ELV-00875, Provides Addl Justification & Clarification for Changes to Rev 11 to Emergency Plan,Per NRC 890813 Request.Concludes That Effectiveness of Subj Plan Not Decreased by Allowing Drill Participation to Substitute for Classroom Training

Provides Addl Justification & Clarification for Changes to Rev 11 to Emergency Plan,Per NRC 890813 Request.Concludes That Effectiveness of Subj Plan Not Decreased by Allowing Drill Participation to Substitute for Classroom Training

ML20248B105
Person / Time
Site:	Vogtle
Issue date:	09/25/1989
From:	Hairston W GEORGIA POWER CO.
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
ELV-00875, ELV-875, NUDOCS 8910030098
Download: ML20248B105 (3)

Text

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.  :* Geortra Power Company -

o 333 P edmont Aenue Ananm. Geo g:a 30308 Tuephone 404 526 319S Mailing Addren 40 Inverness Cenrer Parkway Post Ofice Box 1293 Birmingham. Alabama 3f#01 Telephone 205 868 5581 M

25, 1989 f.p $ptSnSe'Y ?vwupww &tre wuem W. G. Hairston, lil Serjor Vce Prescent Nuclear Operabons ELV-00875 1649n Docket Nos. 50-424 50-425 U. S. Nuclear Regulatory Commission Region II - Suite 2900 101 Marietta Street, N. W.

Atlanta Georgia 30323 Gentlemen:

V0GTLE ELECTRIC GENERATING PLANT JUSTIFICATION FOR EMERGENCY' PLAN CHANGE This reply is in response to your letter dated August.13,1989, requesting additional justification and clarification for a change to'Section 0, item 0.1 in Revision 11 to the Vogtle Electric Generating Plant Emergency Plan, dated January 1989. The change give's credit for annual requalification training to managers who participate in integrated drills.

t The managers affected are those persons assigned emergency response positions as Emergency Director (ED), Technical Support Center (TSC) Manager, Operations Support Center (OSC) Manager, Emergency Operations Facility (EOF) Manager and TSC Operations Supervisor, who are not licensed operators. Licensed operators receive annual classroom requalification training as part of their licensed operator requalification training program. Presently, the following ~ persons are affected by this change and may not receive formal classroom requalification training in Management of Radiological Emergencies:

(1) General Manager - Emergency Director, & TSC Manager (2) Vice-Prestdent - Nuclear - Emergency Director i

• (3) Outage & Planning Manager - EOF Manager

• (4) Maintenance Manager - OSC Manager (5) Maintenance Supervisor (IC) - OSC Manager (6) Acting Maintenance Manager - OSC Manager

• Prr.sently enrolled in licensed operator training Tour letter requested an outline which describes the methods we Omnd to use to assure annual retraining of persons assigned to the affected positions, addre.ising- four areas, specifically:.

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. s Georgia Powerkn U. S. Nuclear Regulatory Commission ELV-00875 Page~Two Concern #1 - Personnel are adequately trained in all emergency organization positions that they may be expected to fill in an emergency, both primary and alternate.

Each manager completes initial training in Management of Radiological Emergencies. These managers then actively participate in the Vogtle Electric Generating Plant (VEGP) drill program to reinforce material covered in the formal classroom program. Plan and procedure changes as well as drill critique and feedback are covered by a separate mechanism as indicated in the response to concern numbers 2 and 3. Participation in either the annual requalification training or an integrated drill once each year is equally effective in ensuring these individuals are well prepared to fulfill their emergency preparedness responsibilities.

In addressing that portion of this concern regarding the designation of a manager for two different positions the following information is provihd.

The only positions where dual designations may be made are the TSC Manager and Emergency Director.

From the management of a Radiological Emergency perspec-tive the responsibilities of these two positions are so similar that it is considered performance in one of the positions will adequately train the person for either position. For example, procedures require that the TSC Manager monitor plant conditions and make recommendations to the Emergency Director concerning emergency classifications. In addition, the TSC Manager must be familiar with offsite notification procedures as these functions are performed in the TSC during an Alert and prior to Emergency Operations Facility (EOF) activation.

Concern #2 - The affected managers are informed of lessons learned from drills, exercises and actual events and the corrective action implemented.

All department heads currently receive the formal drill and exercise critique

' reports which cover these areas. Routing of these reports is being expanded to include all persons assigned as primaries or alternates to the specific Emergency Response Facility (ERF) managers positions in question.

Concern #3 - The individuals are advised of Emergency Plan and procedure changes in a timely manner.

Managers will be informed of significant procedure changes by memorandum from the Manager Trainirig and Emergency Preparedness.

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Georgia Power m_.

U. S. Nuclear Regulatory Commission ELV-00875 Page'Three 3 Concern #4 - Personnel are proficient in the aspects of the Emergency Plan and procedures not specifically addressed during drill participation.

Personnel are given credit for requalification for participation in integrated drills and exercises only. These drill scenarios are specifically designed to address all major aspects of the applicable positions responsibilities. Those minor areas which may not be addressed are adequately covered by comprehensive procedures which will be followed for actual situations.

In summary, it is considered that the training benefits derived from participation in an integrated drill or exercise of 4-6 hours is more beneficial than 2-4 hours of formal review and testing in the classroom.

Therefore, it is concluded that the effectiveness of the plan is not decreased by allowing drill participation to substitute for classroom training. If you or your staff have any additional questions concerning this issue, please contact Mr. Jim Roberts at (404) 722-0624.

Sincerely, Vfl.). f f W. G. Hairston, III WGH,III/KRH/ JAB /gm xc: Georgia Power Company Mr. C. K. McCoy Mr. G. Bockhold, Jr.

Mr. R. M. Odom Mr. P. D. Rushton NORMS U. S. Nuclear Regulatory Commission Mr. 5. D. Ebneter, Regional Administrator Mr. J. B. Hopkins, licensing Project Manager, NRR Mr. J.. F. Rogge, Senior Resident Inspector, Yogtle Document Control Dest

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