ML20049H476
| ML20049H476 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 02/18/1982 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| RTR-NUREG-0654, RTR-NUREG-654, TASK-1.A.1.1, TASK-1.A.1.3, TASK-1.C.5, TASK-1.C.6, TASK-3.A.2.1, TASK-TM TAC-44117, TAC-44118, TAC-46259, TAC-46260, TAC-48851, TAC-48852, NUDOCS 8203030116 | |
| Download: ML20049H476 (25) | |
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2 Wisconsin Electnc eom couem
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231 W. MICHIGAN, P.O. BOX 2046, MILWAUKEE, WI 53201
- - Feb, ry 18, 1982 Q
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dEC UO Q T FF fMn Mr. J. G. Keppler, Regional Director n/3 l
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Office of Inspection and Enforcement, yp r 'n
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S. NUCLEAR REGULATORY COMMISSION wm 799 Roosevelt Road i'
Glen Ellyn, Illinois 60137 51
Dear Mr. Keppler:
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J MINIMUM STAFFING REQUIREMENTS FOR NRC LICENSEES FOR NUCLEAR POWER PLANT EMERGENCIES (TABLE III.A.l.2-1 OR TABLE B-1 OF NUREG-0654, REVISION 1):
AND POINT BEACH NUCLEAR PLANT CONFORMANCE This is in response to item 1 of your letter dated January 21, 1981, which requested a description of how Point Beach Nuclear Plant intends to meet the minimum shift staffing guidance of NUREG-0654, Table B-1.
In making this response, it is our understanding that NUREG-0654 is to be used for informa-tion by the licensee and is not to be considered as providing inflexible criteria.
We believe that such a policy is particularly important in the area of emergency response management where plant location, design, and organizational variations have a significant impact on the planning required.
We summarize below the influences that location, design, staffing philosophy, and communications have on personnel requirements needed to assure safe and reliable operation under all expected conditions.
LOCATION A nuclear power plant, although usually " remote" in location in respect to population densities, should be as acces-sible as possible for personnel response.
Point Beach Nuclear Plant is in a unique rural, low population density, readily accessible site.
Up to within 1 miles of the plant, over one half dozen paved highway routes are available for personnel traffic.
At the sitt-periphery, three alternate traffic routes exist.
Point Beach Nuclear Plant is located in essentially flat farm country with a grid of paved roads.
The only impediment to access and fast response for augmentation to the shift complement is extremely severe winter weather in which two or three severe storms have occurred about one year out of every three.
To overcome this winter storm aspect, Point Beach staff closely follows weather conditions and when severe weather threatens P203030116 820218 pg0 19 1982
/
DR ADOCK 050002p
4 Mr.
J. G.
Keppler February 18, 1982 holds two or three operating shifts in the station on an alter-nating rest and coverage basis.
With the personnel flexibility used in staffing and training, these doubled up shifts compensate for time access problems that might be experienced by augmenta-tion personnel under severe weather conditions.
It should be noted that the location of Point Beach Nuclear Plant, in addition to accessibility for rapid augmenta-tion by off-duty plant staff, has an additional advantage related to emergency planning in that approximately one half of the emsrgency planning area lies in Lake Michigan.
Any radioactive releases toward the east would be relatively innocuous in respect to population effects, and the area to be surveyed by health-physics teams is greatly reduced from many other plants covered by Table B-1.
There are provisions, of course, to evacuate any water craft from the plant vicinity if needed.
Further, the proximity of the Kewaunee Nuclear Power Plant five miles to the north has allowed reciprocal agreements to provide personnel and facility assistance which is not available at many locations.
DESIGN Nuclear power plant layout should be as compact and convenient as possible in order to effect best personnel response in emergencies.
Point Beach Nuclear Plant is designed with a common control room, a common primary auxiliary building and all operating equipment "under one roof" except for the gas turbine, the electric switchyard and the pumphouse. Facility layout throughout was created to keep operations compact and shift personnel requirements small.
It is important to recognize these plant-specific features in the Point Beach design which promote efficient and effective use of personnel.
STAFFING Wisconsin Electric Power Company personnel have been involved in the staffing of nuclear power plants since the early 1950's, including involvement on many government and private projects. From this experience, the following insights regarding normal and emergency staffing and organizational structure have been presented at industry technical meetings and in technical publications in the interest of safe and reliable operation:
1.
