ML20049J212

Forwards Public Version of Response to NRC Second Round Questions Re Radiological Emergency Response Plan.Response Based on Evaluation of Each Specific Area & 820104 & 15 Discussions W/Nrc Emergency Appraisal Audit Team

ML20049J212
Person / Time
Site:	Fort Saint Vrain
Issue date:	02/26/1982
From:	Warembourg D PUBLIC SERVICE CO. OF COLORADO
To:	Clark R Office of Nuclear Reactor Regulation
Shared Package
ML20049J201	List: ML20049J212
References
P-82053, NUDOCS 8203120268
Download: ML20049J212 (15)

Text

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g c - Wl Y CdCIf5C 16305 WCR 19 1/2, Platteville, Colorado 50651-9293 February 26, 1932 Fort St. Vrain Unit #1 ~

P-32053 e 4

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/t RECEP/gn 3 Mr. Robert A. Clark, Chief f 'y'AR037SS2h Operating Reactors Branch #3 ar tsurst Q

Division of Licensing '

U. S. Nuclear Regulatory Cor:missicn Washington, D.C. 20555 6 h 8'

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SUBJECT:

Fort St. Vrain Unit No. 1 N Emergency Response Plan 0-2 Questions

REFERENCE:

NRC Letter Dated December 14, 1981 Cear Mr. Clark:

The above referenced letter forwarded the second round of cuestions on our Radiological Emergency Response Plan (RERP) in response to our letter P-30238, dated August 28, 1980.

We have reviewed these cuestions and have also discussed the questions witn the Nuclear Regulatory Commission Emergency Appraisal Audit Team during their on-site visit (Janua y 4, 1932, through January 15, 1982). ' Attachment A to this lette- represents our response to these questions. Our response is based on our evaluation of each specific area and is based on our discussions with the Emergency Appraisal Audit Team.

N 8203120268 820308 PDR ADOCK 05000267 F PDR

In those areas in which we have agreed to make revisions to our RERP these revisions will be completed in concert witn revisions tnat may be required as a result of the emergency appraisal audit, and our revised RERP will be forwarded to you under the provisions of ICCFR50 within thirty (30) days of completion of these revisions.

Very truly yours,

~ ?Y WY' Don W. Warembourg Manager, Nuclear Production Fort St. Vrain Nuclear Generating Station j

DWW/alk cc: Brian Grires G. Kuzymycz l

John Collins A_.A__aA. .

ATTACH).ENT A P-82053 PSC Response to NRC Second Round Questions Fort St. Vrain RERP B. Onsite Emergency Organization NRC Comment:

• The Plan's normal and augmented shift organization does not agree with Table B-1, of NUREG-0654 with regard to staff assigned to specific assignments and staff totals as well as the augmentation times.

• If the PSC position is that a Rad / Chem technician is not necessary on shift even with the reactor operating at 100%

design power, submit a justification for this position including a description of the qualifications and training of the personnel who would perform such functions in the immediate response in an accident.

• Until the response time of the shift Technical Advisor from 10 minutes to (1) hour letter (Themis Speis to J. Fuller, March, 1980) is resolved this will be carried as an open item.

PSC Response:

• The area of shift organi:ation with reference to Table 1 of NUREG 0654 was recently addressed in our letter P-81308 dated December 7, 1981, to Mr. Brian Grimes. It is our understanding that this letter has been reviewed and we can expect PRC response shortly. <

• The area of response time for Technical Advisors has been resolved.

Page 2 ATTACHMENT A P-32053 D. jmercency Classification System NRC Comment:

• The concept of Emergency Action Levels has the purpose of eliminating indecision on the part of shift personnel on whether or not to report an item. Consequently, the procedure 4

should be that when there are definite measurable or observable indications of a situation, action, such as reporting, should take place at once. The PSC agreement with the State states that it is anticipated that notification can be made within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of the initiating event. The NRC staff position is that 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is an unacceptable delay, since in 2 nours an unusual event could escalate to a general emergency.

Consequently the language in the FSV Emergency Plan should be 1

changed to agree with that in NUREG 0654, Appendix 1,

"Promptly notify state and/or local authorities of nature of unusual conditions as soon as discovered."

