ML20028B880
| ML20028B880 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/06/1982 |
| From: | Pilant J NEBRASKA PUBLIC POWER DISTRICT |
| To: | Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20028B876 | List: |
| References | |
| NUDOCS 8212070141 | |
| Download: ML20028B880 (11) | |
Text
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GENERAL OFFICE
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Nebraska Public Power District August 6,1982 b)M@MU\\Y/M3
,J E '91982 Mr. John T. Collins Regional Administrator b
U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011
Dear Mr. Collins:
Subject:
NPPD Response to NRC Inspection Report 50-298/82-08 This letter is written in response to your letter dated July 1, 1982, which transmitted the subject Inspection Report. Five items were identified during the inspection which you indicated were not in full compliance with current NRC guidance documents.
Following is a listing of the open items and the District's response to each.
Open Item 82-08-01:
Provisions are made to provide adequate space for NRC and Technical Support Center response personnel in the TSC (outside the control room).
l NPPD Response:
As described in Section 22 of the subject report, the microfiche reader / printer and the microfiche file will be removed from the NRC space in the TSC. In addition, two emergency equipment storage cabinets, not mentioned in l
Section 11, will also be removed. To increase space for TSC personnel, a doorway will be constructed between the TSC and the adjacent I&C Electrical OSC.
The TSC will be expanded into this additional space. This area maintains the same habitability as the existing portion of the TSC. The existing I&C/ Electrical OSC will be relocated across the corridor to the electrical maintenance area. Construction of this doorway is expected to be completed by October 31, l
1982.
l l
8212070141 821201 PDR ADOCK 05000290 G
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r Mr. John T. Collins Page 2 August 6,1982 Open Item 82-08-02:
(1) Provisions are made to provide adequate space for the NRC, state, local, and the emergency operations facility personnel in the EOF.
NPPD Response:
Pursuant to the guidance contained in NUREG 0696 and Generic Letter 81-10, NPPD is proceeding with the construction of a new near-site EOF. The following is a description of the facility.
The new EOF will continue to meet the same functional criteria described in the CNS Emergency Plan. It will be the center for the following activities:
1.
Management of overall emergency response.
2.
Coordination of radiological and environmental assessment.
3.
Determination of recommended protective actions for the public.
4.
Coordination of emergency response activities with federal, state, and local agencies.
5.
Recovery organization.
With the exception of Public Information, all activities will be housed in the new, hardened area. It is planned that the public relations efforts will be conducted in the Security Building.
The area of the EOF is approximately 4200 square feet. The EOF will be a concrete structure built in accordance with the National Uniform Building Code and capable of providing a protection factor (pf) of at least five. Its pror,osed location is directly north of the existing Security Br.lding. The ventilation system will be manually isolated in the event a release of radioactive material occurs. This will restrict the amount of fresh air flow into the structure and will direct all air through an activated charcoal and HEPA filter arrangement.
A continuous air monitor (CAM) and an area radiation monitor (ARM) are provided (with alarms) to ensure EOF personnel are aware of any potential radiological consequences. To ensure no airborne contamination enters the EOF through other than the ventilation system, the HVAC system has been sized to be capable of maintaining a b" positive pressure.
.Mr. John T. Collins Page 3 August G,1982 It is anticipated that the EOF will be complete by January 1,
1983.
A floor plan is included as.
(2) Personnel are assigned to make telephone calls, thus allowing the Emergency Director to direct the emergency exercise and minimize time spent on the telephone.
NPPD Response:
The communications requirements of the Emergency Director will be reviewed and pertinent Emergency Plan Implementing Procedures will be revised to limit the Emergency Director's calls to those absolutely necessary. Additionally, the CNS Emergency Organization will be revised to provide personnel to make calls for the Emergency Director at his direction.
These revisions will be completed by Oct(ber 31, 1982.
Open Item 82-08 (1) Provisions are made for enabling backshift personnel to establish timely initial dose assessment values.
NPPD Response:
Emergency Plan Implementing Procedures will be revised to include a method for backshift personnel to determine dose assessment values.
This method will be in tabular form, using meteorological and release rate data. This method will not be necessary after the completion of the CNS computer upgrading [see response to Open Item 82-08-04 (4)], at which time personnel will have release rate, meteorogolical and dose assessment data via the computer. Procedures will be revised to prcvide the capability of backshift personnel to establish initial Jose assessment values by October 31, 1982.
(2) Development of procedures which address requirements for collecting and analyzing charcoal cartridges and determining iodine releases associated with effluent release pathways.
NPPD Response:
CNS Chemistry Procedure 8.4.1.2, Emergency Sampling -
Gaseous Releases, details sample collections and release determination of iodines, as well as particulates and noble gases. This procedure adequately addresses the concerns of sampling accident concentrations of gaseous releases.
