ML15313A043
| ML15313A043 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 10/06/2015 |
| From: | Capristo A South Texas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NOC-AE-1 5003273 | |
| Download: ML15313A043 (36) | |
Text
Nuclear Operating Company South Texas Project Electric GeneratingStation P.O. Box 289 Wadsworth, Texas 77483 ,V V -
October 6, 2015 NOC-AE-1 5003273 10 CFR 50.90 File No. G25 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 License Amendment Request for Approval of a Revision to Staff Augmentation Times in the Sou'th Texas Proiect Electric Generating Station Emergency Plan In accordance with the provisions of 10 CFR 50.90, STP Nuclear Operating Company (STPNOC) hereby requests a license amendment for approval of a revision to revise the South Texas Project Electric Generating Station (STPEGS) Emergency Plan augmentation times. The proposed revision will change the staff augmentation times for ERO positions from 60 minutes and 75 minutes from time of notification to approximately 120 minutes from time of declaration.
Because the proposed change will lengthen the activation time of the STP Emergency Response Facilities (ERFs), this is considered a Reduction In Effectiveness (RIE). Therefore, in accordance with 10 CFR 50.54(q)(4), STPNOC requests NRC review and approval of the proposed Emergency Plan changes. Following implementation of the proposed changes, the Emergency Plan will continue to meet the requirements of 10 CFR 50.54(q)(2), 10 CFR 50 Appendix E, and the planning standards of 10 CFR 50.47(b). to this letter provides a safety evaluation demonstrating that no significant hazards will result from this change. Attachment 1 provides a marked-up version of the affected Emergency Plan Sections. Attachment 2 provides documentation on two critical staffing scenarios which support a revised augmentation time of approximately 120 minutes.
Additionally, STPNOC has communicated these proposed changes with the State of Texas and Matagorda County. These agencies concur with the proposed changes.
The STPNOC Plant Operations Review Committee (PORC) has reviewed and concurred with the proposed changes.
STPNOC requests a 180-day implementation period after the amendment is approved to accommodate required training and procedure changes.
In accordance with 10 CFR 50.91(b), STPNOC is notifying the State of Texas of this request for a license amendment by providing a copy of this letter and attachments.
There are no commitments in this letter. / .*-
STh: 34155529
NOC-AE-1 5003273 Page 2 of 3 If there are any questions regarding the proposed amendment, please contact Fred Puleo at (361) 972-8697 or me at (361) 972-7697.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on__________________" * '--
Date AId* Capristo Executive Vice President, Chief Administrative Officer fjp-mk
Enclosure:
Evaluation of the Proposed Changes Attachments:
- 1. South Texas Project Electric Generating Station Emergency Plan Revised Sections C and G
- 2. Staffing-Related Accident Scenarios
NOC-AE-1 5003273 Page 3 of 3 CC:
(paper copy)
(electronic copy)
Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Morgan, Lewis & Bockius LLP 1600 East Lamar Boulevard Steve Frantz, Esquire Arlington, TX 76011-4511 U.S. Nuclear Regulatory Commission Lisa M. Regner Lisa M. Regner Senior Project Manager U.S. Nuclear Regulatory Commission NRG South Texas LP One White Flint North (O8H04) John Ragan 11555 Rockville Pike Chris O'Hara Rockville, MD 20852 Jim von Suskil NRC Resident Inspector CPS Energy U. S. Nuclear Regulatory Commission Kevin Polio P. O. Box 289, Mail Code: MN116 Cris Eugster Wadsworth, TX 77483 L. D. Blaylock Cramn Caton & James, P.C.
Peter Nemeth City of Austin Cheryl Mele John Wester Texas Dept. of State Health Services Richard A. Ratliff Robert Free
NOC-AE-1 5003273 Page 1 of 18 ENCLOSURE STP NUCLEAR OPERATING COMPANY (STPNOC)
Evaluation of the Proposed Changes
Subject:
License Amendment Request for Approval of a Revision to Staff Augmentation Times in the South Texas Project Electric Generating Station (STPEGS)
Emergency Plan 1.0
SUMMARY
DESCRIPTION 2.0 DETAILED DESCRIPTION 2,1 Proposed Changes 2,2 Background (Emergency Response Organization Augmentation Time Revision) 3.0 TECHNICA*L EVALUATION 3,1 Emergency Response Organization Augmentation Time Revision 3,2 Radiation Protection 3,3 Field Monitoring Teams 3,4 Chemistry 3.5 Plant Operations/Repair and Corrective Actions 3.6 Engineering/Technical Support 3.7 Shift Manager 3.8 Communications 3.9 Fire Fighting/Rescue Operations and First Aid/Site Access Control and Personnel Accountability 3.10 Additional Staffing Commitments
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Determination 4.4 Conclusions
5.0 ENVIRONMENTAL CONSIDERATION
6.0 "REFERENCES
NOC-AE-1 5003273 Page 2 of 18 1.0
SUMMARY
DESCRIPTION STP Nuclear Operating Company (STPNOC) proposes revisions to the South Texas Project Electric Generating Station (STPEGS), Units 1 and 2, Emergency Plan. The proposed change would result in a revision in the staff augmentation times for Emergency Response Organization (ERO) positions from 60 minutes and 75 minutes from time of notification to approximately 120 minutes from time of declaration.
2.0 DETAILED DESCRIPTION 2.1 Proposed Changes The proposed ERO revision in augmentation time would change the Emergency Response Facilities (ERFs) activation time. Therefore, the change is considered a reduction in the Emergency Plan effectiveness as defined in 10 CFR 50.54(q)(1)(iv).
In accordance with 10 CFR 50.54(q)(4), changes to a licensee's Emergency Plan that are considered a Reduction in Effectiveness (RIE) of the plan may not be implemented without prior Nuclear Regulatory Commission (NRC) approval and are required to be submitted as a License Amendment Request (LAR) in accordance with 10 CFR 50.90.
Revising the ERO augmentation would allow an increase in time for ERO members to respond to their assigned ERF, thereby increasing the geographical range in which members may reside. The benefit of the larger residential range provides a larger pool of prospective ERO members. This larger pool increases the ability to have a greater defense in depth of station personnel available to continue to provide reasonable assurance to protect the health and safety of the public.
The table below lists the proposed changes to the STPEGS Emergency Plan:
Item EmergencyChneDsrpinom nt PlanChneDsrpinCmet Reference C.4 Revised first paragraph to This change revises ERO revise augmentation time of augmentation time to 120 on-shift staff by offsite ERO minutes from declaration from members to approximately the current requirement of 60 120 minutes from and 75 minutes from declaration, notification.
2 Table C-i The 6 th and 7 th columns are This change revises ERO combined into a single, augmentation time to 120 minutes column labeled "AVAILABLE from the current requirement of 60 120 MINUTES#". The and 75 minutes.
number of responders listed in each column is summed in the resulting single combined
_____column.
NOC-AE-1 5003273 Page 3 of 18 Itm Emergency ItmPlan Change Description Comments Reference 3G.2 Revised second paragraph to. This change revises ERO change 0S0 activation time augmentation time to 120 minutes from approximately one hour from declaration from the current after notification of an Alert to -requirement of one hour from approximately 120 minutes notification.
after declaration.
4G.3 Revised fifth paragraph to This change revises ERO change TSC activation time augmentation time to 120 minutes from approximately one hour from declaration from the current after notification of an Alert to requirement of one hour from approximately 120 minutes notification.
after declaration.
5G.4 Revised second paragraph to This change revises ERO change EOF activation time augmentation time to 120 minutes from approximately one hour from declaration from the current after declaration of a Site requirement of one hour from Area Emergency or higher to notification.
approximately 120 minutes after declaration.
NOC-AE-1 5003273 Page 4 of 18 2.2 Background (Emergency Response Organization Augmentation Time Revision)
The current ERO augmentation times of 60 and 75 minutes were found to be acceptable by the NRC as documented in a Safety Evaluation Report (SER) dated May 20, 1993 (Reference 2). In the evaluation, the NRC stated that the revision from 45 and 60 minutes to 60 and 75 minutes was a minor reduction in response time compensated for by a commitment to maintain more personnel on-shift than called for in established guidance documents. At the time the SER was issued, STPNOC (then Houston Lighting
& Power Company) committed to maintain 20 personnel on-shift, seven more than required by Table B-I of NUREG 0654. The on-shift ERO staffing was later revised to its current 25 positions.
Attachment 2 provides an analysis of staffing requirements related to accident scenarios for a rapidly escalating General Emergency Steam Generator Tube Rupture and Probable Aircraft Threat with a loss of large areas of the plant due to explosions or fire. The analysis demonstrates that the minimum on-shift staff currently described by Table C-I of the STPEGS Emergency Plan is capable of performing the required mitigation and emergency response actions for at least 120 minutes without offsite ERO augmentation and without interference from collateral duties.
NUREG 0654, Table B-l, requires augmentation of a Notification/Communication functional area within 30 and 60 minutes. The State/County Communicator function is currently provided on-shift by a designated non-licensed Plant Operator (P0) without collateral duties. The NRC-Emergency Notification System Communicator is currently provided on-shift by a designated licensed ReactorOperator (RO) without collateral duties.
The Attachment 2 staffing scenarios provide the bases and ensure the health and safety of the public is maintained during a radiological event with these designated on shift communicators.
NUREG 0654, Table B-I, requires augmentation of "Radiological Accident Assessment and Support of Operational Accident Assessment" and "Protective Actions (in-plant)"
functional area within 30 and 60 minutes. These functions are currently provided on-shift by three Radiation Protection (RP) Technicians, one Chemistry Technician, and the Duty Maintenance Supervisor (DMS). The on-shift Senior Radiation Protection Technician provides radiological dose assessment to the Shift Manager (SM) for Protective Action Recommendations (PAR) without collateral duties. Two on-shift RP Technicians provide onsite surveys and offsite radiological assessment, access control, coverage for jobs, personnel monitoring and dosimetry without collateral duties. One on-shift Chemistry Technician is trained in radiological accident assessment and is available to fulfill the onsite surveys if required during an emergency without collateral duties. One on-shift DMS is trained in access control and limited dosimetry to provide protective actions with no collateral duties. Attachment 2 provides the basis for and assurance that the health and safety of the public is maintained during a radiological event with the On-shift designated RP, Chemistry and DMS resources.
NUREG 0654, Table B-l, requires augmentation of "Plant System Engineering, Repair, and Corrective Actions" functional area within 30 and 60 minutes. These functions are currently provided on-shift by a Shift Technical Advisor (STA) that is a licensed Senior Reactor Operator (SRO) and holds a Technical or Engineering degree, Mechanic, Electrician, Instrument and Control Technician, and P0. The on-shift STA duties are to monitor the core safety functions of the plant; provide advisory technical support to the
NOC-AE-1 5003273 Page 5 of 18 Shift Manager/Emergency Director (SM/ED) in the areas of thermal dynamics, reactor engineering and plant analysis with regard to the safe operation of the unit; and provide peer checks to the operations staff during the implementation and recovery phases of the accident without collateral duties. STPNOC maintains one Mechanic, two Electricians, and one Instrument and Control Technician on-shift for repair and corrective actions without collateral duties.. STPNOC maintains one P0 on-shift for repair and corrective actions with no collateral duties. Attachment 2 staffing study provides the basis for and assurance that the health and safety of the public is maintained during a radiological event with the additional designated on-shift personnel.
NUREG 0654, Table B-i, does not require a SM to augment within 30 or 60 minutes.
STPNOC's process is to maintain two SMs onsite at all times. This allows one SM to assist the current SM/ED (if needed) until relieved without collateral duties. This assistance can be in the form of communications, notifications, or the monitoring of core safety functions. Attachment 2 provides the basis for~and assurance that the health and safety of the public is maintained during a radiological event with the designated additional SM (ED qualified) on shift.
The on-shift complement is capable of maintaining the requirement of reasonable assurance to protect the health and safety of the public as described above for a prolonged time. The on-shift complement exceeds the guidance criteria established in NUREG 0654, and meets the regulatory criteria of 10 CFR 50.47, and its Appendix E.
STPNOC maintains an on-shift complement capable of fulfilling the requirements to respond to an emergency for at least 120 minutes as evaluated in Attachment 2 to this License Amendment Request.
Increasing the ERO augmentation time to the proposed approximately 120 minutes would not reduce the effectiveness of the STPEGS Emergency Plan. In addition, this 120 minute change would enlarge the residential range of those who could respond safely and thereby increase the pool of potential ERO members. This would enhance the overall skill sets, technical expertise, and position defense in depth of the ERO.
3.0 TECHNICAL EVALUATION
3.1 Emergency Response Organization Augmentation Time Revision To validate that the proposed revision in augmentation time will not degrade the ability of the on-shift staff to perform accident mitigation and emergency response functions during an emergency, STPNOC selected two staffing intensive scenarios (Attachment 2) to evaluate their impact on shift resources. The intent of the evaluation was to assess if the minimum required on-shift complement (as described by Table C-i of the STPEGS Emergency Plan) was capable of performing all procedurally required actions without being subjected to overlapping functions or collateral duties that could interfere with the completion of emergency plan responsibilities.
The use of these two scenarios represent rapidly escalating, staffing intensive events for STPNOC's evaluation purposes. Regardless of the event type or classification, STPNOC's ERO capabilities continue to be met by the on-shift complement for at least 120 minutes.
The first scenario selected was a Steam Generator Tube Rupture (SGTR) combined with elevated Reactor Coolant System (RCS) activity and a loss of offsite power (LOOP).
NOC-AE-1 5003273 Page 6 of 18 STPNOC evaluated a SGTR with cladding failure to produce an offsite dose in excess of the Environmental Protection Agency (EPA) Protective Action Guidelines (PAGs) beyond the site boundary. The LOOP resulted in the release of the primary-to-secondary leakage to the atmosphere. This event prompted the declaration of a General Emergency (GE) very shortly after event initiation.
The second scenario was a large-area fire initiated by an aircraft impact in the Protected Area, prompting the declaration of a Site Area Emergency (SAE). This scenario called for the coordination of the site Fire Brigade with offsite assistance to combat the fire.
The evaluation of both events demonstrates the on-shift staff is capable of performing operational and emergency response functions for at least 120 minutes prior to augmentation staffing relief required. Therefore, extending ERO augmentation from the present 60 and 75 minutes to the proposed approximately 120 minutes would not constitute a burden for the on-shift crew and does not reduce the protection of the health and safety of the public nor the effectiveness of the Emergency Plan.
Furthermore, these evaluations demonstrate that on-shift staffing is sufficient to support both emergency response functions and accident mitigation without overlap or conflicting collateral duties as described below.
3.2 Radiation Protection Offsite Radiological Surveys - The change in response time for offsite radiological survey responders is acceptable. There is no need to perform offsite surveys within at least the first 120 minutes of the event due to the use of installed post-accident effluent radiation monitors. Offsite surveys are not needed during the initial stages of an event due to fact that release pathways are monitored release points. In the unlikely event that an offsite survey is needed, the two on-shift RP Technicians would be available to perform the offsite survey.
During at least the first 120 minutes of an event, in-plant radiation monitoring instrumentation would be used. Onsite surveys or installed post-accident effluent radiation monitors can provide rapid indication of a release of radioactive materials and can be used for offsite dose assessment calculation purposes. These dose assessment calculations provide the necessary information for the SM/ED to evaluate and recommend protective actions to offsite response agencies. Therefore, reasonable assurance of the health and safety of the public during the initial phase (120 minutes) of the event will be maintained using either installed technology or on-shift RP Technicians.
Onsite (Out-of-Plant) and In-Plant Surveys - The need for onsite out-of-plant or in-plant surveys before the augmented responders arrive is unlikely. During the initial stages of an event, the major response activities concentrate on determining the cause of the event and placing the plant in a safe condition through plant manipulations and system alignments. In-plant radiological monitoring instrumentation provides a means by which radiological conditions can be determined during an emergency, thereby reducing the need to dispatch RP personnel into the plant.
The radiological monitoring instrumentation ensures that both RP and ERO members are kept informed of current and changing radiological conditions. In-plant radiological instrumentation provides a continuous radiological status of the rooms to ensure areas
NOC-AE-1 5003273 Page 7 of 18 required for safe shutdown are monitored. This instrumentation also provides local and remote alarming capability. Using area radiation monitors, continuous monitoring points within the plant are selected to provide indication and warning where radioactivity may be present. All of these monitors provide sufficient range to provide indication of escalating radioactive environments for severe accident conditions. In the unlikely event that an onsite or in-plant survey is needed, the on-shift RP Technicians are available to perform onsite and in-plant surveys before the augmented responders arrive. Therefore, reasonable assurance of the health and safety of the public during the event will be maintained using either installed technology or RP Technicians.
Access Control and Personnel. Monitorinq - At the time of the original site emergency plan, radiological access control was a labor intensive task. Dedicated RP Technicians were required to check dose margins, training qualifications, and to ensure workers had read and understood their Radiation Work Permit (RWP). Worker access control is now automated through the use of radiation protection work processes which have been computerized. Radiation Work Permit access control and electronic dosimeter computer systems work together to provide a fully integrated system allowing workers to sign-in on their Radiation Work Permit and to self-issue electronic dosimeters. Both systems have been used by plant workers for several years.
