ML20078K606

Forwards Suppl Info Re Emergency Response Organization Staffing

ML20078K606
Person / Time
Site:	Seabrook
Issue date:	11/15/1994
From:	Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NYN-94128, NUDOCS 9411230205
Download: ML20078K606 (31)

Text

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North Atlantic Energy Service Corporation

i. nOrill P.O. Box 300 f

Atlutk Seabrook, NH 03874 h

(603) 474-9521, Fax (603) 474-2987 The Northeast Utilities System Ted C. Feigenbaum NYN 94128 Senior Vice President &

Chief Nuclear Officer November 15,1994 U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention:

Document Control Desk

References:

(a)

Facility Operating License No. NPF-86, Docket No. 50-443 (b)

USNRC Letter dated September 2, 1994, "Seabrook Station Emergency Preparedness (EP) Program Inspection No. 50-443/94-15," J.H. Joyner to T.C. Feigenbaum i

Subject:

Transmittal of Supplemental Information Regarding Emergency Response Organization i

t StafUng Gentlemen:

l in a letter dated September 2,1994 [ Reference (b)], the NRC requested additional information in l

response to an unresolved item identified during an emergency preparedness inspection. Specifically, during the review of Revision 14 to the Seabrook Station Radiological Emergency Response Plan (SSREP), the inspectors noted a change to the number and timing of North Atlantic Energy Service Corporation (North Atlantic) emergency response personnel committed to augment the on-shill emergency response organitation (ERO). Although this revision took exception to some of the guidance contained in NUREG-0654/ FEMA-REP-1, Rev.1, at Table B-1, Nonh Atlantic had concluded that this change did not reduce the effectiveness of the emergency plan. However, the inspection repon identified that the evaluation of this change provided to the inspectors may not have adequately supported this conclusion.

During a subsequent conversation with the NRC, North Atlantic committed to assemble the full evaluation of the change to the augmented stafEng table and to forward it to the NRC for review. During the process of assembling the full evaluation of this revision, North Atlantic determined that additional changes to the stafEng table would further clarify how the tasks stated in NUREG-0654 would be addressed. As with Revision 14 to the SSREP, the total staffing for the ERO was unaffected by these clarifications. Accordingly, the enclosure contains North Atlantic's full evaluation of the changes to the augmented stafEng plan.

North Atlantic is confident that the current augmented stafUng plan is adequate to satisfy both the functional requirements of the emergency plan and the intent of the regulatory guidance contained in N U R EG-0654. Based on this, North Atlantic concludes that Revision 14 to SSREP did not reduce the efTectiveness of the emergency plan, and the SSREP continues to meet the standards of 10 CFR 50.47(b) and the requirements of 10 CFR 50 Appendix E. Notwithstanding this, North Atlantic will revise the 9411230203 941115 g: /)g j[gff th

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United States Nuclear Regulatory Commission November 15,1994 Attention:

Document Control Desk Page two l

SSREP to add the aforementioned clarifications to the augmented staffing table to more clearly delineate f

task responsibility.

Should you have any questions regarding this letter or its enclosure, please contact Mr. James M.

Peschel, Regula'ory Compliance Manager, at (603) 474-9521, extension 3772.

t Very t

> yours,

/gf 6Vs i lf'G Ted C. Feig aum TCF:JES/jes l

Enclosure cc:

Mr. Thomas T. Martin Regional Administrator U.S. Nuclear Regulatory Commission Region I 475 Allendale Road l

King of Prussia, PA 19406 l

Mr. Albert W. De Agazio, Sr. Project Manager l

Project Directorate 1-4 Division of Reactor Projects i

U.S. Nuclear Regulatory Commission Washington, DC 20555 4

Mr. Richard Laura i

NRC Senior Resident Inspector P.O. Box 1149 Seabrook, Nil 03874

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Nonh Atlantic November 15.1994

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ENCLOSURE TO NYN-94128

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i EVALUATION OF CIIANGES TO TIIE SEABROOK STATION RADIOLOGICAL EMERGENCY PLAN AUGN1ENTED STAFFING TABLE The following provides an evaluation of changes made to the Seabrook Station Radiological Emergency Response Plan (SSREP), Revision 14, with regard to the number and timing of emergency response personnel committed to augment the on-shift emergency response organization (ERO).

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1.

Backcround

_j Re_ ulatory Reouirements and Guidance A.

c Onsite emergency plans for nuclear power reactors must meet the planning standards contained j

in 10CFR50.47. One of these standards, requires that:

i On-shift facility licensee responsibilities for emergency response are unambiguously denned, adequate staffing to pmvide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified.

i Contained in the criteria for preparing and evaluating emergency plans, NUREG-0654/ FEMA-l REP-1, is Table B-1 which contains guidance as to the minimum emergency functions that must be performed and the staf6ng needed to satisfy the planning standard. The Seabrook Station Radiological Emergency Plan (SSREP) contains a comparison of the augmented er ergency response organization (ERO) against the guidance of NUREG-0654/ FEMA-REP-1, Rev.1, Table B-1 (Table B-1). This comparison is presented in Figure 8.15 of the SSREP.

i B.

Original North Atlantic Plannine Basis i

In the early versions of the SSREP, Figure 8.15 was added to provide a comparison against

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NUREG-0654, Table B-1. At that time, all of the ERO members that performed a Table B-1 function were listed, not simply those that reprewnted the minimum staffing relied upon to perform the given function. This represented a signi6 cant over-commitme:it in staffing as compared with the guidance of Table B-1. For example, Figure 8.15 listed Control Room Operators and Auxiliary Operators since they are part of the augmented ERO, however, Table B-1 does not indicate any need to augment the on-shift ERO with these positions.

l The over-commitment in augmented ERO staf0ng resulting from the original planning basis was I

noted by NRC inspectors during the initial emergency preparedness program inspection conducted during i

the week of December 9,1985. Inspection Report 85-32, Section (2), Aucmentation of Onsite Emercency Orcanization, states that

• Figure 8.15 of the Emergency Plan describes staffing for the initial phase (on shift) and augmentation phase during emergencies. The individuals assigned to major functional areas during each phase exceeds the minimum staf6ng requirements of Table B-1, NUREG-l' 0654.*

C.