Nuclear power plant personnel should be selected by the use of best available oral and written examina-tions.
Wisconsin Electric used such tests (similar to those of the Nuclear Navy) for evaluation of applicants in hiring all employes at Point Beach Nuclear Plant.
Point Beach will continue to use these tests or equiva-lent examinations in all future hiring.
2.
Nuclear plant staffing should concentrate on quality of people and not attempt to make up for the lack of
1 Mr. J. G. Keppler February 18, 1982 quality by quantity.
Small numbers of selected people appropriately trained and assigned responsibility and authority can function as a closely coordinated team.
This is especially true and important in emergency situations.
Large numbers of people tend to be less
-informed and less coordinated, and managerial supervision becomes more remote. In the determination of final staffing requirements, "across-the-board" numbers may be neither necessary nor desirable. In this regard, it is pertinent to note a statement on page I-28 of NUREG/CR-1656, " Utility Management and Technical
.'in over 500 reactor-years of Resources": "
experience, few if any sericus incidents have resulted from an inadequate number 'cf-op..rators.
The serious incidents that have occurred.
. developed more from a lack of qualifications 3.
Nuclear plant supervisors should be technically and physically skilled in the work they supervise.
All Point Beach Nuclear Plant Group Heads and supporting supervisors are skilled people who, in many cases, are more craft skilled than the skilled craftsmen they supervise.
These Group Heads and supervisors have had extensive " hands on" experience and keep current by continuous and direct operational involvement.
The Point Beach Nuclear Plant layout assists in this involvement by having Group Head's and supervisor's offices decentralized and close to their physical work activity.
4.
Backshift Duty Shift Supervisors should be able to obtain consultation from other experienced people about decisions that can arise in normal and off-normal situations. Therefore, at the outset of Point Beach Nuclear Plant licensed operation, a rigorous Duty and Call Superintendent system was instituted as backup to the Shift Supervisor. The Duty and Call Superintendents are on a duty roster and one, as a minimum, is available at all times by redundant means of communication (see Exhibit A).
In addition to immediate communication i
links, the Duty and Call Superintendents all live f
within fifteen miles of the plant and are committed to arrival at the plant within thirty minutes.
This duty system has been in operation for twelve years and a Duty and Call Superintendent (on duty for the week) averages two to six backshift telephone contacts per week. An event which requires that a Duty and Call Superintendent report to the plant has occurred, on the average, about twice per year.
5.
Key technical and operational support departments of a nuclear power plant should have a duty roster to maintain a senior person of that specialty department in the immediate area for consultation and call out.
Mr. J. G. Keppler February 18, 1982 The Point Beach Nuclear Plant Maintenance, Chemistry, Health Physics, and Instrument and Control groups, all have had rigorous duty rosters for many years (see Exhibit B).
The duty person is committed to immediate telephone availability, carries a telephone pager and is required to arrive at the plant in thirty or sixty minutes.
6.
Motivation of nuclear power plant personnel should be kept at a high level. Keeping the motivation of shift-assigned personnel at a high level is a difficult challenge, and particularly so if shift personnel do not have meaningful work assignments.
Therefore, Point Beach Nuclear Plant has minimized the number of shift workers, and made their shift work variable and comprehensive by multiple function dutie,.
For instance, each Auxiliary Operator is trained and qualified for watch standing at all three Auxiliary Operator stations and in addition is trained and qualified to perform certain chemical analysis work, normal and emergency health physics work (at the Radiation Control Operator level), minor mechanical and electrical maintenance, and radwaste processing and packaging.
Other examples of flexible use of shift personnel are that the Duty Shift Supervisor and Operating Supervisor change some assignments, Control Operators " work down" on occasions as Auxiliary Operators, and Auxiliary Operators cross over to Radiation Control Operator assignments during refuelings.
It is our strong belief that supernumery staff will detract from motivation, flexibility and competence of members of the shift team in dealing with emergencies.
It should be noted that operating nuclear power plants are now experiencing substantial terminations of older qualified shift personnel who are " bidding out" to day work; in some instances at significantly lower wages.
Requiring more shift work will further degrade quality and availability of shift personnel in the operating plants.
7.
The Shift Supervisor should not have excessive admini-strative duties. The more people put on shift, the greater the potential for administrative-type diversions to deal with numbers of people, their reporting, deployment, and assignments.
