ML20205K819

Submits Response to RAI Re Util 981015 Submittal for NRC Review & Approval of Changes to Emergency Plan,Per NRC 990324 & 0401 Requests

ML20205K819
Person / Time
Site:	Comanche Peak
Issue date:	04/07/1999
From:	Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20205K822	List: ML20205K819
References
TXX-99087, NUDOCS 9904140022
Download: ML20205K819 (8)

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Log # TXX-99087 File # 10013 Ref. # 10CFR50.54q nlELECTRIC April 7,1999 C. lance'thavy Senior Mce President

& PrincipalNuclear Officer U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION CHANGES TO CPSES EMERGENCY PLAN REF: (1) TU Electric letter logged TXX-98207 from C. L. Terry to the NRC dated October 15,1998 (2) Telephone conversations on March 24 and April 1,1999, between TU Electric representatives and Messrs. Tim. L. Polich, David H. Jaffe and Ed Fox of NRR Gentlemen:

- The purpose of this letter is to respond to a NRR staff request for additional information concerning TU Electric's October 1998 submittal for NRC review and approval of changes to the CPSES Emergency Plan (Reference 1). The request for additional information was discussed in telephone communications between TU Electric and the NRR staff as documented above (Reference 2).

The attachments to this letter provide the additional information in the form of revised change descriptions and/or justifications (Attachment 1) and supplemental plan changes  ;

(Attachment 2). ' As discussed in the referenced telephone communications, the enclosed l informatioil is intended to support, modify and/or clarify those changes previously requested in TU Electric's letter TXX-98207. ,

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9904140022 990407 PDR ADOCK 05000445 F PDR _

COMANCllE PEAK SILAM E1.ECTRIC STATION P.O. Box 1002 Glen Rose, Texas 76043-1002

r-TXX-99087 Page 2'oT 2 If there are any questions concerning this information, please contact Mr. Norman Hood, Emergency Planning Manager, at (254) 897-5889.

This communication contains no new licensing basis commitments regarding CPSES Units 1 and ?.

l Sincerely, C. L Terry By:

D. R. Woodlan l Docket Licensing Manager l CLW/grj Attachments l

c- Mr. E. W. Merschoff, Region IV Mr. J. l. Tapia, Region IV (clo)

Ms. G. M. Good, Region IV Resident inspectors, CPSES (clo)

Mr. D. H. Jaffe, NRR l

Mr. E. Fox, NRR 1

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Attachment 1 to TXX-99087 Page'1 of'6 DESCRIPTION AND JUSTIFICATION OF PROPOSED CHANGES TO THE CPSES EMERGENCY PLAN NOTE: The additional information provided in this attachment is annotated by bold print, strikeovers and change bars on the original description and justifications of proposed changes as submitted with letter TXX-98207 on Octouer 15, 1998. Only those original plan changes that were of concern to l the NRR reviewer and were discussed on March 24 and April 1. 1999, are further addressed in this attachment.

P. 1 2. Section 1.1.2 " Response" Change

Description:

Add a sentence that the Shift Manager (Emergnecy Coordinator) has the

authority to call in any portion of the augmentation staff specified in Table 1.1 as may be required for emergency response (see supplemental plan change in Attachment 2).

Justification:

This statement clarifies that the Shift Manager has the standing general authority to call in any needed augmentation staff resources that may be required at the first signs of an emergency (i.e., prior to an Alert classification when onshift augmentation is " automatically required" via the staffing requirements of Table 1.1).

P. 1-10. Section 1.2.2 " Local Services Support" Change

Description:

Delete the sentence "The following organizations are the local support groups which have agreed to provide services if requested:" and the six (6) organizations immediately following in bullets. Revise the preceding i

sentence which refers to letters of agreements in Section 15.0. Appendix H.

to add the words "which identifies the local services support crganizations" l Justification:

t 1 This information is identified for deletion because it is redundant to information provided in Appendix H. Section 1.2.2 continues to state that letters of agreements are maintained with each local services support agency. Section 1.2.2 is also clarified to identify these local agencies by I reference to Appendix H which provides a list of the letters of agreement  !

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a Attachment 1 to TXX-99087 Page 2 of'6 l maintained and includes those local support agencies being deleted from l Section 1.2;2. In addition. Section 15.0, Appendix H " Letters of Agreement"  ;

is revised to add general functional statements of the support provided by each listed agency or organization (See supplemental plan change in Attachment 2).

Table 1.1 " Staffing Requirements For Emergencies" )

Change Descriptions:

! 1. Revise the task of providing technical support to the onshift STA by changing the " additions within minutes of Alert" column requirements to delete the Engineer responding at 40-minutes and add one additional member to the TSC Engineering Team responding at 70-minutes. This change effectivelv moves this technical support from a 40-minute response to a 70- ,

minute response. '

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2. Revise footnote annotations of (*) and (**) to (a) and (b). respectively.