NRC Safety Evaluation Report NUREG-0896, Safety Evaluation Report related to the oneration of Seabrook Station. Unit 1 and

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2, Supplement 1, dated April 1983, Section 13.3.2.2, contained two observations related to augmented ERO capabilities and functions.

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i The near-term ERO consists of four individuals who may be contacted at all times and who represent four key areas of specialization (Emergency Direction, Dose Assessment and Protective Actions, Corporate Coordination, and Technical Support) and is headed by the Emergency Director... In addition, other personnel will be notified to support the immediate needs that station conditions dictate as determined by the short-term ERO. This will be accomplished in accordance with a notification scheme that provides flexibility to support all emergency functions. These personnel and the operating shift personnel provide the base for establishing the long-term ERO and initiate or continue those actions necessary to terminate the emergency, assess onsite and offsite radiological c(mditions, provide technical support, and coordinate station activities with the initial response of offsite authorities (state, Federal and local), the media and requested assistance.

Augmentation of the ERO continues with the notification and arrival of the long-term ERO members. These personnel report directly to emergency activity areas and assume responsibilities associated with the following disciplines: direction, administration, coordination, technical assistance and operations.

These statements are unaffected by the changes made in Revision 14 of the SSREP.

2.

Summary of SSREP Revision 14 Chanemmd Evaluation of Chances Revision 14 to the SSREP incorporated several changes to Figure 8.15. A summary of the changes and a summary of the evaluation of the changes is described below.

A.

The number of ERO staff included on Figure 8.15 as augmenting the on-shift ERO within 60 minutes was reduced from 37 to 25.

Attachment I compares Revision 14 of Figure 8.15 to that of Revision 13, with regard to 60 minute augmented staffing requirements. Attachment 2 provides a comparison of NUREG-0654, Table Il-1,60 minute staffing requirements with the Revision 14 Seabrook Station 60 minute augmented ERO. provides an evaluation of the 60 minute augmented ERO staffing changes to SSREP Figure 8.15 incorporated in Revision 14 of the SSREP.

It should be noted that the staffing of the ERO remains at 128 and is unchanged by Revision 14.

This is evidenced by the fact that Figures 8.3,8.4 and 8.5, which describe the augmented ERO staffing, were not revised. All these positions, including those formerly listed on Figure 8.15, are still called out, either by pager or the Emergency Response Organization Notification System (ERONS). ERONS is an automated, telephone-based callout system.

11.

The method for notifying the augmented ERO responders included on Figure 8.15 was changed

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from ERONS to pagers.

This change also resulted in enhancing the ERO callout process by changing the notification method for Figure 8.15 augmented responders from ERONS to pagers. Notification by pager reduces the elapsed time between emergency declaration and responder notification. Additionally, pager notification obviates the need for the responder to be at home to receive an emergency notification. Pager notification increases the likelihood that Figure 8.15 augmented responders can report within 60 minutes, and that additional personnel, in excess of those required to fulfill the staffing guidance of Figure 8.15, j

may also be available.

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The ERO positions that had previously been included in Figure 8.15 as 30 minute augmentation positions are now 60 minute augmentation positions.

Under the regulatory guidance contained in NUREG-0654, Table B-1, and NUREG 0737, Supplement 1, Table 2,11 ERO positions would have been required to be filled within 30 minutes.

Revision 14 provides that all of these positions will be filled within 60 minutes. North Atlantic has determined that this change does not reduce the effectiveness of the emergency plan since either the specified functions are adequately addressed by other on-shift personnel, or there are no emergency planning-related provisions or station procedures specifically anticipating the use of these personnel prior to activation of emergency response facilities. The deletion of the reference to 30-minute responders does not adversely affect the station's ability to assess or respond to an accident. provides a summary table delineating how the specified functions of the NUREG-0654 30 minute responders are addressed with the current staffing plan. North Atlantic intends to include a similar table in a future revision of the SSREP for clarification purposes. Additionally, Attachment 5 provides a position-specific justification of why augmentation by these individuals within 60 minutes rather than 30 minutes does not decrease the effectiveness of the emergency plan.

D.

The number of augmented ERO responders performing radiation protection (in-plant) tasks within 60 minutes has been reduced by one.

This change is justified by the provisions of the station radiation protection program, enhanced radiation protection training requirements and station-specific arrangements for dosimetry and radiation monitoring. The detailed evaluation of this specific revision is contained in Attachment 6.

3.

Conclusion in summary, the changes incorporated into SSREP Revision 14 affecting Figure 8.15 do not decrease the effectiveness of the SSREP or emergency response capabilities, and the SSREP continues to meet the standards of 10 CFR 50.47(b) and the requirements of 10 CFR 50 Appendix E.