• The NRC staff position is that a written summary is required to forestall misinterpretations that may result from verbal only reports. It is also the NRC staff position that Emergency Action Levels should be defined in terms of specified instrument readings with definite parameter values

1. in line with NUREG 0654, I.1.

PSC Resconse:

• As we indicated in our response to the first round questions  ;

(see p-80288, Attachment A, Item 5), we established the two (2) hour time f*ame with the clock starting from initiating

event. The time frame was to allow time for immediate ,

l response to mitigate the consequences of the event, time to .

evaluate the event, and time to classify the event and declare an emergency level. This two (2) hours is compared to a fifteen (15) Our minute notification after declaration of an intent, of course, is to provide notification emergency.

j as soon as possible. To avoid having to renegotitate our

• agreement with the State, while at the same time trying to 4

meet the intent of NUREG 0654, we will add to our plan that we will notify the State within two (2) hours of the initiating event, but in any event, within fifteen (15) minutes of declaration of the emergency.

• We will revise our plan to indicate closecut of an incident by written report.

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Page 3 ATTACHMENT A P-82053 Unusual Event Item 2 NRC Comment:

• It is the NRC staff position that if the radiological effluent technical specification limits are exceeded, the incident should be treated as an Unusual Event and reported accordingly in order to insure that such releases are reported accurately _

without exaggeration of diminution.

PSC Resoonse:

• As discussed with the Nuclear Regulatory Commission Emergency Appraisal Team, Item 1 of Table 4.1-1 indicates that any unpisnned radiological release to the Reactor Building ventilation system will be classified as an unusual event. We believe this is a more conservative position than reporting against the Technical Specification limits. In addition, we are adding an adcitional initiating event to Table 4.1-1 which states that any liquid waste release resulting in offsite effluent in excess of Technical Specification limits will be classified as an Unusual Event.

Unusual Event Item 4 NRC Comnent: ,

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. the NRC staff position that abnormal coolant temperatures and/or abnormal fuel temperatures are indicators of unplanned operational transients, and as such should be c defined as Unusual Events.

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• We agree that abnormal coolant temperatures and/or abnorSal- -

fuel temperatures are indicators of . unplanned operational transients. Under the provisions of itbe" licensing doc ~umenti- ,

(Final Safety Analysis Report and- Technical Specifications), 1 1 ,.,

however, we are allowed time to correct these situations arid, s s if corrected within the prov,isions of. the. Technical ; s Specification LCO's, there is no consequen P t_o the health ,and safety of the public. In_this respect we did not want' to establish meaningless reporting requirements. -The core safety limits established by SL311, LC0; 471.7, :and -LCO 4.1:9 are so conservative that limits calling 1or corrective actich.willg ensure fuel particle integrity. Our primary concern of .', -

abnormal temperatures and fuel damage is addrested by 1 1 increases in circulating activity -which .is continuously ,

monitored by RT-9301, which is covered by an Initiating Event (see Item 2, Table 4.1-1).1 =We will, however, include the following initiating event'to Tabfe 4.1-1: Abnorraal coolant temperatures or core region temperature rises to the extent '

requiring shutdown-in accordance with Technical Specification , ,

N limits. This item will be addressed by the fol?%ing- EAL: e* . '.

Violations of LCO 4.1.7 "or LCO 4.1.9 for region outlet mismatch, or region _ AT,' bespectively, to the extent that '

shutdown per Station , Technical ' Specifications is required ,'

(SOP 12-04). ,

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• 'The NRC staff positi6n is that a fire which piant person'nel' [

cannot bring under control and extinguish within 10 minutes-has the potential for beceming uncontrolled and consequent,1y should be defined ..as an Unusual Event and treated.f in s accordance witn the guideline in NUREG s 0654, Appendix. 1.

pSC Response: , '

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We will revise this lhttiatiiig Ivent to7eflect th'at a fin , a 4 a

within the plant lasting longer than tdn (10) minutes will be y cause for Unusual. Event notification. , ," ;a '

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Page 5 ATTACHMENT A P-52053 Unusual Event Item 6 NRC Comment:

• The NRC staff position is that f ailure of a safety or relief valve in a safety related system -(not the domestic water system mentioned in PSC P-302SS) to close following reductit of applicable pressure should be defined as an Unusual Event.