Procedure 8.4.1.2 will be referenced in EPIP 5.7.16, Release Rate Determination.
The revision of Procedure 5.7.16 to include this reference for callecting and analyzing charcoal cartridge to determine iodine release rates will be completed by October 31, 1982.
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Mr. John T. Collins Page 4 August 6,1982 (3) Development of a method for displaying the maximum centerline plume doses on the TSC and EOF radiological status boards.
NPPD Response:
The District is in the process of modifying the TSC and EOF Radiological Status Boards. The new format will better suit the existing Emergency Preparedness Atmospheric Dispersion Model computer printout. The District is also reviewing a possible modification of the Special Receptor Points utilized by the computer to facilitate determining plume centerline doses.
These modifications will be completed by October 1,1982.
(4) Development of a computer program which contains a calculational program for projecting dose in the downwind direction of the plume.
NPPD Response:
Nebraska Public Power District (NPPD) is in the process of developing a Plant Management Information System (PMIS) utilizing the lates' computer technology at Cooper Nuclear Station (CNS).
The objectives of this system are to:
1.
Replace the existing GE/ PAC 4020 plant process computer which is becoming obsolete.
2.
Satisfy the Nuclear Regulatory Commission (NRC)
Emergency Response Facility (ERF) requirements of NUREG-0696 and Meteorological and Radiological requirements of NUREG-0654.
3.
Provide computer capability to perform other balance of plant and plant management functions.
4.
Provide a system compatible with the NPPD's long-range goal of an overall computer network.
Figure 1 shows the various functions of the PMIS. Also shown is the anticipated percentage of the PMIS computer CPU usage for various groups of functions.
As can be seen, the overall PMIS encompasses a greater number of functions than those required by NUREG-0696 and 0654 and will provide additional benefits to Cooper Nuclear Station.
2
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Mr. John T. Collins Page 6 August 6,1982 Over the past year, the following activities toward implementing a Plant Management Information System have occurred:
May,1981 A task force was established to determine what NPPD should do concerning the post-TMI Emergency Response F'acilities and upgrading of the computer system at CNS.
June,1981 The task force initiated the evaluation process for selection of a nuclear / software vendor to design a PMIS for Cooper Nuclear Station that would satisfy the guidance of NUREG-0696 and NUREG-0654.
Thirteen vendors made preliminary proposals.
It became apparent I
during the interviews that a more thorough assessment of the requirements of a PMIS was needed.
August,1981 General Electric was contracted to perform a
Plant Management Information System Application Assessment Report for Cooper Nuclear Station.
December,1981 General Electric presented the results of the report to NPPD management along with a budgetary cost estimate for the PMIS.
January,1982 A Project Manager was named to head up the PMIS project.
March,1982 A " Plant Management Information System Overview Report" was generated and presented to NPPD's Board of Directors.
May,1982 The Board of Directors approved project funding for further evaluation of nuclear / software vendors, generating implementation plans, engineering studies, and development of specifications. An architect / engineer was also approved to assist NPPD in these tasks.
1
.Mr. John T. Collins Page 7 August 6,1982 An implementation plan is presently being generated.
This plan will include a work breakdown structure, responsibility matrix, schedule for selection of the nuclear / software vendor who will design the PMIS and a project overview schedule.
This project will be divided into three phases:
Phase I - Conceptual Design to determine specific requirements, prepare technical bid specifications, evaluate nuclear computer systems integrators, and award contract.
Phase II - Detailed Engineering and Design to imple-ment Phase I design at Cooper Nuclear Station including procurement of all additional equipment required.
Phase III - Construction, Installation, and Start-up Testing to fully implement this system at the plant site.
A.
Phase I - Conceptual Design This phase of the project consists of formulating a specific PMIS overall system concept encompassing all portions of the project including:
- planning, system specification, system selection, implementation and test, installation and training, and operation. Particular emphasis will be placed on the first three items during Phase I, with the other items covered in greater detail during the other phases of the project.
1.
Planning Planning will include such activities as the establishment of goals, function requirements, and the performance of cost / benefit analysis.
A working group has been established to provide this planning for Cooper Nuclear Station. The members include representatives from management, plant reactor engineering, plant operations, computer systems, and the architect / engineer.
This group will determine PMIS interfaces with the Safety Parameter Display System (SPDS), Technical Support Center (TSC), Emergency Operations Facility (EOF), Control Room, Computer Room, Computer System, and the Meteorological and Radiological Monitoring Systems which will serve as a basis for tha preparation of a project criteria document.
)
i Mr. John T. Collins Page 8 August 6,1982 This criteria document will formalize the results of the above work and identify any other areas which should be considered, such as CNS Emergency Procedures and Emergency Procedure Guidelines, expansion capabilities, testing, and training requirements.
It is anticipated that the system installation will be Lccomplished in phases; the most urgent requirements satisfied first, followed by the other requirements in order of priority.
