ML20137T088

Responds to NRC 851220 Request for Addl Info Re 810403, 830202 & 0415 Proposed Exemptions to Emergency Staffing Augmentation Goals (NUREG-0737,Suppl 1).Survey of Proposed Emergency Augmentation Organization Response Times Encl

ML20137T088
Person / Time
Site:	Peach Bottom
Issue date:	02/11/1986
From:	Cooney M PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Muller D Office of Nuclear Reactor Regulation
References
RTR-NUREG-0654, RTR-NUREG-0737, RTR-NUREG-654, RTR-NUREG-737 NUDOCS 8602180177
Download: ML20137T088 (2)

Text

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f PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 (ats)eas. sono a ..."U . .' .*"UI*.".,...,

February 11, 1986 Docket Nos. 50-277 50-278 Mr. Daniel R. Muller, Director BWR Project Directorate #2 Division of BWR Licensing U. S. Nuclear Regulatory Commission Washington, DC 20$bb SUBJ ECT: Request for Additional Information Concerning the Proposed Exceptions to the Staffing Goals for Emergencies

REFERENCE:

Peach bottom Atomic Power Station, Units 2 and 3

Dear Mr. Muller:

By letters dated April 3, 1981, February 2, 1983 and April 15, 1983, the Philadelphia Electric Company (PECo) requested exceptions to the staf fing augmentation goals for emergencien (NUREG-0737, Supplement 1) for Peach Bottom, Unita 2 and 3.

In your response dated December 20, 1985, you requested that PECo submits

1. A current staffing proposal keyed to the goals in NUREG-0654/ FEMA-REP-1, Rev. 1, Table B-1, identifying any differences.

2. A survey of the expected elapsed time from the declaration of an emergency to arrival of emergency response pe rsonnel for each augmentation position identified in the current staffing proposal. This is simply adding the notification time and the commuting time for each person occupying those positions.

3. Where there are dif ferences from Table b-1 goals for arrival times, provide an explanation of how the a functions will be performed using on-chif t resources. $44 B602190177 3 1i PDR ADOCM 0 7  %

F F $

p O.

Mr. ' Daniel" R. Muller, J r. , USNRC February. 11,.1986

( Page.2 of.7 Our response to items 1 and 3 are presented in-Attachment A (Staffing Goals Versus Current PBAPS Staffing and Proposed PhAPS Staffing) which provides a tabular comparison between Table B-1 and PBAPS . staf fing.. Any differences are indicated in the third column of each of the major timing areas, i.e., on-shift, 30 minute augmentation, 60 minute augmentation.

Attachment 1 also reflects the proposed addition of personnel to the emergency response organization which we intend to accomplish by the third quarter 1986.

A more detailed discussion of PBAPS current and prop ssed emergency response staffing is as follows:

1. Plant Operations and Assessment of Operational Aspects PEAPS currently- is consistent with the goals of Table B-1.

L PEAPS presently has three (3) Auxiliary Operators on shif t rather than the two (2) Auxiliary Operators proposed by Table B-1.

2. Emergency Direction and Control PBAPS currently is consistent with the goals of Table b-1.

3. Notification / Communication The goal in Table B-1 is to have one (1) person on-shifts and one communicator to arrive within 30 minutes and two within 60 minutes. .

PBAPS currently has two (2) persons on-chif t to perform communicators functions and two (2) within 60 minutes.

4. Radiological Accident Assessment and Support of Operational Accident Assessment.

a. Emergency Operations Facility (EOF) Director (Senior Manager)

PhAPS currently is consistent with the goals of Table B-1.

o Mr. Daniel R. Muller, Jr. , USNRC February 11, 1986 Page 3 of 7

b. Off-Site Dose Assessment (Senior Health Physics Exper tise)

The goal in. Table B-1 is to have one person arrive within 30 minutes.