PSC Response:

• As discussed with the Emerger.cy Appraisal Team we have no safety valves which have not been analyzed under the single failure criterion. On this basis we did not include failure of safety relief valves in Table 4.1-1. The only safety valve of serious consequence is the PCRV safety relief valve.

Failure of this valve is addressed as an initiating event under Item 3, Table 4.1-3, Site Emergency.

Unusual Event Item 7 NRC Comment:

• Loss of offsite pcwer or loss of AC power capability and Item 9, Loss of Engineered Safety Feature or Fire Protection System Function Shutdcwn by Technical Specifications, and Item 11, Indication or Alarms on Process Effluent Monitors Not Functional. The NRC staff position is that these items should be defined as Unusual Events since they have the potential for escalating to more serious events.

PSC Comment:

• Item 7 As we discussed with the Emergency Appraisal Team an EAL for loss of AC power has been established as an Alert EAL in Table 4,1-2, Item 7. This is a more conservative approach than an Unusual Event and on that basis appears to be acceptable.

Discussions with the Emergency Appraisal Team and FSV staff appears to have resulted in NRC acceptance of the PSC position on this item.

Page 6 ATTACHMENT A P-82053

• Item 9 PSC will address this item with the following initiating event item added to Table 4.1-1: Loss of Engineered Safety Feature or Fi re Protection System function to the extent reaufring Specifications.

shutdown in accordance with station Technical Associated witn this item will be the following EAL:

Shutdown required in accordance with app icable LCOs.

l a) Engineered Safety Features

1) Plant Ventilation - LCO 4.5.1

2) Steam / Water Oump System - LCO 4.3.3

3) PCRV panetrations flow restriction devices LCO 4.2.7 LCO 4.2.9

5) PCRV Safety Valves LCO 4.2.6 SL 3.2 LSSS 3.3.2.c b) Fire Protection System LC0 4.2.6 LCO 4.10.1-4.10.5

Page 7 ATTACHMENT A P-32053

• Item 11 PSC will address this item with the following initiating event item- added to Table 4.1-1: Indication or alarms on Radiological Effluent Monitors not functional. Associated with this item will be the following EAL:

Data Logger Alarn / Alarm Summary indication of non-operational alarm or indication on:

a) RT 7324-1 and RT 4803; or b) RT 7325-1, 2, RT 4802, and RT 73437-1; or, c) RT 73437-2 and RT 4801; or d) RT 6212 and RT 6213.

Unusual Esent Item 12 NRC Comment:

• Security threat or attempted entry or attempted sabotage. The NRC staff position is that such events have the potential for serious consequences and should be defined as Unusual Events.

PSC Resoonse:

• A compromise of our security system is included as Item 12 of Table 4.1-2. The purpose of indicating an " ongoing" security comarcmise is to differentiate between actual security problems as compared with false alarms. Under 10CFR73 we 1 report security related problems to Weld County authorities.

We believe this reporting requirement is more appropriate and therefore have not included additional reporting recuirements to the State unless such security problems represent an on going threat. In addition. item 4 of the FSV Significant

' Event reporting table addresses any threatened civil disturcance or threatened sabotage that results in initiation i

of the Security Contingency Plan and, as such, assures prompt notification to the NRC as well as to local authorities. We believe our reporting requirements and the existing EAL adequately adcress the intent of regulations both for NUREG

< 0654 and for 10CFR73.55.

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Page S ATTACHMENT A P-82053 Unusual Event Item 14e NRC Corment:

• Turbine rotating component failure causing rapid plant shutdown. The NRC staff position is that, while this event coes not have the potential for radioactive release, it is certainly a most unusual event and should be defined accordingly.

PSC Resconse:

• In our discussion with the Emergency Appraisal Team we were informed that, due to the particular orientation of the turbine and because we have no radiation on the secondary side of our plant, that it was not necessary to address this item as an Unusual Event. It should be noted that while we do not consider this item as an initiating event, the State would be informed under the provisions of our Agreement with the State for Public Information notification.