The 7
requirements of NUREG-0696 and NUREG-0654 will be addressed first, since a number of the concepts l
and requirements of these documents are common to the other functions of the system. These include Class 1E isolation of safety related signal interfaces, high system availability, design verification and validation, system testing, con-figuration and documentation control, integrated data base, and independence between the various functions of the system. This independence implies that the ERP's computer and other computer system l
functions have access to the same data base, but are completely self-safficient and independent such that changes in software of one function will not affect any other function of the integrated system.
A draft PMIS Master Schedule and a draft Project l
Cost Estimate will be developed to be refined in Phase II - Detailed Engineering and Design for the PMIS and interfacing systems and facilities.
2.
System Specification l
Functional technical specifications will be written I
covering the requirements of the system. These l
specifications will conform to the project criteria document and addres.: items such as:
computer system functions, man / machine interface, system sof tware, system hardware, availability, testing, 7
l and training.
l 3.
System Selection A request for proposal (RPP), which will include the functional technical specifications, will be prepared as part of the selection process of a nuclear system integrator who will provide a complete hardware / software package. The system will be selected by a formal evaluation committee using formal criteria which will show the degree of i
compliance with the bid specifications.
t I
. Mr. John T. Collins Page 9 August 6,1982 B.
Phase II - Detailed Engineering and Design This phase of the project consists of performing the detailed engineering and design work to implement this system at Cooper Nuclear Station.
1.
Implementation This activity includes not only refining the details of the computer system hardware and software, but also the interfacing systems.
These include: electrical power, HVAC, fire detection and protection systems, plant instrumentation, etc.
2.
Testing Verification and validation testing will be performed on the system hardware and software.
This will include a formal test program at the vendor's plant, as well as testing at the Cooper Nuclear Station after installation.
3.
Training A training program for both plant operators and computer maintenance personnel will be established.
C.
Phase III - Construction, Installation, and Start-Up Testing The final phase of the project includes physical modifications required in the plant to support the installation of the computer system, computer installation, system start-up and testing, and turnover to plant staff.
It is anticipated that a definition of the functional requirements and interfaces with the various subsystems will be completed by October,1982.
Open Item 82-08-05:
(1) The review of the post-accident sampling system design and correct system operation such that a representative primary coolant sample can be obtained during a loss of onsite and/or offsite power.
i
, Mr.. John T. Collins Page 10 August 6,1982 NPPD Response:
We have reviewed the requirements for the post-accident sampling system and can find no requirement for the system to be operational during a total loss of onsite and offsite AC power.
We also do not consider it plausible that such a sample would be necessary during this condition.
The post-accident sampling system is powered from a normal station power source.
Upon loss of offsite power, Diesel General #1 supplies the power to this sampling system.
Should the loss of DG #1 occur, power can be cross connected to DG #2. If all onsite and offsite power should be lost, a portable generator could be connected to power the post-accident sampling system. The information needed to make such a connection has been incorporated into Procedure 8.4.1.1, Revision 1.
Additionally, the District is aware of an impending letter from D. B. Vassallo regarding a post-implementation review of Item II.B.3 (post-accident sampling system). In this letter, there will be guidelines and clarifications for the District to assess the acceptability of the system and to see whether it meets the requirements of this NUREG item. Specifically, in the clarification to Criteria 1 of NUREG 0737, Item II.B.3, information is requested on how a sample will be taken during loss of offsite power, i.e., designated alternate backup power sources (not necessarily the vital Class 1E Bus), that can be energized in sufficient time to meet the three-hour sampling and analysis time limit. The District is already in compliance with this NRR requirement and feels this item is closed.
(2) Development and implementation of offsite radiological D, % o r --
plume characteristic monitoring procedures, e.g.,
procedures to lead the offsite monitoring teams to direct and characterize the radiological plume.
NPPD Response:
Cooper Nuclear Station Emergency Plan Implementing Procedure 5.7.18, Offsite and Site Boundary Monitoring, will be revised to include more explicit directions and information for offsite monitoring tests to more accurately characterize the radiological plume. These instructions will include plume centerline determination, indications for determination if the plume is elevated or at ground level, outer edge determination of the plume and concentration determination by sampling.
This information will be forwarded to the Radiological Assessment Coordinator in the TSC.
The Radiological Assessment Coordinator will use this plume information from field monitoring teams (NPPD and governmental) to more accurately define plume travel, exposure levels, and comparison with projected dose assessment information to better formulate more accurate
)
r
.Mr. John T. Collins Page 11 August 6,1982 protective action recommendations to the Emergency Director.
EPIP 5.7.18 will be revised to include the above details by October 31, 1982.
If you have any further questions in regard to this response, please contact my office.
Sincerely, W
Ja
. Pilant Division Manager of Licensing &
Quality Assurance JMP/kcw:kr6/8 Attachment