Worker dose margins and training qualifications are also automatically verified when the RWP access control system is used. If a worker's dose margin is inadequate or training is expired, the worker's access would be precluded and the access control system would not allow issuance of an electronic dosimeter. During the log-in process, workers acknowledge their electronic dosimeter alarm setpoints and that they have read and understand their Radiation Work Permit. The electronic dosimeter provides the worker with a continuous status of dose received and work area dose rates, and it will alarm at preset dose and dose rate alarms. Should personnel receive an alarm, they are required to exit the area immediately for additional instructions and follow-up. Use of electronic dosimeters facilitates more efficient use of RP Technicians to provide RP coverage while preserving the ALARA concept.
Access Control is maintained by the emergency responders obtaining an electronic dosimeter and entering a RWP number into the access control Computer system prior to being allowed access into the Radiological Controlled Area (RCA). No setup is required for the RWP access control computers, which allows RP Technicians time for more critical tasks during emergency response. Personnel are required to self-monitor for radioactive contamination whenever they exit any RCA. No RP involvement is necessary for this contamination monitoring activity due to the fact that the workers are trained to perform this task without supervision or oversight.
As additional defense in depth, sTP utilizes a 'grab and go' method using Direct Reading Dosimeters as emergency Electronic Personal Dosimeter (EPD's) when entering the RCA for an emergency. The EPD would then be manually entered into the database after the emergency has been resolved.
The proposed changes in RP Technician response times are supported by current advances in technology with access control and personnel monitoring processes and equipment.
NOC-AE-1 5003273 Page 8 of 18 RP Coverage (Repair, corrective actions, search and rescue, first aid and firefiflhtinfl)-
The need for RP coverage for workers in the plant before the RP Technician augmented responders arrive would be limited. In the early stages of an emergency event, the major site response activities are concentrated on determining the cause of the event, identifying the status of plant equipment, and following Emergency Operating Procedures (EOP) to place the plant in a safe condition. Only after plant status is understood and the plant is in a stable condition would operator attention be focused on corrective maintenance that may be needed to restore plant capabilities.
RP coverage would only be needed if the radiological status of a room is unknown and there is a definitive need for emergency workers to enter the room to perform a critical task. The decision to provide RP coverage may be based on plant radiological conditions as indicated by installed Area Radiation Monitors (ARMs). During the initial stages of an accident, not all areas of the plant would be affected by releases of radioactive materials.
Therefore, RP coverage would not be required for all areas. If RP coverage is deemed necessary, multiple emergency teams can be covered by the on-shift RP Technicians. In addition to the coverage provided by the RP staff, Chemistry personnel are trained in the use of specific portable radiation survey instruments so that certain on-shift functions can be performed without the assistance of RP Technicians. If RP coverage is not provided for entry into areas with low radiological risk or known radiological status, worker protection would not be an issue as emergency workers are required to wear electronic dosimeters which will alarm at preset dose and dose rate setpoints. Also, ARMs which alarm locally and remotely at preset dose rates are located throughout the plant. Should personnel receive an alarm on dose or dose rate, they are required to exit the area immediately for additional instructions and follow-up. Reasonable assurance of the health and safety of the public during an event will be maintained using either installed technology or on-shift RP Technicians.
Dosimetry - When the site emergency plan was originally issued, dosimetry issuance was a manual process requiring RP Technicians to zero and issue dosimeters, verify worker training, and verify and track radiation dose margins. As addressed in the Access Control/Personnel Monitoring Section above, access control computers are now used for issuance of battery powered electronic dosimetry with alarming capability. Worker self-issuance of electronic dosimeters has eliminated the need for RP Technicians to physically issue dosimetry with the exception of any tasks that require specialized dosimetry and/or special body placement of the dosimetry. These special dosimetry types of tasks are not expected in the initial stages of an event, but during the recovery phase when ERO augmentation would be met. The changes concerning the augmented RP Technician responders are supported by reductions in RP Technician workload due to improvements in RP processes and equipment, and would not impact the ability of the on shift staff to mitigate an emergency event.
3.3 Field Monitoring Teams During the initial stages of an event, the major response activities are concentrated on determining the cause of the event and placing the plant in a safe condition through plant manipulations and system alignments. In-plant radiological monitoring instrumentation provides a means by which radiological conditions can be determined during an emergency, thereby reducing the need to send RP personnel to obtain onsite radiological data, particularly when assessing initial radiological conditions in the early stages of an event. The radiological monitoring instrumentation ensures that both RP and ERO
NOC-AE-1 5003273 Page 9 of 18 members are kept informed of current and changing radiological conditions. In the unlikely event that onsite field monitoring is needed, the on-shift RP Technicians would be available to perform onsite field monitoring before the augmented responders arrive.
Onsite field monitoring would be performed by seven RP Technicians reporting within approximately 120 minutes. These RP Technicians would assess environmental radiation/contamination and provide input to the individual providing senior radiation protection expertise. These RP Technicians would also provide RP coverage for the field monitoring team.
Offsite field monitoring is not expected to be needed during the initial stages of an event.
During at least the first 120 minutes of an event, in-plant radiation monitoring instrumentation would be used since radiological release instrument data is readily obtainable. Onsite field monitoring or installed post-accident effluent radiation monitors can provide rapid indication of a release of radioactive materials and can be used for offsite dose assessment calculation purposes. In the unlikely event that offsite field monitoring is needed within the first 120 minutes, the two on-shift RP Technicians would be available to perform the offsite field monitoring before the augmented responders arrive.
Offsite field monitoring is performed by two Technicians and two drivers reporting within approximately 120 minutes. These Technicians would perform environmental radiation/contamination assessments and radioactive plume tracking. The Technicians would communicate and coordinate with applicable ERO supervision, and would also be responsible for the radiological protection of their field team.
3.4 Chemistry An event that results in a loss of all three fission product barriers would represent a condition that is already at a higher emergency classification than any emergency classification that could be achieved from Emergency Action Level (EAL) thresholds associated with chemistry sampling. For this condition, other fission product barrier EALs would be applied in order to facilitate timely assessment and classification of an emergency. Therefore, the Chemistry Technician's duties, early in an event, would not be required to conduct chemistry samples for fuel barrier integrity purposes.
Containment isolation would occur for accidents of this type. In order to collect and analyze a primary coolant sample following such an event, containment must be un-isolated manually. The On-shift Staffing Analysis (OSA) Report (Reference 3) appropriately assessed that these actions would not take place in the first 120 minutes following such an accident sequence.
Current STPNOC qualifications for on-shift Chemistry Technicians (E-Plan Table C-i RP Technician), qualifies these personnel to assist in radiological accident assessment through performance of onsite or offsite surveys if needed. This qualification provides additional on-shift RP capabilities. There is reasonable assurance of the health and safety of the public during an event with the additional RP Technician qualifications required for the on-shift Chemistry Technician.
NOC-AE-1 5003273 Page 10 of 18 3.5 Plant OperatorslRepair and Corrective Actions As defined in Section 2.5 of NEI 10-05, "Analysis of Repair and Corrective Action Responses," a repair or corrective action is an action that can be performed promptly to restore a non-functionai component to functional status (e.g., resetting a breaker), or to place a component in a desired configuration (e.g., open a valve), and does not require work planning or implementation of lockout or tagout controls to complete. These actions are normal operational tasks performed by plant operations personnel during their daily routine shift coverage and are trained to perform these repair and corrective action type tasks as defined in NEI 10-05.
The STP Emergency Core Cooling System (ECCS) includes three redundant, 100%
capacity trains, each containing low and high pressure safety injection pumps. Backup power for each train is provided by a dedicated emergency diesel generator. All system components, including the emergency diesel generators, meet quality standards, and are designed to withstand phenomena such as seismic events, tornadoes, floods, and fires, without a loss of function. The site Technical Specifications (TS) contain operabilitY and surveillance test requirements that assure that the ECCS is available to perform its required safety functions. The ECCS is designed such that it can perform its safety functions assuming a single failure and a loss of offsite power, as required by 10 CFR 50, Appendix A, "General Design Criteria for Nuclear Power Plants." That is, the ECCS is designed to be capable of performing its required safety functions with no required repairs or corrective actions.
Repair and corrective actions as defined in NEI 10-05 are intended to enhance plant response in various accident scenarios and are limited in scope. Although highly unlikely, these actions may be desired to ensure that the ECOS performs its required functions. If any malfunction occurred that would require prompt manual action, the manual action would most likely involve a repair or corrective action as defined in NEI 10-05, which the POs are fully capable of performing. These repair and corrective actions are to be promptly performed by POs and are not dependent on the arrival of Maintenance personnel on site. These actions involve activities such as resetting breakers and repositioning valves, prior to 120 minutes after event initiation. More complex and involved actions requiring Maintenance personnel are not expected to be performed in a prompt manner (i.e., not within 120 minutes of event initiation), since work planning and implementation of tagout controls would typically preclude such prompt completion.
3.6 Engineering/Technical Support The STA is available on-shift to monitor core/thermal hydraulics and provide the necessary technical support for the 120 minute approximate response time requested.
The STA monitors core/thermal hydraulics and provides technical support throughout the emergency event until relieved by the augmented ERO.
The STA is trained as an advisor to the Control Room operating shift per NUREG-0737
'Clarification of TMI Action Plan Requirements.' In 1990, additional guidelines were developed by the Institute of Nuclear Plant Operations (INPO) for the training of STAs.
This is detailed in the guidance document INPO 90-003, 'Guidelines for the Training and Qualification of Shift Technical Advisors.' The STA performs independent assessments of plant operating concerns, technical support, appropriate corrective actions, analysis of events and their effects, effectiveness of response(s) to emergent conditions,
NOC-AE-1 5003273 Pagell1of18 classifications of emergencies, protection of the public, and any other actions related to critical safety functions and plant safety during abnormal and emergency situations.
STP's Plant Computer System was upgraded to an Integrated Computer System (lCS).
This computer system provides plant personnel, including the STA, the capability to monitor and trend plant parameters in real time, including primary coolant system parameters, reactor core thermal performance parameters, emergency core cooling system parameters, meteorological data, containment isolation status, and radiation monitor readings.
The Emergency Operating Procedures (EQOPs) and Severe Accident Management Guidelines (SAMGs) were implemented to improve the quality of operational information and guidance during emergency events. These improvements in the monitoring of plant parameters via the lCS, and in emergency procedures, have reduced the burden on the STA during postulated events, allowing the STA to perform monitoring and technical support in support of the Emergency Plan (EP) response without impacting their primary ERO actions. Therefore, reasonable assurance of the health and safety of the public during an event will be maintained using installed advances in computerized plant monitoring technology.
3.7 Shift Manager The SM is responsible for the overall assessment of emergency conditions and becomes the ED. The SM has the overall responsibility for operational decisions involving the safety of the plant and its personnel, and for making PARs to offsite agencies for the protection of the public during an emergency event.
The SM implements the site EP through the use of specific Emergency Plan Implementing Procedures (EPIP). SMs and STAs are trained in these activities as part of their initial qualification training and annual requalification training, and are required to demonstrate competence in these areas during annual simulator training sessions and emergency drills.
While the SM has overall responsibility for operational decisions involving the safety of the plant, the Unit Supervisor (US) and ROs within the control room have the direct responsibility of operating the plant during an emergency situation. The US and ROs would implement the appropriate EOPs for the particular event and operate the plant. The SM would oversee the US and RO activities while implementing the site EP and maintain situational awareness of the event as it unfolds. The SM has overall responsibility for the emergency response event until this responsibility is transitioned to the ED in the Technical Support Center (TSC) or Emergency Operations Facility (EOF). The SM continues to maintain control of plant operations after overall emergency response responsibilities have been turned over to a TSC or EOF ED.
Initial SM training requires that the SM demonstrates knowledge and understanding of emergency planning procedure processes. These processes include making required notifications, recommending protective actions to public officials, determining protective measures for onsite personnel, managing the plant response to the event while implementing the EP, understanding the typical decisions concerning priorities in transitioning from normal operations to coping with an emergency event and implementation of the EP, and assigning priorities to activities to ensure resources are
NOC-AE-1 5003273 Page 12 of 18 appropriately directed to manage the plant condition.
The proficiency of the on-shift operations staff to perform critical emergency planning functions, without support from off-shift/offsite resources, is evaluated during operations continuing training and annual license exams. Emergency response drill objectives are integrated into evaluated simulator sessions for the Control Room staff. During these sessions, there is no augmentation of the on-shift operations staff with additional personnel, and ther~e is not a turnover of emergency response duties or responsibilities to the TSC or EOF. The shift Control Room staff is expected to perform all emergency response tasks that are required by the simulated scenario, in conjunction with other required actions that are directed by normal, abnormal, and EOPs. Evaluated emergency response tasks include emergency classification, notification, offsite dose assessment, formulation, and simulated implementation of PARs for offsite authorities.
The ability of the SM to implement the site EP while maintaining command and control of the plant is also verified during emergency planning drills and exercises. Emergency planning drills and exercises require the SM to perform required emergency planning duties through the Unusual Event (UE), Alert, Site Area Emergency (SAE), or General Emergency (GE) stages of scenarios while maintaining command and control of the plant response in accordance with plant operating procedures.
The required emergency planning actions and notifications for the SM specified in site emergency planning procedures for the UE, Alert, SAE, and GE classifications are very similar. For each classification, the SM, or a designee such as the communicator, is required to announce the emergency on the site public address system; sound the emergency siren if required; notify county, state, and NRC officials; perform accountability if required; ensure the emergency response data system is activated; and initiate onsite monitoring and habitability. The only difference between the UE, Alert, SAE, and GE is that the GE requires a PAR. The SMs practice developing and issuing PARs as part of their normal training, drills, or exercises. Otherwise, the required emergency actions and notifications specified in emergency planning procedures are virtually the same between an Alert, SAE, and GE.
In summary, operator training and emergency planning drills/exercises are sufficient to demonstrate that the SM can maintain situational awareness of the event, while performing all required emergency planning functions, without assistance from augmented staff. This training demonstrates the reasonable assurance of protecting the health and safety of the public for a protracted time up to 120 minutes.
3.8 Communications NUREG 0654, Table B-i, requires augmentation of a Notification/Communication functional area within 30 and 60 minutes. The State/County Communicator function is currently provided on-shift by a designated non-licensed Plant Operator (P0) without collateral duties. The NRC-Emergency Notification System Communicator is currently provided on-shift by a designated licensed Reactor Operator (RO) without collateral duties. Each of these communicators have access to a dedicated Operator Communications Panel (OCP) that is powered with normal plant 120 Volt AC and backed up with non-Class 1 E DGs and an 8-hour battery.
NOC-AE-1 5003273 Page 13 of 18 3.9 Fire Fighting/Rescue Operations and First Aid/Site Access Control and Personnel Accountability NUREG-0654, Table B-i specifies that the Fire Brigade Major Functional Area be staffed in accordance with the Technical Specifications This section does not contain specific 30 and 60 minute augmentation response infor-mation other than a reference to local support. STPEGS is not requesting a change for the Fire Fighting Major Functional Area. STPNOC has a .5-person fire brigade crew that is available onsite at all times. The availability of an on-shift fire brigade allows the other on-shift personnel to perform their required emergency planning duties without the added tasks of fire brigade or first-aid duties.
NUREG-0654, Table B-i specifies Rescue Operations and First Aid be staffed on-shift by shift personnel assigned other functions. This section does not contain specific 30 and 60 minute augmentation response information other than a reference to local support. STPEGS maintains an on-shift Rope Rescue Team and Medical Responders within our Security on-shift staffing requirements. STPEGS is not requesting a change for the Rescue Operations and First Aid Major Functional Area.
NUREG-0654, Table B-i specifies Site Access Control and Personnel Accountability
- positions on-shift by Security Personnel and in accordance with Security Plan. STPEGS is not requesting a change for the Site Access Control and Personnel Accountability Major Functional Area.
3.10 Additional Staffing Commitments On November 25, 2014, STP Nuclear Operating Company (STPNOC) submitted the Phase 2 Staffing Assessment to the NRC in response to the 10 CFR 50.54(f) request for information regarding Near-Term Task Force (NTTF) Recommendation 9.3 for Emergency Preparedness programs. Following this submittal, STPNOC performed a revalidation of the assessment results using the final validated FLEX Support Guidelines (FSGs) and any applicable new procedures that were not complete when the staffing assessment tabletop was performed.
STPNOC performed the revalidation of the staffing assessment results between April 13, 2015 and April 21, 2015. The results of the revalidation showed that effectively implementing the STP diverse and flexible coping (FLEX) strategies requires two maintenance personnel per unit. One Instrumentation and Control (l&C) Technician and one Electrician are currently included in the minimum staffing requirements in the STP Emergency Plan. In order to effectively implement STP's FLEX strategies with two maintenance personnel in each unit, a Mechanic and either an additional l&C Technician or an Electrician are needed.
