ML20040D898
"Draft Supplement" is not in the list (Request, Draft Request, Supplement, Acceptance Review, Meeting, Withholding Request, Withholding Request Acceptance, RAI, Draft RAI, Draft Response to RAI, ...) of allowed values for the "Project stage" property.
| ML20040D898 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 01/27/1982 |
| From: | Broehl D PORTLAND GENERAL ELECTRIC CO. |
| To: | Clark R Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0696, RTR-NUREG-0814, RTR-NUREG-696, RTR-NUREG-814 TAC-43091, TAC-46059, TAC-46131, NUDOCS 8202020372 | |
| Download: ML20040D898 (7) | |
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- Ellll PortlandGeneralElectricCompany Donald J. Broehl Assciant Vce Prescent January 27, 1982 Trojan Nuclear Plant Docket 50-344 License NPF-1 Director of Nuclear Reactor Regulation N
g ATTN:
Mr. Robert A. Clark, Chief D
Operating Reactors Branch No. 3
,,d t:p,; g c3 Division of Licensing U. S. Nuclear Regulatory Commission g
Washington, DC 20555 FEB 1 1982:*- %
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Dear Mr. Clark:
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TROJAN NUCLEAR PLANT g
Emergency Response Facilities Draft NUREG-0814 This letter provides supplemental information regarding NUREG-0696,
" Emergency Response Facilities". This supplemental information is submitted in response to your letter of December 3, 1981, which pro-vided the results of the NRC review on the Trojan Emergency Response Facilities.
Your letter of December 3, 1981 recommended PGE revise the design of the Trojan Emergency Response Facilities in accordance with draft NUREG-0814.
NUREG-0814 is still in draft form and has not been finalized. PCE reviewed the draft NUREG-0814 and submitted extensive comments to the NRC on November 6, 1981 in accordance with Federal Register Volume 46, No. 173. Our review of draft NUREG-0814 indicated that a number of new requirements were imposed in the draf t, most of which go beyond the scope of NUREG-0696, or in some cases are inconsistent with the requirements in NUREG-0696. Besides new requirements, some of the criteria in the draf t are too specific and prescriptive, which will discourage possible develop-ment of innovative designs to meet the intent of NUREG-0696. Based on this, we do not believe revising the Trojan Emergency Response Facilities in accordani:e with draf t NUREG-0814 is justifiable, and we would request the NRC to reconsider its application for evaluation of the Emergency Response Facilities.
In reviewing your evaluation of December 3, 1981, it came to our atten-tion that some of the criteria marked as "not specified" or " subject not addressed" are already contained in the Trojan Radiological Emergency 8202020372 820127 p
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PbrtiguiciGe 1eral BecVicCoiiipesiy Mr. Robert A. Clark January 27, 1982 Page two Plan (TREP) and associated Emergency Procedures (EPs) which were pro-vided to the NRC staff in accordance with 10 CFR 50.54 and Appendix E to 10 CFR 50.
For these criteria, the Attachment was prepared to reference appropriate sections of the TREP and EPs for your information.
With regard to your evaluation of the Emergency Operations Facility (EOF),
PGE continues its review of the habitability feature of the primary EOF at the Visitors Information Center against NUREG-0696 requirements. Our review should be complete by April 1, 1982. Supplemental information regarding the EOF will be submitted upon completion of our review.
Sincerely, Y
ATTACHMENT TROJAN NUCLEAR PLANT SUPPLEMENTAL INFORMATION ON NUREG-0696 EMERGENCY RESPONSE FACILITIES This Attachment contains the information prepared in response to the NRC letter of December 3, 1981 to supplement PGE responses transmitted on October 21, 1980 and April 15, July 2, and October 6,1981. The number-ing of the following sections corresponds to that of the evaluation criteria listed in the Attachment (draft NUREG-0814) to the NRC letter of December 3, 1981.
2.0 Technical Support Center (TSC) 2.1 Integration with Overall Planning Adequate PGE response.
2.2 Location The TSC is located in close proximity to the control room, which can facilitate face-to-face communication with control room per-sonnel. Thus, no other means to facilitate visual or auditory communication other than regular voice communication are necessary.
