ML20054G113
| ML20054G113 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 06/15/1982 |
| From: | Linder F DAIRYLAND POWER COOPERATIVE |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0654, RTR-NUREG-654 LAC-8351, NUDOCS 8206210114 | |
| Download: ML20054G113 (6) | |
Text
I 0 DA/RYLAND h
[k COOPERAT/1/E pO box siv 2615 EAST AV SOUTH LA CROSSE. WISCONSIN 54601 (608) 788 4 000 June 15, 1982 In reply, please refer to LAC-8351 DOCKET NO. 50-409 Director of Nuclear Reactor Regulation ATTN:
Mr. Dennis M. Crutchfield, Chief Operating Reactors Branch No. 5 Director of Operating Reactors U. S. Nuclear Regulatory Commission Washington, D. C.
20555
SUBJECT:
DAIRYLAND POWER COOPERATIVE LA CROSSE BOILING WATER REACTOR (LACBWR)
PROVISIONAL OPERATING LICENSE NO. DPR-45 SHIFT AUGMENTATION - REQUEST FOR EXEMPTION TO TABLE B-1 NUREG 0654
REFERENCE:
(1) DPC Letter, Linder to Crutchfield, LAC-8329, dated June 7, 1982.
(2)
NRC Letter, Keppler (NRC) to Linder (DPC),
dated May 21, 1982 (3) NUREG 0654, Revision 1, November, 1980, TABLE B-1 Gentlemen:
As a result of further consideration of NUREG-0654 emergency response requirements as they relate to LACBWR and DPC staff availability and capabilities we have revised our previous submittal (Reference 1) with this letter. Please disregard tne earlier letter.
Following a recent NRC Emergency Preparedness inspection it was determined that immediate corrective actions were required for significant inspection findings.
A confirmatory action letter (Reference 2) was issued to us by the Regional Administrator for NRC, Region III.
This letter requested that we take four actions, the first one of which was:
SHIFT STAFFING:
1.
The licensee shall describe by position / title the number of personnel who can respond to the site in thirty and sixty
[00k minutes luring off-shift hours and the ; job qualificatione or I
perfornunce capabilities of each of these individiaule to meet the position described in NUREG-0654, Table B-1.
(This item is to be completed by June 16,1982).
206210114 820615 DR ADOCK 05000409 PDR L!P-1 Mr. Dennis M. Crutchfield, Chief June 15, 1982 U. S. Nuclear Regulatory Commission LAC-8351 Based upon justifications presented in this letter it is requested that exemptions be granted from the minimum staffing requirements. (capability for additions) which are listed in Table B-1 of NUREG-0654. These exemptions would allow a smaller emergency response team than the requirements presented i n Tabl e B-1.
Since LACBWR is a small (165 MWt) Boiling Water Reactor with simpler controls, a reduced response team is justifiable. The plant design is not complex and nearly all control functions for startup and continuous operation can be conducted from the control room. Reactor shutdown can be accomplished from within or outside the control room by a minimum of two operators.
Past operating experience has shown that current levels of shift staffing are adequate. More than 200 scrams have been capably and safely handled.
The small size of the plant places lesser demands on the radiation protection personnel. The compact plant layout minimizes survey times. The smaller core inventory reduces the possible magnitude of a radioactive release, and hence the distance a survey team needs to travel. A computer program has been written for dose assessment to minimize the time the technicians need to spend on calculations. The Operations Department has been trained to assist the Health and Safety Department in radiological activities, such as surveying and post-accident sampling.
A boiling water reactor does not have the analytical chemistry requirements of a pressurized water reactor. The designation of a smaller emergency planning zone and the simplified chemical analysis tasks required in activation of the emergency plan lend themselves to fewer total personnel needed for emergency response. For the above mentioned reasons, DPC feels a radiological response team of four individuals, three reporting to the plant and one to the Emergency Operations Facility will be sufficient.
