IR 05000344/1992028

Insp Rept 50-344/92-28 on 921109-1215.No Violations or Deviations Noted.Major Areas Inspected:Rev 7 to Emergency Plan Implementing Procedure EP-001, Emergency Classification

ML20127B144
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	12/21/1992
From:	Good G, Pate R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20127B137	List: IR 05000344/1992028 ML20127B133
References
50-344-92-28, NUDOCS 9301120184
Download: ML20127B144 (4)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report N /92-28 Docket N License N NPF-1 Licensee: Portland General Electric Company 121 S.W. Salmon Street Fortland, Oregon 97204 Facility Name: Trojan Inspection at: Walnut Creek, California Inspection Dates: November 9 through December-15, 1992 Q 3 L/9';L

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Inspector:

uall M. Goo , nbrcjency reparedness Analyst Date Slgned Approved by: , /)t) () jt,g[ p.jpj hobert' J. Pate,' Chibf Dafe gned Safeguards, Emergency Preparedness, and

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Non-Pawer Reactor Branch S_UfMMARY:

Inspection on i cvember 9 through December 15, 1992 (Report No. 50-344/92-28)

Areas Inspected: In-office inspection to review Revision 7 to emergency plan implementing procedure EP-001, " Emergency Classification." Inspection procedure 82701 was used as guidanc Results: EP-001, Revision 7, continued to meet the standards in 10 CFR 50.47(b) and the requirements in 10 CFR 50, Appendix E; however, one emergency action level (EAL), involving a general emergency classification, was incorrectly changed in Revision 7. This change appeared to result in a decrease in the effectiveness of the emergency plan (see Item 2 in Section 2).

No deviatior,s or violations of NRC requirements were identified during thi inspectio ..

9301120184 921224 PDR ADOCK 05000344:

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DETAILS Persons Contacted

• J. Cooper, Manager, Emergency Preparedness

• B. Hugo, Compliance Engineer

• Janouski, Emergency Planning Specialist

• J. Thale, Emergency Planning Engineer

• T. Walt, General Manager, Technical Functions

• Denotes participation in the December 15, 1992, telephonic exit intervie '- Operational Status of the Emergency Preparedness Program (Inspection Procedure 82701) Background This in-office inspection was conducted to review Revision 7 to emergency plan implementing procedure (EPIP) EP-001, " Emergency Classification," which was submitted on July 13, 1992, in accordance with 10 CFR 50, Appendix E, Paragraph The licensee implemented EP-001, Revision 7, without prior approval, under the provisions _ of 10 CFR 50.54(q). This review was conducted to address 10 CFR 50, Appendix E, Paragraph IV.B, which specifically requires that

- emergency action levels (EAls) be agreed on by State and . local

. governmental authorities and approved by the NRC. Regional-emergency preparedness ~ staff evaluated the changes to the procedure text and EAls to determine whether the changes decreased the effectiveness of the Trojan Emergency Plan and whether the changes continued to meet the standards in 50.47(b) and the requirements of 10 CFR 50, Appendix Evaluation in reviewing EP-001, Revision 7, the inspector found that most of the changes were editorial / cosmetic in nature. These changes did not affect the intent or implementation of the procedure. Examples of cosmetic changes included modifications to the procedure text to conform to the new format established for~ Trojan Plant Procedures, minor wording changes to provide clarification or to correct minor internal inconsistencies,. and modifications required to formally-incorporate temporary change notices (TCNs).

The inspector contacted the emergency preparedness manager (EPM), on November 20, December 4, and December 9,1992, to obtain additional information/ clarification on several of the changes. The EPM was able to satisfactorily explain all of the changes with the exception of the following two:

(1) Section 5.3.5 - the instructions in 5.3.5(a) were not consistent with NUREG-0654, Evaluation Criterion Evaluation Criterion E.3 states that initial emergency messages

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from the plant shall include information about whether there is a release in progress. This step of the procedure identified the minimum item numbers to be completed on the classification notification form. The form item number for release information/ status (number 7) was not include Response - the EPM agreed that the procedure step did not appear to be consistent with the NUREG-0654 guidance. The EPM stated that the procedures used by security to complete the notification process did require that release status be included in initial notifications. The EPM stated that this part of EP-001 would be corrected in a future TCH or revisio (2) Module 2, Step 6, Substep 6.2a - the units on area radiation monitors (ARMS) ARM-15A and B were changed from mrem / hour to R/ hour. As a result, the EAL, which was one of the-combinations for loss of two fission product barriers with a potential for loss of the third (a general emergency), was changed from ARM 15A, B readings greater than 2000 mrem / hour and loss, or potential loss, of containment, to ARM 15A, B readings greater than 2000 R/ hour and loss, or potential loss, of containment. This change resulted in an ARM reading that appeared to be too high (non-conservative) and prompted the inspectar to obtain a technical justification from the license '

Response - the EPM stated that it was their intent to correct the error on the units (i.e., 2000 mrem / hour (2 R/ hour) was too low for the monitor readings), not to introduce a non-conservative change. The EPM could not produce a technical justification for the use of the 2000 R/ hour number. On December 9,1992, the EPH stated that the number would be reduced by about a factor of 10 (100 R/ hour - 200 R/ hour). The EPM stated that the ARM readings would be corrected in a future TCH or revisio As part of this review, the inspector verified that EP-001, Revision 7, had been submitted to the States and Counties for r eiew and that the licensee had received responses and/or comments from all of the offsite agencies. As of December 15, 1992, the licensee had responded to all of the offsite agency comments pertaining to EP-00 . Exit Intervie_w An exit interview, via telephone conference call, was held on December 15, 1992, to discuss the preliminary findings of the in-office inspection. Section 1 ot~this report identifies the licensee personnel who participated in the conference call. The licensee was informed that the change in the ARM readings appeared to decrease the effectiveness of the emergency plan, but that overall, EP-001, Revision 7, continued to meet the standards in 50.47(b) and the requirements of 10 CFR 50, t  ;

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-3 Appendix During the exit interview, the licensee comitted to revise O

J- "'-001, by January 27, 1993, to address both of the issues identified in JL' Jion 2 of this report. This schedule was considered acceptabl a *

ltion of the procedure revisinn will be reviewed in a future 5I  : ion (50-344/9228-01).

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