Regarding face-to-face communication, travel between the TSC and the control room can be done through the Turbine Building and Control Building via the road between the TSC and Turbine Building.
Based on analysis in Trojan FSAR Section 15.5, an individual's integrated dose during this transit should be less than 0.1 rem.
2.3 Staffing Staffing of the TSC is described in the Trojan Radiological Emer-gency Plan (TREP), Chapter 2, Section 5.2.2.2, for the interim TSC; similar staffing will be maintained at the permanent TSC.
Locations of personnel work stations and equipment for TSC person-nel will be developed to satisfy each function as described in the TREP, Chapter 2, Section 5.2.2.2.
The layout of the TSC data system displays will be coordinated with the working space layouts.
Sufficient space is available in the record area, office cubicles, and command center in the TSC for working with drawings and documents.
2.4 Structure Adequate PGE response.
2.5 Habitability The permanently installed radiation monitors, ie, the area radia-tion monitor on each floor of the TSC and the airborne radioactivity mocitor in the ventilation system of the TSC, provide warning in 7
2 a' timely manner to the TSC personnel to take protective actions.
The airborne radioactivity monitoring system consists of a noble gas.
monitor, a particulate monitor, and an airborne iodine detector.' The monitoring system instruments operate continuously and unattended.
The TSC ventilation system can be manually isolated when the airborne radioactivity monitor alarms. The permanently inatslied area radia-'
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tion monitors will provide two levels of. warnings: an alert alarm,
and a high alarm. The alarm aetpoints for the airborne radioactivity monitoring system and the area radiation monitors will be establish'd e
in the future. Dedicated dose rate instruments',T survey meters and airborne monitors which have the ' capability to detect 1 x 10-7 pCi/cc of I-131 are also assigned to the TSC as described in Trojan Emer-gency Procedure EP-15, Table 15-7.
Emergency supplies, including KI tablets, which are available at the interim TSC, are described in the TREP, Chapter 2, Section 7.4, Appendix 2-D, and Emergency Procedure EP-15, " Emergency Supply Lists".
The supplies of the emergency kit at the permanent TSC will be expanded to include protective clothing and respiratory equipment.
Instructions for and administrations of KI tablets in the emergency response facilities are described in Emergency i
Procedure EP-14.
2.6 Staffing See Section 2.3, above. The specific duties and responsibilities of all TSC personnel are provided in Emerge,ncy Procedure EP-7.,
" Operation of the TSC".
Several clerical personnel will be. assigned to support the TSC staff. Coordination among other emergenuy response facilities and within the TSC is also provided 'in Figures 2:5.2-1 and 2:5.2-2 in the TREP.
2.7 Communications A description of the TSC communication system at'the interim TSC is provided in the TREP, Chapter 2, Section 7.2, and Emergency Proce-dures EP-7, " Operation of the TSC", and EP-19, " Communications".
The same level of communication will be established at the permanent TSC. The commercial telephone 9ystems will be available for the backup communication system to the NRC.
2.8 and 2.9 Instrumentation and Technical Data System i
See Sections 6, 7, 8, and 9, following.
2.10 Records Availability and Management
[
l All the records, operational specifications, and procedures listed I
in Section 2.10 of the NRC evaluation criteria (NRC letter of l
December 3,1981) will be either stored in the TSC or accessible to the TSC personnel. The TSC has a record storage vault which i
l complies with ANSI N45.2.9-1979 for Trojan hard copy records. The l
records which have been microfilmed will have a microfilm copy available in the record storage area on the upper level of the TSC.
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3 3.0 Control Room
- 3.1 Integration with Overall Planning Staffing of the control room during normal operations is covered in
' Trojan Technical Specifications, Section 6.2.2, and Trojan Adminis-trative Order, A0-3-1.
The restrictions on control room access by the Shif t Supervisor during normal and accident conditions are specified in A0-3-8.
The functions and responsibilities of the
_J control room operators during emergency conditions are described in the TREP,-Chapter 2, Sections 5.2 and 7.1.1.
