ML20052D918
| ML20052D918 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 05/03/1982 |
| From: | Withers B PORTLAND GENERAL ELECTRIC CO. |
| To: | Clark R Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0696, RTR-NUREG-696 TAC-43091, TAC-46131, TAC-51292, NUDOCS 8205070317 | |
| Download: ML20052D918 (9) | |
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\\ W / t'n May 3, 1982 Trojan Nuclear Plant Docket 50-344 License NPF-1 Director of Nuclear Reactor Regulation ATTN:
Mr. Robert A. Clark, Chief Operating Reactors Branch No. 3 Division of Licensing U. S. Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. Clark:
TROJAN NUCLEAR PLANT NUREG-0696, Emergency Operations Facility The NRC issued guidance for emergency response facilities in NUREG-0696 in February 1981. PGE anticipated many of the recommendations for these facilities and submitted a report on the Trojan Nuc? ear Plant emergency response facilities, providing a description of the Technical Support Center (TSC), Emergency Operations Facility (EOF), and the Safety Parame-ter Display System (SPDS) for the Trojan Nuclear Plant, on October 21, 1980 (B. D. Withers to D. G. Eisenhut). PGE subsequently updated that submittal on April 15 and July 2, 1981 (both B. D. Withers to D. G. Eisenhut) and on October 26, 1981 (B. D. Withers to R. A. Clark).
This subject has been discussed on numerous occasions with various mem-bers of the NRC staf f, including meetings expressly for this purpose in Bethesda on June 15, 1981 and April 6, 1982.
It is believed that PGE has a clear understanding of NRC guidance and its underlying technical basis for these issues. This letter provides additional supplementary informa-tion to the above submittals.
o6 The current design and operational features of the Trojan EOF and its backup provide an adequate capability for responding to an emergency.
Attached is a summary description of these facilities. This summary is submitted in order to present the current PGE position for the Trojan EOF
/ l in response to NUREG-0696.
PGE has attempted to follow the guidelines of NUREG-0696 and as a result, has established a workable and functional EOF at Trojan in the Visitors Information Center (VIC). Drills and exercises conducted since 1975 show the adequacy and capability of the Trojan VIC to function as the EOF. Previous correspondence has identified and provided technical justifications to the NRC in areas where the specific NRC criteria 8205070317 820503 PDR ADOCK 05000344 mop gm p
N Gerierd %Corryxviy Mr. Robert A. Clark May 3, 1982 Page two recommended in NUREG-0696 are not applied at Trojan. The shielding and ventilation design of the Trojan EOF were demonstrated to provide sufficient habitability for EOF personnel during an emergency to meet the requirements - of 10 CFR 50, Appendix A General Design Criterion 19.
Further, it was demonstrated that additional shielding for the command, communications and dose assessment areas of the Trojan EOF is not cost-effective and technically unfeasible due to building settlement prob-less.
The cost of shielding modifications to the command ' communica-tion and dose assessment areas of the EOF, based on 75 ft$ per person and the expected number of occupants (35), is estimated to be about
$1 million. The estimated cost of shielding and HEPA filtration modi-fications to even a small area of the EOF designed to accomodate 8-10 persons with very little space (350 f t2 total) is in excess of-
$100,000.
Use of an alternate EOF in St. Helens, approximately 13 miles south of the Plant, provides assurance that an emergency can be controlled and supervised from a central location in the event that the primary EOF must be evacuated. The Trojan Radiological Emergency Plan provides j
detailed guidance for shif ting control from the primary to the backup i
EOF with no loss of continuity or function, as well as anticipatory i
protective action criteria for relocation to the alternate EOF based on Plant accident conditions.
A summary of this guidance is presented in Attachment 1.
1 During the shift from the EOF to the alternate EOF, the EOF command, communication, dose assessment and protective a'ction recommendation-functions will be performed by the TSC. The Plant General Manager, in the TSC, will assume the position of Emergency Coordinator during the I
shif t to the alternate EOF. Transfer of control from the EOF to the TSC is done by telephone; there is no transfer of EOF personnel to the i
TSC.
