ML20039C011
| ML20039C011 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 12/07/1981 |
| From: | Warembourg D PUBLIC SERVICE CO. OF COLORADO |
| To: | Grimes B Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0654, RTR-NUREG-0737, RTR-NUREG-654, RTR-NUREG-737, TASK-1.A.1.3, TASK-TM P-81308, NUDOCS 8112280312 | |
| Download: ML20039C011 (8) | |
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%M December.7, 1981 Fort St. Vrain j
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'IN Mr. Brian' Grimes C80
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Office of Nuclear Reactor Regulation g
U. S. Nuclear Regulatory Commission
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SUBJECT:
Emergency Planning i
Table B-1, NUREG 0654 i
REFERENCE:
P-80288 4
Dear Mr. Grimes:
On December 3, 1981, a meeting was held at Fort St. Vrain to discuss l.
the ORNL report on the applicability of NUREG 0737 to Fort St..Vrain and to resolve many of the issues which have been outstanding since late 1979. The Nuclear Regulatory Commission was represented by _the project staff and the Regional Office, and the Nuclear Regulatory Commission Emergency Preparedness Group was represented by Mr. Dave Rohrer.
During this meeting the subject of shift manning under NUREG 0737, Item I.A.I.3, was discussed and-Public Service Company's position regarding Item I.A.1.3 was accepted. As an item directly related to-Item I.A.1.3 the subject of shift manning per Table B-l'of NUREG 0654 i
was discussed.
We pointed out that in our letter P-80288, dated I
August 28,1980, (see excerpt attached) we had set forth our position on Table B-1,-but had never received a response. Your Mr. Rohrer asked if we had clearly set forth our position on this matter, and we' indicated that we felt we had, as evidenced by the attached excerpt-of P-80288.
Mr. Rohrer indicated that'perhaps we should reiterate our position in-~ separate correspondence, and we are therefore-p resubmitting our position.
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As stated in the referenced correspondence, we do not feel the augmentation times of Table B-1 are applicable to Fort St.
Vrain.
Dee to the rate at which our accidents develop we justified, and received official Nuclear Regulatory Commission approval, for a one (1) hour response time for our Technical Advisors. On the basis of the time involved in the development of accidents, v:e have committed to having our emergency organization activated within 90 minutes, and we indicated in P-80288 that this activation would include the augmented staff equivalent to Table B-1 of NUREG 0654.
All of the essential personnel to provide the equivalency of Table B-1 are within a 45 minute to 50 minute driving time of the plant.
Allowing sufficient time for personnel to be notified, time for getting on the road, inclement weather, etc_, we believe the staff augmentation can be accomplished in 90 minutes. Given the basis of our Technical Advisor response we also feel that the 90 minutes represents a more than acceptable time equivalency for staff augmentation per Table B-1 with reference to the health and safety of the public and the intent of Table B-1 augmentation as it was developed for a light water reactor.
With reference to tne Rad / Chem Technician on shift, we indicated in the referenced correspondence that the on-shift Health Physics
- Technician had suf ficient training to perform the necessary initial surveys for access centrol and make initial surveys to protect in plant personnel.
Again, we have no immediate requirement for Rad / Chem expertise in terms of isotope analysis or analysis of off site survey semples.
The on-shift operating personnel have sufficient training to perform off site dose assessment calculations either manually or with the aid of computerized models.
Given the characteristics of Fort St. Vrain, our existing staff is more than adequate to meet the intent of Table B-1.
In order to clarify Table B-1 we have prepared the attached Table B-1 which sets forth the minimum staffing for Fort St.
Vrain Station based on the above comments.
As further clarification we have also prepared a table which depicts our overall emergency response staffing.
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-3 It should be noted that other than the "on-shift" requirements and the Technical Advisor response, these tables represent a capability rather than a commitment.
For example, the 60 minute and 90 minute columns represent a capability of response, but depending on the category of the incident or the severity of the situation, many of the peopla may not be called upon to respond. The term " capability" is also taKen in the context that under normal circumstances the personnel are at home or can be reasonably reached.