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ATTACHMENT 1 COMPARISON OF REVISION 13 and REVISION 14 60 MINUTE AUGMENTED STAFFING REQUIREMENTS Position Title Rev. 13 Rev. 14 Revised Position Pager Major functional Area location / Major Tasks or Expertise Number Number Titles Wearer Plant Ooerations and Shift Supervisor (SRO) 0 0

N/A N/A Assessment of Operational Shift Foreman (SRO) 0 0

N/A N/A Aspects Control Room Operators 1

0 N/A N/A Auxiliary Operators 2

0 N/A N/A Emergency Direction and shift Technical Advisor, 0

0 N/A N/A Control (Emergency Shift Supervisor or Coordinator) designated facility manager Notification /

Notify licensee, State, 3

3 Site Emer Director Yes Conriunication local and Federal Emer Operations Mgr Yes personnel & maintain ERO Tech Liaison Yes communication Radiological Accident Emergency Operations Senior Manager 1

1 Response Manager Yes Assessment and Support of Facility (EOF) Director Operational Accident Offsite Dose Assessment Senior HP Expertise 2

1 EOF Coordinator Yes Assessment Offsite Surveys 6

4 2 Monitors /2 Drivers Yes Onsite (out-of-plant) 2 2

HP Technician Yes In-plant surveys HP Technicians 3

2 HP Technician Yes Chemistry / Radiochemistry Rad / Chem Technicians 3

1 Chem Technician Yes Plant System Engineering, Technical Support Shift Technical Advisor 0

0 N/A N/A Repair and Corrective Core / Thermal Hydraulics 1

1 Reactor Engineer Yes Actions Electrical 1

1 TSC Elec Eng Yes Mechanical 1

1 TSC Mech Eng Yes Repair and Corrective Mechanical Maintenance /

2 2

Mech Main Personnel Yes Actions Rad Waste Operator 1

N/A Yes Electrical Maintenance /

2 2

Elec Main Personnel Yes IEC Technician 2

1 I&C Personnel Yes Page 1 of 2

ATTACHMENT 1 COMPARISON OF REVISION 13 and REVISION 14 60 MINUTE AUGMENTED STAFFING REQUIREMENTS Position Title Rev. 13 Rev. 14 Revised Position Pager Major Functional Area Location / Major Tasks or Expertise Number Nunber

_ Titles Wearer Protective Actions (In-Radiation Protection:

HP Technicians I.

3 HP CMrdinator Yes plant)

Rad Controls Coord Yes

a. Access Control HP Technician Yes

b. HP Coverage for repair, corrective actions, search and rescue first-aid &

firefighting

c. Personnel monitoring

d. Dosimetry Firefighting Local local N/A N/A Support Support Rescue Operations and Local Local N/A N/A First-Aid Support Support Site Access Control and Security, firefighting Security Personnel All per All per N/A N/A Persomel Accountability connunications, personnel Security Security accountability plan plan PERSONNEL TOTAL 37 25 Page 2 of 2

. ATTACHMENT 2 COMPARISON OF TABLE B-160 MINUTE STAFFING REQUIREMENTS WITH REVISION 14 SEABROOK STATION 60 MINUTE AUGMENTED ERO Position Title 0654 SS ERO SS Position waior Functional Area location /Maior Tasks or Exmrtise Ntrber Number Titles Plant Operations and Shift Supervisor (SRO) 0 0

N/A Assessment of Operational Shift Foreman (SRO) 0 0

N/A Aspects Control Room Operators 0

0 N/A Auxiliary Goerators 0

0 N/A Emergency Direction and Shift Technical Advisor, 0

0 N/A Control (Emergency Shift Supervisor or Coordinator) designated facility manager Notification /

Notify licensee, State, 3

3 Site Emer Director Comunication local and Federal Emer Operations Mgr personnel & maintain ERO Technical consnunication Liaison Radiological Accident Emergency Operations Senior Manager 1

1 Response Manager Assessment and Support of Facility (EOF) Director Operational Accident Of f site Dose Assessment Senior HP Expertise 1

1 EOF Coordinator Assessment Offsite Surveys 4

4 2 Monitors /2 Drivers Onsite (out-of-plant) 2 2

HP Technician in-plant surveys HP Technicians 2

2 HP Technician Chemistry / Radiochemistry Rad / Chem Technicians 1

1 Chem Technician Plant Systein Engineering, Technical Support Shift Technical Advisor 0

0 N/A Repair and Corrective Core / Thermal Hydraulics 1

1 Reactor Engineer Actions Electrical 1

1 TSC Elec Eng Mechanical 1

1 TSC Mech Eng Repair and Corrective Mechanical Maintenance /

2 2

Mech Main Personnel Actions Rad Waste Operator Electrical Maintenance /

2 2

Elec Main Personnel I&C Technician 1

1 I&C Personnel I

Page 1 of 2 l

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ATTACHMENT 2 COMPARISON OF TABLE B-160 MINUTE STAFFING REQUIREMENTS WITH REVISION 14 SEABROOK STATION 60 MINUTE AUGMENTED ERO Position Title 0654 SS ERO SS Position Major Functional Area Location /Maier Tasks or Expertise Number Ntster Titles Protective Actions (In-Radiation Protection:

HP Technicians 4

3 HP Coordinator plant)

Rad Controls Coord

a. Access Control HP Technician

b. HP Coverage for See Att. 6 repair, corrective actions, search and rescue first-aid &

firefighting

c. Persomel monitoring

d. Dosimetry Firefighting Local Local N/A Support Support Rescue Operations and Local Local N/A First-Aid Support Support Site Access Control and Security, firefighting Security Persomel All per All per N/A Personnel Accountability cennunications, personnel Security Security accountability plan plan PERSONNEL TOTAL 26 25 Page 2 of 2

ATTACHMENT 3 EVALUATION OF 60-MINUTE AUGMENTED ERO STAFFING CHANGES TO FIGURE 8.15 INCORPORATED IN SSREP, REVISION 14 POSITION! FUNCTION DESCRIPTION OF CHANGE BASIS / JUSTIFICATION Plant Operations and Change number of Control Room Bring SSREP staffing goals into closer alignment with Assessment of Operational Operators and Nuclear System (Auxiliary)

NUREG 06S4, Table B-1 guidance _ Table B-1 does not Aspects Operators from 1 and 2, respectively, to specify augmentation by Control Room Operators or 0 for both.

Nuclear System (Auxiliary) Operators. Station programs and procedures do not require additional Control Room Operators and NSOs within 60 minutes to obtain or maintain a station shutdown.