Alert Item 7 NRC Comment:

• Loss of offsite Power and Loss of all onsite AC Power. The NRC staff position is that this event has tne potential for substantial degradation of the level of safety of the plant since when the event happens, it cannot be predicted how long the outage would last. For FSV this item may be defined as an Unusual Event. If the outage lasts more than 30 minutes, an

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c Alert should be called.

PSC Resconse:

• EALs for.the alert category have been established as Item 5 of Table 4.1-2, Alert. We assume these EALs adequately address the comment.

Alert Item 3 NRC Comment:

• Loss of all onsite DC power. The NRC staff position is that such a loss at FSV should be defined as an Unusual Event, and if the outage lasts more than 30 minutes, an Alert should be called.

Page 9 ATTACHMENT A P-82053 PSC Comment:

• An EAL already exists as Item 6 of Table 2.1-2, Alert. We assume this EAL addresses the NRC comment.

Notification Methods and Procedures NRC Comment:

• The Plan does not indicate that an Early Warning Alerting System meeting the design objectives of Appendix 3 of the criterla has been developed. .

• The Plan should address the administrative and physical means, and the time required to promptly notify the public of an emergency. The Plan should commit to the establishment of such a system and indicate when the system will be implemented.

• The NRC staff position is that in the event of a serious incident, the general public should have as much lead time as possible to prepare to take protective measures and consequently a prompt early warning system is a requirement of 10CFR50, Appendix E.

PSC Response:

• In our letter to Brian Grimes, P-82006, dated January 8, 1932, we setforth plans for the early warning alert system. This system has been installed as planned, and is discussed in detail by letter, dated February 5,1982, (P-32031), from PSC 4 to the Regional Administrator, Region IV. We will revise our plan to incorporate the description of the system and the time required to activate it.

F. Emergency Ccmmunications NRC Comment:

• The Plan does not provide for communications between the l Forward Command Post and radiological monitoring teams.

Page 10 ATTACHMENT A P-32053

• It is the NRC staff position that the licensee is responsible for offsite radiological monitoring in the event of a release offsite in compliance with 100FR20. In this respect the FSV Emergency Plan should clarify the following:

Radiological monitoring teams are dispatched from the PCC (5.2.lb.3).

The FCP (EOF) functions as the control and coordination center for offsite emergency operations (5.4.la).

• It is also the NRC staff position that collection, review and analysis of all offsite radiological surveys should be coordinated at a single location, the EOF (NUREG 0654, H.12).

This point is not addressed in the FSV Emergency Plan.

PSC Response:

• As discussed with the Emergency Appraisal Team, our plan is-developed on the basis that our radiological monitoring teams are dispatched and controlled from the Personnel Control Center (PCC). The State's radiological teams are dispatched and controlled form the Forward Command Post (FCP).

• Field monitoring information for PSC teams is gathered at the PCC and transmitted to the FCP via the Technical Support Center (TSC). This information is compared with the State's radiological monitoring teams' findings at the FCP.

• Other than the NRC Emergency Appraisal Team finding that we must be prepared to cover offsite monitoring until appropriately relieved by the State, the team had no immediate problems with this type of operation. We will be revising our RERP to make provisions for offsite monitoring in response to the appraisal team finding. Based on our discussions we assume this revision will adequately acdress the matter.

G. Public Information NRC Comment:

• Section 8.1.1.d of the FSV Emergency Plan should be written to describe the yearly public informa tion program required by 10CFR50, Appendix E IVD 2. The yearly statistical sampling program in NUREG 0654, Appendix 33 should be described in detail.

Page 11 ATTACHMENT A P-32053 PSC Resconse:

• We have developed a complete set of public information procedures since our original submittal of the RERP. These procedures will be referenced in the RERP and will be submitted as a part of our next RERP update to the NRC. The Emergency Appraisal Team indicated that this would be acceptable in response to this item.

H. Emeroency Facilities and Ecuicment NRC Comment:

• The description of the Technical Support Center and of the Emergency Operations Facility at Fort Lupton in the FSV Emergency Plan and the December 19, 1980, letter, P-80472, should be revised and amplified in conformance with the guidance in NUREG 0696, February, 1981, to include the times to activate these centers.