Detailed instructions for emergency notification and control room protective action recom-mendations are provided in Emergency Procedures EP-6 and EP-23.
3.2,/ Staffing The TREP, Chapter 2, Section 5.2.2.1, defines the specific authori-ties, responsibilities, and duties of the control room personnel.
The manning levels of the control room operators during normal and emergency conditions are provided in Figures 2:5.1-2 and 2:5.2-2, respectively.
3.3 Communications A description of the control room communication system is provided in the TREP, Chapter 2, Section 7.2, and Emergency Procedure EP-19.
p 4.0 Opetational Support Center (OSC) 4.1 Integration with Overall Planning m
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A description of the OSC and its assigned functions is provided in the TREP, Chapter 2, Section 7.1.6.
Figure 2:5.2-2 of the TREP, Chapter 2, provides an overall integration of the OSC with other emergency response facilities. Activation and operation of the OSC are discussed in detail in Emergency Procedure EP-9.
t 4.2 Habitability The OSC is located at the area behind the control boards around the Hagan Recks and at the access control area at Elevation 45 ft of the Control Building. The Hagan Rack OSC provides the same levels of habitability as the control room. Personnel at the access con-trol OSC will evacuate to the Hagan Rack OSC if required. Therefore, a backup facility for the OSC is not necessary at Trojan. Emergency supplies of protective clothing, respirators, survey meters, dosi-meters, and KI tablets available in the OSC are described in the i
TREP, Chapter 2, Appendix 2-D, and Emergency Procedure EP-15.
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4.3 Communications A detailed descripton of the OSC communication system is described in the TREP, Chapter 2, Section 7.2, and Emergency Procedure EP-19.
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4.4 Staffing The staffing level of the OSC, together with assigned authority and duties, are discussed in the TREP, Chapter 2, Section 5.2.2.3.
4.5 Size Two areas are designated as the OSC to provide sufficient space for the assigned personnel:
the Hagan Rack area at Elevation 93 ft of the Control Euilding, and the access control area at Elevation 45 f t of the Control Building. A decostamination facility is available in the access c_ontrol area at Elevation 45 f t of the Control Building.
5.0 Edergency Operations Facility (EOF) 5.1 Integration with overall Emergency Planning Adequate PGE response.
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5.2 Location, Structure, and Habitability PGE continues its review of the option of the primary EOF at the Visitors Information Center and the alternate EOF at the PGE St. Helens Office. It is expected that our review will be com-pleted by April 1, 1982. Supplemental information for this section will therefore be provided upon completion of our review.
5.3 Staffing The staffing for the EOF is discussed in the TREP, Chapter 2, Section 5.2.2.5, including a detailed description of authority and responsibilities of the assigned personnel.
5.5 Radiological Monitoring See Section 5.2, above.
l 5.6 Communications A description of the EOF communication system is provided in the TREP, Chapter 2, Section 7.4, and Emergency Procedure EP-19.
The commercial telephone system is available for backup communications to the NRC.
5.7 Instrumentation 5.8 Technical Data System 5.9 Records Availability and Management See Section 5.2, above.
6.0 Data Acquisition System 7.0 Data Display System 8.0 Data Communications 9.0 System Support Requirements i
5 We do not believe the detailed information requested in these sections provides useful purposes for design review of the TSC computer system.
NUREG-0814 should be limited to specifying objectives to be met and leave particular methods to utilities for meeting the stated objectives.
The functional criteria for the TSC computer system is described in WCAP-9725, which was transmitted to the NRC in PGE letter dated July 2, 1981. Instead of requiring massive amounts of data concerning the TSC computer system, we propose that the NRC conduct a generic technical audit of the Westinghouse TSC computer system as discussed in the Westinghouse letter, NS-EPR-2530, of January 6,1981 (E. P. Rahe to D. G. Eisenhut and L. Beltracchi). This technical audit is similar to the verification and validation process described in Section 5 of NUREG-0835. We believe such a review would be manpower cost-effective for both the NRC and PGE.
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