Notification /

Change personnel performing these The Site Emergency Director is responsible for relieving Communication functions from Emergency Operations the STED of State notification responsibilities; the Manager, EOF Coordinator, and Emergency Operations Manager is responsible for Communicator to Site Emergency relieving the STED of NRC communications; and the Director Emergency Operations. Manager, ERO Technical liaison initiates and maintains and ERO Technical Liaison.

communications with the NH PUC Engineer and the MEMA Nuclear Engineer.

Senior HP Expertise Change number of personnel from 2 to 1; Bring SSREP staffing goals into closer alignment with delete requirement for Dose Assessment NUREG 0654, Table B-1 guidance. Table B-1 specifies Specialist.

augmentation by 1 individual with " Senior HP Expertise". The EOF Coordinator is trained in dose assessment and protective action decision-making.

Page 1 of 4

ATTACHMENT 3 EVALUATION OF 60-MINUTE AUGMENTED ERO STAFFING CHANGES TO FIGURE 8.15 INCORPORATED IN SSREP, REVISION 14 POSITION! FUNCTION DESCRIPTION OF CHANGE BASIS / JUSTIFICATION Offsite Surveys Change number of personnel from 6 to 4 Bring SSREP staffing goals into closer alignment with by deleting 1 HP Technician and 1 NUREG 0654, Table B-1 guidance. Table B-1 specifies Driver. Replace term "HP Technician" augmentation by 4 individuals to perform "Offsite with " Monitors".

Surveys". The term " Monitors" is used since not all assigned personnel are "HP Technicians" Two teams (staffed by 4 individuals) are sufficient for early accident phase field monitoring.

In-Plant Surveys Change number of personnel from 3 to 2.

Bring SSREP staffing goals into closer alignment with NUREG 0654, Table B-1 guidance. Table B-1 specifies augmentation by 2 individuals to perform "in-plant Surveys" Two individuals are sufficient for early accident phase surveys of in-plant areas. Since it is unlikely that in-plant surveys would be conducted except for those required to support coverage for repair and corrective actions, an HP Technician could perform both of these tasks at the same time.

Chemistry /

Change number of personnel from 3 to 1.

Bring SSREP staffing goals :nto closer alignment with Radiochemistry NUREG 0654, Table B-1 guidance. Table B-1 specifies augmentation by 1 individual to provide

" Chemistry / Radiochemistry" expertise. Two chemistry technicians (1 on-shift and 1 augmented) are sufficient for early accident phase chemistry support, e.g., lab operations and obtaining samples.

Page 2 of 4

ATTACHMENT 3 EVALUATION OF 60-MINUTE AUGMENTED ERO STAFFING CHANGES TO FIGURE 8.13 INCORPORATED IN SSREP, REVISION 14 e

POSITION / FUNCTION DESCRIPTION OF CHANGE BASIS / JUSTIFICATION Technical Support For " Electrical", change I&C Coordinator Previously, the TSC staff included 2 "TSC Engineers" to TSC Electrical Engineer. For with no discipline specified. Also, personnel assigned to

" Mechanical", change Engineering the positions of Engineering Coordinator and l&C Coordinator to TSC Mechanical Engineer.

Coordinator may not have been fully knowledgeable of mechanical or electrical engineering design and analysis.

This change split out the two existing engineer positions by establishing two new ERO position titles - TSC Mechanical Engineer and TSC Electrical Engineer. This change facilitates assignment of better qualified personnel to provide discipline-specific mechanical and electrical engineering support.

Repair and Corrective Change number of personnel providing Bring SSREP staffing goals into closer alignment with Actions

" Mechanical Maintenance" expertise from NUREG 0654, Table B-1 guidance. Table B-1 specifies 2 to 1.

augmentation by 1 individual to provide " Mechanical Maintenance" expertise. One individual is sufficient to provide early accident phase mechanical maintenance support, i.e., prior to TSC and OSC activation.

Repair and Corrective For " Rad Waste Operator", change Mechanical Maintenance Personnel offer greater Actions Nuclear Systems Operator to Mechanical assignment flexibility for implementing " Repair and Maintenance Personnel.

Corrective Actions". Onshift Nuclear Systems Operators are capable of operating radwaste-related systems to the extent necessary to support early phase accident responses.

Page 3 of 4

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ATTACHMENT 3 EVALUATION OF 60-MINUTE AUGMENTED ERO STAFFING CHANGES TO FIGURE 8.13 INCORPORATED IN SSREP, REVISION 14 POSITION / FUNCTION DESCRIPTION OF CHANGE BASIS / JUSTIFICATION Repair and Corrective Change number of personnel providing Bring SSREP staffing goa:s into closer alignment with Actions "I&C Technician" expertise from 2 to 1.

NUREG 0654, Table B-1 guidance. Table B-1 specifies augmentation by 1 individual to provide "l&C Technician" expertise. One individual is sufficient to provide early accident phase mechanical maintenance support, i.e., prior to TSC and OSC activation.

Protective Actions (In-Change personnel performing this task As discussed in Attachment 6,4 augmented Health i

plant) from 4 Health Physics-Technicians to 1 Physics 'echnicians are not required for Access Control, i

I Health Physics Coordinator,1 HP Coverage for search and rescue and firefighting, Radiological Controls Coordinator and 1 Person sel Monitoring, or Dosimetry during the early Health Physics Technician.

phases of an accident.