On July 2, 2015, STPNOC submitted a "Supplement to Response to Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident Phase 2 Staffing Assessment" (Reference 4).This submittal identified that the Mechanic and second Electrician or l&C Technician, hereafter referred to as the two additional maintenance personnel, are not included in the minimum staffing requirements in our Emergency Plan. They are two of the 'double-asterisk' positions listed in Table B-i of NUREG-0654 that could be covered by shift personnel assigned other functions.
NOC-AE-1 5003273 Page 14 of 18 While these two individuals are not part of the minimum on-shift staff as required by the STP Emergency Plan, these two maintenance personnel are currently procedurally obligated (Reference 4, NRC Commitment 12-11658-584) to be onsite at all times to support the station Integrated Maintenance Team (IMT).
With .the addition of the ERO qualified Mechanic and either an I&C Technician or an Electrician, the current minimum on-shift ERO staff would be augmented with an additional two (2) on-shift responders at the onset of an emergency. These additional responders are available to support the emergency response efforts without the assignment of collateral duties that would adversely affect the ability to execute Emergency Plan functions. This additional on-shift staffing enhances the reasonable assurance of protecting the health and safety of the public for a protracted time up to 120 minutes.
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.47(b)(1 ) and (2) establish standards applying to emergency response plans:
The onsite and, except as provided in paragraph(d) of this section, offsite emergency response plans for nuclear power reactors must meet the following standards (I) Primary responsibilitiesfor emergency response by the nuclfear facility licensee and by State and local organizationswithin the Emergency Planning Zones have been assigned, the emergency responsibilitiesof the various support organizationshave been specifically established, and each principalresponse organization has staff to respond and to augment its initial response on a continuous basis.
(2) On-shift facility licensee responsibilitiesfor emergency response are unambiguously defined, adequate staffing to provide initial facility response in key functional areas is maintainedat all times, timely augmentation of response capabilitiesis available and the interfaces among various onsite response activities and offsite support and response activities are specified.
The existing STPEGS Emergency Plan includes onsite and offsite emergency response plans that meet the requirements listed above. This License Amendment Request proposes to revise the current staff augmentation response time from 60 minutes and 75 minutes to approximately 120 minutes. An evaluation of staffing intensive scenarios based on design basis accidents has been performed that confirms that this revision to augmentation response time will not adversely impact the performance of required emergency functions. The revised augmentation response time, to the STPEGS Emergency Plan, will continue to have onsite and offsite emergency response plans that meet 10 CFR 50.47(b) and continue to provide reasonable assurance that adequate protection of the health and safety of the public will be maintained in the event of a radiological emergency.
Proposed changes to the STPEGS Emergency Plan to realign the Emergency Response Organization (ERO) do not impact on-shift personnel and therefore do not degrade the
NOC-AE-1 5003273 Page 15 of 18 ability of on-shift personnel to respond to an emergency. The proposed realignment is limited to augmented ERO personnel and continues to establish the response activities and staffing levels recommended in Table B-i of NUREG-0654 (Reference 1).
Therefore, the Emergency Plan will continue to employ staffing that meets the requirements of 10 CER 50.47(b).
10 CFR 50.54(q) establishes requirements for changes to emergency plans:
(q) Emergency plans.
(1)(iv) Reduction in effectiveness means a change in an emergency plan that results in reducing the licensee's capablilityto perform an emergency planning function in the event of a radiologicalemergency.
(2) A holder of a license under this part, or a combined license under part 52 of this chapter after the Commission makes the finding under § 52.103(g) of this chapter, shall follow and maintain the effectiveness of an emergency plan that meets the requirements in Appendix E to this part and, for nuclear power reactorlicensees, the planning standards of § 50.4 7(b).
(4) The changes to a licensee's emergency plan that reduce the effectiveness of the plan as defined in paragraph(q) (1)(iv) may not be implemented without priorapproval by the NRC. A licensee desiring to make such a change after February21, 2012 shall submit an application for an amendment to its license. In addition to the filing requirements of §§ 50.90 and 50.91, the request must include all emergency plan pages affected by that change and must be accompaniedby a forwarding letter identifying the change, the reason for the change, and the basis for concluding that the licensee's emergency plan, as revised, will continue to meet the requirements in Appendix E to this part and, for nuclearpower reactor licensees, the planning standardsof§ 50.4 7(b).
The existing STPEGS Emergency Plan meets the planning standards of 10 CFR 50.47(b) and 10 CFR 50 Appendix E as required by 10 CER 50.54(q). This LAR proposes to change the current staff augmentation response times from 60 minutes and 75 minutes to approximately 120 minutes. The revision in augmentation response times is supported by the results of an evaluation of staffing intensive scenarios which found that the on-shift crew is capable of performing emergency response functions without undue distraction by accident mitigation actions. This proposed change to approximately 120 minutes is considered a reduction in effectiveness as defined by 10 CFR 50.54(q)(1)(iv) and requires submittal based on 10 CFR 50.54(q)(4). Therefore, STPNOC is submitting this LAR pursuant to 10 CER 50.90.
The scenario analysis confirms that lengthening the staff augmentation response times will not negatively impact the performance of required emergency response functions, the Emergency Plan will continue to meet the requirements of 10 CFR 50.54(q)(2) by maintaining the effectiveness of the Plan in accordance with requirements of 10 CFR 50 Appendix E and the planning standards of 10 CFR 50.47(b).
NUREG-0654/FEMA-REP-1, Revision 1 (Reference 1), Section II.B provides evaluation criteria for the onsite emergency organization:
NOC-AE-1 5003273 Page 16 of 18 ll.B.5 Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity. For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table B-i entitled, "Minimum Staffing Requirements for Nuclear Power Plant Emergencies." The minimum on-shift staffing levels shall be as indicated in Table B-I. The licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency. This capability shall be as indicated in Table B-I. The implementation schedule for licensed operators, auxiliary operators and the shift technical advisor on shift shall be as specified in the July 31, 1980 letter to all power reactor licensees. Any deficiencies in the other staffing requirements of Table B-I must be capable of augmentation within 30 minutes by September 1, 1981, and such deficiencies must be fully removed by July 1, 1982.
The current STPEGS Emergency Plan staffing in Table C-i meets the intent of NUREG-0654, Table B-i. While Table B-i of NUREG-0654 provides guidance for staff augmentation at 30 minutes and 60 minutes, the current Emergency Plan establishes augmentation times of 60 minutes and 75 minutes as previously approved by the NRC.
The LAR proposes to change the current staff augmentation response time from 60 minutes and 75 minutes to approximately 120 minutes. An evaluation of staffing-intensive scenarios has been performed that confirms that this change in augmentation response time will not adversely impact the performance of required emergency functions. This change has been reviewed and concurrence has been received by the State of Texas and Matagorda County.
4.2 Precedent None.
4.3 No Significant Hazards Consideration Determination STP Nuclear Operating Company (STPNOC) proposes revisions to the South Texas Project Electric Generating Station (STPEGS), Units 1 and 2, Emergency Plan. The proposed changes would result in a revision in the staff augmentation time for certain ERO positions from 60 minutes and 75 minutes to approximately 120 minutes.
STPNOC has evaluated whether a Significant Hazards Consideration is warranted with the proposed change by addressing the three criteria set forth in 10 CFR 50.92(c) as discussed below:
Criterion 1:
Does the proposed amendment involve a significant increase in the probability or consequence of an accident previously evaluated?
Response: No.
NOC-AE-1 5003273 Page 17 of 18 The proposed revision to staff augmentation times has no effect on normal plant operation or on any accident initiator or precursors and does not impact the function of plant structures, systems, or components. The proposed changes do not alter or prevent the ability of the Emergency Response Organization to perform their intended functions to mitigate the consequences of an accident or event.
Therefore, the proposed Emergency Plan change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
Criterion 2:
Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed change does not impact the accident analysis. The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed), a change in the method of plant operation, or new operator actions. The proposed change does not introduce failure modes that could result in a new accident, and the change does not alter assumptions made in the safety analysis. The proposed change revises the staff augmentation response times in the Emergency Plan. The proposed changes do not alter or prevent the ability of the Emergency Response Organization to perform their intended functions to mitigate the consequences of an accident or event.
Therefore, the proposed changes does not create the possibility of a new or different kind of accident from any accident previously evaluated.
Criterion 3:
Does the proposed change involve a significant reduction in margin of safety?
Response: No.
Margin of safety is associated with confidence in the ability of the fission product barriers (i.e., fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public. The proposed change is associated with Emergency Plan staffing augmentation and does not impact operation of the plant or its response to transients or accidents. The change does not affect the Technical Specifications. The proposed change does not involve a change in the method of plant operation and no accident analyses will be affected by the proposed change. Safety analysis acceptance criteria are not affected by the proposed change. The revised Emergency Plan will continue to provide the necessary response staff with the proposed change. Therefore, the proposed change is determined to not adversely affect the ability to meet the requirements of 10 CFR 50.54(q)(2), 10 CFR 50 Appendix E, or the emergency planning standards described in 10 CER 50.47(b).Therefore, the proposed change does not involve a significant reduction in a margin of safety.
NOC-AE-1 5003273 Page 18 of 18 4.4 Conclusions Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
5.0 ENVIRONMENTAL CONSIDERATION
STPNOC has determined that the proposed change would not change requirements with respect to use of facility component within the restricted area as defined by 10 CFR 20, nor would it change inspection or surveillance requirements. STPNOC has evaluated the proposed change and has determined the change does not involve: (i) a significant hazards consideration, (ii) significant change in the types or significant increase in the amounts of an effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.
Accordingly, the proposed amendment meets the eligibility criterion for a categorical exclusion set forth in 10 CFR 51 .22(c)(9). Therefore, STPNOC concludes that, pursuant to 10 CFR 51 .22(b), no environmental impact statement or environmental assessment is required to be prepared in connection with the proposed amendment.
6,0 REFERENCES
- 1. NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1, U.S. Nuclear Regulatory Commission and Federal Emergency Management Agency, November 1980
- 2. Letter from Lawrence E. Kokojka to William T. Cottle, dated May 20, 1993, "Safety Evaluation Report: South Texas Project Units 1 and 2 - Revision to Emergency Plan Staff Augmentation Times" (ADAMS Legacy Accession Number 9305280305)
- 3. NEI 10-05 "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities"
- 4. Letter from G.T. Powell, STPNOC, to NRC Document Control Desk, "Supplement to Response to Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident- Phase 2 Staffing Assessment", July 2, 2015 (NOC-AE-1 5003255)
NOC-AE-1 5003273 Attachment 1 ATTACHMENT I South Texas Project Electrical Generating Station Emergency Plan Sections C and G
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION EMERGENCY PLAN SECTION C C.4 Emergency Response Organization Those members of the Emergency Response Organization who are not on site at the time of the emergency shall be able to augment the Onshift Response Organization within approximately 120 minutes of an emergency declaration as specified in Table C-i to provide manning levels recommended in NUREG-0654.
The Technical Support Center and Operations Support Center Station Emergency Response Organization are activated at an Alert emergency classification. Positions for these facilities are depicted in Figure C-2 & Figure C-3. The Emergency Operations Facility and Joint Informlation Center are staffed at the Alert and may be activated at the discretion of the Emergency Director. Positions for these facilities are depicted in Figure C-4 & Figure C-5. The Emergency Operations Facility and Joint Information Center shall be activated at a Site Area Emergency. The Emergency Operations Facility dose projection capability is activated at an Alert classification. If during an Unusual Event the trending of plant conditions indicates the need for additional support, the Emergency Director can activate all or part of the Station Emergency Response Organization to report to the Technical Support Center, Emergency Operations Facility, Joint Information Center or Operations Support Center. The process to maintain a fully staffed Emergency Response Organization is described in 0PGP05-ZV-0003, Emergency Response Organization.
Modifications to the Emergency Response Organization may be made by the Emergency Director as required by the complexity of the emergency.
The following key Emergency Response Organization positions report to the Technical Support Center, the Operations Support Center, and the Emergency Operations Facility, and are added to the Onshift Response Organization during the declaration and mitigation of an Alert, Site Area Emergency or General Emergency. These positions can be activated by the Emergency Director at an Unusual Event emergency classification.
C.4.1 Technical Support Center Manager The Technical Support Center Manager reports to the Technical Support Center at an Alert and provides guidance and advice to the Control Room on plant design and coordinating engineering activities in the areas of analysis, design modifications, system response, and offsite protective action recommendations.
The Technical Support Center Manager may assume the position of Emergency Director from the Shift Manager.
E-PLAN\SEC-C Page 9 of 23 Revision ICN 20-xx Xx/xx/xx
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION EMERGENCY PLAN SECTION C TABLE C-i Page 1 of 3 MINIMUM STAFFING REQUIREMENTS (STPEGS)
(Including Capability for Additional Staffing)
MAJOR POSITION UNIT 1 UNIT 2 ONSITE AVAILABLE FUNCTIONAL TITLE ONSHIFT ONSIIIFT* ONSHIFT 120 MINUTES #
AREA
- Shift Manager -- 2 Unit Supervisor 1 1-Plant Operations Reactor2-and Assessment Operators2 of Operational Plant Operators 2 2-Aspects Shift Technical -1 **
Advisor Plant Operations1 4 Discipline Lead Emergency Direction and Control *** Shift Manager 1"** 1"*-
(Emergency Director)
Notification/Corn2 munications Emergency Director Radiological Senior Health Accident Physics Assessment and Expertise (Dose-1 Support of Assessment)
Operational RP Technicians Accident (onsite/offsite--27 Assessment surveys)
Chemistry Technician-1 E-PLAN\SEC-C Page 15 of 23 Revision ICN 20-xx Xx/xx/xx
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION EMERGENCY PLAN SECTION C TABLE C-i Page 2 of 3 MINIMUM STAFFING REQUIREMENTS (STPEGS)
(Including Capability for Additional Staffing)
MAJOR POSITION UNIT 1 UNIT 2 ONSITE AVAILABLE FUNCTIONAL TITLE ONSHIFT* ONSHIFT* ONSLHFT 120 MINUTES AREA Shift Technical-Advisor Nuclear
-- - 1 Plant System Engineer Engineering Electrical
-- - 1 Engineer Mechanical Engineer--1 Operator **1*
Repair and Mechanical - 1l** 1 Corrective Maintenance Actions Electrical Maintenance -1~ N I&C Technician - -1 RP Technicians (Access ControlIRP Coverage for corrective Protective actions, search -- 2** 4 Actions and rescue, first aid, and fire-fighting/Person nel Monitoring!
Dosimetry)
Plant Fire Brigade Fire Suppression Operations -- per Technical Local Support personnel Specifications E-PLAN\SEC-C Page 16 of 23 Revision ICN 20-xx Xx/xx/xx
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION EMERGENCY PLAN SECTION C TABLE C-i Page 3 of 3 MINIMUM STAFFING REQUIREMENTS (STPEGS)
(Including Capability for Additional Staffing)
MAJOR POSITION UNIT 1 UNIT 2 ONSITE AVAILABLE FUNCTIONAL TITLE ONSHIFT* ONSHIFT* ONSIIIFT 120 MINUTES AREA#
Rescue ~~Plant Protection-2*LoaSupr Operations and Personnel2*LoaSupr First Aid Plant Protection Site Access Personnel Control and (Security/Corn All per Personnel munications/Per Security Plan Accountability sonnel Accountability)
TOTAL 5 5 15 21 Notes: *For each unaffected unit in operation, maintain at least one Unit Supervisor, two Reactor Operators, and two Plant Operators. In accordance with Section 6.0 of the Technical Specifications for each unit, the shift crew composition may be less than the minimum number of operators (licensed or non-licensed) shown above for a period of time not to exceed two (2) hours in order to accommodate unexpected absences of on-duty shift crew members, provided immediate actions are taken to restore the crew composition. The minimum staff for a unit in cold shutdown will be one Senior Reactor Operator, one Reactor Operator, and one Plant Operator for that unit.
- These positions may be covered by onshift personnel assigned other functions.
- ** Overall, direction of emergency response to be assumed by the Emergency Director at the Emergency Operations Facility when all centers are fully manned. Direction of minute-to-minute facility operation remains with senior manager in the Technical Support Center or Control Room.
- Although such a short response time may be achieved in many cases, it is not possible to assure this response time in every instance.
- This position is filled by personnel with plant operations experience E-PLAN\SEC-C Page 17 of 23 Revision ICN 20-xx Xx/xx/xx
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION EMERGENCY PLAN SECTION G G EMERGENCY RESPONSE FACILITIES This section of the Plan describes the location of equipment and facilities maintained by the Station for use in the event of an emergency at the Station. The design of the Station's Emergency Response Facilities meets the intent of Supplement 1 to NUREG-073 7, Clarification of Three Mile Island Action Plan Requirements, and NUJREG-0696, Functional Criteria for Emergency Response Facilities. The locations of the Emergency Response Facilities are indicated on Figures G-1 and G-4. A typical listing of emergency supplies and equipment maintained by the Station is given in Table G- 1. Plant records necessary to perform the functions of each onsite facility are available in and/or at each onsite facility listed in Table G-2. A detailed list of Control Room equipment and instrumentation is provided in Chapter 7 of the Updated Final Safety Analysis Report. The equipment and facilities comprising the Operations Support Center, Technical Support Center, and Emergency Operations Facility do not perform any safety-related functions.
