establish a formal call-in procedure that will ensure that within approximately 60 minutes of identifying the need, the necessary person (s) with expertise in the areas of Mechanical, Electrical, or Instrument and Control Maintenance, as appropriate, will arrive at the plant to perform the identified corrective maintenance.
Table B-1 requires augmentation of the on-site personnel within 30 and 60 minutes with t
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Mr. Robert A. Clark 3
August 10, 1981 additional emergency response force personnel. Based on a review of the road distances most plant personnel live from the Calvert Cliffs plant, it is not realistic except during the normal work day : expect most augmentation personnel to be able to start their support functions at the plant within 30 minutes af ter being contacted. However, we do expect to have all necessary support personnel at the plant within approximately 60 minutes.
This also applies to the maintenance support personnel discussed in the preceding paragraph.
We recognize the importance of and obligation to the community for maintaining a reasonable emergency response capability on shif t at all times and are committed to this principle. We believe the modification to Tatie B-1 requirements, described above, still meets this objective.
Very truly yours,
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Vice Presiden Supply AEL/LBR/DWL/gla cc:
- 3. A. Biddison, Esquire G. F. Trowbridge, Esquire Director, Office of Inspection & Enforcement R. E. Architzel, NRC Resident inspector