ML20041B855
| ML20041B855 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 01/05/1982 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20041B852 | List: |
| References | |
| NUDOCS 8202250264 | |
| Download: ML20041B855 (13) | |
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- xms (412) 456-6000 43$ Stath Avenue Pittsburgh Pa 15219 January 5, 1982 United States Nuclear Regulatory Commission Office of Inspection and Enforcement Attn:
Mr.
R. C. Haynes, Regional Director Region 1 631 Park Avenue King of Prussia, Pennsylvania 19406
Reference:
Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 NRC Emergency Planning Appraisal Centlemen:
In response to your letter of November 2, 1981, the attached reply provides a report on the status of corrective measures being taken to respond to the significant findings identified by the NRC Emergency Planning Appraisal team in their evaluation of the implementation of the Beaver Valley Power Station Emer-gency Preparedness Plan.
Your.etter identified six (6) items.
Each item is addressed in Appendix A of this reply.
Appendix B provides a report on the evaluation that was per-formed pursuant to Item 2 to determine how the augmentation of the on-shif t staf f could be achieved within criteria of NUREG-0654 Table B-1.
This eval-uation indicated that the on-shift personnel could be augmented with called-in personnel in about 30 minutes, with complete activation within about 60 minutes.
Howeve r, as we indicated in our letter of August 25, 1981 from Mr. J. J. Carey to Mr. S. A. Varga, this represents a best time estimate.
The analysis does not take into account inclement weather, nor does it take into account failures of the l
paging devices to alert personnel and the subsequent delays in sequentially locating designated alternates. As we expressed in our previous letter, we do not feel that we can realistically commit to 100% activation within 30 minutes for every occasion.
Duquesne Light conducted an on-site exercise'of the EPP on November 18, 1981.
During the critique to that exercise, our personnel identified additional deficiencies in procedures and equipment.
Some of these additional deficiencies are related, in part, to the six itens; identified by the Appraisal Team.
- Thus, although we feel that we have adequately responded to the commitments specified in your letter, related, additionri work on EPP aspects covered by the identi-fied items is on-going.
B202250264 820216 PDR ADOCK 05000334 G
n United States Nuclear Regulatory Commission January 5, 1982 Page If you have any questions concerning this response, please contact my office.
Very truly yours, J. J. Carey Vice President, Nuclear Attachments cc:
Mr. D. A. Beckman, Resident Inspector U. S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 U. S. Nuclear Regulatory Commission c/o Document Management Branch Washington, DC 20555 l
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I COMM0fNEALTH OF PENNSYLVANIA)
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COUNTY OF BEAVER
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On this 4
day of edu,fut
/974, before
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Yaku 'Jers, N j, a NotaryjPublic ir}fand for said Commonwealth me,
m and County, personally appeared J. J. Carey, who being duly sworn, deposed,
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and said that (1) he is Vice President of Duquesne Light, (2) he is duly authorized to execute and file the foregoing Submittal on behalf of said Company, and (3) the statements set forth in the Submittal are true and correct to the best of his knowledge, information and belief.
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DUQUESNE LIGHT COMPANY Beaver Valley Power Station Unit No. 1 Status of Emergency Planning Appraisal Items Appendix A Inspection No. 81-27 Letter dated November 2, 1981 ITEM 1 Revise the emergency organization, the BVPS Emergency Plan and implementing procedures to provide for performing required emergency functions at your Emergency Operations Facility (EOF).
Specifically, the EOF staff should be responsible for performing the functions of (a) overall management of your emergency response, (b) radiological / environmental assessment and (c) offsite protective action recommendations.
These actions will be completed by December 1,1981, with the exception that the performance of the function of radiological /
environmental assessment from the EOF will be implemented by December 31, 1981.
The BVPS Emergency Preparedness Plan and Implementing Procedures were revised to provide for an Emergency Operations Facility organization responsive to the guidance of NUREG-0696.
These revisions were approved in September 1981, but not made effective in order to provide time to complete personnel training on the new organization. These proposed revisions were discussed with the NRC appraisal team members.