Their design assures that any fault or malfunction does not compromise any safety-related equipment, components or structures.
G. 1 Control Room The Station Operations staff will function from the Control Room for each level of emergency at the Station. The Control Room is radiologically hardened and seismically designed to withstand all credible events that could occur at the Station.
The Control Room is the primary facility at the Station in which Station conditions are monitored and controlled and where corrective actions are initiated to mitigate any abnormal occurrence. In the event the Control Room must be evacuated, a remote Auxiliary Shutdown Panel has been provided for safe shutdown of the Station. Control Room habitability and radiation monitoring capabilities, as well as Auxiliary Shutdown capability, are discussed in detail in the Final Safety Analysis Report.
G.2 Operations Support Center The Operations Support Center is the onsite emergency response staging area, separate from the Control Room and the Technical Support Center. The Operations Support Center is used for assembling the plant emergency response teams and other Station personnel. A typical layout for each unit's Operations Support Center is provided in Figure G-2. If the Operations Support Center must be evacuated, the personnel from the Operations Support Center will relocate to the Operations Support Center of the unaffected unit.
Communications are provided between the Operations Support Center, Technical Support Center, Control Room and the Emergency Operations Facility. Personnel are assigned duties in support of emergency response operations by the Operations Support Center E-PLAN\SEC-G Page 1 of 23 Revision 20 05/01/02
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION EMERGENCY PLAN SECTION G Coordinator, located in the Operations Support Center on the 41' elevation of the Mechanical Auxiliary Building of each unit. An emergency Assembly Area is located in the Electrical Auxiliary Building. This emergency Assembly Area is utilized for the accountability of Station personnel, other than non-essentials, without Emergency Response Organization assignments during the assembly and accountability process.
The Operations Support Center is designed to be fully activated within approximately one hundred twenty (120) minutes after declaration of an Alert, in conjunction with the Technical Support Center. Radiation levels in and around the Operations Support Center are assessed during radiological events.
G.3 Technical Support Center The Technical Support Center is the onsite technical support facility for emergency response. The Station provides one Technical Support Center for each unit. Each facility is located on the 72-foot elevation of the respective unit's Electrical Auxiliary Building and is within a two minute walking distance from the unit's Control Room as described in the Updated Final Safety Analysis Report. In the event of a site-wide emergency, the Unit 1 Technical Support Center will be activated. Otherwise, the Technical Support Center in the affected unit will be activated. These facilities are equipped to enable response personnel to monitor the course of an accident and plan corrective and recovery actions.
Personnel access to the activated Technical Support Center is controlled. During periods of activation, the affected Technical Support Center is staffed continuously to provide plant management and technical support to plant operations personnel and to relieve the reactor operators of peripheral duties and communications not directly related to reactor system manipulations. The typical layout of each unit's Technical Support Center is provided in Figure G-3.
Each Technical Support Center is provided sufficient radiological protection and monitoring equipment to assure that radiation exposure to any person working in the activated Technical Support Center will not exceed five (5) remn TEDE or twenty-five (25) rem thyroid CDE during the duration of a declared accident. Should the affected unit's Technical Support Center become uninhabitable, the Emergency Response personnel within the Technical Support Center can relocate to other emergency response facilities and resume their assigned functions.
The Heating, Ventilation and Air Conditioning (HVAC) for each Technical Support Center is designed to provide a suitable environment during nonnal and post-accident operation, including protection from post-accident radiological releases. The Technical Support Center HVAC System will be verified when positioned in the recirculation mode. Each E-PLAIN\SEC-G Page 2 of 23 Revision ICN 20-xx Xx/xx/xx
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION EMERGENCY PLAN SECTION G respective Technical Support Center diesel generator has the capability of continuous operation for a minimum of seven days.
Radiation monitoring and smoke detection capability, alarms and indications are provided in each respective Technical Support Center. Detection of high airborne levels of radioactive materials causes each respective Technical Support Center HVAC to automatically switch over to activated charcoal filtration. Detection of smoke levels above tolerance causes the system to automatically isolate.
Each Technical Support Center is designed to be fully activated within approximately one hundred twenty (120) minutes after declaration of an Alert, in conjunction with activation of the Operations Support Center. The Technical Support Center may activate simultaneously with activation of the Operations Support Center.
G.4 Emergency Operations Facility The Emergency Operations Facility is located in Bay City, Texas at 4000 Avenue F, approximately 12.5 air miles north-northeast of the Station. Figure G-4 depicts the location compared to the site. The floor plan of the Emergency Operations Facility is depicted on Figure G-5. When activated, the Emergency Operations Facility serves as the primary location for the following typical functions:
- Coordination between Station and non-station organizations, such as the Department of State Health Services;
- A coordination center for the preparation and approval of news releases and bulletins for release of information to the media and notifications to offsite agencies;
- A central point for coordinating all Station offsite dose projection and radiological monitoring activities at the time of the emergency; and
- The primary location for coordinating both technical and non-technical support activities of personnel brought in to assist Station personnel.
The Emergency Operations Facility provides for management of overall Station emergency response, coordination of radiological and environmental assessment, determination of E-PLAN\SEC-G Page 3 of 23 Revision ICN 20-xx Xx/xx/xx
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION EMERGENCY PLAN SECTION G recommended offsite protective actions, and coordination of emergency response activities with Federal, State, and County authorities. The Emergency Operations Facility can be fully activated within approximately one hundred twenty (120) minutes of a declaration of Site Area Emergency or higher. When activated, the Emergency Operations Facility will be staffed by Emergency Response personnel.
A qualified Emergency Operations Facility Director will manage activities in the Emergency Operations Facility.
Resources are provided in the Emergency Operations Facility for the acquisition, display, and evaluation of radiological and meteorological data and containment conditions necessary to perform accident assessment and determine protective measures. This equipment and instrumentation is described in Section H of this Plan.
The Emergency Operations Facility provides for occupancy by Nuclear Regulatory Commission, Federal Emergency Management Agency, State, County, American Nuclear Insurers, and Station Emergency Response Organization personnel.
The Emergency Operations Facility provides sufficient radiological protection and monitoring equipment to assure that radiation exposure to any person working in the Emergency Operations Facility will not exceed five (5) remn TEDE or twenty-five (25) remn thyroid CDE during the duration of a declared emergency. The Emergency Operations Facility has the capability for decontaminating personnel and providing protective clothing.
The Emergency Operations Facility has a backup generator that can provide full load capability should power be lost. Radiation monitoring and smoke detection capability, alarms and indications are provided in the Emergency Operations Facility.
E-PLAN'.*SEC-G Page 4 of 23 Revision ICN 20.-xx Xx/xx/xx
NOC-AE-5003273 Attachment 2 ATTACHMENT 2 Staffing-Related Accident Scenarios
NOC-AE-1 5003273 Attachment 2 Page 1 of 5 Staffinq-Related Accident Scenarios STPNOC conducted on-shift staffing analyses of two scenarios considered to be the most intensive in the utilization of on-shift staff. The results of the analyses demonstrate that on-shift personnel are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the Emergency Plan. For the purpose of the analyses, 120 minutes from the time of event declaration was used as the time period for the conduct of on-shift ERO response actions.
The two scenarios analyzed are a steam generator (SG) tube failure (described in Chapter 15 of the Updated Final Safety Analysis Report (UFSAR)) and a large-area fire caused by an aircraft impact in the Protected Area.
Scenario 1: SG Tube Failure - UFSAR 15.6.3 This design basis accident (DBA) scenario results in a General Emergency with offsite radiological doses that exceed the EPA protective action guidelines (PAGs) and necessitate protective action recommendations (PARs).
The accident initiates at power and involves the complete severance of a single steam generator tube. The reactor trip automatically trips the turbine and with a coincident loss of offsite power, the steam dump valves automatically close to protect the condenser. The steam generator pressure rapidly increases resulting in steam discharge to the atmosphere through the steam generator PORVs (and safety valves if their setpoint is reached). When offsite power is not available, the pressure relief system on the ruptured SG discharges to the atmosphere rather than the condenser. This increases the environmental effect of the steam generator tube rupture (SGTR).
The reactor coolant is contaminated with fission products at a level necessary to support the offsite radiological conditions, thus a non-realistic damage source term input is necessary (DBA accident corresponds to continuous operation with a limited amount of defective fuel rods). The accident leads to an increase in contamination of the secondary system due to leakage of radioactive coolant from the reactor coolant system (ROS).
Normal operation of the various plant control systems is assumed, with the exception of the failure of the condenser steam dump system which allows discharge of activity to the atmosphere via the steam generator power-operated relief valves (and safety valves if their setpoint is reached).
The magnitude of the break flow is such that recovery procedures can be carried out on a time scale that ensures that break flow to the secondary system is terminated before water level in the affected steam generator rises into the main steam pipe.
NOC-AE-1 5003273 Attachment 2 Page 2 of 5 Initial Conditions: 100% power, equilibrium conditions, core burnup 10,000 MWD/MTU Abnormal Conditions: Coolant activity (gap failure) is sufficient to result in an offsite dose that exceeds the EPA Protective Action Guidelines beyond the site boundary.
Scenario Events: Guillotine break of one SG tube.
Coincident loss of offsite power upon reactor trip. SG PORV failed open the ruptured SG This event prompted the declaration of a General Emergency under Initiating Condition FG1, Loss of Any Two Barriers and Potential Loss or Loss of Third Barrier.
For the purposes of this scenario, the onsite staffing was assumed to be limited to the on-shift complement listed in Table C-i of the STPEGS Emergency Plan. No augmented staffing was assumed.
The methodology employed to assess the impact of the event on onsite staffing analyzed the staffing requirements for the following procedures:
0POP05-EO-EO00 Reactor Trip or Safety Injection 0POP05-EO-EO30 Steam Generator Tube Rupture In addition, staffing requirements for emergency response related procedures (i. e.,
classification, notification, assembly and accountability, protective action recommendations, dose assessment, etc.) were also considered for performance in parallel with the two procedures above.
The staffing assessment for this event evaluated the procedurally required actions against the availability of on-shift personnel. The assessment examined the duration of significant tasks in order to determine if overlaps occurred and to detect if personnel with assigned emergency response functions also had collateral duties that could distract the individuals from those functions. No overlaps or distracting Collateral duties were noted.
This scenario intensively employs Radiation Protection and Chemistry personnel to provide site surveys, personnel monitoring, offsite dose assessment, and chemical analyses. The required minimum on-shift staffing includes three Radiation Protection Technicians and one Chemistry Technician. This complement is sufficient to meet procedural requirements.
In conclusion, the results of the analysis demonstrate that the minimum onsite staff described by Table C-i of the STPEGS Emergency Plan is capable of performing the required mitigation and emergency response actions for at least 120 minutes without augmentation and without interference from collateral duties. Furthermore, the analysis indicates that all required emergency response actions, aside from periodic notification updates, are completed within 60 minutes of event initiation.
NOC-AE-1 5003273 Attachment 2 Page 3 of 5 Scenario 2: Probable Aircraft Threat with Loss of Larae Areas of the Plant Due to Explosion or Fire This event includes all emergency response actions taken prior to an aircraft impact in accordance with Regulatory Guide 1.214 for an aircraft threat that is less than 5 minutes from the site, including the dispersal of the fire brigade away from target areas. These actions should generally reflect those listed in 10 CFR 50.54(hh)(1), as expanded upon in Regulatory Guide 1 .214, and others required by the emergency plan.
The event consists of notification to the Unit 1 Shift Manager from the NRC Headquarters Operations Officer (HOO) that an Imminent Aircraft Threat has been declared for STPEGS.
The event continues with the aircraft impacting the site resulting in loss of large areas of the plant due to explosions or fire as reflected by 10 CFR 50.54(hh)(2).
Initial Conditions: 100% power, equilibrium conditions, end of core life Abnormal Conditions: None Scenario Events: At T=0 the Shift Manager receives a phone call from the NRC HQ HOO that a Probable Aircraft Threat (impact >5 and <30 minutes) has been issued for STP. At T+10 minutes, the aircraft impacts inside the Protected Area, creates a large burning pool of jet fuelI consuming the Fire Protection pumps and storage tanks.
Notes: This scenario constitutes a dual unit event. Validation of authenticity of the notification is confirmed.
This scenario results in the initial declaration of an Alert under Initiating Condition HA7 followed by the declaration of a Site Area Emergency (HS4 - Site Attack).
For the purposes of this scenario, the onsite staffing was assumed to be limited to the on-shift complement listed in Table C-i of the STPEGS Emergency Plan. No augmented staffing was assumed.
The methodology employed to assess the impact of the event on onsite staffing initially analyzed the staffing requirements for the following procedures:
0POP04-ZO-SEC4 Guideline for Airborne (Aircraft) Threat 0P0P05-EO-EO00 Reactor Trip or Safety Injection In addition, staffing requirements for emergency response related procedures (i. e.,
classification, notification, assembly and accountability, etc.) were also considered for performance in parallel with the two procedures above.
The staffing assessment for this event evaluated the procedurally required actions against the availability of on-shift personnel. The assessment examined the duration of significant tasks in order to determine if overlaps occurred and to detect if personnel with assigned emergency response functions also had collateral duties that could distract the individuals from those
NOC-AE-1 5003273 Attachment 2 Page 4 of 5 functions. No overlaps or distracting collateral duties were noted.
To address the possible branching that could result from the aircraft impact, the analysis then considered the staffing implications of performing various extreme .damage mitigation guidelines (EDMGs) in parallel with emergency response functions. The following EDMGs were reviewed:
0POPi10-ZO-EDMG Extensive Damage Mitigation Guideline 0POP10O-SG-0001 Maximizing the SGS Heat Sink Coping Time Using Firewater Feed 0POP10O-SG-0002 Maximizing the SGS Heat Sink Coping Time Using DA Gravity Feed 0POP1 0-SG-0003 Manual Operation of Condensate and Feedwater for Steam Generator Supply 0POPi10-Sl1-0001 Firewater Makeup to RWST 0POPi10-FC-0001 Spent Fuel Pool Damage Mitigation Strategies 0POPi10-FC-0002 Maximizing the SFP Heat Sink Coping Time Using Barn Door Ventilation 0POP1 0-EW-0001 Emergency Cross Connecting ECW Trains 0POP1 0-EW-0002 Emergency Supply to Diesel Generator ECW from Firewater 0POP1 0-AE-0001 Emergency AC Electrical Supply to the Opposite Unit 0POPi10-XC-000i Flooding Containment with Firewater 0POP1 0-XC-0002 Spraying Buildings for Cooling and Radiation Release Mitigation 0POPi10-HE-0001 Loss of EAB HVAC 0POP10o-cv-oo01 RCS Feed and Bleed Using Positive Displacement Pump 0POP1 0-FP-0001 Alternate Fire Protection System Operation After discussion of probable event progression due to an aircraft impact, the judgment of the tabletop subject matter experts was a large area fire resulting in loss of the fire protection pumps would be the most personnel resource intensive sequence for implementation by the on-shift minimum staff. The following procedures were then assessed in detail for implementation' by available oin-shift resources:
S 0POP10-ZO-EDMG - Extensive Damage Mitigation Guideline 0
0POP1 0-FP-0001 - Alternate Fire Protection System Operation Also considered was the staffing impact of performing 0ERP01-ZV-IN09 (Offsite Assistance Coordination) which requires the Fire Brigade leader to provide interface and unified command with responding organizations during a fire requiring offsite assistance.
Several site-specific factors influence the ability of the on-shift staff to respond to this event:
- The Fire Brigade is composed of five Plant Operators who have no concurrent safe shutdown tasks. As directed by procedure 0ERP01-ZV-IN09 - (Offsite Assistance Coordination), the Fire Brigade Leader relocates to the Incident Command Post (ICP) to provide unified command with offsite response organizations. This leaves the remaining four members to implement 0POP1 0-FP-0001 (Alternate Fire Protection System Operation).
- The minimum staffing of three Radiation Protection Technicians and one Chemistry Technician is sufficient to accomplish both operational and emergency response duties until the augmented staff arrives. Even with the Senior Radiation Protection Technician
NOC-AE-1 5003273 Attachment 2 Page 5 of 5 relocated to the lCP as directed by procedure 0ERP01-ZV-1N09 - (Offsite Assistance Coordination) to provide radiological controls for offsite response organizations, the remaining two Radiation Protection Technicians are adequate to support radiological controls and surveys for both units.
- The minimum on-shift staff includes enough maintenance personnel to provide repair and corrective actions without the need for assignment of collateral duties to Plant Operators.
- First aid and rescue operations are performed by Plant Protection (Security) personnel without additional duties under the STPEGS Security Plan.
- The presence of two Shift Managers (one per unit) onsite allows the Shift Manager of the lesser impacted unit to provide ongoing emergency direction and control and leaves the more heavily impacted unit's Shift Manager to focus on accident assessment and mitigation.
In conclusion, the results of the analysis demonstrate that the minimum onsite staff described by Table C-1 of the STPEGS Emergency Plan is capable of performing the required mitigation and emergency response actions for at least 120 minutes without augmentation and without interference from collateral duties. Furthermore, the analysis indicates that all required emergency response actions, aside from periodic notification updates, are completed within 60 minutes of event initiation.