Provisions of the Technical Support Center and the EOF that will not comply with NUREG 0696 should be identified and your proposed alternatives described and justified. Your submittal should include a letter of agreement from the appropriate authorities for your use of the Fort Lupton facility.

• FSV Emergency Plan at Section 7.3.2 does not describe the placement of radiological monitors that meet as a minimum, the NRC Radiological Assessment Branch (RAB) Technial Position for the Environmental Radiological Monitoring Program, i.e., a total of 40 TLD's in 2 rings around the reactor site (NUREG 0654 H6b).

PSC Response:

• We will revise our plan to describe the facilities as they presently exist. Our plans for meeting NUREG 0696 are contained in our submittal P-81178, dated June 30, 1931.

• Provisions of the Technical Support Center and FCP that will not comply with NUREG 0696 are contained in our letter F-81178. Following our last emergency drill in August, we were requested to submit our interim plans for using the Fort Lupton facility which we did via letter P-81229, dated September 14, 1981, to Mr. Karl Seyfrit. We received concurrence with these plans from Mr. John Collins in his letter dated October 8,1981.

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Page 12 ATTACHMENT A .

P-82053

• We presently have a Technical Specification change request, P-81001, to provide changes to our environmental monitoring.

This change will accomodate the NUREG 0654 program. We are presently in the process of negotiating with Colorado State University with regard to making provision for placing additional TLDs in accordance with the RAB Technical Position in advance of receiving our requested change to Technical ,

j Specification SR 5.9.1.

I. Accident Assessment NRC Comment:

• The iodine instrumentation capability described in Answer 23 in Attachment A to the FSC August 28, 1980, letter should be described in the FSV Emergency Plan. ,

• Answer 21 in Attachment A to the PSC August 28, 1980, letter properly points out that the PCRV is the containment vessel.

Please describe methods and techniques for determining the relationship between confinement building radiation monitors e readings and radioactive material available for release from the confinement building.

• The description in 7.3.la.1 of Meterological Monitors should be amplified to show conformance with the provisions of NUREG 0654, Appendix 2. There should be meteorological readouts for both the primary and the backup systems at the TSC, the EOF, and offsite NRC center, and to the State EOC. Please describe such provisions. <

PSC Resoonse:

• Our iodine instrumentation capability will be described. As a result of the Emergency Team Appraisal comments we are evaluating our iodine measuring capability and will be responding to the Emergency Team findings by March 1, 1982.

Page 13 ATTACHMENT A P-S2053

• We have no definite relationship between the confinement building radiation monitors and the PCRV containment primarily because the confinement building does not provide any significant containment. This relationship, however, is not

{ as important as it might appear in our case since we are establi-shing EALs based on potential releases, not actual releases taking place. On this basis we are utili:ing samples of primary coolant to determine the potential for the release which makes the radiation monitors in the confinement building somewhat insignificant as far as EALs are concerned.

• We presently do not have meteorological readouts in the FCP, an offsite NRC center, and the State ECC. Our provisions and schedules for meeting these requirements have been setforth in varicus correspondence, but will not be in place until the ERF's are upgraded to meet NUREG 0696 requirements as indicated in P-81178. It should be noted, however, that we have no plans to have meteorological data in direct readout forms at the State EOC and we are not certain what is meant by the NRC offsite center. Our meteorological information will be available in the Control Room, the FCP, and TSC. Since the State Health Department is operating out of the FCP we can see no need to have direct readout capability at the State EOC.

Information will be available to the State EOC via voice communication links with the FCP.

J. Protective Response NRC Comment:

• It is the NRC staff position that sufficient radioprotective drugs for thyroid protection should be stockpiled for onsite and offsite emergency workers. Please describe the location and amount of such stockpiling and the authority for administering the drugs for use.

pSC Resoonse:

• We have already stockpiled a supply of radio-thyroid protective drugs onsite to be administered by the authority of the Radiation Protection Manager. We will describe our thyroid protection program as a part of the revi sion to our plan.

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