It does not infer that personnel are on 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> call nor does it take into account unusual circumstances such as inclement weather, road haza.ds, etc.
This matter has remained unresolved for a considerable period of time.
In this cespect we would request your immediate attention to this matter.
Very truly yours, 7Y1% w drw Don W. Warembourg Manager, Nuclear Produc ion Fort St. Vrain Nuclear Generating Station DWW/alk Attachments cc: John Collins, Region iV George Kuzmycz
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~ f MINIMUM STAl'FING REQUIREMENTS FOR NRC LICENSEES kd
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FOR NUCLEAR POWER PLANT EMERCENCIES (See B.5.)
i CADABILIT FOR ADDITIONS POSITION TITLE ON
/
MAJOR FUNCTIONAL AREA LOCATION MAJOR TASKS OR EXPERTISE S!!IFT * '
60 MIN 90 MIN
/
Plant Operations and Shift Supervisor (SRO) 1 \\
Assessment of Senior Reactor Operator (SRO) 1 \\
Operational Aspects Reactor Operator
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(2 Equipment Operators Auxiliary Operators Emergency Direction and l
Control (Emergency Shift Supervisor or 1
1 Coordinator)***
designated facility h,
manager h*
Notification /
Notify licensee, State 1
2 Communication ****
locc1 and Federal personnel & maintain communication Radiological Accident Emergency Operations Senior Manager 1
Assessment and Support Facility (EOF) Director Senior llealth Physics of Operational Accident Offsite Dose (IIP) Expertise 1
Assessment Assessment Orfsite Surveys 2
2 Onsite (out-of-plant) 1 1
In-plant serveys llP Technicians 1,
1 1
Chemistry / Radio-Rad / Chem Technicians
--l 2
1 chemistry Plont System Technical Support Technical Advisor On Call 1
Engineering, Repair Core / Thermal liydraulics 1
and Corrective Actions Electrical 1
Mechanical 1
Repair and Corrective Mechanical Maintenance /
1**
i Actions Rad Waste Operator 1
Electrical Maintenance /
1**
1 1
Instrument and Control (I & C) Technician 1
O e,
Table B-1. (cont 'd)
POSITION TITLE ON CAPABILITY FOR ADDITIONS-MAJ0ft FUNCTIONAL AREA LOCATIOi+3 MAJOR TASKS OR EXPERTISE SilIFTO -
'60 MIN 90 MIN 4
Protective Actions Radiatica Protection:
llP Technicians 2**
2:
2 (In-Plant)-
a.
Access Control b.
IIP Coverage for repair, corrective. actions, search and rescue first-aid 6 firafighting c.
Personnel monitoring.
d.
Dosimetry Fire. fighting Fire Brigade Local Support per Technical Specifications Rescue Operations 2**
Local Support and First-Aid Site' Access Control Security, firefighting Security Personnel All per and Personnel communications, personnel Security plan
. Accountability accountability.
Lead Security Officer 1
2 2
TOTAL 9
18 19 Ef0TES:
O For'each unaffected nuclear unit in operation, maintain at least one shift foreman, one control room operator and one auxiliary operator except that units sharing a control room may share a shift foreman if all functions are covered.
00-May be provided by shift personnel assigned other functions.
000 Overall direction of facility response to be ass.umed by EOF director when all centers are fully manned. Director of~ minute-to-minute facility operations remains with senior manager in technical support center or control room.
! 0000 May be performed by engineering aide to shift supervisor.
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FORT ST. VRAIN STATION
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STAFFING FOR EMERGENCY RESPONSE RESPONSE TIME NUMBER OF PERSONNEL MAJOR FUNCTIONAL AREA LOCATION MAJOR-TASKS POSITION / TITLE ON SHIFT 60 MIN 90 MIN Plant Operations &
CR Initial Assessment &
Shift Supervisor (SLO' 1
1 4
Assessment of Actions Required to Sr. Reactor Oper (SLO) 1 1
-2 :
Operational ~A9pects Control & Mitigate the Reactor Operator (LO) 1' l'
6 Consequences of the Event Equip. Operator-2 1
9.