Nuclear Operating Company South Texas Project Electric GeneratingStation P.O. Box 289 Wadsworth, Texas 77483 ,V V -
October 6, 2015 NOC-AE-1 5003273 10 CFR 50.90 File No. G25 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 License Amendment Request for Approval of a Revision to Staff Augmentation Times in the Sou'th Texas Proiect Electric Generating Station Emergency Plan In accordance with the provisions of 10 CFR 50.90, STP Nuclear Operating Company (STPNOC) hereby requests a license amendment for approval of a revision to revise the South Texas Project Electric Generating Station (STPEGS) Emergency Plan augmentation times. The proposed revision will change the staff augmentation times for ERO positions from 60 minutes and 75 minutes from time of notification to approximately 120 minutes from time of declaration.
Because the proposed change will lengthen the activation time of the STP Emergency Response Facilities (ERFs), this is considered a Reduction In Effectiveness (RIE). Therefore, in accordance with 10 CFR 50.54(q)(4), STPNOC requests NRC review and approval of the proposed Emergency Plan changes. Following implementation of the proposed changes, the Emergency Plan will continue to meet the requirements of 10 CFR 50.54(q)(2), 10 CFR 50 Appendix E, and the planning standards of 10 CFR 50.47(b). to this letter provides a safety evaluation demonstrating that no significant hazards will result from this change. Attachment 1 provides a marked-up version of the affected Emergency Plan Sections. Attachment 2 provides documentation on two critical staffing scenarios which support a revised augmentation time of approximately 120 minutes.
Additionally, STPNOC has communicated these proposed changes with the State of Texas and Matagorda County. These agencies concur with the proposed changes.
The STPNOC Plant Operations Review Committee (PORC) has reviewed and concurred with the proposed changes.
STPNOC requests a 180-day implementation period after the amendment is approved to accommodate required training and procedure changes.
In accordance with 10 CFR 50.91(b), STPNOC is notifying the State of Texas of this request for a license amendment by providing a copy of this letter and attachments.
There are no commitments in this letter. / .*-
STh: 34155529
NOC-AE-1 5003273 Page 2 of 3 If there are any questions regarding the proposed amendment, please contact Fred Puleo at (361) 972-8697 or me at (361) 972-7697.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on__________________" * '--
Date AId* Capristo Executive Vice President, Chief Administrative Officer fjp-mk
Enclosure:
Evaluation of the Proposed Changes Attachments:
- 1. South Texas Project Electric Generating Station Emergency Plan Revised Sections C and G
- 2. Staffing-Related Accident Scenarios
NOC-AE-1 5003273 Page 3 of 3 CC:
(paper copy)
(electronic copy)
Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Morgan, Lewis & Bockius LLP 1600 East Lamar Boulevard Steve Frantz, Esquire Arlington, TX 76011-4511 U.S. Nuclear Regulatory Commission Lisa M. Regner Lisa M. Regner Senior Project Manager U.S. Nuclear Regulatory Commission NRG South Texas LP One White Flint North (O8H04) John Ragan 11555 Rockville Pike Chris O'Hara Rockville, MD 20852 Jim von Suskil NRC Resident Inspector CPS Energy U. S. Nuclear Regulatory Commission Kevin Polio P. O. Box 289, Mail Code: MN116 Cris Eugster Wadsworth, TX 77483 L. D. Blaylock Cramn Caton & James, P.C.
Peter Nemeth City of Austin Cheryl Mele John Wester Texas Dept. of State Health Services Richard A. Ratliff Robert Free
NOC-AE-1 5003273 Page 1 of 18 ENCLOSURE STP NUCLEAR OPERATING COMPANY (STPNOC)
Evaluation of the Proposed Changes
Subject:
License Amendment Request for Approval of a Revision to Staff Augmentation Times in the South Texas Project Electric Generating Station (STPEGS)
Emergency Plan 1.0
SUMMARY
DESCRIPTION 2.0 DETAILED DESCRIPTION 2,1 Proposed Changes 2,2 Background (Emergency Response Organization Augmentation Time Revision) 3.0 TECHNICA*L EVALUATION 3,1 Emergency Response Organization Augmentation Time Revision 3,2 Radiation Protection 3,3 Field Monitoring Teams 3,4 Chemistry 3.5 Plant Operations/Repair and Corrective Actions 3.6 Engineering/Technical Support 3.7 Shift Manager 3.8 Communications 3.9 Fire Fighting/Rescue Operations and First Aid/Site Access Control and Personnel Accountability 3.10 Additional Staffing Commitments
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Determination 4.4 Conclusions
5.0 ENVIRONMENTAL CONSIDERATION
6.0 "REFERENCES
NOC-AE-1 5003273 Page 2 of 18 1.0
SUMMARY
DESCRIPTION STP Nuclear Operating Company (STPNOC) proposes revisions to the South Texas Project Electric Generating Station (STPEGS), Units 1 and 2, Emergency Plan. The proposed change would result in a revision in the staff augmentation times for Emergency Response Organization (ERO) positions from 60 minutes and 75 minutes from time of notification to approximately 120 minutes from time of declaration.
2.0 DETAILED DESCRIPTION 2.1 Proposed Changes The proposed ERO revision in augmentation time would change the Emergency Response Facilities (ERFs) activation time. Therefore, the change is considered a reduction in the Emergency Plan effectiveness as defined in 10 CFR 50.54(q)(1)(iv).
In accordance with 10 CFR 50.54(q)(4), changes to a licensee's Emergency Plan that are considered a Reduction in Effectiveness (RIE) of the plan may not be implemented without prior Nuclear Regulatory Commission (NRC) approval and are required to be submitted as a License Amendment Request (LAR) in accordance with 10 CFR 50.90.
Revising the ERO augmentation would allow an increase in time for ERO members to respond to their assigned ERF, thereby increasing the geographical range in which members may reside. The benefit of the larger residential range provides a larger pool of prospective ERO members. This larger pool increases the ability to have a greater defense in depth of station personnel available to continue to provide reasonable assurance to protect the health and safety of the public.
The table below lists the proposed changes to the STPEGS Emergency Plan:
Item EmergencyChneDsrpinom nt PlanChneDsrpinCmet Reference C.4 Revised first paragraph to This change revises ERO revise augmentation time of augmentation time to 120 on-shift staff by offsite ERO minutes from declaration from members to approximately the current requirement of 60 120 minutes from and 75 minutes from declaration, notification.
2 Table C-i The 6 th and 7 th columns are This change revises ERO combined into a single, augmentation time to 120 minutes column labeled "AVAILABLE from the current requirement of 60 120 MINUTES#". The and 75 minutes.
number of responders listed in each column is summed in the resulting single combined
_____column.
NOC-AE-1 5003273 Page 3 of 18 Itm Emergency ItmPlan Change Description Comments Reference 3G.2 Revised second paragraph to. This change revises ERO change 0S0 activation time augmentation time to 120 minutes from approximately one hour from declaration from the current after notification of an Alert to -requirement of one hour from approximately 120 minutes notification.
after declaration.
4G.3 Revised fifth paragraph to This change revises ERO change TSC activation time augmentation time to 120 minutes from approximately one hour from declaration from the current after notification of an Alert to requirement of one hour from approximately 120 minutes notification.
after declaration.
5G.4 Revised second paragraph to This change revises ERO change EOF activation time augmentation time to 120 minutes from approximately one hour from declaration from the current after declaration of a Site requirement of one hour from Area Emergency or higher to notification.
approximately 120 minutes after declaration.
NOC-AE-1 5003273 Page 4 of 18 2.2 Background (Emergency Response Organization Augmentation Time Revision)
The current ERO augmentation times of 60 and 75 minutes were found to be acceptable by the NRC as documented in a Safety Evaluation Report (SER) dated May 20, 1993 (Reference 2). In the evaluation, the NRC stated that the revision from 45 and 60 minutes to 60 and 75 minutes was a minor reduction in response time compensated for by a commitment to maintain more personnel on-shift than called for in established guidance documents. At the time the SER was issued, STPNOC (then Houston Lighting
& Power Company) committed to maintain 20 personnel on-shift, seven more than required by Table B-I of NUREG 0654. The on-shift ERO staffing was later revised to its current 25 positions.
Attachment 2 provides an analysis of staffing requirements related to accident scenarios for a rapidly escalating General Emergency Steam Generator Tube Rupture and Probable Aircraft Threat with a loss of large areas of the plant due to explosions or fire. The analysis demonstrates that the minimum on-shift staff currently described by Table C-I of the STPEGS Emergency Plan is capable of performing the required mitigation and emergency response actions for at least 120 minutes without offsite ERO augmentation and without interference from collateral duties.
NUREG 0654, Table B-l, requires augmentation of a Notification/Communication functional area within 30 and 60 minutes. The State/County Communicator function is currently provided on-shift by a designated non-licensed Plant Operator (P0) without collateral duties. The NRC-Emergency Notification System Communicator is currently provided on-shift by a designated licensed ReactorOperator (RO) without collateral duties.
The Attachment 2 staffing scenarios provide the bases and ensure the health and safety of the public is maintained during a radiological event with these designated on shift communicators.
NUREG 0654, Table B-I, requires augmentation of "Radiological Accident Assessment and Support of Operational Accident Assessment" and "Protective Actions (in-plant)"
functional area within 30 and 60 minutes. These functions are currently provided on-shift by three Radiation Protection (RP) Technicians, one Chemistry Technician, and the Duty Maintenance Supervisor (DMS). The on-shift Senior Radiation Protection Technician provides radiological dose assessment to the Shift Manager (SM) for Protective Action Recommendations (PAR) without collateral duties. Two on-shift RP Technicians provide onsite surveys and offsite radiological assessment, access control, coverage for jobs, personnel monitoring and dosimetry without collateral duties. One on-shift Chemistry Technician is trained in radiological accident assessment and is available to fulfill the onsite surveys if required during an emergency without collateral duties. One on-shift DMS is trained in access control and limited dosimetry to provide protective actions with no collateral duties. Attachment 2 provides the basis for and assurance that the health and safety of the public is maintained during a radiological event with the On-shift designated RP, Chemistry and DMS resources.
NUREG 0654, Table B-l, requires augmentation of "Plant System Engineering, Repair, and Corrective Actions" functional area within 30 and 60 minutes. These functions are currently provided on-shift by a Shift Technical Advisor (STA) that is a licensed Senior Reactor Operator (SRO) and holds a Technical or Engineering degree, Mechanic, Electrician, Instrument and Control Technician, and P0. The on-shift STA duties are to monitor the core safety functions of the plant; provide advisory technical support to the
NOC-AE-1 5003273 Page 5 of 18 Shift Manager/Emergency Director (SM/ED) in the areas of thermal dynamics, reactor engineering and plant analysis with regard to the safe operation of the unit; and provide peer checks to the operations staff during the implementation and recovery phases of the accident without collateral duties. STPNOC maintains one Mechanic, two Electricians, and one Instrument and Control Technician on-shift for repair and corrective actions without collateral duties.. STPNOC maintains one P0 on-shift for repair and corrective actions with no collateral duties. Attachment 2 staffing study provides the basis for and assurance that the health and safety of the public is maintained during a radiological event with the additional designated on-shift personnel.
NUREG 0654, Table B-i, does not require a SM to augment within 30 or 60 minutes.
STPNOC's process is to maintain two SMs onsite at all times. This allows one SM to assist the current SM/ED (if needed) until relieved without collateral duties. This assistance can be in the form of communications, notifications, or the monitoring of core safety functions. Attachment 2 provides the basis for~and assurance that the health and safety of the public is maintained during a radiological event with the designated additional SM (ED qualified) on shift.
The on-shift complement is capable of maintaining the requirement of reasonable assurance to protect the health and safety of the public as described above for a prolonged time. The on-shift complement exceeds the guidance criteria established in NUREG 0654, and meets the regulatory criteria of 10 CFR 50.47, and its Appendix E.
STPNOC maintains an on-shift complement capable of fulfilling the requirements to respond to an emergency for at least 120 minutes as evaluated in Attachment 2 to this License Amendment Request.
Increasing the ERO augmentation time to the proposed approximately 120 minutes would not reduce the effectiveness of the STPEGS Emergency Plan. In addition, this 120 minute change would enlarge the residential range of those who could respond safely and thereby increase the pool of potential ERO members. This would enhance the overall skill sets, technical expertise, and position defense in depth of the ERO.
3.0 TECHNICAL EVALUATION
3.1 Emergency Response Organization Augmentation Time Revision To validate that the proposed revision in augmentation time will not degrade the ability of the on-shift staff to perform accident mitigation and emergency response functions during an emergency, STPNOC selected two staffing intensive scenarios (Attachment 2) to evaluate their impact on shift resources. The intent of the evaluation was to assess if the minimum required on-shift complement (as described by Table C-i of the STPEGS Emergency Plan) was capable of performing all procedurally required actions without being subjected to overlapping functions or collateral duties that could interfere with the completion of emergency plan responsibilities.
The use of these two scenarios represent rapidly escalating, staffing intensive events for STPNOC's evaluation purposes. Regardless of the event type or classification, STPNOC's ERO capabilities continue to be met by the on-shift complement for at least 120 minutes.
The first scenario selected was a Steam Generator Tube Rupture (SGTR) combined with elevated Reactor Coolant System (RCS) activity and a loss of offsite power (LOOP).
NOC-AE-1 5003273 Page 6 of 18 STPNOC evaluated a SGTR with cladding failure to produce an offsite dose in excess of the Environmental Protection Agency (EPA) Protective Action Guidelines (PAGs) beyond the site boundary. The LOOP resulted in the release of the primary-to-secondary leakage to the atmosphere. This event prompted the declaration of a General Emergency (GE) very shortly after event initiation.
The second scenario was a large-area fire initiated by an aircraft impact in the Protected Area, prompting the declaration of a Site Area Emergency (SAE). This scenario called for the coordination of the site Fire Brigade with offsite assistance to combat the fire.
The evaluation of both events demonstrates the on-shift staff is capable of performing operational and emergency response functions for at least 120 minutes prior to augmentation staffing relief required. Therefore, extending ERO augmentation from the present 60 and 75 minutes to the proposed approximately 120 minutes would not constitute a burden for the on-shift crew and does not reduce the protection of the health and safety of the public nor the effectiveness of the Emergency Plan.
Furthermore, these evaluations demonstrate that on-shift staffing is sufficient to support both emergency response functions and accident mitigation without overlap or conflicting collateral duties as described below.
3.2 Radiation Protection Offsite Radiological Surveys - The change in response time for offsite radiological survey responders is acceptable. There is no need to perform offsite surveys within at least the first 120 minutes of the event due to the use of installed post-accident effluent radiation monitors. Offsite surveys are not needed during the initial stages of an event due to fact that release pathways are monitored release points. In the unlikely event that an offsite survey is needed, the two on-shift RP Technicians would be available to perform the offsite survey.
During at least the first 120 minutes of an event, in-plant radiation monitoring instrumentation would be used. Onsite surveys or installed post-accident effluent radiation monitors can provide rapid indication of a release of radioactive materials and can be used for offsite dose assessment calculation purposes. These dose assessment calculations provide the necessary information for the SM/ED to evaluate and recommend protective actions to offsite response agencies. Therefore, reasonable assurance of the health and safety of the public during the initial phase (120 minutes) of the event will be maintained using either installed technology or on-shift RP Technicians.
Onsite (Out-of-Plant) and In-Plant Surveys - The need for onsite out-of-plant or in-plant surveys before the augmented responders arrive is unlikely. During the initial stages of an event, the major response activities concentrate on determining the cause of the event and placing the plant in a safe condition through plant manipulations and system alignments. In-plant radiological monitoring instrumentation provides a means by which radiological conditions can be determined during an emergency, thereby reducing the need to dispatch RP personnel into the plant.
The radiological monitoring instrumentation ensures that both RP and ERO members are kept informed of current and changing radiological conditions. In-plant radiological instrumentation provides a continuous radiological status of the rooms to ensure areas
NOC-AE-1 5003273 Page 7 of 18 required for safe shutdown are monitored. This instrumentation also provides local and remote alarming capability. Using area radiation monitors, continuous monitoring points within the plant are selected to provide indication and warning where radioactivity may be present. All of these monitors provide sufficient range to provide indication of escalating radioactive environments for severe accident conditions. In the unlikely event that an onsite or in-plant survey is needed, the on-shift RP Technicians are available to perform onsite and in-plant surveys before the augmented responders arrive. Therefore, reasonable assurance of the health and safety of the public during the event will be maintained using either installed technology or RP Technicians.
Access Control and Personnel. Monitorinq - At the time of the original site emergency plan, radiological access control was a labor intensive task. Dedicated RP Technicians were required to check dose margins, training qualifications, and to ensure workers had read and understood their Radiation Work Permit (RWP). Worker access control is now automated through the use of radiation protection work processes which have been computerized. Radiation Work Permit access control and electronic dosimeter computer systems work together to provide a fully integrated system allowing workers to sign-in on their Radiation Work Permit and to self-issue electronic dosimeters. Both systems have been used by plant workers for several years.