PhAPS currently adds this person within 6u minutes but will cover the 30 minute requirement by having a person on-shift who is trained in dose assessment at the same level as the senior health physics management personnel. This person will be trained in the new computerized dose assessment program which is expected to be installed by the third quarter of 1986. Senior Management with health physics expertise will be available within one hour.

Additionally, the new computer dose assessment system will provide guidance to shif t personnel on protective action recommendations.

c. Off-site Surveys (health physics technicians)

The goal in Table B-1 is to have two (2) persons to arrive by 30 minutes and two ( 2) persons to arrive by 60 minutes.

PBAPS currently has four (4) persons available within 60 minutes.

PhAPS proposes to change staf fing such that two (2) health physics technicians will be available within 30 minutes and two (2) additional health physics technicians will be available within 60 minutes.

d. On-site (out-of-plant) (health physica technicians)

The goal in Table B-1 is to have one (1) person to arrive by 30 minuten and one (1) person to arrive by 60 minutes.

PBAPS currently has one pornon on shift and one person arriving within 60 minutco.

I l

.,_____mm

Mr. Daniel R. Muller, Jr. , USNRC February 11, 1966 Page 4 of 7

e. In-plant surveys (health physics technicians)

The goal in Table B-1 is to have one person on-shif t, one person to arrive within 30 minutes and one person to arrive within 60 minutes.

PBAPS currently has one (1) person on-shif t and two

( 2) persons to arrive within 60 minutes.

PBAPS proposes to change staf fing such that one (1) health physics technician will be available on-shif t, one (1) health physics technician will be available within 30 minutes, and one health physics technician will be available within 60 minutes. b

f. Chemistry /Radiochemis try (Rad / Chem Technicians)

PbAPS currently meets the goals of Table B-1.

5. Plant System Engineering, Repair and Corrective Actions

a. Technical Support (Shif t Technical Advisor)

PbAPS currently meets the goals of Table B-1.

b. Technical Support (Core / Thermal Hydraulics)

The goal in Table B-1 is to have one (1) person available within 30 minutes.

PbAPS currently has one person on-shif t, i.e., the Shift Technical Advisor (STA) to fulfill this function which is part of the STA 's primary responsibility. The Core / Thermal Hydraulics function and the function of the STA are synonymous. The STA is uniquely qualified to perform this function because the STA:

o is part of the shif t organization and rotates schedules with the shift.

o has a four (4) year technical degree.

o is trained in mitigation of core damage and transient analysis, heat transfer, fluid flow and thermodynamics.

In addition, PbAPS' shif t organization (Shitt Superintendent and the Shif t Supervisor) has responsibility for portormance of emergency operating procedures in the Control Room.

r Mr. Daniel R. Muller, Jr. , USNRC February ll, 1986 Page 5 of 7

c. Technica) Support (Electrical)

The goal in Table b-1 is to have one (1) person available within 60 minutes.

PBAPS currently is consistent with the goals of Table B-1. .

d. Technical Support (Mechanical)

The goal in Table B-1 in to have one (1) person available within 60 minutes.

PBAPS currently is consistent with the goals of Table B-1.

e. Repair and corrective actions (Mechanical Maintenance)

The goal in Table B-1 is to have one (1) person available who may be assigned other functions and one (1) person within 60 minutes.

PbAPS currently is consistent with the goals of Table B-1.

PbAPS proposes to change staf fing such that in addition to the one (1) person on-shift, one person would be available within 60 minutes.

f. Repair and corrective Actions (Rad Waste Operator)

The goal in Table b-1 is to have one (1) pornon available who may be assigned other functions and one (1) person within 60 minutco.

PbAPS currently in consistent with the goals of Table B-1.

F Mr. Daniel R. Muller, Jr. , USNRC February 11, 1986 Page 6 of 7

g. Repair and Corrective Actions (Electrical Maintenance)

The goal in Table B-1 is to have one (1) person available who may be assigned other functions and one person available within 30 minutes and one person available within 60 minutes.