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Ed ATTACHMENT 4 COMPARISON OF TABLE B-130 MINUTE STAFFING REQUIREMENTS WITH REVISION 14 SEABROOK STATION STAFFING AND RESPONSE BASIS Onshift ERO Position Title 0654 Position Major Functional Area Location /Maior Tasks or Expertise Number Performino Task Plant Operations and Shift Supervisor (SRO) 0 N/A

)

Assessment of Operational Shift Foreman (SRO) 0 N/A Aspects Control Room Operators 0

N/A Auxiliary Operators 0

N/A Emergency Direction and Shift Technical Advisor, O

N/A Control (Emergency Shift Supervisor _or Coordinator) designated facility manager Notification /

Notify licensee, State, 1

CR Comm, Security, Cormiunication local and Federal STED & Work Control' personnel & maintain Coordinator comunication Radiological Accident Emergency Operations Senior Manager 0'

N/A Assessment and Support of Facility (EOF) Director Operational Accident Offsite Dose Assessment Senior HP Expertise 1

STED/ Work Control Assessment Coordinator offsite Surveys 2

None - See Att. 5 Onsite (out-of-plant) 1 HP Technician, NSO, Fire Fighter /EMT or Chem Technician In-plant surveys HP Technicians 1

HP Technician, NSO, Fire Fighter /EMT or i'

Chem Technician Chemistry / Radiochemistry Rad / Chem Technicians 0

N/A Page 1 of 2 '

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a ATTACHMENT 4 COMPARISON OF TABLE B-130 MINUTE STAFFING REQUIREMENTS WITH REVISION 14 SEABROOK STATION STAFFING AND RESPONSE BASIS Onshift ERO Position Title 0654 Position Malor Functional Area location / Major Tasks or Expertise Ntsber Performing Task Plant System Engineering, Technical Support Shift Technical Advisor 0

N/A Repair and Corrective Core / Thermal Hydraulics 1

Shift Technical Actions Advisor Electrical 0

N/A

[

Mechanical 0

N/A Repair and Corrective Mechanical Maintenance /

0 N/A Actions Rad t!aste Operator Electrical Maintenance /

1 NSO

!&C Technician 1

None - See Att. 5 1

Protective Actions (In-Radiation Protection:

HP Technicians 2

HP Technician plant)

NSO

a. Access Control Fire Fighter /EMT

b. HP Coverage for Chem Technician repair, corrective actions, search and rescue first-aid &

firefighting

c. Personnel monitoring

d. Dosimetry 4

Firefighting Local N/A Support Rescue Operations and Local N/A First-Aid Support Site Access Control and Security, firefighting Security Personnel All per All per Security Personnel Accountability consnunications, personnel Security plan accountability plan PERSONNEL TOTAL 11 Page 2 of 2 l

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i ATTACHMENT 5 EVALUATION OF REVISION TO AUGMENTATION TIMING FOR FIGURE 8.15 PERSONNEL NUREG 0654 Major Task:

Notify licensee State, local and Federal personnel & maintain communication Number Required within 30 min.:

1 Onshift ERO Positions to which the Major Task is assigned:

a. licensee - Control Room Communicator and Security

b. State - Short Term Emergency Director or Work Control Coordinator

c. local - Notified by State under NHRERP and MARERP

d. Federal - Short Term Emergency Director or Work Control Coordinator Basis for the Assignment:

As indicated above, the SSREP separates each notification subtask and assigns it to different several groups and individuals, not just one. This arrangement distributes the work load that would be performed by one individual under NUREG 0654 Table B-1 to several individuals.

Following the initial emergency notification, both State response plans require only one brief verification callback to the Control Room before continuous communications are later established upon EOF activation. Neither State response plan requires continuous communications with North Atlantic emergency response facilities until their respective State Emergency Operations Centers are activated. Upon activation, their procedures direct that communications with North Atlantic be conducted through the EOF.

Numerous drills and exercises have demonstrated that onshift personnel can adequately perform " Notification / Communication" tasks within the first 60 minutes without adversely impacting other response actions.

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Augmented ERO Positions that Assume Major i

Task within 60 minutes:

a. licensee - not required; initial callout completed by onshift personnel

b. State - Site Emergency Director and ERO Technical Liaison

c. local - Notified by State under NHRERP and MARERP

d. Federal - Emergency Operations Manager i

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l ATTACHMENT 5 EVALUATION Of REVISION TO AUGMENTAllON TIMING FOR flGURE 8.15 PERSONNEL NUREG 0654 Major Task:

Offsite Dose Asi.essment Number Required within 30 min.:

1 Onshift ERO Positions to which the Major Task is assigned:

Short Term Emergency Director / Work Control Coordinator Bads for the Assignment:

Primary responsibility for initial offsite dose assessment is assigned to the Work Control Coordinator in the Control Room. This task is carried out at the direction of the Shift Superintendent /Short Term Emergency Director.

Authorization and timely transmission of protective action recommendations is the responsibility of the Shift Superintendent /Short Term Emergency Director, lhe Offsite Dose Projection System (ODPS) can be operated on selected Main Plant Computer System terminals located in the Control Room and the TSC.

ODPS can also be operated on a back-up laptop computer located in the Control Room. ODPS uses the sam, dose projection and plume dispersion model as the METPAC system used L, Jose assessment personnel in the EOF.

i The PAR methodology used by the Control Rooni (contained in SSER Procedure ER 1.2) is identical to the PAR merbodolc'y used by the EOF (contained in SSER Procedure ER 5.4).

Experience in numerous drills and exercises, as well as Licensed Operator Requalification Training, has confirmed the Operators' proficiency in making timely and appropriate protective action recommendations. This fact was noted by NRC Inspectors during the annual EP program inspection conducted the week of July 25,1994. The inspectors obse ved three crews assess and classify postulated events. They noted in the irspection Report that all PARS were correct except one and that that one was conservative.

The inspectors concluded that "no errors mada by the crews in the walk-throughs would have resulted in an adverse effect on the ability to protect the public health and safety.. " and that "the training of shift supervisory personnel was adequate based on performances observed."

Page 2 of 12

ATTACHMENT 5 EVALUATION OF REVISION TO AUGMENTATION TIMING FOR FIGURE 8.15 PERSONNEL Augmented ERO Positions that Assume Major Task within 60 minutes:

EOF Coordinator Page 3 of 12

ATTACHMENT 5 EVALUATION OF REVISION TO AUGMENTATION TIMING FOR flGURE 8.15 PERSONNEL NUREG 0654 Major Task:

Offsite Surveys Number Required within 30 min.: 2 Onshift ERO Positions to which the Major Task is assigned:

None Basis for the Assignment:

Determination of early offsite protective action recommendations are primarily based on plant indications, not offsite monitoring results. This is in keeping with existing regulatory guidance, examples of which are noted below.