Worker dose margins and training qualifications are also automatically verified when the RWP access control system is used. If a worker's dose margin is inadequate or training is expired, the worker's access would be precluded and the access control system would not allow issuance of an electronic dosimeter. During the log-in process, workers acknowledge their electronic dosimeter alarm setpoints and that they have read and understand their Radiation Work Permit. The electronic dosimeter provides the worker with a continuous status of dose received and work area dose rates, and it will alarm at preset dose and dose rate alarms. Should personnel receive an alarm, they are required to exit the area immediately for additional instructions and follow-up. Use of electronic dosimeters facilitates more efficient use of RP Technicians to provide RP coverage while preserving the ALARA concept.
Access Control is maintained by the emergency responders obtaining an electronic dosimeter and entering a RWP number into the access control Computer system prior to being allowed access into the Radiological Controlled Area (RCA). No setup is required for the RWP access control computers, which allows RP Technicians time for more critical tasks during emergency response. Personnel are required to self-monitor for radioactive contamination whenever they exit any RCA. No RP involvement is necessary for this contamination monitoring activity due to the fact that the workers are trained to perform this task without supervision or oversight.
As additional defense in depth, sTP utilizes a 'grab and go' method using Direct Reading Dosimeters as emergency Electronic Personal Dosimeter (EPD's) when entering the RCA for an emergency. The EPD would then be manually entered into the database after the emergency has been resolved.
The proposed changes in RP Technician response times are supported by current advances in technology with access control and personnel monitoring processes and equipment.
NOC-AE-1 5003273 Page 8 of 18 RP Coverage (Repair, corrective actions, search and rescue, first aid and firefiflhtinfl)-
The need for RP coverage for workers in the plant before the RP Technician augmented responders arrive would be limited. In the early stages of an emergency event, the major site response activities are concentrated on determining the cause of the event, identifying the status of plant equipment, and following Emergency Operating Procedures (EOP) to place the plant in a safe condition. Only after plant status is understood and the plant is in a stable condition would operator attention be focused on corrective maintenance that may be needed to restore plant capabilities.
RP coverage would only be needed if the radiological status of a room is unknown and there is a definitive need for emergency workers to enter the room to perform a critical task. The decision to provide RP coverage may be based on plant radiological conditions as indicated by installed Area Radiation Monitors (ARMs). During the initial stages of an accident, not all areas of the plant would be affected by releases of radioactive materials.
Therefore, RP coverage would not be required for all areas. If RP coverage is deemed necessary, multiple emergency teams can be covered by the on-shift RP Technicians. In addition to the coverage provided by the RP staff, Chemistry personnel are trained in the use of specific portable radiation survey instruments so that certain on-shift functions can be performed without the assistance of RP Technicians. If RP coverage is not provided for entry into areas with low radiological risk or known radiological status, worker protection would not be an issue as emergency workers are required to wear electronic dosimeters which will alarm at preset dose and dose rate setpoints. Also, ARMs which alarm locally and remotely at preset dose rates are located throughout the plant. Should personnel receive an alarm on dose or dose rate, they are required to exit the area immediately for additional instructions and follow-up. Reasonable assurance of the health and safety of the public during an event will be maintained using either installed technology or on-shift RP Technicians.
Dosimetry - When the site emergency plan was originally issued, dosimetry issuance was a manual process requiring RP Technicians to zero and issue dosimeters, verify worker training, and verify and track radiation dose margins. As addressed in the Access Control/Personnel Monitoring Section above, access control computers are now used for issuance of battery powered electronic dosimetry with alarming capability. Worker self-issuance of electronic dosimeters has eliminated the need for RP Technicians to physically issue dosimetry with the exception of any tasks that require specialized dosimetry and/or special body placement of the dosimetry. These special dosimetry types of tasks are not expected in the initial stages of an event, but during the recovery phase when ERO augmentation would be met. The changes concerning the augmented RP Technician responders are supported by reductions in RP Technician workload due to improvements in RP processes and equipment, and would not impact the ability of the on shift staff to mitigate an emergency event.
3.3 Field Monitoring Teams During the initial stages of an event, the major response activities are concentrated on determining the cause of the event and placing the plant in a safe condition through plant manipulations and system alignments. In-plant radiological monitoring instrumentation provides a means by which radiological conditions can be determined during an emergency, thereby reducing the need to send RP personnel to obtain onsite radiological data, particularly when assessing initial radiological conditions in the early stages of an event. The radiological monitoring instrumentation ensures that both RP and ERO
NOC-AE-1 5003273 Page 9 of 18 members are kept informed of current and changing radiological conditions. In the unlikely event that onsite field monitoring is needed, the on-shift RP Technicians would be available to perform onsite field monitoring before the augmented responders arrive.
Onsite field monitoring would be performed by seven RP Technicians reporting within approximately 120 minutes. These RP Technicians would assess environmental radiation/contamination and provide input to the individual providing senior radiation protection expertise. These RP Technicians would also provide RP coverage for the field monitoring team.
Offsite field monitoring is not expected to be needed during the initial stages of an event.
During at least the first 120 minutes of an event, in-plant radiation monitoring instrumentation would be used since radiological release instrument data is readily obtainable. Onsite field monitoring or installed post-accident effluent radiation monitors can provide rapid indication of a release of radioactive materials and can be used for offsite dose assessment calculation purposes. In the unlikely event that offsite field monitoring is needed within the first 120 minutes, the two on-shift RP Technicians would be available to perform the offsite field monitoring before the augmented responders arrive.
Offsite field monitoring is performed by two Technicians and two drivers reporting within approximately 120 minutes. These Technicians would perform environmental radiation/contamination assessments and radioactive plume tracking. The Technicians would communicate and coordinate with applicable ERO supervision, and would also be responsible for the radiological protection of their field team.
3.4 Chemistry An event that results in a loss of all three fission product barriers would represent a condition that is already at a higher emergency classification than any emergency classification that could be achieved from Emergency Action Level (EAL) thresholds associated with chemistry sampling. For this condition, other fission product barrier EALs would be applied in order to facilitate timely assessment and classification of an emergency. Therefore, the Chemistry Technician's duties, early in an event, would not be required to conduct chemistry samples for fuel barrier integrity purposes.
Containment isolation would occur for accidents of this type. In order to collect and analyze a primary coolant sample following such an event, containment must be un-isolated manually. The On-shift Staffing Analysis (OSA) Report (Reference 3) appropriately assessed that these actions would not take place in the first 120 minutes following such an accident sequence.
Current STPNOC qualifications for on-shift Chemistry Technicians (E-Plan Table C-i RP Technician), qualifies these personnel to assist in radiological accident assessment through performance of onsite or offsite surveys if needed. This qualification provides additional on-shift RP capabilities. There is reasonable assurance of the health and safety of the public during an event with the additional RP Technician qualifications required for the on-shift Chemistry Technician.
NOC-AE-1 5003273 Page 10 of 18 3.5 Plant OperatorslRepair and Corrective Actions As defined in Section 2.5 of NEI 10-05, "Analysis of Repair and Corrective Action Responses," a repair or corrective action is an action that can be performed promptly to restore a non-functionai component to functional status (e.g., resetting a breaker), or to place a component in a desired configuration (e.g., open a valve), and does not require work planning or implementation of lockout or tagout controls to complete. These actions are normal operational tasks performed by plant operations personnel during their daily routine shift coverage and are trained to perform these repair and corrective action type tasks as defined in NEI 10-05.
The STP Emergency Core Cooling System (ECCS) includes three redundant, 100%
capacity trains, each containing low and high pressure safety injection pumps. Backup power for each train is provided by a dedicated emergency diesel generator. All system components, including the emergency diesel generators, meet quality standards, and are designed to withstand phenomena such as seismic events, tornadoes, floods, and fires, without a loss of function. The site Technical Specifications (TS) contain operabilitY and surveillance test requirements that assure that the ECCS is available to perform its required safety functions. The ECCS is designed such that it can perform its safety functions assuming a single failure and a loss of offsite power, as required by 10 CFR 50, Appendix A, "General Design Criteria for Nuclear Power Plants." That is, the ECCS is designed to be capable of performing its required safety functions with no required repairs or corrective actions.
Repair and corrective actions as defined in NEI 10-05 are intended to enhance plant response in various accident scenarios and are limited in scope. Although highly unlikely, these actions may be desired to ensure that the ECOS performs its required functions. If any malfunction occurred that would require prompt manual action, the manual action would most likely involve a repair or corrective action as defined in NEI 10-05, which the POs are fully capable of performing. These repair and corrective actions are to be promptly performed by POs and are not dependent on the arrival of Maintenance personnel on site. These actions involve activities such as resetting breakers and repositioning valves, prior to 120 minutes after event initiation. More complex and involved actions requiring Maintenance personnel are not expected to be performed in a prompt manner (i.e., not within 120 minutes of event initiation), since work planning and implementation of tagout controls would typically preclude such prompt completion.
3.6 Engineering/Technical Support The STA is available on-shift to monitor core/thermal hydraulics and provide the necessary technical support for the 120 minute approximate response time requested.
The STA monitors core/thermal hydraulics and provides technical support throughout the emergency event until relieved by the augmented ERO.
The STA is trained as an advisor to the Control Room operating shift per NUREG-0737
'Clarification of TMI Action Plan Requirements.' In 1990, additional guidelines were developed by the Institute of Nuclear Plant Operations (INPO) for the training of STAs.
This is detailed in the guidance document INPO 90-003, 'Guidelines for the Training and Qualification of Shift Technical Advisors.' The STA performs independent assessments of plant operating concerns, technical support, appropriate corrective actions, analysis of events and their effects, effectiveness of response(s) to emergent conditions,
NOC-AE-1 5003273 Pagell1of18 classifications of emergencies, protection of the public, and any other actions related to critical safety functions and plant safety during abnormal and emergency situations.
STP's Plant Computer System was upgraded to an Integrated Computer System (lCS).
This computer system provides plant personnel, including the STA, the capability to monitor and trend plant parameters in real time, including primary coolant system parameters, reactor core thermal performance parameters, emergency core cooling system parameters, meteorological data, containment isolation status, and radiation monitor readings.
The Emergency Operating Procedures (EQOPs) and Severe Accident Management Guidelines (SAMGs) were implemented to improve the quality of operational information and guidance during emergency events. These improvements in the monitoring of plant parameters via the lCS, and in emergency procedures, have reduced the burden on the STA during postulated events, allowing the STA to perform monitoring and technical support in support of the Emergency Plan (EP) response without impacting their primary ERO actions. Therefore, reasonable assurance of the health and safety of the public during an event will be maintained using installed advances in computerized plant monitoring technology.
3.7 Shift Manager The SM is responsible for the overall assessment of emergency conditions and becomes the ED. The SM has the overall responsibility for operational decisions involving the safety of the plant and its personnel, and for making PARs to offsite agencies for the protection of the public during an emergency event.
The SM implements the site EP through the use of specific Emergency Plan Implementing Procedures (EPIP). SMs and STAs are trained in these activities as part of their initial qualification training and annual requalification training, and are required to demonstrate competence in these areas during annual simulator training sessions and emergency drills.
While the SM has overall responsibility for operational decisions involving the safety of the plant, the Unit Supervisor (US) and ROs within the control room have the direct responsibility of operating the plant during an emergency situation. The US and ROs would implement the appropriate EOPs for the particular event and operate the plant. The SM would oversee the US and RO activities while implementing the site EP and maintain situational awareness of the event as it unfolds. The SM has overall responsibility for the emergency response event until this responsibility is transitioned to the ED in the Technical Support Center (TSC) or Emergency Operations Facility (EOF). The SM continues to maintain control of plant operations after overall emergency response responsibilities have been turned over to a TSC or EOF ED.
Initial SM training requires that the SM demonstrates knowledge and understanding of emergency planning procedure processes. These processes include making required notifications, recommending protective actions to public officials, determining protective measures for onsite personnel, managing the plant response to the event while implementing the EP, understanding the typical decisions concerning priorities in transitioning from normal operations to coping with an emergency event and implementation of the EP, and assigning priorities to activities to ensure resources are
NOC-AE-1 5003273 Page 12 of 18 appropriately directed to manage the plant condition.
The proficiency of the on-shift operations staff to perform critical emergency planning functions, without support from off-shift/offsite resources, is evaluated during operations continuing training and annual license exams. Emergency response drill objectives are integrated into evaluated simulator sessions for the Control Room staff. During these sessions, there is no augmentation of the on-shift operations staff with additional personnel, and ther~e is not a turnover of emergency response duties or responsibilities to the TSC or EOF. The shift Control Room staff is expected to perform all emergency response tasks that are required by the simulated scenario, in conjunction with other required actions that are directed by normal, abnormal, and EOPs. Evaluated emergency response tasks include emergency classification, notification, offsite dose assessment, formulation, and simulated implementation of PARs for offsite authorities.
The ability of the SM to implement the site EP while maintaining command and control of the plant is also verified during emergency planning drills and exercises. Emergency planning drills and exercises require the SM to perform required emergency planning duties through the Unusual Event (UE), Alert, Site Area Emergency (SAE), or General Emergency (GE) stages of scenarios while maintaining command and control of the plant response in accordance with plant operating procedures.
The required emergency planning actions and notifications for the SM specified in site emergency planning procedures for the UE, Alert, SAE, and GE classifications are very similar. For each classification, the SM, or a designee such as the communicator, is required to announce the emergency on the site public address system; sound the emergency siren if required; notify county, state, and NRC officials; perform accountability if required; ensure the emergency response data system is activated; and initiate onsite monitoring and habitability. The only difference between the UE, Alert, SAE, and GE is that the GE requires a PAR. The SMs practice developing and issuing PARs as part of their normal training, drills, or exercises. Otherwise, the required emergency actions and notifications specified in emergency planning procedures are virtually the same between an Alert, SAE, and GE.
In summary, operator training and emergency planning drills/exercises are sufficient to demonstrate that the SM can maintain situational awareness of the event, while performing all required emergency planning functions, without assistance from augmented staff. This training demonstrates the reasonable assurance of protecting the health and safety of the public for a protracted time up to 120 minutes.
3.8 Communications NUREG 0654, Table B-i, requires augmentation of a Notification/Communication functional area within 30 and 60 minutes. The State/County Communicator function is currently provided on-shift by a designated non-licensed Plant Operator (P0) without collateral duties. The NRC-Emergency Notification System Communicator is currently provided on-shift by a designated licensed Reactor Operator (RO) without collateral duties. Each of these communicators have access to a dedicated Operator Communications Panel (OCP) that is powered with normal plant 120 Volt AC and backed up with non-Class 1 E DGs and an 8-hour battery.
NOC-AE-1 5003273 Page 13 of 18 3.9 Fire Fighting/Rescue Operations and First Aid/Site Access Control and Personnel Accountability NUREG-0654, Table B-i specifies that the Fire Brigade Major Functional Area be staffed in accordance with the Technical Specifications This section does not contain specific 30 and 60 minute augmentation response infor-mation other than a reference to local support. STPEGS is not requesting a change for the Fire Fighting Major Functional Area. STPNOC has a .5-person fire brigade crew that is available onsite at all times. The availability of an on-shift fire brigade allows the other on-shift personnel to perform their required emergency planning duties without the added tasks of fire brigade or first-aid duties.
NUREG-0654, Table B-i specifies Rescue Operations and First Aid be staffed on-shift by shift personnel assigned other functions. This section does not contain specific 30 and 60 minute augmentation response information other than a reference to local support. STPEGS maintains an on-shift Rope Rescue Team and Medical Responders within our Security on-shift staffing requirements. STPEGS is not requesting a change for the Rescue Operations and First Aid Major Functional Area.
NUREG-0654, Table B-i specifies Site Access Control and Personnel Accountability
- positions on-shift by Security Personnel and in accordance with Security Plan. STPEGS is not requesting a change for the Site Access Control and Personnel Accountability Major Functional Area.
3.10 Additional Staffing Commitments On November 25, 2014, STP Nuclear Operating Company (STPNOC) submitted the Phase 2 Staffing Assessment to the NRC in response to the 10 CFR 50.54(f) request for information regarding Near-Term Task Force (NTTF) Recommendation 9.3 for Emergency Preparedness programs. Following this submittal, STPNOC performed a revalidation of the assessment results using the final validated FLEX Support Guidelines (FSGs) and any applicable new procedures that were not complete when the staffing assessment tabletop was performed.
STPNOC performed the revalidation of the staffing assessment results between April 13, 2015 and April 21, 2015. The results of the revalidation showed that effectively implementing the STP diverse and flexible coping (FLEX) strategies requires two maintenance personnel per unit. One Instrumentation and Control (l&C) Technician and one Electrician are currently included in the minimum staffing requirements in the STP Emergency Plan. In order to effectively implement STP's FLEX strategies with two maintenance personnel in each unit, a Mechanic and either an additional l&C Technician or an Electrician are needed.
On July 2, 2015, STPNOC submitted a "Supplement to Response to Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident Phase 2 Staffing Assessment" (Reference 4).This submittal identified that the Mechanic and second Electrician or l&C Technician, hereafter referred to as the two additional maintenance personnel, are not included in the minimum staffing requirements in our Emergency Plan. They are two of the 'double-asterisk' positions listed in Table B-i of NUREG-0654 that could be covered by shift personnel assigned other functions.