Our November 3, 1980 letter to Mr. D. G. Eisenhut which discussed many of these concerns, as well as staffing plans, provided a plan to add an eighth person on shift while indicating that such an increase, at that time, was not necessary.
Our April 14, 1981 letter to Mr. Denton stated our intention to achieve a shift complement of eight by July 1982.
Training is actively underway in an effort to carry out that plan.
In
Mr. J. G. Keppler February 18, 1982 addition, we have added a Rad Chem Technician to one additional shift, 5 days per week, providing 88 hours0.00102 days <br />0.0244 hours <br />1.455026e-4 weeks <br />3.3484e-5 months <br /> of the 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> per week.
COMMUNICATIONS AND AUGMENTATION Nuclear power plant communications should be as reliable, simple, and automated as the state-of-the-art affords.
Point Beach Nuclear Plant has more than one dozen outside telephone trunk lines, intercompany lines, intra-plant voice lines and over 100 telephone extensions; intra-plant radios on two frequen-cies; an area radio system of portable and auto mounted radios; and NAWAS communications.
The NAWAS and NRC direct lines afford the best in communications for the alerting of regulatory agencies and the community, in a most straightforward manner and without requiring extensive effort.
" Tone-alert" radios are being placed in the homes of key emergency preparedness employees to further ensure the capability of calling on necessary additional personnel in the event the need arises.
Each Point Beach Nuclear Plant Duty and Call Super-intendent and the senior Duty Chemistry and Health Physics Supervisor has been provided with a four-wheel drive high-clearance vehicle.
A total of six of these vehicles are available and, in addition to the assigned key personnel use, can be used in adverse weather conditions for augmentation transportation.
All Duty and Call Superintendents when away from home (in the 20-mile local area) carry message-type pagers all having the same call number which enhances multiple Duty and Call Superintendent response.
Attached is a list showing home locations of key plant personnel who might be needed for augmentation (Exhibit C).
The general close proximity of homes to the plant site is, we believe, an important factor and may, together with plant location, as already discussed, be unique to Point Beach.
TABLE B-1 GUIDANCE COMPARISONS summarizes how each major functional area of Table B-1 is implemented at the Point Beach Nuclear Plant. provides a direct comparison with Table B-1, including alternate measures for those major functional areas not maintained 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day.
These attachments, together with the exhibits and discussion related to personnel staffing, provides the description of a timely shift augmentation system meeting the goals of Table B-1.
l
Mr.
J. G. Keppler February 18, 1982
SUMMARY
Our letters dated November 3, 1980 to Mr. D. G. Eisenhut and April 30, 1981 to Mr. H. R. Denton included discussions related to staffing for emergency situations.
This letter is in reply to your request of January 21, 1982 and repeats some of the earlier information, as well as providing more recent develop-ments, regarding staffing at the Point Beach Nuclear Plant.
This letter also responds to your letter of February ll, 1982 as related to Appendix A of that letter.
We have discussed, in some detail, the specifics of the plant location, design, and manning in order that you may understand why we firmly believe that the plans which we have in place and underway are completely adequate to meet the intent of Table B-1 of NUREG-0654.
The only actions as yet incomplete are the addition of a fourth auxiliary operator on shift and the purchase and installation of tone-alert radios in certain employe homes.
The fourth auxiliary operator (or equivalent) is to be placed on shift effective July 1, 1982, and is expected to become licensed as a Reactor Operator contingent upon completion of NRC license examinations.
Tone-alert radios are being ordered at this time; delivery is not yet determined but is expected by July 1, 1982.
It is emphasized that we believe that a competent shift organization, backed up with ready communications with senior plant staff at all times plus the capability for expeditious call in of additional personnel provides adequate assurance that Point Beach Nuclear Plant will continue to be operated in a manner which protects the public health and safety.
In the event that you require further information, we shall be pleased to meet with you at your convenience.
Very truly yours, b'u,h C. W. Fay Assistant Vice President Attachments Copy to NRC Resident Inspector
Y',
EXHIBIT A PSNP 3.13 Revision 6 fg 06-26-81 k
DUTY & Call. SUPERINTENDENTS 1.0 PURPOSE A Duty & Call Superintendent will be on call at all times. He will be available to assist and counsel the Duty Shift Supervisor in the event of off-normal occurrences and/or reportable occurrence. The Duty & Call group has been established consisting, but not limited to senior qualified and/or Manager's Supervisory Staff members, including the Manager.