The TSC already performs the command, communication,. dose assess-ment and protective action recommendation functions during the initial phases of the emergency until the EOF is activated. In fact, the Plant General Manager continues as Emergency Coordinator after'the EOF is activated until the Vice-President Nuclear (Emergency Response Manager) arrives at the EOF from PCE Headquarters and assumes the.
i Emergency Coordinator responsibilities. Therefore, the TSC'will simply be reassuming some of the functions that it performs during the initial.
l stages of an emergency.
The TSC is a habitable structure with at least 12' inches of concrete shielding, plus HEPA and charcoal filters.. These habitability features
. are considerably in excess of those required in NUREG-0696 for an EOF.
.A dose assessment area will be designated'in the TSC~which will have the same computerized dose assessment capability as the EOF, as well as 1
the capability to communicate via radio with the field monitoring teams.
All other critical communications sytems in the EOF will be duplicated in the TSC.. Furthermore, PGE plans to designate ' specific individuals
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j trained to perform dose calculations and communications in the TSC in the event that a shift to the alternate EOF is necessary.
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Portland General ElectricCompany Mr. Robert A. Clark May 3, 1982 Page three The EOF shielding and ventilation filtration criteria were included in NUREG-0696 due to concerns by the NRC that EOF personnel should not be moving to an alternate EOF at the same time that decisions to evacuate the public needed to be made. At Trojan all protective action decisions are made ar.d implemented at the state and county Emergency Operations Centers (EOC), based in part on protective action recommendations received from the EOF.
The Trojan EOF /TSC/altcrnate EOF concept insures the continuity of protective action recommendations coming from Trojan to the state and county EDCs during all emergency situations.
In addition, the state and county representatives at the EOF do not have decision making roles, so relocation to the alternate EOF will not prevent the states and countics from making and implementing timely protective action decisions.
PGE has attempted to comply with the basic intent of the guidance of NUREC-0696 and has established a sound and workable EOF at the Trojan Nuclear Plant. However, it is imperative that PGE receive timely NRC approval for the Trojan EOF in order to continue our efforts to provide an adequate emergency response facility by the October 1, 1982 deadline specified in NUREG-0737.
It is therefore requested that the NRC pro-vide a definitive ruling on the acceptability of the Trojan EOF no later than June 1,1982.
Unless we hear otherwise, PCE will continue to maintain the Trojan EOF at the Trojan VIC with an alternate at the PGE St. Helens office.
Due to the prolonged 51RC review and uncertain NRC position on the EOF location, PCE has not initiated design and engineering work on TSC data transmission to the EOF.
According to the vendor, lead time for necessary equipment at the EOF is approximately 12 months.
It is therefore expected the TSC data transmission to the EOF will not be completed until 15 months after PGE receives NRC approval on the EOF location.
Sincerely,
_W _.4 Bart D. Withers Vice President Nuclear Attachment c:
Mr. Lynn Frank, Director State of Oregon Department of Energy Mr. R. H. Engelken Regional Administrator, Region V U. S. Nuclear Regulatory Commission
Troj:n Nuclocr Plent Robert A. Clark Dock t 50-344 May 3, 1982 License NPF-1 Page 1 of 4 TROJAN NUCLEAR PLANT EMERGENCY OPERATIONS FACILITIES Trojan EOF (Primary)
The Trojan EOF is located in the Trojan Visitors Information Center (VIC),
approximately 1/2 mile west southwest of the Containment. A floor plan of the EOF is shown in Figure 1.
The VIC possesses several advantages as an EOF location:
1.
Its closeness to the Plant allows for fast activation and permits the use of Plant personnel as the initial EOF staff.
2.
It can serve as an assembly / decontamination area for personnel evacuated from the Plant.
Any personnel can then quickly travel to the Plant if needed.
3.
The EOF staff, including the Emergency Response Manager (PCE Vice President Nuclear), is located close to the Plant, providing more effective control of the emergency.
4.
NRC, FEMA, State and County representatives are located close to the Plant.
5.