NOC-AE-1 5003273 Page 14 of 18 While these two individuals are not part of the minimum on-shift staff as required by the STP Emergency Plan, these two maintenance personnel are currently procedurally obligated (Reference 4, NRC Commitment 12-11658-584) to be onsite at all times to support the station Integrated Maintenance Team (IMT).
With .the addition of the ERO qualified Mechanic and either an I&C Technician or an Electrician, the current minimum on-shift ERO staff would be augmented with an additional two (2) on-shift responders at the onset of an emergency. These additional responders are available to support the emergency response efforts without the assignment of collateral duties that would adversely affect the ability to execute Emergency Plan functions. This additional on-shift staffing enhances the reasonable assurance of protecting the health and safety of the public for a protracted time up to 120 minutes.
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.47(b)(1 ) and (2) establish standards applying to emergency response plans:
The onsite and, except as provided in paragraph(d) of this section, offsite emergency response plans for nuclear power reactors must meet the following standards (I) Primary responsibilitiesfor emergency response by the nuclfear facility licensee and by State and local organizationswithin the Emergency Planning Zones have been assigned, the emergency responsibilitiesof the various support organizationshave been specifically established, and each principalresponse organization has staff to respond and to augment its initial response on a continuous basis.
(2) On-shift facility licensee responsibilitiesfor emergency response are unambiguously defined, adequate staffing to provide initial facility response in key functional areas is maintainedat all times, timely augmentation of response capabilitiesis available and the interfaces among various onsite response activities and offsite support and response activities are specified.
The existing STPEGS Emergency Plan includes onsite and offsite emergency response plans that meet the requirements listed above. This License Amendment Request proposes to revise the current staff augmentation response time from 60 minutes and 75 minutes to approximately 120 minutes. An evaluation of staffing intensive scenarios based on design basis accidents has been performed that confirms that this revision to augmentation response time will not adversely impact the performance of required emergency functions. The revised augmentation response time, to the STPEGS Emergency Plan, will continue to have onsite and offsite emergency response plans that meet 10 CFR 50.47(b) and continue to provide reasonable assurance that adequate protection of the health and safety of the public will be maintained in the event of a radiological emergency.
Proposed changes to the STPEGS Emergency Plan to realign the Emergency Response Organization (ERO) do not impact on-shift personnel and therefore do not degrade the
NOC-AE-1 5003273 Page 15 of 18 ability of on-shift personnel to respond to an emergency. The proposed realignment is limited to augmented ERO personnel and continues to establish the response activities and staffing levels recommended in Table B-i of NUREG-0654 (Reference 1).
Therefore, the Emergency Plan will continue to employ staffing that meets the requirements of 10 CER 50.47(b).
10 CFR 50.54(q) establishes requirements for changes to emergency plans:
(q) Emergency plans.
(1)(iv) Reduction in effectiveness means a change in an emergency plan that results in reducing the licensee's capablilityto perform an emergency planning function in the event of a radiologicalemergency.
(2) A holder of a license under this part, or a combined license under part 52 of this chapter after the Commission makes the finding under § 52.103(g) of this chapter, shall follow and maintain the effectiveness of an emergency plan that meets the requirements in Appendix E to this part and, for nuclear power reactorlicensees, the planning standards of § 50.4 7(b).
(4) The changes to a licensee's emergency plan that reduce the effectiveness of the plan as defined in paragraph(q) (1)(iv) may not be implemented without priorapproval by the NRC. A licensee desiring to make such a change after February21, 2012 shall submit an application for an amendment to its license. In addition to the filing requirements of §§ 50.90 and 50.91, the request must include all emergency plan pages affected by that change and must be accompaniedby a forwarding letter identifying the change, the reason for the change, and the basis for concluding that the licensee's emergency plan, as revised, will continue to meet the requirements in Appendix E to this part and, for nuclearpower reactor licensees, the planning standardsof§ 50.4 7(b).
The existing STPEGS Emergency Plan meets the planning standards of 10 CFR 50.47(b) and 10 CFR 50 Appendix E as required by 10 CER 50.54(q). This LAR proposes to change the current staff augmentation response times from 60 minutes and 75 minutes to approximately 120 minutes. The revision in augmentation response times is supported by the results of an evaluation of staffing intensive scenarios which found that the on-shift crew is capable of performing emergency response functions without undue distraction by accident mitigation actions. This proposed change to approximately 120 minutes is considered a reduction in effectiveness as defined by 10 CFR 50.54(q)(1)(iv) and requires submittal based on 10 CFR 50.54(q)(4). Therefore, STPNOC is submitting this LAR pursuant to 10 CER 50.90.
The scenario analysis confirms that lengthening the staff augmentation response times will not negatively impact the performance of required emergency response functions, the Emergency Plan will continue to meet the requirements of 10 CFR 50.54(q)(2) by maintaining the effectiveness of the Plan in accordance with requirements of 10 CFR 50 Appendix E and the planning standards of 10 CFR 50.47(b).
NUREG-0654/FEMA-REP-1, Revision 1 (Reference 1), Section II.B provides evaluation criteria for the onsite emergency organization:
NOC-AE-1 5003273 Page 16 of 18 ll.B.5 Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity. For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table B-i entitled, "Minimum Staffing Requirements for Nuclear Power Plant Emergencies." The minimum on-shift staffing levels shall be as indicated in Table B-I. The licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency. This capability shall be as indicated in Table B-I. The implementation schedule for licensed operators, auxiliary operators and the shift technical advisor on shift shall be as specified in the July 31, 1980 letter to all power reactor licensees. Any deficiencies in the other staffing requirements of Table B-I must be capable of augmentation within 30 minutes by September 1, 1981, and such deficiencies must be fully removed by July 1, 1982.
The current STPEGS Emergency Plan staffing in Table C-i meets the intent of NUREG-0654, Table B-i. While Table B-i of NUREG-0654 provides guidance for staff augmentation at 30 minutes and 60 minutes, the current Emergency Plan establishes augmentation times of 60 minutes and 75 minutes as previously approved by the NRC.
The LAR proposes to change the current staff augmentation response time from 60 minutes and 75 minutes to approximately 120 minutes. An evaluation of staffing-intensive scenarios has been performed that confirms that this change in augmentation response time will not adversely impact the performance of required emergency functions. This change has been reviewed and concurrence has been received by the State of Texas and Matagorda County.
4.2 Precedent None.
4.3 No Significant Hazards Consideration Determination STP Nuclear Operating Company (STPNOC) proposes revisions to the South Texas Project Electric Generating Station (STPEGS), Units 1 and 2, Emergency Plan. The proposed changes would result in a revision in the staff augmentation time for certain ERO positions from 60 minutes and 75 minutes to approximately 120 minutes.
STPNOC has evaluated whether a Significant Hazards Consideration is warranted with the proposed change by addressing the three criteria set forth in 10 CFR 50.92(c) as discussed below:
Criterion 1:
Does the proposed amendment involve a significant increase in the probability or consequence of an accident previously evaluated?
Response: No.
NOC-AE-1 5003273 Page 17 of 18 The proposed revision to staff augmentation times has no effect on normal plant operation or on any accident initiator or precursors and does not impact the function of plant structures, systems, or components. The proposed changes do not alter or prevent the ability of the Emergency Response Organization to perform their intended functions to mitigate the consequences of an accident or event.
Therefore, the proposed Emergency Plan change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
Criterion 2:
Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed change does not impact the accident analysis. The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed), a change in the method of plant operation, or new operator actions. The proposed change does not introduce failure modes that could result in a new accident, and the change does not alter assumptions made in the safety analysis. The proposed change revises the staff augmentation response times in the Emergency Plan. The proposed changes do not alter or prevent the ability of the Emergency Response Organization to perform their intended functions to mitigate the consequences of an accident or event.
Therefore, the proposed changes does not create the possibility of a new or different kind of accident from any accident previously evaluated.
Criterion 3:
Does the proposed change involve a significant reduction in margin of safety?
Response: No.
Margin of safety is associated with confidence in the ability of the fission product barriers (i.e., fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public. The proposed change is associated with Emergency Plan staffing augmentation and does not impact operation of the plant or its response to transients or accidents. The change does not affect the Technical Specifications. The proposed change does not involve a change in the method of plant operation and no accident analyses will be affected by the proposed change. Safety analysis acceptance criteria are not affected by the proposed change. The revised Emergency Plan will continue to provide the necessary response staff with the proposed change. Therefore, the proposed change is determined to not adversely affect the ability to meet the requirements of 10 CFR 50.54(q)(2), 10 CFR 50 Appendix E, or the emergency planning standards described in 10 CER 50.47(b).Therefore, the proposed change does not involve a significant reduction in a margin of safety.
NOC-AE-1 5003273 Page 18 of 18 4.4 Conclusions Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
5.0 ENVIRONMENTAL CONSIDERATION
STPNOC has determined that the proposed change would not change requirements with respect to use of facility component within the restricted area as defined by 10 CFR 20, nor would it change inspection or surveillance requirements. STPNOC has evaluated the proposed change and has determined the change does not involve: (i) a significant hazards consideration, (ii) significant change in the types or significant increase in the amounts of an effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.
Accordingly, the proposed amendment meets the eligibility criterion for a categorical exclusion set forth in 10 CFR 51 .22(c)(9). Therefore, STPNOC concludes that, pursuant to 10 CFR 51 .22(b), no environmental impact statement or environmental assessment is required to be prepared in connection with the proposed amendment.
6,0 REFERENCES
- 1. NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1, U.S. Nuclear Regulatory Commission and Federal Emergency Management Agency, November 1980
- 2. Letter from Lawrence E. Kokojka to William T. Cottle, dated May 20, 1993, "Safety Evaluation Report: South Texas Project Units 1 and 2 - Revision to Emergency Plan Staff Augmentation Times" (ADAMS Legacy Accession Number 9305280305)
- 3. NEI 10-05 "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities"
- 4. Letter from G.T. Powell, STPNOC, to NRC Document Control Desk, "Supplement to Response to Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident- Phase 2 Staffing Assessment", July 2, 2015 (NOC-AE-1 5003255)
NOC-AE-1 5003273 Attachment 1 ATTACHMENT I South Texas Project Electrical Generating Station Emergency Plan Sections C and G
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION EMERGENCY PLAN SECTION C C.4 Emergency Response Organization Those members of the Emergency Response Organization who are not on site at the time of the emergency shall be able to augment the Onshift Response Organization within approximately 120 minutes of an emergency declaration as specified in Table C-i to provide manning levels recommended in NUREG-0654.
The Technical Support Center and Operations Support Center Station Emergency Response Organization are activated at an Alert emergency classification. Positions for these facilities are depicted in Figure C-2 & Figure C-3. The Emergency Operations Facility and Joint Informlation Center are staffed at the Alert and may be activated at the discretion of the Emergency Director. Positions for these facilities are depicted in Figure C-4 & Figure C-5. The Emergency Operations Facility and Joint Information Center shall be activated at a Site Area Emergency. The Emergency Operations Facility dose projection capability is activated at an Alert classification. If during an Unusual Event the trending of plant conditions indicates the need for additional support, the Emergency Director can activate all or part of the Station Emergency Response Organization to report to the Technical Support Center, Emergency Operations Facility, Joint Information Center or Operations Support Center. The process to maintain a fully staffed Emergency Response Organization is described in 0PGP05-ZV-0003, Emergency Response Organization.
Modifications to the Emergency Response Organization may be made by the Emergency Director as required by the complexity of the emergency.
The following key Emergency Response Organization positions report to the Technical Support Center, the Operations Support Center, and the Emergency Operations Facility, and are added to the Onshift Response Organization during the declaration and mitigation of an Alert, Site Area Emergency or General Emergency. These positions can be activated by the Emergency Director at an Unusual Event emergency classification.
C.4.1 Technical Support Center Manager The Technical Support Center Manager reports to the Technical Support Center at an Alert and provides guidance and advice to the Control Room on plant design and coordinating engineering activities in the areas of analysis, design modifications, system response, and offsite protective action recommendations.
The Technical Support Center Manager may assume the position of Emergency Director from the Shift Manager.
E-PLAN\SEC-C Page 9 of 23 Revision ICN 20-xx Xx/xx/xx
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION EMERGENCY PLAN SECTION C TABLE C-i Page 1 of 3 MINIMUM STAFFING REQUIREMENTS (STPEGS)
(Including Capability for Additional Staffing)
MAJOR POSITION UNIT 1 UNIT 2 ONSITE AVAILABLE FUNCTIONAL TITLE ONSHIFT ONSIIIFT* ONSHIFT 120 MINUTES #
AREA
- Shift Manager -- 2 Unit Supervisor 1 1-Plant Operations Reactor2-and Assessment Operators2 of Operational Plant Operators 2 2-Aspects Shift Technical -1 **
Advisor Plant Operations1 4 Discipline Lead Emergency Direction and Control *** Shift Manager 1"** 1"*-
(Emergency Director)
Notification/Corn2 munications Emergency Director Radiological Senior Health Accident Physics Assessment and Expertise (Dose-1 Support of Assessment)
Operational RP Technicians Accident (onsite/offsite--27 Assessment surveys)
Chemistry Technician-1 E-PLAN\SEC-C Page 15 of 23 Revision ICN 20-xx Xx/xx/xx
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION EMERGENCY PLAN SECTION C TABLE C-i Page 2 of 3 MINIMUM STAFFING REQUIREMENTS (STPEGS)
(Including Capability for Additional Staffing)
MAJOR POSITION UNIT 1 UNIT 2 ONSITE AVAILABLE FUNCTIONAL TITLE ONSHIFT* ONSHIFT* ONSLHFT 120 MINUTES AREA Shift Technical-Advisor Nuclear
-- - 1 Plant System Engineer Engineering Electrical
-- - 1 Engineer Mechanical Engineer--1 Operator **1*
Repair and Mechanical - 1l** 1 Corrective Maintenance Actions Electrical Maintenance -1~ N I&C Technician - -1 RP Technicians (Access ControlIRP Coverage for corrective Protective actions, search -- 2** 4 Actions and rescue, first aid, and fire-fighting/Person nel Monitoring!
Dosimetry)
Plant Fire Brigade Fire Suppression Operations -- per Technical Local Support personnel Specifications E-PLAN\SEC-C Page 16 of 23 Revision ICN 20-xx Xx/xx/xx
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION EMERGENCY PLAN SECTION C TABLE C-i Page 3 of 3 MINIMUM STAFFING REQUIREMENTS (STPEGS)
(Including Capability for Additional Staffing)
MAJOR POSITION UNIT 1 UNIT 2 ONSITE AVAILABLE FUNCTIONAL TITLE ONSHIFT* ONSHIFT* ONSIIIFT 120 MINUTES AREA#
Rescue ~~Plant Protection-2*LoaSupr Operations and Personnel2*LoaSupr First Aid Plant Protection Site Access Personnel Control and (Security/Corn All per Personnel munications/Per Security Plan Accountability sonnel Accountability)
TOTAL 5 5 15 21 Notes: *For each unaffected unit in operation, maintain at least one Unit Supervisor, two Reactor Operators, and two Plant Operators. In accordance with Section 6.0 of the Technical Specifications for each unit, the shift crew composition may be less than the minimum number of operators (licensed or non-licensed) shown above for a period of time not to exceed two (2) hours in order to accommodate unexpected absences of on-duty shift crew members, provided immediate actions are taken to restore the crew composition. The minimum staff for a unit in cold shutdown will be one Senior Reactor Operator, one Reactor Operator, and one Plant Operator for that unit.
- These positions may be covered by onshift personnel assigned other functions.
- ** Overall, direction of emergency response to be assumed by the Emergency Director at the Emergency Operations Facility when all centers are fully manned. Direction of minute-to-minute facility operation remains with senior manager in the Technical Support Center or Control Room.
- Although such a short response time may be achieved in many cases, it is not possible to assure this response time in every instance.
- This position is filled by personnel with plant operations experience E-PLAN\SEC-C Page 17 of 23 Revision ICN 20-xx Xx/xx/xx
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION EMERGENCY PLAN SECTION G G EMERGENCY RESPONSE FACILITIES This section of the Plan describes the location of equipment and facilities maintained by the Station for use in the event of an emergency at the Station. The design of the Station's Emergency Response Facilities meets the intent of Supplement 1 to NUREG-073 7, Clarification of Three Mile Island Action Plan Requirements, and NUJREG-0696, Functional Criteria for Emergency Response Facilities. The locations of the Emergency Response Facilities are indicated on Figures G-1 and G-4. A typical listing of emergency supplies and equipment maintained by the Station is given in Table G- 1. Plant records necessary to perform the functions of each onsite facility are available in and/or at each onsite facility listed in Table G-2. A detailed list of Control Room equipment and instrumentation is provided in Chapter 7 of the Updated Final Safety Analysis Report. The equipment and facilities comprising the Operations Support Center, Technical Support Center, and Emergency Operations Facility do not perform any safety-related functions.
Their design assures that any fault or malfunction does not compromise any safety-related equipment, components or structures.