Aux.. Tender 2
1.
9' Emergency Direccion CR Control Room Emergency Initially Assumed and Control Director by Shift-Supervisor CR Assumes CR Emerg Director Supt. Operations 1
1 CR Assists Oper. Control Sr. Shift 2 Supervisor CR Assessment / Tech. Advice Tech Advisor 1
.1 TSC Overall On Site Mgr. Nuclear Prod.
1 Emergency Control Station Manager 1
-p
. Tech. Asst.
2 5
FCP Licensen Offsite V.P. Production 1
1 Emerg. Control Rad. Prot. Mgr.
Tech. Manager 1
. Tech / Admin Asst.
2:
ECP Offsite Corporate Chief Exec. Officer 1
1 Emergency Control Tech Support Mgr.
1 Mgr. Resources 1
Mgr. Security Mgr. Media Relations
.1 1
PCC Direction & Control PCC Director of Licensee.On-Site Tech / Admin Asst.
2
^2 Asaigned Personnel EOC Tech / Admin Assistance Tech / Admin Asst.
1 2 --
i-State Emergency.
j Operation Center Media Reps 1
.2:
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FORT ST. VRAIN STATION STAFFING FOR EMERGENCY RESPONSE RESPONSE TI!!E NUMBER OF PERSONNEL MAJOR FUNCTTONAL AREA LOCATION MAJOR TASKS POSITION / TITLE ON SilIFT 60 MIN 90 MIN Notification CR Initial notification Operations personnel Communication and initiate RERP on shift Actions TSC On going communications TSC personnel Radiological Accident CR Initial assessment Operations personnel Assessment & Support and offsite dose on shift projections TSC On going assessment TSC pereonnel FCP Dose projections &
Senior Manager technical assistance Rad. Prot. Mgr.
to State / Local EOC Coordination with Mgr. Nuclear Engr.
1**
State and Health Mgr. Cov. Affairs 1**
Dept.
Rad. Prot. Consultant 1**
PCC Radiological Surveys llP Techs 1
4 4
Chemistry / Rad CSem Rad' Chem Techs 2
1 Plant System CR/TSC Technical Support Tech Advisor 1**
1**
Engineering, Repair &
React. Engr.
1**
Corrective Action I & C Supvr.
1**
Tech Personnel 2**
PCC Repair and Corrective Mech. Maint.
2 10 Action Elect. Maint.
1 2
1 & C Personnel 1
6 Protective Actions PCC Radiation Protection /
IIP Techs 1*
See PCC under Assessment Rad. Accident Suppor3
FORT ST. VRAIN STATION STAFFIMG FOR EMERGENCY RESPONSE RESPONSE TIME NUMBER OF PERSONNEL MAJOR FUNCTIONAL AREA LOCATION MAJOR TASKS POSITION / TITLE ON SilIFT 60 MIN 90 MIN Fire Fighting CR/PCC Fire Fighting Fire Brigade Fire Brigade Per Tech Specs Local Support Rescue Operations PCC Initially on Shift Personnel Site Access Security, Firefighting Security Personnel All Security Personnel per Security Plan Control & Personnel communications Lead Security Officer 1
1 3
Accountability accountability 9
32 74 May be provided by shift personnel assigned other functions.
^^ Personnel accounted for under a different category or task of the Table.
L:gend - CR - Control Room ECP - Executive Command Post (Denver)
EOC - Emergency Operations Center (Camp George West)
FCP - Forward Command Post, Fort Lupton (ECF in NRC Terms)
PCC - Personnel Control Center (OSC in NRC Terms)
TSC - Technical Support Center (On Site)
SLO - Senior Licensed Operator LO - Licensed Operator l
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Pul2lIC CCi",'IOC COmpalW N C:5Md3
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August 28, 1930 i.
Fort St. Vrain Unit fio. 1 P-80288 Mr. Robert L. Tedesco, Assistant Director Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C.