The Manager may assign additional members to the Duty & Call Superintendent group if they are determined to be qualified by the Manager.
2.0 QUALIFICATICNS A member of the Duty & Call Superintendent active rester will be appointed by the Manager - Nuclear Operations in consideration of following qualifications.
2.1 Past Senior Reactor Operator (SRO) license (s) and experience.
2.2 Active SRO license at Point Beach Nuclear Plant.
2.3 Professional degree and extensive nuclear power plant experience such as years en Duty & Call Technical Advisor roster.
MemberofManager'sSupervisory)itaff 2.4 3.0 DUTIES 3.1 A Duty & Call Superintendent will normally be assigned the duties en a weekly basis, such as~ Monday 3:00 a.m. to Menday 8:00 a.m.
A c py of the week-by-week assignments of Duty & Call Superintendents will l
be distributed to the centrol room for shift Supervisor reference.
3.2 In the event of an off-ncr:tal occurrence, the Shift Supervisor shall i
communicate with at least ene Duty & Call Superintendent before taking other than the immediate on-the-spot action required.
Prior to deviating frem any approved major precedure (pertaining to nuclear safety), at least ene Cuty & Call Superintendent must be contacted for approval. The Duty & Call Superintendent will be contacted during all conditions that require the use of any Imergency Cperating Procedure, aspects of the Emergency Plan, or any reportable event.
The Duty & Call Superintendent will be kept informed of any abnormal status with respect to Technical Specifications equipment, er equipment that could jecpardi:e the facility's capability to produce electrical power. The Duty & Call Superintendent will be informed of any off-hour regulat:ry inspections by such groups as the NRC, OSHA, State inspectors, etc.
The Duty & Call Super.ntendent will be.
PBNP 3.13 Page 2 l
.s s
contacted as a last resort concerning group matters after reasonable attempts to contact the particular group supe.mtision have failed.
In all cases, the Duty & Call Superintendent will provide continuous counsel, callout backup, and review to the Shift Supervisor.
3.3 In the event of an incident causing the implementation of the Emergency Plan, the Duty & Call Superintendent will proceed as directed in that Plan.
3.4 In the event of fire, the Duty & Call Superintendent wi'll be notified and he will proceed as directed in the Fire Protection Manual. He will. initiate an emergency call-out if required and report to the contrcl room to assist in coordination of activities.
3.5 During periods of a unit shutdown (on backshifts and weekends), the l
Duty & Call Superintendent may act as liaison between the Wisconsin Electric Power Ccmpany and outside contractors if shutdown jobs a're not progressing satisfactorily due to poor coordination with the outside contractors. He may also act to effect, coordinate with Point Beach Nuclear Plant groups and e.tpedite the work activities of the outage, depending upon the assigned availability of group heads.
4.0 CDNDUCT
\\.
The assigned Duty & Call Superintendent will keep the Duty Shift Supervisor informed of his whereabouts at all times and will carry on his person a radio-telephone " beeper" receiver if temporarily out of direct phone contact. The Duty & Call Superintendent must be immediately available by phone or radio for consultation with the Duty shift Supervisor or to leave for the plant in case of an emergency.
Committed time allowed for Duty &
Call Superintendent arrival at Point Beach Nuclear Plant (from time of contact) is 30 minutes.
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EXHIBIT A (CONTINUED)
TYPICAL EXAMPLE September 3, 1981 i
DUTY & CALL SUPERINTENDENT ROSTER JULY 6, 1981 THROUGH SEPTEMBER 13, 1981 Please note that duty begins at 0700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> of the first listed date and extends past midnight of the last listed date to 0700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> the next morning.
Changeover to 0800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> for duty beginning will occur on October 10, 1981.
September 14 - September 20 REL September 21 - September 27 GAR September 28 - October 4 TJK October 5 - October 11 JJZ October 12 - October 18 GAR October 19 - October 25 REL October 26 - November 1 TJK November 2 - November 8 JJZ November 9 - November 15 GAR November 16 - November 22 REL November 23 - November 29 (Holiday)
JJZ November 30 - December 10 TJK December 10 - December 17 JJZ December 17 - December 20 TJK December 20 - December 27 (Holiday)
GAR December 28 - January 3 (Holiday)
REL GAR
EXHIBIT B TYPICAL EXAMPLE September 25, 1981 DCMS COVERAGE The following is the Duty & Call Maintenance Superintendent coverage for the period October 2, 1981 through January 4, 1982.
