ML20008F580
| ML20008F580 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 04/15/1981 |
| From: | Withers B PORTLAND GENERAL ELECTRIC CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0654, RTR-NUREG-0696, RTR-NUREG-654, RTR-NUREG-696, TASK-1.D.2, TASK-3.A.1.2, TASK-TM TAC-43091, TAC-46131, TAC-46346, TAC-4651292, TAC-51292, NUDOCS 8104210312 | |
| Download: ML20008F580 (8) | |
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April 15, 1981 h i' Trojan Nuclear Plant Docket 50-344 License NPF-1 Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. Eisenhut:
Forwarded hereby is PGE's response to NRC generic letters 81-10 (February 18, 1981) and 81-17 (March 5, 1981), requesting a commitment to the implementation schedules for TMI Action Plan Item III. A.1.2 (Upgrade Emergency Support Facilities) and NUREG-0696.
A.
Emergency Response Facilities PGE's basic commitments to the emergency response facility requitcments of Action Plan Item III.A.1.2 and NUREG-0696 were submitted on October 17, 1979 and October 21, 1980. At this time, PGE commits to the require-ments and schedule set forth in generic letter 81-10 with the following exceptions:
1.
M n,1 cal Support Center (TSC) Computer System:
The TSC computer system will provide the necessary informa-tion for the Plant uanagement, Engineering, and technical personnel assigned to the TSC to aid the control room operators in handling accident conditions. The data set available for display at the TSC includes the Safety Para-meter Display System (SPDS), the Bypassed and Inoperable i
Status Indication (BISI), pertinent radiological and meteoro-logical data, and the critical Plant system parameters. The critical system parameters available in the TSC computer system do act include the entire set of variables listed in Regulatory Guide 1.97 (Revision 2), since the Regulatory Guide is still undergoing evaluation for its implementation in 1983. However, the set of paramenters included in the TSC data system covers the majority of the variables in Regulatory Guide 1.97 (Revision 2), which are pertinent to determine the Plant systems dynamic behavior through the course of the accident and appropriate mitigating actions.
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PCf t!Ed CCrant DC!ric CCGpy Mr. Darrell G. Eisenhut April 15, 1981 Page two a
Selection of the parameters is based on an evaluatica of Plant systems / functions which are critical'in mitigating accident conditions. The critical Plant systems / functions include: reactor core integrity, primary coolant system integrity, reactor core cooling, Containment integrity, and radioactive effluents.
The TSC data set will also be made available on demand to the EOF and alternate EOF.
2.
Emergency Operations __ Facility (EOF) Location and Hebitability:
PGE's October 21, 1980 letter described the location and nabitability of the Trojan EOF, which is located at the Trojan Visitors Information Center (VIC), approximately 1/2 mile from the Plant. A fully-equipped alternate EOF is located at the PGE office in St. Helens, Oregon, 13 miles from the Plant. The alternate EOF will have the same data displays and communications as the primary EOF. The primary EOF does nct meet the NUREG-0696 requirements for shielding and ventilation system filtration, although the building does meet the 100-year flood criteria. The compliance of the EOF with the 100-year wind criteria is currently being evaluated.
In PGE's October 21, 1980 response, an evaluation of the habitability of the EOF was made versus the Standard Review Plan (SRP) 6.4 dose criteria. Due to the location of the EOF (in a very infrequent wind direction), the results of the analysis indicated that the EOF met the SRP 6.4 habita-bility criteria for a Design Basis Accident at the Trojan Nuclear Plant.
a i
In view of this, and the desirability to keep overall l
control of the emergency as close to the Plant as possible, PGE hereby requests that the Trojan EOF be exempted from the shielding and ventilation requirements of NUREG-0696.
3.
NUREG-0654, Appendix 2 Impirmentation:
i NUREG-0654 Appendix 2 requirements, as they relate to descriptions of the TSC and F.0F instrumentation and data
(
systems, will be addressed according to the implementation t
schedule for NUREG-0654 Appendix 2 (system description j
to be submitted by Junuary 1,1982). PCE compliance with i
the scheduled dates for equipment installation (July 1, 1982) and full operation (October 1, 1982) will be depen-dent upon hardware and sof tware availability and equipment delivery schedules.
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Mr. Darrell G. Eisenhut April 15, 1981 Page three 4.
