ML20137U191
| ML20137U191 | |
| 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-0737, RTR-NUREG-737 NUDOCS 8602190082 | |
| Download: ML20137U191 (12) | |
Text
. _ _ _ _ _ _ _ _ _ - _ _ _
a PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET i
P.O. BOX 8699 PHILADELPHIA. PA.19101 (255) 849 5020 (Lacen s.noove ion es antasan, February 11, 1986 Docket Nos. 50-277 50-278 Mr. Daniel R. Muller, Director l
BWR Project Directorate #2
)
Division of bHR Licensing
)
U. S. Nuclear Regulatory Commission Washington, DC 20555 i
SUBJ ECT:
Request for Additional Information Concerning the Proposed Exceptions to the Staf fing Goals for Emergencies
REFERENCE:
Peach Bottom Atomic Power Station, Units 2 and 3
Dear Mr. Muller:
By letters datad April 3, 1981, February 2, 1983 and April 15, 1983, the Philadelphia Electric Company (PECo) requested exceptions to the staf fing augmentation goals for emergencies (NUREG-0737, Supplement 1) for Peach Bottom, Units 2 and 3.
In your response dated December 20, 1985, you requested that PEco submit:
1.
A current staffing proposal keyed to the goals in NUREG-0654/ FEMA-REP-1, Rev. 1, Table B-1, identitying any differences.
2.
A survey of the expected elapsed time from the declaration of an emergency to arrival of emergency response personnel for each augmentation position identified in the current staf fing proposal.
This is simply adding the notification time and the commuting time for each person occupying those positions.
3.
Where there are dif ferences f rom Table B-1 goals for arrival times, provide an explanation of how the lj,.".T"Euu,,
f unctions will be performed using on-shif t resources.
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Mr. Daniel R. Muller, Jr., USNRC February 11, 1966 Page 2 of 7 Our response to items 1 and 3 are presented in Attachment A (Staffing Goals Versus Current PBAPS Staffing and Proposed PBAPS Staffing) which provides a tabular comparison between Table B-1 and PBAPS staffing.
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.
, 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 proposed emergency response staffing is as follows:
1.
Plant Operations and Assessment of Operational Aspects PBAPS currently is consistent with the goals of Table B-1.
PBAPS presently has three ( 3) Auxiliary Operators on shift 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-shift; and one communicator to arrive within 30 minutes and two within 60 minutes.
PBAPS currently has two (2) persons on-shift 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)
PBAPS currently is consistent with the goals of Table B-1.
i 1
e Mr. Daniel R. Mulle r, Jr., USNRC February 11, 1986 Page 3 of 7 b.
Off-Site Dose Assessment (Senior Health Physics Expertise)
The goal in Table B-1 is to have one person arrive within 30 minutes.
PBAPS currently adds this person within 60' 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 6 0 minutes.
PBAPS currently has four (4) persons available.
within 60 minutes.
f PBAPS proposes to change staffing 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 physics technicians)
The goal in' Table B-1 is to have one (1) person to l
arrive by 30 minutes and one (1) person to arrive l
by 6 0 minutes.
PBAPS currently has one person on shift and one person arriving within 60 minutes.
L.
t
Mr. Daniel R. Muller, J r., USNRC February ll, 1966 Page 4 of 7 e.
In-plant surveys (health physics technicians)
The goal in Table B-1 is to have one person on-shift, one person to arrive within 30 minutes and one person to arrive within 60 minutes.
PBAPS currently has one (1) person on-chif t and two
( 2) persons to arrive within 60 minutes, i
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.
8 f.
Chemistry / Radiochemistry (Rad / Chem Technicians)
PBAPS currently meets the goals of Table B-1.
b.
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-shift, i.e.,
the Shif t 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 shift organization (Shift Superintendent and the Shift Supervisor) has responsibility for performance of emergency opera. ting procedures in the Control Room.
Mr. Daniel R.'
Muller, Jr., USNRC February ll, 1966 Page 5 of 7 c.
Technical 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 is 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 staffing 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-l _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.
~
-Mr. Daniel.R. Mulle r, J r., 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-shift 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 availabl.e within 30 minutes.
PhAPS currently has two people on-shift able to fulfill this function.
6.
Protective Actions (In-Plant) (health physics technicians)
The goal in Table B-1 is to have two (2) health physics technicians on shift (who may be assigned other functions) and two (2) persons available within 30 minutes and two ( 2) persons available within 60 minutes.
PBAPS currently has two ( 2) persons on shift and four (4) persons within 60 minutes to fulfill this function.
PBAPS proposes to increase staffing such that in addition to the'two ( 2) health physics technicians available on shift, one additional health physics technician and one (1) person-for dosimetry would be available within 30 minutes.
Two ( 2) health physics technicians will be available within 60 minutes.
7.
Fire Fighting PBAPS currently is consistent with the goals of Table b-1.
8.
Rescue Operations and First Aid PBAPS currently is consistent with the goals of Table B-1.
9.
Site Access Control and~ Personnel Accountability PBAPS currently is consistent with the goals of Table B-1.
]
I.
Mr..Danier R. Muller, Jr., -USNRC February 11, 1986 Page 7 of 7' Since we are proposing to change our emergency response
' augmentation organization, our response time survey (Attachment B) addresses 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 organization are consistent with our emergency response organization as outlined in our letters dated April 3,
- 1981, February 2, 1983 and April 15, 1983.
We believe that the current shift complement and the prop' sed staffing ~ organization:
o o
adequately responds to.the letter G. Gears, NRC to E. G.
Bauer, Jr.,
PECo and Attachment 1 of same.
o adequately addresses the goals of NUREG-06b4/ 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.
cere y,
,p N bdA cc:
Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 T.
P. Johnson, Resident Site Inspector
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I Attachment B Response Times for the Proposed Emergency Augmentation Organization POSITION / REQUIREMENT TIME TO REPORT -(RANGE)
Communicators
'l 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 1 within 60 minutes 15 to 60 minutes In-Plant' Surveys 1 within 30 minutes On-Shift 1 within 60 minutes 15 to 60 minutes Radio Chemistry Technicians 1 within 60 minutes 15 to 60 minutes Page 1 of 2
h-
. Attachment B.
l l
l Core / Thermal Hydraulics 1 within 30 minutes On-Shift plus 1 within 60 minutes Electrical and Mechanical Technical Support 2 within 60 minutes-lb to 60 minutes Mechanical Maintenance 1 within 60 minutes 15 to 60 minutes Radwaste Operator 1 within 60 minutes On-Shift Electrical Maintenance 1 within 30 minutes On-Shift a
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 l
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