ML20195H980
| ML20195H980 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 11/17/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20195H968 | List: |
| References | |
| NUDOCS 9811240162 | |
| Download: ML20195H980 (4) | |
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4 UNITED STATES g
j NUCLEAR REGULATORY COMMISSION I
g WASHINGTON, D.C. 20086-0001
$9.....,o SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION PROPOSED REVISIONS TO EMERGENCY PLAN WOLF CREEK NUCLEAR OPERATING CORPORATION WOLF CREEK GENERATING STATION DOCKET NO. 50-482
1.0 INTRODUCTION
By letter dated kugust 6,1997, as supplemented by letters dated January 27 and March 19, 1998, Wolf Creek Nuclear Operating Corporation (WCNOC) submitted proposed changes to the Wolf Creek Generating Station Radiclogical Emergepcy Response Plan (RERP). By letter dated September 18,1998, WCNOC proposed changes to the RERP that replaced the previous submittals in their entirety. The changes in the September 18,1998, submittal were evaluated by WCNOC under 10 CFR 50.54(q) and WCNOC determined that the changes required prior NRC approval. Specifically, WCNOC requested approval to change the activation time for the Technical Support Center (TSC) during off-hours to 75 minutes; change the specific positions required to activate the TSC; eliminate the Emergency Planner position at the TSC; and change exercise frequencies to reflect revisions to the regulations.
2.0 EVALUATION TSC Off-Normal Hours Activation Time WCNOC proposes to increase the off-normal working hours activation time for the TSC from the current time of 60 minutes to a goal of 75 minutes following the declaration of an Alert or higher classification (Section 6.6.1.1, Wolf Creek Generating Station (WCGS) RERP). (It is the staffs understanding that the term " activation" as used by the licensee means " fully operational,"
as used in Supplement 1 to NUREG-0737.) WCNOC would retain the normal working hours TSC activation time goal of 30 minutes following the declaration of an Alert or higher classification (Section 6.6.1.2, WCGS RERP). The licensee justifies increasing the off-normal TSC activation time goal by (1) the increase in the operations staff (personnel who would be on l
shift for emergencies); (2) the remote location of the plant; and (3) the offset of this increase by the licensee's ability to distribute the emergency response organization responsibilities to include the large population of employees that live in more heavily populated areas outside the current living radius for activation in 60 minutes.
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i l WCNOC indicates that the nttmber of operations personnel on-shift has been increased above a normal operating crew by two to three people. Included is the addition of the Shift Engineer position, which has relieved the Shift Supervisor of some tasks required to be performed during an event. The addition of other personnel in the control room to perform certain tasks improves
. the ability of the Shift Supervisor and control room staff to retain overall command and control 1
l of the event while the TSC completes the activation proce'ss. In addition, the licensee states that the control room personnel ha ve the ability to augment the staff at any time or emergency I
f classification level as described in the RERP. The increase in both number and types, as specified by the licensee, of control room staff would provide the NRC confidence that the 15 i
minute delay time in activating the TSC during off-normal working hours would be compensated j
for by these personnel.
In addition, the WCGS is remotely sited in Coffey County, Kansas, approximately 90 miles southwest of Kansas City, Missouri and approximately 55 miles south of Topeka, Kansas. The j
plume exposure pathway emergency planning zone (EPZ) population is approximately 5,885 i
persons. The population within 2 miles of the facility, the area where prompt protective actions would need to be taken, is approximately 75 persons. The licensee indicates that there are approximately 3,560 persons within 2 to 5 miles of the facility and approximately 2,250 persons within 5 to 10 miles of the facility. Consequently, the remote siting of the plant and the i
corresponding low population density, especially within 2 miles of the plant where prompt actions could be taken based initially' on plant conditions without TSC input, provides additional confidence that the TSC off-normal working time goal could be extended 15 minutes.
The licensee also states that since the plant was licensed, many employees now reside in more heavily populated towns such as Topeka, Emporia, Ottawa and Burlington located approximately 60,41,44, and 10 miles, respectively, from the site. Consequently, the licensee has not been able to fill emergency response organization positions during drills and exercises needed to activate the TSC during off-normal hours and meet a TSC activation goal of 60 minutes. The licensee indicates this delay of about 15 minutes is partially attributable to the driving time between WCGS and these heavily populated towns. To compensate for the delay, the licensee, as discussed above, added additional personnel to its operating staff. The licensee states that by extending the TSC off-normal working hours activation goal, the licensee will have a broader base from which to obtain emergency response personnel to fil! those positions needed to activate the TSC in 75 minutes. This would provide greater assurance that the TSC would be staffed by sufficient technical engineering and senior designed licensee officials to provide needed support and be fully operational within 75 minutes as opposed to not having these personnel in trying to meet a 60 minute goal.
l Increasing the TSC activation time goal during off-normal hours from 60 to 75 minutes is l
acceptable because of the increased number of on shift staff; the remote siting and low population density in the Wolf Creek plume exposure pathway EPZ; and by the offset of the i
increased off-normal working hours activation time by expanding the emergency response base to obtain appropriate personnel to fill positions necessary to activate the TSC in 75 minutes.
