ML20035H355
| ML20035H355 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/29/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20035H341 | List: |
| References | |
| NUDOCS 9305040289 | |
| Download: ML20035H355 (3) | |
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ENCLOSURE SAFETY EVALUATION FOR REVISION TO THE SOUTH TEXAS PROJECT i
UNITS 1 AND 2 l
EMERGENCY PLAN STAFF AUGMENTATION TIMES Docket Nos. 50-498,50-499
1.0 BACKGROUND
By letter of November 3,1992, William J. Jump, General Manager, Nuclear licensing, for Houston Light and Power Company (HP&L) proposed a revision to the South Texas Project (STP) Emergency Plan (EP) to increase the amount of l
time allowed to augment the onshift emergency response organization (ERO).
The current response times of 45 and 60 minutes would be increased by 15 l
minutes to 60 and 75 minutes following an emergency declaration.
2.0 APPLICABLE REGULATIONS AND GUIDANCE 10 CFR 50.47(b)(2) states in part that " adequate staffing to provide initial facility accident response in key functional areas is maintained at all l
times... timely augmentation of response capabilities is available."
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NUREG-0737, Supplement 1, states the following:
i 8.2.1.j.
[The TSC should be] staffed by sufficient technical, I
engineering and senior designated licensee officials to provide l
needed support and be fully operational within approximately I hour after activation.
8.4.1.i.
[The EOF should be] staffed using Table 2 (previous guidance approved by the Commission) as a goal.
Reasonable i
exceptions to goals for the number of additional staff personnel
~1 and response times for their arrival should be justified and will be considered by NRC staff.
NUREG-0654/ FEMA-REP-1, Revision 1, Table B-1 3.0 LICENSEE'S BASIS FOR PROPOSED REVISION j
The licensee has proposed increasing the augmentation time to reflect actual expected travel time for ERO personnel to travel to the STP site. The licensee stated that 58 percent of the personnel assigned to the ERO reside i
with a 20-minute drive to the site. Another 40 percent of the personnel assigned to the ERO reside in an area that is located some 50 miles from the STP site. The licensee has expressed concerns with the current specified augmentation time.
By increasing the augmentation time goals by 15 minutes, the licensee's concerns would be reduced. The licensee maintains that the capabilities of the ERO would not be reduced by the increased response time.
9305040289 930429 PDR ADOCK 05000498 j
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'. The licensee states that sufficient personnel are assigned to the Onshift Response Organization to cope with an emergency in its early stages.
4.0 STAFF EVALUATION NUREG-0654, Table B-1, establishes, as a minimum onshift staffing goal for a two-unit site, a total of 13 individuals in key functional areas. The licensee, in Table C-2 of their EP, has committed to a minimum of 20 individuals on shift, with all of the Table B-1 key functional areas covered.
This manning commitment provides for an excess of 7 personnel onshift above Table B-1 minimums.
Table B-1 sets a goal to have an additional 11 personnel respond within 30 minutes of the declaration of an emergency. At the point in time (30 minutes after event declaration), Table B-1 goals would have a total of 24 personnel onsite for a two-unit site. The licensee, in the proposed revision to EP Table C-2, is committing to having 20 personnel onsite from onshift positions and an additional 8 personnel respond within 60 minutes for a total of 28 personnel onsite at 60 minutes.
For the first 30 minutes, the licensee has 7 personnel onsite in excess of Table B-1 minimums and would, at the 30-minute mark, be short by only 4 individuals of the Table B-130-minute goal.
Considering the fact that personnel onsite should be more effective initially than personnel arriving from offsite, the 4-person deficit at the 30-minute mark is not a significantly detrimental point; the 7 excess onshift positions is a very beneficial situation.
Again, Table B-1 sets a goal of 15 additional responders to be available 60 minutes after event declaration for a total of 39 personnel at the 60-minute point for a two-unit site. The licensee, in the proposed revision to EP Table C-2, is committing to have the 28 ERO members onsite at the 60-minute mark augmented by 13 additional personnel at the 75-minute mark for a total of 41 4
ERO personnel onsite.
In consideration of the long travel distances required of approximately 40 percent of the licensee's ERO, it is reasonable to allow the additional 15 minute window for response time.
5.0 CONCLUSION
Based upon our review and evaluation of the licensee's proposed revision to the STP EP, Table C-2, submitted by letter dated November 3,1992, the Emergency Preparedness Branch (PEPB) staff has concluded that the proposed revision is acceptable.
The 15-minute increase in response times from 45 and 60 minutes to 60 and 75 minutes respectively is a minor reduction in response time. The slight delay in meeting response goals is. compensated for by the licensee commitment to maintain more personnel onshift than called for in the goals established by guidance documents.
The licensee has maintained the same overall response capabilities so the effectiveness of the emergency plan is not reduced. The emergency plan, as revised, still meets the standards of 10 CFR 50.47(b) and the requirements of 10 CFR 50, Appendix E.
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7; The licensee has provided a reasonable justification for exception to the NRC's guidance found in NUREG-0654 and NUREG-0737, Supplement 1, in that a significant number of personnel live an extended distance from the site.
Principal Contributor:
D. Barss, PEPB/NRR 504-2922 i
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