20555-
SUBJECT:
Fort St. Vrain Unit fio. 1 Emergency Response Plan
REFERENCE:
NRC Letter July 23,.1980
Dear Mr. Tedesco:
We are transmitting herewith three (3) copies of our revised emergency response plan. This revised plan includes changes as a result of the May 21,
- 1930, plant site review meeting as well as certain changes that resulted from comments contained in your-July 23,
- 1930, letter.
In addition to the revised plan, we are provit:ing our response as Attachment A to this letter tc address your July 23,1930, letter.
As we indicated in the May 21, 1980, meeting as well as in various correspondence submitted as a part of the TMI-2 Lessons Learned Tasks, we believe Fort St. Vrain is a completely different reactor This reactor concept coupled with the size of the reactor concept.
negates many of the requirements setforth by N'JREG's 0654 and 0610 which were developed primarily on the basis of 1,000 MW(e) light l
water reactor technology.
It is imperative, therefore, that our Emergency Plan be evaluated on the basis of our reactor design and t
size, and that generic requirements be evaluated on the basis of specific technical, safety, and environmental differences'.
essentially develop our own criteria for Fort St.
We have had to Vrain utilizing water reactor criteria setforth by various Nuclear-Regulatory Commission documents.
On this basis our criteria is necessarily different from that published and we have taken-justifiable exception to the NUREG's.
These. exceptions were supported in various correspondence (see reference list attached) and are further supported by Attachment A of this letter.
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J s In the May 21, 1980, meeting we ' were. informed by theNuclhar Regulatory Commission review team that many of the' items were.a matter of policy, and'that the review team did'not have the authority to make exceptions on policy -
regardless of the technical matters justification.
We.cannot accept this position, and we request that as soon as you have had the. opportunity to review our revised emergency plan and our respo~nse that we be given the opportunity to meet with you and other personnel who do have the authority to evaluate and/or accept our positions on the basis of the technical justification provided.
In the interest of time it is requested that such a meeting be established at the earliest possible date so that we may finalize our plans to meet. the various commitment dates setforth. We will be available to meet with you at your convenience and are looking forward to hearing from y.ou shortly.
Very truly yours, W Owr ~by
' ' Don W. Warembourg y
Manager, Nuclear Production Fort St. Vrain Nuclear Generating Station DWW/alk Attachments i
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PSC CORRESPONDENCE LISTING
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LETTERS TO NRC INVOLVING TMI-2/ EMERGENCY PLANNING / EMERGENCY RESPONSE PLA"5 Correspondence Number Date Subject 1.
P-79130 June 15, 1979 Gaseous Effluent Monitors 2.
P-79205 September 10, 1979 Emergency.
- Planning, Fort St. Vrain 3.
P-79239 October 17, 1979 Followup Action TMI-2 4.
P-79249 October 29, 1979 Followup Action Resulting From NRC Reviews Regarding the TMI-2 Accident 5.
P-79290 November 30, 1979 NUREG-0610 6.
P-79298 December 12, 1979 Fcrt St. Vrain, Unit No. 1, TMI Lessons Learned 7.
P-79299 December 12, 1979 Revised Followup Actions Resulting From NRC Reviews Regarding TMI-2 Accident
~ ~ ~
8.
P-79305 December 18, 1979 Supplementa ry
- Response, Item 2.2.1.b, Lessons Learned Task Force, TMI-2 9.
P-79312 December 28, :079 Additional Information Regarding June 1,
- 1980, Action Items Resulting from TMI-2 10.
P-80011 January 29, 1980 Request for Evacuation Times 7
11.
P-80028 February 20, 1980 Additional Information Resulting from TMI-2 NRC Review Team Site Visit, j
January 21-22, 1980 l
12.
P-80041 March 5, 1980 Request for Evacuation Times
- 13. P-80083 March 18, 1980 Fort St. Vrain, Unit No. 1, I
Radiological Emergency Response Plan l
14.
P-80066 April 1, 1980 Fort St. Vrain, Unit No. 1, Emergency Planning 1
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ATTACHMENT A pSC RESPONSE TO NRC COMMENTS FSV EMERGENCY RESPONSE PLAN 1.
NRC Ouestion/ Comment Plan 'must-be revised to establish a principal and an alternate EOF.