Planning and protection concepts in NUREG-0654 embrace larger nuclear plants and do not reflect differences in plant size and complexity. Just as a relatively smaller average staff is sufficient for the conduct of normal plant operations, a smaller emergen:y response team at LACBWR can be capable of fulfilling all the functions listed in Table B-1.
Therefore, we propose staffing in accordance with the attached Table,
" Emergency Response Capabilities During Operational Conditions 1-3,"
as a suitable alternative to Table B-1 of NUREG-0654.
It is our conclusion that our proposed emergency response capabilities as present u in the attachment meet the intent of NUREG-0654 for the protection of the public.
f WP-1 _
Mr. Dennis M. Crutchfield, Chief June 15, 1982 U. S. Nuclear Regulatory Commission LAC-8351 If there are any questions on this letter, please contact us.
Very truly yours, DAIRYLAND POWER COOPERATIVE lA-Frank Linder, Genera Manager FL:LSG:eme Attachment cc:
J. G. Keppler, Regional Administrator, NRC-DR0 III NRC Resident Inspector R. Dudley I
i i
I WP-1 t
EMERGENCY RESPONSE _CRPABILITIES DURING OPERATIONAL CONDITIONS'1-3 REMAINING PERSONNEL RESIDING NEAR APPLICABLE PLANNED INITIAL EMERGENCY EMERGENCY RESPONSE FACILITY RESPONSE TEAM
RESPONSE
NORMAL (PLANT OR E0F)
(AS NEEDED)
FUNCTION POSITION ON-SHIFT 30 MIN l
60 MIN TOTAL 30 MIN 60 MIN TOTAL Plant Shift Supervisor (SRO) 1 Operations Reactor Operators 2
Plant Operators 2
l l
Emergency Shift Sup_ervisor 1
l Control Asst. GeneraT Manager -
4 4
1 1
Power or Alternates i
l Notification -
Securip Guard I
3 8
T-
--f--
3- -
Communications Supervisor Tech icians
-~5--
-~--"
and Specialists trained in Emergency Communications Health Ph 1*
liadiatTon_ysics Technicians
- - ~5* --- 12*
2
-2 4
Radiological Protection Eng.
7*
Activities In-Plant Surveys Rad. Prot. Eng. Specialist On-Site Surveys Health & Safety Supervisor j
Off-Site Surveys Health Physics Technicians Dose Assessment Environmental Engineer Radiation Sr Environmental Biologist i
Protection Air Quality Analyst Radiological Director, Environ Affairs Assessment l
00perators are also trained to perform surveys and can be used for augmentation if necessary.
There are generally 20 operations personnel not on-duty at anytime, l
TSP-1 l l
1, t
1 EMERGENCY RESPONSE CAPABILITIES DURING_0PERATIONAL CONDITIONS 1-3 l
REMAINING PERSONNEL RESIDING NEAR APPLICABLE PLANNED INITIAL EMERGENCY EMERGENCY RESPONSE FACILITY RESPONSE TEAM
RESPONSE
(AS NEEDED)
FUNCTION POSITION ON-SHIFT 30 MIN l 60 MIN TOTAL 30 MIN 60 MIN TOTAL 1
Technical Shift Technical Advisor 1
Support Plant Superintendent 9
5 14 1
2 2f- - ~~
Asst. Plant Superintendent Operations Supervisor Asst. to Operations Sup.
Shift Supervisors Reactor Engineer Operations Engineer Electrical Engineer Mechanical Engineer Technical Support Enginner Engineer Assistait Engineering Specialist Director Power Production Director Power Engineering Repair and Operators and Shift (See Plant Oper)
Corrective Supervisor Actions Instrument & ETec. Supv.
10**
10**
20**
2 T-- - 5I~ -"
Mech. Maint. Supv.
Maintenance Mechanics Instrument Technicians Electricians Firefighting Fire Brigade per Local Tech. Specs.
Support
- Includes Instrument Technicians who may _ be augmenting in communicator function.
WP-1 -
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