The VIC is a good location from which to control site security.
6.
The VIC has been used as the EOF since 1975.
Plant per-sonnel, as well as State and County emergency response personnel, are familiar with the facility and its location.
7.
Using the VIC as an EOF helps to utilize existing struc-tures near the Plant most efficiently.
8.
A low wind frequency (0.5 percent) toward the west-southwest provides good assurance of EOF habitability.
The EOF is a well engineered structure that is designed to withstand a 100 yr. flood.
An analysis was performed on the ability of the EOF to withstand a 100 yr. wind. At this wind level, some damage to the EOF Building may occur, but will likely be limited to broken windows.
How-ever, the command, communications and dose assessment functions of the EOF take place in the building auditorium, which has no windows.
The auditorium is protected from the building areas that have windows by internal walls. Therefore, the essential f unctions of the EOF are not expected to be adversely affected by a 100 yr. wind.
4
Troj:n Nuclser Plcnt Robert A. Clark Dockst 50-344 May 3, 1982 License NPF-1 Page 2 of 4 The structural analysis conducted to evaluate the feasibility of adding concrete walls and a roof slab to the command, communications and dose 2
assessment areas of the EOF based on 75 ft / person and the expected number of occupants (35) indicated that extensive structural modifica-tions would be required to provide a protection factor of 5.
Modifi-cations would include removal of the existing wall and column footings, metal siding, structural wall, roof framing and concrete floor slab.
Because of soil consolidation conditions already experienced, new pile or mat foundations would probably have to be constructed to support the new walls, columns and roof slab. The cost for the shielding modifica-tion is estimated to be approximately $1million. A preliminary settle-ment analysis indicates that a significant weight addition due to the modifications for the EOF would affect the VIC structure in terms of additional total and differential settlee rt and tilting. Damage to the existing VIC structure could result.
It is therefore not con-sidered to be structurally practicable to upgrade the existing VIC building to comply with the NRC requirement for shielding.
An additional analysis was performed to determine the cost and feasibility of shielding a small area with the EOF (for 8 to 10 people). While this approach is technically feasible, it is not cost-effective. The cost of shielding a 350 ft2 area was estimated to be in excess of $100,000.
Feasibility of upgrading the existing ventilation system in the VIC was also evaluated.
In order to install HEPA filters in the VIC ventilation system per NUREG-0696, extensive modifications will be required to the mechanical rooms which house the supply and return fans, filters and plenums.
Based on the limited space availability and the design flow of the existing ventilation system in the Trojan EOF, it is not practicable to modify the ventilation system. An estimated cost for upgrading ventilation system is in excess of $30,000.
Fur the rmo re, it was demonstrated that HEPA filters are not required for the EOF ventilation system because of the protective action criteria established for the EOF.
The anticipatory protective action criteria for the EOF will require relocation to the backup EOF before slow-developing accidents (ie, greater than 1 hr.) reach the point where significant particulate radioactivity will be released. For accidents involving a quick release of radioactivity (ie, less than 1 hr.), the releases will initially be dominated by volatile nuclides (noble gases and iodine).
Particulate radioactivity will consist of iodine or short-lived noble gas daughters which do not contribute significantly to the dose rate inside the EOF.
Furthermore, the presence of these short-lived noble gas daughters in the EOF would not be prevented by the HEPA filters because of their continuous generation by the decay of the noble gases inside the EOF.
The dose rate and iodine air concentrat ion protective action cri-teria (see below) will ensure relocation to tre backup EOF before sig-nificant long-lived particulate radioactivity such as cesium 137 will be relessed.
l
Troj:n Nuciscr Plant Robert A. Clcrk Dockat 50-344 May 3, 1982 License NPF-1 Page 3 of 4 An analysis was performed to evaluate the radiation deaes to personnel within the existing Trojan EOF as the result of a Design Basis Accident (DBA) at Trojan. The atmospheric dispersion factor (X/Q) used in the analysis is the 0.5 percentile value over the entire year for the west-southwest sector in accordance with Regulatory Guide 1.145.