Safety Parameter Display System:
The SPDS is an integral part of the TSC computer system which provides the data collection, manipulation and the CRT graphics displays of the Plant system safety parameters.
The SPDS displays will be located in the control room and the TSC.
The SPDS is not designed to meet seismic qualifications since it is a non-safety system and is not required to mitigate accidents. In response to the requirements in NUREG-0696 for seismically qualified backup displays, a minimum set of the critical parameters will be displayed on a seismically-qualified panel (post-accident panel) which is installed to incorporate certain post-TMI instru-ments in the control room. The critical parameters located in the post-accident panel include:
the reactor vessel water level, Containment water level, and Containment high-range pressure. In addition, the RCS hot leg and cold leg temperatures and the RCS pressure are also avail-able on this panel although the circuitry from isolators located elsewhere in the Control Room to the display devices is not seismically qualified. Other pertinent parameters, such as core flux, Containment isolation yalves, and radio-active offluent monitors are already displayed in locations which are easily accessfble and highly visible from the operating station of the control room operator. These parameters constitute a minimum set of critical parameters which meet the intent of ANSI Standard 4.5, 1980, for monitoring Plant safety functions.
B.
Emergency Staffing Requirements to this letter shows PGE's proposed staffing levels for emergency situations. The proposed on-shift staffing levels are con-sistent with Table B-1 of NUREG-0654, Revision 1, provided the following assumptions are made:
1.
The requirement for two maintenance technicians on-l shif t can be met by utilizing a single on-shif t main-tenance technician to perform both mechanical and electrical /I6C maintenance, and by utilizing the Plant Auxiliary Operators to perform Radwaste Operator functions.
2.
The Security Watch Supervisor and other security personnel can be utilized to perform a portion of the i
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PCd!EY 10Cd E9dfC CCirpCny Mr. Darrell G. Eisenhut Acril 15, 1981 Pa e four s
communications / notification function until the TSC is activated.
The on-shif t staffing levels will be fully irglemented by September 1, 1981 with the exception of the licensed operators and maintenance techni-cian. The licensed operators requirement will be implemented according to the schedule specified in Task Action Item I.A.l.3.
The on-shift maintenance technician position will be filled on an interim basis by on-call personnel who will be able to augment the Plant staff within 60 minutes; the on-shift maintenance technician requirement will be implemented fully by July 1, 1982.
The PGE proposed augmentation capability complies with Table B-1 augmentation requirements with the exception of the following areas:
1.
Table B-1 requires a certain number of persc:onel to report to Trojan within 30 minutes. PGE proposes that the minimum augmentation time be 60 minutes.
A 60-minute augmentation time is appropriate for the following reasons:
a.
Compliance with a 30-minute time requirement is not feasible given the location of the Trojan Nuclear Plant relative to the areas where Plant personnel live. Sixty minutes is a more reasonable amount of time for Plant personnel living in the vicinity of the Trojan Nuclear Plant to report onsite after notification. In reality, some per-sonnel may be able to report onsite in lees than 60 minutes.
l b.
It is unlikely that requiring Plant per-sonnel to report onsite within 30 minutes would add significantly to the Plant staff's ability to cope with a quick-occurring accident, such as a steam generator tube rupture, main steam line break, or WASH-1400 l
PWR-8 or PWR-9 accident. Accidents that involve core degradation and significant radioactivity releases to the environment occur over much longer periods of time (ie, several hours); for these accidents, l
a 60-minute augmentation time would be sufficient.
2.
The total number of Chemistry and Radiation Protection (C&RP) Technicians reporting onsite within 60 minutes
Por f'/J OCITf1Ci EeC#dC CCfrirriy Mr. Darrell G. Eisenhut April 15, 1981 Page five is 3 versus 13 required by Table B-1.
As shown in, these three personnel, in addition to the two C&RP technicians on shift, will provide sufficient chemistry and radiation protection exper-tise to meet all anticipated emergency requirements in the short te rm. It should be noted that licensed Plant operators are qualified in radiation protection access control and monitoring procedures. The Table B-1 requirement is not feasible in that it would require a total of 15 of the 18 available C6RP technicians to be onsite within 60 minutes.
3.
The total number of maintenance technicians reporting onsite within 60 minutes is 2 versus 5 in Table B-1.
These two personnel, along with the on-shif t Maintenance Technician and Auxiliary Operator (Radwaste Operator),
will provide sufficient maintenance expertise for emergency situations in the short term.
