ML18153B794

Forwards Proposed Revs to Plant Emergency Plan for NRC Approval.Proposed Revs Meet Intent of NUREG-0737,Suppl 1 Re Min Staffing Requirements for Emergencies.Justification for Proposed Revs Also Encl

ML18153B794
Person / Time
Site:	Surry
Issue date:	06/30/1989
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-NUREG-0654, RTR-NUREG-0737, RTR-NUREG-654, RTR-NUREG-737 89-341, NUDOCS 8907070148
Download: ML18153B794 (10)

Text

e e VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 June 30, 1989 United States Nuclear Regulatory Commission Serial No.89-341 Attention: Document Control Desk SPS:vlh R2 Washington, D. C. 20555 Docket Nos. 50-280 50-281 License Nos. DPR-32 DPR-37 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 PROPOSED EMERGENCY PLAN REVISIONS Pursuant to the requirement of 10 CFR 50.54(q), the Virginia Electric and Power Company requests approval of revisions to the Surry Emergency Plan. The revisions to Table 5.1 address the minimum staffing requirements for emergencies. The proposed revisions are provided in Attachment 1. Attachment 2 provides the justification for the proposed revisions. These changes will be implemented upon NRC approval.

We have considered the guidance of NUREG-0654 and NUREG-0737, Supplement 1 and feel that the proposed revisions meet the intent of NUREG-0737, Supplement 1 which states that staffing levels listed therein are goals and not strict requirements and that the augmentation response times of emergency response personnel are only approximate. Therefore, we believe that the overall effectiveness of the Plan is not decreased.

If you have any questions, please contact us.

Very truly yours, L. Stewart enior Vice President - Power Attachments cc: U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N. W.

Suite 2900 Atlanta, Georgia 30323 Mr. W. E. Holland NRC Senior Resident Inspector Surry Power Station

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ATTACHMENT 1 PROPOSED REVISIONS TO THE SURRY EMERGENCY PLAN

MINIMUM STAFFING REQUIREMENTS FOR EMERGENCIES TABLE 5.1 Additional Required Emergency Title On WitFiin Aeprox.

Major Functional Area Location Major Tasks Exeertise Shlft 60 Minutes Plant Operations and CR Supervision of Station Shift Supervisor - 1 Assessment of Operation- Operations &Assessment (SRO) al Aspects of Operational Aspects CR Plant Operations Asst. Shift Supv.

(SRO) l*

Control Room Operator (CRO) 3*

Control Room Operator 4 (Unlicensed)

CR Engineering Support STA 1*

of Operations Emergency Direction and CR/TSC Direction & Control of Station Emergency 1##

Contra 1 On Site Emergency Manager Activities Notifications and CR/TSC Notify Off Site Emergency Communicator 2# 2 Communications Support Groups and Maintain Communications Radiological Accident HP OFC/ Off Site Dose Radiological Assessment 1 Assessment &Support CR/TSC Assessment Director of Operational Accident Assessment

MINIMUM STAFFING REQUIREMENTS FOR EMERGENCIES TABLE 5.1 (Continued)

Additional Reguired Emergency Title On Witfiin Aeerox.

Major Functional Area Location Major Tasks Exeertise SliTft 60 Minutes Off Site On Site Off Site Surveys On Site (Out of Off Site Monitoring Team On Site Monitoring Team 4

2 Plant) Surveys In-Plant In-Plant Surveys & In-Plant Monitoring Team 2 2 Radiochemistry In-Plant In-Plant Chemistry Chemistry Team 1 2 Plant System Engr. Repair CR/TSC Technical Support - Technical Support Team/ 1# 1

&Corrective Actions Operations Operations/Shift Technical Advisor TSC Core &Thermal Technical Support Team/ 1# 1 Hydraulics Core/Thermal Hydraulics TSC Electrical Technical Support Team/ 1 Electrical Engineering TSC Mechanical Technical Support Team/ 1 Mechanical Engineering osc Repair & Corrective Damage Control Team/ l** 2 Action Mechanical Maintenance

MINIMUM STAFFING REQUIREMENTS FOR EMERGENCIES TABLE 5.1 (Continued)

Additional Reguired Emergency Title On Witfiin Aeprox.