Wind rose data collected around Trojan for the periods of 1971-74 and 1976-81 indicate winds blowing toward the Trojan EOF 0.5 percent of the time.
The monthly variation in the frequency of winds blowing toward the EOF was also determined to be small (a maximum frequency of less than 1 percent). As discussed in the PGE letter to the NRC of October 21, 1980, the result of the analysis indicates that the calculated radiation doses are less than the Standard Review Plan 6.4 dose criteria for a DBA at the Trojan Nuclear Plant.
The inclusion of calms in the habitability analysis of the EOF has no effect on the conclusions of the analysis.
Over the period 1971-80, calms accounted for only about 1.2 percent of the recorded observations.
Regulatory Guide 1.145 states that calms should be assigned wind direc-tions in the same proportion as the wind direction frequencies for winds of less than 1.5 m/sec. For 1971-74, winds of less than 1.5 m/sec. blew toward the EOF 1.3 percent of the time, so the frequency of calms "toward" the EOF is 0.016 percent. The total frequency of winds toward the EOF is therefore increased from 0.5 percent to 0.516 percent, a negligible increase.
In addition, the X/Q values used in the habitability analysis included calms, which were assigned to the lowest wind speed group per Regulatory Guide 1.145.
The above analysis has also been reevaluated for " worst-case" meteorology conditions (5 percentile site meteorology with wind blowing toward the EOF). The X/Qs for this case were taken from Figure 2.3-16 of the Trojan FSAR (see Figure 2).
The resulting 30-day whole body dose is 3.69 rem, which is less than the GDC 19 limit of 5 rem.
The whole body dose in this reanalysis was calculated using the semi-infinite cloud model described in Regulatory Guide 1.4.
Therefore, this calculation is an effective upper bound for doses from other site meteoro-logical conditions, such as shine from an effluent plume traveling up-or down-valley, a plume which has reversed direction within the river valley and subsequently filled up the valley, or a spherical plume generated by calm conditions.
Trojan Alternate EOF The alternate EOF is located at the PCE St. Helens District Office in St.
Helens, Oregon (13 mi a from the Plant), and if activated, will have the same staff and functions as the primary EOF. Emergency equipment and supplies are stored at the alternate EOF, and all EOF communications and dose assessment capabilities exist at the alternate EOF.
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Trojnn Nuclser Plent Robert A. Clerk Dockat 50-344 May 3, 1982 License NPF-1 Page 4 of 4 The alternate EOF will be prepared for activation whenever the primary EOF is activated by notifyin8 the St. Helens District Manager.
If evacuation of the EOF is required, the St. Helens office staff will be notified to begin activation of the alternate EOF.
During the time required to move the EOF staff to the alternate EOF (approximately 30 minutes), the command, communications, dose assessment and pro-tective action documentation functions of the EOF will be assumed by the TSC. The TSC staff is trained and qualified to carry on these tasks, and the required communications and dose assessment facilities exist in the TSC.
PGE has included anticipatory protective action criteria for relocation to the alternate EOF in the Trojan Radiological Emergency Plan.
These anticipatory protective action criteria for the EOF, which are shown below, should permit relocation prior to substantial releases of radio-activity from the Containment:
Fuel melting indicated by Containment area monitors or dose rate measurements outside Containment; and 1.
Containment sprays and air coolers not func-tioning; and Containment pressure greater than 70 psig for 2 min; or 2.
Other conditions exist which will lead to loss of Containment integrity.
The anticipatory protective action criteria are in addition to the following criteria which are based on radiation levels in the EOF:
1.
One rem /hr whole body for one hour or more; or 100 MPC I-131 for one hour or more; or 2.
Ten times these levels persisting for greater than 5 min.
-It should also be noted that over 350 units of potassium iodide (KI) are stored in the EOF. For accidents releasing considerable amounts of radioiodine, the use of KI by the EOF staff will provide an inhalation thyroid dose protection factor of 100.
PCE will test the relocation to and operation of the alternate EOF during the 1982 Trojan Emergency Plan Exercise.
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