3. Add footnote (c) as applicable to the onshift minimum staffing column. This footnote allows. upon exercising certain compensating actions. a temporary exception to the onshift minimum staffing requirements due to unforseen circumstances (e.g. . personal illness).

4. Rey;"9 The tcMa entry under 0NSHIFT for the functional area of Com unications to change "I&C Technician" to " Communicator".

Justifications:

1. This change is related to one aspect of guidance found in NUREG-0654/ FEMA-REP-1 (Rev.1). Table B-1 " Minimum Staffing Requirements for NRC Licensees for Nuclear Power Plant Emergencies", which recommends that the onshift STA position be supported within about 30-minutes with one additional individual who can provide technical support in the area of core / thermal hydraulics.  ;

The CPSES Emergency Plan is currently approved for a 40-minute support j response.

The justification for allowing the change to a 70-minute responder (support would come via the TSC Engineering Team) is based on the following:

i a) The current understanding of the development and timing of reactor core degradation / melting during a postulated severe accident is documented in NUREG-1465 " Accident Source Terms for Light-Water Nuclear Power Plants" i published in 1994. NUREG-1465 information postulates that significant core l

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Attachment 1 to TXX-99087 Page3ofi j degradation / melting first occurs at longer times post-accident than previously believed (i.e. as postulated in the reactor safety study of WASH-1400, published in 13/5, which is one basis for NUREG-0654. Table B-1 response timing). NUREG-1465 contends that, for PWRs. during the first 30-minutes only a small fraction of the core inventory of radionuclides could be released into containment, and the onset of significant fuel damage occurs at over an hour post-accident. This more current understanding of the timing sequence for PWR post-accident core damage (i.e., damage occurs after a longer time period po:t-accident that previously believed) acts to l increase the creditable planning basis for the time from the initiating event to start of atmospheric release and therefore reduces the immediacy for providing augmented technical support. Additionally. it is recogr.ized l that information for quantifying fuel damage would not be required, or l available, until some time after the TSC is expected to be activated. For l example. NUREG-0737. Supp. 1. recognizes that determicing the level of fuel damage requires chemistry data / analysis and provides the expectation that j this sampling / analysis be completed within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> from the decision to do j l

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l b) The CPSES TSC Engineering Team (which would be increased from 3 to 4 members and assume this responsibility) would have sufficient personnel j resources to take on this technical support and " staffed / activated in a time frame (within 70 minutes of Alert) adequate to meet the required support needs (see item above). Additionally, the description of the TSC Engineering Team in Section 1.1.2.2 "CPSES Emergency Response Organization (ER0)" is revised to reflect four (4) augmenting technical support engineers, state that the TSC is located in close proximity to the Control Room (less than one minute transit time), and that contact is made with the Control Room, staff for providing assistance and if necessary or requested, that an engineer (s) can promptly relocate to the Control Room (See supplemental plan change in Attachment 2). The current Section 1.1.2.2 description of the TSC Engineering Team specifies the technical support available to the Control Room. This support includes " engineering data analysis ircluding core thermal hydraulics".

c) The recent development and availability of the CPSES Emergency Response Guidelines and Severe Accident Management Guidelines enhance the resources immediately available to the onshift operating crew and serve to make the initial response to a severe accident situatMn more manageable. The availability of these guidelines reduces the level and/or immediacy of augmentation support that may be required from the STA.

d) Since NUREG-0654 was issued in Novem a r. 1980, the accident assessment capabilities of nuclear power plants (ir:luding that for CPSES in the area of core / thermal hydraulic evaluation) have been greatly enhanced by the installation and application of new sy.. ems / equipment such as the Safety

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Attachment 1 to TXX-99087 Page' 4 of' 6 Parameter Display System (SPDS) anc the Radiation Monitoring System (PC-11 at CPSES). Parameters such as core exit thermocouple temperature, reactor vessel water level, containment radiation level, etc., are easily monitored and trended using these systems. These systems are readily available to assist Control Room staff in the early stages of an accident and were not accounted for in minimum staffing considerations of NUREG-0654. Table B-1.

2. This change enhances table readability and reduces the potential for misinterpretation.

3. This footnote addition allows a temporary exception to minimum staffing that is consistent with similar provisions allowed for the onsbift crew in the CPSES Technical Specifications and FSAR. Proposed footnote @ is intended to be used by the onshift staff, especially during backshift or weekends, in response to certain situations such as sudden illness, family emergency, or in the case of the CPSES pre-identified onshift medical responders (i.e. ,

Chemistry Technicians). to allow care for, or transport of, injureu plant personnel to the hospital. Similar temporary staffing exceptions are already allowed by eithe- the CPSES Technical Specification Administrative Controls (6.2.2), FSAR (Table 13.1 2) or the regulations of 10 CFR 50.54(m)(2)(I) note 1 for the minimum staffing of onshift Radiation Protection Technicians, Chemistry Technicians, Fire Brigade members or licensed operators.

