ML20083F080
| ML20083F080 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 12/22/1983 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| ULNRC-708, NUDOCS 8312300134 | |
| Download: ML20083F080 (5) | |
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- December 22, 1983 ar. LoE. S.*o'Ja*.= i..
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$Mr. Richard C. DeYoung, Director ULNRC-708 -
.Officeiof. Inspection-& Enforcement
.U.S.
Nuclear. Regulatory-Commission Washington,-DCc20555-
Dear _Mr.cDeYoung:
DOCKET NO. 50-483
=CALLAWAY PLANT, UNIT 1 REQUEST FOR EXCEPTION TO EOF ACTIVATION TIME RECOMMENDATION Inra meeting on. November;28 and 29,:1983, with DavidLRohrer of your Staff,.we-were told that-the Callaway
- Plant Emergency ( Operations Facility -(EOF) must be physically
. activated'approximately one hour after declaration of a Site
" Area Emergency.
The.Callaway Plant Radiological Emergency Response Plan 5(Onsite. Plan) calls for staffing _the EOF with corporate' personnel primarily..from our St. Louis office, which wouldi entail'approximately a three-hour activation Ltime..LConsequently,1we request an exception from the recom-mendation contained in NRC-guidance documents that the EOF become~fullyLactivated in one hour.-
We understand the Staff's-one-hour EOF tctivation criterion to be based'on the recommendations contained in LNUREG-0654, Rev; 1 (Nov.1980) ; NUREG-0696 (Feb. 1981) ; and-
'NUREG-0737, Suppl. 1 (Dec. 1982).-
Specifically, NUREG-0654 recommends that emergency facilities be activated and staffed
'in a timely fashion.
NUREG-0696 states that designated-emergency response. personnel shall report directly to the EOF to achieve, full functional operation within one hour.
NUREG-0737 provides-as a goal that the' EOF be. staffed in accordance with. Table 2lof that document, which specifies one hour for availability of the. EOF Director.
NUREG-0737 also notes that reasonable exceptions to the specified goals for staffing ~and response times for their arrival will be considered _by'the Staff.
These recommendations recently were discussed by the Commission in the TMI-l restart decision.
See Metropolitan Edison Co. (Three Mile Island
~
Unit-No. 1), CLI-83-22, 18 N.R.C.
Nuclear Station,
-(Sept. 8, 1983).
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'8312300134 831222 1, V PDR ADOCK 05000403 F
We believe staffing of the emergency response facilities at Callaway Plant meets the intent of NUREG-0737 and NUREG-0696, and constitutes a reasonable exception to the one-hour EOF activation goal specified in Table 2 of NUREG-0737.
At Callaway, those onsite personnel responding to an emergency within the first hour who have functions subsequently carried out at the EOF initially report to the Technical Support Center (TSC).
See Onsite Plan, Table 5-1.
These emergency response functions are carried out at the TSC until corporate personnel arrive at the Callaway Plant site, which is conservatively estimated to take two to three hours after declaration of a Site Emergency.
All data systems and displays available in the EOF also are present in the TSC to ensure satisfactory emergency response capability.
Specifically, the following EOF functions, specified in NUREG-0696 and NUREG-0737, are fully satisfied by our proposed staffing arrangement:
1.
Management of overall licensee emergency response.
Initially, the functions of the EOF Director identified in NUREG-0737, Table 2 are performed by the Emergency Coordinator in the TSC.
The Emergency Coordinator will be responsible for directing overall emargency response from the TSC until arrival of the Recovery Manager.
See Onsite Plan, Section 5.2.3.1.
2.
Coordination of radiological and environmental assessment.
This activity will be accomplished in the TSC by the Health Physics (HP) Coordinator and the Dose Assessment Coordinator until these personnel are relieved by corporate staff at the EOF.
See Onsite Plan, Sections 5.2.3.3 and 5.2.3.10.
3.
Determination of recommended public protective actions.
The Emergency Coordinator, located in the TSC, is responsible for recommending public protective actions.
He is assisted in this determination by the HP Coordinator and the Dose Assessment Coordinator.
When the onsite emergency staff is relieved by corporate personnel, this function is transferred to the corporate staff located in the EOF.
See Onsite Plan, Section 5.2.3.1.
4.
Coordination of emergency response activities with Federal, State, and local agencies.
Initial com-munications with offsite agencies are made from the Control Room and the TSC.
At the Alert or higher classification, the Offsite Liaison Coordinator, who is a member of the corporate i
k
r-organization, reports to the EOF and handles coordination with offsite agencies from that location.
Since onsite nuclear operations personnel initially will perform the emergency functions described above, we belteve that having these individuals report to the TSC results in the most efficient use of manpower, t me, and space.
If these personnel were required to work from the EOF, an awkward transition would.take place when corporate personnel begin to arrive at the EOF.
Operations personnel would be required to physically move from the TSC to the EOF at the declaration of a Site Area Emergency and then move back to the TSC when relieved.
We believe that, in the case of the Callaway Plant, it would be counterproductive to require all personnel with responsibilities for offsite emergency response functions to report to the EOF within one hour.
We are aware of the Commission's decision in the TMI-l case.
However, we believe that the basis for the Commission's requirement in that case that the EOF be operational in one hour was.its disapproval of the licensee's plan to conduct offsite response activities from the control room for the first four hours of an emergency.
In the Commission's view, this proposal did "not adequately reflect one of the primary lessons learned from the Three Mile Island accident," namely, "that those in the control room should be free to concentrate on accident assessment, plant control, and accident mitigation and should not be responsible for carrying out other critical functions such as radiological assessment and making protective action recommendations."
CLI-82-22, slip op at 14.
The Callaway Plant Onsite Plan does not present this problem.
Not withstanding the fact that the EOF is not operational within one hour, at Callaway, since the functions of radiological assessment and protective action recommenda-tions will be the responsibility of individuals stationed in the TSC, the attention of control room personnel will not be distracted away from plant technical conditions.
Furthermore, the opportunity for face-to-face communications between the licensee and government officials, which was another Commission concern in the TMI-1 case, is not adversely affected by the Callaway Plant Onsite Plan.
This is because the Offsite Liaison Coordinator reports to the EOF at the Alert (or higher) classification within 90 minutes after declaration.
In summary, we believe that the Callaway Plant Onsite Plan effectively and efficiently uses manpower and other resources available over the initial hours of an emergency.
We also believe that the way in which this is accomplished
._4_
at Callaway, with an orderly transition from TSC to EOF
' direction of radiological assessment-and protective action recommendations asicorporate personnel arrive from St. Louis, is fully consistent with the Commission's decision in the
.TMI-l case.
Consequently, we hereby request an exception from the regulatory guidance criterion that the EOF be activated in one hour.
Very truly yours, Donald F.
Schnell NGS/lkr
a
.r e
STATE OF MISSOURI )
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Donald F. Schnell, of lawful age, being first duly sworn upon oath says that he is Vice President-Nuclear and an officer of
. Union Electric Company; that he has read the foregoing document and
'knows the content thereof; that he has executed the same for and on behalf of said company with full. power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.
By Donald F. Sthnell Vice President Nuclear SUBSCRIBED and sworn to before me this ofo/M day of rese/v, 198 3.
$2,,, 0-a BARBARA J. PFAfr, NOTARY PUBL!C, STATE OF MissCURt MY COT.flSSION EXrIRES AFRIL 22,1;o5 ST, LOUIS COUf4TY.
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