The period of duty will be from the end of the working day, Friday, to the start of the working day, Monday.
Holidays and holiday weekend coverage will be from the end of the last working day until the start of the first working day after the holiday.
October 2 - 5 ROG October 9 - 12 WJH October 16 - 19 JOS October 23 - 26 TRB October 30 - November 2 GB November 6 - 9 MEC November 13 - 16 DAM November 20 - 23 ROG November 25 - 27 (Thanksgiving)
DAM November 27 - 30 WJH December 4 -7 JOS December 11 - 14 TRB December 18 - 21 GB December 23 - 28 (Christmas)
MEC December 30 - January 4, 1982 JOS (New Years) l WJH
EXHIBIT B (CONTINUED)
(
TYPICAL EXAMPLE December 14, 1981 Duty & Call Superintendents Chemistry & Health Physics Supervisors Control Room CHEMISTRY & HEALTH PHYSICS ON-CALL SCHEDULE Health Physics Chemistry Date LDE TLF 01/08 - 01/14 CDB TLS 01/15 - 01/21 MDM RAN 01/22 - 01/28 EJM RSB 01/29 - 02/04 JVM PJS 02/05 - 02/11 LDE TLF 02/12 - 02/18 CDB TLS 02/19 - 02/25 MDM RAN 02/26 - 03/04 EJM RSB 03/05 - 03/11 JVM PJS 03/12 - 03/18 LDE TLF 03/19 - 03/25' MDM RAN 03/26 - 04/01 EJM RSB 04/02 - 04/08 CDB TLS 04/09 - 04/15 - Easter JVM PJS 04/16 - 04/22 LDE TLF 04/23 - 04/29 MDM RAN 04/30 - 05/06 Except where noted, the Chemistry & Health Physics Duty &
Call Supervisor assignments are divided between two supervisors for any given on-call period.
To contact the Health Physics or _ - - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
j
Chem & HP - 2 December 14, 1981 Chemistry Duty & Call Supervisor (HPDCS or CDCS) when not at home, dial the appropriate beeper number as follows:
Health Physics:
793-4301 Chemistry:
793-5156 The CDCS or HPDCS should normally be contacted before calling in Chemistry & Health Physics personnel.
In the event that either the CDCS or HPDCS cannot be reached, an attempt should be made to contact the other Duty & Call Supervisor or another available Chemistry & Health Physics Supervisor.
PJS t
EXHIBIT B (CONTINUED)
TYPICAL EXAMPLE January 5, 1982 I&C GROUP DUTY SUPERVISOR ASSIGNMENTS For emergency situations during off normal working hours which may require assistance or advice from the 127 Group, the first supervisor to contact shall be as follows:
January 4 - 10 JCR January 11 - 17 GLR January 18 - 24 AJP January 25 - 31 EAL February 1 - 7 JCR February 8 - 14 GLR February 15 - 21 AJP February 22 - 28 EAL March 1 - 7 JCR March 8 - 14 GLR March 15 - 21 AJP March 22 - 28 EAL l
March 29 - April 4 JCR i
l l
JCR
EXHIBIT C POINT BEACH NUCLEAR PLANT EMPLOYEES INVOLVED IN EMERGENCY PREPAREDNESS AND/OR AUGMENTATION (Projected as of 07-01-82) 15-MILES NAME JOB FUNCTION 30 MINUTES 60 MINUTES RA Radiochemical Technician X
JB Nuclear Plant Specialist /
-Duty Technical Advisor X
GB Nuclear Plant Engineer -
Maintenance /
Duty Technical Advisor X
IB Shift Supervisor X
CB Health Physics Supervisor X
RB Auxiliary Operator X
TB Nuclear Plant Engineer -
Maintenance /
Duty Technical Advisor X
RB Health Physicist X
MB Auxiliary Operator X
RB Superintendent - Training X
MC Radiochemical Technician X
BC Auxiliary Operator X
GC Control Operator X
MC Assistant to Superintendent -
Maintenance & Construction X
KD Operating Supervisor X
DD Auxiliary Operator X
LE Health Physics Supervisor X
TF Nuclear Plant Engineer X
TF Radiation Control Operator X
WF Nuclear Plant Engineer /
Duty Technical Advisor X
TG Operating Supervisor X