G. 1 Control Room The Station Operations staff will function from the Control Room for each level of emergency at the Station. The Control Room is radiologically hardened and seismically designed to withstand all credible events that could occur at the Station.
The Control Room is the primary facility at the Station in which Station conditions are monitored and controlled and where corrective actions are initiated to mitigate any abnormal occurrence. In the event the Control Room must be evacuated, a remote Auxiliary Shutdown Panel has been provided for safe shutdown of the Station. Control Room habitability and radiation monitoring capabilities, as well as Auxiliary Shutdown capability, are discussed in detail in the Final Safety Analysis Report.
G.2 Operations Support Center The Operations Support Center is the onsite emergency response staging area, separate from the Control Room and the Technical Support Center. The Operations Support Center is used for assembling the plant emergency response teams and other Station personnel. A typical layout for each unit's Operations Support Center is provided in Figure G-2. If the Operations Support Center must be evacuated, the personnel from the Operations Support Center will relocate to the Operations Support Center of the unaffected unit.
Communications are provided between the Operations Support Center, Technical Support Center, Control Room and the Emergency Operations Facility. Personnel are assigned duties in support of emergency response operations by the Operations Support Center E-PLAN\SEC-G Page 1 of 23 Revision 20 05/01/02
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION EMERGENCY PLAN SECTION G Coordinator, located in the Operations Support Center on the 41' elevation of the Mechanical Auxiliary Building of each unit. An emergency Assembly Area is located in the Electrical Auxiliary Building. This emergency Assembly Area is utilized for the accountability of Station personnel, other than non-essentials, without Emergency Response Organization assignments during the assembly and accountability process.
The Operations Support Center is designed to be fully activated within approximately one hundred twenty (120) minutes after declaration of an Alert, in conjunction with the Technical Support Center. Radiation levels in and around the Operations Support Center are assessed during radiological events.
G.3 Technical Support Center The Technical Support Center is the onsite technical support facility for emergency response. The Station provides one Technical Support Center for each unit. Each facility is located on the 72-foot elevation of the respective unit's Electrical Auxiliary Building and is within a two minute walking distance from the unit's Control Room as described in the Updated Final Safety Analysis Report. In the event of a site-wide emergency, the Unit 1 Technical Support Center will be activated. Otherwise, the Technical Support Center in the affected unit will be activated. These facilities are equipped to enable response personnel to monitor the course of an accident and plan corrective and recovery actions.
Personnel access to the activated Technical Support Center is controlled. During periods of activation, the affected Technical Support Center is staffed continuously to provide plant management and technical support to plant operations personnel and to relieve the reactor operators of peripheral duties and communications not directly related to reactor system manipulations. The typical layout of each unit's Technical Support Center is provided in Figure G-3.
Each Technical Support Center is provided sufficient radiological protection and monitoring equipment to assure that radiation exposure to any person working in the activated Technical Support Center will not exceed five (5) remn TEDE or twenty-five (25) rem thyroid CDE during the duration of a declared accident. Should the affected unit's Technical Support Center become uninhabitable, the Emergency Response personnel within the Technical Support Center can relocate to other emergency response facilities and resume their assigned functions.
The Heating, Ventilation and Air Conditioning (HVAC) for each Technical Support Center is designed to provide a suitable environment during nonnal and post-accident operation, including protection from post-accident radiological releases. The Technical Support Center HVAC System will be verified when positioned in the recirculation mode. Each E-PLAIN\SEC-G Page 2 of 23 Revision ICN 20-xx Xx/xx/xx
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION EMERGENCY PLAN SECTION G respective Technical Support Center diesel generator has the capability of continuous operation for a minimum of seven days.
Radiation monitoring and smoke detection capability, alarms and indications are provided in each respective Technical Support Center. Detection of high airborne levels of radioactive materials causes each respective Technical Support Center HVAC to automatically switch over to activated charcoal filtration. Detection of smoke levels above tolerance causes the system to automatically isolate.
Each Technical Support Center is designed to be fully activated within approximately one hundred twenty (120) minutes after declaration of an Alert, in conjunction with activation of the Operations Support Center. The Technical Support Center may activate simultaneously with activation of the Operations Support Center.
G.4 Emergency Operations Facility The Emergency Operations Facility is located in Bay City, Texas at 4000 Avenue F, approximately 12.5 air miles north-northeast of the Station. Figure G-4 depicts the location compared to the site. The floor plan of the Emergency Operations Facility is depicted on Figure G-5. When activated, the Emergency Operations Facility serves as the primary location for the following typical functions:
- Coordination between Station and non-station organizations, such as the Department of State Health Services;
- A coordination center for the preparation and approval of news releases and bulletins for release of information to the media and notifications to offsite agencies;
- A central point for coordinating all Station offsite dose projection and radiological monitoring activities at the time of the emergency; and
- The primary location for coordinating both technical and non-technical support activities of personnel brought in to assist Station personnel.
The Emergency Operations Facility provides for management of overall Station emergency response, coordination of radiological and environmental assessment, determination of E-PLAN\SEC-G Page 3 of 23 Revision ICN 20-xx Xx/xx/xx
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION EMERGENCY PLAN SECTION G recommended offsite protective actions, and coordination of emergency response activities with Federal, State, and County authorities. The Emergency Operations Facility can be fully activated within approximately one hundred twenty (120) minutes of a declaration of Site Area Emergency or higher. When activated, the Emergency Operations Facility will be staffed by Emergency Response personnel.
A qualified Emergency Operations Facility Director will manage activities in the Emergency Operations Facility.
Resources are provided in the Emergency Operations Facility for the acquisition, display, and evaluation of radiological and meteorological data and containment conditions necessary to perform accident assessment and determine protective measures. This equipment and instrumentation is described in Section H of this Plan.
The Emergency Operations Facility provides for occupancy by Nuclear Regulatory Commission, Federal Emergency Management Agency, State, County, American Nuclear Insurers, and Station Emergency Response Organization personnel.
The Emergency Operations Facility provides sufficient radiological protection and monitoring equipment to assure that radiation exposure to any person working in the Emergency Operations Facility will not exceed five (5) remn TEDE or twenty-five (25) remn thyroid CDE during the duration of a declared emergency. The Emergency Operations Facility has the capability for decontaminating personnel and providing protective clothing.
The Emergency Operations Facility has a backup generator that can provide full load capability should power be lost. Radiation monitoring and smoke detection capability, alarms and indications are provided in the Emergency Operations Facility.
E-PLAN'.*SEC-G Page 4 of 23 Revision ICN 20.-xx Xx/xx/xx
NOC-AE-5003273 Attachment 2 ATTACHMENT 2 Staffing-Related Accident Scenarios
NOC-AE-1 5003273 Attachment 2 Page 1 of 5 Staffinq-Related Accident Scenarios STPNOC conducted on-shift staffing analyses of two scenarios considered to be the most intensive in the utilization of on-shift staff. The results of the analyses demonstrate that on-shift personnel are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the Emergency Plan. For the purpose of the analyses, 120 minutes from the time of event declaration was used as the time period for the conduct of on-shift ERO response actions.
The two scenarios analyzed are a steam generator (SG) tube failure (described in Chapter 15 of the Updated Final Safety Analysis Report (UFSAR)) and a large-area fire caused by an aircraft impact in the Protected Area.
Scenario 1: SG Tube Failure - UFSAR 15.6.3 This design basis accident (DBA) scenario results in a General Emergency with offsite radiological doses that exceed the EPA protective action guidelines (PAGs) and necessitate protective action recommendations (PARs).
The accident initiates at power and involves the complete severance of a single steam generator tube. The reactor trip automatically trips the turbine and with a coincident loss of offsite power, the steam dump valves automatically close to protect the condenser. The steam generator pressure rapidly increases resulting in steam discharge to the atmosphere through the steam generator PORVs (and safety valves if their setpoint is reached). When offsite power is not available, the pressure relief system on the ruptured SG discharges to the atmosphere rather than the condenser. This increases the environmental effect of the steam generator tube rupture (SGTR).
The reactor coolant is contaminated with fission products at a level necessary to support the offsite radiological conditions, thus a non-realistic damage source term input is necessary (DBA accident corresponds to continuous operation with a limited amount of defective fuel rods). The accident leads to an increase in contamination of the secondary system due to leakage of radioactive coolant from the reactor coolant system (ROS).
Normal operation of the various plant control systems is assumed, with the exception of the failure of the condenser steam dump system which allows discharge of activity to the atmosphere via the steam generator power-operated relief valves (and safety valves if their setpoint is reached).
The magnitude of the break flow is such that recovery procedures can be carried out on a time scale that ensures that break flow to the secondary system is terminated before water level in the affected steam generator rises into the main steam pipe.
NOC-AE-1 5003273 Attachment 2 Page 2 of 5 Initial Conditions: 100% power, equilibrium conditions, core burnup 10,000 MWD/MTU Abnormal Conditions: Coolant activity (gap failure) is sufficient to result in an offsite dose that exceeds the EPA Protective Action Guidelines beyond the site boundary.
Scenario Events: Guillotine break of one SG tube.
Coincident loss of offsite power upon reactor trip. SG PORV failed open the ruptured SG This event prompted the declaration of a General Emergency under Initiating Condition FG1, Loss of Any Two Barriers and Potential Loss or Loss of Third Barrier.
For the purposes of this scenario, the onsite staffing was assumed to be limited to the on-shift complement listed in Table C-i of the STPEGS Emergency Plan. No augmented staffing was assumed.
The methodology employed to assess the impact of the event on onsite staffing analyzed the staffing requirements for the following procedures:
0POP05-EO-EO00 Reactor Trip or Safety Injection 0POP05-EO-EO30 Steam Generator Tube Rupture In addition, staffing requirements for emergency response related procedures (i. e.,
classification, notification, assembly and accountability, protective action recommendations, dose assessment, etc.) were also considered for performance in parallel with the two procedures above.
The staffing assessment for this event evaluated the procedurally required actions against the availability of on-shift personnel. The assessment examined the duration of significant tasks in order to determine if overlaps occurred and to detect if personnel with assigned emergency response functions also had collateral duties that could distract the individuals from those functions. No overlaps or distracting Collateral duties were noted.
This scenario intensively employs Radiation Protection and Chemistry personnel to provide site surveys, personnel monitoring, offsite dose assessment, and chemical analyses. The required minimum on-shift staffing includes three Radiation Protection Technicians and one Chemistry Technician. This complement is sufficient to meet procedural requirements.
In conclusion, the results of the analysis demonstrate that the minimum onsite staff described by Table C-i of the STPEGS Emergency Plan is capable of performing the required mitigation and emergency response actions for at least 120 minutes without augmentation and without interference from collateral duties. Furthermore, the analysis indicates that all required emergency response actions, aside from periodic notification updates, are completed within 60 minutes of event initiation.
NOC-AE-1 5003273 Attachment 2 Page 3 of 5 Scenario 2: Probable Aircraft Threat with Loss of Larae Areas of the Plant Due to Explosion or Fire This event includes all emergency response actions taken prior to an aircraft impact in accordance with Regulatory Guide 1.214 for an aircraft threat that is less than 5 minutes from the site, including the dispersal of the fire brigade away from target areas. These actions should generally reflect those listed in 10 CFR 50.54(hh)(1), as expanded upon in Regulatory Guide 1 .214, and others required by the emergency plan.
The event consists of notification to the Unit 1 Shift Manager from the NRC Headquarters Operations Officer (HOO) that an Imminent Aircraft Threat has been declared for STPEGS.
The event continues with the aircraft impacting the site resulting in loss of large areas of the plant due to explosions or fire as reflected by 10 CFR 50.54(hh)(2).
Initial Conditions: 100% power, equilibrium conditions, end of core life Abnormal Conditions: None Scenario Events: At T=0 the Shift Manager receives a phone call from the NRC HQ HOO that a Probable Aircraft Threat (impact >5 and <30 minutes) has been issued for STP. At T+10 minutes, the aircraft impacts inside the Protected Area, creates a large burning pool of jet fuelI consuming the Fire Protection pumps and storage tanks.
Notes: This scenario constitutes a dual unit event. Validation of authenticity of the notification is confirmed.
This scenario results in the initial declaration of an Alert under Initiating Condition HA7 followed by the declaration of a Site Area Emergency (HS4 - Site Attack).
For the purposes of this scenario, the onsite staffing was assumed to be limited to the on-shift complement listed in Table C-i of the STPEGS Emergency Plan. No augmented staffing was assumed.
The methodology employed to assess the impact of the event on onsite staffing initially analyzed the staffing requirements for the following procedures:
0POP04-ZO-SEC4 Guideline for Airborne (Aircraft) Threat 0P0P05-EO-EO00 Reactor Trip or Safety Injection In addition, staffing requirements for emergency response related procedures (i. e.,
classification, notification, assembly and accountability, etc.) were also considered for performance in parallel with the two procedures above.
The staffing assessment for this event evaluated the procedurally required actions against the availability of on-shift personnel. The assessment examined the duration of significant tasks in order to determine if overlaps occurred and to detect if personnel with assigned emergency response functions also had collateral duties that could distract the individuals from those
NOC-AE-1 5003273 Attachment 2 Page 4 of 5 functions. No overlaps or distracting collateral duties were noted.
To address the possible branching that could result from the aircraft impact, the analysis then considered the staffing implications of performing various extreme .damage mitigation guidelines (EDMGs) in parallel with emergency response functions. The following EDMGs were reviewed:
0POPi10-ZO-EDMG Extensive Damage Mitigation Guideline 0POP10O-SG-0001 Maximizing the SGS Heat Sink Coping Time Using Firewater Feed 0POP10O-SG-0002 Maximizing the SGS Heat Sink Coping Time Using DA Gravity Feed 0POP1 0-SG-0003 Manual Operation of Condensate and Feedwater for Steam Generator Supply 0POPi10-Sl1-0001 Firewater Makeup to RWST 0POPi10-FC-0001 Spent Fuel Pool Damage Mitigation Strategies 0POPi10-FC-0002 Maximizing the SFP Heat Sink Coping Time Using Barn Door Ventilation 0POP1 0-EW-0001 Emergency Cross Connecting ECW Trains 0POP1 0-EW-0002 Emergency Supply to Diesel Generator ECW from Firewater 0POP1 0-AE-0001 Emergency AC Electrical Supply to the Opposite Unit 0POPi10-XC-000i Flooding Containment with Firewater 0POP1 0-XC-0002 Spraying Buildings for Cooling and Radiation Release Mitigation 0POPi10-HE-0001 Loss of EAB HVAC 0POP10o-cv-oo01 RCS Feed and Bleed Using Positive Displacement Pump 0POP1 0-FP-0001 Alternate Fire Protection System Operation After discussion of probable event progression due to an aircraft impact, the judgment of the tabletop subject matter experts was a large area fire resulting in loss of the fire protection pumps would be the most personnel resource intensive sequence for implementation by the on-shift minimum staff. The following procedures were then assessed in detail for implementation' by available oin-shift resources:
S 0POP10-ZO-EDMG - Extensive Damage Mitigation Guideline 0
0POP1 0-FP-0001 - Alternate Fire Protection System Operation Also considered was the staffing impact of performing 0ERP01-ZV-IN09 (Offsite Assistance Coordination) which requires the Fire Brigade leader to provide interface and unified command with responding organizations during a fire requiring offsite assistance.
Several site-specific factors influence the ability of the on-shift staff to respond to this event:
- The Fire Brigade is composed of five Plant Operators who have no concurrent safe shutdown tasks. As directed by procedure 0ERP01-ZV-IN09 - (Offsite Assistance Coordination), the Fire Brigade Leader relocates to the Incident Command Post (ICP) to provide unified command with offsite response organizations. This leaves the remaining four members to implement 0POP1 0-FP-0001 (Alternate Fire Protection System Operation).
- The minimum staffing of three Radiation Protection Technicians and one Chemistry Technician is sufficient to accomplish both operational and emergency response duties until the augmented staff arrives. Even with the Senior Radiation Protection Technician
NOC-AE-1 5003273 Attachment 2 Page 5 of 5 relocated to the lCP as directed by procedure 0ERP01-ZV-1N09 - (Offsite Assistance Coordination) to provide radiological controls for offsite response organizations, the remaining two Radiation Protection Technicians are adequate to support radiological controls and surveys for both units.
- The minimum on-shift staff includes enough maintenance personnel to provide repair and corrective actions without the need for assignment of collateral duties to Plant Operators.
- First aid and rescue operations are performed by Plant Protection (Security) personnel without additional duties under the STPEGS Security Plan.
- The presence of two Shift Managers (one per unit) onsite allows the Shift Manager of the lesser impacted unit to provide ongoing emergency direction and control and leaves the more heavily impacted unit's Shift Manager to focus on accident assessment and mitigation.
In conclusion, the results of the analysis demonstrate that the minimum onsite staff described by Table C-1 of the STPEGS Emergency Plan is capable of performing the required mitigation and emergency response actions for at least 120 minutes without augmentation and without interference from collateral duties. Furthermore, the analysis indicates that all required emergency response actions, aside from periodic notification updates, are completed within 60 minutes of event initiation.