Both facilities should meet the recuirements of Darrell G. Eisenhut's letter of April 25,
- 1980, subject
" Clarification of NRC Requirements for Emergency
Response
Facilities at Each Site."
~
PSC Resoonse We cannot address the principle and alternate EOF as we have never received the April 25, 1980, letter which you reference.
It is our understanding that new criteria will be published as'a part of NUREG-0696.
Upon receipt and evaluation of this document we will modify our emergency plan.
In the interim we intend to continue with,our plans to utilize the Fort Lupton Municipal Building for the EOF as stated in our letter P-80083.
As we understand the new criteria being developed under NUREG-0696, a distance of approximately 10 miles from the reactor would be acceptable for the EOF.
Depending on the criteria specified for the EOF and an alternate EOF we will re-evaluate our position at the time NUREG-0696 is published.
2.
NRC Ouestion/ Comment Plan must be revised to take into consideration the plant staffing in Table B-1 of NUREG-0654.
There must be some augmentation of on-site personnel within 30 minutes. Must identify position that will not be filled and provide rationale for not having 10 personnel on shift at all-times.
PSC' Response t
Consideration was given to the plant staffing in our April draft of the RERP.
Figures 5.1-1 through 5.2-6 of the RERP depict l
' both the normal and the emergency staffing for the plant.
Figure 5.1-2 provides the normal operating staff (9 personnel plus a Lead Security Officer) for the plant and fulfills the on-shift requirements of Table B-1, NUREG-0654, with the exception that we do not have a Rad / Chem Technician on shift.
The on-shift Health Physics Technician has sufficient training to perform the necessary initial surveys and radiological assessments to protect in plant personnel. The operating staff has sufficient training and procedures to evaluate the off-site effects. We can see no immediate requirement for the Rad / Chem Technician ~ especially since our. accidents develop at a much slower rate than comparable water reactor accidents (see NRC letter Themis Speis to J. Fuller, March, 1980, Acceptance of Category A TMI-2 Recuirements).
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With reference to the augmented staff called for in Table B-1, NUREG-0654, we have justified delaying the response time of the Shift Technical Advisor (STA) (based again on the rate in which our accidents develop) from 10 minutes to one (1j hour (see PSC letters P-79249, October 29, 1979; P-79299, December 12, 1979; P-79305, December 18, 1979; P-79312, December 28, 1979).
The accident time frames and the associated response times were accepted by the Nuclear Regulatory Commission by. the above referenced letter (Themis Speis to J. Fuller, March,1930) in
-the overall acceptance of the Catego y A TMI-2 requirements.
Since the Nuclear Regulatory Commission found the response time of the STA to be acceptable we maintain that the 30 minute augmented staff time called for in NUREG-0654, Table B-1, is not apclicable to Fort St. Vrain. On the basis of the slow time in wnich accidents develop and the one (1) hour resonse time of the Technical Advisor we committed in our RERF (Section 5.2) to have the emergency organization activated within 90 minutes which would include an augmented staff equivalent to Table B-1, NUREG-0654.
This staff zugmentation is consistent with Tecnnical Advisor response time and is certainly consistent wi n accident analysis and the accident development time frames.
3.
NRC Duestion/ Comment The plan must (in addition to other NUREG-0610 notification requirements) specify that when a " general" emergency is declared that the off-site authorities resconsible for implementation of protective measures will be notified by the
" Plant Emergency Director" and advised of recommended protective actions within 15 minutes of the direction-of the emergency condition.
The plan must specify the content of this initial message to include:
a.
Class of emergency b.
Whether a release is taking place c.
Affected areas d.
Protective measures NOTE: The protective measures recommended in the initial message off-site may be "go inside - turn on radio" (30 minutes) provided a followup message indicating more detail protective measures based on dose projections.
PSC Response Per your request the notification time of fifteen (15) minutes after determination that a "gener&1" emergency exists has been-added to Table 4.1-4 of the RERP.
Sample notification messages as well as followup messages have been included in Section 6 of the RERO (see Figures 6.1-1 through 6.1-3).
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