RG Maintenance Supervisor X
DG Radiochemical Technician X
SG Auxiliary Operator X
HG Training Specialist X
CG Shift Supervisor X
JH I&C Technician X
MH Auxiliary Operator X
RH Superintendent - Reactor Engineering /
s Duty Technical Advisor X
RH Auxiliary Operator X :
Pcgo 2 15 MILES NAME JOB FUNCTION 30 MINUTES 60 MINUTES WH Control Operator X
WH Superintendent - Maintenance
& Construction X
NH Modification Engineer /
Duty Technical Advisor X
JH Radiation Control Operator X
NH Auxiliary Operator X
RI Auxiliary Operator X
LK Shift Supervisor X
Auxiliary Operator X~
RK TK Auxiliary Operator X
TK Superintendent --Operations /
Duty & Call Superintendent X
MK Radiation Control Operator X
JK Auxiliary Operator X
PK Nuclear Plant Engineer /
Duty Technical Advisor X
DL Operating Supervisor Trainee /
Auxiliary Operator X
EL I&C Supervisor X
AL Control Operator X.
RL Superintendent - Engineering, Quality & Regulatory Services /
Duty &:-Call Superintendent X
ML Nuclear Plant Engineer /'
Duty Technical Advisor X
TL Auxiliary Operator X
SL Radiation Control Operator X
DM Maintenance Supervisor X
WM Auxiliary Operator X
EM Nuclear Plant Specialist -
l
- Health Physics X
l PM Training Specialist X
GM.
Assistant to Superintendent -
Operations /
Duty Technical Advisor X
JM I&C Technician X
JM Control Operator X
DM Auxiliary Operator X
RM Shift Supervisor X
MM Auxiliary Operator X
JM Nuclear Plant Specialist -
Health Physics X
RM Operating Supervisor X
l MM Nuclear Plant Specialist -
Health Physics X
RM Radiation Control Operator X
RR Shift Supervisor X
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Pago 3
^
15 MILES NAME JOB FUNCTION 30 MINUTES 60 MINUTES e
RN Nuclear Plant Specialist -
Chemistry X
SN Auxiliary Operator X
I DO Control Operator X
l CO Nuclear Plant Engineer /
Duty Technical Advisor X
RP Auxiliary Operator X
GP Auxiliary Operator X
AP Radiation Control Operator X
PP Nuclear Plant Engineer /
Duty Technical Advisor X
DP Radiochemical Technician X
AP Radiation Control Operator X
MP Radiochemical Technician X
AP Nuclear Plant Engineer X
JQ I&C Repairer X
NR Training Specialist /
Control Operator X
GR Nuclear Plant: Engineer X
GR Manager - Nuclear Operations /
Duty & Call Superintendent X
KR Radiation Control Operator X
JR Superintendent - I&C X
RR Auxiliary Operator X
TR Training Supervisor X
SR Auxiliary Operator X
JS Auxiliary Operator X
GS I&C Repairer X'
DS Auxiliary Operator X
JS Radiochemical Technician X
I JS Maintenance Supervisor X
DS Control Operator X
PS Auxiliary Operator X
.JS Inservice Inspection Engineer /
Duty Technical Advisor X
AS Control Operator X
TS Operating Supervisor X
GS Nuclear Plant Engineer /
Duty Technical Advisor X
PS Superintendent - Chemistry
& Health Physics X
TS Nuclear Plant Specialist -
Chemistry X
KS Control Operator X
TS Nuclear Plant Engineer /
Duty Technical Advisor X
WS Auxiliary Operator X
GS Auxiliary Operator X
TV Auxiliary Operator X
Page 4 15 MILES NAME JOB FUNCTION 30 MINUTES 60 MINUTES RV Auxiliary Operator X
WW Auxiliary Operator X
MW Operating Supervisor X
RW Radiochemical Technician X
MW Auxiliary Operator X
DW Auxiliary Operator X
LW Control Operator X
EW Nuclear Plant Engineer X
JZ General Superintendent /
Duty & Call Superintendent X
EZ Shift Supervisor X
NOTE:
AUXILIARY OPERATOR CATEGORY INCLUDES AUXILIARY OPERATOR TRAIpiEES QUALIFIED IN HEALTH PHYSICS.