Major Functional Area Location Major Tasks Expertise Smft 60 Minutes osc Repair and Corrective Damage Control Team/ l** 2 e

Action Electrical Maintenance osc Repair and Corrective Damage Control Team/ 2 Action I and C CR/OSC Repair and Corrective Damage Control Team/ 1 Action Rad Waste Operations In-Plant Radiation Protection Rad Protection Supv. 2# 4

- Access Control & In-Plant Support

- HP Coverage Team

- Personnel Monitoring

- Dosimetry Firefighting In-Plant Firefighting Fire Team Members 5# Plus Local Support e Rescue Operations & In-Plant First Aid First Aid Team Member 2# Plus First Aid*** Local Support Site Access Control & In-Plant Security/Access Security Team Members (Safeguards Information)

Personnel Accountability Control/Accountability

MINIMUM STAFFING REQUIREMENTS FOR EMERGENCIES TABLE 5.1 (Continued)

• The minimum staffing requirements are governed by Technical Specification Table 6.1-1. The numbers shown are applicable only when at least one unit is operating.

• • Mechanical and Electrical Maintenance coverage will normally be provided on a two shift per day, seven days per week basis.

• • • Rescue operations are the responsibility of the Search and Rescue Team which is composed of Fire Team and First Aid Team members.

1. This coverage is initially provided by personnel assigned other functions and will be assumed by other personnel when they arrive on site.

1. 1. The Shift Supervisor or Assistant Shift Supervisor assumes the responsibilities of the Station Emergency Manager.

ATTACHMENT 2 JUSTIFICATION FOR THE PROPOSED REVISIONS TO THE SURRY EMERGENCY PLAN

Discussion NRC Inspection Report Nos. 50-280/88-22 and 50-281/88-22, dated July 22, 1988, discussed an unannounced Surry Power Station Emergency Response Personnel Callout Exercise which was conducted on June 22, 1988. The following Inspector Follow-up Item (50-280, 281/88-22-03) was included in the report: "Demonstrate that augmentation personnel identified in Table 5.1 can be made available in the specified time by conducting periodic unannounced notification drills." Such drills have been conducted at least once each calendar quarter since that time. Surveillance Test Procedure 56, "Emergency Plan Augmentation Callout Drill," was written to institutionalize the performance of these drills. The results of callouts, including the off-hours emergency exercises conducted on November 1, 1988, and February 16, 1989, revealed that augmentation times listed in the plan may not be achievable in some cases. A similar situation was documented for the North Anna Power Station, which has similar augmentation commitments, in NRG Inspection Report Nos. 50-338/88-24 and 50-339/88-24, dated September 26, 1988. A request was submitted on November 30, 1988, pursuant to the requirements of 10 CFR 50.54(q) to revise that portion of the North Anna Emergency Plan. Similar action was planned for Surry, but held in abeyance pending NRC consideration of the North Anna request.

NRC Inspection Report Nos. 50-280/89-09 and 50-281/89-09, dated May 12, 1989, included a Notice of Violation for failure to meet augmentation staffing requirements. In our response to the Notice of Violation (Serial No.89-369 dated June 12, 1989), we committed to submit a revision to Table 5.1. The proposed revision to Surry's Emergency Plan, although consistent with the North Anna submittal, is being submitted at this time, independent of the status of the North Anna submittal review.

The proposed revision will require designated emergency response personnel to be augmented within approximately one hour for the Technical Support Center (TSC) in the event of an emergency. The proposed Table 5.1 provides the minimum staffing required for the Control Room, Operational Support Center, TSC and other in-plant support.

Justification For Emergency Plan Revisions An evaluation of the functions performed by emergency response personnel is provided below to demonstrate that required assessments and protective actions would not be diminished by the proposed change to the augmentation response times of selected emergency response personnel. These changes do not degrade our ability to take the immediate actions that are necessary in the event of an emergency.

The augmentation response times should be coordinated with the arrival times of the management support teams that will be functioning in the TSC. In addition, credit should be taken for the continuous staffing normally required to operate the station.