Following the appraisal, the need for some additional changes was identified. These additional changes were incorporated on November 16, 1981 and made effective on December 1, 1981, as Issue 6 Revision 4.
With regard to environmental assessment and dose projection capability, proce-dural changes have been incorporated as part of Issue 6 Revision 4.
A radio console necessary for communications with offsite radiological survey teams has been installed for use by the Environmental Assessment and Dose Projection t
personnel. This console utilizes the main Shippingport transmitter and tower and therefore provides for communication over essentially all of the ten-mile EPZ.
A teletype terminal has been installed to provide meteorological data to these personnel. However, the software changes necessary to provide access to the meteorological computer data base have not been completed. We expect this
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capability to be fully operational prior to February 15, 1982.
In the interim, l
EA & DP personnel can access meteorological data via the existing TSC/ Control Room CATV system.
Action on this item will be complete with completion of software changes.
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Status of Emergency Planning Appraisal Items - (Continued)
ITEM 2 Pursuant to the requirements of the generic letter dated February 18, 1981 to all licensees from Mr. D. Eisenhut, NRR, regarding the minimum staf fing requirements for nuclear power plant emergan-cies, a study shall be performed to determine how the augmentation of the onshif t staf f can be achieved within the 30 and 60 minute goals of NUREG 0654, Table B-1 after the declaration of an emergency.
The results of this study will be documented and forwarded to the NRC for review and evaluation along with a description of compensa-tory measures for any augmentation goals not met.
The results of the study will be made available no later than December 31, 1981.
Duquesne Light conducted an evaluation of the capability of the BVPS emergency organization to augment the on-shift personnel within the criteria of NUREG-0654, Table B-1.
The results of this evaluation are attached to this letter as Appendix B.
This report identifies the various emergency organization func-tions, the on-shif t and augmentation personnel who would perform those func-tions, and the expected low, mean, and high travel times for these personnel.
This evaluation indicated that the BVPS Emergency Organizatien is responsive to the Table B-1 criteria.
In addition to this study, Duquesne Light has increased the on-duty shift complement to ten individuals with the addition of an Admin-strative Aide to the Shif t Supervisor.
In an emergency situation, this individual is assigned the responsibility for notifications and communications until relieved by the designated Communications and Records personnel.
Action on this item is complete.
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O Status of Emergency Planning Appraisal Items - (Continued)
ITEM 3 Complete impicmentation of the planned emergency preparedness training program.
Specifically. complete the preparation of lesson plans and conduct the specialized emergency training outlined in the BVPS Emergency Plan for your personnel and offsite support organizations The portions of this training program designed for your Emergency Directors. Emergency Recovery Managers, Dose Projection Coordinators, and Shif t Communications Coordinators will be complete by December 1, 1981.
The remainder of the required training will be complete by February 15, 1982.
Personnel designated as Emergency Director, Emergency / Recovery Manager, Dose Projection Coordinators, and Shift Communications Coordinators, and their designated alternates were provided training in their emergency responsibilities.
With the exception of two alternates to the Emergency / Recovery Managers and an alternate to the Emergency Director, all designated Emergency Directors, Emergency / Recovery Managers, and Shift Supervisors completed the training.
With the exception of one Shift Supervisor, all personnel designated to perform dose projection received training in the new short-form dose projection procedure.
All Shift Communications personnel completed the training.
Personnel who did not attend the required training (four out of forty-eight) have been re-scheduled to a ttend make-up sessions in January 1982.
As specified in your letter, the required training for other emergency personnel will be conducted prior to February 15, 1982.
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Status of Emergency Planning Appraisal Items - (Continued) i i
ITEK 4 Identify techniques which can compensate for uncertainty i
associated with plume trajectories in the BVPS environs and incorporate them into the dose calculation nothodology.
j Additionally. training in this methodology shall be completed i
for all shif t personnel who would be responsible for making dose assessments.
This will be accomplished by December 1,1981.
