ML20039G511
| ML20039G511 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 01/11/1982 |
| From: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0696, RTR-NUREG-696 NUDOCS 8201180341 | |
| Download: ML20039G511 (4) | |
Text
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Consumers David P Hoffman
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Nuclear Licensing AJmunntrator General offices: 1945 West Parnell Road, Jackson, MI 49201 e 1517) 788-1636 January 11, 1982
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b RECGV2O Dennis M Crutchfield, Chief JAN151982* [9 m urat uss'WimmE Operating Reactors Branch No 5 N
Nuclear Reactor Regulation s
US Nuclear Regulatory Commission Washington, DC 20555 N,
4 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT - SHIFT MAh3ING Your letter dated November 20, 1981 provided your evaluation of the minimum shift staffing level proposed by Consumers Power Company for the Big Rock Point Plant in our letters dated June 22, 1981, and July 7, 1981. Your November 20 letter also provided the justifications for your evaluation and suggested alternatives for meeting the purpose and intent of the shift staffing recommendations in NUREG-0696.
As stated in Consumers Power Company letter dated June 22, 1981, we are currently performing an Operator Action Event Tree evaluation, the results of which will be submitted to the NRC by March 31, 1982, in order to provide the bases for our final determination of the minimum shift staffing at Big Rock Point. This Operator Action Event Tree evaluation of staffing levels uses the dominant accident sequences identified by the Big Rock Point Probabilistic Risk Assessment as a starting point. The results of this evaluation will provide the following information.
1.
An assessment of the adequacy of the minimum on-shift staffing as well as the current capability to augment this staff level on a " call-up" basis.
2.
Identification of additional personnel needed after the start of an emergency situation and the time at which these extra people are needed on site.
3.
An assessment of the role of the Shift Technical Advisor (STA) before and during an accident event, thereby identifying whether an on-duty STA is indeed necessary.
Since the preliminary results of this evaluation are currently available for Consumers Power Company review and we have modified our original shift oc0182-000Sa142 04I g 82 5
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Dennis M Crutchfield, Chief 2
Big Rock Point Plant Shift Manning January 11, 1982 staffing proposal described in our letters of June 22 and July 7, 1981, the three issues identified in your November 20 letter are addressed below.
Please note that the results of the Operator Action Event Tree evaluation will etill be submitted by March 31, 1982 for the purpose of providing a more detailed justification of the positions presented below.
Issue 1: Requirement for Two Senior Reactor Operators (SR0s) and One Shift Technical Advisor (STA).
Regarding the need to maintain a second SRO in addition to the Shift Super-visor (SRO) on shift, the Site Emergency Plan calls for the on-call Duty Superintendent and the Site Emergency Director to be notified first in the event of an emergency condition (ie, unusual events, alerts, site emergencies, arid general emergencies). Accordingly, these people will be on site early in the event. Once the Site Emergency Director is on site, he will assume the responsibilities delineated in the Site Emergency Plan. This plan ensures that there is adequate and properly trained personnel on site to perform all necessary activities during emergency situations except those events during which core damage occurs rapidly, before the on-call Duty Superintendent and the Site Emergency Director might arrive on site. Nevertheless, the Big Rock Point Probabilistic Risk Assessment (PRA) shows that severe core damage will not occur sooner than 30 minates.after the onset of an accident event, and that the probability of severe coge damage occurring in less than two hours is very low, on the order of 3.5x10 / year. Furthermore, rapid core damage events are the result of major breaks in the primary coolant system inundary or Anticipated Transients Without Scram and require few operator actions (verify core spray and/or activate the liquid poison system).
Consumers Power Company believes that the early arrival of the Site Emergency Director, the low probability of rapid core damage events occurring, and the small number of operator actions required if severe core damage does occur rapidly provide sufficient justitication for not maintaining a second SRO on shift.
Nevertheless, Consumers Power Company proposes to certify all STAS as SR0s.
The certification process would be identical to the training and testing given to those Big Rock Point operators who go on to become licensed SR0s with the exception that the STAS will not take the SRO licensing exam.
The tests, both written and oral, which will be required as part of the Consumers Power Company SRO certification process are based on the NRC license exams. There-fore, a passing grade will reflect the same level of achievement as licensed SR0s. Note that the SRO training would be in addition to the training that STAS receive in order to function in the role of Shift Technical Advisors.