In addition, the following interpretations of the Table B-1 augmentation requirements were made:
1.
The senior health physics expertise identified in Table B-1 is being interpreted to be the Trojan P.adia-tion Protection Supervisor or one of his alternates.
2.
The senior manager identified in Table B-1 as the EOF Director is interpreted as the duty Trojan Manager, Plant Services.
The augmentation levels shown in Attachment I will be fully implemented by September 1, 1981.
PGE believes that the minimum staffing and augmentation requirements given in Attachment 1 provide a reasonable effort to comply with the intent of Table B-1 to have an effective and responsive emergency organization during off-hours. It should also be noted that the Trojan Radiological Emergency Plan Implementing Procedures contain procedures for notifying the Plant
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Mr. Darrell G. Eisenhut April 15, 1981 Page six staff during off-nours. Therefore, the actual number of personnel augment-ing the Plant off-hours staff would likely be considerably greatet than the minimum number specified in Attachment 1.
Sincerely,
- 2' Bart D. Withers Vite President Nuclear At tact: ment c:
Mr. Robert A. Clark, Chief Operating Reactors Branch No. 3 Division of Licensing U. S. Nuclear Regulatory Commission Mr. Lynn Frank, Director State of Oregon Department of Energy i
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ATTACHMENT 1 TABLE 2:5.2-1 Sheet 1 of 2 STAFFING REQUIREMENTS FOR TROJAN NUCLEAR PLANT EMERGENCIES Capability Position Title for Additions Major Functional Areas Major Tasks or Expertise On Shift 60 Min Plant Operations and Shif t Supervisor 1
Assessment of Operational Assistant Shif t Supervisor 1
As pects Control Operator 1
Assistant Conrrol Operator 1
Auxiliary Operator 3
Emergency Direction and Shift Supervisor 1
Control (Emergency Duty Plant General Manager 1
Coordinator)
Notification /
Notify licensee, State, Security Watch Supervisor /
2 Communication local, and Federal per-Security personnel sonnel and maintain Shif t Supervisorl81 1
cammunication Duty llanager, Plant 1
Services (EOF Director)
Radiological Accident Emergency Operations Duty Manager, Plant 1
Assessment and Support Facility (EOF) Director Services of Operational Accident Assessment Offsite dose assessment Assistant Control 1
Operator [b]
Engineering Emergency Team 2
(TSC)[b]
Duty Radiation Protection 1
Supervisor (EOF)[b]
Offsite surveys Field Team (C&RP 2
Technicians)
Onsite (out-of-Plant)/
C&RP Technicians 2
1 in-Plant surveys /
chemistry / radiochemistry
ATTACllMENT 1 TABLE 2:5.2-1 Sheet 2 of 2 Capability Position Title for Additions Major Functional Areas Major Tasks or Empertise On Shift 60 Min Plant System Engineering, Technical Support Duty Manager, Technical 1
Repair and lJorrective Services Actions Shift Technical Advisor 1
3 Engineering Emergency Team 2
Duty daintenance Supervisor t
Repair and corrective Maintenance Technician 1
2 actions Protective Actions Radiation protection:
C&RP Technicians 2[c]
3lcl (In-Plant) a.
Access control b.
iip coverage for repair, corrective actions, search and rescue, first aid, and firefighting c.
Personnel monitoring d.
Dosimetry Firefighting Fire Brigade 5[d]
Rescue Operations C&RP Technicians 2lel llel and First Aid Site Access Control and Security, firefighag Security personnel All per Personnel Accountability communications, personnel Security accountability Plan Total:
13(fl 13lf)
[a] Security Watch Supervisor and Security personnel perform initial notifications of State and county agencies; Shif t Supervisor notifies NRC and maintains communications until Duty Manager, Plant Services arrives at EOF.
[b] Assistant Control Operator performs dose assessments until the TSC is activated; Engineering Emergency Team performs dose assessments at TSC until EOF is activated; Duty Radiation Protection Supervisor per-forms dose assessments at the EOF.
[c] Duty performed by C&RP Technicians assigned to onsite surveys (Sheet 1).
Licensed operators are also trained in radiation protection.
[d] Fire Brigade consists of three operators and two Security personnel.
[e] Duty performed by C&RP Technicians assigned to onsite surveys (Sheet 1).
[ f] Does not include Security personnel.
TDW/SCG/4 caw 7B18