Appropriate compensatory measures have been incorporated into the BVPS EPP/
implementing Procedures to contend with the uncertainty regarding plumo
'i t rajectories in the BVPS EPZ. A new procedure. EPP/IP-2.6.1, " Dose Projection--
Short Form", has been implemented.
This procedure, incorporates methodologies suggested by members of the appraisal team.
Specifically, the procedure is based on the ground level model of Regulatory Guide 1.143 LESS meander corrections 1
and uses the Xu/Q versus distance and stability class graphs in lieu of the previous X/Q versus distance, wind speed, and stability class tables.
The procedure directs the shif t personnel to recommend appropriate protective measures in a minimum two-mile 360-degree area, if the dose projection in any downwind direction indicates the need for such measures beyond the site boundary.
If dose projection indicates the need for protective measures beyond this two-mile radius area. the additional affected area is determined using a graphical tool. The affected area determined by this tool is the total area enclosed by two 90 degree wedges centered on the indicated 35-foot wind direction (valley floor) and the 500-foot wind direction (synoptic winds).
(Thus, the affected area could range from 90-degrees to 360-degrees.) The radius is determined by dose projection.
This wedge is in addition to the minimum two-mile, 360-degree area.
Procedure EPP/IP-2.1, " Emergency Radiological Monitoring", has been revised to provide guidance to the Environmental Assessment and Dose Projection Coordinator for ensuring that offsite monitoring teams are dispatched in the indicated path of the plume and in other areas where the plume could be expected to disperse due to terrain effects.
Interim compensatory measures are complete.
The status of training on these 1
revisions is as indicated above in Item 3.
These interim compensatory measures implement a conservative, administrative solution to the stated uncertainty. Technical solutions are being evaluated in conjunction with your Meteorological Assessment Branch to provide the permanent meteorological capabilities required in 1983.
Action on this item is complete.
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r Status of Emerger.cy Planning Appraisal Items - (Continued)
ITEM 5 Finalize plans for and nake operational your interim Emergency Operations Facility, including communications equipment, decisional aids and reference materials.
These plans should also include provisions to reduce the potential for congestion in the Control Room / Emergency Coordination Center area by performing non-plant mitigation / operation functions in the Technical Support Center and EOF.
The interim Emergency Operation Facility will be made functional no later than December 1,1981 wi;h the exception of the dose assessment facilities which will be operational no later than December 31, 1981.
As identified for Item 1 and Item 3 above, procedural changes necessary to implement an Emergency Operations Facility are complete, and training has been conducted for primary assigned personnel, with additional training to be completed by February 15, 1982. These procedural changes have relocated all but plant operations from the Control Room to the Technical Support Center and Emergency Operations Facility.
Decisional aides and communications equipment identified to respond to this finding are in place or have been requested.
We have requested, and are awaiting installation of additional NRC ENS and HPN and direct hotline to the Pennsylvania Bureau of Radiation Protection.
Installation of this equipment is not within the control of Duquesne Light and, we are therefore unable to specify installation dates.
Reference materials for the TSC and EOF were available during the inspection in the central records vaults adjacent to the TSC/ EOF.
The availability of these materials in this location will be emphasired in the training program to be completed by Fchruary 15, 1982.
With the exception of the aforementioned communications equipment, action is complete on this item.
During the on-site exercise, conducted on Novemi>er 18, 1981, additional deficiencies were identified by Duquesne Light personnel in communications and decisional aides. Actions to correct these additional deficiencies, are currently underway and are expected to be complete by February 15, 1982.
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Status of Emergency Planning Appraisal Items - (Continued)
ITEH 6 Revise the notification procedures to provide for prompt notification of your offshift emergency response organization and offsite agencies.
Individuals on each shift shall be trained in the use of the revised procedures and any equipment changes These revisions and actions will be implemented no later than December 31, 1981.
We have provided all designated primary emergency response personnel and selected designated alternates with personal radio paging devices.