While this proposal is not exactly what you suggested as an alternative in your November 20, 1981 letter (ie, STAS as licensed SRos), Consumers Power Company believes that certifying all STAS as SR0s follows the same line of reasoning. Accordingly, Consumers Power Company is initiating the certifica-tion process and expects that this first cycle of training and testing will be complete by October 1, 1982.
oc0182-0005a142
o Dennis M Crutchfield, Chief 3
Big Rock Point Plant Shift Manning Janua ry 11, 1982 The current Big Rock Point Technical Specifications requires a Shift Technical Advisor to be part of the minimum shift staff. Nevertheless, the assessment of the role of the STA performed as part of the Operator Action Event Tree evaluation shows that maintaining an on-shift STA is not necessary for the safe operation and shutdown of the plant in the event of an accident. A more detailed explanation of this assessment will be provided in our submittal of the Operator Action Event Tree evaluation results by March 31, 1982.
Based on the findings described above concerning a second SR0 and an STA on-shift, Consumers Power Company proposes to include an SRO-certified STA in the
" call-up" of required personnel who can augment the on-shift staff within 60 minutes. Accordingly, the appropriate Technical Specification Change Request will be submitted to the NRC by March 31, 1982, along with our submittal of the Operator Action Event Tree evaluation results.
The information provided above addresses the question in your November 20, 1981 letter concerning staffing of the STA and SRO functions before and after July 1, 1982.
Issue 2: HP-Rad / Chem Technician Shift Coverage.
Contrary to the statement in our letter dated June 22, 1981 that an HP-Rad / Chem Technician will be on-shift by November 1, 1982, one HP-Rad / Chem Technician is now provided on all shifts at Big Rock Point. Should an emer-gency situation occur, this on-shift Technician would perform in-plant sample collection and analysis, and in-plant monitoring. Since the operations staff routinely monitor plant areas prior to entry as part of their normal func-tions, some of these operations personnel could assist the HP-Rad / Chem Technician in performing area monitoring during the initial phases of an emergency. As additional technicians are called in, they would perform more of the in-plant monitoring functions.
1 Out-of-plant monitoring and decontamination of personnel leaving the plant will be performed by off-site HP-Rad / Chem Technicians. These off-site techni-cians will be contacted at the start of an emergency condition and instructed to go to the Charlevoix Emergency Operations Center (EOC), obtain survey monitors and sample equipment, and begin the out-of plant monitoring according to established procedures. First aid and rescue activities can be performed by shift personnel, one of which will have a valid first aid certificate.
By utilizing the one on-shift HP-Rad / Chem Technician supplemented by other technicians who will be called in to respond in an emergency, off-site HP-Rad / Chem Technicians, and operations personnel to perform emergency situation activities, all the functions listed in NUREG-0654,Section I, paragraphs 7-10, Table B-1 will be adequately manned.
Since the results of the Big Rock Point PRA showed that the probability of rapid core damage events is very low, any in-plant monitoring by the HP-Rad / Chem Technician will not need to be performed immediately in most cases.
In addition, the 21 area radiation monitors and 7 process monitors with read-outs in the Control Room will help to reduce the number of in plant areas oc0182-0005a142
Dennis M Crutchfield, Chief 4
Big Rock Point Plant Shift Manning Janua ry 11, 1982 l
which may require further monitoring. With regard to out-of-plant monitoring, off-site HP-Rad / Chem Technicians who are called in at the alert stage for accident sequences involving release of radiation from the plant will, in most cases, have sufficient time to obtain equipment from the E0C and begin moni-i toring before any major release of radioactivity occurs.
The information presented above addresses the question in your November 20, 1981 letter as to how the duties and responsibilities of the HP-Rad / Chem Tech-nician specified in NUREG-0654 will be performed and by whom.
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Issue 3: Requirement for Separate Communicator Consumers Power Company proposes to delegate the responsibility to perform communications / notification activities to a Security Officer who will be 4
designated on each shift. The designated Security Officer will function in the communicator role during emergency situations until such time as the Site Emergency Director arrives to fulfill that role. The communicator duties and the training that the designated Security Officers will receive in order to perform this function will be specified and documented in the Big Rock Point Site Emergency Plan Implementing Procedures. Security Officers will be trained and designated as emergency communicators by July 1, 1982.
This proposal addresses the state' ment in your November 20, 1981 letter con-cerning the provision of an adequately trained individual, who is not the Shift Supervisor, who will be delegated the role of communicator.
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David P Hoffman Nuclear Licensing Administrator CC Administrator, Region III, USNRC NRC Resident Inspector-Big Rock Point l
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