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ATTACHMENT 1 TABLE B-1 OF NUREG-0654 ON SHIFT MAJOR FUNCTIONAL AREA PBNP RESPONSE 1.
Plant Operations On Shift:
1 shift Supervisor 1 Operating Supervisor 2 Control Operators 4 Auxiliary Operators 2.
Emergency Direction Technical Advisor on site 3.
Notification / Communication One of four Auxiliary Operators to hcndle until relieved by augmentation 4.
Radiation Assessment a.
In Plant Surveys hll four Auxiliary Operators are qualified to do surveys. Accounting for 3, above, three are available for surveys and other assignments noted below.
Additional health physics expertise on call.
b.
Chemistry / Radiochemistry Rad Chem Technician on shift 88 of 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> per week.
Auxiliary operators qcalified to perform certain chemical analysis work.
Additional chemistry expertise on call.
5.
Plant Systen Enginering l
a.
Shift Technical Advisor See 2 above b.
Mechanical Maintenance / Rad One of on-shift auxiliary Waste Operator operators can perform work until augmentation.
l c.
Electrical Maintenance /
A licensed operator or
'one of I&C Technician on-shift can be assigned until augmentation.
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ATTACHMENT 1 (Continued) t 6.
Protective Actions Rad Control Operator All four on shift Auxiliary Operators are qualified.
7.
Rescue Operations and First Aid Many operating shift.
personnel and security personnel are qualified in first aid and fire fighting.
8.
Site Access Control Security Plan provides sufficient personnel as approved by the NRC.
']
r i
S ms., _
- 2..
ATTACHMENT 1 TABLE B-1 OF NUREG-0654 AUGMENTATION 1.' Notification / Communications Duty cnd Call Superintendent can be on site in thirty minutes.
Other management personnel can be called in as described in letter.
2.
Emergency Operating Facility One or more individuals are Director available from Milwaukee approximately two hours.
Site Management acts as EOF Director until arrival of designated Director.
EOF Director can function away from site.
3.
Off Site Dose a.
Assessment On call Chemistry / Health Physics personnel.
Avail-ability of Rad Con / Waste Management in EOF in approximately two hours from Milwaukee area.
b.
Off Site /On Site Surveys On call Chemistry / Health Physics personnel plus agreement with Kewaunee Nuclear Power Plant for mutual assistance.
Auxiliary Operators also qualified.
c.
In Plant Surveys On call Chemistry / Health Physics personnel. Auxiliary 1
Operators are also qualified.
d.
Chemistry / Radiochemistry On call chemistry personnel.
Auxiliary Operators qualified I
to perform certain chemical work.
l 4.
Technical Support Duty and Call Superintendents plus call in availability of nuclear plant engineers, specialists, and Technical Advisors 5.
Repair and Corrective Action Call in availability of l
Maintenance Superintendent l
and supervisort.
Additional ability to call in craftsmen.
.. _ - _ - ~ --
o ATTACHMENT 1 (Continued) 6.
Radiation Protection Call in availability of i
Health Physics supervisors and specialists.
Agreement with Kewaunee Nuclear Power Plant for additional i
equipment and personnel support.
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t 1 ;
ATThCIIMENT 2 COMPARISON OF PBNP SilIFT STAFFING (EffEffjEE JULY _1 1552) 2 TO TAf3LE E:-l OF NUHfU-0654 Major Functional Area or Tasks Position Title or Expertise On Shift Comment on Conformance et variance Plant Opetations &
Assessment of Opera-tional Aspects Snift Supervisor (SRO) 1 Conforms Operating Supervisor (SRO/po) 1 Conforms Control Room Opetatot (RO) 2 Conforms Auxiliary Operator 4
conforms Emergency Ditection &
Control Shi f t Technical Advisor 1**
Other duty and conforms.
Notification /Communi-cation Designated Auxiliary Operator 1**
At vatinnce. One of 4 AO's collected in control toom is designated by Shift Supen-visor to cover communications, until augmentation is accomplished.
In-Plant Surveys Rad Control Operator 1**
At variance. One o f 4 t r ained AO's list ed above can perform duty until augmentation.