1.

USNRC Memorandum, Status Renort on Guidance to Licensees on Protective Action Recommendations for Severe Accidents. Congel to Kwiatkowski, dated October 29,1991, states 1) " Initial scoping of an accident is to be based on plant observables, i.e., predetermined emergency action levels, and not projected doses", and 2) "Following the implementation of the initial, early protective actions near the plant, dose projections and field monitoring should be performed to determine if the protective actions should be expanded with field monitoring data being the preferred basis for relocation from sheltered areas."

2.

EPA 400-R-92-001, Section 2.4, recommends that " Emergency response plans for facilities should make use of Emergency Action Levels (EALs),

based on in-plant conditions, to trigger notification of and recommendations to offsite officials to implement prompt evacuation or sheltering in specified areas in the absence of information on actual releases or environmental measurements."

Additionally, offsite monitoring personnel responding prior to EOF activation could not be effectively deployed or utilized. The EOF staff members that provide direction and support to the survey teams, as well as subsequent data analysis capabilities, would not be able to perform their functions in a coordinated fashion until the EOF is operational. Likewise, key ERO and State decision-makers would not be in a position to effectively use analysis results from offsite monitoring data until the EOF and State EOCs were activated.

Page 4 of 12

ATTACHMENT 5 EVALUATION OF REVISION TO AUGMENTATION TIMING FOR FIGURE 8.15 PERSONNEL Augmented ERO Positions that Assume Major Task within 60 minutes:

Offsite Monitoring / Sampling Personnel Page 5 of 12 i

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d' ATTACHMENT 5 EVALUATION OF REVISION TO AUGMENTATION TIMING FOR FIGURE 8.15 PERSONNEL NUREG 0654 Major Task:

On-site (out of niant) Surveys Number Required within 30 min.: 1 On-shift ERO Positions assigned the Major Task:

Onshift Health Physics Technicians, Nuclear System Operators, Firefighter/EMT personnel, Chemistry Technicians and selected Radwaste Department personnel Basis for the Assignment:

In circumstances where a field measurement is required to determine or confirm that an EAL has been exceeded, the function would be performed by the on-shift Health Physics Technician. The pertinent EALs defined in SSER ER 1.1 are 12(a),12(b),12(d) and 12(e). For each of these EALs, indications from plant instrumentation in conjunction with the Offsite Dose Projection System (ODPS) would be the preferred method of determining whether the EAL has been exceeded.

Determination of early offsite protective action recommendations (PARS) are primarily based on plant indications. This is in keeping with current regulatory guidance. The PAR methodology used by the Control Room is driven primarily by plant indications consistent with the current guidance.

Following emergency declaration and prior to activation of the TSC and OSC, it is unlikely that onsite surveys would be conducted. During this time, the on-shift ERO personnel would be focused on completing required notifications, activating the augmented ERO, and taking mitigating actions.

In the event that an on-site survey were required prior to TSC and OSC activation, additional on-shift personnel are qualified to operate the survey meters used for conducting on-site surveys, including the RO-2 and RO-2A.

These personnel include 5 on-shift Nuclear System Operators,2 on-shift Firefighters/EMTs, and 1 on-shift Chemistry Technician. Training on these survey instruments is included in GT1071C, Radiation Worker Supplemental Training.

Page 6 of 12 i

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ATTACHMENT 5 EVALUATION OF REVISION TO AUGMENTATION TIMING FOR FIGURE 8.15 PERSONNEL Augmented ERO Positions that Assume Major Task within 60 Minutes:

Offsite Monitoring / Sampling Personnel 1

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ATTACHMENT 5 EVALUATION OF REVISION TO AUGMENTATION TIMING FOR FIGURE 8.15 PERSONNEL NUREG 0654 Major Task:

In-plant Surveys Number Required within 30 min.: 1 Onshift ERO Positions to which the Major Task is assigned:

Onshift Health Physics Technicians, Nuclear System Operators, Firefighter/EMT personnel, Chemistry Technicians and selected Radwaste Department personnel Basis for the Assignment:

In-plant surveys required to confirm that an emergency action level had been exceeded would be performed by the onshift HP Technician. Following emergency declaration, there is little likelihood that any in-plant surveys, except those required to support emergency repairs, would be undertaken within the first 60 minutes since the resulting data would not significantly alter pre-established emergency response actions. Surveys supporting emergency repairs are addressed under the NUREG 0654, Table B-1 category of " Radiation Protection" Systematic in-plant surveys may be undertaken following TSC and OSC activation.

In the event that a survey of an in-plant area was required, other personnel are available to perform this task prior to TSC and OSC activation. These positions include Nuclear System Operators, Firefighter/EMT, Chemistry Technicians, and selected Radwaste Department personnel. These individuals are GT1071C qualified. GT1071C, Radiation Worker Supplemental Training, is intended for personnel who require unescorted access into RCA areas normally unoccupied or not recently surveyed. Individuals completing this course are knowledgeable in the proper operation of survey meters including the RO-2 and RO-2A.

Augmented ERO Positions that j

Assume Major

)

Task within 60 minutes:

Health Physics Technicians i

Page 8 of 12 l

ATTACHMENT 5 EVALUATION OF REVISION TO AUGMENTATION TIMING FOR FIGURE 8.15 PERSONNEL NUREG 0654 Major Task:

Core / Thermal Hydraulics Number Required within 30 min.:

1 Onshift ERO Positions to which the Major Task is assigned:

Shift Technical Advisor Basis for the Assignment:

Within the first 60 minutes of an accident, Control Room operators would still be within the Emergency Operating Procedure network (i.e., Emergency Response Procedures, Functional Restoration Procedures or Emergency Contingency Actions procedures). Operators would likely not have exhausted their established procedures to the point where independent recommendations concerning core damage mitigation would be sought. If needed, the Shift Technical Advisor, who has received training in Mitigating Core Damage, could adequately perform this function until the arrival of the Reactor Engineer.