Table 5.1 of the Surry Emergency Plan was implemented per the guidance of NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, and provides the minimum staffing requirements to support the operation of the TSC in the event of an emergency. NUREG-0737, Supplement 1, Clarification of TMI Action Plan Requirements, provides guidance that the TSC be " ... fully operational within approximately one hour after activation."

e In most cases, augmentation times can be revised based on the function of the position relative to activation of the emergency response facility. Another consideration is whether there is already adequate on-shift coverage for positions required for emergency response activities. The following information takes these considerations into account to support each of the proposed revisions.

a. The Station Emergency Manager position is initially assumed by the Shift Supervisor or Assistant Shift Supervisor in the event of an emergency. The Shift Supervisor is fully qualified to perform the functions of the Station Emergency Manager. The Station Manager or a designated alternate will be contacted to relieve the Shift Supervisor by assuming the Station Emergency Manager position. A note has been added to Table 5.1 to specify that the Shift Supervisor or Assistant Shift Supervisor initially assumes the responsibilities of the Station Emergency Manager. These revisions are consistent with the guidance provided in NUREG-0654 and do not represent a reduction in the effectiveness of the plan.

b. The Radiological Assessment Director position is initially and immediately assumed in the event of an emergency by the senior Health Physics representative on site. The position of the Radiological Assessment Director will be filled following callout, but the position is not a required augmented emergency response position because on-shift personnel are fully qualified to perform this function. The Radiological Assessment Coordinator function should be deleted from Table 5.1 because that individual's function is not required to activate the TSC but is associated with the activation of the LEOF. The Radiological Assessment Coordinator provides the coordination of radiological and environmental assessment between the TSC and LEOF. The Radiological Assessment Coordinator function is already established in Table 5.2; therefore, its deletion from Table 5.1 does not represent a reduction in the effectiveness of the Plan.

c. The Recovery Manager position is not required to activate the TSC, but is assumed with the activation of the LEOF. The Station Emergency Manager implements offsite emergency measures .prior to transition of these functions to the Recovery Manager when the LEOF is activated. Accordingly, the Recovery Manager function should be deleted from Table 5.1. The Recovery Manager function is established in Table 5.2. This revision does not represent a reduction in the effectiveness of the Plan in that the Station Emergency Manager maintains responsibility for certain offsite emergency measures until LEOF activation.

d. The Core and Thermal Hydraulic Technical Support Team Member position will have an augmentation response time of approximately 60 minutes consistent with activation of the TSC. Any initial analysis that would be performed by this individual can also be performed by the Shift Technical Advisor (STA) until relieved by augmentation emergency response personnel. This revision does not represent a reduction in the effectiveness of the Plan.

e. The Damage Control Team Members will have an augmentation response time of 60 minutes to be consistent with the activation of the TSC. Damage Control Team personnel are not immediately needed in the event of an emergency because unit stabilization is required prior to the Damage Control Team's performance of their function. Damage control activities are performed by on-shift personnel prior to augmentation. An electrical and mechanical maintenance

maintenance crew currently provides on site coverage for a minimum of two shifts per day. In addition, the notation that a person assigned collateral duties can perform the Rad Waste Operations function is not required by NUREG-0654 and has been deleted. Operations personnel routinely perform Rad Waste Operations and any major evolution will be coordinated by the TSC. These revisions do not represent a reduction in the effectiveness of the Plan.

f. Firefighting, rescue operations and first aid augmentation is being revised to refer to local support consistent with NUREG-0654 Table 8-1 guidance. On shift personnel will continue to be available although they may be assigned other duties unless called upon to respond during a fire, first aid, or search and rescue emergency. These revisions do not represent a reduction in the effectiveness of the Plan.

Additional revisions have been made in the format of the table and are meant to provide clarity. Specifically, the emergency titles have been revised to reflect the groups under generic titles for a team instead of team leaders and team members. These title changes have not changed the composition of the teams. Other changes have been made in Major Functional Areas and Major Tasks that clarify functions and tasks performed by each group. There are revisions to the notes at the end of Table 5.1. The note for the Mechanical and Electrical Maintenance coverage has been revised to reflect personnel on two shifts per day versus a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> per day commitment.