Chem / Radiochemistry Rad Chem Technician 2 shifts, At variance. Oft hours out of 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> per 5% days week are covered. The temainder is covered per week by duty toster augmentation. Auxiliary operators qualified to per for m cer t ain chemical analyses work.
Major Functional Area or Tasks Position Title or Exper tise On Shift Comment on Conformance or Vatiance Plant System Engi-neering, Repair &
Corrective Act. ion Shift Technical Advisor 1
Conforms Mechanical Maintenance 1**
Conforms. One o f 4 AO's listed above can perform work until augmentation.
Electrical Maintenance 1**
Conforms. [.icensed Operators, or AO's can perform work until augmentation.
Protective Action (In-Plant)
Rad Control Operator 2**
Con fo r rns.
AO's can perform work until augmentation.
Rescut Operations &
Fir st Aid 2**
Conforms. Many operating shift personnel and security personnel are qualified in first aid and fire fighting.
Site Access Control
& Personnel Accounta-bility Security Personnel Conforms
- Are covered by shif t personnel assigned other functions.
PilNP Total - 11ine operating personnel per shift with additional one per shift half the time. -
s 1
ATTActir1ENT 2 COMPARISON OF PBNP AtlGNENTATION TO TABLE B-1 Ol' NUREG-0654 NO1 E : Tile FOLtDWING COMPARISON REIATES TO A " WORST" CASE SUCII AS A IlOLIDAY WEEKEND IN TIIE StrittfER VACATION SEASON.
NOTE AI.SO EXIIIRIT "C" OF Tills DOCtIMENT WlilCII SilOWS 114 EMERGENCY PREPAREDNESS-INVOLVED PEOrt.E I.IVING WITIIIN 15 MILES OF TIIE POINT BEACll N11CI. EAR PI, ANT.
Major Functional Position Title Augmentation Comment on Confor-Area or Tasks or Expertise 30 min 60 min mance or Variance Notification /
Technical Advisors, Duty &
1 Conforms Communication Duty & Call Superintendents, Nuclear I lant Engineer s, Group Ileads Radiological Anst. Vice President 1
At vatlance.
Regular EOF Director (or desig-Ansessment.
Mgr-Nuclear Operations nated Nuclear Power Dept alternate) available in EOF Director Duty & Call Supts alcu t 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
Site Mqr will make I hr coverage.
Of f-Site Dose Supt.-Chemistry & IIP 1
Conforms. Radiocheraist posi tion pr esently llP Supervisors, Ileal th unfilled.
Physicist, Nuclear Plant Engineers & Specialists, Radiochemist, Technical Advisors Off-Site Surveys, IIP Supervisors, Nuclear Plant 2
2 At variance (teminrary). Table n-1 requires 1-10 On-Site (Exclusion Specialists (Chem), Rad min anel 1-60 min.
Nuclear Plant P.necialista (Chem)
Area) Surveys Control Operators, Radchem and Radchem Techs will not be tully qualified Techs until 12-31-82, at which time 3 & 3 require-will be met In-Plant Surveys IIP Supervir, ors, Rad Control 1
1 Confonms. Nuclear Plant Specialists (Chem)
(Protected Area)
Operators, Aux Operators, and Radchem Techs will not be fully qual-Nuclear Plant Specialists ified until 12-31-82 (Chemistry), Radchem Techs l at
s Cheinistry/ Radio-Radiochemist, Nuclear Plant 1
Confonms. Radiochemist position presently chetaistry Specialists (Chem), Radchem inif illed Techs Technical Support Technical Advisors, Nuclear
-Core / Thermal Plant Engineers & Specialists 1
Conforms flydraulics EQRS Engineets, Duty & Call
-Electrical Superintendents, Maintenance 1
Conforms
-flechanical Supervisors 1
Conforms Repair I, Correc-Maintenance Supervisots, tive Actions IAC Supervisors, Mechanic-
-Mechanical Maint Electricians, I&C Techs 1
Conforms
-Electtic Maint 1
1 Conforms
- I I.(*
1 Conforms Rad Protection Rad Control Operators, Aux 2
2 Conforms. Radchem Techs will not be fully Operators, IIP Supervisors qualified until 12-31-82 Huclear Plant Specialists (IIP ), Radchem Techs I
P
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