These paging devices were obtained from paging services in Beaver County (for Beaver County area residents) and in Pittsburgh (for Pittsburgh area residents). Telephone calls by the Shift Supervisor's administrative assistant to the two servicing companies tones outs the two sets of pagers simultaneously.
Personnel have been directed to call into a designated line to acknowledge the page.
An auto-matic answering machine on this designated line provides a taped message in-dicating the nature of the emergency condition and the fact that a callout is being made.
Upon receipt of this message, personnel identify themselves to acknowledge that they have received the notification. The Shift Supervisor's administrative assistant plays back this tape after a sufficient period of time has elapsed, to identify any significant shortfalls in personnel activation.
This equipment is installed and procedures governing its use have been incorporated into the EPP Implementing Procedures and applicable personnel have received instruction in the use of the equipment.
However, the pagers supplied by the Beaver County concern have proven to be unreliable due to weak batteries and spurious activation / inactivation. Thus, we have retracted the Beaver County pagers and have requested the paging service to obtain more reliable devices.
The pager firm has notified us that new pagers are on order and are expected to be available in early January.
To facilitate of fsite agency notification, we have installed an auto-dialer device in the Control Room.
The telephone numbers for the primary off site a ge ncie s, the paging services, and other notified parties are pre-programmed into this device. To further facilitate the notification process, we have designated the newly assigned Shif t Supervisor's Administrative Assistant as the individual responsible for making notifications, thus relieving shift operations personnel of this responsibility.
Upon receipt of the replacement Beaver County pagers, action on this item will be complete.
DUQUESNE LIGHT COMPANY Beaver Valley Power Station Unit No. 1 1
Appendix B l
Emergency Organization Augmentation Times Inspection No. 81-27 i
Letter dated November 2, 1981 Introduction This document provides the results of the evaluation performed to determine the time required to augment the Beaver Valley Power Station emergency organization in the event of an emergency conditon requiring the activation of the Technical Support Center and/or Emergency Operations Facility. This evaluation was performed in response to item 2 of the subject inspection report, and was based on a comparison of the BVPS emergency organization and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants".
Methodology The evaluation was performed in two phases. The first phase was to determine the travel time required by the designated personnel to arrive at the site following notification. Questionnaires were distributed to the supervisory personnel designated as primaries and alternates to each emergency position.
Each person responded with the normal travel time from their residences to the j
station.
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The individual travel times were increased by 10 minutes each to provide for preparation time prior to departure.
No adjustments were made for notification time as the primary individuals are provided personal radio paging devices which are simultaneously keyed by the paging services (2) called by the shif t personnel.
Personnel within this group are identified by a letter "B" in the column marked "means of notification" on Table 1, which is attached to this appendix.
Table 1 tabulates the low, mean, and high adjusted travel times for these personnel.
i For supplementary personnel, most of which are bargaining unit or contractor l
personnel, a different methodology was employed.
An area map was annotated with l
the residence and travel time of each individual who was provided questionnaires.
The residence of each supplementary person was located on this map and a travel time extrapolated from adjacent data points.
In addition, these personnel individ-uals responsible for initiating these call-outs have been provided personal radio paging devices. We expect that these call-outs could be completed within about 15 minutes.
Since the call-out times will vary depending on the individual's position on the call-list, no adjustments were made for notification time.
However, the previously discussed 10 minute preparation time was incorporated.
These supplementary personnel are identified on Table 1, by the Letter "C" in the column marked "means of notification",
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Appendix B - (Continued)
The second phase of this evaluation involved the comparison of the derived BVPS augmentation times with the guidance of Table B-1 of NUREG-0654.
A matrix identifying emergency function, major tasks, designated shif t and non-shift personnel, non-shift augmentation times derived in phase 1, and NUREG-0654 Table B-1 requirements, was prepared.
This matrix is attached as Table 1 to this appendix.
Results As can be seen on Table 1, Duquesne T.ight has the capability to substantially augment its on-shif t personnel within the guidance of Table B-1 of NUREG-0654 under favorable conditions.