Augmented ERO Positions that Assume Major Task within 60 minutes:

Reactor Engineer Page 9 of 12 l

ATTACHMENT 5 EVALUATION OF REVISION TO AUGMENTATION TIMING FOR FIGURE 8.15 PERSONNEL NUREG 0654 Major Task:

Electrical Maintenance Number Required within 30 min.: 1 Onshift ERO Positions Assigned the Major Task:

1 Nuclear System Operator Basis for the Assignment:

SSREP Figure 8.15 assigns 2 electrical maintenance personnel to augmented ERO 60 minute reporting positions. Augmented personnel performing electrical maintenance corrective actions would not be deployed until the TSC and OSC are activated. These facilities provide the requisite direction, control, and logistical support necessary to prepare and dispatch maintenance personnel to perform corrective actions effectively. The electrical maintenance personnel could not be effectively utilized until the TSC and OSC are activated to perform these functions. Experience has indicated that the time required for these facilities to activate, evaluate conditions, set priorities, assemble tools and documentation, and establish appropriate work controls will approach 60 minutes.

During the first 60 minutes, the on-shift ERO would be focused on completing required notifications, activating the ERO and taking mitigating actions. The Control Room would not have the time to focus on performing the proper work control functions for deployment of repair teams into the plant.

Augmented ERO Positions that Assume Major Task within 60 Minutes:

Two electrical mainterance personnel Page 10 of 12

ATTACHMENT 5 EVALUATION OF REVISION TO AUGMENTATION TIMING FOR FIGURE 8.15 PERSONNEL NUREG 0654 Major Task:

Instrument and Control Technician Number Required within 30 min.: 1 On-shift ERO Positions to which the Major Task is assigned:

None Basis for not assigning an I & C Tech.

within 30 minutes:

SSREP Figure 8.15 assigns one I & C Technician as an augmented ERO 60 minute reporting position. Augmented personnel performing repair and corrective actions would not be deployed until the TSC and OSC are activated.

These facilities provide the requisite direction, control, and logistical support necessary to prepare and dispatch personnel to perform repair and corrective actions effectively. The I & C Technician could not be effectively utilized or safely deployed until the TSC and OSC are activated to perform these functions. Experience has indicated that the time required for these facilities to activate, evaluate conditions, set priorities, assemble tools and documentation, and establish appropriate work controls will approach 60 minutes.

During the first 60 minutes, the on-shift ERO would be focused on completing required notifications, activating the ERO and taking mitigating actions. The Control Room would not have the time to focus on performing the proper work control functions for deployment of repair teams into the plant.

Augmented ERO Positions that Assume Major Task within 60 Minutes:

One I & C Technician i

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ATTACHMENT 5 EVALUATION OF REVISION TO AUGMENTATION TIMING FOR FIGURE 8.15 PERSONNEL NUREG 0654 Major Task:

Radiation Protection Number Required within 30 min.: 2 Onshift ERO Positions to which the Major Task is assigned:

Onshift Health Physics Technicians, Nuclear System Operators, Firefighter/EMT personnel, Chemistry Technicians and selected Radwaste Department personnel as discussed in detail in Attachment 6.

Basis for the Assignment:

As discussed in Attachment 6, augmented HP Technicians are not required for Access Control, HP Coverage for search and rescue, and firefighting, Personnel Monitoring, or Dosimetry during the early phases of an accident. They would not be required for repair and corrective actions since teams would not be dispatched within the first 60 minutes for the reasons discussed above under Electrical Maintenance, above.

Augmented ERO Positions that Assume Major Task within 60 minutes:

Health Physics Coordinator, Radiological Controls Coordinator and Health Physics Technician Page 12 of 12

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ATTACHMENT 5 l

EVALUATION OF REVISION TO AUGMENTATION TIMING FOR FIGURE 8.15 PERSONNEL NUREG 0654 Major Task:

Radiation Protection

]

l Number Required within 30 min.; 2 Onshift ERO i

Positions to which the Major Task is assigned:

Onshift Health Physics Technicians, Nuclear System Operators, Firefighter/EMT i

personnel, Chemistry Technicians and selected Radwaste Department personinel as discussed in detail in Attachment 6.

Basis for the Assignment:

As discussed in Attachment 6, augmented HP Technicians are not required for Access Control, HP Coverage for search and rescue, and firefighting, Personnel Monitoring, or Dosimetry during the early phases of an accident. They would j

not be required for repair and corrective actions since teams would not be j

dispatched within the first 60 minutes for the reasons discussed above under l

Electrical Maintenance, above.

Augmented ERO l

Positions that Assume Major Task within i

60 minutes:

Health Physics Coordinator, Radiological Controls Coordinator and Health Physics Technician 1

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I l

1 l

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Page 12 of 12

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.x_____________

ATTACHMENT 5 EVALUATION OF REVISION TO AUGMENTATION TIMING FOR FIGURE 8.15 PERSONNEL NUREG 0654 Major Task:

Radiation Prntection Number Required within 30 min.: 2 Onshift ERO Positions to which the Major Task is assigned:

Onshift Health Physics Technicians, Nuclear System Operators, Firefighter/EMT personnel, Chemistry Technicians and selected Radwaste Department personnel as discussed in detail in Attachment 6.

Basis for the Assignment:

As discessed in Attachment 6, augmented HP Technicians are not required for Access Control, HP Coverage for search and rescue, and firefighting, Personnel Monitoring, or Dosimetry during the early phases of an accident. They would not be re quired for repair and corrective actions since teams would not be dispatched witilin the first 60 minutes for the reasons discussed above under Electrical Maintenance, above.