PBAPS currently has one (1) person on-chift and two

( 2) persons with 60 minutes to fulfill this function.

h. Repair and Corrective Actions (Instrument and Control Technicians)

The goal in Table b-1 is to have one (1) person available within 30 minutes.

PbAPS currently has two people on-shift able to fulfill this function.

6. Protective Actions (In-Plant) (health physico technicians)

The goal in Table b-1 is to have two (2) health physico technicians on shift (who may be assigned other functions) and two (2) persons availabic within 30 minutes and two (2) persons available within 60 minutes.

PbAPS currently han two (2) persons on shif t and four (4) persons within 60 minutes to fulfill this function.

PbAPS proposen to increano staffing auch that in addition to the two (2) health physico techniciana available on shift, one additional health physics technician and one (1) pornon for donimetry.would be available within 30 minutes. Two ( 2) health physics technicians will be available within 60 minutes.

7. Fire Fighting PhAPS currently in consistent with the goals of Table b-1.

U. Roncue Operationo and First Aid PBAPS currently in consistent with the 90a10 of Table b-1.

9. Site Accean Control and Personnel Accountability PbAPS currently 10 conolatent with the goalo of Table b-1.

l l

e- .

O Mr. Daniel R._ Muller, Jr. , USNRC

. February 11, 1986 Page 7 of'7 Since we are proposing to change our emergency response augmentation organisation', our response time survey (Attachment b) addressos this proposed organization as 'it will be ef fective -

third' quarter 1986. This information results from four annual

- emergency response exercises observed by NRC inspection teams and numerous practice drills, all which require rapid staffing.

. Additionally, surveillance ~ tests which test response times have.

been performed. The response time for those persons on the current.organisation are consistent with our emergency response organisation as outlined in our letters dated April 3, 1981, February 2, 1983 and April 15, 1983.

We believe that the current shif t complement and the proposed staf fing organizations

, o adequately responds to the letter G. Gears, NRC to E. G.

Jauer, Jr., PECo and Attachment 1 of same.

o adequately addresses the goals of NUREG-0654/ FEMA-REP-1, Rev. 1, Table B-1.

o reflects response _ times for the demographics of a remote-site as PBAPS.

Should you have any further questions or require further information, please do not hesitate to contact us.

Sincerely, Dr!ginal LifN'! bf LM. 'J. COGNEY cca Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20bbb T. P. Johnson, Resident Site Inspector t

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s Attachment B Response ~ Times ;for -the -Proposed Emergency Augmentation Organization POSITION / REQUIREMENT' TIME TO REPORT (RANGE)

Oommunicators.

1-within 30 minutes On-Shift 2 within 60 minutes 15 to 60 minutes Senior EOF Manager

- 60 minutes 15 to 60 minutes Dose Assessment 30 minutes On-Shift (Senior Management 15-60 minutes)

Off-Site Surveys 2 within 30 minutes On-Shift 2 within 60 minutes 15 to'60 minutes On-Site Surveys 1 within 30 minutes On-Shift I within 60 minutes 15 to 60 minutes In-Plant Surveys 1 within 30 minutes On-Shift 1 within 60 minutes 15 to 60 minutes l

Radio Chemistry Technicians l'within 60 minutes 15 to 60 minutes Page 1 of 2

(-

-Attachment B Core / Thermal Hydraulics

^

1 within 30 minutes On-Shift plus 1 within 60 minutes Electrical and Mechanical

Technical Support 2 within 60 minutes 15 to 60 minutes Mechanical Maintenance 1 within 60 minutes 15 to 6u minutes

' Radwas te Ope rato r '

1 within'60 minutes On-Shift Electrical Maintenance 1 within 30 minutes On-Shift 2 within 60 minutes 15 to 60 minutes Instrument and Controls 1 within '30 minutes On-Shift Radiation Protection 2 within 30 minutes On-Shift 2 within 60 minutes 15 to 60 minutes Page 2 of 2