No provision has been made in this evaluation for failure of radio paging devices, or the time necessary to sequentially locate designated alternates. As we expresced in our letter of of August 25, 1981, we do not feel that we can commit to 100% augmentation within 30 minutes of personnel notification.
However, we will continue to maintain an emergency organization and a notification system which will have the objective of meeting the 30-minute response criterion.
TABLE I Augment.
NUREC Major Functional Position Title Tines
-0654 Area Major Tasks Onshift Offshift to Mean Hi 30 60
::-- :----- :--- ;--- = - - -
Plant Operations NSS 1
& assessment of NSOF 1
operational NCO 2
NO 2
STA 1
Emergency dir. &
NSS 1*
Em. Dir.
30 50 70 B
Control (3/3) b RC 30 46 70 B
1 2
Notification &
No ify licensee, NSS 1
Communication state, local &
Asst.
(2/5)
Federal Personnel
& maintain comm-C & RC 25 41 70 C
ications Assts.
(17)
Radiol g cal EOF Director NSS 1
E/RM 50 63 65 B
1 accident assess-(4/4) ment & support of ops. accident Offsite dose NSS 1
EA & DP 30 41 55 B
1 --
assessment projection NSOF 1
(2/4)
Offsite surveys SCRT 1
RCT 20 49 75 C
2 2
(17)
Onsite surveys SCRT 1
RCT 20 49 75 C
1 1
(Outside Plant)
(17)
Inplant surveys SCRT 1
RCT 20 49 75 C
1 1
(17)
Chemistry SCT 1
CT 20 46 75 C
1 (10)
Plant system Tech, support STA 1
TSC 25 50 75 B
eng, repair, (1/3) corr. actions Core & hydraul.
STA 1
off-duty 25 40 50 C
1 --
tech. supp.
STA (6)
= _ -
Electrical STA 1
Elect.
tech. supp.
Eng. (2) 55 55 55
-__=_
Mechanical STA 1
Maint.
30 50 70 C
1 tech, supp.
Eng. (2)
Mech. Maint.
No 1**
Maint.
35 35 35 B
1 Coord.
(1/2)
OSC 40 40 40 B
(1/2)
Radwaste oper.
NO 1**
off-duty 15 40 65 C
1 NSOF/NO
\\
Augment.
NUREG Major Functional Position Title Times
-0654 Area Major Tasks Onshift Offshift to Mean Hi 30 60
~ ::::::::::::::::::--~~ -~~~-- :~~~ 2~ ---------- ~ ~-----_ :::::::~-------- :::---~~-
Electr. Maint.
NO 1**
OSC 45 45 45 B
1 1
(1/2)
Inst. & Control NO 1**
MCR 20 45 65 B
1 (1/4)
Protective Radiation Prot.
SRCT 1
RCC 30 40 55 B
2 2
actions (onsite)
(2/5)
RCT 20 49 75 C
(17)
Firefighting Firefighting Shift Local Local emerg.
Support Supp.
squad
=--
Rescue & First Rescue & First Shift Local Local aid aid emerg.
Support Supp.
squad Site access control in accordance with site security plan State / Local E0C Liaison with Nuclear as requested by agencies Instrs.
offsite agencies Abbreviations:
NSS Nuclear Shift Supervisor NSS Asst.
Nuclear Shift Supervisor Administrative Assistant NSOF Nuclear Shift Foreman NCO Nuclear Control Operator NO Nuclear Operator STA Shift Technical Advisor SRCT Shift RadCon Technician SCT Shift Chemistry Technician RCC Radiological Controls Coordinator RCT RadCon Technician CT Chemistry Technician MCR Meter & Control Repairmen (I & C) l TSC Technical Support Coordinator OSC Operations Support Center Coordinator E/RM Emergency / Recovery Manager (EOF)
C & RC Communications and Records Coordinator C
Notification by call-out B
Notification by beeper p
(2)
Number of personnel designated (1/2)
(have heeper/ designated)
May be provided by shift personnel assigned other functions.
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