1 These temporary exception criteria are recognized precedences with the NRC for allowing short time absence from required minimum onshift staffing to accommodate unforseen situations (e.g., unexpected individual sickness, accident. etc.). The short exception period proposed (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) and the i related compensatory measures (replacement call-in), coupled with the very small chance of an exception being exercised coincident with a declared i emergency event, make this change reasonable for ANY onshift position when I weighed against the benefit to an affected individual and the rather onerous logistics that would otherwise be required to meet 24-hours-a-day minimum staffing. It is inconsistent with the established precedences to not be able to apply some form of tem [arary exception criteria. It is also not practical or reasonable to add several additional personnel to the prescribed minimum staffing complement just to cover the remote chance that an individual will have to leave the site via a subject absence.

As an example in support of this discussion, a recent CPSES off-hours event occurred in which one of the two required onshift Radiation Protection Technicians had a family emeigency and left the site aft. ' getting supervision concurrence and promptly calling for a replacement Radiation Protection Technician. In this event the position was vacant for about 1

, hour (consistent with Operations procedures and the TS allowance) but was a literal noncompliance with the CPSES Emergency Plan's Table 1.1 minimum j staffing requirements. '

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Attachment 1 to TXX-99087 Page'5 of'6 The footnote limits the subject temporary exception criteria for use only during normal operations and specifically states that it is not applicable during declared emergencies.

4. This change is for clarification as the onshift I&C Technician becomes the dedicated communicator during an emergency (see supplemental plan change in Attachment 2).

P.12-2, Section 12.2.4 " Radiological Monitoring Drills" Change

Description:

Revise to provide consistency with other statements in the CPSES Emergency Plan and change the scope of monitoring activities to be performed in drills by CPSES personnel assigned to radiological monitoring teams.

Justification:

This change provides consistency with statements in CPSES Emergency Plan Sections 1.0 and 1.2.4 and clarifies that CPSES personnel assigned to radiological monitoring teams shall participate in annual drills for performance of air sampling / beta-gamma exposure rate determinations and should participate in drills to collect other environmental samples.

The proposed change takes partial exception to annual drills for sampling / analyzing some environmental sample media (NUREG-0654 criteria N.2.d) by implying that CPSES personnel are not required to-ccllect/mcnitor analyze media other than air (i .e., water vegetation and soil). -These-The environmental media of water, vegetation and soil are primarily a responsibility of State monitoring personnel. The State of Texas (Bureau of Radiation Control (BRC)) and CPSES have had discussions on this l responsib'lity and have agreed that the State has the lead for collecting / analyzing these sample media. If actcr. veg:.tation and 001' l CPSES personnel should only maintain an assistance capability in this area in order to assist. if necessary. State agencies duriv an Ingestion Pathway phase. This position is consistent with guiaance provided in NUREG-0654. Appendix 5 "Glosiary" which clarifies responsibilities that must be assigned among various organizations and states, in part: "Where the guidance in this document indicates a function that must be performed, emergency planners it all levels, must decide and agree among themselves, <

which organization is to perform such function."

Accordingly, as proposed in changes to Section 12.2.4, the plan states that CPSES personnel participate in drills to demonstrate the collection of water, vegetation, and soil. This is in addition to CPSES required annual

Attachment 1 to TXX-99087 l 1

Page 6 of6 drills for collecting and analyzing air samples and performing beta-gamma exposure rate determinations.

In Section 1.2.4 " State Agencies", the CPSES Emergency Plan currently states that the State of Texas (BRC) has the capability and responsibility to monitor and analyze environmentai samples. This is consistent with the agreement between CPSES and the BRC that the BRC has the primary ,

responsibility for collecting and analyzing the environmental media of water, vegetation and soil.

P. 0-4, Appendix 0 " Definitions" l

Change

Description:

I Add a definition titled " Periodic Definitions" that defines the terms

~ monthly", " quarterly".~ semi-annual or semi-annually", ~12 =ths", and I

" annual or annually" as used in the CPSES Emergency Plan.

Justification:

Change adds a definition of each frequency term used in describing events / tasks that are required to be performed on a regular periodic basis. ,

This change is added for clarification. The definitions added are specific '

to use in the CPSES Emergency Preparedness Program and are to be used in meeting timely implementation / maintenance of those periodic CPSES Emergency Plan requirements that are tracked and/or scheduled by the CPSES Emergency Planning or Nuclear Overview Department action item tracking systems. These definitions have been reviewed for consistency with guidance documents. The proposed definitior, of " annual" is consistent with information documented in NRC Inspection Report 50-445/446 95-21. Section 4.1.

The proposed periodic definition of "12 months" was withdrawn by TV Electric as discussed in the referenced telephone conversations (see suoplemental plan change in Attachment 2). It was concluded that the proposed TV Electric definition was inconsistent with the regulations and would probably require an exemption.

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