Augmented ERO Positions that Assume Major Task within 60 minutes:

Health Physics Coordinator, Radiological Controls Coordinator and Health Physics Technician 1

i A

Page 12 of 12

ATTACHMENT 6 EVALUATION OF REVISED PERSONNEL ASSIGNMENTS TO AUGMENTED RADIATION PROTECTION DUTIES REQUIRED BY THE SSREP Renulatory Basis The guidance for augmented Ernergency Response Organization (ERO) staffing to perform in-plant radiation protection tasks is presented in NUREG-0654/ FEMA-REP-1, Rev.1 at Table B-1.

The listed tasks include:

Access Control HP Coverage for repair, corrective act;ons, search and rescue first aid & firefighting Personnel monitoring Dosimetry NUREG 0654 Table B-1 assigns these activities to a total of 4 augmented persons with the title of Health Physics (HP) Technicians.

Seab. rook Station Radiolonical Emernency Plan Commitmeni n

The SSREP describes the augmented ERO in Figure 8.15. Revision 13 indicated that 4 HP Technicians were assigned to meet the above guidance.

Revision 14 to the SSREP This revision changes personnel performing in-plant radiation protection tasks from 4 HP Technicians to the following ERO personnel:

1 Health Physics Coordinator 1 Radiological Controls Coordinator 1 HP Technician lustification for Revision Several unique characteristics of the Seabrook Station organization and facility allow for satisfactory performance of the Radiation Protection tasks listed in Table B-1 of NUREG 0654 using an alternative staffing approach. These characteristics include certain provisions of the Station Radiation Protection Program, enhanced radiation protection training requirements, and specific station physical arrangements and layouts regarding dosimetry and radiation monitoring.

This is discussed below.

Page 1 of 3

i ATTACHMENT 6 EVALUATION OF REVISED PERSONNEL ASSIGNMENTS TO AUGMENTED RADIATION PROTECTION DUTIES REQUIRED BY THE SSREP 1.

ACCESS CONTROL HP Technicians are not required to effect access control measures during the early phases of an accident. The HP Coordinator can provide overall direction for this task from the TSC while the Radiological Controls Coordinator controls RCA access at the OSC [ Health Physics Access Control Point (HPACP)]. In addition, the Station Radiation Protection Program Manual, Section 2.2, specifically allows HP supervisory personnel to authorize deviations from normal practices (e.g., granting emergency-related entries into the RCA without an HP Technician being present).

2.

HP COVERAGE Not all response personnel entering the RCA (or unknown areas) need coverage by an HP Technician. For example,2 of the 4 functicns called out in Table B-1, search and rescue first-aid and firefighting, are performed by Fire Fighter /EMT personnel and Nuclear Systems Operators (NSOs). These individuals are GT1071C qualified. GT1071C, Radiation Worker Supplemental Training, is intended for personnel who require unescorted access into RCA areas normally unoccupied or not recently surveyed. Chemistry Technicians and Radwaste Technicians are also GT1071C qualified.

Since NSOs may perform basic mechanical and electrical system troubleshooting and corrective action tasks, only personnel performing specialized repair or corrective actions (e.g., Mechanical Maintenance, Electrical Maintenance, and I&C) would need coverage by an HP Technician during the early phases of an accident.

In addition, Self Contained Breathing Apparatus (SCBA) kits are available near the HPACP to facilitate entries into areas with high airborne radioactivity concentrations or where conditions are unknown.

3.

PERSONNEL MONITORING HP Technicians are not required to perform personnel monitoring during the early phases of an accident. Alarming frisker portal monitors are positioned at the HPACP and routinely used by station radiation workers. In addition, radiation workers are trained in personal monitoring techniques. Personal monitoring mstruments (portable friskers) are readily available at the HPACP. Furthermore, the HP Coordinator and Radiological Controls Coordinator would be available to perform personnel monitoring at the TSC and OSC, respectively.

Page 2 of 3

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5 ATTACHMENT 6 EVALUATION OF REVISED PERSONNEL ASSIGNMENTS TO AUGMENTED RADIATION PROTECTION DUTIES REQUIRED BY THE SSREP 4.

DOSIMETRY l

Dosimetry can be obtained and returned without the assistance of HP Technicians during the early phases of an accident. It is routine station practice for radiation workers to obtain and. return their dosimetry.without the aid of HP Technicians. Radiation worker dosimetry is readily available from racks located adjacent to the HPACP. The HP Coordinator and

[

Radiological Controls Coordinator are also available to facilitate dosimetry issuance within their respective facilities, j

As noted in the above discussion, 3 of the 4 tasks assigned to HP Technicians by NUREG 0654, i

Table B-1, can be performed by other ERO members with no adverse impact to overall emergency response capabilities. In addition, due to enhanced HP training requirements for certain ERO members, HP-Technicians are partially relieved of the fourth task, HP Coverage.

The types and magnitude of tasks envisioned by NUREG 0654 as necessitating 4 HP Technicians l

would not exist at Seabrook Station during the early phases of an accident. Two (2) HP Technicians (1 on-shift and 1 augmented) are available to provide coverage for specialized repair and corrective action teams.

Since it is unlikely that the NUREG-0654 Table B-1 function of "in-plant surveys" would be l

conducted except for those required to support coverage for repair and corrective actions, an HP -

l Technician could perforrn both of these tasks at the same time.

Finally, concerning the task of onsite surveys, TSC and OSC activation would typically occur i

before a team would be dispatched to perform systematic onsite surveys. During the initial phases of an accident, a onsite survey (e.g., a simple site boundary reading to confirm the j

magnitude of a release) could be adequately performed by 1 HP Technician. Therefore,1 of the 2 HP Technicians assigned to this task category could be made available to support more

+

pressing needs (e.g., dispatch of a specialized repair or corrective action team).

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