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. Positions Reauired to Activate the TSC The licensee indicates that the TSC is consid,ered activated when five specific position holders accomplish their activation steps, report their readiness to the Duty Emergency Director (DED),
and subsequently, the DED declaring the facility activated. These five positions are listed in Section 6.6.2 of Rev. O of the WCGS RERP, The licensee states that completion of the TSC activation should be based on the ability of the TSC and its staff to perform the intended functions for a given event. As such, activation should be based on the personnel and activities necessary to be carried out by the facility in responding to a given event. The function of the TSC is to provide control of the emergency and thus remove this burden from the control room. Activation of the TSC should occur when these capabilities are met without waiting for the arrival of other TSC personnel. Augmentatica may occur at any time or emergency classification level, since the activities performed by the augmented staff are separate and event specific.
Supplement 1 to NUREG-0737 states, in part, that the TSC is to be " Staffed by sufficient I
technical, engineering, and senior designated licensee officials to provide needed support, and be fully operational within approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after activation." With the proposed change,,
activation of the TSC will be based on the capability of the TSC to perform its intended functions. NUREG-0696, " Functional Criteria for Emergency Response Functions," states "The licensee-designated TSC staff shall consist of sufficient technical, engineering, and senior l
designated licensee officials to provide the needed support to the control room during emergency conditions.". The licensee intends to prescribe in the WCGS RERP that (1) the Duty Emergency Director, Operations Emergency Coordinator, Radiological Emergency Coordinator, Maintenance Emergency Coordinator, and Administrative Emergency Coordinator, which constitute senior designated licensee officials, are required for TSC activation, and (2) the director and each coordinator assure emergency response personnel identified in Table 1.1-1 if j
the RERP that are needed to respond to a given event in their area (s) of responsibility are i
present and ready to carry out their duties prior to TSC activation.
l As a part of this change, the licensee removed both the ""*" and "**"" footnotes from Attachment D,"WCGS Minimum Staffing for Emergencies." These footnotes had. indicated that the times for capability of additional emergency staff commenced at the " Alert or l
greater classification" or " Site Area emergency or greater classification," respectively. This linked the capability for additions to emergency response facility (ERF) activation time goals.
The times given for capability for additions in Table B-1, NUREG-0654 are for any emergency '
and not linked to a specific classification. The ERF activation time goals are linked to a specific classification and these goals are provided in NUREG-0696 and Supplement 1 of l
Based on the above, the staff has determined that the proposed change to revise the specific positions required to activate the TSC did not decrease the effectiveness of the plan and the plan, as changed, continues to meet the planning standards of 50.47(b) and the requirements of Appendix E to 10 CFR Part 50. Therefore, this change is acceptable, i
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. Elimination of Emeroencv Planner Position at the TSC WCNOC proposes to eliminate the Emergency Planner position in the TSC. The licensee states that the Emergency Planner position is a WCGS specific position added in 1994 as an organizational enhancement due to drill performance concems. The position was intended to be an "in-facility" consultant to address emergency planning questions, double check to ensure task completion, monitor various functions to ensure completion, and lend assistance as requested or directed.
As part of its justification for this change, the licensee provided a table which showed the functions of the Emergency Planner and the Actual Responsible Position (s) assigned these functions. Additionally, the licensee states that recent training, drills and exercises indicate that TSC position holders no longer need the "in house" consultant to assist and remind them of their duties. Further, the licensee indicated that training for ERO positions has increased from 6-8 hours per person per year to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per person per year.
Since the licensee has increased the training of ERO position holders and has shown where position functions are assigned within the TSC, there is no decrease in the effectiveness of the plan and the plan, as changed, continues to meet the planning standards of 10 CFR 50.47(b),
and the requirements of Appendix E to 10 CFR Part 50. Therefore, this change is acceptable.
Exercise Freauencv WCNOC proposes to change the frequency of the on-site and off-site emergency plan exercises from annually to biennially and the frequency by which exercises are varied so as to test all the major components of the WCGS, State, and County plans and response organizations from every five years to every six years. The changes in frequencies are in accordance with changes to 10 CFR Part 50, Appendix E, Part F. The licensee has indicated that to ensure that adequate emergency response capabilities are mair:lained during the interval between biennial exercises, each emergency response team at the site participates in an emergency drill every year. The commitment to implement the emergency drill program is discussed in a letter to the NRC dated February 4,1994.
The staff has determined that the proposed changes do not decrease the effectiveness of the plan and the plan, as changed, continues to meet the planning standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50. Therefore, these changes are acceptable.
Principal Contributors: E. Fox, Jr.
K. Thomas Date: November 17, 1998 i
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